HomeMy WebLinkAbout7193_CCv0001.pdf RESOLUTION NO. 7193
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF REDLANIDS CERTIFYING THE
FINAL ENVIRONMENTAL IMPACT REPORT AND ADOPTING A STATEMENT OF
ENVIRONMENTAL EFFECTS,MITIGATION MEASURES,FINDINGS,AND OVERRIDING
CONSIDERATIONS,AND A MITIGATION MONITORING PROGRAM,FOR THE PROPOSED
FINAL ENVIRONMENTAL IMPACT REPORT FOR CONDITIONAL USE PERMIT NO.945 AND
MINOR SUBDIVISION NO.330(TENATIVE PARCEL MAP NO. 19060);
(ALSO KNOWN AS THE REDLANDS CROSSING PROJECT)
WHEREAS,Walmart Stores, Inc. proposes to develop the Redlands Crossing Center project
which is a regional shopping center consisting of approximately 275,500 square feet of commercial uses
on approximately 32.9 acres, and for which applications for Conditional Use Permit No. 945 and
Tentative Parcel Map No. 19060 have been filed with the City of Redlands; and
WHEREAS,pursuant to the California Environmental Quality Act,the City of Redlands
prepared an Environmental Impact Report in connection with the City's Condition of the application for
Conditional Use Permit No. 945 and Tentative Parcel Map No. 19060; and
WHEREAS,the Planning Commission held a duly noticed public hearing on April 24, 2012, and
adopted motions recommending to the City Council of the City of Redland (the"City Council")
approval of the Environmental Impact Report and the applications for Conditional Use Permit No. 945
and Tentative Parcel Map No. 19060; and
WHEREAS,on July 18, 2012, the City Council held a duly noticed public hearing on the
applications for Conditional Use Permit No. 945 and Tentative Parcel Map No. 19060 at which time the
City Council heard verbal and written testimony presented by City staff and members of the public
regarding the application for Conditional Use Permit No. 945 and Tentative Parcel Map No. 19060 and
the associated Environmental Impact Report for those applications;
NOW,THEREFORE,BE IT RESOLVED by the City Council of the City of Redlands as
follows:
Section 1. The City Council of the City of Redlands hereby certifies the final Environmental Impact
Report and adopts the following statement of environmental effects,mitigation measures, findings, and
overriding considerations, and a mitigation monitoring program, for the proposed Final Environmental
Impact Report("Final EIR") for Conditional Use Permit No. 945 and Tentative Parcel Map No. 19060
(Minor Subdivision No. 330); also known as the Redlands Crossing Project:
I. INTRODUCTION
The City of Redlands(the"City"), in approving Conditional Use Permit No. 945 and Tentative Parcel
Map No. 19060(Minor Subdivision No. 330) for the Redlands Crossing Project(the"Project"), which
requires approval of a number of discretionary approvals as discussed within the Project Summary of the
Final EIR,makes the Findings described below and adopts the Statement of Overriding Considerations
presented at the end of the Findings. The Final EIR was prepared by the City acting as lead agency
pursuant to the California Environmental Quality Act("CEQA"). Hereafter, the Notice of Preparation,
Notice of Availability,Notice of Completion, the Draft Environmental Impact Report("Draft EIR")
(circulated from November 21, 2011 through January 18, 2012), Technical Studies attached as
Appendices to the Draft EIR, the Final EIR, containing Responses to Comments and textual revisions to
the Draft EIR, and the Mitigation Monitoring and Reporting Program will be referred to collectively
L•\cclerk\Resolations\Res 7100-720}17193 Resolution.Certifying EIR(2).doe
City of Redlands-Redlands Crossing Project
Facts,Findings,and Statement of Overriding Considerations
Related to the Final Environmental Impact Report
herein as the"EIR." These Findings are based on the entire record before the City,including the EIR.
The City adopts the facts and analyses in the EIR, which are summarized below for convenience. The
omission of some detail or aspect of the EIR does not mean that the same has been rejected by the City.
11. PROJECT SUMMARY
A. Project Description
1. Site Location and Existing Conditions
The Project is located south of San Bernardino Avenue, and east of the State Route(SR)210 Freeway in
the City of Redlands. Specifically, the Project site is located at the southeast intersection of the
Tennessee Street and San Bernardino Avenue. References to pages of the Draft EIR in this Resolution
are hereafter identified as"DEIR p_." (DEIR p. 2-1.)
The Project site is primarily vacant land previously tended as an orchard and consists of fallow
agricultural land. The Phase I Environmental Site Assessment(see Appendix F of the Draft EIR),
indicated that the Project site contained an orchard from the 1930s until the early 2000s. Three
residences occupied the site from the 1930s until the 1990s. Two of the residences were removed in the
early 1990s, while the remaining residence was removed in 2002. (DEIR p. 2-1.)
Tennessee Street, an existing two-lane road forms the western boundary of the Project site. West of
Tennessee Street is SR-210. The Citrus Plaza shopping center is located across SR-210 Freeway, west
of the Project. (DEIR p. 2-1.) San Bernardino Avenue, an existing two-lane road, serves as the northern
boundary of the Project site. North of San Bernardino Avenue is the extension of Tennessee Avenue,
consisting of orchards and fallow lands. (DEIR p. 2-2.)
The Project site will be bounded on the East by the future extension of New York Avenue. East of the
future extension of New York Avenue and west of Karon Street is a vacant and undeveloped area under
common ownership with the Project site that will include limited offsite improvements that will be
provided to support development of the Project(see discussion below under Subsection 2.2.1 of the
Draft EIR). (DEIR p. 2-2.) A landscape buffer will be located on the west side of Karon Street, which
is part of the off-site improvements as proposed by the Project. This landscape buffer is a requirement
of the East Valley Corridor Specific Plan and Concept Plan No. 4 (CP4), in order to buffer the Project
from the residences on the east side of Karon Street. East of Karon Avenue is an existing single-family
residential subdivision. (Ibid.)
The future extension of Pennsylvania Avenue is planned for a two-lane roadway,which will be located
on the southern boundary of the Project site. South of the future extension is fallow agricultural land.
(DEIR p. 2-2.)
The Project site is designated Commercial (C)per the City of Redlands General Plan Land Use Map
(November 2010). This commercial designation allows for a variety of commercial activities ranging
from shopping centers to business parks. The Project site is also within the boundaries of the East
Valley Corridor Specific Plan, and Cities Pavilion Concept Plan. The Cities Pavilion Concept Plan
functions as a development suitability analysis and land use plan, which identifies development
opportunities and constraints, including physical characteristics, public services and facilities, capacity
of the circulation system, and existing or planned uses for adjacent properties. The intent of the Concept
Plan is to establish limits,parameters, and planning objectives to guide development based on the
identified development constraints and opportunities. According to the City of Redlands Zoning Map
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(November 2010),the Project site is zoned as East Valley Corridor Specific Plan and Concept Plan No.
4 (CP4). Allowable uses within CP4 Zoning use include General Commercial District(GC) and
Administrative Professional (AP). (DEIR p. 2-2.)
2. Project Description
The Project proposes to develop a regional shopping center that consists of approximately 275,500
square feet of commercial retail uses on approximately 32.9 acres. The Project includes 215,000 square
feet for the proposed Redlands Crossing Walmart(Parcel 10) and 60,500 square feet(Parcels I to 9)
consisting of three(3) fast food with drive-thru spaces, three(3)retail spaces, a fast food without drive-
thru and retail, a retail with drive-thru space and a restaurant. In addition, Lot A of the Project will
consist of an approximately 0.52 acre surface level infiltration basin. Further, approximately 1,349
parking spaces will be provided for the 275,500 square feet of commercial retail space. (DEIR p. 2-9.)
The proposed Redlands Crossing Walmart would consist of an approximate area of 215,000 square feet.
The Redlands Crossing Walmart is proposed for build-out at the northwest comer of the extension of
New York Avenue and Pennsylvania Avenue in Redlands. Access to the Redlands Crossing Center and
the Walmart store will be located off San Bernardino Avenue, Tennessee Street,New York Street, and
Pennsylvania Avenue. The Redlands Crossing Walmart will offer groceries and general retail
merchandise including,but not limited to, alcohol for off-site consumption,pool chemicals,petroleum
products, pesticides, and paint products. The Redlands Crossing Walmart will operate 24 hours per day
seven days a week. The Redlands Crossing Walmart may have outdoor seasonal sales and storage. In
addition, a garden center with an exterior customer pick-up facility for pre-paid bagged, garden supplies,
such as potting soil,mulch, and manure is included. The garden center will operate 24 hours per day.
The exterior pick-up facility will have an attendant to assist customer loading. The exterior pick-up
facility will not accommodate direct sales. The exterior pick-up facility will operate the same hours as
the Redlands Crossing Walmart and garden center. (DEIR p. 2-9.)
The Redlands Crossing Walmart will also include a Tire & Lube Express, which will provide routine
servicing and preventive maintenance of vehicles. (DEIR p. 2-9.) The tire and lube facility will have
limited hours of operation(Monday through Sunday 8:00 a.m. to 10:00 p.m.). (DEIR pp. 2-9 to 2-10.)
In addition, the Redlands Crossing Walmart will also include a pharmacy and possibly a vision, hearing
and medical care center, food service, a photo studio and photo finishing center, a banking center and an
arcade, and other similar services inside the store. (DEIR p. 2-10.) The store building will include,
without limitation,truck doors, trash compactors,recycling area, and loading facilities. Table 2-1 of the
Draft EIR summarizes the approximate Redlands Crossing Walmart square footage. (Ibid.)
Implementation of the Project will also increase the amount of impervious surfaces on-site, which could
affect groundwater recharge due to the loss of soil infiltration. To facilitate groundwater recharge, the
permeable areas on-site have been maximized through site design considerations, including vegetated
swales, a nutrient separating baffle box and inlet inserts before discharging into one of five infiltration
basins. The design feature allows the majority of drainage from impervious surface to flow to
permeable areas for on-site infiltration. One surface level infiltration basin and four underground
infiltration basins have been incorporated into the site plan to maximize on-site infiltration. (DEIR p. 2-
10.)
Parcels I to 9 will consist of approximately 60,500 square feet of building area, and will be located west
and north of the Redlands Crossing Walmart along Tennessee Street and San Bernardino Avenue.
(DEIR p. 2-13.) These Parcels will be entitled for various commercial/retail uses including three drive-
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Facts,Findings,and Statement of Overriding Considerations
Related to the Final Environmental Impact Report
thru fast-food facilities and one retail facility with a drive-thru lane. Implementation of the Project will
also incorporate, as previously described, one surface level infiltration basin and four(4)underground
infiltration basins. (Ibid.)
Parcel 1 will be entitled for retail and a gas station,which will be located at the southwest comer of the
Project site,near the intersection of Tennessee Street and Pennsylvania Avenue. The gas station will
include six pumps(12 dispensers), 3,000 square feet of retail uses with a drive-thru component, and a
self-service car wash. Parcels I to 9 will be graded and constructed at the same time the Redlands
Crossing Walmart is graded and constructed(See Table 2-2: Site Summary of the Draft EIR).
Generally,the color scheme,landscaping, etc. of Parcels I to 9 will be of similar design as the Redlands
Crossing Walmart design(i.e. California contemporary retail). See discussionunder Design and
Appearance,below,for additional information in this regard. In addition, Lot A of the Project will
consist of an approximately 0.52 acre surface level infiltration basin. See Table 2-2 of the Draft EIR for
a site summary of proposed uses within the Project site. (DEIR p. 2-13.)
Parcel I I (totaling 9.16 acres),is located between the extension of New York Street and Karon Avenue.
(DEIR p. 2-14.) Activities in Parcel 11 will consist of off-site mass-grading and infrastructure
improvements provided to support development of the Project site. Off-site improvements within this
area include storm drain facility improvements related to the construction of New York Street, a block
wall immediately to the West of Karon Street and mass-grading to"match"grade elevations between
Karon Street and future New York Street. (Ibid.) In addition, a landscape buffer will be located on the
west side of Karon Street,which is part of the off-site improvements as proposed by the Project. (DEIR
pp. 2-14 to 2-15.) This landscape buffer is a requirement of the East Valley Corridor Specific Plan and
Concept Plan No. 4(CP4),in order to buffer the Project from the residences on the east side of Karon
Street. (DEIR p. 2-15.) Development of Parcel 11,beyond the activities described above,is not part of
this Project, and is outside of the scope of this EIR. (Ibid.)
There is an existing operational 126,000 square-foot Walmart discount store(Store No. 1693)located at
2050 West Redlands Boulevard, approximately 1.25 miles southwest of the Project site,which, like the
proposed store,includes a grocery component. Although likely to close once the new store opens since
both stores service similar geographic areas,the timing of the closure of the existing Walmart store is
unknown. Although Walmart is seeking to re-tenant the store once it vacates,the timing of the
establishment of a new to is also unknown. Therefore,upon development of the Project, the
existing Walmart could be either vacant(due to no replacement tenants)or could be re-tenanted upon
Opening Year 2013. Consequently,the Draft EIR analyzed potential"worst-case!'impacts with respect
to the existing Walmart store. For example, analysis of Air Quality, Greenhouse Gases,Noise, and
Traffic will assume the existing Walmart to be re-tenanted upon Opening Year 2013. In this case,
impacts will he worst-me in that both stores will be occupied and will emit greater air and greenhouse
gas emissions and increasednoise and traffic levels. In contrast,the analysis of Urban Decay estimates
the scenario that the existing Walmart site will be vacant upon Opening Year 2013. In this case, impacts
would be worst-case in that the existing store could potentially be closed long-term and potentially
create urban decay for the surrounding area. (DEIR p. 2-15.)
3. Actions Covered by the EIR
The EIR supports the following discretionary approvals:
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Facts,Findings,and Statement of Overriding Considerations
Related to the Final Environmental Impact Report
• Conditional Use Permit(CUP)of the Development Plan for the entire Project,including the
Redlands Crossing Walmart Mire and lube facility, drive-thru garden center, and arcade)
(Parcel 10)
• Individual CUP for future development of the following Parcels:
Convenience store with drive-thru, gas station, alcohol sales, and car wash(Parcel 1);
Three fast-food restaurants with drive-tbu(Parcels 2, 8, and 9), and
One retail with drive-thr (Parcel ).
• Planning Commission Review and Approval (CRA) for fixture development of the following
Panels:
Retail with no drive-thru(Parcels 3, 4, 5, and 7);
• Tentative and Final Parcel Map;
• Sign Plan Approval of a uniform sign program for the entire Project;
• Building and Gr g Permits,
• Encroachment Permits(Sewer,Water, etc), and
• State Water Resources Control Board(SWRCB)Order No. 99-08-D Q National Pollutant
Discharge Elimination System( P1 E )General Permit No.CAS000002 waste Discharge`
Requirements ) for Discharges of Storm Water Runoff Associated with Construction
Activity.
(DEIR pp. 2- 6 through 2-27.)
B. Project Goals and Objectives
The Project goals and objectives include the fallowing:
1. Maximize retail commercial property and sales tax revenues that would be accrued to the various
agencies within the City of Redlands from the development of the Project site.
2. Facilitate customer convenience by providing a full range of goods and services(including
grocery,gardening,dry goods,automotive, and other uses)within a single stare.
3. Develop the Profit site with a high-quality mix of retail, grocery,restaurant,and commercial
uses that will complement each other and encourage one stop shopping thereby reducing vehicle
miles traveled and vehicle trips in the community;
4. Provide convenient and affordable shopping opportunities to the residents of the City of
Redlands and surrounding areas for a wide range of retail goods and services,including the
provision of such goods and services on a 24-hour basis.
. Provide the Redlands Crossing Center with a nationally recognized general-merchandise anchor
to attract consumers and other businesses to the Project.
6. Provide an additional grocery outlet in the North Redlands Community to minimize travel, as
well as provide convenient shopping opportunities for City residents.
7. Develop a new major retail and commercial center along Major Arterial streets and in close
proximity to the 210 Freeway/San Bernardino Avenue Interchange in order to facilitate regional
public access and promote the Project as a regional shopping destination.
8. Develop the vacant unused:parcels comprising the Project site for retail-commercial uses in a
manner that fully utilizes their development potential.
(DEIR p. -26.)
111. ENVIRONMENTAL REVIEW AND PUBLIC PARTICIPATION
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Facts,Findings,and Statement of Overriding Considerations
Related to the Final Environmental Impact Report
The City conducted an extensive review of this Project that included a Draft EIR and a Final EIR,
including technical reports, along with a public review and comment period. The City initially issues a
Notice of Preparation(NOP) on August 20, 2007. However, after transmittal the project as proposed at
that time was revised. Therefore, a revised NOP was issues on February 27, 2009. The City circulated
the NOP to responsible and trustee state agencies, local organizations, and interested individuals to
identify any issues to be addressed in the EIR. The 30-day circulation and review period for the NOP
concluded on March 31, 2009. Additionally,the City held a scoping meeting on March 16, 2009.
Copies of the letters to the revised NOP were included in Appendix A of the Draft EIR. An Initial Study
was not completed for this Project and instead all potential environmental impacts were discussed within
the Draft EIR.
The Draft EIR was circulated for public review from November 21, 2011 through January 18, 2012.
The Draft EIR and technical appendices were made available for public review during normal business
hours both at the City of Redlands Development Services Department, Planning Division, located at 210
East Citrus Avenue and the A. K. Smiley Public Library at 125 W. Vine Street in the City of Redlands,
California. The Draft EIR received a number of comments, responses of which were provided in writing
and incorporated within the Final EIR as Responses to Comments and textual revisions to the Draft EIR.
The EIR was considered by the City of Redlands Planning Commission on March 27,2012.
IV. GENERAL FINDING ON MITIGATION MEASURES
In preparing the Conditions of Approval for this Project, City staff incorporated the mitigation measures
recommended in the EIR as applicable to the Project. In the event that the Conditions of Approval do
not use the exact wording of the mitigation measures recommended in the EIR,in each such instance,
the adopted Conditions of Approval are intended to be identical or substantially similar to the
recommended mitigation measures. Any minor revisions are to improve clarity or to better define the
intended purpose of the mitigation and are not designed to substantively alter the purpose of such
mitigation.
Finding: Unless specifically stated to the contrary in these Findings, it is the City's intent to adopt all
mitigation measures recommended by the EIR which are applicable to the Project. If a measure has,
through error,been omitted from the Conditions of Approval or from these Findings, and that measure is
not specifically reflected in these Findings,that measure shall be deemed to be adopted pursuant to this
paragraph. In addition,unless specifically stated to the contrary in these Findings, all Conditions of
Approval repeating or rewording mitigation measures recommended in the EIR are intended to be
substantially similar to the mitigation measures recommended in the EIR and are found to be equally
effective in avoiding or lessening the identified environmental impact. In each instance,the Conditions
of Approval contain the final wording for the mitigation measures.
V. ENVIRONMENTAL IMPACTS AND FINDINGS
City staff reports,the EIR, written and oral testimony at public meetings or hearings,these facts,
findings and statement of overriding considerations, and other information in the administrative record,
serve as the basis for the City's environmental determination.
The detailed analysis of potentially significant environmental impacts and proposed mitigation measures
for the Project is presented in the Draft and Final EIR, as well as the responses to comments from the
public and from other government agencies on the Draft EIR which are provided in the Final EIR.
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Facts,Findings,and Statement of Overriding Considerations
Related to the Final Environmental Impact Report
The EIR evaluated eighteen major environmental categories for potential impacts including: Aesthetics;
Agricultural Resources; Air Quality; Biological Resources; Cultural Resources; Geology and Soils;
Hazards and Hazardous Materials; Hydrology and Water Quality; Land Use and Planning; Mineral
Resources; Noise; Population, Housing, and SLAG Consistency; Public Services; Recreation;
Transportation; Utilities and Service Systems; Greenhouse Gases; and Urban Decay. Both Project-
specific and cumulative impacts were evaluated. Of these environmental categories,the City concurs
with the conclusions in the EIR that the issues and sub-issues discussed in subsections A, B, and D
below are either less than significant without mitigation or can be mitigated below a level of
significance. For the remaining potential environmental impacts that cannot feasibly be mitigated below
a level of significance discussed in subsection C, the City must evaluate the overriding considerations
and Project benefits and balance them against the significant impacts of the proposed Project.
A. Impacts Identified As Less Than Significant Requiring No Mitigation
The following issues were found in the EIR as having no potential to cause significant impacts and
therefore require no Project-specific mitigation. In the following presentation, each resource issue is
identified and the potential for significant adverse environmental effects is discussed.
As stated previously, the following issues were found in the FIR as having no potential to cause
significant impacts and therefore require no Project-specific mitigation. In the following presentation,
each resource issue is identified and the potential for significant adverse environmental effects is
discussed.
1. Aesthetics
Impact AES-1: Would the proposed Project have a substantial adverse effect on a scenic vista?
Finding: Potential impacts of the Project on Aesthetics are discussed in detail in Section 3.1 of the Draft
EIR. Based on the entire record before it, the City finds that the Project will have a less than significant
impact related to an adverse effect on a scenic vista, and no mitigation is required. (DEIR pp. 3.1-21 to
3.1-22.)
Facts in Support of the Finding: According to the City of Redlands General Plan,there are no
designated scenic vistas on or adjacent to the Project site. During the construction phase,various
equipment, vehicles,building materials, stockpiles, disposal receptacles, and related activities could be
potentially visible from several different vantage points near the Project site. Once, completed, all
equipment, vehicles,building materials, stockpiles, disposal receptacles, and all other general
construction activities will cease, along with any construction-related impacts. (DEIR p. 3.1-21.)
The Redlands Crossing Center includes a 215,000 square foot proposed Redlands Crossing Walmart
approximately 23 feet in height with architectural roof projections approximately 50 feet in height from
the proposed pad elevation and 60,500 square feet for three(3)fast food with drive-thru spaces, three(3)
retail spaces, a fast food without drive-thru and retail, a retail with drive-thru space and a restaurant. In
addition, the Project proposes to develop a decorative masonry wall located adjacent to Karon Street,
from Pennsylvania Avenue to Elise Drive. (DEIR p. 3.1-21.)
The residences most likely affected by the Project are located directly east of the Project site, near Karon
Street. Their view of the San Bernardino Mountains(if any)would be oriented to the north, across the
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Facts,Findings,and Statement of Overriding Considerations
Related to the Final Environmental Impact Report
Project site. However, the Project will be developed below the Karon Street grade. Consequently,
views of the Project site will only be of the upper portion of the Walmart structure, and will be shielded
by landscaping. The Project would maintain the block wall and the landscaping. (DEIR p. 3.1-21.)
Additionally, according to Section EV4.0225, of the EVCSP (Compatibility Standards),developments
adjacent to residential uses are subject to conditions. Where a development abuts a residential district,
an orderly transition of uses and building types should be established consistent with Section EV4.0225
and other applicable policies. Permitted uses at Parcel I I consist of Administrative Professional.
Except for limited off-site improvements on Parcel 11 necessary to support development of the Project
site, this Project does not involve development of Parcel 11. Any future development within Parcel I I
will be required to be consistent with the EVCSP Compatibility Standards for Administrative
Professional (AP)Zone. (DEIR pp. 3.1-21 to 3.1-22.)
In addition, as outlined within EVCSP Compatibility Standards, smaller buildings shall be located near
residential uses with larger buildings further away. These potential future office buildings will serve as
a transition from the less intensive existing residential uses to the east and southeast to the more
intensive Walmart. In addition, a landscape buffer will be located on the west side of Karon Street,
which is part of the off-site improvements as proposed by the Project. This landscape buffer is a
requirement of the East Valley Corridor Specific Plan and Concept Plan No. 4(CP4), in order to buffer
the Project from the residences on the east side of Karon Street(see EVCSP CP4 for additional
information in this regard). Further, landscaping along the Pennsylvania Avenue extension and parking
will also serve as a transition area between future commercial land uses and the proposed Walmart.
Thus, the proposed land uses and site plan design for the Project will comply with Section EV4.0225
and other applicable policies and will have a less than significant impact to views of the San Bernardino
Mountains and other scenic views within the Project area. (DEIR p. 3.1-22.)
As supported by the preceding discussion, the potential for the Project to result in a substantial adverse
effect on a scenic vista or cause any short or long-term visual impacts is less than significant and no
mitigation is required. (DEIR p. 3.1-22.)
Impact AES-2: Would the proposed Project substantially damage scenic resources,including,but not
limited to, trees,rock outcroppings, and historic building within a state scenic highway?
Finding: Potential impacts of the Project on Aesthetics are discussed in detail in Section 3.1 of the Draft
EIR. Based on the entire record before it, the City finds no significant impact related to the damage of
scenic resources,including,but not limited to, trees, rock outcroppings, and historic building within a
state scenic highway. No mitigation is required. (DEIR pp. 3.1-22 to 3.1-23.)
Facts in Support of the Finding: Refer to the discussion under Impact AES-I and AES-3 for additional
details regarding short and long-term visual impacts. There are no significant scenic resources known to
exist in the immediate vicinity of the Project site. Designated Scenic roadways within the City's
General Plan are south of the I-10 Freeway and are not within the vicinity of the Project. The site is
located directly adjacent to the SR-210 Freeway and approximately 0.55 mile north of the I-10 Freeway.
Both Freeways are designated as eligible State Scenic Highways; however, their designation is not
officially designated as a State Scenic Highway. Therefore, the Project will have a less than significant
impact on scenic resources,including,but not limited to, trees, rock outcroppings,and historic building
within a State Scenic Highway and no mitigation is required. (DEIR pp. 3.1-22 to 3.1-23.)
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Impact AES-3: Would the proposed Project substantially degrade the existing visual character or
quality of the site and its surroundings?
Finding: Potential impacts of the Project on Aesthetics are discussed in detail in Section 3.1 of the Draft
EIR. Based on the entire record before it, the City finds the Project will have a less than significant
impact related to the potential for the proposed Project to substantially degrade the existing visual
character or quality of the site and its surroundings. (DEIR pp. 3.1-23 to 3.1-25.)
Facts in Support of the Finding: See the previous discussion under Impact AES-1 regarding short-
term construction activities. As discussed, during the construction phase various equipment, vehicles,
building materials, stockpiles, disposal receptacles, and related activities could be potentially visible
from several different vantage points near the Project site. However, construction-related activities will
be short-term and are expected to last approximately twelve (12)months. Once, completed, all
equipment, vehicles,building materials, stockpiles, disposal receptacles, and all other general
construction activities will cease, along with any construction-related impacts. Therefore, due to the
temporary nature of construction-related activities,potential impacts the visual character of the Project
site would be less than significant. (DEIR p. 3.1-23.)
Development of the Project would convert predominantly urban vacant land to commercial, retail and
restaurant uses, substantially changing the aesthetic nature of the Project site. However,much of the site
is disked on a regular basis and in a blighted condition from illegal dumping activities, and thus would
not be considered scenic in nature. Therefore,the architectural features and landscaping designed for
the Project are intended to provide a visually appealing commercial retail development that attracts
potential customers. As such, it would be expected to enhance the aesthetics of the Project site. (DEIR
p. 3.1-23.)
Specifically, the Walmart store and surrounding outparcel design is characterized as"California
contemporary retail." Landscaping will be incorporated into the overall design that will comply with the
standards set forth in the EVCSP. The architectural features and landscaping design are intended to
provide a visually appealing commercial retail development that would attract potential customers.
Thus, the Project will produce a mixture of urban delights within the City. (DEIR pp. 3.1-23 to 3.1-24.)
Additionally, development of the proposed Redlands Crossing Center will be of similar land uses,height
and scale as the local commercial and retail centers located in close proximity to SR-210 and the Project
site(i.e. Citrus Plaza and Home Depot Center). Less intensive uses(i.e., office) are designated within
the 9.16 acres directly east of the Project site. According to Section EV4.0225 of the EVCSP
(Compatibility Standards),permitted uses at Parcel 11 consist of Administrative Professional. Any
future office buildings on the Parcel 11 are speculative at this time and are not part of the Project.
However, future development within Parcel I I will be required to be consistent with the EVCSP
Compatibility Standards for Administrative Professional (AP)Zone. Given the presence of the existing
commercial and retail centers, and the strategic placement of buildings on the Project site,the Project
would not constitute a substantial change in the visual character of the Project area. (DEIR p. 3.1-24.)
The Project also proposes to construct curbs and gutters with street lighting around the site.
Construction of curbs and gutters will be consistent with the surrounding commercial uses and the
policies found in the City's General Plan. According to the EVCSP Section EV3.0720 Development
Standards, the Project abuts a Special Landscape Street(San Bernardino Avenue). The Project has been
designed in conformance with setback and landscape requirements as outlined in Section EV4.0115 (a).
Therefore, the Project will not result in a significant impact in this regard. (DEIR p. 3.1-24.)
9
City of Redlands-Redlands Crossing Project
Facts,Findings,and Statement of Overriding Considerations
Related to the Final Environmental Impact Report
The surrounding land uses of most concern from a visual character perspective are the existing
residential uses to the east and southeast, the residentially zoned property to the south, and the SR-210
Freeway. (DEIR p. 3.1-24.)
The existing single-family residential uses are located directly east of the Project site along Karon Street
north of Pennsylvania Ave. These units are slightly elevated and a mound exists between the residential
uses and the eastern portion of the Project site, which partially blocks views of the proposed site area.
Implementation of the Project will provide adequate setbacks from nearby residential units. This
includes an approximate 510-foot distance from the existing residential properties along Karon Street
and an approximate 230-foot distance from commercially zoned property south of the Pennsylvania
Avenue extension. A landscape buffer will also be located on the west side of Karon Street, which is
part of the off-site improvements as proposed by the Project. This landscape buffer is a requirement of
the East Valley Corridor Specific Plan and Concept Plan No. 4 (CP4), in order to buffer the Project from
the residences on the east side of Karon Street. In addition, the Project would include a continuous
visual screen of a maximum height of six (6) feet decorative masonry wall (per Section EV4.0225 of the
EVCSP) and landscaping along the eastern portion of the property boundary,between Pennsylvania
Avenue and Elise Drive. The Project would maintain the block wall and the landscaping. Views of the
Project site may be partially obstructed by the decorative wall to most of the residences to the east.
Accordingly, the visual character of the residential uses would be degraded by the Project. However,
according to Section EV4.0225 of the EVCSP, developments adjacent to residential uses are subject to
compatibility standards. Where a development abuts a residential district, an orderly transition of uses
and building types should be established in consistency with Section EV4.0225 and other applicable
policies. As previously mentioned,permitted uses at Parcel 11 consist of Administrative Professional.
Any future office buildings on the Parcel 11 are speculative at this time and are not part of the Project.
However, any future development within Parcel 11 will be required to be consistent with the EVCSP
Compatibility Standards for Administrative Professional (AP) Zone.. Landscaping along the
Pennsylvania Avenue extension and parking will also serve as a transition between commercially zoned
property and the Walmart. Thus, the Project's proposed land uses will comply with Section EV4.0225
and other applicable policies and will have a less than significant impact to visual character in this
regard. (DEIR pp. 3.1-24 to 3.1-25.)
The segment of the SR-210 Freeway overlooking the Project site is positioned approximately 165 feet
west of the Project site. The SR-210 Freeway is located on a raised embankment. Views looking down
on the Project site are relatively obstructed and consist of disturbed vacant land or views of vegetation
and fallow trees. Given the presence of the existing commercial and retail centers, the Project would not
be considered a substantial change in the visual character of the Project site. Moreover,the architectural
features and landscaping designed for the Project are intended to provide a visually appealing
commercial retail development that attracts potential customers. As such, it would be expected to
enhance the aesthetics of the Project site. For these reasons, the Project would not substantially degrade
the visual character of the site. (DEIR p. 3.1-25.)
Other surrounding land uses either have no views or are primarily vacant. Moreover,most of these land
uses are located more than 125 feet away from the Project site. Therefore, the Project would not have
the potential to degrade the visual character of these land uses. (DEIR p. 3.1-25.)
10
City of Redlands-Redlands Crossing Project
Facts,Findings,and Statement of Overriding Considerations
Related to the Final Environmental Impact Report
2. Agricultural Resources
Impact AG-1: Would the proposed Project convert Prime Farmland, Unique Farmland,or Farmland of
Statewide Importance(Farmland), as shown on the maps prepared pursuant to the Farmland Mapping
and Monitoring Program of the California Resources Agency, to non-agricultural use?
Finding: Potential impacts of the Project on Agricultural Resources are discussed in detail in Section
3.2 of the Draft EIR. Based on the entire record before it,the City finds the Project will have a less than
significant impact related to the potential for the proposed Project to convert Farmland, as shown on the
maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources
Agency, to non-agricultural use. (DEIR pp. 3.2-9 to 3.2-10.)
Facts in Support of the Finding: Historically, the Project site has been utilized primarily for
agricultural purposes as an orchard from approximately 1938 until approximately 2002 (KA 2006).
Three single-family residential structures occupied the northeast comers of Parcels 01 and 02 and the
northern boundary of Parcel 04 from at least 1938 until the demolition of the dwellings on Parcels 01
and 04 in the early 1990s. Currently, the Project site is primarily vacant, occupied by a fallow orchard
on Parcel 02 located in the west-central portion of the Project site. Since the 1970s,the general vicinity
of the Project site has been increasingly developed with residential and commercial uses. (DEIR pp.
3.2-9 to 3.2-10.)
According to the City of Redlands General Plan, the Project site is not located in an agricultural preserve
or currently used for agricultural production. However, according to the State's FMMP, the Project site
is classified as having approximately 9.70 acres of prime farmland, 0.15 acre of farmland of statewide
importance, 35.68 acres of grazing land, and 0.10 acre of urban built-up land. However,the FMMP
requires that the land be irrigated and used for agricultural production within the past four(4) years to be
considered prime farmland and farmland of statewide importance. The Project site has not been
irrigated or in agricultural production for over nine(9) years. Consequently, the Project does not fall
within prime farmland or farmland of statewide importance as per FMMP requirements. (DEIR p. 3.2-
10.)
In addition, the Project site is zoned as CP-4 (Concept Plan-4)per the EVCSP and has a Land Use
Designation of Commercial, which is consistent with the Projects proposed uses. Consequently, the
Project site has been planned for urban development as part of the EVCSP. Furthermore,the City of
Redlands retains substantial areas of agricultural lands within the City. Specifically, substantial
agricultural preserves exist in the City's Canyon areas; concentrated areas of agricultural lands remain in
the northern areas of the City; and the City maintains broad areas for Citrus production throughout the
City. This is further confirmed by the City's General Plan, which demonstrates that many agricultural
lands remain within the City(see Redlands Planning Area MEA Figure 5.2, Agricultural Lands).
Implementation of the Project will therefore have a less than significant impact to the conversion of
prime farmland, unique farmland, or farmland of statewide importance. (DEIR p. 3.2-10.)
Impact AG-2: Would the proposed Project conflict with existing zoning for agricultural use, or a
Williamson Act contract?
Finding: Potential impacts of the Project on Agricultural Resources are discussed in detail in Section
3.2 of the Draft EIR. Based on the entire record before it, the City finds the Project's will have a less
than significant impact related to the potential for the proposed Project to conflict with existing zoning
for agricultural use,or a Williamson Act contract. (DEIR pp. 3.2-10 to 3.2-11.)
II
City of Redlands-Redlands Crossing Project
Facts,Findings,and Statement of Overriding Considerations
Related to the Final Environmental Impact Report
Facts in Support of the Finding: The Project site's underlying zoning is EV/SD (Special
Development), of the EVSP. Concept Plan No. 4 was thereafter applied to development of the Project
site, which is consistent with the Projects proposed uses. Additionally, according to the City of
Redlands General Plan,the Project site is not subject to a Williamson Act contract. (DEIR pp. 3.2-10 to
3.2-11.)
In addition, a growth control zoning ordinance within the City of Redlands known as Proposition R, as
amended by Measure N,purports to allow no more than 2800 residential units(excluding congregate
and single room occupancy units) to be built within the City and 1,050 units provided with service
connections located in the County and later to be annexed into the City. The Project does not propose to
develop residential uses within the Project site. Therefore,the City's Proposition R and Measure N are
not applicable to this Project. Therefore, the Project would not conflict with existing zoning for
agricultural use,nor would it affect any Williamson Act contract. Impacts in this regard would be less
than significant. (DEIR p. 3.2-11.)
Impact AG-3: Would the proposed Project conflict with existing zoning for, or cause rezoning of,
forest land (as defined in Public Resources Code section 12220(g)), timberland(as defined by Public
Resources Code section 4526), or timberland zoned Timberland Production(as defined by Government
Code section 511.04(g))?
Finding: Potential impacts of the Project on Agricultural Resources are discussed in detail in Section
3.2 of the Draft EIR. Based on the entire record before it, the City finds no significant impact related to
the potential for the proposed Project to conflict with existing zoning for, or cause rezoning of, forest
land (as defined in Public Resources Code section 12220(g)),timberland(as defined by Public
Resources Code section 4526), or timberland zoned Timberland Production(as defined by Government
Code section 51104(g)). (DEIR pp. 3.2-11 to 3.2-12.)
Facts in Support of the Finding: While the Project will remove the existing Eucalyptus trees located
along the northern property boundary,just south of San Bernardino Avenue, the Project site does not
contain any forestland or timberland as defined within Threshold 2(c). In addition, according to Public
Resources Code sections 12220(g) and 4526, "Forest land"is land that can support 10-percent native
tree cover of any species, including hardwoods, under natural conditions, and that allows for
management of one or more forest resources, including timber, aesthetics, fish and wildlife,biodiversity,
water quality, recreation, and other public benefits. The Project site is regularly disked and is highly
disturbed from past agricultural and human activities, and non-native ruderal (orbs and grasses dominate
the site. In addition,the Project site does not contain flowing water or standing pools,nor does the site
support any vegetation or resources that serves as a habitat for the migratory fish or wildlife. Therefore,
land use and development activities contemplated by the proposed Project are not considered a forest
resource and would not impact these resources. No impacts would occur. (DEIR p. 3.2-11.)
Impact AG-4: Would the proposed Project result in the loss of forest land or conversion of forest land
to non-forest use?
Finding: Potential impacts of the Project on Agricultural Resources are discussed in detail in Section
3.2 of the Draft EIR. Based on the entire record before it,the City finds no significant impact related to
the potential for the proposed Project to result in the loss of forest land or conversion of forest land to
non-forest use. (DEIR p. 3.2-12.)
12
City of Redlands-Redlands Crossing Project
Facts,Findings,and Statement of Overriding Considerations
Related to the Final Environmental Impact Report
Facts in Support of the Finding: The Project site is designated as EV/SD (East Valley Specific Plan/
Special Development) District according to the City of Redlands Zoning Map, which is a non-forest
zoning designation. In addition, according to Public Resources Code sections 12220(g) and 4526,
"Forest land"is land that can support I0-percent native tree cover of any species, including hardwoods,
under natural conditions, and that allows for management of one or more forest resources, including
timber, aesthetics, fish and wildlife, biodiversity, water quality, recreation, and other public benefits.
The Project site is regularly disked and is highly disturbed from past agricultural and human activities,
and non-native ruderal forbs and grasses dominate the site. In addition, the Project site does not contain
flowing water or standing pools, nor does the site support any vegetation or resources that serves as a
habitat for the migratory fish or wildlife. Therefore, land use and development activities contemplated
by the proposed Project are not considered a forest resource and would not impact these resources. This
condition precludes the possibility of the proposed Project conflicting with a forest zoning designation.
No impacts would occur. (DEIR p. 3.2-12.)
Impact AG-5: Would the proposed Project involve other changes in the existing environment which,
due to their location or nature, could result in conversion of Farmland, to non-agricultural use?
Finding: Potential impacts of the Project on Agricultural Resources are discussed in detail in Section
3.2 of the Draft EIR. Based on the entire record before it, the City finds the Project will have a less than
significant impact related to the potential for the proposed Project to involve changes in the existing
environment which,due to their location or nature, could result in conversion of Farmland, to non-
agricultural use. (DEIR p. 3.2-13.)
Facts in Support of the Finding: Previous uses of the Project site include agricultural production.
Some of the land in the surrounding area has been fanned in the recent past, and some surrounding
parcels are used on an infrequent basis for agriculture. It is possible that development of the Project site
as a commercial use will incrementally increase pressure on surrounding agricultural land to convert to
non-agricultural use. However, according to the City's General Plan land use map,the immediate area
of the Project site allows for commercial uses similar to the Project site and low density residential uses
similar to the existing residential uses along Karon Street located to the southeast of the Project site.
Implementation of the Project would not interfere with such uses. Therefore, the impacts in this regard
would be less than significant. (DEIR p. 3.2-13.)
3. Biological Resources
Impact BR-2: Would the proposed Project have a substantial adverse effect on any riparian habitat or
other sensitive natural community identified in local or regional plans, policies, and regulations or by the
CDFG or USFWS?
Finding: Potential impacts of the Project on Biological Resources are discussed in detail in Section 3.4
of the Draft EIR. Based on the entire record before it, the City finds the Project will have a less than
significant impact related to the potential for the proposed Project to have a substantial adverse effect on
any riparian habitat or other sensitive natural community identified in local or regional plans, policies,
and regulations or by the CDFG or USFWS. (DEIR pp. 3.4-13 to 3.4-14.)
Facts in Support of the Finding: The Project site does not contain any riparian/riverine habitat. In
addition, no venial pools, vernal pool habitat, or fairy shrimp habitat occur on the Project site. The
habitat assessment conducted for the Project determined that the Project site does not contain sensitive
natural community as identified in local or State plans or by the CDFG or USFWS (MBA 2009).
13
City of Redlands-Redlands Crossing Project
Facts,Findings,and Statement of Overriding Considerations
Related to the Final Environmental Impact Report
Therefore, the Project would result in a less than significant impact to any riparian habitat or other
sensitive natural community, and no mitigation is required. (DEIR p. 3.4-13.)
Impact BR-3: Would the proposed Project have a substantial adverse effect on federally protected
wetlands as defined by Section 404 of the CWA (including,but not limited to, marsh,vernal pool,
coastal, etc.)through direct removal, filling,hydrological interruption, or other means?
Finding: Potential impacts of the Project on Biological Resources are discussed in detail in Section 3.4
of the Draft EIR. Based on the entire record before it, the City finds no significant impact related to the
potential for the proposed Project to have a substantial adverse effect on federally protected wetlands as
defined by Section 404 of the CWA(including,but not limited to,marsh, vernal pool, coastal, etc.)
through direct removal, filling,hydrological interruption, or other means. (DEIR p. 3.4-14.)
Facts in Support of the Finding: According to the jurisdictional delineation for the Project, there are
no USACE or CDFG wetlands or riparian areas on the Project site; therefore, there would be no
potential impacts to federally protected wetlands. (DEIR p. 3.4-14.)
Impact BR-4: Would the proposed Project interfere substantially with the movement of any native
resident or migratory fish or wildlife species or with established native resident or migratory wildlife
corridors, or impede the use of wildlife nursery sites?
Finding: Potential impacts of the Project on Biological Resources are discussed in detail in Section 3.4
of the Draft EIR. Based on the entire record before it, the City finds the project would have a less than
significant impact related to the potential for the proposed Project to interfere substantially with the
movement of any native resident or migratory fish or wildlife species or with established native resident
or migratory wildlife corridors, or impede the use of wildlife nursery sites. (DEIR pp. 3.4-14 to 3.4-15.)
Facts in Support of the Finding: The Project site does not contain flowing water or standing pools,
nor does the site support any vegetation or resources that serves as a habitat for the migratory fish or
wildlife. The site does not lie within any known wildlife corridors. In addition,the use of the Project
site as a wildlife corridor is unlikely, given the close proximity of residential development to the east,
the State Route 210(SR-210) Freeway located immediately west of the site, and the I-10 Freeway
located approximately one mile south of the Project site. Further, no regional wildlife corridor traverses,
or is in proximity to the Project site. Therefore, implementation of the Project will have a less than
significant impact on wildlife movement routes or result in habitat fragmentation. No mitigation is
required. (DEIR p. 3.4-14.)
Impact BR-5: Would the proposed Project conflict with any local policies or ordinances protecting
biological resources, such as a tree preservation policy or ordinance?
Finding: Potential impacts of the Project on Biological Resources are discussed in detail in Section 3.4
of the Draft EIR. Based on the entire record before it,the City finds the Project will have a less than
significant impact related to the potential for the proposed Project to conflict with any local policies or
ordinances protecting biological resources, such as a tree preservation policy or ordinance. (DEIR pp.
3.4-15 to 3.4-16.)
Facts in Support of the Finding: The following are the implementing policies related to biological
resources within the City of Redlands General Plan applicable to the Project.
14
City of Redlands-Redlands Crossing Project
Facts,Findings,and Statement of Overriding Considerations
Related to the Final Environmental Impact Report
Policy 7.21h -Require a biological assessment of any project site where species or the habitat of species
defined as sensitive or special status by the DFG or the USFWS might be present. A General Biological
Resource and Habitat Assessment Report was prepared for the Project by LSA Associates, Inc. on
August 1, 2005. The report was updated by MBA on March 5, 2009. The report determined that the
Project site does not contain any species or habitat species defined as sensitive or special status by the
DFG or the USFWS. Therefore, impacts in this regard would be less than significant. (DEIR p. 3.4-15.)
Policy 7.21 -Evaluate the habitat value of agricultural fields and groves prior to conversion to other
uses; if habitat value is significant, consider a development plan, which incorporates open space uses of
similar value.
A General Biological Resource and Habitat Assessment Report prepared for the Project analyzed the
habitat value of agricultural fields and citrus groves. The Project site has been historically utilized for
agriculture purposes as an orchard. However, the updated report indicated that the previously mapped
Citrus Grove has been changed. The citrus fanning in the Project site has been discontinued and the
orange trees have been destroyed, cut, and left in place(MBA 2009a). Therefore, at present, the Project
site does not contain significant habitat value in regard to agricultural fields and grooves and therefore
conversion of the Project site to the Redlands Crossing Center would result in a less than significant
impact, and mitigation is not required. (DEIR pp. 3.4-15 to 3.4-16.)
Impact BR-6: Would the proposed Project conflict with the provisions of an adopted HCP,Natural
Community Conservation Plan, or other approved local, regional, or state habitat conservation plan?
Finding: Potential impacts of the Project on Biological Resources are discussed in detail in Section 3.4
of the Draft EIR. Based on the entire record before it, the City finds no significant impact related to the
potential for the proposed Project to conflict with the provisions of an adopted HCP,Natural
Community Conservation Plan, or other approved local,regional, or state habitat conservation plan.
(DEIR p. 3.4-16.)
Facts in Support of the Finding: There are no local, regional or State approved conservation plans
applicable to the Project. Therefore, the Project will not conflict with the provisions of any adopted
habitat/natural community conservation plan and impacts would remain less than significant. (DEIR p.
3.4-16.)
4. Cultural Resources
Impact CR-I: Would the proposed Project cause a substantial adverse change in the significance of a
historical resource as defined in CEQA §15064.5?
Finding: Potential impacts of the Project on Cultural Resources are discussed in detail in Section 3.5 of
the Draft EIR. Based on the entire record before it, the City finds the Project would have a less than
significant impact related to the potential for the proposed Project to cause a substantial adverse change
in the significance of a historical resource as defined in CEQA §15064.5. (DEIR pp. 3.5-14 to 3.5-18.)
Facts in Support of the Finding: The Assessment indicated that three known historical cultural
resources are located within the Project site and 15 additional cultural resources are located within one
mile of the Project site. Phase 11 significance testing was carried out for each of the individual cultural
resources that are located in the Project site. To be significant, an historical resource would have to
demonstrate one or more of the following criteria under the Public Resources Code(PRC) §5024.1,Title
14 CCR, Chapter 11.5, Section 4852: 1. It is associated with the events that have made a significant
15
City of Redlands-Redlands Crossing Project
Facts,Findings,and Statement of Overriding Considerations
Related to the Final Environmental Impact Report
contribution to the broad pattern of California history and cultural heritage; 2. It is associated with the
lives of persons important in our past; 3. It embodies the distinctive characteristics of a type, period,
region, or method of construction, or represents the work of an important creative individual, or
possesses high artistic value; 4. or It has yielded, or may be likely to yield, information important in
prehistory or history. (DEIR,p, 3.5-14.)
The three historic cultural resources that are located within the Project site(CA-SBR-7765H, CA-SBR-
7766H and CA-SBR-7767H) are described and evaluated within the Phase 11 test chapter of the
Assessment document. (DEIR p. 3.5-15.)
The historical resource CA-SBR-7765H was evaluated under the four criteria of the CR, which are
outlined in Public Resources Code(PRC) §5024.1, Title 14 CCR, Chapter 11.5, Section 4852. MBA
(2009)determined that the resource does not meet the criteria for listing in the CR under the context of
Redlands citrus history primarily because the data set is considered exhausted. The resource does not
exhibit orchards, structures or complete historical irrigation systems that might tie the resource directly
into the locally significant and fast disappearing historical citrus industry. (DEIR p. 3.5-15.)
Under Criterion 1,the Assessment analyzed the resource's potential for significance as a part of an
historic trend that may have made a significant contribution to the broad patterns of our history.
According to the Assessment, the resource does not contain enough evidence that substantive subsurface
historic deposits are located within or near the resource, the original orchard complex has been
compromised through abandonment and demolition, and it is unlikely additional information shall be
obtained from other historic sources. Therefore, CA-SBR-7765H does not appear to qualify for the CR
under Criterion 1. (DEIR p. 3.5-15.)
Under Criterion 2,the Assessment analyzed the resource's potential for its association with the lives of
persons significant in our past. According to the Assessment, the remnants of the resource do not appear
to be associated with individuals who were locally, regionally or nationally important. Therefore, the
CA-SBR-7765H does not appear to qualify for the CR under Criterion 2. (DEIR p. 3.5-15.)
Under Criterion 3,the Assessment analyzed the resource's potential for embodying the distinctive
characteristics of a type,period, or method of construction, or representing the work of a master,
possessing high artistic values, or representing a significant and distinguishable entity Whose
components lack individual distinction. According to the Assessment, the resource does not exhibit any
of these qualities. Therefore, CA-SBR-7765H does not appear to qualify for the CR under Criterion 3.
(DEIR p. 3.5-15.)
Under Criterion 4,the Assessment analyzed the resource's potential to yield information to prehistory or
history. According to the Assessment,research has shown that it is very unlikely that additional intact
historic data associated with this resource will be found during future earthmoving on the Project
property. Therefore, CA-SBR-7765H does not appear to qualify for the CR under Criterion 4. (DEIR p.
3.5-15.)
Given the current design of the Project, CA-SBR-7765H will be directly impacted by construction.
Since the site has been deemed not significant through a Phase 11 assessment and all information
available about the resource has been exhausted, all Project-related impacts to this resource are
considered less than significant. (DEIR p. 3.5-15.)
16
City of Redlands-Redlands Crossing Project
Facts,Findings,and Statement of Overriding Considerations
Related to the Final Environmental Impact Report
The historical site CA-SBR-7766H was evaluated under the four criteria of the CR,which is outlined in
PRC §5024.1, Title 14 CCR, Chapter 11.5, Section 4852. The Cultural Resource Assessment
determined that the site does not meet the criteria for the CR under the context of Redlands citrus history
primarily because the data set is considered exhausted. The site does not exhibit orchards, structures or
complete historical irrigation systems that might tic into the locally significant and fast disappearing
historical citrus industry. (DEIR p. 3.5-16.)
Under Criterion 1,the Assessment analyzed the resource's potential for significance as a part of an
historic trend that may have made a significant contribution to the broad patterns of our history.
According to the Assessment, the resource does not contain enough evidence that substantive subsurface
historic deposits are located within or near the resource, the original orchard complex has been
compromised through abandonment and demolition, and it is unlikely additional information shall be
obtained from other historic sources. Therefore, CA-SBR-7766H does not appear to qualify for the CR
under Criterion 1. (DEIR p. 3.5-16.)
Under Criterion 2,the Assessment analyzed the resource's potential for its association with the lives of
persons significant in our past. According to the Assessment, the remnants of the resource do not appear
to be associated with individuals who were locally, regionally or nationally important. Therefore, the
CA-SBR-7766H does not appear to qualify for the CR under Criterion 2. (DEIR p. 3.5-16.)
Under Criterion 3, the Assessment analyzed the resource's potential for embodying the distinctive
characteristics of a type,period, or method of construction, or representing the work of a master,
possessing high artistic values, or representing a significant and distinguishable entity whose
components lack individual distinction. According to the Assessment, the resource does not exhibit any
of these qualities. Therefore, CA-SBR-7766H does not appear to qualify for the CR under Criterion 3.
(DEIR p. 3.5-16.)
Under Criterion 4,the Assessment analyzed the resource's potential to yield information to prehistory or
history. According to the Assessment, research has shown that it is very unlikely that additional intact
historic data associated with this resource will be found during future earthmoving on the Project
property. Therefore, CA-SBR-7766H does not appear to qualify for the CR under Criterion 4. (DEIR p.
3.5-16.)
Given the current design of the Project, CA-SBR-7766H will be directly impacted by construction.
Since the site has been deemed not significant through a Phase 11 assessment and all information
available about the resource has been exhausted, all Project-related impacts to this resource are
considered less than significant. (DEIR p. 3.5-16.)
The historical site CA-SBR-7767H was evaluated under the four criteria of the CR,which is outlined in
PRC §5024.1,Title 14 CCR, Chapter 11.5, Section 4852. The Cultural Resource Assessment
determined that the site does not meet the criteria for the CR under the context of Redlands citrus history
primarily because the data set is considered exhausted. The site does not exhibit orchards, structures or
complete historical irrigation systems that might tie into the locally significant and fast disappearing
historical citrus industry. (DEIR pp. 3.5-16 to 3.5-17.)
Under Criterion 1,the Assessment analyzed the resource's potential for significance as a part of an
historic trend that may have made a significant contribution to the broad patterns of our history.
According to the Assessment, the resource does not contain enough evidence that substantive subsurface
historic deposits are located within or near the resource, the original orchard complex has been
17
City of Redlands-Redlands Crossing Project
Facts,Findings,and Statement of Overriding Considerations
Related to the Final Environmental impact Report
compromised through abandonment and demolition, and it is unlikely additional information shall be
obtained from other historic sources. Therefore, CA-SBR-7767H does not appear to qualify for the CR
under Criterion 1. (DEIR p. 3.5-17.)
Under Criterion 2,the Assessment analyzed the resource's potential for its association with the lives of
persons significant in our past. According to the Assessment,the remnants of the resource do not appear
to be associated with individuals who were locally,regionally or nationally important. Therefore, the
A-SBR-7767H does not appear to qualify for the CR under Criterion.2. (DEIR p. 3.5-17.)
Under Criterion 3, the Assessment analyzed the resource's potential for embodying the distinctive
characteristics of a type,period, or method of construction,or representing the work of a mister,
possessing high artistic values,or representing a significant and distinguishable entity whose
components lack individual distinction.. According to the Assessment,the resource does not exhibit any
of these`qualities. 'Therefore, CA-SBR-7767H does not appear to qualify for the CR under Criterion 3.
(DEIR p. 3.5-17.)
Under Criterion 4,the Assessment analyzed the resource's'potential to yield information to prehistory or
history. According to the.Assessment,research has shown that it is very unlikely that additional intact
historic data associated with this resource will be found during future earthmoving on the Project
property. Therefore,CA-SBR-7767H does not appear to qualify for the CR under Criterion 4. (DEIR p.
3.5-17.)
Given the current design of the Project,CA-SBR-7767H will be directly impacted by construction.
Since the site has been deemed not significant through a Phase 11 assessment and all information
available about the resource has leen exhausted, all Project-related impacts to this resource are,
considered less than significant. (DEIR p. 3.5-17.)
In summary,the Phase II testing indicated that none of the above sites meets any of the following
criteria established by CE( A Guidelines Section 15064.5 to be considered`unique historic properties"
(MBA 009b). One new cultural'resource site(P#36-013622)was identified during Phase II Survey.
However,recordation of the feature exhausted the data set associated with historic cultural resources,
thereby mitigating for impacts if the site is altered or destroyed by construction. Therefore,impacts to
any historic resources one e Project site will be less than significant. (DEIR p. 3.5-17.)
5. Geology and Soils
Impact S= : Would the proposed Project expose people or structures to potential substantial adverse
effects, including the risk of loss,injury or death involving: rupture of a known earthquake fault; as
delineated on the most recent Alquist-Priolo Earthquake Fault;boning Map issued by the State Geologist
for the area or based on other substantial evidence of a known fault; strong seismic ground shaking;
Seismic-related ground failure,including liquefaction,or landslides?
Finding: Potential impacts of the Project due to Geology and Sails are discussed in detail in Section 3.6
of the Draft EIR. Based on the entire record before it,the City finds the Project would have a less than
significant impact related to the potential for the proposed Project to expose people or structures to
potential substantial adverse effects,including the risk of lass,injury or death involving:rupture of a
known earthquake fault,as delineated on the most recent Aquit-Priolo Earthquake Fault Zoning Map
issued by the State Geologist for the area or based on other substantial evidence of a known fault, strong
seismic ground shaking; Seismic-related ground failure, including liquefaction,or landslides. (DEIR pp.
.6-16 to 3.6-17.)
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City of Redlands-Redlands Crossing Project
Facts,Findings,and Statement of Overriding Considerations
Related to the Final Environmental Impact Report
Facts in Support of the Finding: The Project site is located in an area of regular seismic activity and is
prone to periodic earthquakes, as is all of southern California. Specifically, the Project is located
between two of the most active faults, the San Jacinto and the San Andreas Fault Zones. The potential
seismic hazards include fault rupture, strong ground shaking, ground failure, and landsliding. The
geotechnical investigation report evaluated the potential for these seismic hazards; the results are
summarized below. (DEIR p. 3.6-16.)
Fault Rupture-The site is not within any EFZ as created by the Alquist-Priolo Fault Zone Act. The
nearest"zoned"active fault is the San Jacinto Valley Segment of the San Jacinto Fault Zone (Type B
fault), located approximately 4.6 miles from the Project site(Exhibit 3.6-2, Regional Faults). Therefore,
the potential for fault-induced ground rupture on the site is less than significant. (DEIR p. 3.6-16.)
Seismic Ground Shaking-The surrounding area contains several regional faults,which have the
potential to generate strong ground motions at the Project site. An earthquake occurring on the San
Jacinto Valley Segment of the San Jacinto Fault Zone would cause the most severe shaking. This fault
has the potential of generating peak horizontal ground accelerations of 0.49 g(approximately 49 percent
of the force of gravity applied in the horizontal direction). Given the moderate horizontal accelerations
that could occur at this site(0.49 g), the impact of strong seismic ground motion could be a potentially
significant impact. However, the Project site is located at a significant distance from the identified fault
zone and the Project site shows no mapped faults on-site according to Geotechnical Hazards Map (GP
Figure 8.3) in Section 8.0 Health and Safety of the General Plan of the City. In addition, the City of
Redlands enforces a variety of codes to ensure the structural integrity of buildings constructed within the
City. The City adopted revisions of the UBC that address the specific building conditions and structural
requirements in California. CCR,Title 24, Part 2, the CBC, provides minimum standards for building
design in California. The City has adopted the 2010 CBC, as the City's building code which
incorporates the most current seismic design standards and hazard reduction measures recommended by
the ATC the SEAOC,the EERI, the Seismic Safety Commission, and the Southern California
Earthquake Center. Compliance with the State building code and building standards(i.e.,Uniform
Building Code/California Building Code for Zone 4), as well as the City's development review process,
and the design guidelines outlined in the Project geotechnical studies should reduce ground shaking
impacts to less than significant levels, and no mitigation is required. (DEIR pp. 3.6-16 to 3.6-17.)
Seismic-Related Ground Failure-The liquefaction potential of the Project site was evaluated based
upon soil type,groundwater depth,relative density, initial confining pressure and the intensity and
duration of ground shaking. Based on the findings on the geotechnical investigation, the potential for
seismic induced soil liquefaction within the Project site is low due to underlying soil characteristics and
absence of shallow groundwater. Therefore, the Project's impacts on seismic-related ground failure are
less than significant, and no mitigation is required. (DEIR p. 3.6-17.)
Landslides -A review of the"Slope Map," Figure 8.4 of City of Redlands General Plan,shows that the
Project site is not located within an area prone to slope instability. The site reconnaissance does not
show evidence of onsite landslides and the primary earth material at the site is resistant to landslides
(KA 2005). In addition,the Project site area is a nearly leveled area and does not contain any unstable
or steep slopes,which have a higher tendency for landslide activity. Therefore,based upon the existing
topography and proposed design configurations, the occurrence of landslide due to seismic events is less
than significant, and no mitigation is required. (DEIR p. 3.6-17.)
Impact GS-4: Would the proposed Project be located on expansive soil, as defined in Table 18-1-A of
the California Building Code(2007), creating substantial risks to life or property?
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City of Redlands-Redlands Crossing Project
Facts,Findings,and Statement of Overriding Considerations
Related to the Final Environmental impact Report
Finding: Potential impacts of the Project due to Geology and Soils are discussed in detail in Section 3.6
of the Draft EIR. Based on the entire record before it, the City finds the Project would have a less than
significant impact related to the potential for the proposed Project to be located on expansive soil, as
defined in Table 18-1-A of the California Building Code(2007), creating substantial risks to life or
property. (DEIR pp. 3.6-19 to 3.6-20.)
Facts in Support of the Finding: The laboratory tests indicate that on-site soils have very low
expansion potential. The geotechnical report for the Project site indicate that on-site soils do not
contain expansive clay materials and have low shrink-swell properties that may expose buildings to
structural damage. In addition, subsidence within the building area is anticipated at less than 0.05 feet
(KA 2005). Compliance with the recommendations set forth in the geotechnical report should render
any risks associated with expansive soils to less than significant levels, and therefore no mitigation is
required. (DEIR p. 3.6-19.)
Impact GS-5: Would the proposed Project have soils incapable of adequately supporting the use of
septic tanks or alternative wastewater disposal systems where sewers are not available for the disposal of
wastewater?
Finding: Potential impacts of the Project due to Geology and Soils are discussed in detail in Section 3.6
of the Draft EIR. Based on the entire record before it, the City finds the Project will gave a less than
significant impact related to the potential for the proposed Project to have soils incapable of adequately
supporting the use of septic tanks or alternative wastewater disposal systems where sewers are not
available for the disposal of wastewater. (DEIR p. 3.6-20.)
Facts in Support of the Finding: The Project will connect to the City of Redlands sewer system.
Accordingly, potential soil constraints for using septic or alternative wastewater disposal systems are not
applicable and therefore, this is a less than significant impact. No mitigation is required. (DEIR p. 3.6-
20.)
6. Hazards and Hazardous Materials
Impact UHM-3: Would the proposed Project emit hazardous emissions or handle hazardous or acutely
hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school?
Finding: Potential impacts of the Project due to Hazards and Hazardous Materials are discussed in
detail in Section 3.7 of the Draft EIR. Based on the entire record before it,the City finds the Project will
have a less than significant impact related to the potential for the proposed Project to emit hazardous
emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter
mile of an existing or proposed school. (DEIR p. 3.7-15.)
Facts in Support of the Finding: The Project site is approximately 1,600 feet(0.30 mile) south from
the closest school site(Citrus Valley High School, 800 West Pioneer Avenue),which is over the
minimum 1,320 foot(one-quarter mile) significant threshold of CEQA. Therefore,impacts to school
sites will be less than significant due to the distance from the Project site. No mitigation is required.
(DEIR p. 3.7-15.)
Impact HHM4: Would the proposed Project be located on a site which is included on a list of
hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result,
would it create a significant hazard to the public or the environment?
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City of Redlands-Redlands Crossing Project
Facts,Findings,and Statement of Overriding Considerations
Related to the Final Environmental Impact Report
Finding: Potential impacts of the Project due to Hazards and Hazardous Materials are discussed in
detail in Section 3.7 of the Draft EIR. Based on the entire record before it, the City finds the Project will
have a less than significant impact related to the potential for the proposed Project to be located on a site
which is included on a list of hazardous materials sites compiled pursuant to Government Code Section
65962.5 and, as a result,would it create a significant hazard to the public or the environment. (DEIR pp.
3.7-15 to 3.7-16.)
Facts in Support of the Finding: The Project site is not listed on a list of hazardous materials sites
compiled pursuant to Government Code Section 65962.5. In addition,based on the site reconnaissance
and a review of physiographic,historical, and regulatory information, there is no evidence of incidents
or accidents involving hazardous materials on the Project site. Therefore, impacts in this regard would
be less than significant. No mitigation is required. (DEIR p. 3.7-15.)
Impact IIHM-5: For a project located within an airport land use plan or, where such a plan has not been
adopted,within two miles of a public airport or public use airport, would the proposed Project result in a
safety hazard for people residing or working the project area?
Finding: Potential impacts of the Project due to Hazards and Hazardous Materials are discussed in
detail in Section 3.7 of the Draft EIR. Based on the entire record before it, the City finds the Project
would have a less than significant impact related to the potential for the proposed Project to be located
within an airport land use plan or, where such a plan has not been adopted, within two miles of a public
airport or public use airport, and result in a safety hazard for people residing or working the project area.
(DEIR p. 3.7-16.)
Facts in Support of the Finding: The Project site is located more than two miles from the Redlands
Municipal Airport(east). Therefore, the Project site is not located within an applicable Airport Safety
Area, respectively. The Project site is,however, located approximately 1.86 miles northwest of the
SBD. The SBD Airport allows for Stage 2 aircraft and has over 60,000 annual flight operations
comprised mainly of charter, corporate and general aviation users. The width of SBD Airport's
northeast to southwest facing runway is 10,000'x 200' (3,408 x 61 meters) and approximately 11,000
feet in length. Additionally, the Airport has recently completed a redesigned Passenger Terminal
Facility in anticipation of future passenger airlines services(SBD website 2009). (DEIR p. 3.7-16.)
Currently, the SBD Airport is in the process of updating their Airport Land Use Plan. As per
conversation with Bill Ingraham(August 6, 2009), analysis of the Project should be compared to the
California Airport Land Use Planning Handbook(January 2002) as a guideline for the Project's impacts
to the SBD Airport. According to Figure 9K of the California Airport Land Use Planning Handbook,
long general aviation runways with a length of 6,000 feet or more require a safety compatibility zone
setback of 6,000 feet. The Project site is located approximately 9,800 feet from the northeast comer of
SBD's runway. Therefore, the Project site is well over the minimum required safety compatibility zone
setback of 6,000 feet and will not put people at significant risk related to a safety hazard for people
residing or working the Project area. Impacts would be less than significant and no mitigation is
required. (DEIR p. 3.7-16.)
Impact HH-NI-6: For a project within the vicinity of a private airstrip, would the proposed Project result
in a safety hazard for people residing or working in the project area?
Finding: Potential impacts of the Project due to Hazards and Hazardous Materials are discussed in
detail in Section 3.7 of the Draft EIR. Based on the entire record before it, the City finds the Project
21
City of Redlands-Redlands Crossing Project
Facts,Findings,and Statement of Overriding Considerations
Related to the Final Environmental Impact Report
would have a less than significant impact related to the potential for the proposed Project due to its
location within the vicinity of a private airstrip, to result in a safety hazard for people residing or
working in the project area. (DEIR pp. 3.7-16 to 3.7-17.)
Facts in Support of the Finding: The Project site is not located within two miles of a private airstrip
and is not in the vicinity of a private airstrip that would warrant any safety concerns related to aircraft
uses. Therefore,the Project would not put people at a significant risk of safety hazard related to a
nearby private airstrip. Impacts would be less than significant, and no mitigation is required. (DEIR p.
3.7-17.)
Impact HHNI-7: Would the proposed Project impair implementation of or physically interfere with an
adopted emergency response plan or emergency evacuation plan?
Finding: Potential impacts of the Project due to Hazards and Hazardous Materials are discussed in
detail in Section 3.7 of the Draft EIR. Based on the entire record before it, the City finds the Project
would have a less than significant impact related to the potential for the proposed Project to be located
on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code
Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment.
(DEIR pp. 3.7-17 to 3.7-18.)
Facts in Support of the Finding: The City of Redlands has an Emergency Disaster Plan that identifies
specific evacuation routes within the City. In addition, the San Bernardino County General Plan
designates potential evacuation routes in the event of an emergency. Within the San Bernardino Valley,
the major routes out of the County are Interstates 10, 15, and 215, along with State Highways 30 (now
State Highway 210), 31, 60, 66, 71, and numerous major and secondary highways. (DEIR p. 3.7-17.)
Caltrans has identified a number of possible evacuation routes in the San Bernardino Valley. These
roads have the least number of bridges, and may be among the safest roads to travel in the event of a
major earthquake. In the East Valley, those roads, which connect with the Planning Area, include:
Hospitality Drive from Tippecanoe Avenue to Waterman Avenue; Coulston Street from Mountain View
Avenue to Tippecanoe Avenue; Lugonia Avenue from Orange Street to Mountain View Avenue; and
Redlands Boulevard from Orange Street to Waterman Avenue. (DEIR p. 3.7-17.)
An increase in short-term construction traffic is anticipated and could temporarily affect traffic flow on
nearby roadways used for evacuation routes. However, nearby roadways currently include wide paved
lanes that could be used by vehicles to allow emergency vehicles to pass. Therefore, short-term
construction related impacts in regards to evacuation routes would be less than significant. (DEIR p.
3.7-17.)
In addition, Project implementation would not hinder the City of Redlands ability to coordinate with San
Bernardino County or Caltrans on its emergency response and emergency evacuation plans. As the
primary north-south transportation corridor through the City, the adjacent SR-210 serves as an obvious
route for both emergency response and emergency evacuation purposes. In addition,the Project would
introduce on-site emergency response or evacuation plans, including employees who would be subject to
emergency evacuation or response in the event of a major disaster. Therefore,the Project would result
in a less than significant impact regarding emergency evacuation plans. (DEIR pp. 3.7-17 to 3.7-18.)
22
City of Redlands-Redlands Crossing Project
Facts,Findings,and Statement of Overriding Considerations
Related to the Final Environmental Impact Report
Impact HHM-8: Would the proposed Project expose people or structures to a significant risk of loss,
injury or death involving wildland fires, including where wildlands are adjacent to urbanized areas or
where residences are intermixed with wildlands?
Finding: Potential impacts of the Project due to Hazards and Hazardous Materials are discussed in
detail in Section 3.7 of the Draft EIR. Based on the entire record before it,the City finds the Project
would have a less than significant impact related to the potential for the proposed Project to expose
people or structures to a significant risk of loss, injury or death involving wildland fires,including where
wildlands are adjacent to urbanized areas or where residences are intermixed with wildlands. (DEIR pp.
3.7-17 to 3.7-18.)
Facts in Support of the Finding: According to California Department of Forestry and Fire Protection,
the Project area is categorized as having a non-VHFHSZ (Very High Fire Hazard Severity Zones)risk
from fires. There are also City fire stations in the general Project area. The closest City fire station is
located at 10 West Pennsylvania Avenue (Fire Station 263), approximately 0.8-mile east of the Project
site at the intersection of Pennsylvania Avenue and Orange Street. In addition,the Redlands Fire
Department(RFD)has a mutual aid agreement with the San Bernardino County Fire Department
(SBCFD), which allows the SBCFD to provide fire services to areas within the City of Redlands and
vice versa. The closest SBCFD fire station to the Project site is Station 9, located at 1300 Crafton
Avenue, Mentone. The SBCFD provides complete fire protection, including fire,public service and
emergency medical aid response,but County services do not include ambulance and transport services.
In addition, The RFD has mutual aid agreements with the California Department of Forestry, and the
Loma Linda Fire Department. Consistency with the mutual aid program will reduce impacts to the
exposure of people or structures to a significant risk of loss, injury or death involving wildland fires,
including where wildlands are adjacent to urbanized areas or where residences are intermixed with
wildlands. Therefore,the Project will have less than significant impacts related to wildland fire hazards.
No mitigation is required. For more analysis regarding fire hazards, see Section 3.13, Public Services.
(DEIR p. 3.7-17.)
7. Hydrology and Water Quality
Impact HWQ-4: Would the proposed Project create or contribute runoff water which would exceed the
capacity of existing or planned stormwater drainage systems or provide substantial additional sources of
polluted runoff?
Finding: Potential impacts of the Project due to Hydrology and Water Quality are discussed in detail in
Section 3.8 of the Draft EIR. Based on the entire record before it,the City finds the Project would have
a less than significant impact related to the potential for the proposed Project to create or contribute
runoff water which would exceed the capacity of existing or planned stormwater drainage systems or
provide substantial additional sources of polluted runoff. (DEIR p. 3.8-23.)
Facts in Support of the Finding: Implementation of the Project will increase the runoff flow due to the
creation of additional impervious surfaces on the Project site. In order to mitigate the potential impact
associated with such increased flows, the Project will be required to prepare and comply with various
documents pertaining to stormwater runoff. Specifically, the Project will be required to complete a
NPDES permit,which will require the preparation of a SWPPP for construction related activities.
SWPPPs identify BMPs to mitigate construction related pollutants from reaching stormwater and
products of erosion from moving off-site. Furthermore, the Project specific WQMP provide guidance
for wastewater conservation after construction. (DEIR p. 3.8-23.)
23
City of Redlands-Redlands Crossing Project
Facts,Findings,and Statement of Overriding Considerations
Related to the Final Environmental Impact Report
The Project drainage plan allows the majority of drainage from impervious surface to permeable areas
for on-site infiltration. One surface-level infiltration basin and four(4)underground infiltration basins
have been incorporated into the site plan to reduce the runoff water(AE 2007). In addition, the drainage
report indicates that the proposed drainage system (pond, sediment pond, and underground systems) will
control the total peak flow volume of runoff to level similar to the pre-development runoff levels.
(DEIR p. 3.8-23.)
Therefore, with the consideration of the Project design features and implementation of BMPs as
discussed in Preliminary WQMP, the Project's runoff water would not exceed the capacity of existing or
planned stormwater drainages systems. Impacts would be less than significant and no mitigation is
required. (DEIR p. 3.8-23.)
Impact HWQ-5: Would the proposed Project place housing within a 100-year flood hazard area as
mapped on a federal Flood Hazard Boundary or Flood Insurance Rate Map or other flood hazard
delineation map?
Finding: Potential impacts of the Project due to Hydrology and Water Quality are discussed in detail in
Section 3.8 of the Draft EIR. Based on the entire record before it, the City finds the Project would have
a less than significant impact related to the potential for the proposed Project to place housing within a
100-year flood hazard area as mapped on a federal Flood Hazard Boundary or Flood Insurance Rate
Map or other flood hazard delineation map. (DEIR p. 3.8-24.)
Facts in Support of the Finding: According to the FEMA,the Project site is not within a 100-year
flood hazard area(AE 2008). In addition, the Project does not propose to develop residential housing
within the Project site. Therefore, implementation of the Project would not result in the construction of
housing improvements within the ascribed flood hazard area that would impede or redirect flood flows,
and the impact will be less than significant. (DEIR p. 3.8-24.)
Impact HWQ-6: Would the proposed Project place within a 100-year flood hazard area structures,
which would impede or redirect flood flows?
Finding: Potential impacts of the Project due to Hydrology and Water Quality are discussed in detail in
Section 3.8 of the Draft EIR. Based on the entire record before it, the City finds the Project would have
a less than significant impact related to the potential for the proposed Project to place within a 100-year
flood hazard area structures which would impede or redirect flood flows. (DEIR p. 3.8-24.)
Facts in Support of the Finding: According to the FEMA, the Project site is not within a 100-year
flood hazard area(AE 2008). Therefore, implementation of the Project would not result in the
construction of improvements within the ascribed flood hazard area that would impede or redirect flood
flows, and the impact will be less than significant. (DEIR p. 3.8-24.)
Impact HWQ-7: Would the proposed Project expose people or structures to a significant risk of loss,
injury or death involving flooding, including flooding as a result of the failure of a levee or dam?
Finding: Potential impacts of the Project due to Hydrology and Water Quality are discussed in detail in
Section 3.8 of the Draft EIR. Based on the entire record before it, the City finds no significant impact
related to the potential for the proposed Project to expose people or structures to a significant risk of
loss, injury or death involving flooding, including flooding as a result of the failure of a levee or darn.
(DEIR p. 3.8-25.)
24
City of Redlands-Redlands Crossing Project
Facts,Findings,and Statement of Overriding Considerations
Related to the Final Environmental Impact Report
Facts in Support of the Finding: The Project site is not within a dam inundation zone as there are no
dams near the site. The nearest dam to the Project site is the Seven Oaks Dam, located approximately
8.2 miles northeast to the Project site. Therefore, due to the distance to the nearest dam,there is no risk
of significant loss, injury,or death as a result of flooding or inundation due to dam failure and there
would be no impact in this regard. (DEIR p. 3.8-25.)
Impact HWQ-8: Would the proposed Project expose people or structures to inundation by seiche,
tsunami, or mudflow?
Finding: Potential impacts of the Project due to Hydrology and Water Quality are discussed in detail in
Section 3.8 of the Draft EIR. Based on the entire record before it, the City finds the Project would have
a less than significant impact related to the potential for the proposed Project to expose people or
structures to inundation by seiche, tsunami, or mudflow. (DEIR p. 3.8-25.)
Facts in Support of the Finding: The Project site is located approximately 50 miles from the Pacific
Ocean. Therefore,tsunamis (seismic sea waves) are not a significant hazard to the site. Additionally,
the site is not located close to any large bodies of water that could adversely affect the site in the event
of seiche(seismic wave oscillations in an enclosed or semi-enclosed body of water). Further, the Project
site and surrounding area are generally level and the potential impacts from mudflow are nil. Therefore,
the Project would result in a less than significant impact related to seiches, tsunamis,or mudflows.
(DEIR p. 3.8-25.)
8. Land Use and Planning
Impact LUP-1: Would the proposed Project physically divide an established community?
Finding: Potential impacts of the Project due to Land Use and Planning are discussed in detail in
Section 3.9 of the Draft EIR. Based on the entire record before it, the City finds the Project would have
a less than significant impact related to the potential for the proposed Project to physically divide an
established community. (DEIR p. 3.9-10.)
Facts in Support of the Finding: The Project will be constructed on vacant and undeveloped land. The
Project site does not consist of any established communities. A residential neighborhood exists along
Karon Street, the eastern boundary of the Project site. However, the remaining areas adjacent to the
Project site are undeveloped and vacant. Therefore, the Project does not have the potential to divide an
established community so this impact is less than significant. (DEIR p. 3.9-10.)
Impact LUP-2: Would the proposed Project conflict with any applicable land use plan,policy, or
regulation of an agency with jurisdiction over the Project(including, but not limited to the general plan,
specific plan, local coastal program, or zoning ordinance) adopted for the purpose of avoiding or
mitigating an environmental effect?
Finding: Potential impacts of the Project due to Land Use and Planning are discussed in detail in
Section 3.9 of the Draft EIR. Based on the entire record before it,the City finds the Project would have
a less than significant impact related to the potential for the proposed Project to conflict with any
applicable land use plan,policy, or regulation of an agency with jurisdiction over the Project(including,
but not limited to the general plan, specific plan, local coastal program, or zoning ordinance)adopted for
the purpose of avoiding or mitigating an environmental effect. (DEIR pp. 3.9-10 to 3.9-11.)
25
City of Redlands-Redlands Crossing Project
Facts,Findings,and Statement of Overriding Considerations
Related to the Final Environmental Impact Report
Facts in Support of the Finding: The Project site is within the jurisdiction of City of Redlands and is
therefore subject to the City's General Plan goals and policies. The Project site is also located within the
EVCSP to refine the City's General Plan policies for the Project area. The purpose of the EVCSP is to
plan for large undeveloped areas located along 1-10 in the Redlands and Loma Linda area to provide
guidance for future industrial, commercial, and residential development in an orderly and aesthetic
manner. The objectives of the EVCSP are to provide a well-planned community that attracts major
businesses into the area to provide a job base for the surrounding area and strengthen the local economy,
while ensuring high-quality development through design guidelines and standards. Therefore, the
Project is subject to both the City's General Plan and EVCSP goals and policies. Table 3.9-1 in the
Draft EIR provides an analysis of consistency with policies in the City of Redlands General Plan that
directly relates to the mix of land uses in the EVC. (DEIR p. 3.9-10.)
The Project is within the EVCSP, which serves as the principal land use planning document-guiding
development within the EVCSP planning area of the City of Redlands. According to the EVCSP Final
EIR(October 1988),land use was determined to have a significant and unavoidable impact due to the
near total elimination of prime agricultural lands at EVCSP buildout. A statement of overriding
considerations was determined in October 1988,regarding EVCSP land uses. Table 3.9-2 in the Draft
EIR provides an analysis of consistency with policies in the EVCSP that directly relates to the Project.
(DEIR pp. 3.9-11 to 3.9-12.)
The Project is consistent with existing applicable land use policies and designations of the Redlands
General Plan and EVSCP. In addition, the proposed development would be in accordance with the land
use designations identified in the City's General Plan and EVSCP. Therefore,the Project would not
conflict with applicable plans, policies, or regulations, and would be less than significant. (DEIR p. 3.9-
12.)
Impact LUP-3: Would the proposed Project conflict with any applicable habitat conservation plan or
natural community's conservation plan?
Finding: Potential impacts of the Project due to Land Use and Planning are discussed in detail in
Section 3.9 of the Draft EIR. Based on the entire record before it, the City finds a less than significant
impact related to the potential for the proposed Project to conflict with any applicable habitat
conservation plan or natural communities' conservation plan. (DEIR pp. 3.9-12 to 3.9-13.)
Facts in Support of the Finding: There are no applicable habitat conservation plans or natural
community conservation plans that apply to the Project site, therefore, the Project will have a less than
significant impact associated with conflicts with applicable habitat conservation plans or natural
community conservation plans. See Section 3.4, Biological Resources, in the Draft EIR for additional
discussions in this regard. (DEIR p. 3.9-12.)
9. Mineral Resources
Impact MR-1: Would the proposed Project result in the loss of availability of a known mineral resource
that would be of value to the region and the residents of the state or result in the loss of availability of a
locally-important mineral resource recovery site delineated on a local general plan, specific plan or other
land use plan?
Finding: Potential impacts of the Project due to Mineral Resources are discussed in detail in Section
3.1€I of the Draft EIR. Based on the entire record before it, the City finds the Project would have a less
than significant impact related to the potential for the proposed Project to result in the loss of availability
26
City of Redlands-Redlands Crossing Project
Facts,Findings,and Statement of Overriding Considerations
Related to the Final Environmental Impact Report
of a known mineral resource that would be of value to the region and the residents of the state or result
in the loss of availability of a locally-irnportant mineral resource recovery site delineated on a local
general plan, specific plan or other land use plan. (DEIR pp. 3.10-10 to 3.10-11.)
Facts in Support of the Finding: Data from the State indicates the Project site is within an MRZ-2
classification. MRZ-2 classification are areas where adequate information indicates that significant
mineral deposits are present, or where it is judged that a high likelihood for their presence exists.
Development of the Project could significantly impact 32.9 acres of prime mineral resources within the
City of Redlands. (DEIR p. 3.10-10.)
Although the Project site contains significant aggregate resources, the Mentone Dam places flood
control within the Project area, also known as Sector F, and puts a question on the future availability of
much of the resource in this area. The MRZ-2 area designated as "F"is so large,that putting the Project
site to use as commercial development will not result in the loss of availability of any resource or access
to that resource. In addition, due to the water table and clay layers of this area, much of the younger
sediments are not economical to mine for sand and gravel. Finally, as identified within Policy 7.42c of
the City of Redlands General Plan, the City will reserve designated MRZ areas outside the Santa Ana
Wash for agricultural or urban use. The Project is located outside of the Santa Ana Wash and will be
consistent with designated land uses at the Project site(CP-4). Therefore, the City's General Plan
designation and zoning classification do not permit mining activities on the Project site. Consequently,
potential impacts to these resources are considered to be less than significant. (DEIR pp. 3.10-10 to
3.10-11.)
10. Noise
Impact N-1: Would the proposed Project result in the exposure of persons to or generation of noise
levels in excess of standards established in the local general plan or noise ordinance, or applicable
standards of other agencies?
Finding: Potential impacts of the Project due to Noise are discussed in detail in Section 3.11 of the
Draft EIR. Based on the entire record before it, the City finds the Project would have a less than
significant impact related to the potential for the proposed Project to result in the exposure of persons to
or generation of noise levels in excess of standards established in the local general plan or noise
ordinance, or applicable standards of other agencies. (DEIR pp. 3.11-19 to 3.11-47.)
Facts in Support of the Finding: The nearest sensitive receptors to the Project site are the eight homes
that front Karon Street which, are located approximately 75 feet east of the proposed area to be graded.
In compliance with Section 8.06.090(F)of the City's Noise ordinance, all grading and construction-
related activities will be undertaken in between the hours of 7:00 am. and 6:00 p.m. Monday through
Saturday and will not be undertaken anytime on Sundays or holidays. Therefore, construction noise will
not violate City ordinances standards or requirements. (DEIR p. 3.11-19.)
Please note that potential affects addressed under this impact statement consider only whether city
requirements would be violated. The potential impacts of construction noise with respect to temporary
substantial increases in ambient noise levels, in particular how they would affect the eight homes that
front Karon Street, are addressed under impact N-4 in the Draft EIR and findings. (DEIR p. 3.11-19.)
The potential off-site noise impacts caused through the increase in vehicular traffic from the operations
of the Project onto the Project study area roadways has been analyzed for existing with Project, year
2013 without Project,year 2013 with Project, year 2030 without Project, and year 2030 with Project
27
City of Redlands-Redlands Crossing Project
Facts,Findings,and Statement of Overriding Considerations
Related to the Final Environmental Impact Report
scenarios. The analysis provided includes traffic noise conditions with and without Project conditions
for Year 2013 and 2030. In addition, information for each Project condition includes separate
information for weekday and Saturday traffic noise levels. These scenarios are consistent with those
used in the traffic analysis dated September 14, 2011 for this Project and all distance referenced in the
various tables are measured from street centerlines. (DEIR p. 3.11-19.)
In order for off-site roadway noise impacts created by the proposed Project's operations to be considered
significant, the proposed Project would need to increase the noise levels for a noise sensitive land use by
(1) 6 dBA CNEL,where the without Project noise level is less than 60 dBA CNEL; or(2)4 dBA CNEL,
where the without Project noise level is greater than 60 dBA CNEL. These criteria for significance have
been previously discussed in Section 3.11.2, Regulatory Framework. The proposed Project's off-site
traffic noise impacts have been analyzed for the existing, year 2013 and year 2030 weekday and
Saturday conditions and are discussed below. (DEIR p. 3.11-35.)
The results shown in Table 3.11-16 of the Draft EIR shows that for the year 2013-weekday conditions,
noise level contributions from the proposed Project onto the nearby roadways would range from 0.0 to
0.6 dBA CNEL. A 0.6 dBA noise increase would be below the thresholds of significance discussed
above in Section 3.11.2, Regulatory Framework. Therefore, for the year 2013 weekday conditions a less
than significant off-site noise impact from Project-related vehicle traffic noise would occur along the
study area roadways. (DEIR p. 3.11-35.)
The results shown in Table 3.11-18 of the Draft EIR shows that for the year 2013 Saturday conditions,
noise level contributions from the proposed Project onto the nearby roadways would range from 0.1 to
1.0 dBA CNEL. A 1.0 dBA noise increase would be below the thresholds of significance discussed
above in Section 3.11.2, Regulatory Framework. Therefore, for the year 2013 Saturday conditions, a
less than significant off-site noise impact from Project-related vehicle traffic noise would occur along
the study area roadways. (DEIR p. 3.11-37.)
The results shown in Table 3.11-19 of the Draft EIR shows that for the year 2030-weekday conditions,
noise level contributions from the proposed Project onto the nearby roadways would range from 0.0 to
0.6 dBA CNEL. A 0.6 dBA noise increase would be below the thresholds of significance discussed
above in Section 3.11.2, Regulatory Framework. Therefore, for the year 2030 weekday conditions, a
less than significant off-site noise impact from Project-related vehicle traffic noise would occur along
the study area roadways. (DEIR p. 3.11-39.)
The results shown in Table 3.11-20 of the Draft EIR shows that for the year 2030 Saturday conditions,
noise level contributions from the proposed Project onto the nearby roadways would range from 0.0 to
0.7 dBA CNEL. A 0.7 dBA noise increase would be below the thresholds of significance discussed
above in Section 3.11.2, Regulatory Framework. Therefore, for the year 2030 Saturday conditions, a
less than significant off-site noise impact from Project-related vehicle traffic noise would occur along
the study area roadways. (DEIR p. 3.11-41.)
The Project would have potential stationary noise impacts to the nearby residences from the proposed
rooftop HVAC units,truck loading areas,parking lot areas, drive-through speakers, car wash, and on-
site vehicular traffic. In order to assess the Project's stationary noise impacts onto the nearby
residences, the SoundPlan modeling software was utilized. The modeling methodology and input
parameters used to assess stationary noise impacts is provided in Section 8.2.1 of the noise impact
analysis, which can be found in Appendix H of this document. (DEIR p. 3.11-42.)
28
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6
City of Redlands-Redlands Crossing Project
Facts,Findings,and Statement of Overriding Considerations
Related to the Final Environmental Impact Report
Facts in Support of the Finding: The nearest sensitive receptors to the Project site are residential
homes along Karon Street located approximately 75 feet east of the proposed area to be graded.
Construction activities can produce vibration that may be felt by adjacent uses. The construction of the
Project would not require the use of equipment such as jackhammers and pile drivers,which are known
to generate substantial construction vibration levels. The primary sources of vibration during
construction would be from bulldozers,backhoes, crawler tractors, and scrapers. According to the noise
impact analysis prepared for the Project(MBA 2011), a large bulldozer would be the piece of equipment
that would produce the largest amount of vibration on the Project site with a 0.089 Particle Peak
Velocity(PPV)or 87 VdB at 25 feet. (DEIR p. 3.11-49.)
The closest vibration-sensitive land uses are the eight single-family residences to the east,with the
nearest prefabricated residence located approximately 75 feet from the proposed area to be graded. It is
anticipated that the vibration levels caused by a large bulldozer operating on the edge of the area to be
graded during construction of the Project at the nearest structure will be around 0.0027 inches per
second PPV, which is below City's threshold of 0.2 inch per second PPV. Therefore, construction-
related vibration impacts will be less than significant. (DEIR p. 3.11-49.)
The Project would result in the development of approximately 275,500 square feet of commercial retail
uses and would generate approximately 38 truck trips per day. The only potential source of vibration is
from the operation of trucks on the Project site. According to the TIA (MBA 2011), a loaded truck
would typically produce a vibration level of 0.076 inch per second PPV at 25 feet. The nearest existing
residential home is located a minimum of 300 feet away from any of the proposed roadways. At this
distance, this would result in a vibration level of 0.005 inch per second PPV at the nearest sensitive
receptor to where the trucks would operate on-site. This vibration level would not exceed the 0.2 inch
per second PPV threshold. Therefore, vibration impacts from the ongoing operations of the Project
would be less than significant. (DEIR p. 3.11-49.)
Impact N-3: Would the proposed Project create a substantial permanent increase in ambient noise levels
in the Project vicinity above levels existing without the Project?
Finding: Potential impacts of the Project due to Noise are discussed in detail in Section 3.11 of the
Draft EIR. Based on the entire record before it,the City finds the Project would have a less than
significant impact related to the potential for the proposed Project to create a substantial permanent
increase in ambient noise levels in the Project vicinity above levels existing without the Project. (DEIR
pp. 3.11-50 to 3.11-51.)
Facts in Support of the Finding: Substantial permanent increases in ambient noise levels would have
the potential to occur if Project generated noise exceeds City standards and/or threshold requirements.
Potential impacts are discussed below for Project generated traffic and stationary noise. (DEIR p. 3.11-
50.)
.11-50.)
As outlined within Impact N-1, the Project has potential for Long-Tenn off-site traffic noise impacts
created from the ongoing operations of the Project. The Project's off-site noise impacts have been
analyzed for the Year 2013 and Year 2030 weekday and Saturday conditions. In no instance did the
Project related increase in traffic noise exceed the City's most stringent threshold standards for noise:
increases in the noise levels for a noise sensitive land use by(1) 6 dBA CNEL,where the without-
Project noise level is less than 60 dBA CNEL; or(2)4 dBA CNEL, where the without Project noise
level is greater than 60 dBA CNEL. The largest Project-generated increase in noise level that would
occur for any of the scenarios analyzed is 1.0 dBA for the segment of San Bernardino Avenue West of
30
City of Redlands-Redlands Crossing Project
Facts,Findings,and Statement of Overriding Considerations
Related to the Final Environmental Impact Report
Alabama Street under the 2013 Saturday conditions, resulting in an overall noise level of 66.5dBA
CNEL when non-Project traffic noise is included. While the Project-generated level of increase is
consistent with City threshold criteria for residential uses, it should also be noted that land adjoining this
road segment is in an area that is designated for commercial land uses. The City's Land use
Compatibility Matrix(Table 3.11-7 of the Draft EIR), indicates that a noise level of up to 75 dBA CNEL
is clearly compatible with commercial retail uses. (DEIR p. 3.11-50.)
The Project has the potential to result in stationary noise impact to the nearby residences from the
proposed rooftop HVAC units, truck loading areas, parking lot areas, drive through speakers, car wash,
and on-site vehicular traffic. The stationary-only noise levels created by the Project were calculated for
the facades of the same nearby sensitive receptors. The results are summarized in Table 3.11-21,which
shows that for the stationary only scenario all receivers would be within the City's exterior stationary
noise standard of 60 dBA Leq. Therefore, potential impact from stationary noise created by the Project
would be less than significant. (DEIR p. 3.11-50.)
As identified under impact N-I (Table 3.11-22 of the Draft EIR) the Project's combined stationary and
transportation noise impacts would result in noise levels at the nearby sensitive receivers ranging from -
1.0 to 0.4 dBA CNEL compared to the Year 2013 no- Project condition. The decrease in noise levels at
Receivers 1, 2, 3,4, 5, and 6 is primarily due to the noise shielding the proposed structures would
provide from the SR-210 Freeway, which is the primary noise source in the study area. Based on the
threshold of significance defined above, a less than significant combined transportation and stationary
noise impact would occur from the operations of the Project. (DEIR p. 3.11-51.)
Impact N-5: For a Project located within an airport land use plan or, where such a plan has not been
adopted, within two miles of a public airport or public use airport, would the proposed Project expose
people residing or working in the Project area to excessive noise levels?
Finding: Potential impacts of the Project due to Noise are discussed in detail in Section 3.11 of the
Draft EIR. Based on the entire record before it, the City finds a less than significant impact related to
the potential for the proposed Project to expose people residing or working in the Project area to
excessive noise levels related to aircraft noise. (DEIR p. 3.11-54.)
Facts in Support of the Finding: The nearest airports from the Project site are Redlands Municipal
Airport(RMA), which is located approximately 2.5 miles northeast from the Project site and San
Bernardino International Airport(SBIA), located approximately 1.8 miles northwest of the Project site.
The Project site is not located within the noise impact or safety area zones for RMA or SBIA.
Therefore, there would be no significant adverse aviation related impacts that the Project would expose
people residing in the Project area to excessive noise levels. Impacts would be less than significant.
(DEIR p. 3.11-54.)
Impact N-6: For a Project within the vicinity of a private airstrip, would the proposed Project expose
people residing or working in the Project area to excessive noise levels?
Finding: Potential impacts of the Project due to Noise are discussed in detail in Section 3.11 of the
Draft EIR. Based on the entire record before it, the City finds a less than significant impact related to
the potential for the proposed Project to expose people residing or working in the Project area to
excessive noise levels related to aircraft noise. (DEIR p. 3.11-54.)
31
City of Redlands-Redlands Crossing Project
Facts,Findings,and Statement of Overriding Considerations
Related to the Final Environmental Impact Report
Facts in Support of the Finding: The Project site is not located within two miles of a private airstrip.
Therefore, the Project would not put people at a significant risk of noise hazard related to a nearby
private airstrip. Impacts would be less than significant. (DEIR p. 3.11-54.)
11. Population and Housing
Impact PH-1: Would the proposed Project induce substantial population growth in an area, either
directly(e.g.,by proposing new homes and businesses) or indirectly(e.g., through extension of roads or
other infrastructure)?
Finding: Potential impacts of the Project due to Population and Housing are discussed in detail in
Section 3.12 of the Draft EIR. Based on the entire record before it, the City finds the Project would
have a less than significant impact related to the potential for the proposed Project to induce substantial
population growth in an area, either directly(e.g.,by proposing new homes and businesses) or indirectly
(e.g., through extension of roads or other infrastructure). (DEIR p. 3.12-5.)
Facts in Support of the Finding: The Project is commercial in nature, including uses such as retail,
commercial, fast-food/restaurant and administrative/office on approximately 32.9 acres at the southeast
comer of San Bernardino Avenue and Tennessee Street. The Project does not propose any new housing
on- or off-site. The Redlands Crossing Walmart would be expected to create approximately 206 new
job positions. This includes the creation of 85 new job positions at the new Walmart store and
approximately 121 new job positions for Parcels I to 9. In addition, 230 of the existing jobs at the
existing Walmart store would be moved to the new Walmart store, from the potential closure of the
existing Walmart store. Consequently, the Project would provide an overall of 436 jobs at the Project
site. Most of the new employment opportunities created by the Project would be entry-level. The
predicted growth of the City of Redlands from 2008 to 2010 is 71,807 to 73,441 residents,which
represents an increase in population by 1,634. Assuming as a worse case scenario that all employees
will come from outside the City,the population influx from the Project represents approximately 26
percent of the City of Redlands predicted population growth. This increase in population induced by the
Project is within the SLAG forecasted population for the City of Redlands from 2008 to 2010. (DEIR p.
3.12-5.)
The increased population will need approximately 160 housing units, given the assumption that all the
employees do not already live in houses and the average household rate is 2.71 persons per household in
the City of Redlands. Many of the positions will be filled with residents of the region so that the
induced housing burden will be less than significant. According to SCAG estimates, the City of
Redlands had 24,885 housing units in 2005. The 2010 estimate is 26,471 housing units, an increase of
1,586 units (or approximately a 6 percent increase in total inventory). The increase in number of
housing units from the Project(160 units)represents approximately 10 percent of the total projected
housing units increase(1,586 units) for the City of Redlands in 2010. Thus, the additional housing units
necessary are insignificant compared to the available housing market, and there is sufficient housing
supply to house the increase in employees. (DEIR p. 3.12-5.)
Impact PH-2: Would the proposed Project displace substantial numbers of existing housing,
necessitating the construction of replacement housing elsewhere?
Finding: Potential impacts of the Project due to Population and Housing are discussed in detail in
Section 3.12 of the Draft EIR. Based on the entire record before it, the City finds no significant impact
related to the potential for the proposed Project to displace substantial numbers of existing housing,
necessitating the construction of replacement housing elsewhere. (DEIR p. 3.12-6.)
32
City of Redlands-Redlands Crossing Project
Facts,Findings,and Statement of Overriding Considerations
Related to the Final Environmental Impact Report
Facts in Support of the Finding: The Project site does not have existing housing units; therefore, the
proposed development would not result in the displacement of housing. Moreover,implementation of
the Project does not contemplate any off-site development activity that may eliminate or adversely affect
existing housing supplies(or require the development of replacement housing). Therefore,the Project
would result in no impact on existing housing. (DEIR p. 3.12-6.)
Impact PH-3: Would the proposed Project displace substantial numbers of people necessitating the
construction of replacement housing elsewhere?
Finding: Potential impacts of the Project due to Population and Housing are discussed in detail in
Section 3.12 of the Draft EIR. Based on the entire record before it, the City finds no significant impact
related to the potential for the proposed Project displace substantial numbers of people necessitating the
construction of replacement housing elsewhere. (DEIR p. 3.12-6.)
Facts in Support of the Finding: As discussed in Impact PH-2, implementation of the Project would
not displace any existing houses or people. Therefore,the potential impact related to the displacement
of an existing population or need to develop replacement housing is less than significant. (DEIR p.
3.12-6.)
Impact PH-4: Would the proposed Project conflict with regional growth policies established by the
Southern California Association of Governments (SCAG) as they relate to population,housing, and
employment in the Project area?
Finding: Potential impacts of the Project due to Population and Housing are discussed in detail in
Section 3.12 of the Draft EIR. Based on the entire record before it, the City finds the Project would
have a less than significant impact related to the potential for the proposed Project to conflict with
regional growth policies established by the Southern California Association of Governments (SCAG) as
they relate to population, housing, and employment in the Project area. (DEIR pp. 3.12-7 to 3.12-10.)
Facts in Support of the Finding: SCAG provided a comment letter on the Project. The IGR section,
part of the Environmental Planning division of SCAG's Planning and Policy, is responsible for
performing consistency review of regionally significant local plans,projects, and programs with SCAG's
adopted regional plans. According to SCAG's NOP comment letter(See Appendix A of the EIR for
comment letter), SCAG determined that the Project is not regionally significant per SCAG IGR Criteria
and CEQA Guidelines (Section 15206). In addition, SCAG's Regional Growth Principles are provided
in comparison to the proposed Project. (DEIR p. 3.12-7.)
Therefore, implementation of the Project will is consistent with SCAG's Regional Growth Principles
(See Table 3.12-3 in the Draft EIR) and will have a less than significant impact in regards to conflict
with regional growth policies established by SCAG as they relate to population,housing, and
employment in the Project area. (DEIR p. 3.12-10.)
12. Public Services
Impact PS-1: Would the proposed Project result in substantial adverse physical impacts associated with
the provision of new or physically altered governmental facilities, need for new or physically altered
governmental facilities,the construction of which could cause significant environmental impacts, in
order to maintain acceptable service ratios,response times or other performance objectives for Fire
Protection?
33
City of Redlands-Redlands Crossing Project
Facts,Findings,and Statement of Overriding Considerations
Related to the Final Environmental Impact Report
Finding: Potential impacts of the Project related to Public Services are discussed in detail in Section
3.13 of the Draft EIR. Based on the entire record before it, the City finds the Project would have a less
than significant impact related to the potential for the proposed Project to result in substantial adverse
physical impacts associated with the provision of new or physically altered governmental facilities, need
for new or physically altered governmental facilities, the construction of which could cause significant
environmental impacts,in order to maintain acceptable service ratios,response times or other
performance objectives for Fire Protection. (DEIR pp. 3.13-7 to 3.13-8.)
Facts in Support of the Finding: Station No. 263 of the RFD provides primary response for the Project
site. Station No. 263 is located at 263 10 W. Pennsylvania Avenue, which is less than 0.8 mile east of
the Project site. The estimated response time for Station No. 263 to the Project site would be
approximately 1.4 minutes and will not exceed the four-minute RFD average response time(based on an
average speed of 35 miles per hour). Access roads (driveways) are required per the California Fire Code
when any portion of a facility or any portion of an exterior wall of the first story of the building is
located more than 150 feet from fire apparatus access. Continuous fire access roadways and public
hydrants will be provided throughout the Project site in order to allow adequate emergency access.
(DEIR p. 3.13-7.)
The City's municipal code does not provide fire flow requirements or standards. Fire flow requirements
within the City depend upon construction and design factors and are determined after Project plans are
submitted. However, through conversation with the RFD,most projects require a minimum fire flow of
1,500 to 3,000 gallons per minute(GPM). Inadequate fire flow demands would be considered a
significant impact,but are remedied through the proper design of water infrastructure on-site in
coordination with the RFD requirements. In order to offset the incremental costs associated with fire
protection in the City of Redlands, the proposed Project would be required to pay a fire suppression fee
equating to $0.50 per square foot for commercial developments, that would be utilized to fund various
capital improvements and personnel additions. The applicant would pay payment of said fees at the
time of building permit issuance. Further, the Project would contribute money toward ongoing fire
facilities needs through the City's Development Impact Fee program. Therefore, the Project would not
result in physical impacts on the environment from the construction or expansion of fire facilities.
Impacts would be less than significant. (DEIR p. 3.13-7.)
Impact PS-3: Would the proposed Project result in substantial adverse physical impacts associated with
the provision of new or physically altered governmental facilities, need for new or physically altered
governmental facilities,the construction of which could cause significant environmental impacts, in
order to maintain acceptable service ratios, response times or other performance objectives for Schools?
Finding: Potential impacts of the Project related to Public Services are discussed in detail in Section
3.13 of the Draft EIR. Based on the entire record before it, the City finds the Project would have a less
than significant impact related to the potential for the proposed Project to result in substantial adverse
physical impacts associated with the provision of new or physically altered governmental facilities, need
for new or physically altered governmental facilities, the construction of which could cause significant
environmental impacts, in order to maintain acceptable service ratios, response times or other
performance objectives for Schools. (DEIR pp. 3.13-9 to 3.13-10.)
Facts in Support of the Finding: The Project does not contain any residential uses and would not
directly induce population growth. The new employment opportunities created by the Project would not
induce substantial population growth into the Redlands area from outside areas. In addition, Senate Bill
50, dated August 27, 1998, allows that complete mitigation of school related impacts can be covered by
34
City of Redlands-Redlands Crossing Project
Facts,Findings,and Statement of Overriding Considerations
Related to the Final Environmental Impact Report
lawful payment of required school impact fees. According to the Redlands Unified School District,
development impact fees for commercial/industrial construction, total in the amount of$0.47 per square
foot. Impact/mitigation fees are established by each district based on square foot measurements. The
Redlands Unified School District assess construction impact fees at the time of development to assure
each project contributes its equitable share of the cost of providing schools within the Planning Area.
The Project will pay all applicable construction impact fees at the time of building permit issuance and
would therefore not result in physical impacts associated with the provision of or the need for new or
physically/altered governmental facilities. Impacts in this case will be less than significant. (DEIR pp.
3.13-9 to 3.13-10.)
13. Recreation
Impact R-1: Would the proposed Project increase the use of existing neighborhood and regional parks
or other recreational facilities such that substantial physical deterioration of the facility would occur or
be accelerated?
Finding: Potential impacts of the Project related to Recreation are discussed in detail in Section 3.14 of
the Draft EIR. Based on the entire record before it, the City finds the Project would have a less than
significant impact related to the potential for the proposed Project to increase the use of existing
neighborhood and regional parks or other recreational facilities such that substantial physical
deterioration of the facility would occur or be accelerated. (DEIR pp. 3.14-6 to 3.14-7.)
Facts in Support of the Finding: The Project does not contain any residential uses and would not
directly induce population growth. The development is expected to generate approximately 206 new
jobs. This includes the creation of 85 new jobs at the new Walmart store(230 of the existing jobs at the
existing Walmart store will be moved to the new Walmart store). In addition, Parcels 1-9 will create
approximately 121 job positions. Most of the new employment opportunities created by the Project
would be entry-level. The new employment opportunities created by the Project would not induce
substantial population growth into the Redlands area from outside areas. Any increase in population
would be marginal at best as this is a relocation of an existing store and the new jobs created by the
Project's outparcels should be filled by existing residents. Therefore, the potential for generating new
residents and in turn impacting park space such that substantial physical deterioration of the facility
would occur is low. (DEIR pp. 3.14-6 to 3.14-7.)
Additionally, there are four recreational facilities located near the Project site,including the Texonia
Park(approximately 0.18 mile south), the Community Park(approximately 1.06 miles east), the
Jennie Davis Park(approximately 1.1 miles south) and the Ed Hales Park(approximately 1.4 miles
southeast). However,employees are unlikely to frequent parks in close proximity to the Project site
during work hours, and are much more likely to visit parks near their homes on weekends and days off,
which does not constitute a new impact. Furthermore, Ordinance No. 2661 of the Redlands Municipal
Code establishes park and open space fees for new developments within the City of Redlands. In order
to offset the incremental costs associated with recreational facilities in the City of Redlands, the
proposed Project would be required to pay an opens pace/park fee equating to $0.62 per square foot for
commercial developments, that would be utilized to fund exiting or new facility improvements. The
applicant would pay payment of said fees at the time of building permit issuance. Implementation of the
Project will pay all applicable park and open space fees. Accordingly,physical impacts related to
increased use of parks will be less than significant. (DEIR p. 3.14-7.)
35
City of Redlands-Redlands Crossing Project
Facts,Findings,and Statement of Overriding Considerations
'Related to the Final Environmental Impact Report
Impact R-2: Would the proposed Project include recreational facilities or require the construction or
expansion of recreational facilities, which might have an adverse physical effect on the environment?
Finding: Potential impacts of the Project related to Recreation are discussed in detail in Section 3.14 of
the Draft EIR. Based on the entire record before it, the City finds the Project would have a less than
significant impact related to the potential for the proposed Project to include recreational facilities or
require the construction or expansion of recreational facilities, which might have an adverse physical
effect on the environment. (DEIR pp. 3.14-7 to 3.14-8.)
Facts in Support of the Finding: The Project would not include any residential uses and,therefore,
would not result in direct population growth. The new employment opportunities created by the Project
would not induce substantial population growth into the Redlands area from outside areas. Because the
Project would not cause direct or indirect population growth,physical deterioration of recreational
facilities (including local and regional trails) would not occur as a result of Project implementation.
Accordingly, impacts associated with recreational facilities and physical effect on the environment will
be less than significant. (DEIR p. 3.14-7.)
14. Transportation
Impact T-2: Would the proposed Project result in a change in air traffic patterns,including either an
increase in traffic levels or a change in location that results in substantial safety risks?
Finding: Potential impacts of the Project related to Transportation are discussed in detail in Section 3.15
of the Draft EIR. Based on the entire record before it, the City finds the Project would have a less than
significant impact related to the potential for the proposed Project to result in a change in air traffic
patterns, including either an increase in traffic levels or a change in location that results in substantial
safety risks. (DEIR pp. 3.15-113 to 3.15-114.)
Facts in Support of the Finding: The Project site is located approximately 1.8 miles southeast of San
Bernardino International Airport and is not located within the approach or takeoffpattern areas of the
airport. The proposed building height will be approximately 40 feet above grade and will not include
any characteristics considered potentially hazardous to aviation(e.g., intense, distracting lighting; major
sources of dust, steam, or electrical interference; or features that attract birds). Therefore,no changes to
air traffic patterns would occur and impacts will be less than significant. (DEIR p. 3.15-113.)
Impact T-3: Would the proposed Project substantially increase hazards due to a design feature(e.g.,
sharp curves or dangerous intersections)or incompatible uses (e.g., farm equipment)?
Finding: Potential impacts of the Project related to Transportation are discussed in detail in Section 3.15
of the Draft EIR. Based on the entire record before it, the City finds the Project would have a less than
significant impact related to the potential for the proposed Project substantially increase hazards due to a
design feature(e.g., sharp curves or dangerous intersections) or incompatible uses(e.g., farm
equipment). (DEIR pp. 3.15-114 to 3.15-131.)
Facts in Support of the Finding: According to the TIA (UC 2011), the Project would implement five
(5)access points serving the Project site. The Project is proposed to have access on Tennessee Street via
Driveway 1, San Bernardino Avenue via Driveway 3, Pennsylvania Avenue via Driveways 2 and 4 and
New York Avenue via Driveway 5. All Project driveways are proposed to have full access and clear
lines of sight. As part of the development, the Project plans to construct a minimum of one-travel lane
in each direction on Pennsylvania Avenue and New York Avenue in addition to half-section roadway
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Related to the Final Environmental Impact Report
improvements on the Project adjacent roads of San Bernardino Avenue and Tennessee Street. It should
be noted that the construction of Pennsylvania Avenue along the Project frontage will not connect to the
existing Pennsylvania Avenue east of Karon Street. Roadway improvements necessary to provide site
access and onsite circulation are assumed to be constructed in conjunction with site development and are
described below. These improvements will be completed concurrently with occupancy of the Project.
In addition, the Project does not propose any circulation features that may create hazards(e.g.,
roundabout,hairpin turns, etc.). Street improvement plans will be submitted to the City for review and
approval prior to construction. In addition, all street improvements are required to be consistent with all
applicable City design standards. Therefore,the Project would not create any roadway hazards. Impacts
would be less than significant. (DEIR p. 3.15-114.)
However, traffic conditions during construction of the Project will generate traffic related to
construction employees and equipment, and hauling fill and construction material to and from the site.
The highest volumes of construction traffic will occur during the period when the Project site is graded
and the hauling of import and export soil or construction material will occur. Typically,weekday
construction activities would occur between 7:00 a.m. and end around 3:00 p.m.,which typically
consists of construction workforce trips arriving at the Project. Construction activities are temporary
and these trips would cease once the Project is completed. As such, due to the temporary nature of the
construction, construction traffic would not represent a significant impact to intersection,roadway
segment, or queuing impacts on local roadways. (DEIR p. 3.15-114.)
In addition, although truck radii is part of a design feature for this Project and is not a hazard, which
includes sharp curves or dangerous intersections, none the less, the Project could have potential impacts
to hazardous from delivery truck access to the site and circulation behind the proposed Walmart store.
Consequently, the TIA analyzed potential impacts from delivery truck access to the Project site and
circulation behind the proposed Walmart store. Exhibit 3.15-9 of the Draft EIR illustrates delivery truck
access for the site and circulation for each of the proposed Project driveways. Due to the typical wide
turning radii of these large delivery trucks, a truck turning template has been overlaid on the proposed
site plan at each Project driveway anticipated to have heavy trucks in order to determine appropriate
curb radii and to verify that delivery trucks will have sufficient space to execute turning maneuvers to
pull into and out of loading docks. Typically, Walmart stores receive their deliveries from Walmart
distribution centers which utilize large delivery trucks, such as the WB-67 class(Semitrailer truck,
overall wheelbase of 67 ft),which is the largest semi-trailer rig. The deliveries for outparcels typically
originate from local distribution centers and are traditionally served by WB-50 class (Semitrailer truck,
overall wheelbase of 50 ft) or smaller box trucks. As such, it is anticipated that deliveries made to the
other outparcels in the Redlands Crossings Center would be made via WB-50 trucks(to be most
conservative). Each Project access point is discussed below, identifying the necessary curb radii to
accommodate either a WB-50 or WB-67 delivery truck. (DEIR pp. 3.15-114 to 3.15-115.)
Exhibit 3.15-10 of the Draft EIR illustrates the truck access circulation at Driveway I on Tennessee
Street. It is anticipated that this driveway would be utilized by WB-50 trucks (or smaller)making
deliveries to outparcels within the Redlands Crossings Center. A curb radius of 35-feet on the northeast
and southeast comers appears to be sufficient to accommodate the ingress and egress of a WB-50 truck.
In addition,both Tennessee Street and Driveway I would provide sufficient roadway width to
accommodate the wide turns. (DEIR p. 3.15-115.)
Exhibit 3.15-11 of the Draft EIR illustrates the truck access circulation at Driveway 2 on Pennsylvania
Avenue. It is anticipated that this driveway would be utilized by WB-50 trucks(or smaller)making
deliveries to outparcels within the Redlands Crossings Center. The curb radius of 35-feet on the
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northwest comer would be sufficient to accommodate the egress of a WB-50 truck. In addition, both
Pennsylvania Avenue and Driveway 2 provide sufficient roadway width to accommodate the wide turns,
with the exception of the inbound trucks. As shown on Exhibit 3.15-11 of the Draft EIR the trailer for
eastbound left-turning trucks entering the site would cross over the southbound left turning lane.
However, it is anticipated that this would not significantly impact exiting vehicles as this driveway is a
secondary access point with nominal Project traffic. (DEIR p. 3.15-115.)
Exhibit 3.15-12 of the Draft EIR illustrates the truck access circulation at Driveway 3 on San Bernardino
Avenue. It is anticipated that this driveway would be utilized by WB-50 trucks(or smaller)making
deliveries to outparcels within the Redlands Crossings Center. The curb radius of 35-feet on the
southwest and southeast comers would be sufficient to accommodate the ingress and egress of a WB-50
truck. In addition,both San Bernardino Avenue and Driveway 3 provide sufficient roadway width to
accommodate the wide turns. (DEIR p. 3.15-115.)
Exhibit 3.15-13 of the Draft EIR illustrates the truck access circulation at Driveway 4 on Pennsylvania
Avenue. Driveway 4 on Pennsylvania Avenue has been assumed to be utilized for deliveries to the
proposed Walmart as it provides direct access to the proposed Walmart store and would minimize these
large trucks from having to navigate through the site. As such, this driveway should be designed with
appropriate curb cuts to allow for the ingress and egress of large delivery trucks. Due to the typical wide
turning radius of these large delivery trucks, a turning template for a WB-67 truck has been overlaid on
the site plan at Driveway 4 on Pennsylvania Avenue in order to determine appropriate curb radii and to
verify that Walmart delivery trucks will have sufficient space to execute turning maneuvers to pull into
and out of loading docks. As shown,the curb radius of 35-feet on the northwest comer would be
sufficient to accommodate the egress of both a WB-67 and WB-50 truck. In addition,both Pennsylvania
Avenue and Driveway 4 provide sufficient roadway width to accommodate the wide turns, with the
exception of the inbound trucks. As shown on Exhibit 3.15-13 of the Draft EIR the trailer for eastbound
left-turning trucks entering the site would cross over the southbound left turning lane. However, it is
anticipated that this would not significantly impact exiting vehicles as this driveway is a secondary
access point with nominal Project traffic. The curb radii at the drive aisle east of Driveway 4 would also
be adequate to accommodate WB-67 trucks accessing the loading docks behind the proposed Walmart.
(DEIR p. 3.15-116.)
Exhibit 3.15-14 of the Draft EIR illustrates the truck access circulation at New York Avenue on San
Bernardino Avenue. It is anticipated that WB-67 trucks would travel through this intersection to get to
and from Driveway 5 on New York Avenue. As such, this intersection would be designed with
appropriate curb cuts to allow for the ingress and egress of large delivery trucks. As shown a curb
radius of 50-feet on the southwest comer would have sufficient to accommodate the ingress of a WB-67
truck. (DEIR p. 3.15-116.)
Exhibit 3.15-15 of the Draft EIR illustrates the truck access circulation at Driveway 5 on New York
Avenue. Driveway 5 on New York Avenue has been assumed to be utilized for deliveries to the
proposed Walmart as it provides direct access to the proposed Walmart store and would minimize these
large trucks from having to navigate through the site. As such, this driveway would be designed with
appropriate curb cuts to allow for the ingress and egress of large delivery trucks. Due to the typical wide
turning radius of these large delivery trucks, a turning template for a WB-67 truck has been overlaid on
the site plan at Driveway 5 on New York Avenue in order to determine appropriate curb radii and to
verify that Walmart delivery trucks will have sufficient space to execute turning maneuvers to pull into
and out of loading docks. The curb radius of 50-feet on the northwest comer would be sufficient to
accommodate the ingress of a WB-67 truck. In addition, both New York Avenue and Driveway 5
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provide sufficient roadway width to accommodate the wide turns. The curb radii at the drive aisle south
of Driveway 5 would also be adequate to accommodate WB-67 trucks accessing the loading docks
behind the proposed Walmart. (DEIR p. 3.15-116.)
Therefore, impacts in regards to delivery truck accessing the Project site and circulation behind the
proposed Walmart store will be less than significant. (DEIR p. 3.15-131.)
Impact T-4: Would the proposed Project result in inadequate emergency access?
Finding: Potential impacts of the Project related to Transportation are discussed in detail in Section 3.15
of the Draft EIR. Based on the entire record before it, the City finds the Project would have a less than
significant impact related to the potential for the proposed Project to result in inadequate emergency
access. (DEIR p. 3.15-131.)
Facts in Support of the Finding: I-10 and SR-210 provide regional access to the Project area while
various roadways near the Project site provide local access and primarily serve the existing area. As part
of Project development,roadways and signals will be improved in the Project area and the Project will
provide adequate emergency access in all phases of development as indicated in the conceptual site plan.
In addition, the Project applicant will comply with applicable Fire Department and Department of
Building and Safety regulations relating to emergency access. Therefore, impacts in this regard will be
less than significant. (DEIR p. 3.15-131.)
15. Utilities and Service Systems
Impact U-1: Would the proposed Project exceed wastewater treatment requirements of the applicable
Regional Water Quality Control Board?
Finding: Potential impacts of the Project related to Utilities and Service Systems are discussed in detail
in Section 3.16 of the Draft EIR. Based on the entire record before it, the City finds the Project would
have a less than significant impact related to the potential for the proposed Project to exceed wastewater
treatment requirements of the applicable Regional Water Quality Control Board. (DEIR pp. 3.16-10 to
3.16-11.)
Facts in Support of the Finding: Short-term construction and operation of the Project would
marginally increase demands on wastewater treatment services within the City. The Redlands
Municipal Utilities and Engineering Department(RMUED) treats wastewater treatment for the City of
Redlands. The Project will tie in to the nearest wastewater line, which is located immediately adjacent
to the site. The RMUED operates approximately 5.6 million gallons per day of wastewater treatment
and has a capacity of 9.5 million gallons per day. Development of the Project will involve an on-site
system for the collection of wastewater for conveyance to off-site public wastewater facilities.
Wastewater conveyed from the site, totaling 4,910 gallons per day(see Impact U-2 for additional
information in this regard)would ultimately reach RMUED's wastewater treatment facility, located
south of the Santa Ana River and north of Nevada Street(Specifically located at 1950 N Nevada Street),
where it would undergo treatment in accordance with applicable regulations, including the requirements
of the Water Quality Control Plan, for Santa Ana Region 5. The Regional Board's regulatory tools
include National Pollutant Discharge Elimination System permits, Waste Discharge Requirements,
Water Reclamation Requirements, Water Quality Certification, and Waste Discharge Prohibitions.
Implementation of the Project will be consistency with the aforementioned regulatory tools, ensuring
that implementation of the Project will be consistent with the Santa Ana Region 5 Water Quality Control
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Related to the Final Environmental Impact Report
Plan and will not exceed wastewater treatment requirements of the Board. Therefore, impacts in this
regard will be less than significant. (DEIR p. 3.16-10.)
Impact U-2: Would the proposed Project require or result in the construction of new water or
wastewater treatment facilities or expansion of existing facilities, the construction of which could cause
significant environmental effects?
Finding: Potential impacts of the Project related to Utilities and Service Systems are discussed in detail
in Section 3.16 of the Draft EIR. Based on the entire record before it, the City finds the Project would
have a less than significant impact related to the potential for the proposed Project to require or result in
the construction of new water or wastewater treatment facilities or expansion of existing facilities, the
construction of which could cause significant environmental effects. (DEIR pp. 3.16-11 to 3.16-12.)
Facts in Support of the Finding: The Project's water consumption estimate is provided in Table 3.16-4
of the Draft EIR. As shown, the Project is anticipated to demand 14,817 gallons of water on a daily
basis. The 2010 San Bernardino Valley Regional Urban Water Management Plan concluded that
sufficient water supply is available between 2010 and 2030 to serve all customers within the City of
Redlands; refer to Table 3.16-2 (See Section 3.16.2, Existing Conditions, for Table 3.16-2) of the Draft
EIR. The Project is consistent with the Land Use and Zoning designations for the Project site and will
therefore be served with adequate long-term water supply. In addition, as previously outlined within
Table 3.16-2, the current and planned water supplies for the City of Redlands includes 31,479-acre feet
per year for the year 2010 and 43,120-acre feet per year for the year 2030. Consequently,
implementation of the Project will consume approximately 0.00000014 to 0.00000011 percent of the
available water supply for the year 2010 and 2030, respectively. Therefore, implementation of the
Project will not require or result in the construction of new water treatment facilities or expansion of the
existing facility. (DEIR p. 3.16-11.)
As the Project site is currently undeveloped, implementation of the proposed Project would require
wastewater treatment over and above the pre-developed condition. No project specific wastewater
generation rates were available for the proposed project. Typically, wastewater generation can be up to
70 to 90 percent of consumption. Using a conservative estimate of 90 percent,the Project's daily
wastewater generation estimate is provided in Tale 3.16-5 of the Draft EIR. As shown,the Project is
anticipated to generate 4,910 gallons of water on a daily basis. This figure is based on the assumption
that wastewater represents 90 percent of domestic water use, which is consistent with industry standards
and based on the applicant's submittal materials. (DEIR pp. 3.16-11 to 3.16-12.)
The proposed development will include an on-site system for the collection of wastewater and
conveyance to off-site existing WRP. The existing wastewater flows for the City's WRP are
approximately 5.6 mgd. The overall capacity of the WRP is 9.5 mgd. Consequently, implementation of
the Project will increase wastewater generation by approximately 0.001 percent over the existing 5.6
mgd, which is well below the 9.5 mgd overall capacity of the WRP. Therefore,implementation of the
Project will not require or result in the construction of new wastewater treatment facilities or expansion
of the existing facility. Impacts will be less than significant. (DEIR p. 3.16-12.)
Impact U-3: Would the proposed Project require or result in the construction of new storm water
drainage facilities or expansion of existing facilities, the construction of which could cause significant
environmental effects?
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City of Redlands-Redlands Crossing Project
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Finding: Potential impacts of the Project related to Utilities and Service Systems are discussed in detail
in Section 3.16 of the Draft EIR. Based on the entire record before it, the City finds the Project would
have a less than significant impact related to the potential for the proposed Project to require or result in
the construction of new storm water drainage facilities or expansion of existing facilities,the
construction of which could cause significant environmental effects. (DEIR pp. 3.16-12 to 3.16-13.)
Facts in Support of the Finding: The proposed development of the site will result in an incremental
increase in stormwater. The infiltration of the presently undeveloped site will be decreased by
construction of the Project, which will be covered by impervious surfaces. Currently,the Project site
does not have any stormwater drainage facilities and so will require the expansion of the existing local
storm water drainage system. The Project design include various features (underground infiltration
basins, several vegetated swales, vegetative buffers and surface level infiltration basin)which will
reduce the potential storm water runoff and/or the velocity of such runoff from the Project site.
Development will also require coverage under SWRCB NPDES permit, General Permit for Storm Water
Discharges Associated with Construction Activity(Construction Activity General Permit), since the
Project will disturb more than one acre of the land. (DEIR p. 3.16-13.)
Therefore, compliance with all applicable stormwater regulations and incorporation of appropriate storm
water control features in the Project design will reduce the impacts related to capital improvements of
stormwater facilities to less than significant level. (DEIR p. 3.16-13.)
Impact U-4: Would the proposed Project have sufficient water supplies available to serve the project
from existing entitlements and resources, or are new or expanded entitlements needed?
Finding: Potential impacts of the Project related to Utilities and Service Systems are discussed in detail
in Section 3.16 of the Draft EIR. Based on the entire record before it, the City finds the Project would
have a less than significant impact related to the potential for the proposed Project to have insufficient
water supplies available to serve the project from existing entitlements and resources. (DEIR pp. 3.16-
13 to 3.16-14.)
Facts in Support of the Finding: California Water Code Section 10910 through 10915 requires that a
Water Supply Assessment be prepared for any project containing a shopping center or business
establishment employing more than 1,000 persons or having more than 500,000 square feet of floor
space. The Project proposes to develop 215,000 square feet for the proposed Walmart, 60,500 square
feet for outparcels 1-9, totaling 275,500 square feet. In addition, implementation of the Project will
generate approximately 436 new jobs. Therefore, the Project is below the 500,000 square feet of floor
use, 1,000-employee and is not required to provide a Water Supply Assessment. (DEIR p. 3.16-13.)
Water consumption would be consumed from short-term construction activities and long-term
operational activities. Short-term construction water consumption from development of the proposed
Project would be spread out over the length of construction activities and would not occur all at once.
The actual volume of water consumption of at any one time is not expected to pose a significant impact
to water supply. (DEIR pp. 3.16-13 to 3.16-14.)
The Project will tie in to the nearest water line, which is located immediately adjacent to the site. The
Project's water consumption estimate is provided in Table 3.16-4(see Impact Analysis U-2). As shown
in the Table 3.16-4 of the Draft EIR, the Project is anticipated to demand 14,817 gallons of water on a
daily basis. As previously described, the 2010 San Bernardino Valley Regional Urban Water
Management Plan concluded that sufficient water supply is available between 2010 and 2030 to serve all
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Related to the Final Environmental Impact Report
customers within the City of Redlands; refer to Table 3.16-2 of the Draft EIR. The Project is consistent
with the Land Use and Zoning designations for the Project site and will therefore be served with
adequate long-term water supply. In addition, as previously outlined within Table 3.16-2,the current
and planned water supplies for the City of Redlands includes 31,479-acre feet per year for the year 2010
and 43,120-acre feet per year for the year 2030. Consequently, implementation of the Project will
consume approximately 0.00000014 to 0.00000011 percent of the available water supply for the year
2010 and 2030,respectively. (DEIR p. 3.16-14.)
In addition, the Project would reduce its demand on water supply through the implementation of various
indoor and outdoor water conservation measures detailed in the Project's sustainability features
discussed in detail in Section 2, Project Description, of the Draft EIR. Specifically,water conservation
measures recommended by the California Department of Water Resources, as well as the City's
landscape ordinance, will be incorporated into the Project as appropriate, including but not limited to: a)
low flush toilets of no greater than 1.6 gallons per flush and b) keeping water pressure at 55 pounds per
inch or less. Some portion of the landscaping, especially shrubs and trees, may be native species or
species that are adapted to drought conditions. However,the commercial nature of the project means
that a good portion of each lot will likely be asphalt, concrete, and minimal turf,which will have a"low"
water consumption. (DEIR-p. 3.16-14.)
Additionally, while not required to reduce this impact to less than significant, mitigation measure MM
HWQ-2a through HWQ-2c requires the applicant to install outdoor irrigation and indoor domestic water
conservation measures and practices and plumb landscaped areas with"purple pipe"prior to issuance of
the certificate of occupancy for the Walmart store to allow for recycled water irrigation. These
measures would reduce overall Project demand for potable water and further ensure that long-term water
supply impacts are less than significant. (DEIR p. 3.16-14.)
Impact U-5: Would the proposed Project result in a determination by the wastewater treatment
provider,which serves or may serve the project that it has adequate capacity to serve the project's
projected demand in addition to the provider's existing commitments?
Finding: Potential impacts of the Project related to Utilities and Service Systems are discussed in detail
in Section 3.16 of the Draft EIR. Based on the entire record before it, the City finds the Project would
have a less than significant impact related to the potential for the proposed Project to result in a
determination by the wastewater treatment provider, which serves or may serve the project that it has
adequate capacity to serve the project's projected demand in addition to the provider's existing
commitments. (DEIR p. 3.16-15.)
Facts in Support of the Finding: The Project's daily wastewater generation estimate is provided in
Tale 3.16-5 of the Draft EIR(see Impact Analysis U-2). As shown, the Project is anticipated to generate
4,910 gallons of water on a daily basis. This figure is based on the assumption that wastewater
represents 90 percent of domestic water use, which is consistent with industry standards and based on
the applicant's submittal materials. The Proposed development will include an on-site system for the
collection of wastewater and conveyance to off-site existing WRP. The existing wastewater flows for
the City's WRP are 5.6 mgd. The overall capacity of the WRP is 9.5 mgd. Consequently,,
implementation of the Project will increase wastewater generation by approximately 0.001 percent over
the existing 5.6 mgd,which is well below the 9.5 mgd overall capacity of the WRP. Therefore, the City
of Redlands WRP will have adequate capacity to serve the Project and impacts in this regard will be less
than significant. (DEIR p. 3.16-15.)
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Impact U-6: Would the proposed Project be served by a landfill with sufficient permitted capacity to
accommodate the Project's solid waste disposal needs?
Finding: Potential impacts of the Project related to Utilities and Service Systems are discussed in detail
in Section 3.16 of the Draft EIR. Based on the entire record before it, the City finds the Project would
have a less than significant impact related to the potential for the proposed Project to be served by a
landfill with insufficient permitted capacity to accommodate the Project's solid waste disposal needs.
DEIR pp. 3.16-15 to 3.16-17.)
Facts in Support of the Finding: The City of Redlands Quality of Life Department will provide solid
waste service to the Project site. According to the East Valley Corridor Specific Plan EIR(October
1988),buildout of the Specific Plan would contribute to a significant and unavoidable impact towards
solid waste. However, since 1988, solid waste from Redlands is primarily disposed of at the California
Street Landfill and the San Timoteo Sanitary Landfill. (DEIR p. 3.16-15.)
Solid waste would be generated by short-term construction activities and long-term operational
activities. Short-term construction waste generation from development of the proposed Project would be
spread out over the length of construction activities and would not occur all at once. The actual volumes
of construction waste disposed of at any one time is not expected to be more than I or 2 tons of debris
and would not pose a significant impact to landfill capacity. (DEIR p. 3.16-15.)
California Integrated Waste Management Board(CIWMB 2011)provides the estimates for a standard
commercial/retail waste generation rate to be 4.8 pounds per square foot per year. Based on CWIMB
solid waste generation rate,the Project would generate roughly 661 tons of solid waste per annum(4.8
pounds by 275,500 square feet). California Street Landfill and San Timoteo Sanitary Landfill have a
combined remaining capacity of more than 16 million cubic yards. The potential impact associated with
the solid waste generated from the Project is less than significant in light of the total remaining capacity
of landfill sites. (DEIR p. 3.16-16.)
In addition, actual solid waste generation would be expected to be less than 661 tons per annum as
Walmart stores are equipped with recycling facilities and are designed to limit waste of recyclable
material by implementing innovative strategies. (DEIR p. 3.16-16.)
Walmart stores are equipped to recycle the following materials: Aluminum; Plastic(including bottles,
bags, garment bags,shrink wrap, and bubble pack); Glass; Cardboard; Vegetable oil; Single-use
cameras; Electronic waste; and Silver(from photo processing). (DEIR p. 3.16-16.)
Similarly, followings are some of the innovative strategies implemented to limit waste as standard
features: All cardboard generated from delivery packages is segregated and sent to a recycling center;
Each new store has an indoor tank used to collect oil from cooking processes for recycling; All Walmart
photo processing centers recycle single-use cameras after photo processing; Walmart collects and
segregates all recyclable bottles and cans; Walmart currently implements a chain wide program for
"sandwich bale"recycling of plastics, e.g.,bags, garment bags, shrink wrap,bubble pack, etc.; Walmart
photo labs capture silver from the photo processing. (DEIR p. 3.16-16.)
Therefore, as discussed above the landfill sites serving the Project has sufficient permitted capacity to
accommodate the Project's solid waste disposal need and impacts in this regard will be less than
significant. (DEIR p. 3.16-16.)
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.Related to the Final Environmental Impact Report
Impact U-7: Would the proposed Project comply with federal, state, and local statutes and regulations
related to solid waste?
Finding: Potential impacts of the Project related to Utilities and Service Systems are discussed in detail
in Section 3.16 of the Draft EIR. Based on the entire record before it, the City finds the Project would
have a less than significant impact related to the potential for the proposed Project in regards to not
complying with federal, state, and local statutes and regulations related to solid waste. (DEIR pp. 3.16-
17 to 3.16-IS.)
Facts in Support of the Finding: The Project will be required to abide by all federal, state and local
statues and regulations regarding solid waste. The Project does not contemplate or anticipate short-term
construction or long-term operational activities/uses that would exceed or otherwise require special
consideration in relation to compliance with relevant solid waste handling/disposal statues and
regulations. In addition,on January 12, 2010,the State Building Standards Commission unanimously
adopted updates to the California Green Building Standards Code, which went into effect on January 1,
2011. The Code is a comprehensive and uniform regulatory code for all residential, commercial and
school buildings. The California Green Building Standards Code requires a minimum 50-percent
diversion of construction and demolition waste from landfills, increasing voluntarily to 65 and-75
percent for new homes and 80-percent for commercial projects. Most of the Walmart would be
constructed using recycled steel. In addition, all of the plastic baseboards, and much of the plastic
shelving, are manufactured from recycled material. The Walmart store would also be equipped to
accept the following materials for recycling: aluminum; plastic (including bottles,bags, garment bags,
shrink wrap, and bubble pack); glass; cardboard; vegetable oil; motor oil; tires; auto batteries; single-use
cameras; electronic waste; silver(from photo processing). Therefore, impacts in this regard will be less
than significant and no mitigation is required. (DEIR p. 3.16-17; FEIR p. 4-5.)
Furthermore, a Phase 11 ESA was conducted at the Project site located on the 20-acre portion of land at
the west comer of the Project site, adjacent to Tennessee Street and San Bernardino Avenue. The
purpose of the Phase 11 ESA was to collect and analyze soil samples in selected areas of the Project site
to identify the presence or confirm the absence of pesticides contamination at those locations and screen
any detected chemicals for potential risk. The Phase 11 ESA concluded that with exception of two soil
samples, all soil samples contained detectable concentrations of(Dichlorodiphenyldichloroethylene)
DDE. In addition, with exception to four soil samples, all analyzed soil samples contained detectable
concentrations of(Dichlorodiphenyltrichloroethane)DDT. However, according to the Phase 11 ESA, all
detected pesticide concentrations (DDE and DDT) are well below their respective residential soil (1.7
mg/kg) and industrial soil(7 m&kg) EPA Preliminary Remediation Goals (PRG). Therefore, the
reported pesticide concentrations are significantly below the PRGs established by the EPA and may
likely represent ambient"background"concentrations. Therefore, development of the Project will not
include the transfer of soils to an off-site location eligible to accept contaminated soils. Impacts will be
less than significant. (DEIR pp. 3.16-17 to 3.16-18.)
16. Greenhouse Gases
Impact GHG-2: Would the proposed Project conflict with any applicable plan,policy or regulation of
an agency adopted for the purpose of reducing the emissions of greenhouse gases?
Finding: Potential impacts of the Project related to Greenhouse Gases are discussed in detail in Section
3.17 of the Draft EIR. Based on the entire record before it, the City finds the Project would have a less
than significant impact related to the potential for the proposed Project to conflict with any applicable
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Related to the Final Environmental Impact Report
plan, policy or regulation of an agency adopted for the purpose of reducing the emissions of greenhouse
gases. (DEIR pp. 3.17-33 to 3.17-34.)
Facts in Support of the Finding: Although it does not contain specific requirements for regulations for
new or existing developments, the Sustainability Plan has applicable targets and actions as shown in
Table 3.17-15, City of Redlands Sustainability Plan Targets and Actions. These are items that the City
will develop implementing regulations and requirements over time. Many of the Walmart design
features highlighted on Table 3.17-15 of the Draft EIR are in accord the purposes of the sustainability
plan include numerous efforts to conserve energy, conserve water and reduce waste. (DEIR pp. 3.17-33
to 3.17-34.)
The California State Legislature adopted AB 32 in 2006. AB 32 focuses on reducing greenhouse gases
(carbon dioxide,methane,nitrous oxide,hydrofluorocarbons, perfluorocarbons, and sulfur hexafluoride)
to 1990 levels by the year 2020. Pursuant to the requirements in AB 32, the ARB adopted the Climate
Change Scoping Plan(Scoping Plan)in 2008, which outlines actions recommended to obtain that goal.
The Scoping Plan contains a variety of strategies to reduce the State's emissions,which are not
applicable to the Project as shown in the Air Quality and Greenhouse Gas Analysis Report (Appendix
B). One of the Scoping Plan measures, #6 Regional Transportation-Related Greenhouse Gas Targets,
refers to SB 375. The Project is consistent with the intent of SB 375 to reduce per capita vehicle miles
traveled by locating a regional shopping center adjacent to existing transportation corridors and will
include pedestrian walkways, bicycle parking, and a new bus station. (DEIR p. 3.17-34.) Therefore, the
Project will not conflict with any applicable plan, policy or regulation pertaining to GHG emissions, and
impacts will be less than significant.
17. Urban Decay
Impact UD-I: Would the proposed Project create long-term store vacancies or result in the
abandonment of buildings within the retail market served by the Project?
Finding: Potential impacts of the Project related to Urban Decay are discussed in detail in Section 3.18
of the Draft EIR. Based on the entire record before it, the City finds no significant impact related to the
potential for the proposed Project to create long-term store vacancies or result in the abandonment of
buildings within the retail market served by the Project. (DEIR pp. 3.18-13 to 3.18-19.)
Facts in Support of the Finding: This impact area assesses the Project's potential affects on urban
decay with respect to competing retailers within the defined trade areas. Each of the various
components of the Project is addressed individually below. (DEIR p. 3.18-13.)
IMpact of Walmart Grocery Component- The proposed Walmart store is estimated to include up to
43,373 square feet of grocery space. Based on the size and configuration of the proposed store, TNDG
projected that the grocery component of the store would generate sales of approximately$614 per
square foot of building space, or approximately$26.6 million in annual grocery sales. (DEIR p. 3.18-
13.)
By evaluating the trade area demographic characteristics and the typical portion of household income
spent on supermarket goods,TNDG estimated that the year 2010 sales potential for existing
supermarkets within the CRTA was $480 per square foot. In comparison, the median sales performance
measures for supermarkets in the U.S. and the Western U.S. are approximately$473 and$418 per
square foot,respectively. (DEIR p. 3.18-13.)
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Total demand for supermarket sales in the trade area is projected to increase from approximately$324.2
million in 2010 to approximately $337.0 million in 2013, the assumed opening date of the Project. By
2020, total demand for supermarket sales in the trade area is projected to reach approximately$369.0
million(all projections are given in 2010 constant dollars). Table 3.18-3 of the Draft EIR evaluates the
impact of the Walmart's grocery sales in terms of the potential reduction in the sales per square foot
volume at the 18 existing supermarkets. (DEIR p. 3.18-13.)
The current potential sales volumes of the existing stores is estimated to be slightly above the industry
median (for supermarkets in the U.S.) of about$473, suggesting that the existing stores are—on average
—performing in line with the typical sales volumes of supermarkets nationwide. Thus,it is likely that
the supermarket component of the Project would result in reduced sales volumes at the existing stores.
Assuming the supermarket component of the Walmart store opens in 2013, a significant portion of its
initial sales would be derived from sales diversions from existing stores in the CRTA. TNDG Projects
that, with the opening of the Project in 2013,the potential sales volumes at the existing supermarkets in
the CRTA would decrease to an average of$459 per square foot, representing a reduction of 4.3 percent
from the existing sales per square foot average of$480 (see Table 3.18-3 in the Draft EIR). However,
projected growth in trade area demand would be sufficient for the sales volumes at the existing
supermarkets to recover to approximately 97 percent of existing levels by 2014(i.e., one year after the
Project's first full year of operation). (DEIR p. 3.18-14.)
The development of the Walmart supermarket component is unlikely to cause any existing supermarkets
in the trade area to close, given that average sales volumes at the existing supermarkets in the trade area
would never drop below 95 percent of the 2010 level. Moreover, sales volumes are projected to recover
to 97 percent of existing levels within one year of the Project's first full year of operations, and to 100
percent in 2016 (i.e.,within three years of the Project's first full year of operation). Since the estimated
short term, (pre 2016)reduction in sales for the existing stores is not expected to result in store closure
over either the short or long term; potential adverse impacts for the grocery component of the Project
with respect to urban decay would be less than significant. (DEIR p. 3.18-14.)
Impact of Project on General Merchandise and Other Retail Sales -The Project would result in a net
increase of 74,327 square feet of retail space devoted to GAFO (General Merchandise, Apparel,
Furniture/Appliances and Other/Specialty). Although the proposed Walmart's general merchandise
space would total approximately 171,627 square feet, a full 126,000 square feet of this amount would
just be a replacement of the existing Walmart on 2050 West Redlands Boulevard. In addition,the
Project would include 28,700 square feet of Other/Specialty space(separate from Walmart). (DEIR p.
3.18-15.)
TNDG provided an analysis of GAFO existing supply and demand which indicated a year 2009 market
support for$478.4 million in GAFO retail sales in the City of Redlands. Existing sales in these retail
categories in the City are estimated at$429.8 million, suggesting that approximately 10 percent of
potential GAFO sales in the City are currently being lost to other jurisdictions. In other words, there is
currently an estimated $48.6 million($478.4 million—$429.8 million) in unrealized GAFO demand in
the City—demand that could be recaptured with the development of additional retail facilities, The
$48.6 million in unrealized demand translates into approximately 13 7,100 square feet of additional
GAFO retail space that could be currently supported in the City. TNDG also estimated projected
growth in demand within the Primary Market Area(the corporate boundaries of Redlands) indicating
that potential demand for new retail space in the GAFO retail categories is projected to grow to
approximately 413,900 square feet by 2013 (the Project's assumed opening date). Net demand for new
GAFO space is projected to grow to approximately 484,900 square feet by 2016. See Table 3.18-4
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below, for a breakdown of supportable square feet within the GAFO retail categories from 2013 to 2025.
(DEIR p. 3.18-15.)
The Project will result in a net increase of 74,327 square feet of GAFO retail space,which will absorb
approximately 18 percent of the residual market support for GAFO space in the trade area in 2013 (the
Project's assumed opening date). Since this represents a relatively small portion of the residual market
support, TNDG indicated that it is unlikely that the GAFO retail components of the Project will result in
severe economic impacts to existing stores in the trade area. Therefore, it is unlikely that any existing
retail stores will be forced to close due to the Project. Since the affects of the Project are not expected to
result in store closures,which could, in turn if occurring over the long term, cause urban decay, the
impact of the GAFO retail components of the Project would be less than significant. (DEIR p. 3.18-16.)
Impact of Proposed Restaurant Space-The Project would include 31,800 square feet of fast food and
sit-down restaurant space. TNDG's demand analysis indicates existing(year 2009)potential market
support for approximately$125.6 million in restaurant sales in the PMA. Existing restaurant sales in the
PMA are estimated at$117.4 million, suggesting that there is currently$8.2 million($125.6 million—
$117.4 million)in unrealized restaurant demand in the PMA. This translates into approximately 20,500
square feet of additional restaurant space that could currently be supported in the PMA. (DEIR p. 3.18-
16.)
Potential demand for new restaurant space in the PMA is projected to grow to approximately 66,700
square feet by 2013 (the Project's planned opening date). Net demand for new restaurant space is
projected to reach approximately 78,000 square feet by 2016. The Project will result in a net increase of
31,800 square feet of restaurant space. Given that residual market support for restaurant space in 2013
(the Project's planned completion date)is more than the twice the amount of planned square fee,the
TNDG report indicates that it is unlikely that the restaurant component of the Project will result in
severe economic impacts to existing restaurants in the trade area. Therefore, it is unlikely that any
existing restaurants will be forced to close due to the Project. Since closure of existing restaurants in the
PMA is not expected to be caused by the Project's introduction of new restaurant space, the potential for
the Project to result in urban decay related to restaurants would be less than significant. (DEIR p. 3.18-
16.)
Impacts of Proposed Fuel Facility-TNDG concluded in their study that the proposed fuel facility with
convenience store and single user self-serve carwash would not have significant impacts on existing
businesses. It is estimated that the service/gas station within the Project would generate sales of
approximately$4.2 million per year, TNDG's analysis indicates existing market support for$78.0
million in annual service station sales in 2009. Service station sales in 2009 were$74.2 million,
suggesting that the supply and demand for gasoline sales in the market is roughly in equilibrium, even if
the service station proposed by the Project were in operation today. Due to growth in the market,
residual demand for service station sales in 2013 would equal approximately$9.9 million,which is more
than sufficient to support the projected service station sales at the Project. Thus,potential sales impacts
to existing service stations are not expected to be significant with respect to urban decay, given that the
Project's service station sales would fit within the available"envelop"of residual or unmet demand.
(DEIR pp. 3.18-16 to 3.18-17.)
Potential for Reuse of Existing Walmart Site- Given that the Project will result in the relocation of the
existing Walmart store located at 2050 West Redlands Boulevard, it is necessary to evaluate the
potential for the existing Walmart building to remain vacant for an extended period of time and thus
becoming subject to physical blighting. The Project will add approximately 232,100 square feet of non-
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grocery retail space that will be needed to be absorbed in the PMA. This total includes the following:
The existina,Walmart building— 126,000 square feet; The net increase in GAFO space proposed for the
new Walmart—45,627 square feet; The Project's specialty merchandise space—28,700 square feet; and
The Project's fast food and restaurant space—31,800 square feet. (DEIR p. 3.18-17.)
Based on the numbers, as shown on Table 3.18-5 in the Draft EIR, TNDG Projects that demand would
be more than sufficient by 2013 (i.e., the assumed opening date of the Project)to fully absorb all the
retail (non-supermarket) space added by the Project and the existing Walmart. The total available retail
space created by the Project, combining the new space from the Project (approximately 106,127 square
feet) with the space in the existing Walmart building(126,000 square feet) sums to approximately
232,127 square feet,while the projected demand (GAFO subtotal) is 372,529 square feet. (DEIR pp.
3.18-17 to 3.18-18.)
Potential Impacts to Redlands Downtown Area- According to the TNDG report, impacts of big box
retailers on small, independent merchants throughout southern and central California may vary widely
depending on the context. Clearly, there are examples of small businesses that have been unable to
compete with big box stores. There are also prominent examples of traditional downtown areas that
have been able to carve out specialized"niches" and continue to thrive despite the entry of big box
competitors. Generally, the difference in results can be explained by three factors: 1. The amount of
resident demand for retail sales in the market area(i.e., whether the big box stores derive their sales
from residual demand or"leakage"versus diverting sales from existing local merchants); 2. The degree
to which trends in the traditional downtown areas were on a positive or negative path prior to the entry
of the big box competitors(i.e., if an established trend of decline is already in evidence, disinvestment
from an area is likely to occur with or without new competition); 3. The degree to which tenants in a
downtown are selling goods directly comparable to those available at competitor big box stores. (DEIR
p. 3.18-18.)
In their analysis of the impacts of the Project and the specific conditions of the Redlands Downtown
area, which is approximately one mile to the southeast of the Project site, TNDG concluded that, by
itself, the Project will not have a significant impact on the Redlands Downtown area based on the
following factors: Residual demand is anticipated to be sufficient to support the Project without
diverting sales from existing GAFO stores or restaurants; Small merchants in the downtown already face
big box competition from the Citrus Plaza shopping center and Redlands Town Center, and the Project,
in and of itself,will not significantly increase the market draw of these established centers as it relates to
Downtown businesses;The downtown's existing vacancy rate, at 8.2 percent, is within the"normal
vacancy"rate for relatively healthy retail markets (usually 5 percent-10 percent), and there are no visible
indications of urban decay(i.e., dilapidated buildings or marginal uses); The downtown has a strong
representation of boutique retail, eating and drinking establishments, and service-based businesses that
offer a mix of merchandise and services that are not directly comparable to the type of goods available at
the type of big box stores that would locate at the Project or, for that matter big box stores in the Citrus
Plaza and Redlands Town Center shopping centers. (DEIR pp. 3.18-18 to 3.18-19.)
Although the new store will be larger than the existing store(primarily due to the supermarket
component)and include some new specialty merchandise and restaurant space,the Project is largely a
relocation of the existing Walmart store. Since the downtown area already faces competition from the
existing Walmart,the potential net impact of the Project is much less than the development of a brand
new Walmart store. (DEIR p. 3.18-19.)
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Impact UD-2: Would the proposed Project result in the physical deterioration of properties or structures
that impairs the proper utilization of the properties or structures, or health, safety, and welfare of the
surrounding community?
Finding: Potential impacts of the Project related to Urban Decay are discussed in detail in Section 3.18
of the Draft EIR. Based on the entire record before it, the City finds no significant impact related to the
potential for the proposed Project to result in the physical deterioration of properties or structures that
impairs the proper utilization of the properties or structures, or health, safety, and welfare of the
surrounding community. (DEIR pp. 3.18-19 to 3.18-32.)
Facts in Support of the Finding: The purpose of this section is to analyze the potential for the Project
to result in a cumulatively significant urban decay impact when considered in light of the development
of other competitive retail developments within the trade areas of the Project. Consistent with the
analyses provided above under Impact UD-I, this analysis evaluates the cumulative effects of the
Project using the Community Retail Trade Area(CRTA)to evaluate impacts to the grocery
(supermarket)market and the RRTA for the non-grocery market. The analysis takes into account other
planned and pending grocery and non-grocery developments within the two respective trade areas. The
first subsection below(Cumulative Setting and Market Impacts) assesses the impacts of these
developments, combined with the Project, to assess the current and future balance(or imbalances) of
supply and demand and the potential implications with respect to market pressures for the two respective
market areas. The second subsection below(Cumulative Urban Decay Analysis)evaluates the
implications of the market impacts discussed under the first section with respect to potential urban
decay. (DEIR p. 3.18-19.)
Cumulative Setting and Market Impacts
Community Retail Trade Area- There are four known planned and/or pending supermarket Projects in
the CRTA (including the supermarket component of the Project evaluated in this analysis). Table 3.18-6
in the Draft EIR provides the name, location, square feet, and status of each Project. Based on the
known planned and pending tenants in the Food category, Table 3.18-7 in the Draft EIR provides an
analysis of cumulative impacts of all known planned and pending supermarket Projects that would be
developed by 2020. This cumulative analysis follows the same process described under Impact UD-1
above which address direct impacts, differing only in that it includes planned and pending Projects in
addition to the proposed Redlands Walmart store supermarket component. As shown in this table, the
combined sales impacts of the recently developed, approved, and proposed Projects would result in
average supermarket sales volumes of$413 per square foot in the CRTA in 2013. Thus, using the
benchmark median U.S. sales figure of$473 per square foot, the market would technically be overbuilt
by approximately 87,100 square feet of space. This suggests that up to two supermarkets could
potentially close under cumulative conditions. However, the closing of two supermarkets represents
worst-case conditions and is unlikely to occur. The following four key factors would mitigate against
the potential closure of two supermarket stores. (DEIR p. 3.18-20.)
1. It is recognized that the median U.S. sales figure of$473 per square foot does not necessarily
reflect a break-even threshold for all supermarkets. Since the$473 per square foot figure reflects
the median sales figure, by definition half of all supermarkets are operating below this level, and
it is known that some supermarket chains,nationally, operate at substantially lower sales levels
than the median. In addition, the median regional (for the Western U.S.)sales figure is$418 per
square foot. Based on this benchmark factor, the market would technically be overbuilt by
approximately 7,700 square feet, with sales volumes fully recovering to the Western U.S. median
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figure in 2014(i.e., one year after the Projects' first full year of operations). These facts indicate
that it is unlikely for two supermarkets to close as a result of cumulative impacts. (DEIR pp.
3.18-20 to 3.18-21.)
To evaluate the"typical" sales volumes of California supermarkets, the TNDG report utilized a
proprietary database of chain-specific supermarket sales estimates provided by Trade
Dimensions International, Inc., a market research firm of The Nielsen Company. The database,
based on data for more than 3,100 individual stores, includes sales estimates for 50 supermarket
chains operating in California along with aggregate sales estimates for independent
supermarkets. According to this database, average sales per square foot by chain ranges from
$212 to $801 per square foot. For all chains combined, the median and average sales per square
foot measures are$385 and$412, respectively, with a standard deviation of$133 per square foot.
As indicated in the sales per square foot estimates above,there is significant variability in sales
volumes at individual supermarkets, and evidence indicating that a number of stores (and entire
chains) are operating at well below the$473 threshold evaluated in this analysis. In fact, of the
50 grocery chains represented in the database(including the aggregated independent category),
35, or 70 percent of the total, generate average sales volumes below $473 per square foot.
Further,more than half(54 percent) of the chains operate at sales volumes below$400 per
square foot,while 20 percent operate below$300 per square foot. These data further suggest
that the median U.S. sales figure is a relatively aggressive benchmark for estimating potential
store closures. (DEIR p. 3.18-21.)
2. Considering the limited size(13,928 square feet) of the Loma Linda store,in many respects this
store will likely not be a direct competitor with full-scale supermarkets, which are often 50,000
or more square feet and carry a wider range of grocery items. Markets of this size often focus on
a specific product niche—e.g., convenience goods, specialty produce, vitamins and natural
supplements, etc.—to differentiate themselves from full-scale supermarkets. Thus,potential
impacts to the supermarket category may have been overestimated by including a potential more
convenience- and specialty-oriented grocer in the cumulative analysis. (DEIR p. 3.18-21.)
3. The cumulative analysis implicitly assumes that the planned grocery markets' trade areas will be
identical to the Project evaluated in this analysis simply because the planned Projects are located
in the CRTA. More realistically, each planned grocery market will have its own unique trade
area,which will only partially overlap with the CRTA. For instance,the planned San Bernardino
Walmart expansion is located near the northern portion of the CRTA. According to the
economic impact analysis prepared as part of the Draft EIR for that Project,the proposed
expanded store's primary trade area would only partially overlap with the CRTA evaluated in
this analysis. The San Bernardino's store trade area would include areas well outside the CRTA
to the west,east, and north. Thus, assuming all of the planned grocery Projects in the CRTA
would be equally competitive likely overstates cumulative impacts. (DEIR p. 3.18-22.)
Regional Retail Trade Area-This subsection evaluates the cumulative impacts to the market based on
all known pending,non-grocery, retail-development/reuse Projects(including the Project evaluated in
this analysis)in the PMA of the RRTA(City of Redlands). Table 3.18-8 in the Draft EIR shows the
total square feet of new retail space (non-grocery) that could potentially be developed in the PMA over
the next five to ten years. (DEIR p. 3.18-24.)
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The square feet of planned/pending Projects in the SMA-E and SMA-W is not included in the table
since this analysis evaluates demand for new space in the City of Redlands. However,the
planned/pending Projects were taken into account for purposes of estimating capture rates of the SMA's
resident retail demand. Appendix F, Table F-1, of the TNDG report(located in Appendix J of the Draft
EIR)provides a supplemental list of the planned/pending retail Projects in the SMA-E and SMA-W.
(DEIR p. 3.18-24.)
As shown on Table 3.18-8 of the Draft EIR, there could potentially be approximately 1.0 million square
feet of new retail(non-supermarket) space developed in the PMA sometime over the next five to ten
years. Within the evaluated trade area, net demand for new retail space is projected to grow to
approximately 903,200 square feet by 2022. Table 3.18-9 in the Draft EIR provides a breakdown of
supportable square feet by retail category from 2013 to 2022. (DEIR p. 3.18-25.)
Based on the potential demand for new non-grocery retail space shown on Table 3.18-9, the total square
feet of planned retail Projects in the RRTA would absorb all of the projected growth in retail demand
through 2022. In addition,the market would likely be able to support the full 1.0 million square feet of
planned and pending retail space by 2025. (DEIR p. 3.18-25.)
Tables 3.18-10 and 3.18-11 in the Draft EIR provide a range of the projected citywide vacancy rates
assuming all of the pending Projects are developed by 2013. The"High Scenario"provided in Table
3.18-10, is based on the assumption that two supermarkets would become vacant,under"worst-case"
conditions. The"Low Scenario"shown in Table 3,18-11, is based on the assumption that no
supermarkets would become vacant, as shown on Table 3.18-11. The"High"scenario likely
overestimates the amount of new vacant space as a result of potential supermarket closures. The worst-
case scenario in which up to two supermarkets potentially close would not necessarily increase the
amount of vacant supermarket square feet in the City of Redlands—as implicitly assumed on Table
3.18-10 because only 10 of the 20 total supermarkets in CRTA are located in the City. Thus, it is
possible that potential supermarket closures in the CRTA, under the worst-case conditions, would be
outside of the City of Redlands. (DEIR p. 3.18-26.)
In both scenarios,the vacancy rate would be over the"standard"acceptable vacancy rate range for retail
commercial space of 5.0 percent to 10.0 percent if all of the pending Projects were developed in the next
12 years. These projected worst-case impacts,however, are not expected to result in Urban Decay, for
the following reasons. (DEIR p. 3.18-26.)
Redlands Mail. The existing retail inventory includes the Redlands Mall, which has been shut down as a
result of General Growth Properties (the mall's previous owner) recent bankruptcy filing. 'The mall is
now controlled by the Howard Hughes Corp.—a new company formed as part of the bankruptcy process
that has taken over the company's portfolio of master-planned communities along with potential
redevelopment properties. Although General Growth Properties intended to redevelop the mall into a
mixed-use urban village-combining multi-family residential, office, and retail development—when it
purchased the property in 2004, the Howard Hughes Corp. is currently evaluating the property to
determine its"true potential." In any event,the mall is a functionally obsolete, aging,I 970s era
development which is not suitable for contemporary retail uses. Given that retail reuse of the existing
mall is probably not viable, and that it has been shut down by its current owner, a case can be made that
the mall's space should be excluded from the retail inventory. Excluding the mall's space from the
inventory, the projected 2022 vacancy rate under cumulative conditions would range from 9.6 percent
(low scenario)to 11.6 percent(high scenario). (DEIR p. 3.18-26.)
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The potential planned and pending competitive space includes the 595,000-square foot Mountain Grove
shopping center,the second phase of the Citrus Plaza shopping center. Majestic Realty, the Project's
developer,has postponed the Project indefinitely due to current market conditions and limited interest
from potential tenants. Given that there are no current plans to develop this retail space, it somewhat
speculative to include this Project in the new planned and pending competitive space. Removing this
Project from the planned and pending competitive supply, the highest projected vacancy rate would
range from 6.8 percent(low scenario) to 9.0 percent(high scenario)in 2013, and would steadily
decrease for the remainder of the study period. In addition, if the Mountain Grove shopping center is
ultimately developed,the combined center(along with the Citrus Plaza)would function as a super-
regional shopping center with over I million square feet of regional retail space. This type of center
would likely draw shoppers from beyond the trade area boundaries evaluated in this analysis, in addition
to capturing a larger share of retail demand from the SMA-E and SMA-W sub-areas of the RRTA(see
Section 3.18-2). Thus,the additional market support for this Project—which is not projected within this
analysis—indicates that the vacancy rates projected in Tables 3.18-10 and 3.18-11 in the Draft EIR are
relatively aggressive, even with the potential development of the Mountain Grove shopping center
Project. (DEIR pp. 3.18-26 to3.18-27.)
Cumulative Urban Decay Analysis
Community Retail Trade Area- As discussed above, cumulative impacts resulting from planned and
pending supermarket Projects could result, under a worst-case condition, in the closing of up to two
supermarkets in the CRTA. However, this does not mean that the impacts would necessarily result in
urban decay in the CRTA. While the phenomenon of urban decay is not defined under CEQA, it is
assumed to be indicated by significant deterioration of structures and/or their surroundings. Such
deterioration occurs when property owners reduce property maintenance activities below that required to
keep their properties in good condition. A store closure, in and of itself, does not meet the above
criteria. While the closure of a business is clearly a severe impact to the owners and employees of the
firm, within the context of CEQA it is only significant if it results in sustained vacancies and related
deterioration of the physical condition of the vacant building(s). (DEIR p, 3.18-30.)
With the recent consolidation in the supermarket industry, there are many examples of neighborhood
shopping centers that have lost supermarket anchor tenants and have not suffered a significant
deterioration of structures and/or their surroundings. Many of these centers have either attracted new
(non-supermarket) anchor tenants, sub-divided the space for multiple retail users,or reconfigured the
space for non-retail uses. Thus, losing a supermarket anchor tenant does not necessarily indicate that the
shopping center will experience a downward spiral of store closures and long-term vacancies. (DEIR p.
3.18-30.)
Regional Retail Trade Area- With respect to the RRTA, it is possible—as described above—that the
market could become overbuilt during the period from 2013 through 2022 if all of the aggregate retail
development planned by the proponents comes on line during that period. If an overbuilt retail
environment does develop, there would be a potential for business failures with resulting closures of
retail facilities in the trade area. However, most of the future tenants of the planned retail Projects have
not yet been identified. As such, it is currently not possible to identify which retail categories might
become overbuilt,or to identify existing businesses in those categories, which might be forced to close.
Therefore, any attempt to identify specific vacancies, which might result, or to determine the potential
for physical deterioration or urban decay,would be speculative in this context. For purposes of
evaluating CEQA impacts, it is not required or valid to engage in speculative analysis. (DEIR p. 3.18-
30.)
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A more likely cumulative scenario is that retail market conditions would result in a more gradual
buildout of planned retail development, such that the pace of retail development would more closely
follow the growth in retail demand. Under this scenario, there is less potential for overbuilt conditions
to occur, and consequently a reduced potential for building vacancies and urban decay to follow. In fact,
this finding is consistent with the developer's plans for the planned Mountain Grove Project,which has
been put on hold indefinitely due to current market conditions and limited interest from potential
tenants. But again, any attempt to identify businesses which might be affected under this scenario, if
any, and whose closure might ultimately result in urban decay would be speculative, and therefore
would not be required under CEQA. (DEIR p. 3.18-30.)
Retail Reuse of Existing.Walmart Store- Although the Project-specific analysis indicates there would be
sufficient demand to support some type of retail reuse of the existing Walmart store,the cumulative
analysis, as discussed above, indicates that the retail market has the potential to become slightly
overbuilt if all of the planned and pending Projects are built by 2013. As indicated in the cumulative
analysis, the planned and pending aggregate retail development would absorb all of the residual demand
through 2022, which could delay the reuse of the existing Walmart store. (DEIR p. 3.18-31.)
Based on TNDG's knowledge, the relative success in reusing closed Walmart stores for other retail uses
represents a"mixed bag"of sorts,with some successfully reconfigured for other retail stores and others
which have remained vacant for two to three years. Specifically, TNDG has prepared urban decay
studies in the following California cities, identified in Table 3.18-12 in the Draft EIR,which involved
the simultaneous closing of an existing Walmart store and the development of a Walmart store
combining general merchandise and grocery sales. (DEIR p. 3.18-31.)
Even if the property owners of an existing shopping center are unable to attract replacement tenant(s) for
the Walmart store,the closure of the Walmart store would not necessarily result in long-term physical
impacts to the shopping center. Without Walmart,the shopping center would still function as a well-
tenanted neighborhood shopping center with the existing Food 4 Less as a strong anchor tenant. For
example, in Hanford, CA,the similar-size Centennial Plaza experienced the closure of a Walmart store
in 2006, but has remained viable without the re-tenanting of that store. Although vacancies have slightly
increased, the center is still anchored by a Foods Co. Supermarket(which was remodeled in 2005, well
after it was known that the existing Walmart store would be closing), a Pep Boys, and a Dollar or Less
store. (DEIR p. 3.18-31.)
Impacts to Downtown Redlands - Although in the Project-specific analysis under impact UD-1, above,
did not identify potential impacts to downtown retail tenants resulting from development of the Project,
the existing and planned retail development near the Interstate I O/State Route 30(1-10/SR-30)
interchange will potentially place additional competitive pressures on downtown retailers. This
potential impact is also acknowledged in the Economic Development Strategy recently prepared for the
City. However, in terms of potential cumulative impacts, the Project's impact is not expected to be
cumulatively considerable, for two key reasons. First, although the new store will be larger than the
existing store(primarily due to the supermarket component) and include some new specialty
merchandise and restaurant space,the Project is largely a relocation of the existing Walmart store. Since
the downtown area already faces competition from the existing Walmart, the potential net impact of the
Project is much less than the development of a brand new Walmart store. Second, given the downtown
area already faces competition from the existing Walmart, any potential cumulative impacts to the
downtown area resulting from the planned and pending projects would occur with or without the
development of the Project. Such cumulative projects are not driven by the Walmart project, but would
be expected to independently proceed whether or not the proposed Project occurs.
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Moreover,the following factors are expected to lessen potential urban decay impacts in the downtown
area. (DEIR p. 3.18-32.)
• There is an existing assessment district formed under the 1989 Parking and Business
Improvement Area law that provides resource to the City and specific the Development
Services Department, which actively works to preserve and promote the downtown area,
including promoting public events, decorating public places, maintenance of existing facilities,
etc. (DEIR p. 3.18-32.)
• General Growth Properties, a major real estate investment trust(REIT), was considering
developing two key Projects in the downtown area—the Redlands Promenade and the
redevelopment of the Redlands Mall. Due to the firm's recent bankruptcy filing and the
current slowdown in the commercial and residential real estate markets,both Projects have
been on hold. Although no application was filed with the City, General Growth Properties,
which has recently been succeeded by Howard Hughes Corporation as owner or the property,
extensively evaluated the potential to redevelop the Redlands Mall into a mixed-use(retail,
office, and multi-family residential) development incorporating, as one component, an open-
air shopping center. Thus, it is possible that a similar development proposal will emerge to
redevelop the mall site once the residential and commercial real estate markets begin to
recover. (DEIR p. 3.18-32.)
B. Potentially Significant Impacts Which Can Be Mitigated Below A Level Of Significance
With Mitigation Measures
Public Resources Code section 21081 states that no public agency shall approve or carry out a Project
for which an EIR has been completed which identifies one or more significant effects unless the public
agency makes one or more of the following findings:
1. Changes or alterations have been required in, or incorporated into, the Project which mitigate or
avoid the significant effects on the environment.
2. Those changes or alterations are within the responsibility and jurisdiction of another public
agency and have been, or can and should be, adopted by that other agency.
3. Specific economic, legal, social, technological, or other considerations make infeasible the
mitigation measures or alternatives identified in the EIR, and overriding economic, legal, social,
technological,or other benefits of the Project outweigh the significant effects on the
environment.
The following issues from ten of the environmental categories analyzed in the EIR, including Aesthetics,
Air Quality, Biological Resources, Cultural Resources, Geology and Soils, Hazards and Hazardous
Materials, Hydrology and Water Quality,Noise, Public Services, and Greenhouse Gases were found to
be potentially significant,but can be mitigated to a less than significant level with the imposition of
mitigation measures. The City hereby finds pursuant to Public Resources Code section 21081 that all
potentially significant impacts listed below can and will be mitigated to below a level of significance by
imposition of the mitigation measures in the EIR; and that these mitigation measures are included as
Conditions of Approval and set forth in the Mitigation Monitoring and Reporting Program adopted by
the City. Specific findings of the City for each category of such impacts are set forth in detail below.
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Facts,Findings,and Statement of Overriding Considerations
Related to the Final Environmental Impact Report
1. Aesthetics
Impact AES-4: Would the proposed Project create a new source of substantial light or glare which
would adversely affect day or nighttime views in the area?
Finding: Potential impacts of the Project on Aesthetics are discussed in detail in Section 3.1 of the Draft
EIR. Based on the entire record before it, the City finds that this impact is potentially significant but
will be mitigated to a less than significant level through the implementation of Mitigation Measure AES-
4. (DEIR pp. 3.1-25 to 3.1-26.) This mitigation measures, enumerated below, is adopted and
incorporated into the Mitigation Monitoring and Reporting Program for the Project, and will be
implemented as specified therein.
MMAES-4: Prior to issuance of building permits, the Project applicant shall submit a photometric
plan to the City ofRedlands far review and approval. The photometric plan shall identify types of
lighting fixtures and their locations on the Project site. All light fixtures shall be shielded, recessed, or
directed downward to prevent unwanted illumination of neighboring properties. (DEIR p.3.1-26.)
Facts in Support of the Finding: The Project accommodates 275,500 square feet of commercial, retail
and restaurant uses. Development of the Project would require new lighting fixtures to be installed on-
site, including on the building exterior, in landscape areas, in parking areas, and in loading areas.
Vehicles associated with development of the Project may introduce a new light source to the area as
well. The new sources of light associated with the Project could potentially impact nearby properties.
Lighting in the southeastern portion of the Project area is of particular concern because of the proximity
residences. (DEIR pp. 3.1-25 to 3.1-26.)
Currently, existing various uses within the Project area including the Citrus Plaza(directly west of SR-
210 Freeway), the Home Depot Center and associated commercial uses (0.25 mile south)and residential
uses located east and southeast of the Project site generate light sources. In addition,headlights from
nearby traffic on Tennessee Street (east) and the SR-210 Freeway(east) generate additional light within
the Project area. (DEIR p.3.1-26.)
City policy requires that lighting associated with new development Projects be arranged in a manner that
prevents the direction or reflection of annoying light and glare onto residential areas (Section 28.96.2 10
of the Municipal Code). Therefore, mitigation is proposed that would require the Project applicant to
submit a photometric plan to the City that identifies lighting fixtures and practices to be installed that
will prevent spillage of light and glare onto neighboring properties. With the implementation of this
mitigation, the Project would minimize the amount of the light and glare it would add to the ambient
environment and,therefore, ensure that impacts are reduced to a level of less than significant. (DEIR
p.3.1-26.)
2. Air Quality
Impact AQ-1: Would the proposed Project conflict with or obstruct implementation of the applicable
air quality plan?
Finding: Potential impacts of the Project on Air Quality are discussed in detail in Section 3.3 of the
Draft FIR. Based on the entire record before it,the City finds that this impact is potentially significant
but will be mitigated to a less than significant level through the implementation of Mitigation Measures
AQ-1 and AQ-2. (DEIR pp. 3.3-18 to 3.3-21.) These mitigation measures, enumerated below, are
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Related to the Final Environmental Impact Report
adopted and incorporated into the Mitigation Monitoring and Reporting Program for the Project, and
will be implemented as specified therein.
MM AQ-1: During construction, one of the following scenarios shall be applied.
• A maximum of 15,700 horsepower hours per day for the off-road equipment shall be
used and the off-road equipment shall have Tier 2 engines or higher.
• A maximum of 12,100 horsepower hours per day for the off-road equipment shall be
used.
MMAQ-2 During construction,paving shall not occur during the building or grading phases.
Paving can occur during architectural coating(painting).
(DEIR pp. 3.3-20 to 3.3-21.)
Facts in Support of the Finding: An AQMP describes air pollution control strategies to be taken by a
city, county, or region classified as a non-attainment area. The 2007 AQMP prepared by the SCAQMD
is designed to satisfy the State Implementation Plan submittal requirements of the federal Clean Air Act
to demonstrate attainment of the new federal 8-hour ozone and PM2.5 ambient air quality standards, the
California Clean Air Act triennial update requirements, and fulfill the SCAQMD's commitment to
update transportation emission budgets based on the latest approved motor vehicle emissions model and
planning assumptions. CEQA requires that certain proposed projects be analyzed for consistency with
the AQMP. (DEIR p. 3.3-18.)
According to the SCAQMD,the Project is consistent with the AQMP if the Project would not result in
an increase in the frequency or severity of existing air quality violations or cause or contribute to new
violations, or delay timely attainment of air quality standards or the interim emission reductions
specified in the AQMP (South Coast Air Quality Management District 1993,page 12-3). (DEIR p. 3.3-
18.)
Impact AQ-2 demonstrated that during construction the Project could violate an air quality standard or
contribute substantially to an existing or projected air quality violation for nitrogen dioxide. See Table
3.3-9, which illustrates,without mitigation incorporated, an exceedance of nitrogen dioxide(0.205) over
the identified significance threshold(0.180) for localized construction impacts. Therefore,without
mitigation,the Project construction results in a potentially significant impact. During operation,
localized onsite concentrations and impacts at Project impacted intersections are less than significant.
(DEIR pp. 3.3-19 and 3.3-27.)
The second indicator of whether the Project could conflict with or obstruct implementation of the air
quality plan is by assessing the Project's compliance with the control measures in the 2003 and the 2007
AQMPs. (DEIR p. 3.3-19.)
The 2003 AQMP contains a number of land use and transportation control measures including the
following: the District's Stationary and Mobile Source Control Measures; State Control Measures
proposed by ARB; and Transportation Control Measures provided by Southern California Association of
Governments. ARB's strategies for reducing mobile source emissions include the following
approaches: new engine standards; reduce emissions from in-use fleet,require clean fuels, support
alternative fuels and reduce petroleum dependency, work with EPA to reduce emissions from national
and state sources, and pursue long-term advanced technology measures(AQMP 2003,page 4-25).
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Transportation control measures provided by Southern California Association of Governments include
those contained in the Regional Transportation Plans, the most current version of which is the 2008
Regional Transportation Plan. The Regional Transportation Plan has control measures to reduce
emissions from on-road sources by incorporating strategies such as high occupancy vehicle
interventions, transit, and information-based technology interventions (AQMP 2003,page 4-19). The
Project is in compliance with regional control measures and has incorporated means of encouraging
alternative methods of transportation, and thus would indirectly comply with the control measures set by
ARB and Southern California Association of Governments. (DEIR p. 3.3-19.)
The focus of the 2007 AQMP is to demonstrate attainment of the federal PM2.5 ambient air quality
standard by 2015 and the federal 8-hour ozone standard by 2024, while making expeditious progress
toward attainment of state standards. The proposed strategy, however, does not attain the previous
federal I-hour ozone standard by 2010 as previously required prior to the recent change in federal
regulations. This is to be accomplished by building upon improvements from the previous plans and
incorporating all feasible control measures while balancing costs and socioeconomic impacts. The 2007
AQMP indicates that PM2.5 is formed mainly by secondary reactions or sources. Therefore, instead of
reducing fugitive dust,the strategy for reducing PM2,5 focuses on reducing precursor emissions of SO,,
directly emitted PM2.5,NOx, and VOC. The Final 2007 AQMP control measures consist of four
components. These components are discussed Impact AQ-I in the Air Quality and Greenhouse Gas
Analysis Report(around page 70). The Project is consistent with the components. (DEIR p. 3.3-19.)
Geographical areas in the state that exceed the federal air quality standards are called nonattaimnent
areas. The Project area is in nonattainment for ozone, PM 10, PM2.5, and nitrogen dioxide. State
Implementation Plans(SIPs) show how each area will attain the federal standards. To do this, the SIPS
identify the amount of pollutant emissions that must be reduced in each area to meet the standard and the
emission controls needed to reduce the necessary emissions. On September 27,2007, ARB adopted its
State Strategy for the 2007 SIP. In 2009, the SIP was revised to account for emissions reductions from
regulations adopted in 2007 and 2008 and clarifies ARB's legal commitment. There are currently
proposed revisions and a 2011 Progress Report. The South Coast is currently 94 percent of the way
towards achieving the 2014 emissions levels identified in its PM2.5 SIP. The SIP takes into account
ARB rules and regulations. The Project will comply with applicable rules and regulations. (DEIR p.
3.3-20.) The Project would comply with all applicable rules and regulations. Therefore,the Project
complies with this criterion. (DEIR p. 3.3-210.)
According to Chapter 12 of the SCAQMD, CEQA, Air Quality Handbook, the purpose of the
consistency finding is to determine whether a project is inconsistent with the assumptions and objectives
of the regional air quality plans, and thus whether it would interfere with the region's ability to comply
with federal and State air quality standards. If a project is inconsistent, local governments need to
consider project modifications or inclusion of mitigation to eliminate the inconsistency. Consistency
with the AQMP implies that a project is consistent with the goals, objectives, and assumptions in the
respective plan to achieve the national and State air quality standards. To assess the environmental
impacts of new or renovated developments accurately, environmental pollution and population growth
are projected for future scenarios. (DEIR p. 3.3-20.)
Since the AQMP could be based on local general plans,projects that are deemed consistent with the
general plan.are found to be consistent with the AQMP. The City of Redlands General Plan has
designated the Project area as "commercial"to accommodate business growth in the Project vicinity.
Since the Project's intended land use is consistent with the current General Plan, implementation of the
Project would not require any amendments to the City's zoning designations for the Project site.
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Therefore, the Project would be within the City's General Plan designation and is consistent with the
adopted SCAQMD AQMP according to this criterion. (DEIR p. 3.3-20.)
As shown in Impact AQ-2 of the findings and Draft EIR, implementation of mitigation measures AQ-1
and AQ-2 would reduce localized impacts of nitrogen dioxide to less than significant. The measures
reduce daily emissions of NOx thereby reducing the Project's localized contribution to air quality
violations to less than significant. (DEIR p. 3.3-21.)
Impact AQ-2: Would the proposed Project violate an air quality standard or contribute substantially to
an existing or projected air quality violation?
Finding: Potential impacts of the Project on Air Quality are discussed in detail in Section 3.3 of the
Draft EIR. Based on the entire record before it,the City finds that this impact is potentially significant
but will be mitigated to a less than significant level through the implementation of Mitigation Measure
AQ-1 and AQ-2. (DEIR pp. 3.3-21 to 3.3-39.) These mitigation measures, enumerated below, are
adopted and incorporated into the Mitigation Monitoring and Reporting Program for the Project, and
will be implemented as specified therein.
See MMAQ-1 and MMAQ-2 under Impact AQ-1 above.
(DEIR p. 3.3-38.)
Facts in Support of the Finding: The potential for violation of ambient air quality standards was
judged based on three criteria: Criterion 1: the localized significance analysis for the Project's
construction; Criterion 2: the localized significance analysis for the Project's operational emissions; and
Criterion 3: the CO hotspot assessment for operational emissions. (DEIR p. 3.3-21.)
Localized Analysis Methodology-The localized analysis assesses the impact of onsite Project
emissions to sensitive receptors located within the vicinity of the Project. The SCAQMD, in its
Localized Significance Threshold Methodology indicates that only onsite emissions are included in the
localized analysis. In order to estimate the impact to sensitive receptors, the future concentration of
pollutants must be calculated at the location of the sensitive receptors and compared with a standard or
threshold. The onsite emissions are input into an air dispersion model, the U.S. EPA AERMOD Model,
to simulate the transport and dispersion of Project-related emissions released from onsite construction
and operational activities. These impacts were then compared to the applicable SCAQMD localized
concentration thresholds and ambient air quality standards to assess the regulatory significance of these
impacts. (DEIR p. 3.3-21.)
Note that the SCAQMD's localized methodology only applies to nitrogen dioxide,CO, PM 10, and PM2.5.
Ozone and VOC are not included because it is not a localized pollutant and modeling for ozone is
complex and speculative to occur at the Project level; ozone is addressed under the regional analysis (see
Impact AQ-3). Sulfur dioxide, sulfates, visibility reducing particles, and hydrogen sulfide are not
modeled because the Basin is in attainment for those pollutants and the Project would not emit those
pollutants in sufficient quantity(background concentrations are low). Diesel particulate matter and
benzene are assessed in Impact AQ-4. (DEIR pp. 3.3-21 to 3.3-22.)
Criterion 1: Localized Significance Analysis -Construction
Localized construction emissions were estimated using the SCAQMD-recommended model,
CaIEEMod. Short-term construction impacts would include fugitive dust and other particulate matter
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Facts,Findings,and Statement of Overriding Considerations
Related to the Final Environmental impact Report
SCAQMD Rule 403 requires fugitive dust generating activities follow best available control measures to
reduce emissions of fugitive dust. These measures are accounted for in CalEEMod as mitigation
because the model categorizes the measures as mitigation, even though they are technically not
mitigation. The best available control measures and the associated measure in CalEEMod are displayed
in Table 3.3-7 of the Draft EIR. (DEIR p. 3.3-24.)
The construction emissions for the localized assessment were extracted from the CalEEMod model
considering only emissions generated from onsite construction activities such as from construction
equipment exhaust (off-road diesel) and fugitive dust from earth-moving activities. A review of the
CaIEEMod model outputs indicated that the highest emissions generated from onsite construction
activities are associated with the mass grading activities of the Project site. Therefore, grading
emissions during this construction activity were evaluated in the localized assessment. The maximum
daily grading emissions are provided in Table 3.3-8 of the Draft EIR. (DEIR pp. 3.3-25 to 33-26.)
The modeling assessment used the meteorological data for the year 2007 as provided by the SCAQMD
for their Redlands monitoring station, which is located 2.5 miles southeast of the Project site. A
construction area of 10.5 acres was assumed based on the extent of the area that could be disturbed in a
day as derived from the CaIEEMod model, which considers the amount of work that construction
equipment can accomplish in a day. Two construction emission sources were evaluated: Onsite
construction equipment exhaust emissions were represented by an area source distributed over the 10.5-
acre construction area with a release height of five meters (16.5 feet); and An area source with a size of
10.5 acres and a ground-level release height was used to represent the onsite emissions of fugitive dust.
(DEIR p. 3.3-26.)
The two onsite construction emission sources were located along the southeastern corner of the Project
property line across from the closest residences along Karon Street. Construction was assumed to occur
over an 8-hour day on weekdays. (DEIR p. 3.3-26.)
It should be noted that nitrogen dioxide present in the atmosphere is formed from two sources. One
source is the direct emission of nitrogen dioxide from the combustion of fuel. The second source
involves the formation of nitrogen dioxide in the atmosphere due to reactions of oxides of nitrogen
emissions and ambient concentrations of ozone and reactive hydrocarbons. The concentrations of
nitrogen dioxide increases as the distance from the emission source increases, but only to a certain point,
since dispersion dilutes the concentrations. The Ozone Limiting Method (OLM) was used in the
AERMOD model to convert the NOx emissions to nitrogen dioxide based on the distance from the
source to the receptor and background ozone concentrations. (DEIR p. 3.3-26.)
Table 3.3-9 in the Draft EIR provides a comparison of the Project's localized construction impacts with
the SCAQMD's significance thresholds without mitigation.
Table 0-1: Localized Construction Impacts-Construction
Carbon 1-hour,ppm 0.7 3 3.7 20.0 ! No
monoxide(CO) g-hour,ppm 0.1 2.2 2.3 9.0 No
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Facts,Findings,and Statement of Overriding Considerations
Related to the Final Environmental Impact Report
Nitrogen 1-hour,ppm 0.114 0.091 0.20 0.18 Yes
dioxide (NO,)) 5
Particulate 24-hour, 10.2 NA 10.2 10.4 No
matter(PM 10) ❑g/m3
Annual, 0.7 NA 0.7 1.0 No
g/m3
Particulate 24-hour, 8.6 NA 8.6 10.4 No
matter (PM1_5) j ❑g/m3
Notes:
NA =Not Applicable; background levels are not defined for PMIo and PM2; for purposes
of significance testing
ppm =parts per million(a unit of concentration); Elg/m3 =micrograms per cubic meter (a
unit of concentration)
Source: Michael Brandman Associates 2011.
Note that the impact estimates for PMio and PM2s include compliance with SCAQMD Rule 403
regarding fugitive dust as discussed previously. The highest impacts were generally noted along the
southeast corner of the Project's fence line along Pennsylvania Avenue. Concentrations from the
Project during construction would exceed the SCAQMD's localized construction significance threshold
for NOz but not exceed the significance thresholds for CO,PMIo, and PM2.5. As a result, the Project
would result in a significant localized air quality impact during construction. As identified within Table
3.3-22, with incorporation of mitigation measures AQ-1 and AQ-2, the localized construction impacts
for nitrogen dioxide would be reduced below the threshold of significance.
Table 0-2: Localized Construction Impacts—Construction (Mitigated)
i
I
4
Nitrogen dioxide our, 0.078 0.091 0.169 0.18 No
(NO2) ppm
Source: Michael Brandman Associates 2011.
(DEIR pp. 3.3-27 and 3.3-39.)
Criteria 2: Localized Significance Analysis—Operation
Operational or long-term emissions occur over the life of the Project. The assessment of local
operational impacts was accomplished for three scenario years: Scenario 2010 representing an existing
condition in accordance with the Project's traffic impact study(Urban Crossroads 2011); although the
Project would not be operational it is assumed for purposes of this analysis that the Project would be
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Related to the Final Environmental Impact Report
operational; Scenario 2013 representing the expected build out year when the Project would commence
operations; Scenario 2030 representing a long-term future Horizon Year. (DEIR p. 3.3-27.)
Note that the Project impacts during the above three scenario years result from the changes in emissions
that occur over time associated with the various Project emission sources such as motor vehicles and
transport refrigeration units. These emission changes occur as a result of future vehicle turnover to
newer and cleaner vehicle models and the implementation of regulatory mandated emission control
technologies. The aforementioned Project impacts are incremental in nature and result from the changes
in Project emissions. (DEIR pp. 3.3-27 to 3.3-28.)
The predominant sources of onsite operational emissions are the motor vehicles and trucks that access
the Project site. Such emissions result from the delivery truck traffic that arrives, unloads, and departs
daily from the various Project buildings and from the daily customer and worker traffic accessing the
Project's parking lots. Additional operational emissions also arise from the combustion of natural gas
for heating, landscape emissions, operation of the gasoline service station, and from the use of consumer
products. In this assessment, four main emission sources were evaluated as to their localized operational
impacts on air quality: Delivery truck exhaust emissions from traffic that would move onto the Project
site from the entrances along San Bernardino Avenue, Tennessee Street, and the future Pennsylvania
Avenue; Truck idling emissions at loading docks; Emissions associated with the use of TRUs, which are
used in the transport of perishable food items; and Automobile traffic from workers and customers while
traveling and idling within the parking lots. (DEIR p. 3.3-28.)
The estimation of the onsite mobile source emissions requires the specification of several key pieces of
information including the number of vehicle trips by vehicle type, trip travel lengths, vehicle idling time,
and emission factors that define the amount of emissions as a function of vehicle speed and distance
traveled or amount of idling time per vehicle. (DEIR p. 3.3-28.)
Pollutant emissions from the various onsite mobile sources were calculated using information derived
from the Project description, Project traffic study, truck delivery information for Walmart operations,
and mobile source emission factors from the ARB EMFAC2007 emissions factor model. Vehicle trip
distances were determined from the Project's site plan as the distance from the nearest Project entrance
to the various Project buildings. The emission factors for the Project's mobile source operational
emissions were based on the fleet years 2010, 2013, and 2030. Vehicle travel speeds while traveling
onsite were assumed to be 10 miles per hour(mph) for both trucks and customer vehicles. Delivery
trucks were assumed to idle for 15 minutes per day at the building loading areas pursuant to guidance
from the SCAQMD while customer vehicles were assumed to idle for I minute per day while in the
parking lots. (DEIR p. 3.3-28.)
The number of delivery trucks was estimated from the type of retail/commercial operation and
information available from similar Walmart projects and from similar retail/commercial projects.
(DEIR p. 3.3-28.)
The average trip distance for the Walmart delivery trucks was assumed to be 20 miles as the distance to
the nearest Walmart distribution centers in Mira Loma and Fontana, California. The percentages of
worker and customer trips are from CalEEMod defaults. The trip generation rates are from the Project's
Traffic Impact Analysis (Urban Crossroads 2011). (DEIR p. 3.3-29.)
The Traffic Impact Analysis assumed that there would be an internal capture of 10 percent for all uses.
Internal capture is a percent reduction attributed to trips internal to the site; trips may be made between
62
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Facts,Findings,and Statement of Overriding Considerations
Related to the Final Environmental Impact Report
Emissions are also associated with the customer and employee motor vehicles that would visit the
various retail and commercial facilities as these vehicles travel and idle within the parking lots. The
emission calculation for parking lot access was based on the number of vehicle trips expected to access
the Project during a Saturday and also the Saturday peak traffic period. The parking lot usage assumed a
24-hour operation in keeping with the 24-hour operation of the large Walmart store. (DEIR p. 3.3-32.)
Appendix B in the Air Quality and Greenhouse Gas Analysis Report provides a detailed tabulation of
the criteria pollutant mobile source emission factors assumed in this assessment. The emission factors
were derived from the ARB EMFAC2007 mobile source emission model as a function of fleet year,
vehicle class (axle number), vehicle speed, and pollutant. (DEIR p. 3.3-32.)
Small amounts of criteria pollutant emissions would also be released from the combustion of natural gas
within the Project buildings for water and air heating. The natural gas emissions were estimated from
CalEEMod and apportioned to each building according to building size. (DEIR p. 3.3-32.)
Each of the emission source types described above also requires geometrical and emission release
specifications for use in the air dispersion model. Exhibit 5 in the Air Quality and Greenhouse Gas
Analysis Report provides the location of the various Project facilities and emission source locations. By
way of explanation,the following definitions are used in defining the emission source geometrical
configurations referred to in Table 3.3-14 of the Draft EIR: Point source: a single identifiable local
source of emissions;it is approximated in the AERMOD air dispersion model as a mathematical point in
the modeling region with a location and emission characteristics such as height of release,temperature,
etc. (Example: a stack or vent); Area source: a diffuse source of emissions released uniformly over a
broad area(Example: a parking lot); Volume source: an area source with a third dimension(Example:
construction area using off-road equipment with a height of release); and Line source: a series of volume
sources along a path(Example: vehicular traffic along a street). (DEIR pp. 3.3-32 to 3.3-33.)
The assessment also requires that a network of receptors be specified such that the impacts can be
computed at the various locations within the network. Exhibit 6 in the Air Quality and Greenhouse Gas
Analysis Report shows the various receptor locations. For purposes of this assessment, the following
receptor network was used: Lines of receptors spaced 70 meters (230 feet) along the Project boundary
line then spaced out to 500(1,640 feet)meters in increments of 100 meters (330 feet); Receptors
located at nearby sensitive receptors such as at residences immediately to the east of the Project. (DEIR
p. 3.3-34.)
The assessment of air quality and health risk impacts from pollutant emissions from this Project applied
the U.S. EPA AERMOD Model which is the air dispersion model accepted by the SCAQMD for
performing air quality impact analyses. AERMOD predicts pollutant concentrations from point, area,
volume, line, and flare sources with variable emissions in terrain from flat to complex with the inclusion
of building downwash effects from buildings on pollutant dispersion. It captures the essential
atmospheric physical processes and provides reasonable estimates over a wide range of meteorological
conditions and modeling scenarios. (DEIR p. 3.3-34.)
Account was taken of the effects of building downwash on the dispersion of emissions from the various
sources located on the Project's property. Building downwash occurs when the aerodynamic turbulence,
induced by nearby buildings, causes pollutants emitted from an elevated source to be mixed rapidly
toward the ground(downwash). This results in potentially higher ground-level concentrations than if
the buildings were not present. The dispersion model contains algorithms to account for building
downwash effects. The required information includes the location of the emission source, location of
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adjacent buildings, and the building geometry in ten-ns of length, width, and height. For purposes of this
analysis,the emission source and building locations were taken from the Project site plan. The building
geometries assumed a building height of 10 meters (3 5 feet) for the Walmart store(Parcel 10) and the
future buildings on Parcel 11 and 6 meters (20 feet) for all other buildings (Parcels I —9). (DEIR pp.
3.3-34 to 3.3-35.)
Hourly meteorological data are also required to operate the AERMOD model to determine the direction
and rate of dispersion of emissions released into the atmosphere. Meteorological data for use in the air
dispersion model was obtained from the SCAQMD website for their Redlands Air Monitoring Station
for the year 2007,the only period of valid data provided by the SCAQMD for performing air dispersion
modeling assessments using the Redlands meteorological data. (DEIR p. 3.3-35.)
The Draft EIR(Table 3.3-16, -17, and-18)provide the results of the Project's localized operational
impacts along with a comparison to the SCAQMD's localized thresholds for NO2 CO, PM10, and PM2.5
for the years 2010, 2013, and 2030, respectively. The residential receptors with the highest localized
operational impacts were found to the east of the Project across Karon Street. The results contained in
the tables indicates that operation of the Project would not exceed the SCAQMD's localized significance
thresholds for any pollutant during any analysis year. Therefore, operation of the Project would not
result in a significant localized air quality impact. (DEIR p. 3.3-35.)
Criterion 2: CO Hot Spot Assessment
Within an urban setting,motor vehicle exhaust is the primary source of CO emissions. Consequently,
the highest ambient CO concentrations are generally found within close proximity to congested
intersection locations. A CO hotspot analysis is the appropriate tool to determine if emissions of CO
from the operation of the Project would exceed federal or State ambient air quality standards for CO.
During typical meteorological conditions, CO concentrations tend to decrease as the distance from the
emission source(congested intersection) increases. For purposes of providing a worst-case impact
analysis, CO concentrations are typically analyzed at the most congested intersection locations,because
if impacts were less than significant in close proximity to the most congested intersections, impacts
would also be less than significant at less congested intersections. (DEIR pp. 3.3-36 to 3.3-37.)
To examine potential traffic impacts from the Project, a Traffic Impact Analysis was prepared by Urban
Crossroads in 2011. This study examined the traffic volumes and Levels of Service(LOS) at
intersections surrounding the Project both with and without the Project-generated traffic. Traffic
projections were made for the Project in 2010, 2013, and 2030. The intersections forecasted for existing
plus Project intersections to have the five highest traffic volumes and an LOS F(prior to any traffic
mitigation) in both forecast years were identified from the traffic study and a CO hot spot assessment
was performed for each intersection. This approach represents a worst-case analysis since these
intersections will not operate at LOS F as a result of the implementation of mitigation measures when
the Project is operational. The highest CO emissions would be expected at such intersections because
these intersections exhibit the highest intersection traffic volumes and congestion. CO impacts would be
expected to be less at all other intersections. In estimating traffic volumes, the traffic generated by the
Project was added to traffic growth in the area as well as from traffic from projects that are in the
process of or have been approved by the City of Redlands. (DEIR p. 3.3-37.)
The CO emission factors used to calculate vehicle emissions at the various intersections depend on
vehicle speed and vehicle mix and were derived from the ARB EMFAC2007 mobile source emission
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model for the years 2010, 2013, and 2030. The results of the CO hot spot assessment are provided
within the Draft EIR(Tables 3.3-19, -20, and-21). (DEIR p. 3.3-37.)
The CO hot spot analysis demonstrated that Project emissions of CO during operation at Project
impacted intersections along with emissions from other foreseeable projects in the area would not result
in an exceedance of the most stringent ambient air quality standards for CO. Therefore, according to
this criterion,air pollutant emissions during operation would result in a less than significant impact.
(DEIR p. 3.3-38.)
Reducing the hours of equipment operation per day and/or requiring that the engines are Tier 2 or higher
would reduce NOx emissions (mitigation measure AQ-1). The mitigation is applied in CalEEMod by
requiring Tier 2 engines and reducing the hours of the equipment. Similar to mitigation measure AQ-1,
measure AQ-2 would reduce the equipment in operation at one time. The mitigated concentrations are
shown in the Draft EIR (Table 3.3-22). As shown in the table, mitigation reduces impacts to less than
significant. (DEIR pp. 3.3-38 to 3.3-39.)
Impact AQ-3: Would the proposed Project result in a cumulatively considerable net increase of a
criteria pollutant for which the Project region is non-attainment under an applicable federal or state
ambient air quality standard (including releasing emissions, which exceed quantitative thresholds for
ozone precursors)?
Finding: Potential impacts of the Project on Air Quality are discussed in detail in Section 3.3 of the
Draft EIR. Based on the entire record before it, the City finds that this impact is potentially significant
but will be mitigated to a less than significant level through the implementation of Mitigation Measure
AQ-1 through AQ-3 for construction related impacts. (DEIR pp. 3.3-39 to 3.3-49.) Mitigation
measures, enumerated below, are adopted and incorporated into the Mitigation Monitoring and
Reporting Program for the Project, and will be implemented as specified therein. However, the
operational related emissions impacts, while discussed below, were determined to remain significant
and unavoidable(See Impact AQ-3 under Section ll(C)).
Construction Criteria Air Pollutant Measures
See MMA Q-1 and MMAQ-2 under Impact AQ-1 above
MMAQ-3 Paint used during construction of the Project shall have a volatile organic compound
content less than 125 grams per liter.
Operational Criteria Air Pollutant Measures
Mitigation measure T-6a is also required. Note that there are a variety of'mitigation measures in the
Transportation section of the EIR that would improve motor vehicle trqfficflow. However, no reduction
is taken for those measures because they encourage motor vehicle use. Cities with limited motor vehicle
lanes, abundant and safe bicycle lanes, and dedicated alternate transportation lanes will observe
reductions in vehicle miles traveled. Increasing the ease for motor vehicles encourages motor vehicle
use and not alternate transportation.
MHA -4 Electrical hookups shall be provided in all loading docks for transportation refrigeration
units visiting the site.
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MMAQ-5 The City of Redlands shall improve traffic flow by signal synchronization along San
Bernardino Avenue, Tennessee Street, and Pennsylvania Avenue.
MMAQ-6 All dock and delivery areas shall be posted with signs informing truck drivers of the
California Air Resources Board regulations including the following:
a) Truck drivers shall turn off engines when not in use;
b) All delivery trucks servicing the Project shall not idle for more than five minutes
per truck tripper day; and
c) Telephone numbers of the building facilities manager and the California Air
Resources Board to report violations.
MMAQ-7 The following measures shall be implemented to improve pedestrian access on and off
site.
a) The Project shall incorporate pedestrian pathways between onsite uses. Site
design and building placement shall provide pedestrian connections between
internal and external facilities. Physical barriers such as walls, berms,
landscaping, merchandising, and slopes that impede bicycle or pedestrian
circulation shall be eliminated. Sidewalks shall be a minimum offive feet wide.
b) The Project shall ensure that there is safe pedestrian access to the developments
located at Lugonia Avenue and Tennessee Street and Lugonia Avenue and
Frontage Road. The pedestrian facilities shall be designed in accordance with
City of Redlands regulations and shall be installed prior to opening of the
Project.
c) The Project shall ensure that there is safe pedestrian access on Tennessee Street
between Pioneer Avenue and San Bernardino Avenue. The pedestrian facilities
shall be designed in accordance with City of Redlands regulations and shall be
installed prior to opening of the Project.
MAIIAQ-8 Transportation Demand Management(TDM)Program: A TDMprogram shall be
instituted for the Project or the buildings shall join an existing program located within a quarter mile
radius from the Project site. The TDM program shall do the following:
a) Publish ride-sharing information for ride sharing vehicles and provide a website
or message board for coordinating rides.
b) Ensure that appropriate bus route information is placed in each building and at
the onsite bus stop.
c) Advertise the TDM Program to the Project's employees.
d) Identify a grace period for which employees who use public transportation can
avoid disciplinary action for arriving late to work.
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MMAQ-9 Bicycle parking shall be provided in safe and convenient locations throughout the
Project, within 30feet from all main entrances. Secure employee bicycle parking shall also be provided
that is separate from public areas.
MMAQ-10 In the Walmart building, there shall be at least one locker for each employee working
during the peak day. A minimum of five percent of the lockers shall be at least 38 inches high by 12
inches wide by 15 inches deep and reserved for employees who bicycle to work. In addition, a minimum
of one shower shall be provided onsite for employees who bicycle to work.
MMAQ-11 Class H bicycle lanes and pedestrian sidewalks shall be provided on the new sections of
roadway constructed or sides of any roadways that are widened as part of this Project.
(DEIR pp. 3.3-47 to 3.3-48; FEIR pp. 4-1 to 4-2.)
Facts in Support of the Finding:
The following analysis includes both mitigated impacts and significant impacts. They are addressed
together here and identified under the Significant and Unavoidable Impacts section due to the
method of analysis discussed within the EIR.
In accordance with CEQA Guidelines 15130(b), this analysis of cumulative impacts is based on a
summary of projections analysis. This analysis considers the current CEQA Guidelines,which includes
the recent amendments approved by the Natural Resources Agency and effective on March 18, 2010.
This analysis is based on the 2003 and 2007 AQMPs. The South Coast Air Basin is in nonattainment for
ozone,particulate matter(PM 10 and PM2.5), and nitrogen dioxide, which means that concentrations of
those pollutants currently exceed the ambient air quality standards for those pollutants. When
concentrations of ozone,PM i o, PM2.5, and nitrogen dioxide exceed the ambient air quality standard, then
those sensitive to air pollution(i.e., children, elderly, sick) could experience health effects such as
decrease of pulmonary function and localized lung edema in humans and animals,increased mortality
risk, and risk to public health implied by altered connective tissue metabolism and altered pulmonary
morphology in animals after long-term exposures and pulmonary function decrements in chronically
exposed humans. (DEIR pp. 3.3-39 to 3.3-40.)
Under the amended CEQA Guidelines, cumulative impacts may be analyzed using other plans that
evaluate relevant cumulative effects. The AQMPs describe and evaluate the future projected emissions
sources in the South Coast Air Basin and sets forth a strategy to meet both state and federal Clear Air
Act planning requirements and federal ambient air quality standards. Therefore,the AQMPs are
relevant plans for a CEQA cumulative impacts analysis. The 2003 AQMP updates the attainment
demonstration for the federal standards for ozone and PM 10; replaces the 1997 attainment demonstration
for the federal CO standard and provides a basis for a maintenance plan for CO for the future; and
updates the maintenance plan for the federal nitrogen dioxide standard that the South Coast Air Basin
has met since 1992. The 2007 AQMP focuses on ozone and PM2.5. The AQMP also incorporates
significant new scientific data, emission inventories, ambient measurements, control strategies, and air
quality modeling. (DEIR p. 3.3-40.)
In accordance with CEQA Guidelines section 15064, subdivision(h)(3), a lead agency may determine
that a project's incremental contribution to a cumulative effect is not cumulatively considerable if the
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Project will comply with the requirements in a previously approved plan or mitigation program. As
identified in Impact AQ-1,the Project complies with the control measures in the 2003 and the 2007
AQMP and all of the SCAQMD's applicable rules and regulations. Under the CEQA Guidelines
Amendments, the lead agency should explain how implementing the particular requirements in the plan,
regulation, or program ensures that the Project's incremental contribution to the cumulative effect is not
cumulatively considerable. To explain how implementing the requirements in the AQMPs ensures the
Project's incremental contribution to the cumulative effect is not cumulatively considerable, the
following three-pronged analysis was performed. To result in a less than significant impact, the
following criteria must be met:
1. Regional analysis: emissions of nonattainment pollutants must be below the regional
significance thresholds. This is an approach recommended by the SCAQMD in its comment
letters.
2. Summary of projections: the project must be consistent with current air quality attainment plans
including control measures and regulations. This is an approach consistent with Section
15130(b) of the CEQA guidelines.
3. Cumulative health impacts: the project must result in less than significant cumulative health
effects from the nonattainment pollutants. This approach correlates the significance of the
regional analysis with health effects, consistent with the court decision,Bakersfield Citizens for
Local Control v. City of Bakersfield(2004) 124 Cal.AppAth 1184, 1219-20.
(DEIR pp. 3.3-40 to 3.3-41.)
The South Coast Air Quality Management District 1993 Handbook suggests three voluntary approaches
to determine cumulative significance. The first approach is a I-percent-per-year reduction(or 18
percent over 18 years to the year 2010) in Project emissions of VOC, NO, CO, PM10, and SOS. This
approach is not straightforward and operational reductions are not easy to quantify. The second
approach is not applicable because it relies on SCAQMD Regulation XV, which was repealed in 1995
and therefore is not applicable. The third approach is to reduce the rate of growth in vehicle miles
traveled and trips. In this approach,the rate of growth in vehicle miles traveled and trips"should be
held to the rate of population or household growth." Data that was used by Southern California
Association of Governments in the AQMP should be used in this approach; however, that data is not
available. Therefore,the approaches in the 1993 SCAQMD Handbook pertaining to cumulative impacts
are not used. (DEIR p. 3.3-41.)
Criterion 1: Regional Impact Analysis
If an area is in nonattainment for a criteria pollutant, then the background concentration of that pollutant
has historically been over the ambient air quality standard. It follows that if a project exceeds the
regional threshold for that nonattainment pollutant, then it would result in a cumulatively considerable
net increase of that pollutant and result in a significant cumulative impact. (DEIR p. 3.3-41.)
The Basin is in nonattainment for nitrogen dioxide, PM10, PM,,,_i, and ozone. Therefore, if the project
exceeds the regional thresholds for PM10, or PM2.5, then it contributes to a cumulatively considerable
impact for those pollutants. Additionally, if the Project exceeds the regional threshold for NO,, or VOC,
which are precursors to the formation of ozone and PMo and PM2,5, then it follows that the Project
would contribute to a cumulatively considerable impact for ozone, PM10 and PM2,5. If the Project
exceeds the threshold for NOx, it would contribute to nitrogen dioxide concentrations. Project impacts
on a regional scale may occur many miles away from the Project site. Project emissions when added to
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the overall emission burden of the Basin could result in a cumulatively significant impact. (DEIR p. 3.3-
41.)
Other parameters (besides those presented in Impact AQ-2)which are used to estimate emissions such
as the worker and vendor trips and trip lengths utilize the CalEEMod defaults, with the addition of 5
daily haul trips during grading,which is to haul the construction equipment to the site or any
import/export of material. (DEIR p. 3.3-41.)
Construction emissions are calculated during each period according to the type and level of construction
activity occurring during the period. Activities can be discreet or overlapping. Emissions occur from
construction equipment, fugitive dust, asphalt paving, architectural coating, and worker and delivery
vehicles. Table 3.3-24 in the Draft EIR summarizes the Project's short-term regional construction
emissions without application of mitigation measures for each construction activity(however, the
particulate matter emissions do include compliance with the mitigation measures outlined in SCAQMD
Rule 403). As shown in the Draft EIR, without mitigation, the Project's construction emissions would
exceed the AQMD regional emission thresholds for VOC and NOx during construction. Therefore, the
short-term construction emissions would have a potentially significant regional impact. (DEIR p. 3.3-
42.)
Mobile source emissions from motor vehicles are the largest single long-term source of air pollutants
from the operation of the Project and consist of emissions from delivery trucks and customer and worker
vehicles. Small amounts of emissions are also generated from area sources such as landscaping
equipment, use of consumer products, natural gas consumption, and architectural coating/painting and
from the operation of the service station. The emissions were generated using CaIEEMod; assumptions
are discussed in Impact AQ-2. Operational emissions (unmitigated) from mobile and area operational
emission sources as derived from CalEEMod and from the service station shown in Table 3.3-25, Table
3.3-26, and Table 3.3-27 for the summer season for years 2010, 2013, and 2030, and Table 3.3-28 for
the winter season within the Draft EIR. (DEIR p. 3.3-43; FEIR p. 4-1.)
As shown in the Draft EIR, operation of the Project would exceed the SCAQMD's regional operational
significance thresholds for VOC,NO,, CO, and PM10. VOC and NOx are precursors in the formation of
as
ozone and both contribute to the formation of PM10 and PM2.5, pollutants for which the Basin h been
identified as a non-attainment area(i.e., an area exceeding national or State standards). Thus, even
though the Project's incremental emissions by themselves would not likely exceed the ozone, PM10 and
PM2.5 standards,their contribution to the overall SCAQMD regional emission burden would add to a
cumulatively considerable impact. Therefore, the Project does not meet Criterion 1. (DEIR p. 3.3-45.)
Note that as discussed in Impact AQ-2, during operation the Project would not exceed the ambient air
quality standards for the pollutants assessed. This is based on localized emissions and concentrations.
The analysis under this impact assesses the emissions based on the regional thresholds identified by the
SCAQMD. Based on the regional thresholds, the cumulative impact is significant. (DEIR p. 3.3-45.)
Criterion 2: Consistency with Existing Air Quality Plans
The geographic scope for cumulative criteria pollution from air quality impacts is the Basin, because
that is the area in which the air pollutants generated by the sources within the basin circulate and are
often trapped. The SCAQMD is required to prepare and maintain an AQMP and a State Implementation
Plan to document the strategies and measures to be undertaken to reach attainment of ambient air quality
standards. While the SCAQMD does not have direct authority over land use decisions, it recognized
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that changes in land use and circulation planning are necessary to maintain clean air. The SCAQMD
evaluated the entire basin when it developed the AQMP. (DEIR p. 3.3-45.)
According to the above analysis, the Project is not consistent with the most recent AQMP without
mitigation. Therefore, the Project does not meet Criterion 2. (DEIR p. 3.3-46.)
Criterion 3: Cumulative Health Impacts
The basin is in nonattainment for ozone, nitrogen dioxide, PM10, and PM2,5, which means that the
background levels of those pollutants are at times higher than the ambient air quality standards. The air
quality standards were set to protect public health, including the health of sensitive individuals (i.e.,
elderly, children, and the sick). Therefore, when the concentration of those pollutants exceeds the
standard, it is likely that some sensitive individuals in the population will experience health effects as
described above in the sub-section, Air Pollutants. However, the health effects are a factor of the dose-
response curve. Concentration of the pollutant in the air(dose), the length of time exposed, and the
response of the individual are factors involved in the severity and nature of health impacts. If a
significant health impact results from Project emissions, it does not mean that 100 percent of the
population would experience health effects. There are no models or methodology to calculate with
certainty what health risks would be experienced from potential cumulative impacts. (DEIR p. 3.3-46.)
The regional analysis of construction emissions indicates that without mitigation,the Project would
exceed the SCAQMD regional significance thresholds for VOC and NO, (ozone precursors). In
addition, long-term operational emissions of VOC and NO, are over the District's significance
thresholds. Because ozone is a secondary pollutant(it is not emitted directly but formed by chemical
reactions in the air),it can be formed miles downwind of the Project site. Project emissions of VOC and
NOx may contribute to the background concentration of ozone and cumulatively cause health effects.
Project emissions of NOx may contribute to the background concentration of nitrogen dioxide and cause
health effects. (DEIR p. 3.3-46.)
Health impacts from ozone exposure may or may not include the following:
(a) Pulmonary function decrements and localized lung edema in humans and animals
(b) Risk to public health implied by alterations in pulmonary morphology and host defense in
animals
(c) Increased mortality risk
(d) Risk to public health implied by altered connective tissue metabolism and altered pulmonary
morphology in animals after long-term exposures and pulmonary function decrements in
chronically exposed humans.
(DEIR p. 3.3-46.)
Short-term exposure to ozone can result in breathing pattern changes, reduction of breathing capacity,
increased susceptibility to infections, inflammation of the lung tissue, and some immunological changes.
Children who live in high ozone communities and who participate in multiple sports have been observed
to have a higher asthma risk. This is a significant cumulative health impact associated with ground-level
ozone concentrations. (DEIR p. 3.3-46.)
Health effects from nitrogen dioxide may include the following:
(a) Potential to aggravate chronic respiratory disease and respiratory symptoms in sensitive groups
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(b) Risk to public health implied by pulmonary and extra-pulmonary biochemical and cellular
changes and pulmonary structural changes
(c) Contribution to atmospheric discoloration
(DEIR p. 3.3-47.)
Additionally, during operation, the Project could result in a significance cumulative contribution to
PMIO. Sensitive individuals may experience health impacts when concentrations of those pollutants
exceed the ambient air quality standards. Health impacts from particulate matter may include the
following: (a) exacerbation of symptoms in sensitive patients with respiratory or cardiovascular disease;
(b) declines in pulmonary function growth in children; (c) and/or increased risk of premature death from
heart or lung diseases in the elderly. Therefore, the Project does not meet Criterion 3. (DEIR p. 3.3-47.)
Criteria pollutants are treated differently from toxic air contaminants because criteria pollutants have
state and federal standards and are set in a different regulatory environment than toxic air contaminants.
Diesel particulate matter is a major part of PM2.5 and PM10 and thus is included in the criteria pollutant
impact analysis for PM2.5 and PM10. Benzene is a hydrocarbon whose emissions are also estimated as
part of the Project's operational VOC emissions (see regional operational emissions). Further, risk (as
in estimating health risks)is estimated on a probability basis (e.g., cancer risk of 10 in one million)
while criteria pollutant impacts are expressed as a not to be exceeded basis. Therefore, criteria pollutant
impacts are not expressed as a risk. (DEIR p. 3.3-47.)
Construction: Less than significant. Mitigation measures AQ-1, AQ-2, and AQ-3 would reduce the
significance of construction emissions, as shown in Table 3.3-29 of the Draft EIR.
Table 0-3: Construction Air Pollutant Emissions (Mitigated)
Grading of main Project 46.1 95.8 70.7 0.1 11.9 6.7
Grading of outparcels 8.9 72.2 40.5 0.1 7.4 4.8
Paving(parking lots, 9.4 35.7 22.2 <0.1 3.4 3.1
1 Lroads)
i Building 1 12.2 76.9 53.6 0.1 6.7 15.1
I Coating I 58.0 3.1 1 3.1 0.0 0.5 0.3
I Overlapping. 67.4 j 38.8 25.3 <0.0 j 3.9 3.4
Paving, Coating
Overlapping: 70.2 80.0 567 0.1 17.2 5.4
Building, Coating
Maximum Daily 70.2 95.8 70.7 0.1 11.9 6.7
Emissions
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Significance Threshold ; 75 100 550 150 150 j 55
Significant Impact? No No No No 4 No No
Notes:
The maximum daily emissions refer to the maximum emissions that would occur in one
day.
VOC =volatile organic compounds NO,=nitrogen oxides CO=carbon
monoxide
SOX= sulfur oxides PMIo and PM2.$ =particulate matter
Source of emissions: Appendix A: CaIEEMod Output.
Source of thresholds: South Coast Air Quality Management District 201 la.
The emissions reductions from AQ-I are estimated by CaIEEMod. The emission reductions from AQ-2
(not allowing overlap)are manually estimated by changing the overlapping additions. To attribute the
emission reductions from AQ-3: the unmitigated emissions were estimated assuming 250 grams of
VOC per Liter; assuming 125 grams per Liter would reduce emissions by half (DEIR p. 3.3-49.)
Operation: Significant and unavoidable. The Project would result in a cumulatively significant
impact even after mitigation because of the exceedances of the SCAQMD's regional emission
thresholds for VOC,NOx, CO, and PM10. The Project may result in cumulative health effects from
cumulative exposures from ozone, nitrogen dioxide, and PM10. The emission reductions resulting from
the implementation of mitigation measures AQ-5, AQ-7, AQ-8, AQ-9, AQ-10, AQ-11, and T-ba would
result in approximately a 1 percent reduction in motor vehicle emissions (see Table 3.17-6 in the
Greenhouse Gas Draft EIR section for documentation). This reduction would not reduce operational
emissions to less than significant. (DEIR p. 3.3-49.)
Impact AQ-4: Would the proposed Project expose sensitive receptors to substantial pollutant
concentrations?
Finding: Potential impacts of the Project on Air Quality are discussed in detail in Section 3.3 of the
Draft EIR. Eased on the entire record before it, the City finds that this impact is potentially significant
but will be mitigated to a less than significant level through the implementation of Mitigation Measure
AQ-1 and AQ-2. (DEIR pp.3.3-50 to 3.3-57.) These mitigation measures, enumerated below, are
adopted and incorporated into the Mitigation Monitoring and Reporting Program for the Project, and
will be implemented as specified therein.
See MMAQ-1 and MMAQ-2 under linpact AQ-1 above.
(DEIR p.3.3-57.)
Facts in Support of the Finding: The closest existing sensitive receptors are residences located
approximately 25 meters(82 feet) to the east and southeast of the Project across Karon Street. A review
of the City of Redlands General Plan(City of Redlands 1995)indicates that the areas to the north, south,
and west of the Project site have been designated as commercial and, therefore,would not involve the
future location of sensitive receptors in these areas. The closest schools are the Citrus Valley High
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School located 0.3 miles north of the Project, the Lugonia School located 0.8 mile east of the Project,
Clement Middle School located 1.0 miles east of the Project, and the Packinghouse Christian Academy
located 0.6 mile west of the Project. (DEIR p.3.3-50; FEIR p. 4-1.)
Criterion 1: Localized Significance Analysis
The localized analysis uses thresholds that represent the maximum emissions for a Project that would
not cause or contribute to an exceedance of the most stringent applicable federal or State ambient air
quality standard,and are developed based on the ambient concentrations of that pollutant for each source
receptor area. The thresholds are also based on the location of the sensitive receptors. If the Project
results in emissions less than those thresholds, it follows that the Project would not cause or contribute
to an exceedance of the standard and, therefore, would not expose sensitive receptors to substantial
pollutant concentrations. (DEIR p.3.3-50.)
The localized analysis discussed in Impact AQ-2 demonstrated that with incorporation of mitigation, the
Project would not exceed any SCAQMD localized significance threshold during construction or
operation. Therefore,the Project would not expose sensitive receptors to substantial pollutant
concentrations. The Project meets Criterion 1. (DEIR p.3.3-50.)
Criterion 2: CO Hot Spot Analysis
The CO hot spot analysis presented in the discussion of Impact AQ-2 found that the CO emissions from
Project-related traffic,combined with CO emissions resulting from the growth in background traffic and
identified development projects, would not result in the formation of a CO hot spot and, thus, not result
in an exceedance of the CO air quality standards. The standards are set to protect the health of sensitive
individuals. Because the standards would not be exceeded, the Project would not result in a significant
impact related to CO. Therefore, the Project meets Criterion 2. (DEIR pp.3.3-50 to 3.3-51.)
Criterion 3: Toxic Air Contaminants
Cancer risk is expressed in terms of a probability that an individual out of a population of one million
people would contract cancer because of continuous exposure to toxic air contaminants over a specified
period. For sensitive receptors such as residences, this exposure period is a lifetime of 70 years. (DEIR
p.3.3-51.)
Assumptions
The operation of the Project would result in the release of two primary TACs that pose the greatest
potential to cause a health risk to the community surrounding the Project. These two TACs are diesel
particulate matter(DPM)from the operation of diesel-powered trucks and transport refrigeration units
and benzene from the operation of a gasoline service station that would be located at the southwest
comer of the Project- Exposure to these TACs would have the potential to cause health risks in terms of
excess risk of cancer and chronic and acute non-cancer health effects as discussed below. (DEIR p.3.3-
51.)
The air dispersion model,receptor locations, and meteorological data used in the HRA used the same
information as that used in the assessment of criteria pollutant impacts described in Impact AQ-2.
(DEIR p.3.3-51.)
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The cancer risk.from IPM and benzene is calculated by multiplying the annual average DPM I and
benzene concentrations calculated using the AERMOD model and an inhalation exposure factor. See
the Draft EIR for the associated.equations. (DEIR pp. 3.3-51 to 3. -52.) Values for the Inhalation
Exposure Factor for DPM and Benzene are shown in Table .3-30 of the Draft EIR. (DEIR p.3.3-52.)
Exposures to TACs such as DPM and benzene can also cause chronic(long-term)related non-cancer
illnesses such as reproductive effects,respiratory effects, eye sensitivity,immune effects,kidney effects,
blood effects, central nervous system,girth defects,or ether adverse environmental effects. Risk
characterization for non-cancer health risks from.DPM and benzene;is expressed as a hazard index(HI).
The H1 is a rattan of the predicted concentration of the Project's emissions to a concentration considered
acceptable to public health professionals,termed:the Reference Exposure Level L). A significant
risk is defined by the SCAQMD as an H(of I or greater. (DEIR p.3.3-52.)
For the assessment of health risks to sensitive/residential receptors,the IPM emissions factors derived
from the ARB EMFAC model were developed,as an average of fleet emission factor over a 70-year
time period commencing in 2010(2010 to 2080 average emissions) and in 2013(2013 to 2083 average
emissions). For the year 2030 assessment,the DPM emission factors from the EMFAC2007 model in
the year 2030 were utilized. The DPM emission factors used in this assessment are provided in Table
3.3-31 of the Draft EM (DEIR p.3.3-54.)
Benzene emissions are associated with the operation of a gasoline service station located at the
southwestern corner of the Project. Benzene emissions were estimated considering the following
emission processes; Offloading of cargo tank trucks into the storage tanks at the station(Loading
emissions); Gasoline vapors released from the storage tank due to temperature and pressure changes
within the storage tank vapor space(Breathing emissions); Vehicle refueling process(Refueling
emissions),and spillage of fuels during vehicle fueling(Spillage emissions). The emission factors for
benzene emissions associated with the gasoline service station are shown in Table 3.3-32 of the Draft
IR. (DEIR p.3.3-54.)
The benzene emission factors were assumed to be constant over both the 70-year and 40-year exposure
periods An annual gasoline throughput of 6.4 million gallons was assumed to estimate benzene
emissions, 's amounts to the delivery of tanker truck with two 8,800 gallon each day. (DEIR
p.3,3-55.)
The SCAQMD health risk significance thresholds specifically state tithe cancer threshold(10 in one
million cancer risk)is based on the incremental increase. Communications with SCAQMID staff
indicate that the SCAQMD does not discourage lead agencies from reporting the total cumulative impact
from all sources in the basin on an individual receptor;however the SCAQMD
not requested that a
lead agency use the incremental threshold(10 in I million cancer risk)to determine cumulative
significance.ce. DEIl p.3, -5 .)
This analysis addresses the impact to sensitive receptors,not onsite or offsite worker receptors, since the
sensitive receptors resid ces)would receive a greater impact than offsite workers. The offsite workers
would not he exposed to the onsite pollutants for as long as the residences because they would only be
there for eight hours or less. (DMR p.3.3-55 )
Onsite workers are not required to be addressed through this health risk assessment process. A
document published by the California Air Pollution Control Officers Association(2009),Health Risk
Assessments for Proposed Land Use Projects,indicates that onsite receptors are included in risk
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assessments if they are persons not employed by the Project. Persons not employed by the Project
would not remain onsite for any significant period. Therefore, a health risk assessment for onsite
workers is not required or recommended. The document also states that the guidance does not include
how risk assessments for construction projects should be addressed in CEQA. Risks near construction
projects are expected to be included at a later time as the toxic emissions from construction activities are
better quantified. The equipment used during construction would emit DPM, which has been identified
by the ARB as a carcinogen. However, the DPM emissions during construction are short term in nature.
Determination of the health risk from DPM is considered over a 70-year exposure time for sensitive
receptors. Therefore,considering the short timeframe during which DPM emissions would be emitted
during construction, exposure to DPM is anticipated to be less than significant during construction.
(DEIR p.3.3-56.)
During operation of the Project, diesel-powered delivery vehicles would emit DPM emissions from
truck exhausts, idling, and the use of transport refrigeration units. A health risk assessment of these
DPM emissions was performed to assess the health consequences from the DPM emissions from the
onsite truck activity associated with Project operations on nearby sensitive receptors such as residences.
Estimates of DPM emissions were prepared using the trip generation and vehicle information from the
Project-specific traffic impact analysis, the diesel truck inventory established for the Project and
emission factors from the ARB EMFAC mobile source emission model. Because the California
Environmental Protection Agency methodology(see report for reference) dictates that health risks are
calculated over periods of 70-years for sensitive receptors, the estimates of DPM emissions were also
averaged over each respective period using the fleet average emission factors contained in the
EMFAC2007 model. (DEIR p.3.3-56.)
In addition to the DPM emissions from the diesel truck traffic, the Project description also calls for the
operation of a gasoline service station located at the southwest comer of the Project. As a result,
emissions of benzene from the operation of the service station were also analyzed in the health risk
assessment. Benzene has been identified by the ARB as a toxic air contaminant having both cancer and
non-cancer health impacts. The estimation of benzene emissions follows the procedures of the
California Air Pollution Control Officers Association risk assessment guidelines for gasoline service
stations. The estimation of health risks followed the guidance from the California Office of
Environmental Health Hazard Assessment that uses the AERMOD air dispersion model to disperse the
DPM and benzene emissions and to determine health risks from nearby sensitive receptors. (DEIR
p.3.3-56.)
The results of the health risk assessment are summarized in Table 3.3-33 of the Draft EIR and indicate
that the Project's operations would not exceed the SCAQMD's cancer risk health risk significance
threshold for any scenario year. (DEIR pp.3.3-56 to 3.3-57.) All other receptors and locations outside
of the Project site would have a cancer risk less than the values listed in Table 3.3-33 in the Draft EIR.,
including the Packinghouse Christian Academy and the Citrus Valley High School. Contours of the
cancer risk are shown on page 4-3 of the Final EIR,which was created using the results of the Health
Risk Assessment. As shown in the figure, the greatest risk is near the fueling station,which is located
away from the residences and the high school. The maximum risk shown to sensitive receptors is the
residences located between the 0.6 and 0.8 cancer risk contour to the east of the project. (FEIR p. 4-3.)
The maximum chronic non-cancer risk is calculated to have a value of 0.0006 at the maximally
impacted sensitive receptor or worker receptor. An acute non-cancer hazard index due to the emissions
of benzene was estimated to be 0.001. The magnitudes of both the acute and chronic non-cancer indices
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are less than the SCAQMD hazard index of 1.0. Therefore, the operation of the Project would not
exceed the SCAQMD's threshold for chronic or acute non-cancer risk. (DEIR p.3.3-57.)
Impact AQ-5: Would the proposed Project create objectionable odors affecting a substantial number of
people?
Finding: Potential impacts of the Project on Air Quality are discussed in detail in Section 3.3 of the
Draft EIR. Based on the entire record before it, the City finds that this impact is potentially significant
but will be mitigated to a less than significant level through the implementation of Mitigation Measure
AQ-12. (DEIR pp.3.3-57 to 3.3-58.) These mitigation measures, enumerated below, are adopted and
incorporated into the Mitigation Monitoring and Reporting Program for the Project, and will be
implemented as specified therein.
MMAQ-12 The Project shall have a Maintenance Plan for any detention basins, which includes a
description oJ'the routine and non-routine maintenance. The Plan shall include the following
components:
Routine inspections,particularly after major rainfall events, to check for obstructions and damage and
to remove debrisltrash.
Vegetation management, including prohibiting the use of fertilizers and pesticides in and around the
basins to minimize entry into downstream waters or the underwater basin.
Routine trash, debris, and litter removal.
Structural component check, to inspect the outlet structure, inlet, orifice, emergency spillway (if
applicable)on a regular basis.
Non-routine maintenance such as bank erosion stabilization and ensuring that all surfaces of the basin
are vegetated for proper infiltration of runoff
Sediment removal once per year to ensure that the depth of the accumulated sediment is less than 25
percent of the original design depth. Sediment blocking inlets or outlets should be removed.
(DEIR p.3.3-58.)
Facts in Support of the Finding: Diesel exhaust and VOCs would be emitted during construction of
the Project,which are objectionable to some; however, emissions are short-term in nature only lasting as
long as the construction equipment operates, would disperse rapidly from the Project site,and therefore
should not be at a level to induce a negative odor response. (DEIR p.3.3-58.)
The odors from the operation of the Project would include the occasional scent from cooking odors from
the restaurants, odors from trash recycling, and from the gasoline service station. However,these
emission sources are generally located within the western half of the Project and,after accounting for
distance and air dispersion, would not induce a negative odor response to nearby sensitive receptors.
(DEIR p.3.3-58.)
Poorly maintained detention basins could result in odors. Therefore, with the implementation of
Mitigation Measure AQ-12, regular maintenance, as required, within the proposed detention basin will
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ensure the basin will operate as intended and will not emit any objectionable odors. Thus,no significant
impact would result after implementation of mitigation. (DEIR p.3.3-58.)
3. Biological Resources
Impact BR-1: Would the proposed Project have a substantial adverse effect, either directly or through
habitat modifications,on any species identified as a candidate, sensitive, or special status species in local
or regional plans,policies, or regulations, or by the CDFG or USFWS?
Finding: Potential impacts of the Project on Biological Resources are discussed in detail in Section 3.4
of the Draft EIR. Based on the entire record before it, the City finds that this impact is potentially
significant but will be mitigated to a less than significant level through the implementation of Mitigation
Measure BR-la and BR-lb. (DEIR pp.3.4-12 to 3.4-13.) These mitigation measures, enumerated
below, are adopted and incorporated into the Mitigation Monitoring and Reporting Program for the
Project, and will be implemented as specified therein.
Western Burrowing Owl(BU099
MMBR-la Aprotocol.focus survey for BUOW shall be conducted pursuant to CDFG protocols and
prior to grading activities to determine presence or absence. If owls are found,passive relocation (i.e.,
use of one-way doors to ensure owls have been evacuated and then collapse of burrows)shall be used to
ensure that no owls are directly injured or killed during construction. Active relocation shall not be
employed unless approved by the CDFG prior to grading, and if passive relocation has been determined
not to be practical. Active relocation would entail capture of the owls, relocation off-site, construction
of an artificial burrow, and fencing and feeding to habituate the owls to the new burrow.
Nesting Birds
MMBR-lb Vegetation removal shall occur outside of the nesting bird season (February to August).
If such avoidance is not feasible, the applicant shall have a qualified biologist survey for actively
nesting birds within the nesting bird season. Any active nests identified shall have highly visible
construction fencing installed not less than 100-
.Pet(200-feetfor birds of prey)of the active nests.
Disturbance shall not occur within the buffer area until the biologist determines that the young have
fledged.
(DEIR p.3.4-13.)
Facts in Support of the Finding: The biological resource and habitat assessment report(LSA 2005b,
MBA 2009a)indicated that none of the special-status plants was observed on the site during the field
surveys. The Project site is regularly disked and is highly disturbed from past agricultural and human
activities, and dominated by non-native species. Therefore, there is a very low potential for any rare
plant species to occur on the Project site. (DEIR p.3.4-14.)
None of the special-status wildlife species was observed in the 2005 and 2009 surveys. However,the
literature survey suggested that the Project site provides moderately suitable habitat for SBKR and
BUOW. Both of these species are special-status wildlife species. Therefore, a live-trapping effort for
the federally listed endangered SBKR was conducted within portions of the Project site(Appendix Q.
The focused survey was conducted to determine the presence or absence of SBKR on the site, as
suggested by the habitat assessment report. According to the focused SBKR survey report, SBKR were
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not captured as part of the 2009 trapping effort and they are not currently present on the Project site.
The species diversity is very low within the survey area(MBA 2009b). (DEIR p.3.4-14.)
Additionally,the Project site is not located within USFWS designated critical habitat for SBKR. The
closest designated critical habitat area is approximately one mile north of the Project site. Based on the
negative findings of the focused surveys and the disturbed nature of the habitat on-site, development and
operation of the Project will not directly impact SBKR. Therefore, impacts to SBKR are less than
significant. (DEIR p.3.4-14.)
The Project site contains suitable burrows and foraging habitat for BUOW. Even though BUOW were
not observed during the biological survey, there is a potential for BUOW to utilize the site. Therefore,
significant impacts could occur to BUOW from the Project without implementation of appropriate
mitigation measures. (DEIR p.3.4-14.)
A number of common variety bird species were observed foraging on the Project site(MBA 2009).
None of the common variety bird species observed were"special-status" species,however,the Project
site contains approximately 0.25 acre of eucalyptus trees that will,presumably,be taken off the site.
Ground clearance and vegetation removal (including the 0.25 acre of eucalyptus trees)could result in
potential impacts to the nesting birds, as per Section 3503 of the State Fish and Game Code. Therefore,
significant impacts could occur to nesting birds from the Project without implementation of appropriate
mitigation measures. (DEIR p.3.4-14.)
4. Cultural Resources
Impact CR-2: Would the proposed Project cause a substantial adverse change in the significance of an
archaeological resource pursuant to CEQA §15064.5?
Finding: Potential impacts of the Project on Cultural Resources are discussed in detail in Section 3.5 of
the Draft EIR. Based on the entire record before it, the City finds that this impact is potentially
significant but will be mitigated to a less than significant level through the implementation of Mitigation
Measure CR-2a.through CR-2c. (DEIR pp.3.5-18 to 3.5-21.) These mitigation measures, enumerated
below, are adopted and incorporated into the Mitigation Monitoring and Reporting Program for the
Project, and will be implemented as specified therein.
MM CR-2a Cultural resource monitoring by a qualified Project Archaeologist andlor his
representative in thefteld, an Archaeological Inspector, is required during construction-related
earthmoving. The Inspector shall comply with the cultural mitigation-monitoring plan (CMMP) written
and signed by the Project Archaeologist. The CMMP shall be based on excavation parameters
associated with a rough grading plan the City will approve as part of the construction permitting
process and should, in addition to the qualities noted below, include certain archaeological
performance standards specific to the required earthmoving methods. A pre grade meeting shall occur
between the Project Archaeologist, the grading contractor, and a City representative to discuss the
details of the CMMP.
The CMMP shall contain the following attributes, and if needed, additional attributes may be added at
the request of the City:
i) Archaeological monitoring is defined to include monitoring of all excavation activities of virgin
earth encountered within the Project site once Project-related excavations occur at least three
(3)feet below the modern ground sur/ace.
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ii) On-site archaeological monitoring must be undertaken by the Project Archaeologist andlor a
qualified archaeological inspector whose credentials shall be provided to the City of Redlands.
iii) The archaeological inspector shall perform monitoring duties safely and must avoid slowing the
rough grading work ifpossible. The inspector shall keep a daily log of all activities and
observations. Copies of*the log shall be delivered at the end of each workweek to the Applicant
or his/her designated on-site representative.
iv) It is not necessary for the archaeological inspector to observe cuts of*earth than were turned
during previous Project-related excavations, but the inspector must make certain that no virgin
earth will be turned by the contractors before the end of a work day before discontinuing his/her
work for the day.
v) If cultural deposits are observed by the inspector, earthmoving shall be diverted temporarily
around the find until the deposits have been thoroughly examined. The inspector will create a
buffer zone of at least 20 feet around the furthest margins of the find with lathe and yellow tape.
E arthmoving shall be allowed to proceed through the area of the find only after the Project
Archaeologist determines and reports to the City that all potential isolated artifacts are
recovered andlor the site has been mitigated to the extent necessary.
vi) Any observed cultural resources made on or before about 1965 shall be identified and plotted
following standard professional archaeological practice. Examination by an archaeological
specialist shall be included where necessary, dependent upon the artifacts,features, or sites that
are encountered. Resources that are isolated andlor considered not significant by the inspector
will be plotted but need not be further analyzed or curated in a local museum.
vii)If it is determined that the observed resources are part of previously recorded resource CA-SBR-
7765H, CA-SBR-7766H or CA-SBR-7767H, work on the find can be discontinued.
viii) Ifthe find is not a previously recorded resource, it is understood that the archaeological
team will undertake significance determinations with the concurrence of the City. If it is found
that a significance determination is required for an inadvertent find, the site shall be evaluated
and recorded in accordance with requirements of California Code of Regulations§15064.5(l)
thusly:
a) If the resource is determined Not Significant, no additional mitigation measures, save for
recordation of the site onto DPR523 site forms, will be required. Construction-related
earthmoving can resume in the area of thefind.
b) If the resource is determined to be Significant, it is assumed that the site cannot be
avoided by construction and Phase III data recovery must be undertaken before
construction-related earthmoving at the resource can continue.
ix) Any resources removed_ om the Project site for curation in an appropriate facility shall be those
resources considered Signfizcant under CR-2a (viii) above. Resources recovered and examined,
but not considered significant, shall be catalogued and reburied on the Project site where later
Project-related disturbance is not anticipated.
x) A final report of findings will be prepared by the Project Archaeologist for submission to the
Proponent and the City. Reports associated with cultural resource finds shall be submitted to
the EIC at the University of California-Riverside. The report will describe the history of the
Project area, summarize field and laboratory methods used, if applicable, and include any
testing or special analysis in/6rination conducted to support the resultant findings.
xi) In the event that any potentially significant cultural remains are encountered by earthmoving
when the monitor is not present, the earthmoving contractor will divert excavations around the
find location and the Project Archaeologist shall called to the location immediately to recover
the remains.
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MM CR-2b Once a depth of'three (3)feet is reached by construction-related earthmoving, the
potential for impacts to significant archaeological resources rises to a "moderate"level. Earthmoving
of all "moderate"potential soils shall be inspected on a full-time basis, but the Project Archaeologist
may, at his or her discretion, terminate monitoring if and only if no buried cultural resources have been
detected after 50 percent of the qualifying ground has been moved during the grading process. IJ'any
buried cultural resources are detected by the Inspector, monitoring shall continue until 100 percent of
the virgin earth on the Project site has been inspected.
MM CR-2c Following CEQA Guidelines§15064.5 and the objectives, criteria and procedures
required by PRC 21083.2, should any previously unidentified prehistoric or historic-era resources be
found during monitoring, they shall be Phase 11 tested and evaluated for significance following
performance standards found in the MMP(see MAI CR-2a[i through x])prior to allowing a continuance
of grading in the area of the find. Should the Project Archaeologist determine that the finds are
significant, and with the concurrence of the City, the finds shall be Phase III excavated before
earthmoving is allowed to continue in the area.
(DEIR pp.3.5-18 to 3.5-21.)
Facts in Support of the Finding: MBA archaeological staff conducted a cultural resource records
search at the Archaeological Information Center(AIC) on August 1, 2007. The search shows that three
known historic cultural resources are located within the Project site, and that 15 additional cultural
resources are located within one mile of the Project area boundary. Cultural resources CA-SBR-7765H,
CA-SBR-7766H and CA-SBR-7767H are located within the Project site and these resources could be
significant archaeological resources. Thus, MBA conducted Phase 11 testing within the site footprints.
As described in Impact CR-1, the Assessment determined that these cultural resources are not significant
and do not meet any of the following criteria established by CEQA Guidelines Section 15064.5 to be
considered "significant archaeological resources"(MBA 2009b). (DEIR p.3.5-18.)
It is known that the whole of the Project site was plowed and utilized for citrus,which destroys the
integrity of the topsoil to a point roughly three(3) feet below modem grade. Certain places on the
property once exhibited structures and buried utilities, which can disrupt soils at an even greater depth,
but most of the property was in citrus. Despite this damage, and based upon the prehistoric sensitivity of
the Project area, there is potential for impacts to potentially significant archaeological resources at depth.
MBA's testing work showed that the upper three feet of soil has "low" potential for impacts to
archaeological resources because of fanning related disturbances, but depths below the three foot level
have a"moderate"potential for impacts to archaeological resources. Therefore,mitigation measures
MM CR-2a through MM CR-2c shall be implemented to reduce potentially significant archaeological
impacts to a less than significant level in those portions of the Project site with moderate potential (i.e.
three feet below modem grade). (DEIR p.3.5-18.)
Impact CR-3: Would the proposed Project directly or indirectly destroy a unique paleontological
resource or site or unique geologic feature?
Finding: Potential impacts of the Project on Cultural Resources are discussed in detail in Section 3.5 of
the Draft EIR. Based on the entire record before it, the City finds that this impact is potentially
significant but will be mitigated to a less than significant level through the implementation of Mitigation
Measure CR-3a. (DEIR pp.3.5-21 to 3.5-23.) These mitigation measures, enumerated below, are
adopted and incorporated into the Mitigation Monitoring and Reporting Program for the Project, and
will be implemented as specified therein.
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MM CR-3a Limited paleontological resource monitoring by a qualified Project Paleontologist andlor
his representative in the field, a Paleontological Inspector, is required during construction-related
earthmoving. The Paleontological Inspector shall comply with a paleontological resource impact
mitigation plan (PRIMP) written and signed by the Project Paleontologist. The PRIMP shall be based
on excavation parameters associated with a rough grading plan the City will approve as part of the
construction permitting process and should, in addition to the qualities noted below, include certain
paleontological performance standards specific to the required earthmoving methods. A pre-grade
meeting shall occur between the Project Paleontologist, the grading contractor, and a City
representative to discuss the details of the PRIMP.
The PRIMP shall contain the following attributes, and if needed, additional attributes may be added at
the request of the City:
i) Paleontological monitoring is defined to include monitoring of all excavation activities of virgin
earth encountered within the Project site once Project-related excavations occur at least fifteen
(15)feet below the modern ground surface.
ii) Iffossil remains are found, the Project Paleontologist must develop a storage agreement with a
museum repository acceptable to the City to allowfor the permanent storage and maintenance of
any fossil remains recovered in the Project area as a result of the mitigation program, and for
the archiving of associated specimen data and corresponding geologic and geographic site data.
iii) Any recovered fossil remains will be prepared to the point of identification and identified to the
lowest taxonomic level possible by knowledgeable paleontologists. The remains then will be
curated(assigned and labeled with museum repository,fossil specimen numbers and
corresponding fossil site numbers, as appropriate;placed in specimen trays and, if necessary,
vials with completed specimen data cards)and catalogued. Associated specimen data and
corresponding geologic and geographic site data will be archived(specimen and site numbers
and corresponding data entered into appropriate museum repository catalogs and computerized
databases)at the museum repository by a laboratory technician. The remains then will be
accessioned into the museum repository,fossil collection, where they will be permanently stored
and maintained. The associated specimen and site data will be made available for future study
by qualified investigators.
iv) A final report of findings will be prepared by the Project Paleontologist for submission to the
Proponent and the City. The report shall be submitted to the museum in which the fossil
collection has been curated. The report will describe thefiindss, i m field and laboratory
summarize i
methods used, if applicable, and include any testing or special analysis information conducted to
support the resultant findings.
v) In the event that any fossil remains are encountered by earthmoving when the monitor is not
present, the earthmoving contractor will divert excavations around the fossil site and the Project
Paleontologist shall called to the location immediately to recover the remains.
(DEIR pp.3.5-22 to 3.5-23.)
Facts in Support of the Finding: A paleontological records check was prepared in August 13, 2007
from Eric Scott of the San Bernardino County Museum. The paleontological records review showed
that the entire Project site is located upon middle Holocene younger axial-valley alluvium, and that no
known fossil resources are located within I mile of the Project area in any direction. The Holocene
sediments have low potential to contain fossil resources; however, the Holocene units may overlie older
Pleistocene alluvium sediments. The Pleistocene alluvial deposits can carry significant fossil deposits
and therefore have"high"potential for significant impacts(MBA 2009b). In this area,such deposits are
typically encountered at a point about 15 feet below modem grade and lower. Therefore,the Project has
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potential to result in impacts to unique paleontological resources without mitigation measures once
Project-related excavations reach 15 feet below modem grade. (DEIR p.3.5-21.)
Impact CR-4: Would the proposed Project disturb any human remains, including those interred outside
of formal cemeteries?
Finding: Potential impacts of the Project on Cultural Resources are discussed in detail in Section 3.5 of
the Draft EIR. Based on the entire record before it, the City finds that this impact is potentially
significant but will be mitigated to a less than significant level through the implementation of Mitigation
Measure CR-4a. (DEIR pp.3.5-23 to 3.5-24.) These mitigation measures, enumerated below, are
adopted and incorporated into the Mitigation Monitoring and Reporting Program for the Project, and
will be implemented as specified therein.
MM CR-4a If human remains are uncovered under any circumstances, the County Corner shall be
notified. If the Corner determines that the remains are of Native American origin,pursuant to Public
Resource Code Section 5097.98, the Applicant shall halt work, and shall ensure that the immediate
vicinity of the find is not further disturbed, and that notification of,* and conferral with, likely decedents
occurs immediately. Through coordination between the Coroner, Native American Heritage
Commission, local Native American representatives, the archaeological consultants, and Applicant, the
disposition of the remains will be determined. The cost of the recovery and disposition of the remains
shall be the responsibility of the Applicant.
(DEIR p.3.5-23.)
Facts in Support of the Finding: Based on the records search and field survey, no human remains are
located in or near the Project site and none are expected (MBA 2009b). However,there is always the
potential that unknown human remains will be uncovered. Consequently, impacts in this regard are
potentially significant. Therefore, mitigation will be imposed to reduce impacts to human remains to a
level of less than significant. In addition, State law (California Health and Safety Code 7050.5) requires
that, if human remains are recovered, the County Coroner shall be immediately notified and the
excavation shall be halted until the situation is resolved. With implementation of mitigation, impacts
associated with human remains will be less than significant for the Project. (DEIR p.3.5-23.)
5. Geology and Soils
Impact GS-2: Would the proposed Project result in substantial soil erosion or the loss of topsoil?
Finding: Potential impacts of the Project on related to Geology and Soils are discussed in detail in
Section 3.6 of the Draft EIR. Based on the entire record before it, the City finds that this impact is
potentially significant but will be mitigated to a less than significant level through the implementation of
Mitigation Measures MM HWQ 1a and HWQ lb. (DEIR p.3.6-18.) These mitigation measures,
enumerated below,are adopted and incorporated into the Mitigation Monitoring and Reporting Program
for the Project,and will be implemented as specified therein.
See Mitigation Measures-,VMHWQ ]a-and HWQ lb under the hydrology and Water Quality section of
the Findings.
(DEIR p.3.6-18.)
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Facts in Support of the Finding: According to the Geotechnical Report(2005)conducted for the
Project, mass grading of the majority of the site is expected to entail minor cuts and fills (±5 feet) from
existing grades to establish building pads and to provide for surface drainage of the site,thus resulting in
a balance of cut and fill. The entire Project site is proposed to be massed graded in one phase. During
construction activities, there would be the potential for surface water to carry sediment from on-site
erosion into the stormwater system and local waterways. Soil erosion may occur along Project
boundaries during construction in areas where temporary soil storage is required. In addition,the
geotechnical report indicated that a majority of the areas planned for development on the Project site
have soil types with moderate erosion potential. Therefore, a potentially significant risk of erosion
associated with construction activities exists. However, consistency with mitigation measures MM
HWQ la- and HWQ 1-b (See DEIR Section 3.8 Hydrology and Water Quality), as well as all other
applicable water quality standards and requirements will reduce impacts from erosion associated with
construction activities to a level of less than significant. (DEIR p.3.6-18.)
Impact GS-3: Would the proposed Project be located on a geologic unit or soil that is unstable, or that
would become unstable as a result of the Project and potentially result in on-or off-site landslide, lateral
spreading, subsidence, liquefaction or collapse?
Finding: Potential impacts of the Project on related to Geology and Soils are discussed in detail in
Section 3.6 of the Draft EIR. Based on the entire record before it, the City finds that this impact is
potentially significant but will be mitigated to a less than significant level through the implementation of
Mitigation Measures GS-3a. (DEIR pp.3.6-18 to 3.6-19.) These mitigation measures, enumerated
below, are adopted and incorporated into the Mitigation Monitoring and Reporting Program for the
Project, and will be implemented as specified therein.
MM GS-3a The developer shall implement the grading recommendations identified in the
Geotechnical Report(KA 2005). Prior to the commencement of building construction, the applicant
shall retain a qualified engineer to design foundations adequate to support the Project's structures
where necessary, based on the recommendations of the Geotechnical Report(KA 2005). Settlement
analysis shall be performed once the structural design loads and foundation system geometry have been
defined for each building. The total settlement due to foundation loads shall not exceed the 1-inch. The
differential settlements shall be less than ]-inch between adjacent columns andperimeter-Kalls to
adjacent columns, and less than 112-inch in 40 feet along perimeter walls. Most of the settlement is
expected to occur during construction as the loads are applied.
(DEIR p.3.6-19.)
Facts in Support of the Finding: The geotechnical report for the Project site indicates that the
underlying bedrock is capable of supporting the proposed development(KA 2005). In addition, the
potential for liquefaction is considered low based on the analysis of soil characteristics and depths to the
groundwater(see Impact GS-1). However, the Preliminary Geotechnical Investigation by Cruzan&
Associates Inc. in 2005 concluded that the subsurface soils generally consisted of 6 to 12 inches of loose
disturbed soil and a thin layer of fill underlain by native alluvial silty sand. These soils are disturbed,
have low strength characteristics, and are highly compressible when saturated. The Geotechnical
Engineering Investigation Report(KA 2005)provided grading recommendations based on the
underlying soil conditions, which should be implemented during grading activities. Unless these
recommendations are implemented,the Project has the potential to produce potentially significant
impacts concerning unstable geologic units. (DEIR pp.3.6-18 to 3.6-19.)
84
City of Redlands-Redlands Crossing Project
Facts,Findings,and Statement of Overriding Considerations
Related to the Final Environmental Impact Report
6. Hazards and Hazardous Materials
Impact HHM-I: Would the proposed Project create a significant hazard to the public or the
environment through the routine transport, use, or disposal of hazardous materials?
Finding: Potential impacts of the Project on related to Hazards and Hazardous Materials are discussed
in detail in Section 3.7 of the Draft EIR. Based on the entire record before it, the City finds that this
impact is potentially significant but will be mitigated to a less than significant level through the
implementation of Mitigation Measures HHM-I a for short-term impacts and Mitigation Measures
HHM-lb and HHM-le for long-term impacts. (DEIR pp.3.7-11 to 3.7-13.) These mitigation measures,
enumerated below, are adopted and incorporated into the Mitigation Monitoring and Reporting Program
for the Project, and will be implemented as specified therein.
MUHHM-la If septic systems or domestic water wells are identified during excavation of the Project
site, then the septic systems and domestic water wells shall be properly abandoned1closed or destroyed
in accordance with Section 13.42.020, Permits, of the City of Redlands Municipal Code.
MMHHM-lb If any hazardous materials or contamination is found during excavation, all work shall
be halted in the affected area until a qualified hazmat consultant(i.e., Registered Environmental
Assessor, Registered Geologist) makes a determination as to the scope and extent of the contamination.
If contamination is limited, remediation of the site shall be conducted by a licensed contractor in
accordance with State and local guidelines. If the scope of the contamination is considered extensive,
the developer shall contact the State DTSC to determine the appropriate form of remediation, which
may include the developer entering into a Voluntary Work Plan (VWP). The hazmat consultant shall file
afinal report to the City upon completion of remediation activities. This measure shall be implemented
to the satisfaction of the Development Services Director or his designee.
MMl171M1c Any removal of the soils from the entire site identified to contain elevated levels of DDT
and DDE will require profiling and manifesting for disposal as potentially hazardous waste. Jf
contamination is limited, remediation of the site shall be conducted by a licensed contractor in
accordance with State and local guidelines. Any soils removed from the site that have high levels of
DDT or DDE shall be disposed of at a landfill or other facility licensed to accept such materials. If the
scope of the contamination is considered extensive, the developer shall contact the State DTSC to
determine the appropriate form of remediation, which may include the developer entering into a VWP.
The hazmat consultant shall file afinal report to the City upon completion of remediation activities.
This measure shall be implemented to the satisfaction of the Development Services Director or his
designee.
(DEIR pp.3.7-12 to 3.7-13.)
Facts in Support of the Finding:
Short-Tenn Impacts-Grading and construction activities may involve the limited transport, storage,
usage, or disposal of hazardous materials, such as the fueling/servicing of construction equipment.
However, such activity is short-term or one-time in nature and is subject to federal, State, and local
health and safety requirements. Adherence to federal, State, and local health and safety requirements
would reduce the potential impacts associated with construction activities to less than significant.
(DEIR p.3.7-11.)
85
City of Redlands-Redlands Crossing Project
Facts,Findings,and Statement of Overriding Considerations
Related to the Final Environmental Impact Report
In addition, septic systems and domestic water wells were likely associated with the three former on-site
dwellings located along the northern boundary of the Project site. According to a Bear Valley Mutual
Water Company(BVMWQ official, no water wells were associated with the Project site. However, it
is unknown if septic systems are currently located in the vicinity of the former dwellings. Therefore,
short-term impacts during excavation are potentially significant. (DEIR p.3.7-11.)
Long-Term, Impacts-The Project site is not listed on a list of hazardous materials sites compiled
pursuant to Government Code Section 65962.5. Based on the site reconnaissance and a review of
physiographic,historical, and regulatory information, there is no evidence of incidents or accidents
involving hazardous materials on the Project site. However, hazardous materials have been used on the
site in the past,mainly for agricultural uses. Therefore, there is a potential for soil contamination on the
site. (DEIR p.3.7-11.)
In addition, the proposed Project would result in the construction of approximately 275,500 square feet
of commercial retail uses and a gas station on-site. Potentially hazardous materials such as petroleum
products, pesticides, fertilizer, and other household hazardous products such as paint products, solvents,
and cleaning products would be stored and sold in conjunction with on-site commercial retail sales. The
transport, storage,handling, and retail sale of these substances are routinely conducted at such sites. All
activity involving hazardous substances would be conducted in accordance with applicable local, State,
and Federal safety standards. The transport and delivery of fuel to gasoline stations is regulated by the
Federal Department of Transportation while the Hazardous Materials Division of the San Bernardino
County Fire Department provides permitting, inspection, and enforcement activities of gas stations
including leaking and non-leaking underground storage tanks(USTs) and spill incidents. With
adherence to the existing requirements applicable to activities at the commercial retail and gas station,
potential impacts associated with the use, transport, storage, and disposal of hazardous materials would
be less than significant. (DEIR p.3.7-12.)
Impact HHM-2: Would the proposed Project create a significant hazard to the public or the
environment through reasonably foreseeable upset and accident conditions involving the likely release
of hazardous materials into the environment?
Finding: Potential impacts of the Project on related to Hazards and Hazardous Materials are discussed
in detail in Section 3.7 of the Draft EIR. Based on the entire record before it, the City finds that this
impact is potentially significant but will be mitigated to a less than significant level through the
implementation of Mitigation Measures HHM-I a through HHM-I c. (DEIR pp.3.7-13 to 3.7-15.) These
mitigation measures, enumerated below, are adopted and incorporated into the Mitigation Monitoring
and Reporting Program for the Project, and will be implemented as specified therein.
See MM HHNI-I a through HHM-I c as identified under Impact HHM-I above.
(DEIR p.3.7-15.)
Facts in Support of the Finding: Based on the Phase I and Phase 11 ESAs, there is no evidence of
incidents or accidents involving hazardous materials on the Project site. Due to the past presence of
agricultural activities, it is likely on-site soils may be contaminated by low levels of pesticides,
herbicides, waste oil from smudge pots, etc. Some persistent chemicals were used in the past for citrus
orchards and row crops(e.g., DDT, DDE, etc.). Therefore, a Phase 11 ESA was conducted on the
westerly portion of the Project site to identify areas with soils contaminated by hazardous materials, if
any are still present on-site. The Phase 11 ESA concluded that with exception to two soil samples, all
86
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�e t
City of Redlands-Redlands Crossing Project
Facts,Findings,and Statement of Overriding Considerations
Related to the Final Environmental Impact Report
The Burlington Northern Santa Fe Railroad line is located approximately 0.85 mile south of the Project
site. Due to the distance to the Project site(i.e. 0.85 mile) and the up-gradient elevation of 40 feet above
mean sea level to the Project site(i.e. an elevation of 1,245 above mean sea level at the Burlington
Northern Santa Fe Railroad line to an elevation of 1,285 feet above mean sea level at the Project site),
potential impacts related to a release of hazardous materials by the Burlington Northern Santa Fe
Railroad are considered less than significant. (DEIR p.3.7-14.)
7. Hydrology and Water Quality
Impact HWQ-1: Would the proposed Project violate any water quality standards or waste discharge
requirements, or otherwise substantially degrade water quality?
Finding: Potential impacts of the Project on related to Hydrology and Water Quality are discussed in
detail in Section 3.8 of the Draft EIR. Based on the entire record before it, the City finds that this impact
is potentially significant but will be mitigated to a less than significant level through the implementation
of Mitigation Measures HWQ-la for construction impacts and HWQ-lb for operational impacts. (DEIR
pp.3.8-14 to 3.8-17.) These mitigation measures, enumerated below, are adopted and incorporated into
the Mitigation Monitoring and Reporting Program for the Project, and will be implemented as specified
therein.
Construction Mitigation Measure
MMHWQ-la Prior to the issuance of grading permits for any portion or phase of the Project, the
Project applicant shall submit an NOI to the State Water Board and shall also prepare a SWPPP, which
shall be submitted to the Regional Water Board for approval and to the City for review. The SWPPP
shall contain a site map(s), which shows the construction site perimeter, existing and proposed
buildings, lots, roadways, storm water collection and discharge points, general topography both before
and after construction, and drainage patterns across the Project. The SWPPP shall list BMPs the
discharger will use to protect storm water runoff and the placement of those BMPs. Additionally, the
SWPPP shall contain a visual monitoring program; a chemical monitoring program for "non-visible"
pollutants to be implemented if there is afailure of BMPs. Once approved by the City, the applicant's
contractor shall be responsible, throughout the duration of the Project for installing, constructing,
inspecting, and maintaining the control measures included in the SWPPP and Grading Plan.
Operation Mitigation Measure
MM HJVQ-lb Prior to buildingpermit issuance for any portion orphase of the Project, the applicant
shall receive City approval for the Final WQMP. Prior to final building inspection, the applicant shall
be responsible for installing, constructing, inspecting all provisions of the final WQMP, and maintaining
the control measures included in the Final WQMP. Operation and maintenance (0") requirements
for all Source Control, Site Design, and Treatment Control BMPs shall be identified within the WQMP.
The WQMP shall include thefollowing:
O&M Description and Schedule That Must:
List and identify each BMP that requires O&V
Provide a thorough description of O&M activities (include the O&M process, and the handling and
placement of any wastes).
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City of Redlands-Redlands Crossing Project
Facts,Findings,and Statement of Overriding Considerations
Related to the Final Environmental Impact Report
Include BMP start-up dates.
Provide a schedule of the frequency of O&M for each BMP.
Inspection &Monitoring Requirements That Must:
Provide thorough descriptions of water quality monitoring(if locally required).
Provide self-inspections and record keeping requirements for BMPs (review local specific requirements
regarding sel(Iinspections andlor annual reporting), including identification of responsible parties for
inspection and record keeping.
Identification of Responsible Parties That Must:
Provide the party or parties that will be responsible for each BMP O&M. For each responsible party,
include the party's name, address, contact name and telephone number.
(DEIR pp.3.8-16 to 3.8-17.)
Facts in Support of the Finding:
Short-term Construction Impacts -Project implementation would require extensive construction and
grading. Implementation of the Project will result in construction activities that may have the potential
to contribute pollutants to three off-site drainage courses (Area 1, 2 and 3 of the Drainage Report, 2008),
including the confluence of Tennessee Street/Channel at San Bernardino Avenue. Construction may
generate increased amounts of pollutants, mainly silt, debris, chemicals, and dissolved solids, from the
following sources: Grading- Disruption of surface soils and increased susceptibility to erosion; Building
construction-Use of sealants, glues, wood preservatives, oils, concrete, and the generation of debris
related to construction activities; Painting- Paint fragments and stucco flakes; and Construction
equipment and vehicle maintenance-Washing, chemical degreasing. (DEIR p.3.8-14.)
These construction activities may result in short-term degradation of surface water quality due to the
increased pollutant burden. However, the Project must be consistent with the SWRCB NPDES General
Permit for Storm Water Discharges Associated with Construction Activity. The permit requires the
property owner/developer to prepare and implement a Project-specific SWPPP,which includes BMPs
intended to reduce erosion, sedimentation, and non-permitted discharges of materials during
construction. The BMPs to be used during construction typically include gravel bags, silt fencing, and
general housekeeping measures to prevent erosion and stormwater contact with construction materials.
(DEIR p.3.8-14.)
The Project will be required to develop and implement a SWPPP which will demonstrate compliance
with the State NPDES permit, and provide protection of water quality during construction and operation
of the Project and will submit the SWPPP to the RWQCB along with the required Notice of Intent prior
to commencement of grading activities. The imposition of BMPs ensure that federal and State water
quality standards will not be violated and are considered less than significant without mitigation. (DEIR
p.3.8-14.)
Typically, the following would occur during construction of the Project:
.qQ
City of Redlands-Redlands Crossing Project
Facts,Findings,and Statement of Overriding Considerations
Related to the Final Environmental Impact Report
• Erosion control. Employ measures to prevent the movement of soil by wind or water during
construction and may include watering, and physical barriers to the movement of soil particles.
• Tracking of Soil. Employ measures to effectively minimize the tracking of soil by vehicles and
may include gravel driveways, wheel washes and street sweeping.
• Wastes and Cleanup. The SWPPP must also address washout, cleanup, and disposal related to
debris, trash,concrete, asphalt,paint, coatings, solvents, and other materials applicable to
preparation and construction at the Project site.
• Other Reasonable BMPs. The SWPPP must also implement other applicable BMPs as needed to
keep pollutants away from stormwater.
• The SWPPP must also identify additional applicable measures taken during the storm season and
when storms are anticipated. (DEIR pp.3.8-14 to 3.8-15.)
Compliance with the requirements and the provisions of the SWPPP during construction activities
would mitigate any potential construction period impacts on water quality to a less than significant level.
(DEIR p.3.8-1.5.)
Long-Term Operational Impacts -This Project falls under five(5) of the Project Categories/Land Uses
including Industrial/Commercial Development(>I 00,000 ft.), Automotive Repair Shops, Restaurants
(>5,000 ft.) , Parking Lots(>5,000 ft.), and Streets/Highways/Freeways as indicated in Table 2-1 of the
San Bernardino County Stormwater Program Model Water Quality Management Plan Guidance(revised
June, 2005). The potential and expected pollutants of concern for the Redlands Crossings development
were identified in the Project's Water Quality Management Plan(see Appendix G of this DEIR) and are
based on the Project categories and land uses utilizing Table 2-1 the San Bernardino County Stormwater
Program Model Water Quality Management Plan Guidance(revised Jun e, 2005). According to the
Project's Water Quality Management Plan(WQMP), the long-term operations, and development of the
Project would potentially increase the pollutant burden of the stormwater flows. The Project will
increase the amount of impervious surfaces on-site, resulting in an increase in stormwater flows.
Furthermore, the Project's potential commercial and retail activities may result in runoff containing the
following contaminants: oil, grease surfactants, heavy metals, solvents, pesticides or nutrients. (DEIR
p.3.8-15.)
To minimize potential pollutant burden, by virtue of the size of the Project, the applicant has prepared,
and will be consistent with, the Preliminary WQMP through the Municipal Separate Storm Sewer
System (MS4),NPDES. The Project's Preliminary WQMP may include,but is not limited to, guidance,
operation and maintenance for all source control, site design, and treatment control BMPs; that requires
operation and maintenance, which include maximizing canopy interception and water conservation,
landscape planning,roof runoff controls, efficient irrigation, storm drain system signage,trash storage
areas and litter control,employee training/education program, protect slopes and channels, common area
catch basin inspection,energy dissipaters, pervious concrete/alternative materials, and stormwater
filtration systems. The Project will also be required to provide a thorough description of operation and
maintenance activities, and provide a schedule of the frequency of operation and maintenance for each
BMP. (DEIR pp.3.8-15 to 3.8-16.)
Implementation of Mitigation Measures HWQ-I a and HWQ-I b will require the Project to follow the
recommendations of the Preliminary WQMP concerning water supplies, demands,and BMPs for the
90
City of Redlands-Redlands Crossing Project
Facts,Findings,and Statement of Overriding Considerations
Related to the Final Environmental Impact Report
Project relating to water quality. Consistency with Mitigation Measures HWQ-1a and HWQ-lb will
reduce impacts to any violation of water quality standards or waste discharge requirements, or otherwise
substantially degrade water quality(as outlined within the Preliminary WQMP),to a level of less than
significant. (DEIR p.3.8-16.)
Impact HWQ-2: Would the proposed Project substantially deplete groundwater supplies or interfere
substantially with groundwater recharge such that there would be a net deficit in aquifer volume or a
lowering of the local groundwater table level (e.g., the production rate of pre-existing nearby wells
would drop to a level which would not support existing land uses or planned uses for which permits
have been granted?
Finding: Potential impacts of the Project on related to Hydrology and Water Quality are discussed in
detail in Section 3.8 of the Draft EIR. Based on the entire record before it, the City finds that this impact
is potentially significant but will be mitigated to a less than significant level through the implementation
of Mitigation Measures HWQ-2a through HWQ-2c. (DEIR pp.3.8-17 to 3.8-21.) These mitigation
measures, enumerated below, are adopted and incorporated into the Mitigation Monitoring and
Reporting Program for the Project, and will be implemented as specified therein.
MM HWQ-2a Prior to issuance of building permits, the Project applicant shall submit landscaping
plans to the City of Redlands for review and approval that identify and require the use of the following
outdoor irrigation water conservation measures:
Drought resistant vegetation.
Irrigation systems employing the following features:
Drip irrigation;
Low-precipitation-rate sprinklers;
Bubbler/soaker systems;
Programmable irrigation controllers with automatic rain shutoff sensors;
Matched precipitation rate nozzles that maximize the uniformity of the water distribution characteristics
of the irrigation system;
Conservative sprinkler spacings that minimize oversprqv onto paved surfaces; and
L(Ydrozones that keep plants with similar water needs in the same irrigation zone.
Minimally or gently sloped landscaped art-as to minimize runoff and maximize infiltration.
Organic topdressing mulch in non-turf areas to decrease evaporation and increase water retention.
,UMHWQ-2b Prior to issuance of building permits, the Project applicant shall submit buildingplans to
the City of Redlands for review and approval that identify and require the use of the following indoor
water conservation measures:
Low-flow or ultra-low-flow toilets and urinals;
91
City of Redlands-Redlands Crossing Project
Facts,Findings,and Statement of Overriding Considerations
Related to the Final Environmental Impact Report
Faucet aerators or low flow faucets in bathrooms; and
Sensor-actii,ated, low flow faucets.
MM HWQ-2c Prior to issuance of'the certificate of occupancy, the Project applicant shall install the
"purple pipe"system (used to distinguish recycled waterfirom potable-viater) within the landscaped
areas, as approved by the City Engineer,for future use of'recycled irrigation water from the Redlands
Municipal Utilities and Engineering Department.
(DEIR p.3.8-21.)
Facts in Support of the Finding: Potential Project impacts to groundwater include the increased
consumption/use of groundwater supplies and creation of impermeable surface cover restricting
groundwater recharge. The Project consists of a Walmart, totaling approximately 215,000 square feet
and Parcel's 1-9 totaling approximately 60,500 square feet for a grand total of approximately 275,500
square feet of commercial retail uses with an overall total of approximately 436 employees. As per SB
221 and SB 610, a WSA is required for the commercial center or business with more than 500,000
square feet of space or 1,000 employees. Additionally, as defined under State CEQA Guidelines Section
15155, the Project would not contribute an equivalent volume of water as a 500 dwelling unit project.
Thus, the Project does not meet the criteria on virtue of its size and number of employees. (DEIR
pp.3.8-17 to 3.8-18.)
Implementation of the Project will increase the amount of impervious surfaces on-site,which could
conceptually affect groundwater recharge due to the loss of soil infiltration. To facilitate groundwater
recharge, the permeable areas on-site have been maximized through site design considerations, including
vegetated swales, a nutrient separating baffle box and inlet inserts before discharging into one of five
infiltration basins. The design feature allows the majority of drainage from impervious surface to
permeable areas for on-site infiltration. One surface level infiltration basin and four(4)underground
infiltration basins have been incorporated into the site plan(Exhibit 3.8-3, Proposed Drainage Plan) to
maximize on-site infiltration. In addition, various BMPs have been incorporated in the Project design
(AE 2007). Maximizing permeable areas on-site will improve the groundwater recharge in the local
aquifer. Since the Project will not deplete groundwater in the local area and is not expected to lower the
groundwater recharge rate to any measurable degree, impacts will be less than significant. (DEIR p.3.8-
18.)
Currently, the City of Redlands provides water services within the Project area and it is anticipated to
provide water to the Project site. According to water usage rates for Walmart stores with similar square
footage, the Project is anticipated to demand approximately 11,571 gallons of water per day(0.042
gallons per square foot multiplied by 275,500 equals 11,571). Redlands' average daily water
consumption is 27 million gallons per day(mgd)with a maximum daily of 50 mgd in the summer. The
maximum storage capacity for the City is 54.5 million gallons. Therefore,the estimated amount of
water usage by the Project(11,571 gallons of water per day)will be well below the City's average water
consumption rate(50 mgd). (DEIR p.3.8-18.)
Further, the Project will be consistent with the City of Redlands Municipal Code Chapter 15.54, Water
Efficient Landscape Requirements,through installation, maintenance, and management of water
efficient landscaping; and through implementation of water management practices and water waste
prevention for landscaping. Consistency with the City of Redlands Municipal Code Chapter 15.54 will
further reduce impacts to groundwater supplies. (DEIR p.3.8-18.)
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City of Redlands-Redlands Crossing Project
Facts,Findings,and Statement of Overriding Considerations
Related to the Final Environmental Impact Report
Nonetheless, long-term water supply is a significant concern in California, and the Project can reduce its
demand on water supply through the implementation of water conservation measures. Mitigation is
proposed that would require the Project applicant to implement outdoor irrigation and indoor domestic
water conservation measures and practices. These measures would reduce overall Project demand for
potable water and ensure that long-term water supply impacts are less than significant. (DEIR p.3.8-18.)
Impact HWQ-3: Would the proposed Project substantially alter the existing drainage pattern of area,
including through the alteration of the course of a stream or river, in a manner which would result in
substantial erosion or siltation on-or off-site or which would result in flooding on-or off-site?
Finding: Potential impacts of the Project on related to Hydrology and Water Quality are discussed in
detail in Section 3.8 of the Draft EIR. Based on the entire record before it, the City finds that this impact
is potentially significant but will be mitigated to a less than significant level through the implementation
of Mitigation Measures HWQ-la and HWQ-1b. (DEIR pp.3.8-22 to 3.8-23.) These mitigation
measures, enumerated below, are adopted and incorporated into the Mitigation Monitoring and
Reporting Program for the Project, and will be implemented as specified therein.
See MM HWQ-la and HWQ-lb under Impact HWQ-1 ahove.
(DEIR p.3.8-23.)
Facts in Support of the Finding: The development of the Project will result in an increase in surface
runoff,due to increasing the amount of impervious surfaces and decreasing the amount of permeable
surfaces. This lowers the infiltration rate through the Project site, resulting in the necessity for an on-
site drainage system(See Exhibit 3.8-3 Proposed Drainage Plan in the Draft EIR). (DEIR p.3.8-22.)
Currently, the site drains northerly and westerly towards the Santa Ana River. The proposed drainage
system will alter the current drainage pattern. In post-development conditions the 45.71 acre of the
property area will be re-parceled and some of the area will be dedicated to the Tennessee Street to the
West, some area to the San Bernardino Avenue to the North, a small portion to the existing Karon Street
to the east,but the major changes will be the construction and dedication of a new portion of
Pennsylvania Avenue to the south and a new portion of New York Avenue,now crossing the Project site
and dividing it with I I parcels to the west and limited off-site improvements to the east. However, the
drainage report prepared by Adams Engineering indicated that the total area draining to the comer of
San Bernardino Avenue and Tennessee Street will remain the same and the proposed drainage system
(pond, sediment pond and underground systems)would control the peak flow and reduce the total
volume of runoff to levels similar to the pre-development runoff levels (AE 2008). (DEIR p.3.8-22.)
Additionally, the drainage report concluded that the proposed drainage system will improve the drainage
conditions of Tennessee Street, Tennessee Channel and San Bernardino Avenue. The drainage system
will not only reduce the peak flows, but will also provide more inlets along San Bernardino Ave and
Tennessee Street. This will relieve existing flooding conditions experienced by Tennessee and San
Bernardino Avenue during significant storm events. Thus, the proposed drainage system will improve
the overall flooding situation in the drainage conditions of the existing channels(AE 2008). Therefore,
as discussed above,the Project will not substantially alter the existing drainage pattern of the area or
result in flooding on-or off-site. (DEIR p.3.8-22.)
Implementation of Mitigation Measures HWQ-I a and HWQ-I b (see Impact HWQ-I for mitigation
measures) will require erosion and siltation reduction measures to be implemented during construction
93
City of Redlands-Redlands Crossing Project
Facts,Findings,and Statement of Overriding Considerations
Related to the Final Environmental Impact Report
of the Project by developing and implementing a SWPPP, which will demonstrate compliance with the
State NPDES permit and will submit the SWPPP to the RWQCB along with the required Notice of
Intent (NOI) prior to commencement of grading activities, which is consistent with federal and State
standards. Consistency with Mitigation Measures MM HWQ-la and MM HWQ-lb will reduce impacts
to substantial erosion or siltation on- or off-site to a level of less than significant. (DEIR p.3.8-22.)
8. Noise
Impact N4: Would the proposed Project create a substantial temporary or periodic increase in ambient
noise levels in the Project vicinity above levels existing without the Project?
Finding: Potential impacts of the Project on related to Noise are discussed in detail in Section 3.11 of
the Draft EIR. Based on the entire record before it,the City finds that this impact is potentially
significant but will be mitigated to a less than significant level through the implementation of Mitigation
Measures N-1. (DEIR pp. 3.11-51 to 3.11-53.) These mitigation measures, enumerated below, are
adopted and incorporated into the Mitigation Monitoring and Reporting Program for the Project, and
will be implemented as specified therein.
MM N-1 The Project applicant shall require construction contractors to adhere to the following
noise attenuation requirements:
Construction activities shall be limited to the hours of'7:00 a.m. to 6:00p.m., except Sundays and
holidays. No construction shall be allowed on Sundays or holidays.
All construction equipment shall use noise-reduction features (e.g., mufflers and engine shrouds) that
are no less effective than those originally installed by the manufacturer.
Construction staging and heavy equipment maintenance activities shall be performed a minimum
distance of 300feet from the nearby noise sensitive uses.
The existing berm along the eastern edge of the Project site shall be preserved and a minimum 10-foot
high temporary noise barrier with a minimum STC 12 rating shall be placed along the length of the
eastern property line that is adjacent to Karon Street. The temporary noise barrier shall be placed on
the top of the existing berm. The temporary noise barrier shall be installed prior to the commencement
ofgrading activities and shall not be removed until completion qf'building construction. A noise barrier
with a minimum STC 12 rating could be obtained through the use of lry inch or greater plywoodl
oriented strand board(OSB), or from acoustically rated vinyl curtains.
(DEIR p. 3.11-53.)
Facts in Support of the Finding: Short-term noise impacts could occur during construction activities
from either the noise impacts created from the transport of workers and movement of construction
materials to and from the Project site,or from the noise-generated on-site during ground
clearing/excavation, grading,and building construction activities. The nearest sensitive receptors to the
Project site are residential homes located approximately 75 feet east of the proposed area to be graded.
Construction noise impacts onto the nearby receptors have been calculated based on the loudest
construction equipment noise sources. Table 3.11-23 in the Draft EIR provides the estimated maximum
noise levels that sensitive receptors would be expected to experience during construction. The
construction noise often vanes significantly on a day-to-day basis, and the noise levels shown in the
table represent a worst-case scenario. (DEIR p. 3.11-51.)
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Table 3.11-23 of the Draft EIR shows that the Project construction activities would increase the existing
noise level by as much as 12.7 dBA over baseline conditions and result in noise levels of up to 65.9 dBA
at the nearby receptors. Although the City Noise Ordinance allows for construction noise for specified
hours and the Project would comply with these requirements, these increases in temporary noise level
are considered substantial since they would exceed the City's 60-dBA CNEL standard for residential
uses. However, mitigation measure MM N-I that would require the Project applicant to install a
temporary 10-foot high noise barrier along the length of the eastern property line that is adjacent to
Karon Street and implement noise-reduction measures and practices during construction. Additional
measures to further reduce noise impacts to nearby sensitive receptors, include limiting construction
activities to daytime hours,using noise attenuation devices on heavy equipment, preserving the existing
berm along the eastern edge of the Project site, and locating staging and maintenance areas at least 300
feet from residences. (DEIR p. 3.11-52.)
The construction noise levels have been recalculated based on construction of the temporary I0-foot
high wall on the east side of the Project site and the results are shown in Table 3.11-24 of the Draft EIR.
(DEIR p. 3.11-52.)
As indicated in Table 3.11-24 in the Draft EIR, with implementation of Mitigation Measure MM N-1,
the Project will provide noise-suppression techniques to minimize the impact of temporary construction
noise and avoid possible violations of local rules, standards, and ordinances. In addition,the Project will
require the installation of noise reduction features (e.g., mufflers and engine shrouds)on construction
equipment that are no less effective than those originally installed by the manufacturer. implementation
of mitigation measure MM N-1, construction noise levels at the nearby sensitive receptors would be
reduced to meet the City's 60-dBA CNEL standard, or, in the case of Receiver 8 where the standard is
already exceeded under the existing condition, would not result in an increase in noise above existing
levels. Therefore, with implementation of Mitigation Measure MM N-1 impacts impacts would be less
than significant. (DEIR p. 3.11-53.)
9. Public Services
Impact PS-2: Would the proposed Project result in substantial adverse physical impacts associated with
the provision of new or physically altered governmental facilities,need for new or physically altered
governmental facilities,the construction of which could cause significant environmental impacts, in
order to maintain acceptable service ratios,response times or other performance objectives for Police
Protection?
Finding: Potential impacts of the Project on related to Public Services are discussed in detail in Section
3.13 of the Draft EIR. Based on the entire record before it, the City finds that this impact is potentially
significant but will be mitigated to a less than significant level through the implementation of Mitigation
Measures PS-2. (DEIR pp. 3.13-8 to 3.13-9.) These mitigation measures, enumerated below, are
adopted and incorporated into the Mitigation Monitoring and Reporting Program for the Project, and
will be implemented as specified therein.
MM PS`2: Prior to issuance of the certificate qf'occupancyfor each building, the Project applicant shall
install the following applicable security measures and implement the following operational practices:
Install strategically placed emergency phones.
Provide sufficient,professionally trained loss prevention staff on-site.
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Submit loss prevention plan with staffing levels on-site to the Redlands Police Department for review
and approval.
Install security devices and alarms in the Walmart pharmacy.
Ensure that the site layout for the parking lot areas are properly designed to provide maximum safety
and security through adequate lighting, and ingress and egress.
Installation of high-quality resolution video surveillance cameras throughout the interior and parking
lot areas.
Provide 24-hour staffed roving security patrols throughout the parking lot areas and rear of building. If
applicant intends to use an outside private security company, thefirm must be from the approved list
provided by the Police Department or the firm must be approved by the Police Department.
Provide Redlands Police Department with access to live and historical surveillance video for
investigations, responses to issues, andprosecution of suspects. Surveillance cameras should be of
sufficient quality to ensure identification qf'suspects.
Prohibit the private sales of vehicles in the parking lot areas.
(DEIR p. 3.13-9.)
Facts in Support of the Finding: The proposed 24-hour operation of the Walmart store and outparcels
have the potential to increase demands of policing in the early morning hours and during the holiday
season. In addition,the Project's location to the States Route 210(SR-210) Freeway increases the
potential for criminal activity to occur on-site. An increase in calls for service has the potential to
impact the agency's response time. Consequently, several recommendations for security measures and
operational practices will be implemented to deter criminal activity and ultimately reduce demands on
the agency. The recommendations include providing emergency phones, on-site security personnel,
exterior lighting, surveillance equipment, and prohibiting overnight recreational vehicle parking and
private vehicle sales in the parking areas. The recommendations are reflected in.Mitigation Measure PS-
2. (DEIR p. 3.13-8.)
In order to offset the incremental costs associated with police protection in the City of Redlands, the
proposed Project would be required to pay a law enforcement fee equating to $0.31 per square foot that
would be utilized to fund various capital improvements and personnel additions. The applicant shall pay
the applicable law enforcement fee at the time of building permit issuances. Furthermore, impacts on
police protection would be minimized through the provision of on-site security personnel 24 hours a day
at the Walmart store that would monitor and patrol the store and parking areas. Security personnel
would serve as a first line of defense against criminal activities and nuisances, and would be able to
resolve minor incidents that ordinarily would not warrant a police response(e.g., a lost child or a verbal
dispute between customers). In addition, exterior lighting would be provided along buildings and in the
parking area,which would serve to deter criminal activity during the nighttime hours. Refer to Section
2, Project Description,for further discussion of the proposed security measures. With the
implementation of mitigation,impacts would be reduced to a level of less than significant. (DEIR p.
3.13-8.)
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10. Transportation
Impact T-5: Would the proposed Project conflict with adopted policies, plans or programs supporting
alternative transportation(e.g. bus turnouts,bicycle racks)?
Finding: Potential impacts of the Project on related to Transportation are discussed in detail in Section
3.15 of the Draft EIR. Based on the entire record before it,the City finds that this impact is potentially
significant but will be mitigated to a less than significant level through the implementation of Mitigation
Measure TRANS-6a. (DEIR pp.3.15-131 to 3.15-132.) These mitigation measures, enumerated below,
are adopted and incorporated into the Mitigation Monitoring and Reporting Program for the Project, and
will be implemented as specified therein.
MM TRANS-6a: Prior to Project occupancy, the Project applicant shall install an enhanced Omnitrans
bus stop to serve the Project site. The bus stop shall conform to Omnitrans requirements and include, at
a minimum: a shelter, signage, transit information, lighting, and a trash receptacle. Alternately, the
Project applicant can satisfy this requirement by providing payments to Omnitrans for the cost of this
improvement if Omnitrans commits to having it in place prior to Project occupancy. The design of the
bus shelter shall be compatible with the architecture of the Project.
(DEIR p. 3.15-132.)
Facts in Support of the Finding: The Project area is currently served by Omnitrans, a public transit
agency serving the San Bernardino Valley, with bus service along Orange Street, San Bernardino
Avenue, Alabama Street, Lugonia Avenue, Mountain View, and Redlands Boulevard through various
routes (Routes 8, 15 and 19).Due to the size of the Project and the employment of approximately 436
new jobs, it would be expected that transit usage would increase. Accordingly,it would be expected that
Omnitrans would serve the Project. At the time of this writing, the Project site plan does not identify a
bus stop. As such,mitigation is proposed that would require the Project applicant to install an enhanced
bus stop that would include amenities such as a shelter, signage, transit information,lighting, a trash
receptacle, and direct pedestrian connection to the store entrance. The implementation of this mitigation
measure would ensure that adequate access to public transit is provided. Therefore, impacts would be
less than significant. (DEIR p. 3.15-132.)
In addition, the City of Redlands East Valley Corridor Specific Plan identifies a trail system for the
Project area. There is a proposed trail located along the east side of Mountain View Avenue trending
southeast through the study area, and a proposed Class I bikeway trail located along the east side of
California Street trending north-south. Given the proximity of bicycle facilities and nearby residential
neighborhoods, it would be expected that some customers and employees would use bicycles to travel to
the Project. To facilitate bicycle access, the Project will provide bicycle receptors throughout the
Project site to facilitate both customer and employee bicycle storage. The provision of these bicycle
storage facilities would ensure that adequate storage is available. Therefore, impacts would be less than
significant. (DEIR p. 3.15-132.)
11. Utilities and Service Systems
Impact U4: Would the proposed Project have sufficient water supplies available to serve the project
from existing entitlements and resources, or are new or expanded entitlements needed?
Finding: Potential impacts of the Project on related to Utilities and Service Systems are discussed in
detail in Section 3.16 of the Draft EIR. Based on the entire record before it, the City finds that this
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impact is potentially significant but will be mitigated to a less than significant level through the
implementation of Mitigation Measure HWQ-2a through HWQ-2c. (DEIR pp. 3.16-13 to 3.16-14.)
These mitigation measures, enumerated below, are adopted and incorporated into the Mitigation
Monitoring and Reporting Program for the Project, and will be implemented as specified therein.
See Mitigation Measures HWQ-2a through HWQ-2c as discussed under Impact HWQ-2.
(DEIR p. 3.16-14.)
Facts in Support of the Finding: California Water Code Section 10910 through 10915 requires that a
Water Supply Assessment be prepared for any project containing a shopping center or business
establishment employing more than 1,000 persons or having more than 500,000 square feet of floor
space. The Project proposes to develop 215,000 square feet for the proposed Walmart, 60,500 square
feet for outparcels 1-9,totaling 275,500 square feet. In addition, implementation of the Project will
generate approximately 436 new jobs. Therefore, the Project is below the 500,000 square feet of floor
use, 1,000-employee and so a Water Supply Assessment is not required. (DEIR p. 3.16-13.)
Water consumption would be consumed from short-term construction activities and long-term
operational activities. Short-term construction water consumption from development of the proposed
Project would be spread out over the length of construction activities and would not occur all at once.
The actual volume of water consumption of at any one time is not expected to pose a significant impact
to water supply. (DEIR pp. 3.16-13 to 3.16-14.)
The Project will tie in to the nearest water line, which is located immediately adjacent to the site. The
Project's water consumption estimate is provided in Table 3.16-4 (see Impact Analysis U-2). As shown
in the Table 3.16-4,the Project is anticipated to demand 14,817 gallons of water on a daily basis. As
previously described,the 2010 San Bernardino Valley Regional Urban Water Management Plan
concluded that sufficient water supply is available between 2010 and 2030 to serve all customers within
the City of Redlands; refer to Table 3.16-2 (See Section 3.16.2, Existing Conditions,for Table 3.16-2).
The Project is consistent with the Land Use and Zoning designations for the Project site and will
therefore be served with adequate long-term water supply. In addition, as previously outlined within
Table 3.16-2, the current and planned water supplies for the City of Redlands includes 31,479-acre feet
per year for the year 2010 and 43,120-acre feet per year for the year 2030. Consequently,
implementation of the Project will consume approximately 0.00000014 to 0.00000011 percent of the
available water supply for the year 2010 and 2030, respectively. (DEIR p. 3.16-14.)
In addition, the Project would reduce its demand on water supply through the implementation of various
indoor and outdoor water conservation measures detailed in the Project's sustainability features
discussed in detail in Section 2, Project Description. Specifically,water conservation measures
recommended by the California Department of Water Resources, as well as the City's landscape
ordinance, will be incorporated into the Project as appropriate, including but not limited to: a) low flush
toilets of no greater than 1.6 gallons per flush and b)keeping water pressure at 55 pounds per inch or
less. Some portion of the landscaping, especially shrubs and trees, may be native species or species that
are adapted to drought conditions. However, the commercial nature of the project means that a good
portion of each lot will likely be asphalt, concrete, and minimal turf, which will have a"low"water
consumption. (DEIR p. 3.16-14.)
Additionally, mitigation measure MM HWQ-2a through HWQ-2c requires the applicant to install
outdoor irrigation and indoor domestic water conservation measures and practices and plumb landscaped
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areas with"purple pipe"prior to issuance of the certificate of occupancy for the Walmart store to allow
for recycled water irrigation. These measures would reduce overall Project demand for potable water
and ensure that long-term water supply impacts are less than significant. (DEIR p. 3.16-14.)
12. Greenhouse Gasses
Impact GHG-1: Would the proposed Project generate direct and indirect greenhouse gas emissions;
however, these emissions would not result in a significant impact on the environment?
Finding: Potential impacts of the Project on related to Greenhouse Gasses are discussed in detail in
Section 3.17 of the Draft EIR. Based on the entire record before it, the City finds that this impact is
potentially significant but will be mitigated to a less than significant level through the implementation of
Mitigation Measure AQ-5;AQ-7 through AQ-11; HWQ-2a and HWQ-2b; and TRANS-6a. (-DEIR pp.
3.17-14 to 3.17-32.) These mitigation measures, enumerated below, are adopted and incorporated into
the Mitigation Monitoring and Reporting Program for the Project, and will be implemented as specified
therein.
See Mitigation Measures Measure AQ-5; AQ-7 through AQ-11; HYD-2a and HYD-2b; and T-6a as
discussed under Impact AQ-3, HWQ-2, and T-6
(DEIR p.3.17-32.)
Facts in Support of the.Finding: To determine whether the Project is significant, this Project utilizes
the SCAQMD draft local agency tiered threshold. The threshold is as follows:
• Tier 1: The Project is not exempt under CEQA; go to Tier 2.
• Tier 2: There is no greenhouse gas reduction plan applicable to the Project; go to Tier 3.
• Tier 3: Project greenhouse gas emissions compared with the threshold: 3,000 MTCO2e per year
(see analysis below).
• Tier 4, option 1: Reduce greenhouse gas emissions from business as usual by 28.4 percent. The
California 2020 emissions target is 427 MMTCO2e and the 2020 business as usual is 596
MMTCO2e(California Air Resources Board 201 lb). Therefore, a 28.4 percent reduction is
required to reduce emissions to the target.
• Tier 4, option 3: 4.8 MTCO2e per service population per year(see analysis below). The service
population refers to the quantity of workers anticipated on the Project site.
(DEIR p.3.17-17.)
Section 15064.4(b)of the CEQA Guideline amendments for greenhouse gas emissions state that a lead
agency may take into account the following three considerations in assessing the significance of impacts
from greenhouse gas emissions. Consideration#1: The extent to which the Project may increase or
reduce greenhouse gas emissions as compared to the existing environmental setting. Consideration#2:
Whether the Project emissions exceed a threshold of significance that the lead agency determines applies
to the Project. Consideration#3: The extent to which the Project complies with regulations or
requirements adopted to implement a statewide, regional, or local plan for the reduction or mitigation of
greenhouse gas emissions. Such regulations or requirements must be adopted by the relevant public
agency through a public review process and must include specific requirements that reduce or mitigate
the Project's incremental contribution of greenhouse gas emissions. If there is substantial evidence that
the possible effects of a particular project are still cumulatively considerable notwithstanding
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compliance with the adopted regulations or requirements, an EIR must be prepared for the Project.
(DEIR pp.3.17-17 to 3.17-18.)
The operational emissions for the Project are shown in Table 3.17-10 of the Draft EIR,with minor
clarifications on page 4-4 to 4-5 of the Final EIR. The main source of emissions is motor vehicles,
contributing almost 75 percent of the business as usual emissions. (DEIR p.3.17-25;FEIR pp. 4-4 to 4-
5.)
A variety of regulations would reduce Project emissions. A summary of the future regulations that
would reduce Project emissions are shown in Table 3.17-11 of the Draft EIR, and are discussed in more
detail below. (DEIR p.3.17-27.)
The following tables outline the various Project design features and mitigation measures in other impact
areas that would reduce greenhouse gas emissions. The Project will meet the energy efficiency
standards of Title 24. To achieve this reduction in energy consumption, the Walmart store will
incorporate, at a minimum, the following sustainability features or other features that are equally
efficient. Table 3.17-12 in the Draft EIR displays the design features that Walmart would implement to
conserve energy, conserve water, and reduce waste. (DEIR pp. 3.17-27 to 3.17-31.) Strategy
consistency refers to consistence with strategies in the ARB Scoping Plan and the papers published by
the California Air Pollution Control Officers Association. Table 3.17-11 in the Draft EIR shows
mitigation measures in other impact areas that would reduce greenhouse gas emissions. As shown in the
tables,the Project is consistent with a variety of Scoping Plan measures. (DEIR p.3.17-27.)
Several measures that have been identified as greenhouse gas emissions reduction strategies by various
agencies are not applicable or are infeasible to implement with regard to the Project. For example, the
ARB Scoping Plan identifies a number of strategies that apply to statewide activities, such as tailpipe
emissions standards for vehicles. (DEIR p.3.17-31.)
Emissions with Reductions
The operational emissions, after incorporation of Project design features, mitigation measures in other
impact areas, and future regulations are shown in Table 3.17-14 of the Draft EIR,with additional
clarifications on page 4-5 of the Final EIR. Project reductions and future regulations reduce emissions
from business as usual by approximately 30 percent, meeting the threshold set by Tier 4, Option 1.
After application of reductions from the Project and regulations, the main source of emissions is from
motor vehicles, contributing approximately 75 percent of the emissions. (DEIR p.3.17-31; FEIR pp. 4-5
to 4-6.)
The Project will promote the goals of AB 32. The Walmart store would retail general merchandise and
groceries 24 hours a day, 7 days a week and the other components of the Project would operate 12 hours
per day, providing convenient access to nearby residents and employees. The Project site is near public
transit and accessible to bicycles and pedestrians. Collectively, these characteristics indicate that the
Project is planned growth within the urban footprint of Redlands and is well positioned to reduce travel
lengths. The Project incorporates a number of features and mitigation measures in other impact areas
that would minimize greenhouse gas emissions. These features are consistent with Project-level
strategies identified in the ARB's Scoping Plan and the California Air Pollution Control Officers
Association white papers. Therefore, although the Project would generate greenhouse gas emissions,
these emissions would not have a significant impact on the environment. The Project would not conflict
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City of Redlands-Redlands Crossing Project
Facts,Findings,and Statement of Overriding Considerations
Related to the Final Environmental Impact Report
The South Coast Air Quality Management District 1993 Handbook suggests three voluntary approaches
to determine cumulative significance. The first approach is a 1-percent-per-year reduction(or 18
percent over 18 years to the year 2010) in Project emissions of VOC,NO,,, CO,PM1o, and SO,. This
approach is not straightforward and operational reductions are not easy to quantify. The second
approach is not applicable because it relies on SCAQMD Regulation XV, which was repealed in 1995
and therefore is not applicable. The third approach is to reduce the rate of growth in vehicle miles
traveled and trips. In this approach, the rate of growth in vehicle miles traveled and trips"should be
held to the rate of population or household growth." Data that was used by Southern California
Association of Governments in the AQMP should be used in this approach; however,that data is not
available. Therefore, the approaches in the 1993 SCAQMD Handbook pertaining to cumulative impacts
are not used. (DEIR p. 3.3-41.)
Criterion 1: Regional Impact Analysis
If an area is in nonattainment for a criteria pollutant, then the background concentration of that pollutant
has historically been over the ambient air quality standard. It follows that if a project exceeds the
regional threshold for that nonattainment pollutant, then it would result in a cumulatively considerable
net increase of that pollutant and result in a significant cumulative impact. (DEIR p. 3.3-41.)
The Basin is in nonattainment for nitrogen dioxide, PM10, PM2.5, and ozone. Therefore,if the project
exceeds the regional thresholds for PM10, or PM2.5, then it contributes to a cumulatively considerable
impact for those pollutants. Additionally, if the Project exceeds the regional threshold for NOx or VOC,
which are precursors to the formation of ozone and PM 10 and PM2.5,then it follows that the Project
would contribute to a cumulatively considerable impact for ozone, PM10 and PM2.5. If the Project
exceeds the threshold for NOx, it would contribute to nitrogen dioxide concentrations. Project impacts
on a regional scale may occur many miles away from the Project site. Project emissions when added to
the overall emission burden of the Basin could result in a cumulatively significant impact. (DEIR p. 3.3-
41.)
Other parameters(besides those presented in Impact AQ-2)which are used to estimate emissions such
as the worker and vendor trips and trip lengths utilize the CalEEMod defaults, with the addition of 5
daily haul trips during grading, which is to haul the construction equipment to the site or any
import/export of material. (DEIR p. 3.3-41.)
Construction emissions are calculated during each period according to the type and level of construction
activity occurring during the period. Activities can be discreet or overlapping. Emissions occur from
construction equipment, fugitive dust, asphalt paving, architectural coating, and worker and delivery
vehicles. Table 3.3-24 in the Draft EIR summarizes the Project's short-term regional construction
emissions without application of mitigation measures for each construction activity(however, the
particulate matter emissions do include compliance with the mitigation measures outlined in SCAQMD
Rule 403). As shown in the Draft EIR, without mitigation, the Project's construction emissions would
exceed the AQMD regional emission thresholds for VOC and NO,during construction. Therefore, the
short-term construction emissions would have a potentially significant regional impact. (DEIR p. 3.3-
42.)
Mobile source emissions from motor vehicles are the largest single long-term source of air pollutants
from the operation of the Project and consist of emissions from delivery trucks and customer and worker
vehicles. Small amounts of emissions are also generated from area sources such as landscaping
equipment, use of consumer products, natural gas consumption, and architectural coating/painting and
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from the operation of the service station. The emissions were generated using CaIEEMod; assumptions
are discussed in Impact AQ-2. Operational emissions (unmitigated) from mobile and area operational
emission sources as derived from CalEEMod and from the service station shown in Table 3.3-25, Table
3.3-26, and Table 3.3-27 for the summer season for years 2010, 2013, and 2030, and Table 3.3-28 for
the winter season within the Draft EIR. (DEIR p. 3.3-43; FEIR p. 4-1.)
As shown in the Draft EIR, operation of the Project would exceed the SCAQMD's regional operational
significance thresholds for VOC, NO,,, CO, and PM10. VOC and NO,are precursors in the formation of
ozone and both contribute to the formation of PM 10 and PM2,5,pollutants for which the Basin has been
identified as a non-attainment area(i.e., an area exceeding national or State standards). Thus, even
though the Project's incremental emissions by themselves would not likely exceed the ozone, PM10 and
PM2.5 standards, their contribution to the overall SCAQMD regional emission burden would add to a
cumulatively considerable impact. Therefore, the Project does not meet Criterion 1. (DEIR p. 3.3-45.)
Note that as discussed in Impact AQ-2, during operation the Project would not exceed the ambient air
quality standards for the pollutants assessed. This is based on localized emissions and concentrations.
The analysis under this impact assesses the emissions based on the regional thresholds identified by the
SCAQMD. Based on the regional thresholds,the cumulative impact is significant. (DEIR p. 3.3-45.)
Criterion 2: Consistency with Existing Air Quality Plans
The geographic scope for cumulative criteria pollution from air quality impacts is the Basin, because
that is the area in which the air pollutants generated by the sources within the basin circulate and are
often trapped. The SCAQMD is required to prepare and maintain an AQMP and a State Implementation
Plan to document the strategies and measures to be undertaken to reach attainment of ambient air quality
standards. While the SCAQMD does not have direct authority over land use decisions, it recognized
that changes in land use and circulation planning are necessary to maintain clean air. The SCAQMD
evaluated the entire basin when it developed the AQMP. (DEIR p. 3.3-45.)
According to the above analysis, the Project is not consistent with the most recent AQMP without
mitigation. Therefore, the Project does not meet Criterion 2. (DEIR p. 3.3-46.)
Criterion 3: Cumulative Health Impacts
The basin is in nonattainment for ozone, nitrogen dioxide, PM10, and PM2.5, which means that the
background levels of those pollutants are at times higher than the ambient air quality standards. The air
quality standards were set to protect public health, including the health of sensitive individuals (i.e.,
elderly, children, and the sick). Therefore, when the concentration of those pollutants exceeds the
standard, it is likely that some sensitive individuals in the population will experience health effects as
described above in the sub-section, Air Pollutants. However, the health effects are a factor of the dose-
response curve. Concentration of the pollutant in the air(dose), the length of time exposed, and the
response of the individual are factors involved in the severity and nature of health impacts. If a
significant health impact results from Project emissions, it does not mean that 100 percent of the
population would experience health effects. There are no models or methodology to calculate with
certainty what health risks would be experienced from potential cumulative impacts. (DEIR p. 3.3-46.)
The regional analysis of construction emissions indicates that without mitigation, the Project would
exceed the SCAQMD regional significance thresholds for VOC and NOx (ozone precursors). In
addition, long-term operational emissions of VOC and NO, are over the District's significance
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thresholds. Because ozone is a secondary pollutant(it is not emitted directly but formed by chemical
reactions in the air),it can be formed miles downwind of the Project site. Project emissions of VOC and
NO,may contribute to the background concentration of ozone and cumulatively cause health effects.
Project emissions of NOx may contribute to the background concentration of nitrogen dioxide and cause
health effects. (DEIR p. 3.3-46.)
Health impacts from ozone exposure may or may not include the following:
(a) Pulmonary function decrements and localized lung edema in humans and animals
(b) Risk to public health implied by alterations in pulmonary morphology and host defense in
animals
(c) Increased mortality risk
(d) Risk to public health implied by altered connective tissue metabolism and altered pulmonary
morphology in animals after long-term exposures and pulmonary function decrements in
chronically exposed humans.
(DEIR p. 3.3-46.)
Short-term exposure to ozone can result in breathing pattern changes, reduction of breathing capacity,
increased susceptibility to infections, inflammation of the lung tissue, and some immunological changes.
Children who live in high ozone communities and who participate in multiple sports have been observed
to have a higher asthma risk. This is a significant cumulative health impact associated with ground-level
ozone concentrations. (DEIR p. 3.3-46.)
Health effects from nitrogen dioxide may include the following:
(a) Potential to aggravate chronic respiratory disease and respiratory symptoms in sensitive groups
(b) Risk to public health implied by pulmonary and extra-pulmonary biochemical and cellular
changes and pulmonary structural changes
(c) Contribution to atmospheric discoloration
(DEIR p. 3.3-47.)
Additionally, during operation, the Project could result in a significance cumulative contribution to
PM10. Sensitive individuals may experience health impacts when concentrations of those pollutants
exceed the ambient air quality standards. Health impacts from particulate matter may include the
following: (a)exacerbation of symptoms in sensitive patients with respiratory or cardiovascular disease;
(b)declines in pulmonary function growth in children; (c) and/or increased risk of premature death from
heart or lung diseases in the elderly. Therefore, the Project does not meet Criterion 3. (DEIR p. 3.3-47.)
Criteria pollutants are treated differently from toxic air contaminants because criteria pollutants have
state and federal standards and are set in a different regulatory environment than toxic air contaminants.
Diesel particulate matter is a major part of PM2.5 and PM 10 and thus is included in the criteria pollutant
impact analysis for PM2.5 and PM 10. Benzene is a hydrocarbon whose emissions are also estimated as
part of the Project's operational VOC emissions(see regional operational emissions). Further, risk (as
in estimating health risks)is estimated on a probability basis(e.g., cancer risk of 10 in one million)
while criteria pollutant impacts are expressed as a not to be exceeded basis. Therefore,criteria pollutant
impacts are not expressed as a risk. (DEIR p. 3.3-47.)
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Construction: Less than significant. Mitigation measures AQ-1, AQ-2, and AQ-3 would reduce the
significance of construction emissions, as shown in the Draft EIR. The emissions reductions from AQ-1
are estimated by CalEEMod. The emission reductions from AQ-2 (not allowing overlap) are manually
estimated by changing the overlapping additions. To attribute the emission reductions from AQ-3: the
unmitigated emissions were estimated assuming 250 grams of VOC per Liter; assuming 125 grams per
Liter would reduce emissions by half. (DEIR p. 3.3-49.)
Operation: Significant and unavoidable. The Project would result in a cumulatively significant
impact even after mitigation because of the exceedances of the SCAQMD's regional emission
thresholds for VOC,NOx, CO, and PM10. The Project may result in cumulative health effects from
cumulative exposures from ozone, nitrogen dioxide, and PM10. While the Project and associated air
quality reports and evaluations completed a thorough review of all feasible mitigation measures that
would reduce the operational impacts to the greatest extent possible, the impacts would remain
significant and unavoidable.No additional mitigation measures were considered to be feasible or
determined to further reduce the operational emissions. The EIR also considered three Alternatives
developed to reduce the air quality impacts of the Project(Ten Percent Reduction Alternative, Walmart
Standalone Alternative, and No Walmart/Medium Size Tenant Alternative). However,while each of
these Alternatives would reduce the Project's air quality impacts, none would reduce those impacts to a
less than significant level. (See DEIR 6-14,, 6-24, 6-31- 6-32.)The emission reductions resulting from
the implementation of mitigation measures AQ-5, AQ-7, AQ-8, AQ-9, AQ-10,AQ-11, and T-6a would
result in approximately a I percent reduction in motor vehicle emissions(see Table 3.17-6 in the
Greenhouse Gas Draft EIR section for documentation). This reduction would not reduce operational
emissions to less than significant. (DEIR p. 3.3-49.)
2. Transportation
Impact T-1: The EIR evaluated and concluded that the Project would cause an increase in traffic, which
is substantial in relation to the existing traffic load and capacity of the street system(i.e.,result in a
substantial increase in either the number of vehicle trips, the volume to capacity ratio on roads, or
congestion at intersections)and/or exceed, either individually or cumulatively, a level of service
standard established by the county congestion management agency for designated roads or highways.
Finding: Project related Transportation impacts are discussed in detail in Section 3.15 of the Draft EIR.
Based on the entire record before it, the City finds that this impact is potentially significant but will be
reduced to the extent feasible through mitigation measures. (DEIR pp. 3.15-36 to 3.15-113.) Mitigation
Measures TRANS-la through TRANS-Ie will reduce direct project impacts; Mitigation Measures
TRANS-2a through TRANS-2t will reduce cumulative impacts; and Mitigation Measures TRANS-3a
through TRANS-3i,TRANS-4a through TRANS-4e, and TRANS 5a through TRANS 5b will reduce
impacts related to site access and onsite roadway improvements. These mitigations, as set forth below,
are incorporated into the Mitigation Monitoring and Reporting Program for the Project, and will be
implemented as specified therein. Notwithstanding, while the direct Project impacts will be reduced to
less than significant with mitigation, the Project's cumulative impacts and impacts to freeway ramps and
mainline improvements will remain significant and unavoidable.
Direct Project Impacts
The following mitigation measures reduce the Project's direct impacts to below a level qfsignificance.
These measures shall be implemented and improvements constructed prior to the issuance of occupancy
permits,
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MM TRANS-la: Alabama StreetII-1 0 Westbound Ramps (#9) - The addition of Project traffic
would result in unacceptable levels of service during the Saturday peak hour as compared to existing
(2010) conditions. Southbound Approach: Stripelbr a southbound right turn lane.
MM TRANS-1b: SR-210 Eastbound Ramps/San Bernardino Avenue (#12) - The addition oj'Project
traffic would result in unacceptable levels of'service during the PM and Saturday peak hours as
compared to existing(2010) conditions. Southbound Approach: Re-stripe the number I through lane to
provide a 2nd left turn lane. Eastbound Approach: Re-stripe the right turn lane to provide a shared
through-right turn lane (with a minimum of 5507feet Qfstorage).
MM TRANS-]c: SR-210 Westbound RampslSan Bernardino Avenue (#14) - The addition of Project
traffic would result in unacceptable levels of service during the PM and Saturday peak hours as
compared to existing(2010) conditions. Northbound Approach: Widen to provide a dedicated right turn
lane. Eastbound Approach:Re-stripe to provide a 2nd through lane, Westbound Approach: Construct
a 2nd through lane and a dedicated right turn lane with a minimum of 150-feet of storage.
111M TRANS-Id: Church Street/San Bernardino Avenue (#40) - The addition of Project traffic
would result in unacceptable levels qfservice during the PM and Saturday peak hours as compared to
existing (2010) conditions. Install a traffic signal.
MM TRANS-le: Church StreetlLugonia Avenue (#41) - The addition of'Project traffic would result
in unacceptable levels of service during the PM peak hour as compared to existing(2010) conditions.
Northbound Approach:Re-stripe to provide a left turn lane and a shared through-right turn lane.
Southbound Approach:Re-stripe to provide a left turn lane and a shared through-right turn lane.
Cumulative Impacts
The applicant will be required to provide payment for their fair share of the improvements identified
under Mitigation TRANS-2 as described below. Fair share improvements are typically satisfied through
the payment of fees for improvements included in an established fee program, a financial contribution
based on estimated costs of improvements as assigned by the approving jurisdiction, specific
improvements that are significantly triggered by the Project or a combination of these strategies.
Several of the facilities forecasted to be impacted under cumulative conditions would be funded by the
City of Redlands Development Impact Fee(DIF) Program, while many of them are not included in the
DIF. Further, the following improvements are located outside of the City, within unincorporated San
Bernardino County:
• Alabama Street/San Bernardino Avenue: LNB Right Turn Lane with Overlap, I." Left Turn Lane.
• Alabama Street/Lugonia Avenue: LNB Left Turn Lane, I.NI3 Through Lane, LNB Right Turn Lane
with Overlap, LSB Left Turn Lane, LEB Left Turn Lane, I EB Right Turn Lane with Overlap, I.WI3
Left Turn Lane.
- SR-210 Eastbound Ramps/San Bernardino Avenue: I.NI3 Right Turn Lane with Overlap, 1.SB Left
Turn Lane, LSB Right Turn Lane, LEB Left Turn Lane, 2.EB Through Lanes, LWB Left Turn Lane,
2.WB Through Lanes, LWB Right Turn Lane.
None of these improvements are included in the County's Development Impact Fee Program. As a
condition of approval, Walmart will be required to make a fair share contribution into the existing
County fee program to be directed towards those improvements.
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As shown in Table 7-5 of the Traffic Impact Analysis,the proposed Project contributes to cumulative
traffic impacts at twenty(20) intersections located within the City of Redlands or the County of San
Bernardino. For facilities not covered by an existing fee program, the Project would contribute the
associated intersection fair-share percentage toward the costs of the recommended improvements.
Improvements included in the column labeled"Non-Program Improvements"do not appear to be in an
established fee program. A fair share financial contribution based upon the Project's fair share impacts
may be imposed in order mitigate the Project's share of impacts in lieu of construction.The fair-share
calculations provided in Appendix 7.11 of the Draft EIR shows that the proposed Project contributes
between 2.0% and 37.6%of trips at the study area intersections. These percentages are also shown on
Table 7-5 of the Traffic Impact Analysis in the last column for each cumulatively impacted location.
However, cumulative impacts will remain significant and unavoidable. This is because, although the
intersections identified as being subject to cumulative impacts may be improved by time that the various
improvements identified are needed to maintain acceptable LOS in support of the Project,there are
many uncertainties related to the timing of the full funding and completion of such improvements
including; payment of DIF fees/fair share payments by other development in the future, availability of
non-DIF funding that may be available to the City in the future, and, for improvements located in
County unincorporated areas, County decisions and funding availability for completing the necessary
improvements. Due to these uncertainties, timely construction of improvements needed to address
cumulative impacts cannot be guaranteed.
MU TRANS-2: The applicant shall participate in the funding of off-site improvements, including
traffic signals that are needed, as identified in Mitigation Measures 2a through 2t to serve cumulative
traffic conditions through the payment of City of Redlands Development Impact Fees (DIF) or through a
fair share contribution, or combination of both, as directed by the City.
MM TRANS-2a: California StreetlI-10 Westbound Ramps (#3) - This intersection can be mitigated
by providing the following geometric improvement: Westbound Approach: Widen to provide a left turn
lane.
MM TRANS-2b: California StreetlRedlands Boulevard(#5) - This intersection can be mitigated by
implementing protected left turn phasing on all approaches in conjunction with the following geometric
improvement:Northbound Approach: Widen to provide a left turn lane. Striping shall be provided
within the intersection for the eastbound and westbound left turning vehicles due to the off-set nature of
the intersection.
MU TRANS-2c: Alabama StreetlSan Bernardino Avenue (#7) - This intersection can be mitigated
by providing the following geometric improvements: Northbound Approach:Re-stripe to provide a
dedicated northbound right turn lane with overlap phasing. Westbound Approach: Widen to provide a
2nd left turn lane.
MU TRANS-2& Alabama StreetlLugonia Avenue (#8) - This intersection can be mitigated by
providing the following geometric improvements: Northbound Approach: Widen to provide a 2nd left
turn lane, 3rd through lane and a right turn lane with overlap phasing. Southbound Approach: Widen
to provide a 2nd left turn lane. Eastbound Approach: Widen to provide a 2nd left turn lane and right
turn lane with overlap phasing, Westbound Approach: Widen to provide a 2nd left turn lane.
MU TRANS 2e: Alabama StreetJ-10 Westbound Ramps (#9) - This intersection can be mitigated
by providing the following geometric improvements:Northbound Approach: Widen to provide a 2nd left
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City of Redlands-Redlands Crossing Project
Facts,Findings,and Statement of Overriding Considerations
Related to the Final Environmental Impact Report
MM TRANS-2o: Texas Street/Brockton Avenue (#31) - This intersection can be mitigated by
installing a traffic signal and providing the following geometric improvements:Northbound Approach:
Widen to provide a left turn lane. Southbound Approach: Widen to provide a left turn lane.
MM TRANS-2p: Orange StreetlPioneer Avenue (#35) - This intersection can be mitigated by
installing a traffic signal. No other lane geometric improvements are needed.
MM TRANS-2q: Church StreetlSan Bernardino Avenue (#40) - This intersection can be mitigated
by installing a traffic signal and providing the following geometric improvements:Northbound
Approach: Re-stripe to provide one left turn lane and a shared through-right turn lane. Southbound
Approach: Re-stripe to provide one left turn lane and a shared through-right turn lane. Eastbound
Approach: Widen to provide a left turn lane and 2nd through lane. Westbound Approach: Widen to
provide a left turn lane and 2nd through lane.
MM TRANS-2r: Church StreetlLugonia Avenue (#41)- This intersection can be mitigated by
protecting the northbound and southbound approach left turn movements and providing the following
geometric improvements:Northbound Approach: Widen to provide a left turn lane and 2nd through
lane. Southbound Approach: Widen to provide a left turn lane and 2nd through lane.
MM TRANS-2s: University Street/San Bernardino Avenue (#42) - This intersection can be
mitigated by installing a traffic signal andproviding the following geometric improvements:Eastbound
Approach: Widen to provide a 2nd through lane. Westbound Approach: Widen to provide a 2nd
through lane.
MM TRANS-2t: Judson Street/San Bernardino Avenue (#44) - This intersection can be mitigated
by providing the following geometric improvements: Eastbound Approach: Widen to provide a left turn
lane and 2nd through lane. Westbound Approach: Widen to provide a left turn lane and 2nd through
lane.
Site Access and On-Site Roadway Improvements
Roadway improvements necessary to provide site access and on-site circulation are assumed to be
constructed in conjunction with site development and are described below. These improvements should
be in place prior to occupancy.
Site Access Improvements
Site access driveway improvements for the Project are described below. Construction of on-site and site
adjacent improvements shall occur in conjunction with adjacent project development activity or as
needed for Project access purposes. These improvements shall be in place prior to occupancy, to ensure
impacts are mitigated to a level of less than significant.
MM TRANS-3a: Tennessee Street at Driveway I -Install a traffic signal and construct the
intersection with the following geometries: one northbound through lane, one northbound shared
through-right turn lane, southbound left turn lanes providing a minimum of 350-feet of storage, two
southbound through lanes, one westbound left turn lane and one westbound right turn lane.
MM TRANS-3b: Tennessee Street at Pennsylvania Avenue -Install a traffic signal and construct
the intersection with the following geometries: one northbound through lane, one northbound shared
through-right turn lane, one southbound left turn lane providing a minimum of 150 feet of storage, two
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Facts,Findings,and Statement of Overriding Considerations
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southbound through lanes, one westbound left turn lane with a minimum of 150 feet of storage and one
westbound right turn lane.
IVIM TRANS-3c: Driveway 2 at Pennsylvania Avenue -Install a stop control on the southbound
approach and construct the intersection with the following geometrics: one southbound left turn lane,
one southbound right turn lane, one eastbound left turn lane one eastbound through lane and one
westbound shared through-right turn lane.
MM TRANS-3d: Driveway 3 at San Bernardino Avenue-Install a traffic signal and construct the
intersection with the following geometrics: dual northbound left turn lanes, one northbound right turn
lane, three eastbound through lanes, one eastbound right turn lane providing a minimum of 300 feet of
storage, one westbound left turn lane providing a minimum of 250 feet of storage and one westbound
through lane. It should be noted that it is necessary for the Project to construct a second westbound
through lane between Tennessee Street and Driveway 3 to provide the appropriate number of receiving
lanes for the dual northbound left turn lanes out of Driveway 3.
MM TRANS-3e: Driveway 4 at Pennsylvania Avenue -Install a stop control on the southbound
approach and construct the intersection with the following geometrics: one southbound shared left-right
turn lane, one eastbound left turn lane with a minimum of 100 feet of storage, one eastbound through
lane and one westbound shared through-right turn lane.
MM TRANS-3f• New York Avenue at San Bernardino Avenue -Install a traffic signal and
construct the intersection with the following geometrics: one northbound left turn lane with a minimum
of 150 feet of storage, one northbound right turn lane with a minimum of 150 feet of storage, two
eastbound through lanes, one eastbound shared through-right turn lane, one westbound left turn lane
providing a minimum of 300 feet of storage and one westbound through lane. It should be noted that
space for a northbound through lane should be provided for future access onto the extension of New
York Avenue, north of San Bernardino Avenue.
MM TRANS-3g: New York Avenue at Driveway 5 -Install a stop control on the eastbound
approach and construct the intersection with the following geometrics: one northbound left turn lane
with a minimum of 100-feet of storage, one northbound through lane, one southbound shared through-
right turn lane and one eastbound shared left-right turn lane.
MM TRANS-3h: On-site traffic signing and striping should be implemented in conjunction with
detailed construction plans for the Project site.
MM TRANS-3i: Sight distance at each Project access point should be reviewed with respect to
standard Caltrans and City of Redlands sight distance standards at the time ofpreparation of final
grading, landscape and street improvement plans,
On-Site Roadway Improvements
Site-adjacent roadway improvements for the Project are described below. Construction of site-adjacent
roadway improvements shall occur in conjunction with adjacent Project development activity or as
needed for Project access purposes.
MM TRANS`4a: San Bernardino Avenue- Constnict at its ultimate half-section width as a Major
Arterial(120 foot right-of-way) between Tennessee Street and New York Avenue, consistent with the
circulation recommendations found in the East Valley Corridor Specific Plan.
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MM TRANS-4b: Tennessee Street- Construct at its ultimate full-section width as a Minor Arterial
(88footright-of-way)between San Bernardino Avenue and Pennsylvania Avenue, consistent with the
City of Redlands General Plan Circulation Element.
MM TRANS-4c: New York Avenue- Construct a minimum of one lane in each direction of travel
and a two-way-left-turn lane (painted median) on New York Avenue between San Bernardino Avenue
and Pennsylvania Avenue 1 (66 foot right-oflivay).
MM TRANS-4d Pennsylvania Avenue- Construct a minimum of one lane in each direction of
travel and a two-way-left-turn lane (painted median) on Pennsylvania Avenue between Tennessee Street
and New York Avenue(48footright-of-way). It should be noted that the construction of Pennsylvania
Avenue along the Project frontage will not connect to the existing Pennsylvania Avenue east of Karon
Street.
MM TRANS 4e: Roadways adjacent to the Project, site access points and site-adjacent
intersections will be constructed to be consistent with the recommended roadway classifications and
respective cross-sections in the East Valley Corridor Specific Plan (the governing land use document for
the area north of the Project site which includes San Bernardino Avenue).
Short-Term Construction
MM TRANS-5a The export and import of construction materials shall occur during off-peak hours
in order to have a minimal traffic impact to the surrounding roadway network. In addition, a
construction traffic managementplan shall be implemented for the duration of the construction phase.
MM TRANS-5b The delivery and removal of heavy equipment shall occur outside of the morning
and evening peak hours in order to have nominal impacts to traffic and circulation near the vicinity of
the Project.
(DEIR pp. 3.15-103 to 3.15-112.)
Facts in Support of the Finding: According to the East Valley Corridor Specific Plan(EVCSP) Final
EIR(October 1988),buildout of the Specific Plan will have a significant and unavoidable impact to
local and regional traffic within the Specific Plan area. Pursuant to State CEQA Guidelines Section
15093, decision-makers are required to adopt a statement of overriding considerations for the Project's
significant unavoidable impacts that cannot be fully mitigated or avoided and to explain why the
EVCSP's benefits outweigh the unavoidable adverse environmental effects. Therefore,the County of
San Bernardino Land Management Department/Office of Planning(Lead Agency)prepared a statement
of overriding considerations to find that the EVCSP would provide specific economic, social, and other
benefits that outweigh the unavoidable adverse environmental impacts of the EVCSP, such that those
impacts are considered acceptable. (DEIR p. 3.15-36.)
The Project site is located within the East Valley Corridor Plan (September 1989)and is required to be
consistent with the following applicable goals and policies related to the transportation and circulation.
The Project related traffic impacts were analyzed in the TIA prepared by Urban Crossroads (UC 2011).
Operation of these facilities has been analyzed for both weekday evening(4:00 to 6:00 PM) and
Saturday(2:00 to 4:00 PM)peak hour conditions for the following scenarios: Scenario 1: Existing—
Existing volumes obtained from recent(2010)traffic counts and existing lane configurations. Scenario
2: Existing Plus Project—Existing volumes obtained from recent(2010)traffic counts and existing lane
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configurations plus the new traffic generated by the proposed Project. Scenario 3: Opening Year 2013
With Project—Existing volumes plus three(3) years of ambient growth plus the new traffic generated
by pending and approved,but not yet constructed developments in the area, plus the new traffic
generated by the proposed Project. Scenario 4: Year 2030 Without Project—Traffic volumes
representing the area-wide growth anticipated between 2010 and Year 2030, less traffic from the
proposed Project. Scenario 5: Year 2030 With Project—Year 2030 volumes with the proposed Project.
(DEIR pp. 3.15-36 to 3.15-37.)
Note: AM Peak Hour conditions were not analyzed because these conditions are not worse case scenario
when compared to PM Peak Hour and Saturday Peak Hour conditions. (DEIR p. 3.15-37.)
The traffic generation is based upon the specific land uses planned for the Project. A summary of
Project trip generation is shown in Table 3.15-9 in the Draft EIR. The trip generation rates are based
upon data collected by the Institute of Transportation Engineers(ITE) Trip Generation Manual, 8th
Edition, 2008. (DEIR p. 3.15-37.)
As shown on Table 7.1 of the ITE Trip Generation Handbook, the internal capture percentage between
retail-to-retail land uses is approximately 20%during the weekday PM peak hour. As such, a 10%
internal capture reduction has been utilized in an effort to estimate a conservative trip generation for the
proposed Project. Weekend daily trip generation has been estimated for both Saturday and Sunday at
the request of City of Redlands staff. However, only the Saturday peak hour and daily trip generation
has been utilized for the purposes of this analysis as Saturday is the worst-case weekend condition. As
such, the Sunday daily trip generation has been provided in Table 3.15-9 for comparative purposes
only. Sunday daily trip generation rates are not available in the ITE Trip Generation Manual for the
fast-food without drive-thru window and gas station with convenience market and car wash uses. As
such, a percentage has been applied to the Saturday daily rate to estimate a Sunday daily trip generation
rate. In comparing land uses that had daily trip generation rates available for both Saturday and Sunday,
it appears the Sunday rate is approximately 49 to 88 percent of the Saturday trip generation rate. A
conservative reduction rate of 80 percent has been applied to the Saturday trip generation rate to
determine the Sunday daily rate for the fast-food without drive-thru window and gas station with
convenience market and car wash uses. (DEIR pp. 3.15-37 to 3.15-38.)
As can be seen within Table 3.15-9 in the Draft EIR, the proposed development is projected to generate
a total of approximately 19,481 net trip-ends per day on a typical weekday, 22,907 net trip-ends per day
on a Saturday and approximately 18,820 net trip-ends per day on a Sunday. The Project is anticipated to
generate a total of approximately 1,402 net weekday PM peak hour trips and 1,941 net Saturday peak
hour trips. (DEIR p. 3.15-38.)
The Project traffic is distributed to the network via Project driveways to ensure the necessary lane
geornetrics for the site access points are understood, and to identify potential Project impacts to nearby
intersections. The Project inbound trip distribution pattern is graphically depicted on Exhibit 3.15-5a of
the Draft EIR. The Project outbound distribution pattern is graphically depicted on Exhibit 3.15-5b of
the Draft EIR. (DEIR p. 3.15-38.)
CEQA Guidelines require that other reasonably foreseeable development projects which are either
approved or being processed concurrently in the study area also be included as part of a cumulative
analysis scenario. As a worst-case scenario, the cumulative development projects included in this
analysis were derived form current applications and projects undergoing development within the City of
Redlands and were subsequently provided by City of Redlands staff. Projects outside of the City of
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Redlands city limits have also been obtained from the County of San Bernardino, City of Highland and
City of Loma Linda to include the future projects proposed within the study area, including the Donut
Hole region. (DEIR p. 3.15-38.)
Cumulative development projects included in this analysis are assumed to contribute traffic to at least
one or more of the study area intersections. A list of the cumulative development projects is included in
Table 3.15-10 and shown in Exhibit 3.15-6 of the Draft EIR. (DEIR p. 3.15-38.)
The cumulative development projects assumed in the TIA were estimated to generate 126,627 net trip-
ends per day with approximately 11,601 vehicle trips during the weekday PM peak hour and 11,851
vehicle trips during the Saturday peak hour. In light of current market conditions,these traffic forecasts
would tend to overstate as opposed to understate traffic impacts for cumulative conditions. (DEIR p.
3.15-49.)
In an effort to more accurately represent current economic conditions,the forecasted growth in traffic
volumes related to cumulative development has been based on a different absorption percentage for each
future year scenario. Specifically, the future traffic scenarios assume 30 percent of the projected
cumulative development traffic for 2013 conditions and 100 percent of the projected cumulative
development traffic for 2030. Future projected cumulative development traffic is assumed as a worst-
case scenario for 2013 and 2030 cumulative traffic conditions. (DEIR p. 3.15-49.)
Note that future year traffic forecasts have been based upon three(3) years of background (ambient)
growth at 2%per year for Opening Year 2013 traffic conditions. The ambient growth factor is intended
to approximate regional traffic growth. The adopted Southern California Association of Governments
(SLAG) 2008 Regional Transportation Plan(RTP) growth forecasts for San Bernardino County
identifies projected growth in population of 1,864,264 in 2003 to 3,133,801 in 2035,or a 68% increase
over the 32 year period. The change in population equates to roughly a 1.64 percent growth rate
compounded annually. Similarly, growth over the same 32-year period in households is projected to
increase by 76 percent,or 1.78 percent annual growth rate. Finally, growth in employment over the
same 32-year period is projected to increase by 96 percent, or a 2.13 percent annual growth rate. The
use of an annual growth rate of 2.0 percent would appear to conservatively approximate the anticipated
regional growth in traffic volumes in the San Bernardino County, especially when considered along with
the addition of project-related traffic and traffic generated by other known development projects. (DEIR
p. 3.15-49.)
The total ambient growth is 6.12%for Opening Year 2013 traffic conditions (compounded growth of
two percent per year over three years). This ambient growth rate is added to existing traffic volumes to
account for area-wide growth not reflected by cumulative development projects. Ambient growth has
been added to daily and peak hour traffic volumes on surrounding roadways, in addition to traffic
generated by the Project. Opening Year 2013 with Project traffic conditions includes the traffic
generated by the Project, which is added to the Opening Year 2013 without Project traffic volumes.
(DEIR p. 3.15-49.)
Construction Traffic-Traffic operations during the proposed construction phase of the Project may
potentially result in traffic impacts related to construction employees, export of materials,import of
construction materials,etc. It is anticipated that the following construction-related activities would
generate traffic and may potentially result in construction-related traffic impacts: Employee trips; Export
of materials; Import of construction materials; Use of heavy equipment. Each of the traffic generating
activities listed above is discussed thoroughly in the subsequent sections. It has been assumed that
113
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Facts,Findings,and Statement of Overriding Considerations
Related to the Final Environmental Impact Report
construction activity will occur during the hours of 7:00 AM and 4:00 PM. (DEIR pp. 3.15-49 to 3.15-
50.)
Employee trips are estimated based on the number of employees estimated to be onsite throughout the
various stages of construction. Each employee is assumed to drive and from the construction site each
day. It has been assumed that employees will arrive up to 30 minutes prior to the workday and will
leave up to 30 minutes after the workday ends. Parking for employees and non-employee vehicles can
be accommodated through the construction of a portion of the proposed parking lot for the Project.
(DEIR p. 3.15-50.)
It is anticipated that the majority of employees would arrive and depart from the site adjacent to the peak
commute traffic periods(i.e., 7:00 a.m. to 9:00 a.m. and 4:00 p.m. to 6:00 p.m.)with a period of overlap.
Employee trips are based on the number of employees estimated to be onsite during different points
throughout the Project. Each employee is assumed to drive to and from the site alone each day. The
impacts of construction-related parking and employee traffic are considered less-than-significant.
(DEIR p. 3.15-50.)
Construction of the Project will require the export and import of construction materials to and from the
site. The export/import materials will be transported via 15-cubic yard (cy) capacity dump trucks. Each
truck will generate one(1)inbound and one(1) outbound trip, accounting for a total of two (2)truck
trips per load of material exported or imported. Export of construction materials is anticipated to consist
of the exportation of"cut"soil from the site. Import of construction materials is anticipated to consist of
the importation of raw building materials, concrete, asphalt, etc. (DEIR p. 3.15-50.)
In order to minimize the impact of construction truck traffic to the surrounding roadway network,
mitigation measure MM TRANS-5a will require trucks to utilize the most direct route between the site
and the SR-210 Freeway via San Bernardino Avenue to Tennessee Street. It is anticipated that the
construction staging will be located off of Tennessee Street. As such, the proposed construction access
on Tennessee Street will provide the most direct access. (DEIR p. 3.15-50.)
In addition, implementation of mitigation measure MM TRANS-5b will require the export and import of
construction materials to occur during off-peak hours in order to have a minimal traffic impact to the
surrounding roadway network. Further, a construction traffic management plan shall be implemented
for the duration of the construction phase. Consistency with these measures will reduce truck traffic
impacts associated with the export and import of construction materials to less-than-significant levels.
(DEIR p. 3.15-50.)
Heavy equipment to be utilized onsite during construction include, but is not limited to: flat beds,
dozers, scrapers, graders, track hoes, dump trucks, forklifts, cranes, cement trucks,pavers,rollers,water
trucks, rolling container trucks and bobcats. Heavy equipment will be delivered and removed from the
site throughout the construction phase. As most heavy equipment is typically not an authorized vehicle
to be driven on a public roadway, most of the equipment will be delivered and removed from the site via
large flatbed trucks. It is anticipated that delivery of heavy equipment would not occur on a daily basis,
but rather periodically throughout the construction phase based on need. (DEIR p. 3.15-51.)
The delivery and removal of heavy equipment shall occur outside of the morning and evening peak
hours in order to have nominal impacts to traffic and circulation near the vicinity of the Project.
Consistency with this measure will reduce traffic impacts associated with the delivery and removal of
heavy equipment to less-than-significant levels. (DEIR p. 3.15-51.)
114
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Facts,Findings,and Statement of Overriding Considerations
Related to the Final Environmental Impact Report
Existing 2010 Plus Project
No changes to existing lane configurations and traffic controls have been assumed to be in place for
existing plus Project traffic conditions. This scenario includes existing(2010) traffic volumes plus
traffic generated by the proposed Project. (DEIR p. 3.15-51.)
Intersection Operations -Level of service calculations were conducted for the study intersections to
evaluate their operations under existing plus Project conditions with roadway and intersection
modifications. The results of the intersection level of service analysis are presented in Table 3.15-11 of
the Draft EIR. (DEIR p. 3.15-51.)
As shown in Table 3.15-11,the study area intersections that are projected to not meet the City of
Redlands level of service threshold of C or better have been denoted with bold text. It should be noted
that the level of service threshold of C or better does not apply to the intersection of Boulder Street at
Greenspot Road in the City of Highland. The level of service threshold for the City of Highland is LOS
D or better. (DEIR p. 3.15-57.)
For existing plus Project traffic conditions,the following study area intersections are projected to
operate at an unacceptable level of service during the peak hours: California Street/Redlands Boulevard
(LOS D—Saturday peak hour); Alabama Street/Lugonia Avenue(LOS D —PM and Saturday peak
hours); Alabama Street/1-10 Westbound Ramps(LOS D—Saturday peak hour); Alabama
Street/Redlands Boulevard(LOS D—PM and Saturday peak hours); SR-210 Eastbound Ramps/San
Bernardino Avenue(LOS F—PM and Saturday peak hours); SR-210 Westbound Ramps/San Bernardino
Avenue(LOS F—PM peak hour; LOS E—Saturday peak hour); Tennessee Street/Lugonia.Avenue
(LOS D—Saturday peak hour); Texas Street/Brockton Avenue(LOS D —Saturday peak hour); Church
Street/San Bernardino Avenue(LOS F—PM and Saturday peak hours); Church Street/Lugonia Avenue
(LOS E—PM peak hour). (DEIR p. 3.15-57.)
It should be noted that the intersections listed above are consistent with the locations that have been
identified to be currently operating at unacceptable levels of service under existing traffic conditions,
with the exception of the intersection of Alabama Street at the 1-10 Westbound ramps. (DEIR p. 3.15-
57.)
Freeway Mainline Operations -The existing plus Project freeway analysis assumes the existing mixed-
flow lanes only and does not include any future mainline improvements. Segment analysis results for
the weekday PM and Saturday peak hours are summarized on in Table 3.15-12 of the Draft EIR. As
shown on in Table 3.15-12 of the Draft EIR, the following segment is anticipated to operate at
unacceptable service levels for existing plus Project conditions: SR-210 Westbound,north of San
Bernardino Avenue(LOS F—Saturday peak hour). (DEIR pp. 3.15-57 to 3.15-59.)
Freeway Ramp Operations -Ramp merge and diverge operations were evaluated under existing plus
Project conditions for the 1-10/California Street(Saturday peak hour only), I-10/Alabama Street, SR-210
to/from I-10 Freeway,I-I O/Tennessee Street and SR-210/San Bernardino Avenue interchanges, as
presented in Table 3.15-13 in the Draft EIR. As also shown on Table 3.15-13,it is anticipated that the
following ramp junctions along the SR-210 and I-10 Freeways would operate at unacceptable service
levels for existing plus Project conditions: SR-210 Westbound, on-ramp at San Bernardino Avenue
(LOS F—Saturday peak hour); I-10 Eastbound,on-ramp from SR-210 Eastbound(LOS F—PM and
LOS E Saturday peak hours). It should be noted that these ramp junction locations are currently
operating deficiently under existing traffic conditions. (DEIR p. 3.15-59.)
115
C4 of Redlands-Redlands Crossing Project
Facts,Findings,and Statement of Overriding Considerations
Related to the Final Environmental Impact Report
Project Impacts,Proposed Mitigation and Improvement Strategies
The study area intersections found to be significantly impacted by the Project at which are shown in
Table 3.15-14 in the Draft EIR. As shown on Table 3.15-14, five (5) intersections are projected to
operate at level of service D or worse and are significantly impacted by the Project. They are as follows:
Alabama Street/1-1.0 Westbound Ramps—Saturday peak hour only; SR-210 Eastbound Ramps/San
Bernardino Avenue—PM and Saturday peak hours; SR-210 Westbound Ramps/San Bernardino Avenue
—PM and Saturday peak hours; Church Street/San Bernardino Avenue—PM and Saturday peak hours;
Church Street/Lugonia Avenue—PM peak hour only. (DEIR pp. 3.15-59 to 3.15-64.)
Mitigation measures have been identified to address LOS and delay at each affected intersection
consistent with the applicable jurisdiction's LOS standards. Consistency with Mitigation Measures MM
TRANS-I a through MM TRANS-I e will reduce impacts for Existing Plus Project Conditions to a level
of less than significant. (DEIR p. 3.15-64.)
Opening Year 2013 -Based on discussions with City staff,there are no committed improvements that
are currently planned to be in place by Opening Year 2013 traffic conditions. The results of the
intersection LOS analysis for Opening Year 2013 are presented in Table 3.15-15 (including Existing
2010, Year 2013 Without Project and Year 2013 With Project). The study area intersections that are
projected to not meet the City of Redlands LOS threshold of C or better have been denoted with bold
text. It should be noted that the LOS threshold of C or better does not apply to the intersection of
Boulder Street at Greenspot Road in the City of Highland. The LOS threshold for the City of Highland
is LOS D or better. (DEIR p. 3.15-64.)
As can be seen within Table 3.15-15 of the Draft EIR, for 2013 Conditions Intersection Analysis, the
following study area intersections are projected to operate at an unacceptable level of service during the
peak hours (see Exhibit 3.15-7 for Year 2013 Without Project Peak Hour Intersection LOS): California
Street/Redlands Boulevard(LOS D— Saturday peak hour); Alabama Street/Lugonia Avenue(LOS D —
PM peak hour; LOS E—Saturday peak hour); Alabama Street/1-10 Westbound Ramps(LOS D—PM
peak hour; LOS F—Saturday peak hour); Alabama Street/1-10 Eastbound Ramps(LOS D—PM peak
hour; LOS F—Saturday peak hour); Alabama Street/Redlands Boulevard(LOS F—PM and Saturday
peak hours); SR-210 Eastbound Ramps/San Bernardino Avenue(LOS F—PM and Saturday peak
hours); SR-210 Westbound Ramps/San Bernardino Avenue(LOS F—PM and Saturday peak hours);
Tennessee Street/Lugonia Avenue(LOS D—PM and Saturday peak hours); Tennessee Street/I-10
Eastbound Ramps(LOS D—PM peak hour); Tennessee Street/Colton Avenue(LOS D—PM and
Saturday peak hours); Tennessee Street/Redlands Boulevard(LOS D—PM peak hour); Texas
Street/Brockton Avenue(LOS D—PM peak hour; LOS E—Saturday peak hour); Church Street/San
Bernardino Avenue(LOS F— PM and Saturday peak hours); and Church Street/Lugonia Avenue(LOS
F—PM peak hour). (DEIR p. 3.15-69.)
These study area intersections are anticipated to exceed LOS thresholds and thus have a significant
cumulative impact due to traffic volumes generated by other reasonably foreseeable development
projects in the area in conjunction with Project traffic. Measures to address cumulative impacts for
Opening Year 2013 traffic conditions are discussed in Mitigation Measure MM TRANS 2 at the end of
this Impact Analysis. As such, the Project is required to pay its fair share/DIF amount of the
improvement costs of the impacted intersections to the City in order to mitigate the Project's traffic
impacts. Additionally, as a condition of approval, Walmart will be required to make a fair share
contribution into the existing County fee program to be directed towards those improvements.
116
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Facts,Findings,and Statement of Overriding Considerations
Related to the Final Environmental Impact Report
After the City's DIF fees are collected, they are placed in a separate restricted use account pursuant to
the requirements of Government Code sections 66000 et seq. The timing to use the DIF fees is
established through periodic capital improvement programs which are overseen by the City's Municipal
Utilities and Engineering Department. Periodic traffic counts, review of traffic accidents, and a review
of traffic trends throughout the City are also periodically performed by City staff and consultants. The
City uses this data to determine the timing of the improvements listed in its facilities list. The City also
uses this data to ensure that the improvements listed on the facilities list are constructed before the LOS
falls below the LOS performance standards adopted by the City. In this way, the improvements are
constructed before the LOS falls below the City's LOS performance thresholds. The City's DIF
program establishes a timeline to fund, design, and build the improvements. The Project applicant will
be subject to the City's DIF fee program, and will pay the requisite City DIF fees at the rates then in
effect pursuant to the City's ordinance. The payment of the requisite DIF fees then in effect pursuant to
the DIF Program will mitigate its contribution to cumulative impacts to DIF-funded facilities.
Fair share improvements are typically satisfied through the payment of fees for improvements included
in an established fee program, a financial contribution based upon rough order of magnitude costs as
assigned by the approving jurisdiction, specific improvements that are significantly triggered by the
project or a combination of these strategies. As shown in Table 7-5 of the Traffic Impacts Analysis, the
proposed Project contributes to cumulative traffic impacts at twenty(20) intersections located within the
City of Redlands or the County of San Bernardino. For facilities not covered by an existing fee
program, the Project would contribute the associated intersection fair-share percentage toward the costs
of the recommended improvements. Improvements included within the column labeled'Non-Program
Improvements"do not appear to be in an established fee program. A fair share financial contribution
based upon the Project's fair share impacts that are reasonably related to the traffic burdens caused by
the Project will be imposed in order to mitigate the Project's share of impacts in lieu of construction.
This fee is collected by the City and County, held in a separate reserve account in the jurisdiction's
general fund, and used solely for the specific surface transportation improvements. The fair-share
calculations provided in Appendix 7.11 of the Traffic Impacts Analysis shows that the proposed Project
contributes between 2.0%and 37.6%of trips at the study area intersections. These project-related traffic
increases provide the basis for the Project's fair share percentage contribution.
Although these intersections may be improved by time that the various improvements identified are
needed to maintain acceptable LOS in support of the Project, there are many uncertainties related to the
timing of the full funding and completion of such improvements including; payment of DIF fees/fair
share payments by other development in the future, availability of non-DIF funding that may be
available to the City in the future, and, for improvements located in County unincorporated areas,
County decisions and funding availability for completing the necessary improvements.
Due to these uncertainties, timely construction of improvements needed to address cumulative impacts
cannot be guaranteed. Therefore, impacts in this regard will be significant and unavoidable and a
Statement of Overriding Considerations will be developed. (DEIR p. 3.15-69.)
Freeway Mainline Operations- Opening Year 2013 without and with Project mainline directional
volumes for the PM and Saturday peak hours assumes the existing mixed-flow lanes only and do not
include any future mainline improvements. Segment analysis results for the weekday PM and Saturday
peak hours are summarized on Table 3.15-16 of the Draft EIR. (DEIR p. 3.15-69.)
117
City of Redlands-Redlands Crossing Project
Facts,Findings,and Statement of Overriding Considerations
Related to the Final Environmental Impact Report
As shown on Table 3.15-16, the following segment is anticipated to operate at unacceptable service
levels for Opening Year 2013 without Project conditions: SR-210 Westbound, north of San Bernardino
Avenue (LOS F—Saturday peak hour). Consequently, impacts in,this regard will be significant.
However, for Opening Year 2013 with Project conditions,there are no additional segments along the
SR-210 or 1-10 Freeways anticipated to operate at unacceptable service levels. (DEIR p. 3.15-73.)
Freeway Ramp Operations- Ramp merge and diverge operations were evaluated under Opening Year
2013 conditions for the I-10/California Street(Saturday peak hour only), I-10/Alabama Street, SR-210
to/from I-10 Freeway, I-10/Tennessee Street and SR-210/San Bernardino Avenue interchanges, as
presented in Table 3.15-17 of the Draft EIR. As also shown on Table 3.15-17, it is anticipated that the
following ramp junctions along the SR-210 and I-10 Freeways would operate at unacceptable service
levels for Opening Year 2013 without Project conditions: SR-210 Westbound, on-ramp at San
Bernardino Avenue(LOS F—Saturday peak hour); and I-10 Eastbound, on-ramp from SR-210
Eastbound(LOS F—PM and Saturday peak hours). (DEIR pp. 3.15-73 to 3.15-76.)
Consequently, impacts in this regard will be significant. However, for Opening Year 2013 with Project
conditions, there are no additional ramp junctions along the SR-210 or I-10 Freeways anticipated to
operate at unacceptable service levels. (DEIR p. 3.15-76.)
Mitigation measures have been identified at intersections that have been identified as cumulatively
impacted to improve each location's peak hour delay and associated LOS grade to LOS C or better,
consistent with the City of Redlands General Plan Policy 5.20. The effectiveness of the mitigation
measures discussed below to address Opening Year 2013 cumulative traffic impacts are presented in
Table 3.15-18. The Project shall participate in funding or construction of offsite improvements that are
needed to serve cumulative traffic conditions through the payment of the City of Redlands Development
Impact Fees(DIF)or on a fair share basis as directed by the City. The fees are collected as part of a
funding mechanism aimed at ensuring that roadway network improvements keep pace with the projected
population increases. Measures to address cumulative impacts for Opening Year 2013 cumulative
traffic conditions are discussed in Mitigation Measure MM TRANS 2 at the end of this Impact Analysis.
(DEIR p. 3.15-76.)
In addition, in consultation with Caltrans District 8 staff, planned future improvements to the SR-210
Freeway includes the construction of a mixed-flow lane and HOV lane in each direction and the future
planned improvements to the 1-10 Freeway include the construction of an HOV lane in each direction.
Caltrans does not have an estimated date of completion for these widening projects; however, it is
anticipated that due to the existing need and volume of traffic utilizing the freeway, Caltrans would
work diligently to complete the upgrades by Year 2030. (DEIR p. 3.15-76.)
As shown on Table 3.15-1.8 of the Draft EIR, the freeway segment and merge junctions are anticipated
to operate at acceptable levels of service with the planned future improvements in place, with the
exception of the I-10 Eastbound on-ramp merge junction from the SR-210 Freeway during the weekday
PM peak hour. This location is anticipated to operate at LOS D operations. However, this merge
junction is anticipated to experience capacity issues due to projected future SR-210 Eastbound on-ramp
volumes, and as a result is anticipated to operate at LOS F. As this merge junction is a freeway-to-
freeway interchange within Caltrans'jurisdiction,neither the Project nor the City the Redlands has the
ability to improve this cumulative near-term impact. (DEIR p. 3.15-76.)
Horizon Year 2030- LOS calculations were conducted for the study intersections to evaluate their
operations under Horizon Year 2030 conditions with roadway and intersections and are shown in Table
918
City of Redlands-Redlands Crossing Project
Facts,Findings,and Statement of Overriding Considerations
Related to the Final Environmental impact Report
3.15-19 of the Draft EIR. The study area intersections that are projected to not meet the City of
Redlands LOS threshold of LOS C or better have been denoted with bold text. It should be noted that
the LOS threshold of LOS C or better does not apply to the intersection of Boulder Street at Greenspot
Road in the City of Highland. The LOS threshold for the City of Highland is LOS D or better. (DEIR
p. 3.15-80.)
As can be seen within Table 3.15-19 of the Draft EIR, for Horizon Year 2030 without Project traffic
conditions, the following study area intersections are projected to operate at an unacceptable LOS during
the peak hours (see Exhibit 3.15-8 of the Draft EIR, for Year 2030 Without Project Peak Hour
Intersection LOS): California Street/1-10 Westbound Ramps (LOS D—Saturday peak hour); California
Street/Redlands Boulevard(LOS D—Saturday peak hour); Alabama Street/San Bernardino Avenue
(LOS F—PM peak hour); Alabama Street/Lugonia Avenue(LOS E—PM peak hour; LOS F—Saturday
peak hour); Alabama Street/I-10 Westbound Ramps (LOS F—PM and Saturday peak hours); Alabama
Street/I-10 Eastbound Ramps (LOS F—PM and Saturday peak hours); SR-210 Eastbound Ramps/San
Bernardino Avenue(LOS F —PM and Saturday peak hours); SR-210 Westbound Ramps/San Bernardino
Avenue(LOS F—PM and Saturday peak hours); Tennessee Street/Lugonia Avenue(LOS D —Saturday
peak hour); Tennessee Street/I-10 Eastbound Ramps(LOS E—PM peak hour; LOS D—Saturday peak
hour); Tennessee Street/Colton Avenue(LOS D —PM and Saturday peak hours); Tennessee
Street/Redlands Boulevard(LOS D—PM peak hour);New York Street/Lugonia Avenue(LOS D—
Saturday peak hour);Texas Street/Brockton Avenue(LOS E—PM and Saturday peak hours); Orange
Street/Pioneer Avenue(LOS E— PM peak hour); Church Street/San Bernardino Avenue(LOS F—PM
and Saturday peak hours); Church Street/Lugonia Avenue(LOS F—PM peak hour);University
Street/San Bernardino Avenue (LOS D—PM peak hour); Judson Street/San Bernardino Avenue (LOS D
—PM peak hour). (DEIR p. 3.15-85.)
As shown on Table 3.15-19 of the Draft EIR, there are no additional intersections anticipated to operate
at unacceptable levels of service with the addition of Project traffic, with the exception of the
intersection of Tennessee Street/Lugonia Avenue(#17) during the weekday PM peak hour. Although
the intersection of Tennessee Street/Lugonia Avenue is projected to operate unacceptably during the
Saturday peak hour(as listed above), the intersection is projected to operate at acceptable levels of
service during the weekday PM peak hour without the Project. However, the addition of Project traffic
is anticipated to result in unacceptable operations during the PM peak hour(i.e., LOS D). (DEIR p.
3.15-85.)
It is anticipated that the addition of Project traffic would result in an increase in delay of less than two
seconds and the projected delay at the intersection of Tennessee Street/Lugonia Avenue is 34.0 seconds
(one second below LOS D)without the Project. (DEIR p. 3.15-86.)
Measures to address cumulative traffic impacts for Horizon Year 2030 traffic conditions are discussed at
the end of this Impact Assessment under Mitigation Measure TRANS 2. The Project is required to pay
its fair share/DIF amount of the improvement costs of the impacted intersections to mitigate the
Project's traffic impacts. Both the City of Redlands and the County of San Bernardino have DIF
programs to fund identified improvements. As discussed previously, for facilities and improvements not
covered by an existing fee program, the Project would contribute the associated intersection fair-share
percentage toward the costs of the recommended improvements to the appropriate agencies as directed
by the impacted jurisdiction. Although these intersections may be improved by time that the various
improvement-,identified are needed to maintain acceptable LOS in support of the Project,there are
many uncertainties related to the timing of the full funding and completion of such improvements
including; payment of DIF fees/fair share payments by other development in the future, availability of
119
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4
City of Redlands-Redlands Crossing Project
Facts,Findings,and Statement of Overriding Considerations
Related to the Final Environmental Impact Report
of service to a level of less than significant; however, cumulative impacts will remain significant and
unavoidable due to the uncertain timing of the completion oj'improvements. (DEIR p. 3.15-99.)
It is not within the jurisdictional authority or purview of the lead agency or developer to adopt,
implement, or enforce mitigation measures requiring the construction of improvements by Caltrans, or
upon facilities within Caltrans'jurisdiction. As such, there are no further mitigation measures that will
reduce cumulative mainline freeway impacts below significance thresholds. Traditional funding
mechanisms used to improve mainline freeways include Measure I retail sales tax revenue for
transportation, state and federal gas tax, and formula distributions from vehicle registration fees. Future
patrons of the Project contribute indirectly to freeway improvements through these sources. Therefore,
impacts in this regard will remain significant and unavoidable. (DEIR p. 3.15-99.)
The Project applicant will participate in the funding and construction of offsite improvements, including
traffic signals that are needed to serve cumulative traffic conditions through the payment of City of
Redlands Development Impact Fees (DIF) or through a fair share contribution as directed by the City.
Both the City of Redlands and the County of San Bernardino have DIF programs to fund identified
improvements. As discussed previously, for facilities and improvements not covered by an existing fee
program, the Project would contribute the associated intersection fair-share percentage toward the costs
of the recommended improvements to the appropriate agencies as directed by the impacted jurisdiction.
These fees are collected as part of a funding mechanism aimed at ensuring that regional highways and
arterial expansions keep pace with the projected population increases. See Table 3.15-23 of the Draft
EIR for a summary of transportation impact fee program improvements for Horizon Year 2030
conditions. (DEIR p. 3.15-99.)
The improvements listed in Table 3.15-22 are comprised of lane additions, installation of signals and
signal modifications. Lane additions are shown as the number of lanes required and the direction of
travel, for example, LEBT indicates one additional eastbound through lane. Depending on the width of
the existing pavement and right-of-way, these improvements may involve only striping modifications or
they may involve construction of additional pavement width. As set forth in Table 3.15-22, several of
the facilities forecast to be impacted under cumulative conditions are already planned for improvements
through the City of Redlands DIF Program. The Project applicant will be subject to the City's DIF fee
program, and will pay the requisite City DIF fees at the rates then in effect pursuant to the City's
ordinance. The payment of the requisite DIF fees then in effect pursuant to the DIF Program will
mitigate its contribution to cumulative impacts to DIF-funded facilities. (DEIR p. 3.15-103.)
As previously discussed and as shown in Table 3.15-22 of the Draft EIR, the proposed Project
contributes to cumulative traffic impacts at twenty(20) intersections located within the City of Redlands
or"Redlands Sphere"of the County of San Bernardino. For facilities not covered by an existing fee
program, the Project would contribute the associated intersection fair-share percentage toward the costs
of the recommended improvements. (DEIR p. 3.15-103.)
There are no additional ramp merge and diverge junctions anticipated to operate at unacceptable levels
of service with the addition of Project traffic, with the exception of the SR-210 Westbound on-ramp at
San Bernardino Avenue and the 1-10 Eastbound off-ramp to the SR-210 Westbound(upstream only). It
should be noted that the I-10 Eastbound off-ramp to the SR-210 Westbound is a freeway-to-freeway
diverge junction and is anticipated to operate at LOS F due to the addition of background growth and
cumulative traffic in conjunction with Project traffic. (DEIR p. 3.15-112.)
121
City of Redlands-Redlands Crossing Project
Facts,Findings,and Statement of Overriding Considerations
Related to the Final Environmental Impact Report
With respect to the significant impacts to the State facilities (mainline and ramp junctions) at the 2030
time horizon, no further mitigation measures or improvements are feasible. The
I-10 Freeway and SR-210 Freeway would operate at LOS F even without the Project under Horizon
Year 2030 traffic conditions. The Project's contribution to cumulative impacts under 2030 conditions is
relatively minor, involving only a small percentage of the forecast traffic occurring on the identified
segments at Horizon Year 2030 traffic conditions. Because the City has no control over State facilities,
and because the State facilities funded and planned to be developed under 2030 conditions are already
anticipated to operate at LOS E and F even without the Project, there are no further mitigation measures
that can be imposed upon the Project to mitigate its small cumulative contribution to significant impacts
to the identified segments of SR-210 Freeway and 1-10 Freeway under 2030 conditions. Caltrans has
exclusive control over State highway improvements and State highway improvements are by and large a
matter of statewide control. Thus, for the aforementioned reasons there are no available and feasible
mitigation measures available to mitigate the Project's minor cumulative contribution to traffic on the
SR-210 and I-10 Freeways under Horizon Year 2030 traffic conditions. Therefore, impacts in this
regard will be significant and unavoidable and a Statement of'Overriding Considerations will be
developed.for the deficient Caltrans facilities. (DEIR pp. 3.15-112 to 3.15-113.)
Mitigation for the cumulative transportation impacts the Project will have on intersections is provided
under Mitigation Measure TRANS 2 above. As previously detailed, the Project is required to pay its fair
share/DIF amount of the improvement costs of the impacted intersections to mitigate the Project's traffic
impacts in both the City and County(See Table 3.15-23 for a summary of transportation impact fee
program improvements for Horizon Year 2030 conditions). Although these intersections may be
improved by time that the various improvements identified are needed to maintain acceptable LOS in
support of the Project,there are many uncertainties related to the timing of the full funding and
completion of such improvements including; payment of DIF fees/fair share payments by other
development in the future, availability of non-DIF funding that may be available to the City in the
future, and, for improvements located in County unincorporated areas, County decisions and funding
availability for completing the necessary improvements. Due to these uncertainties,timely construction
of improvements needed to address cumulative impacts cannot be guaranteed. Therefore, impacts in this
regard will be significant and unavoidable and a Statement of Overriding Considerations will be
developed. (DEIR p. 3.15-113.)
The Project and associated traffic impact reports and evaluations completed a thorough review of all
feasible mitigation measures that would reduce the operational impacts to the greatest extent and would
ensure the traffic impacts operate at appropriate levels of service. Regardless,the impacts would remain
significant and unavoidable due to the inability to ensure the identified improvements are completed in a
timely manner in order to offset the traffic impacts as they may occur in the future. Additional
mitigation measures considered were found to be infeasible or it was determined the mitigation would
not solve this uncertainty in regards to timing. Furthermore, a majority of these impacts will occur
regardless of project implementation. Therefore, while it is anticipated that all future improvements will
be completed and the identified intersections and roadway segments would operate at an appropriate
level of service once the improvements are completed, impacts remain significant and unavoidable.
D. Cumulative Impacts
The Cumulative Impact section of the Findings include all of the listed impact categories associated with
the proposed Project. The discussion includes both discussions of impacts determined to be less than
significant as well as impacts that are only less than significant with mitigation incorporated. There are
no significant and unavoidable impacts for the cumulative impact section.
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For purposes of the proposed Redlands Crossings Project, criteria No. I as discussed within the EIR was
considered to identify the past, present, and reasonably foreseeable actions or projects that could, when
combined with the proposed Project, result in cumulative impacts to the physical environment. Table 4-
1 in the Draft EIR identifies approved and pending projects that are in the Project vicinity that will be
considered in the scope of this cumulative analysis. The cumulative development projects included in
this analysis were provided within the Traffic Impact Analysis conducted for this Project. The
cumulative development projects included in the analysis were provided by City of Redlands staff.
Projects outside of the City of Redlands city limits have also been obtained from the County of San
Bernardino, City of Highland and City of Loma Linda to include the future projects proposed within the
study area, including the"Donut Hole"region. (DEIR p. 4-2.)
1. Aesthetics
The geographic scope of the cumulative aesthetics, light, and glare analysis is the area surrounding the
Project site. This is the area within view of the Project; therefore, the area most likely to experience
changes in visual character or experience light and glare impacts. As shown in Table 4-1, there are
several development projects in the Project vicinity(e.g., Cumulative Numbers 11, 13, 36, etc.)that
have the potential to alter the visual character of the area. These projects would be subject to design and
landscaping requirements to ensure that they do not degrade visual character and comply with applicable
General Plan and Zoning Ordinance standards. (DEIR p. 4-6.)
The design guidelines the City has adopted in its General Plan address various land use classifications
within the City, including commercial development located within the East Valley Corridor Specific
Plan(on which the Project site and area is located). The East Valley Corridor Specific Plan(EVCSP) is
consistent with the land use map and land use element of the General Plan; however,the standards of
development established by the general provisions, community design, overlay districts, and community
facility sections of the EVCSP are covered in the Specific Plan and are not expressly part of the General
Plan. The EVSP address building scale, setbacks, parking, landscaping, signs, and lighting, and are
designed to encompass a large geographic area, and ensures that projects within this area aesthetically
integrate with the character of the adjacent neighborhood. The EVSP's design guidelines therefore
contemplate an evaluation of how the Project would integrate with existing and future development that
would occur over a broad area. At the same time, the purpose of the City's zoning ordinances is to
protect the character of all areas of the City and encourage the orderly and beneficial development of the
City. This includes ensuring that projects are compatible with the aesthetic quality and character of the
adjacent neighborhood. Therefore, the governing land use regulations would ensure that the proposed
Project, in conjunction with other planned or approved projects,would not have cumulatively
considerable aesthetic impacts. (DEIR p. 4-6.)
The proposed Project has the potential to introduce new sources of light and glare,but mitigation is
proposed requiring that fixtures be shielded, recessed, or directed downward to prevent spillage onto
neighboring properties. Consequently, the amount of light spillage onto neighboring roads would be
extremely insignificant,and the existing streetlights are brighter than the light halos of Project and thus
would render any contribution to be indiscernible. To some extent, other City requirements, such as
those pertaining to landscaping, would further reduce impacts. As such, given the small amount of
spillover and intervening landscaping, the proposed Project would not have the potential to have a
cumulative contribution to a light and glare impact. (DEIR p. 4-6.)
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2. Agricultural Resources
The"universe" for agricultural resource impacts is the current agricultural land uses within the City of
Redlands. Projects within Table 4-1 are included in the"universe." The proposed Project has not been
used for agricultural operations in the recent past(i.e., at least eight years), however, it may have been
used for some type of agriculture before that time. According to state resource maps, the site contains
Prime Farmland and Farmland of Statewide Importance. However, due to the significant duration of
absence of agricultural production(i.e. over eight years) at the Project site, impacts to Prime Farmland
and Farmland of Statewide importance are considered less than significant. (DEIR p. 4-7.)
In addition, the City of Redlands General Plan proposes to preserve approximately 500 acres of citrus in
agricultural lands of Prime Agricultural Land, Unique Agricultural Land, and Agricultural Lands of
Statewide Importance. The Project site is not designated within the City of Redlands General Plan as an
area preserved for agricultural lands. Consequently, development of the Project site will be not
cumulatively considerable impacts on agriculture. (DEIR p. 4-7.)
3. Air Quality
The"universe"for this issue is the South Coast Air Basin, as that is the area in which air pollutants
circulate and are at times trapped. Cumulative Air Quality Impacts are addressed in Section 3.3 of this
EIR, specifically under Impact AIR-3. Analysis in this section of the EIR determined the Project would
result in a cumulatively significant impact during operation because of the exceedances of the South
Coast Air Quality Management District(SCAQMD's)regional emission thresholds for VOC, NOx,
PM10, and CO. During construction,before mitigation, emissions of VOC and NOx would exceed the
regional significance thresholds. (DEIR p. 4-7.)
Regarding toxic air contaminants, the health risk assessment summarized in Impact AIR-4 in Section 3.3
of the EIR indicates that the incremental increase in cancer risk at the nearby sensitive receptors(0.8 in
one million)is below the SCAQMD's cancer threshold of 10 in one million. The SCAQMD does not
have a cumulative risk threshold. As discussed in the Air Quality and Greenhouse Gas Analysis Report,
the South Coast Air Basin has many sources of toxic air contaminants, which results in an overall cancer
risk over 10 in one million throughout the Basin. The Project's minor increase in cancer risk at the
sensitive receptors would not result in a significant cumulative risk because the emissions are minor and
because the concentrations would be below the individual cancer risk threshold. (DEIR pp. 4-7 to 4-8.)
See Mitigation measures AQ-I through AQ-12 as discussed under the Air Quality sections of the
Findings. The Project would result in a cumulatively significant impact even after mitigation by
exceedances;of the SCAQMD's regional emission thresholds during operation for VOC,NO,, CO, and
PMIO. This cumulative impact could result in cumulative health effects from exposure to ozone, PM10,
and PM2.5. Mitigation measures would reduce impacts during construction to less than significant.
(DEIR p. 4-8.)
4. Biological Resources
The"universe"for this issue is the general Project area, but any potential impacts must be viewed in the
context of available natural areas/habitat, and any planned regional habitat preservation programs such
as the Multi-Species Habitat Conservation Plan(MSHCP) for Western Riverside County.
San Bernardino County has not yet developed a similar type MSHCP for this portion of the County.
The general area contains a number of vacant upland areas to the north and east that contain native
vegetation. In addition,the Santa Ana River is located one mile north of the Project site. The
"universe"area contains significant regional biological resources. Continued development in this
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portion of the City,mainly commercially zoned areas to the north and southeast,may cause cumulative
impacts to local flora and fauna. Impacts may cause an incremental loss of native vegetation and habitat
from encroachment along the Santa Ana River, and by the contribution of additional sediments and other
urban pollutants into the river from local runoff. From impacts, local wildlife will have less resource
areas to use, although much of the land already supports development. In contrast,the Project site and
surrounding area have been largely impacted by industry(i.e. agricultural uses) and human activity, so
their loss does not represent a regional or cumulative impact to plants or wildlife. (DEIR p. 4-8.)
Development projects in the Project vicinity would be contiguous to existing development. Of the
potentially impacted species at the Project site, including the Burrowing Owl, (Athene cunicularia)
(BUOW) and nesting birds, the focused surveys conducted at the Project site did not detect any
occurrences of the species(see Section 3.4, Biological Resources). Note that the Project site was
previously used for agricultural uses,which involved regular disking and tilling of the soil. As such, the
Project site is in a disturbed state, which limits the potential for special-status species to be present on-
site. Still,the other cumulative projects may contain nesting and foraging habitat for the above species,
and so the potential to result in a loss of individual specimens and the loss of species habitat. (DEIR p.
4-8.)
The loss of individual specimens would most likely occur as a result of construction activities. To the
extent there is potential for cumulative project's to result in a loss of individual specimens and the loss
of species habitat,mitigation measures in the form of pre-construction surveys can be proposed to
reduce potential impacts on these species to a less than significant level. Future development projects
would be required to mitigate for impacts on special-status species in a manner similar to the Project.
Given there is only a low to moderate likelihood of encountering the above-listed species, the disturbed
nature of the Project site, and the comprehensive nature of the construction mitigation programs,
cumulative impacts to special-status species would be less than significant. (DEIR pp. 4-8 to 4-9.)
With regard to the loss of habitat,the Project impact was deemed less than significant owing to the fact
that it formerly was used for agricultural production. The Project would not make a cumulatively
considerable contribution to any cumulative impact because of this reason, and because it sits on the
edge of an urbanized area and adjacent to Tennessee Street and SR-210 Freeway, a major thoroughfare
in the City. Thus, given the level of existing development in the area, and the relatively small likelihood
of these species frequenting the vicinity of the Project and the nearby probable future projects, there
would not be a cumulatively significant impact and sits at the edge of an urbanized area. (DEIR p. 4-9.)
5. Cultural Resources
The geographic scope of the cumulative cultural resources analysis is the Project vicinity,which
includes projects located within Table 4-1, above. Cultural resource impacts tend to be localized
because the integrity of any given resource depends on what occurs only in the immediate vicinity
around that resource, such as disruption of soils; therefore, in addition to the Project site itself, the area
near the Project site would be the area most affected by Project activities(i.e., generally within a 500-
foot radius). Construction activities associated with development projects in the Project vicinity may
have the potential to encounter undiscovered cultural resources. These projects would be required to
mitigate for impacts through compliance with applicable federal and state laws governing cultural
resources. Even if a significant cumulative impact could be found, the Project would not make a
cumulatively considerable impact. The Project site was previously used for agricultural uses, which
involved regular disking and tilling of the soil. As such, the Project site is in a disturbed state,which
limits the potential for undiscovered resources to be encountered. (DEIR p. 4-9.)
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'The Phase I Cultural Resource Survey indicated that three known historical cultural resources are
located within the Project site and 15 sites are located within one mile of the Project area boundary.
Thus, Phase 11 testing was carried out for each of the individual sites. Phase 11 testing at the Project site
indicated that none of the sites meets any of the significant criteria established by CEQA Guidelines
Section 15064.5 to be considered"unique historic properties" (MBA 2009b). One new cultural resource
site(P#36-013622)was identified during Phase 11 Survey. However,recordation of the feature
exhausted the data set associated with this historic cultural resources, thereby mitigating for impacts if
the site is altered or destroyed by construction. (DEIR pp. 4-9 to 4-10.)
The Cultural Resource Survey(MBA 2009b) indicated the Project site is located within a moderately
sensitive cultural resource area. Therefore,mitigation measures CR-I a through CR-I c were
recommended to reduce the potential significant cultural resource impact to less than significant level.
Although there is the possibility that previously undiscovered resources could be encountered by
subsurface earthwork activities, the implementation of standard construction mitigation measures would
ensure that undiscovered cultural resources are not adversely affected by project-related construction
activities, which would prevent the destruction or degradation of potentially significant cultural
resources in the Project vicinity. Given the low potential for disruption, and the comprehensiveness of
mitigation measures that would apply to this Project and those in the vicinity, the residual, insignificant
impacts of the projects would not combine to make a significant cumulative impact and, even if the
combine impact was significant owing to substantial resources on a different project site, the Project
would fail to make a cumulatively considerable contribution given previous disruptions to its ground and
the lack of any significant resource within its boundaries. (DEIR p. 4-10.)
6. Geology and Soils
The"universe"for this issue is development in the City of Redlands and western San Bernardino
County, within the larger context of Southern California due to regional seismicity. Development
projects in the Project vicinity may have the potential to be exposed to seismic hazards. However,there
is a less than significant potential of the projects in combination to expose people or structure to
substantial adverse affects,including the risk of loss, injury, or death in the event of a major earthquake,
fault rupture, groundshaking, seismic related ground failure, landslide, or liquefaction. There are no
active or potentially active faults in the Project area and, though the Project site might be exposed to
strong ground shaking during an earthquake from faults that lie further afield, continued construction of
buildings and other structures to current development codes would minimize the potential for severe
damage and loss of life. Seismic design criteria account for peak,ground acceleration, soil profile, and
other site conditions, and they establish corresponding design standards intended primarily to protect
public safety and secondly to minimize property damage. (DEIR p. 4-10.)
Regarding liquefaction and soil stability, the topography of the Project site and the sites of the projects
listed in Table 4-1 is relatively flat. At the same time,there is only a remote possibility that disruption
of soils at one site would increase the risk of liquefaction and soil stability at another site, as soil
stability is largely unaffected by instability at another site, especially in cases where there exist
intervening roads between sites, as is the case for adjacent Tennessee Street and San Bernardino
Avenue. Thus, there is little potential of projects to cumulate in this regard, and so a less-than-
significant cumulative impact would result. (DEIR p. 4-11.)
Regarding soil erosion,groundbreaking that could lead to increased erosion rates on-site soils, which in
turn could cause unstable ground surfaces and increased sedimentation in nearby streams and drainage
channels. However,Project construction activities would implement standard stormwater pollution
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prevention mitigation measures to ensure that earthwork activities do not result in substantial erosion
off-site. This mitigation, in turn, would have to comply with the NPDES stormwater permitting
program, which regulates water quality originating from construction sites. The National Pollutant
Discharge Elimination System(NPDES) program, which governs projects statewide(and nationwide),
requires the preparation and implementation of Stormwater Pollution Prevention Programs for
construction activities that disturb more than one acre, and implement Best Management Practices
(BMP) that ensure the reduction of pollutants during stormwater discharges, as well as compliance with
all applicable water quality requirements. Thus, given the Project and nearby projects would have to
comply with federal and state regulations that are designed to minimize impacts to projects on a wide
geographic scale,this Project would make no cumulatively considerable contribution to any significant
cumulative impact. (DEIR p. 4-11.)
7. Greenhouse Gasses
The universe for this issue is the planet Earth. By its nature, climate change is a global and cumulative
issue, as greenhouse gases combine with other greenhouse gases and this increase is believed to result in
climate change. As discussed in Section 3.17, the Project would emit greenhouse gases during
construction and operation. These emissions are potentially significant without the implementation of
State regulation, Project design features, and mitigation measures. (DEIR p. 4-11.)
See Mitigation Measures GHG-1, AQ-5, AQ-7, AQ-8, AQ-9, AQ-10, AQ-11, HYD-2a, HYD-2b, and
TRANS-6a as discussed under the Air Quality, Greenhouse Gasses, Hydrology, and Transportation
sections.
8. Hazards and Hazardous Materials
The"universe"for this issue is the Project area but within a context of western San Bernardino County,
and the northern portion of the City of Redlands in terms of transport of hazardous materials. As
development of the identified Commercial project occurs, the area will experience an increase in the use
of hazardous materials(i.e. automotive fluids, brake dust, oil, etc.). Growth may also increase the
amount of these hazardous materials in the area, which may be especially destructive to natural
waterways such as the Santa Ana River. However, it is expected that these materials will be handled,
transported, and disposed of properly, according to existing City and State regulations. (DEIR p. 4-12.)
Furthermore, two freeways, the SR-210(approximately 170 feet west) and Interstate 10(1-10) Freeway
(approximately 0.6 mile south), serve the area,both of which can provide routes for evacuation out of
the area in all directions. If the area were to experience a major disaster(e.g., major flood, fire, or
earthquake), evacuation of several thousand residents and employees via the current road system would
probably take several hours, which is marginal even assuming there is adequate warning. Based on
available information, evacuation routes for this area appear to be adequate for planned growth, so the
Project will not create any cumulatively considerable impacts related to hazards. Therefore, no
mitigation is required. (DEIR p. 4-12.)
9. Hydrology and Water Quality
The larger"universe"for this issue is Southern California,which is largely dependent on imported water
to support existing development and planned growth. By comparison, the local universe for these
impacts is the water service areas of the City of Redlands and other providers within the west
San Bernardino County. In terms of construction, implementation of all the projects would require
grading and construction. While potential to degrade water quality exists,the projects would have to
comply with the NPDES stormwater permitting program, which regulates water quality originating from
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for these projects would be required(as would the applicant for the Project) to provide stormwater
quality management plans to the City for review and approval prior to the issuance of building pen-nits
for the Project. Each plan must include the various control measures that will be in effect during Project
operations to ensure that water quality in downstream water bodies is not degraded. Compliance with
the aforementioned federal and State and local requirements will avoid significant adverse cumulative
hydrology and water quality impacts in the Project area. (DEIR p. 4-14.)
10. Land Use and Planning
The potential "universe"for this issue ranges from the local Project area(i.e., the City of Redlands) to
the western portion of San Bernardino County. Development of the area will eventually modify
hundreds of acres of vacant land into additional commercial uses and suburban-type neighborhoods.
The Project has existing residential uses to the east and southeast, with new residential uses being
developed approximately 0.60 miles northeast of the site(Beaver Homes). Additionally,existing
commercial uses (i.e. Citrus Plaza and Homes Depot Center) are to the cast and south of the Project site.
This and other planned development projects will eventually change the fundamental character of the
area. However, the City of Redlands's General Plan has anticipated this type of change. (DEIR p. 4-
14.)
On a broader scale, countywide growth will add tens of thousands of new homes,residents,businesses,
and jobs in the future. This growth is not expected to have cumulatively considerable impacts related to
land use and planning, as long as it occurs according to the City of Redlands General Plan. The Project
site is zoned for commercial uses and is consistent with the General Plan. Due to the size of the Project,
the Project is expected to create substantial contribution to new jobs, and will also help meet at least one
of the City of Redlands General Plan job goals. The Project area already supports a wide variety and
density of land uses,and the implementation of commercial uses is not expected to be cumulatively
considerable in terms of land use impacts. Therefore, implementation of the Project will be consistent
with the City's General Plan and will not make a significant contribution to cumulatively considerable
land use impacts. Furthermore, as long as growth continues according to established plans, no
cumulatively considerable impacts to land use and planning will occur. Because the Project would not
result in a significant impact with respect to mineral resources, it would not contribute to cumulatively
considerable regional impacts to mineral resources. These other impacts have separate regional
mitigation programs that will be presented in each section. (DEIR pp. 4-14 to 4-15.)
11. Mineral Resources
The"universe"for this issue is the general Project area(City of Redlands), but any potential impacts
must be viewed in the context of available mineral resources within San Bernardino County, and the
City of Redlands. As development increase in the City of Redlands, greater demand will be placed on
mineral resources, especially sand and gravel from areas along local drainages, including the Santa Ana
River watershed,north of the Project site. Data from the State indicates the Project site is within an
MRZ-2 classification. As outlined within Section 3.1 (Mineral Resources) although the Project site
contains significant aggregate resources, the Mentone Dam places flood control -within the Project area,
also known as Sector F, and puts a question on the future availability of much of the resource in this
area. The MRZ-2 area designated as"F"is so large that putting the Project site to use as commercial
development will not result in the loss of availability of any resource or access to that resource. In
addition, due to the water table and clay layers of this area, much of the younger sediments are not
economical to mine for sand and gravel. Finally, as identified within Policy 7.42c of the City of
Redlands General Plan,The city will reserve designated MRZ areas outside the Santa Ana Wash for
agricultural or urban use. The Project is located outside of the Santa Ana Wash and will be consistent
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with designated land uses at the Project site(CP-4). Therefore, the City's General Plan designation and
zoning classification do not pen-nit mining activities on the Project site and development of the Project
will not create cumulatively considerable regional impacts to mineral resources. (DEIR p.4-15.)
12. Noise
The"universe" for this issue is the City of Redlands, including the 1-1.0 Freeway corridor. Noise
impacts tend to be localized because ambient noise generally tends to dissipate within 0.25 mile, and
existing noise from roadways tends to have a canceling effect on noise emanating from a project site;
that is,the logarithmic properties of noise and distance usually mean there are no additive effects.
Therefore, the area near the Project site(i.e., generally 0.25 mile) would be the area most affected by
Project activities. (DEIR pp. 4-15 to 4-16.)
Construction activities associated with the Project would result in substantial sources of noise. As
discussed in Section 3.11,Noise, the construction activities for Project would exceed the noise
thresholds for certain receivers. Mitigation is proposed that would require the contractor implement
various sound control measures including limitation of construction hours, using noise attenuation
devices on heavy equipment, and the use of a minimum 10-foot-high construction noise barrier along the
perimeter of the Project site within 300 feet of any residences. Implementation of these mitigation
measures would reduce impacts to a less than significant level. (DEIR p. 4-16.)
The timing of construction activities associated with other development projects would overlap
minimally, if at all,with the Project. Furthermore,because noise is a highly localized phenomenon,
even if construction activities did overlap in time with the Project, the intervening distance and roadway
noise would diminish any additive effects. Construction activities at these other planned and approved
projects would be required to take place during daytime hours, and the City and project applicants would
be required to evaluate construction noise impacts and implement mitigation, if necessary,to minimize
noise impacts. Given these distances and the intervening structures and vegetation,no significant
cumulative construction noise impact would be expected. In addition, as outlined within Section 3.11,
Noise, cumulative noise impacts were analyzed for Year 2030. The results shown below in Section 3.11
shows that for the year 2030 weekday and Saturday conditions,noise level contributions from the
proposed Project onto the nearby roadways would range from 0.0 to 0.7 dBA CNEL. A 0.7 dBA noise
increase would be below the thresholds established within the Section 8.06.070 of the City of Redlands
Municipal Code. Therefore, for the year 2030 weekday and Saturday conditions,it is reasonable to
conclude that construction noise from the Project would not combine with noise from other development
projects to cause cumulatively considerable noise impacts. The average equivalent A-weighted sound
level during a 24-hour day was obtained by adding 10 decibels to the hourly noise levels measured
during the night(from 10 pm to 7 am). In this way, Ldn takes into account the lower tolerance of people
for noise during nighttime periods. (DEIR p. 4-16.)
The Project's construction and operational vibration levels would not exceed annoyance thresholds.
Because vibration propagates in waves through the soil,multiple pieces of equipment operating
simultaneously would each produce vibration waves in different phases that typically would not increase
the magnitude of the vibration. Furthermore, vibration is a highly localized phenomenon, and tends to
dissipate to insignificant levels within dozens of feet, as explained in Section 3.11,Noise; thus, there
would be no possibility for vibration associated with the Project to combine with vibration from other
projects because of their distances from the Project site. Therefore, the Project would not contribute to a
cumulatively considerable vibration impact. (DEIR p. 4-16.)
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development projects are required to pay fees (i.e., Quimby) that typically mitigate any potential impact.
The planned growth in the area will eventually generate hundreds of new residents who will need
additional parkland based on the City's Quimby standard. Parks built within other projects,plus
collection of anticipated in lieu fees, will allow the City to continue providing parkland and
improvements within the surrounding area. As long as future projects continue to provide onsite parks
or in lieu fees, there should be no cumulatively considerable impacts to recreational services. Therefore,
no additional mitigation is required. (DEIR p. 4-18.)
16, Transportation
Opening Year 2013 and Horizon Year 2030 cumulative transportation impacts are addressed in Section
3.15 of this EIR. As outlined within Section 3.15,there are no additional ramp merge and diverge
junctions anticipated to operate at unacceptable levels of service with the addition of Project traffic, with
the exception of the SR-210 Westbound on-ramp at San Bernardino Avenue and the 1-10 Eastbound off-
ramp to the SR-210 Westbound (upstream only). It should be noted that the 1-10 Eastbound off-ramp to
the SR-210 Westbound is a freeway-to-freeway diverge junction and is anticipated to operate at LOS
"F"due to the addition of background growth and cumulative traffic in conjunction with Project traffic.
(DEIR pp. 4-18 to 4-19.)
With respect to the significant impacts to the State facilities (mainline and ramp junctions) at the 2030
time horizon, no further mitigation measures or improvements are recommended. The
I-10 Freeway and SR-210 Freeway would operate at LOS "F" even without the Project under Horizon
Year 2030 traffic conditions. The Project's contribution to cumulative impacts under 2030 conditions is
relatively minor,involving only a small percentage of the forecast traffic occurring on the identified
segments at Horizon Year 2030 traffic conditions. Because the City has no control over State facilities,
and because the State facilities funded and planned to be developed under 2030 conditions are already
anticipated to operate at LOS "E" and "F"even without the Project,there are no further mitigation
measures that can be imposed upon the Project to mitigate its small cumulative contribution to
significant impacts to the identified segments of SR-210 Freeway and 1-10 Freeway under 2030
conditions. Caltrans has exclusive control over State highway improvements and State highway
improvements are a matter of Statewide control. Thus, for the aforementioned reasons there are no
available and feasible mitigation measures available to mitigate the Project's minor cumulative
contribution to traffic on the SR-210 and I-10 Freeways under Horizon Year 2030 traffic conditions.
Therefore, impacts in this regard will be significant and unavoidable and a Statement of Overriding
Considi,,rations will be developed.for the deficient Caltrans facilities. (DEIR p. 4-19.)
Moreover, mitigation for the cumulative transportation impacts the Project will have on intersections is
provided under Mitigation Measure MM TRANS 2. As previously discussed,the Project is required to
pay its fair share/DIF amount of the improvement costs of the impacted intersections to mitigate the
Project's traffic impacts in both the City and County. Although these intersections may be improved by
time that the various improvements identified are need to maintain acceptable LOS in support of the
Project, there are many uncertainties related to the timing of the full funding and completion of such
improvements including; payment of DIF fees/fair share payments by other development in the future,
availability of non-DIF funding that may be available to the City in the future, and, for improvements
located in County unincorporated areas, County decisions and funding availability for completing the
necessary improvements. Due to these uncertainties,timely construction of improvements needed to
address cumulative impacts cannot be guaranteed. Therefore, impacts in this regard will be
cumulatively significant and unavoidable and a Statement of Overriding Considerations will be
developed. (DEIR p.4-19.)
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17. Utilities
The geographic scope of the cumulative potable water analysis is the City of Redlands water service
area, which encompasses the City limits. (DEIR p. 4-20.)
The City has four main supply sources. The potable wells can produce about 34 million gallons per day
(mgd) of supply. In addition,The City has numerous options for obtaining new potable water sources or
managing demand. The potential options include(1) increased use of existing surface water sources
through purchase of additional water rights; (2) increased production of water from the groundwater
basin through well rehabilitation, contaminated flow treatment, or new well construction; (3)increased
conservation practices;(4)continued expansion of its reclaimed water system; or(5)purchase of
additional water from the State Water Project(SWP). The Water Supply Analysis within Section 3.16
concluded that the City of Redlands Utilities and Engineering Department has sufficient water supply to
serve the Project between 2010 and 2030 in addition to all customers within the City of Redlands.
(DEIR p. 4-20.)
The Project is estimated to demand 14,817 gallons per day of potable water. Nonetheless,because long-
term water supply is a significant concern in California, the Project would reduce its demand on water
supply through the implementation of indoor and outdoor water conservation measures. An additional
mitigation measure requires the applicant to plumb landscaped areas with"purple pipe"to allow for
recycled water irrigation when this service becomes available. These measures would reduce overall
Project demand for potable water and ensure that long-term water supply impacts are less than
significant. All future projects also would be required to demonstrate that potable water supply sources
are available, and these projects may be required to implement water conservation measures. Finally,
the Urban Water Management Plan prepared for the City of Redlands (2005) concludes that sufficient
supplies are available to serve growth contemplated by the General Plan, which accounts for a majority
of the projects listed in Table 4-1. Therefore, the Project, in conjunction with other planned and
approved projects,would not have a cumulatively considerable impact on potable water supply. (DEIR
p. 4-20.)
The geographic scope of the cumulative wastewater analysis is the City of Redlands Wastewater
Treatment Plant service area, which collects wastewater from Redlands. Those projects listed in Table
4-1 that lie in the City of Redlands have the potential to combine with the Project to exert cumulative
impacts. (DEIR pp.4-20 to 4-21.)
All future projects would be required to demonstrate that sewer service is available to ensure that
adequate sanitation can be provided. The estimated wastewater generation of the Project is 4,910
gallons of wastewater on a daily basis. The existing wastewater flows for the City's Water Reclamation
Plant(WRP) are between 6 and 6.5 mgd. The overall capacity of the WRF is 9.5 mgd. Consequently,
implementation of the Project will increase wastewater generation by approximately 0.001 percent over
the existing 6.5 mgd,which is well below the 9.5 mgd overall capacity of the WRF. Based on current
growth projections that include buildout of the Projects in Table 4.1, the WRP will have adequate
capacity for the City(including the Project). Therefore,the Project, in conjunction with other planned
and approved projects,would not have a cumulatively considerable impact on wastewater. (DEIR p. 4-
21.)
The geographic scope of the cumulative storm drainage analysis is the City of Redlands' storm drainage
system, which generally encompasses lands within the city limits. (DEIR p. 4-21.) All future
development projects in the Project vicinity would be required to provide drainage facilities that collect
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and detain runoff such that off-site releases are controlled and do not create flooding. The Project would
be served by on-site drainage facilities that impound runoff and ensure that it is released at a rate no
greater than the pre-development condition at the site. As such, the Project would ensure that no net
increase in stormwater would leave the Project site and would avoid cumulatively considerable
contribution of stormwater to downstream waterways. During construction, the Project would
implement standard pollution prevention measures to ensure that downstream water quality impacts are
minimized to the greatest extent possible. In addition, the Project would provide water quality measures
to prevent pollution during store operations. Therefore, the Project, in conjunction with other planned
and approved projects, would not have a cumulatively considerable impact on storm drainage. (DEIR p.
4-21.)
The geographic scope of the cumulative solid waste analysis comprises those projects contributing to the
California Street Landfill and the San Timoteo Sanitary Landfill. (DEIR p. 4-21.) The CaliforniaStreet
Landfill and San Timoteo, Sanitary Landfill have a combined remaining capacity of more than 16
million cubic yards. Future development projects would generate construction and operational solid
waste and, depending on the volumes and end uses, would be required to implement recycling and waste
reduction measures. The Project is anticipated to generate 1,068 tons of solid waste annually during
operations. Consequently, the potential impact associated with the solid waste generated from the
Project is less than significant in comparison to the total remaining capacity of landfill sites. (DEIR p.
4-21.)
In addition, actual solid waste generation would be expected to be less than 661 tons per annum, as
Walmart stores are generally equipped with recycling facilities and are designed to limit waste of
recyclable material by implementing innovative strategies. (DEIR p. 4-22.)
Walmart stores are equipped to recycle the following materials:
• Aluminum;
• Plastic(including bottles,bags, garment bags, shrink wrap, and bubble pack);
• Glass;
• Cardboard;
• Vegetable oil;
• Single-use cameras;
• Electronic waste; and
• Silver(from photo processing).
In addition, actual solid waste generation would be expected to be less than 661 tons per annum as
Walmart stores are equipped with recycling facilities and are designed to limit waste of recyclable
material by implementing innovative strategies. (DEIR p. 4-22.)
Walmart stores are equipped to recycle the following materials:
• Aluminum;
• Plastic(including bottles,bags, garment bags, shrink wrap, and bubble pack);
• Glass;
• Cardboard;
• Vegetable oil;
0 Single-use cameras;
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• Electronic waste; and
• Silver(from photo processing).
(DEIR p. 4-22.)
Similarly, followings are some of the innovative strategies implemented to limit waste as standard
features:
• All cardboard generated from delivery packages is segregated and sent to a recycling center.
• Each new store has an indoor tank used to collect oil from cooking processes for recycling.
• All Walmart photo-processing centers recycle single-use cameras after photo processing.
• Walmart collects and segregates all recyclable bottles and cans.
• Walmart currently implements a chain wide program for"sandwich bale"recycling of plastics,
e.g.,bags, garment bags, shrink wrap,bubble pack, etc.
• Walmart photo labs capture silver from the photo processing.
(DEIR p. 4-22.)
Therefore, as discussed above the landfill sites serving the Project has sufficient permitted capacity to
accommodate the Project's solid waste disposal need and accordingly, the Project, in conjunction with
other future projects,would not have a cumulatively considerable impact on solid waste. (DEIR p. 4-
23.)
18. Urban Decay
Cumulative Urban Decay impacts are addressed in Section 3.18 of this EIR. Analysis in this section of
the EIR determined that cumulative Urban Decay impacts would be less than significant. (DEIR p. 4-
23.)
E. Project Alternatives
Section 6.1.2 of the Draft EIR analyzed the following four alternatives to the Project as proposed, and
evaluated these alternatives for their ability to meet the Project's goals and objectives. CEQA requires
the EIR include in its evaluation a No Project Alternative. Additionally, CEQA requires an EIR to
describe a range of reasonable alternatives to the Project, which would feasibly attain the basic Project
objectives,but would avoid or substantially lessen any of the significant environmental effects of the
proposal. Thus, in order to develop a range of reasonable alternatives, the Project objectives must be
considered when the City evaluates the alternatives.
Alternatives sites were considered and rejected as either infeasible or having similar potentially
significant impacts. Examples of such available sites would include the vacated former Mervyn's
building, which did provide sufficient space to accommodate the proposed development, an available
site within the City of Loma Linda along Redlands Boulevard, and across the 1-214 freeway in the
"donut hole" area. While the Donut hole site could accommodate the proposed development, the project
impacts would remain nearly identical given the roadway limitations and proximity to the current
proposed site. The potential site in the City of Loma Linda would result in similar air quality impacts
and have potentially greater impacts with regard to traffic. Furthermore, the City of Redlands would not
benefit or receive the potential tax revenue for out-of-jurisdiction sites.
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1. No Project Alternative
Under the No Project Alternative, the Project site would remain in its existing condition and no
development would occur. The Project site would remain in its existing condition and no changes
would occur. Currently, the Project site is undeveloped. If developed, the likely alternative is that the
site would be built out as another type of commercial center that is consistent with current General Plan
and zoning designations; the scenarios that are evaluated under Alternatives 2, 3 and 4 are representative
of this buildout. (DEIR p. 6-4.)
Finding: The No Project Alternative would avoid all of the Project's significant unavoidable impacts
and have less impact on all environmental topical areas. However, this alternative would not advance
any of the project objectives. Furthermore, this alternative would not realize the project benefits of
increased retail opportunities, additional employment opportunities, and new tax revenues.
Accordingly, this alternative is rejected by the City as infeasible. (DEIR p. 6-5.)
2. Ten Percent Reduction Alternative
The 10-Percent Reduction Alternative would reduce the proposed Redlands Crossing Center total square
footage from 275,500 square feet to 247,950 square feet for the Project. This alternative would
represent a net reduction of 2'1,550 square feet, or approximately 10 percent relative to the Project.
Table 6-1 in the Draft EIR provides a summary of the 10-Percent Reduction Alternative. Under this
alternative each building footprint would be reduced by approximately 10%, including each of the
outparcels and the major tenant(Walmart). (DEIR p. 6-5.)
Finding: The 10-Percent Reduced Density Alternative would result in the same significant unavoidable
impacts as those of the Project(i.e., cumulative Air Quality and cumulative Freeway ramp and mainline
traffic impacts). However,the severity of the significant unavoidable traffic impacts would be less,
because fewer daily and peak-hour trips would be generated. In addition, the severity of impacts
associated with air quality,noise, hydrology,public services and utilities, transportation, and urban
decay would be less. Otherwise, this alternative would have impacts similar to the Project. (DEIR p. 6-
14.)
This alternative would not achieve most of the basic Project objectives, or would not achieve them to the
same degree, as the Project. Sales revenue is dependent on many factors, including the type of retail
store and the density of the retail goods presented to the public. Nonetheless, a general rule for retail
sales is that a reduction in the square footage of retail establishments for a store that can support the
identified gross floor area will have a proportional reduction in overall retail sales. A reduction in 10%
of the floor area typically translates to fewer goods easily presented to the retail customers,translating
into a store that is less attractive to retail users. Therefore, as a general rule, a 10%reduction in the size
of the retail development would mean the store would not generate as much sales, thereby resulting in
less positive contribution to the local economy, generating less tax revenue. The reduction in sales and
tax revenues would prevent achievement of Objective 1, as such revenues would not be maximized. It
would not fully achieve Objective 2 as the reduction in square footage of sales area represented by this
alternative would likely result in a narrowing of the range of goods and set-vices that would be provided
to the currently underserved community as compared to the Project. Likewise, this alternative would
not fully meet Objective 4 since the range of goods and services would be narrowed as compared to the
Project. Also, since the building area is reduced by 10%under this alternative Objective 8 is not met
because the full development potential of the site is limited as compared to the Project. (DEIR p. 6-14.)
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In addition, a 10%reduction in the size of the outparcels would impact the overall marketability of the
Project. The outparcel retail pads have been designed and sized so as to attract compatible uses to the
shopping center, including smaller retailers, banks, fast food and sit down restaurants, and other such
uses. Most retailers have a particular size of parcel that is required in order to meet their operational
needs. The determination of size requirements has been determined through numerous developments in
similar shopping centers throughout the State. Therefore, a farther reduction in the already small pad
sizes for these uses decreases their marketability to potential businesses and reduces the ability to attract
stable tenants. (DEIR p. 6-14.) In fact, a 10%reduction on the outparcels creates a greater impact on the
viability of such retail operations, as opposed to a larger store with greater flexibility, due to the specific
nature of the retailers that would be interested in such outparcels.
Also, although it will lessen the magnitude of cumulative air quality and freeway traffic impacts, these
impacts would remain significant, adverse and unavoidable under this alternative. Therefore, for the
above discussed reasons, this alternative is rejected by the City as infeasible. (DEIR p. 6-14.)
3. Walmart Standalone Alternative
The Walmart Standalone Alternative would eliminate the proposed commercial and retail buildings in
the Redlands Crossing Center, except for the Walmart. The Standalone Walmart would operate 24
hours per day. The total square footage would be reduced from 275,500 square feet to 215,000 square
feet. The Walmart Standalone Alternative would represent a net reduction of 60,500 square feet, or
approximately 22 percent relative to the Project. Table 6-3 in the Draft EIR provides a summary of the
Walmart Standalone Alternative. (DEIR p. 6-14.)
Finding: The Walmart Standalone Alternative would result in the same significant unavoidable impacts
as the Project. However, the severity of traffic impacts would be less because fewer daily and peak hour
trips would be generated. In addition, the severity of impacts associated with aesthetics, air quality,
hydrology and water quality, noise, public services and utilities, and transportation would be lessened
relative to the Project. (DEIR p. 6-23.)
The Walmart Standalone Alternative would not meet most of the basic Project objectives,or would not
further them to the same degree as the Project. In general, the elimination of the outlots would result in
fewer sales, thereby resulting in less positive contribution to the local economy, and generating less tax
revenue for local agencies. DEIR p. 6-23.)
The reduction in sales and tax revenues would prevent achievement of Objective 1, as such revenues
would not be maximized. This alternative also fails to meet Objective 3 since the mix of complementary
uses is limited because the Project site would only be occupied by the Walmart Store. Likewise, this
alternative would not fully meet Objective 4 since the range of goods and services would be narrowed as
compared to the Project. Objective 5 is not met because the nationally recognized anchor(Walmart)
would not attract other businesses to the Project. Objective 7 is compromised as a major new center
would not be developed--only the Walmart store. Since the building area is reduced by approximately
22%under this alternative, Objective 8 is not met because the full development potential of the site is
limited as compared to the Project. (DEIR p. 6-23.)
Further, use of the Project site for a stand-alone Walmart would be contrary to Implementing Policy
11.01 of the Economic Development Element of the City's General Plan which encourages the location
of commercial centers according to function and scale of the particular development so that centers of
different scales complement one another and each is accessible to the primary market it is designed to
serve.
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In addition, although it will lessen the magnitude of cumulative air quality and freeway traffic impacts,
these impacts would remain significant, adverse and unavoidable under this alternative. (DEIR p. 6-24.)
Therefore, for the above discussed reasons, this alternative is rejected by the City as infeasible.
4. No Walmart/Medium Size Tenant Alternative
Under this alternative total building area would be the same as the Project and the uses for the parcels
other than the Walmart Parcel would also be the same. This alternative would differ from the Project, in
that it would not include a"big box," general merchandise anchor,but would include medium- sized,
individual tenants with retail space generally in the 15,000 square feet to 50,000 square feet range. This
alternative also includes the other types of retail uses than the proposed Walmart would have(grocery
store, tire/auto and nursery), except under this alternative they would be independent, freestanding
tenants. Unlike big box discount/general merchandise stores such as Walmart, Target, Costco or K-
Mart,medium sized stores tend to concentrate on certain type of product types such as clothing,books
and music, electronics,office supplies/equipment, etc. Consequently, shopper visits to these types of
establishments tend to be more limited-purpose in nature than a visit to a general merchandise business
(such as Walmart)where a shopper may purchase many types of goods. Table 6-5 in the Draft EIR
shows uses that were assumed to replace the 215,000 square foot floor area occupied by the Walmart
store for the Project and are typical types of commercial uses for shopping centers. Table 6-5 also
shows the aggregate figures for the freestanding uses, comprising 60,500 square feet,which would
remain the same for both the Project and this alternative. (DEIR p. 6-24.)
The total weekday average daily trips (ADT) for the Project at 19,481 ADT would be slightly higher
than the estimated 19,106 ADT resulting from this alternative. However, that ADT would vary
substantially depending on what specific commercial use is assumed to be in the mix. For example, if
this alternative is reduced in area to 240,500 (by 35,000 square feet) and, instead of 70,000 square feet
devoted to two clothing apparel stores a single 35,000 book/media store(ITE Code 868)is included
(such as a Barnes and Noble) the weekday ADT for the alternative would be 2,1074 ADT,despite the
35,000 square feet reduction in floor area. (DEIR p. 6-24.)
Finding: The alternative would result in the same significant unavoidable impacts as those of the
Project (i.e. cumulative Air Quality and Freeway ramp and mainline traffic impacts). However, the
severity of these significant unavoidable traffic and air quality impacts would be slightly less since this
alternative would create somewhat less (375) average daily trips than the Project which will, in turn,
result in slightly less traffic and emissions. Likewise, under this alternative cumulative impacts to Air
Quality and Freeway facilities would be slightly less but still remain significant adverse and
unavoidable. Otherwise, this alternative would have impacts similar to the Project. (DEIR pp. 6-31 to
6-32.)
This alternative does not meet most of the Project Objectives, including Objective 2 in that it does not
provide for the wide range of uses that is typical of"big box"general merchandise discount stores, nor
does it provide for the convenience of providing these goods and services within a single store. Since
the types of uses that would occupy the Project site is more limited, Objective 3 would not be fully
achieved due to the narrow, focused nature of the uses, -which are also not likely to be as complementary
to one another as compared to the Project., The potential for"one-stop shopping"is limited which also
hinders achievement of Objective 3. Objective 4 is not met by this alternative because the range of
goods and services provided would be limited, and few if any of the stores identified under this
alternative would be open 24 hours, thus hindering convenience. Since a nationally recognized, general
merchandise anchor is not included for this alternative Objective 5 would not be met. (DEIR p. 6-32.)
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Further,this alternative is inconsistent with the City's development and planning preferences as
reflected in the City's June 8, 2010 defeat of Measure 0(Yes 44.96%, No 55.04%,), a measure which
would have prohibited retail establishments such as the proposed Project.
Therefore, for the above discussed reasons, this alternative is rejected by the City as infeasible.
5. Environmentally Superior Alternative
State CEQA Guidelines Section 15126(e)(2)requires an EIR to identify an "environmentally superior
alternative." If the no project alternative is the environmentally superior alternative,the EIR must also
identify an environmentally superior alternative from among the other alternatives. The no project
alternative is environmentally superior because it avoids significant and adverse impacts to regional air
quality and traffic impacts. (DEIR p. 6-33.)
The Walmart Standalone Alternative would be the most environmentally superior among the other three
alternatives. Among the three alternatives, it would result in the greatest reductions in terms of traffic,
noise, air quality and climate change,utilities and public services. However, it does not meet most of
the basic Project objectives. Table 6-6 in the Draft EIR summarizes the impacts of the Project compared
to the four alternatives discussed in this section. Table 6-7 of the Draft EIR summarizes the ability of
the alternatives to meet the basic Project objectives. (DEIR p. 6-33.)
F. Significant Irreversible Environmental Changes
The environmental,effects associated with the development of the Project are summarized in Table ES-1
and in Section 4,Project and Cumulative Impacts, of this document. Implementation of the Project will
require a long-term commitment of land as discussed below. More specifically,if the Project is
approved, and subsequently implemented,new structures would be built, additional utilities would be
constructed, and circulation improvements would be made. Nonrenewable resources would be
committed, primarily in the form of fossil fuels, and would include fuel oil, natural gas, and gasoline
used by vehicles and equipment associated with the construction of the Project. The consumption of
other nonrenewable or slowly renewable resources would result from development of the Project. These
resources would include,but not be limited to, lumber and other forest products, sand and gravel,
asphalt,petrochemical construction,materials, steel, copper, lead, and water. Because alternative energy
sources such as solar or wind energy are not currently in widespread local use, it is unlikely that a real
savings in nonrenewable energy supplies (i.e., oil and gas) could be realized in the immediate future.
(DEIR p. 5-3)
VI. STATEMENT O►F OVERRIDING CONSIDERATIONS
The City of Redlands as the Lead Agency hereby declares that, pursuant to State CEQA Guidelines
Section 15093,the City has balanced the benefits of the proposed Project against any significant and
unavoidable environmental impacts in determining whether to approve the proposed Project. If the
benefits of the proposed Project outweigh the unavoidable adverse environmental impacts, those impacts
are considered"acceptable."
The City hereby declares that the EIR has identified and discussed significant effects that may occur as a
result of the Project. With the implementation of the mitigation measures discussed in the EIR, these
impacts can be mitigated to a level of less than significant except for the unavoidable and significant
impacts discussed in the findings herein.
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The City hereby declares that it has made a reasonable and good faith effort to eliminate or substantially
mitigate the potential impacts resulting from the Project.
The City hereby declares that to the extent any mitigation measures recommended to the City are not
incorporated, such mitigation measures are infeasible because they would impose restrictions on the
Project that would prohibit the realization of specific economic, social, and other benefits that this City
finds outweigh the unmitigated impacts.
The City further finds that except for the Project, all other alternatives set forth in the EIR are infeasible
because they would prohibit the realization of the Project objectives and/or specific economic, social or
other benefits that the City finds outweigh any envirom-nental benefits of the alternatives.
The City hereby declares that, having reduced the adverse significant environmental effects of the
Project, to the extent feasible by adopting the proposed mitigation measures,having considered the
entire administrative record on the Project and having weighed the benefits of the Project against its
unavoidable significant impact after mitigation, the City has determined that the social, economic and
environmental benefits of the Project outweigh the potential unavoidable significant impacts and render
those potential significant impacts acceptable based upon the following considerations, each of which
the City declares to be independently sufficient to outweigh the potential significant and unavoidable
impacts of the Project:
• Maximize retail commercial property and sales tax revenues that would be accrued to the various
agencies within the City of Redlands from the development of the Project site. The Project as
proposed will develop approximately 275,500 square feet of commercial retail space in an
existing vacant lot within the City of Redlands. This includes the Redlands Crossing Walmart
consisting of approximately 215,000 square feet of full service retail goods,open 24-hours per
day, seven days a week.
• Facilitate customer convenience by providing a full range of goods and services(including
grocery, gardening, dry goods, automotive, and other uses) within a single store. As discussed
within the Draft EIR, the entire shopping center will include the Redlands Crossing Walmart
which sells both groceries and general retail merchandise. The store will also offer a Tire &
Lube Express,pharmacy, banking center, food service, a photo center, garden center, and
similar services. The Walmart will be open 24-hours per day, seven days a week.
• Develop the Project site with a high-quality mix of retail, grocery, restaurant and commercial
uses that will complement each other and encourage one stop shopping thereby reducing
vehicle miles traveled and vehicle trips in the community. As discussed above, the Walmart
will include a variety of one-stop shopping services at the one store. Additionally, the
outparcels on lots I through 9 will contain complementary retail and commercial
establishments including drive-through food service restaurants and a gas station.
• Provide convenient and affordable shopping opportunities to the residents of the City of
Redlands and surrounding areas for a wide range of retail goods and services, including the
provision of such goods and services on a 24-hour basis.
• Provide the Redlands Crossing Center with a nationally recognized general-merchandise anchor
to attract consumers and other businesses to the Project. Walmart is one of the largest retail
companies in the world, with a strong and loyal customer base that will ensure the center
remains a vibrant shopping center for the City of Redlands.
• Provide an additional grocery outlet in the North Redlands Community to minimize travel, as
well as provide convenient shopping opportunities for City residents. The Redlands Crossing
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Walmart, in addition to general retail merchandise, will include the sale of groceries to the
surround community on a 24-hour, seven days per week,basis providing the surrounding
community with enhance grocery options.
• Develop a new major retail and commercial center along Major Arterial streets and in close
proximity to the 210 Freeway/San Bernardino Avenue Interchange in order to facilitate
regional public access and promote the Project as a regional shopping destination. The
Redlands Crossing Center will be located on vacant land adjacent to the 210 Freeway and in
close proximity to the Interstate 10 located to the south of the Project site. Additionally, the
site is bordered by the existing Tennessee Street and San Bernardino Avenue,providing
excellent access to and from the 210 Freeway.
• Develop the vacant unused parcels comprising the Project site for retail-commercial uses in a
manner that fully utilizes their development potential.
• Provide off-site improvements within the Project area, including storm drain facility
improvements related to the construction of New York Street, a block wall immediately to the
West of Karon Street and mass-grading to "match"grade elevations between Karon Street and
future New York Street.
• Promote and implement the following policies of the Land Use Element of the City's General
Plan:
• Guiding Policy: East Valley Corridor—4.62g Promote high quality development in the
East Valley Corridor by protecting and enhancing existing amenities in the area, creating
an identifiable community character, and adopting development standards and guidelines
to ensure aesthetically pleasing design and maximum land use compatibility.
a Implementing Policy:East Valley Corridor—4.621 Maximize generation of employment
opportunities in a region, which has a significant imbalance of housing versus
employment opportunities. (See DEIR Table 3.91-1 at p. 3.9-11.)
• Implementing Policy:East Valley Corridor—4.62m Facilitate location in the project area
of a wide range of commercial uses to serve the region, local industry, and residential
neighborhoods. (See DEIR Table 3.91-1 at p. 3.9-11.)
• Promote and Implement the following policies of the Economic Development Element of the
City's General Plan:
Guiding Policy 11.0a Promote a climate conducive to economic growth and rejuvenation
to enhance employment and investment opportunities without sacrificing environmental
standards.
* Implementing Policy 11.Oe Attract business and industry by providing a wide range of
urban amenities and services throughout the City.
* Implementing Policy IL 01 Encourage the location of commercial centers according to
function and scale of the particular development so that centers of different scales
complement one another and each is accessible to the primary market it is designed to
serve.
• Promote and Implement the following policies of the East Valley Corridor Specific Plan(see
DEIR Table 3.9-2 at p. 3.9-12):
* Goal EV2.0205(a) Develop the East Valley Corridor Specific Plan so as to promote and
facilitate high-quality commercial and industrial development within the corridor area.
* Policy EV2.0205(q)(1) Maximize generation of employment opportunities in a region,
which has a significant imbalance of housing versus employment opportunities.
* Policy EV2.0205(a)(2) Facilitate location in the project area of a wide range of
commercial uses to serve the region, local industry and residential neighborhoods.
(See Project Objectives, DEIR p. 2-26.)
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The City's findings set forth in the preceding sections identified all of the adverse environmental
impacts and feasible mitigation measures which can reduce impacts to less than significant levels where
feasible, or to the lowest feasible levels where significant impacts remain. The findings have also
analyzed three alternatives to determine whether there are reasonable or feasible alternatives to the
proposed action,or whether they might reduce or eliminate the significant adverse impacts of the
Project. The EIR presents evidence that implementing the development of the Project will cause
significant adverse impacts,which cannot be substantially mitigated to non-significant levels. These
significant impacts have been outlined above and the City makes the following finding:
Finding: Having considered the unavoidable adverse impacts of the Project, the City hereby determines
that all feasible mitigation has been adopted to reduce or avoid the potentially significant impacts
identified in the EIR, and that no additional feasible mitigation is available to further reduce significant
impacts. Further,the City finds that economic, social and other considerations of the Project outweigh
the unavoidable adverse impacts described above. The reason for accepting these remaining
unmitigated impacts are described below. In making this finding, the City has balanced the benefits of
the Project against its unavoidable environmental impacts and has indicated its willingness to accept
those effects. The City further finds that the Project's benefits are substantial and override each
unavoidable impact of the Project as follows:
I. Findings Related to Air Quality
Operational and Cumulative Exeeedance of the SCAQMD's Regional Emission Thresholds:
Operation of the Project would violate SCAQMD's regional emission thresholds for VOC,NO,, CO,
and PM10 and result in a significant impact on a regional and cumulative level even after mitigation.
The Project may result in cumulative health effects from cumulative exposures from ozone,nitrogen
dioxide, and PM10.While the provided Air Quality Mitigation Measures would reduce the emissions
impacts, the impacts would remain significant and unavoidable. However, benefits obtained from the
Project are sufficient to justify approval of the Project. These impacts are overridden by Project benefits
described above in the findings.
2. Findings Related to Traffic Impacts
Horizon Year 2030 Traffic Conditions: Freeway Ramp and Mainline Improvements would remain
significant and unavoidable. There are no additional ramp merge and diverge junctions anticipated to
operate at unacceptable levels of service with the addition of Project traffic, with the exception of the
SR-210 Westbound on-ramp at San Bernardino Avenue and the I-10 Eastbound off-ramp to the SR-210
Westbound(upstream only). With respect to the significant impacts to the State facilities(mainline and
ramp junctions)at the 2030 time horizon, no further mitigation measures or improvements are feasible.
The I-10 Freeway and SR-210 Freeway would operate at LOS "I"'even without the Project under
Horizon Year 2030 traffic conditions. Because the City has no control over State facilities, and because
the State facilities funded and planned to be developed under 2030 conditions are already anticipated to
operate at LOS"E"and"F" even without the Project, there are no further mitigation measures that can
be imposed upon the Project to mitigate its small cumulative contribution to significant impacts to the
identified segments of SR-2110 Freeway and 1-10 Freeway under 2030 conditions. Caltrans has
exclusive control over State highway improvements and State highway improvements are by and large a
matter of Statewide control. As such,while the Project will contribute all required fees related to the
Project's proportional impacts, any improvements are within the sole responsibility and jurisdiction of
Caltrans. Thus, for the aforementioned reasons there are no available and feasible mitigation measures
available to mitigate the Project's minor cumulative contribution to traffic on the SR-210 and I-10
Freeways under Horizon Year 2030 traffic conditions.
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Related to the Final Environmental Impact Report
Mitigation for the cumulative transportation impacts the Project will have on intersections is provided
under Mitigation Measure TRANS 2. As such, the Project is required to pay its fair share/DIF amount
of the improvement costs of the impacted intersections to mitigate the Project's traffic impacts within
the City of Redlands and the County of San Bernardino.
Although these intersections may be improved, there are many uncertainties related to the timing of the
full funding and completion of such improvements identified to maintain acceptable LOS in support of
the Project. Due to these uncertainties, timely construction of improvements needed to address
cumulative impacts cannot be guaranteed. Therefore, impacts in this regard will be significant and
unavoidable.
However,benefits obtained from the Project are sufficient to justify approval of the Project. These
impacts are overridden by Project benefits described above in the findings.
California Public Resources Code section 21002 provides: "In the event specific economic, social and
other conditions make infeasible such Project alternatives or such mitigation measures, individual
projects can be approved in spite of one or more significant effects thereof." Section 21002.1(c)
provides: "In the event that economic, social, or other conditions make it infeasible to mitigate one or
more significant effects of a project on the environment,the project may nonetheless be approved or
carried out at the discretion of a public agency..." Finally, California Code of Regulations,Title 4,
15093 (a) states: "If the benefits of a proposed project outweigh the unavoidable adverse environmental
effects, the adverse environmental effects may be considered 'acceptable."'
The City hereby declares that the foregoing benefits provided to the public through approval and
implementation of the Project outweighs the identified significant adverse environmental impacts of the
Project that cannot be mitigated. The City finds that each of the Project benefits outweighs the
unavoidable adverse environmental impacts identified in the Draft EIR and, therefore, finds those
impacts to be acceptable.
VII. CERTIFICATION OF EIR
The City of Redlands finds that it has reviewed and considered the Final EIR evaluating the proposed
Project; that the Final EIR is an accurate and objective statement that fully complies with CEQA and the
State CEQA Guidelines; and that the Final EIR reflects the independent judgment of the City of
Redlands. The City declares that no new significant information as defined by the State CEQA
Guidelines section 15088.5 has been received by the City after circulation of the Draft EIR that would
require recirculation. The City certifies the Environmental Impact Report based on the following
findings and conclusions:
1. Findings:
a) CEQA Compliance: As the decision-making body for the Project, the City has reviewed and
considered the information contained in the Findings and supporting documentation. The City
determines that the Findings contain a complete and accurate reporting of the environmental impacts and
mitigation measures associated with the Project, as well as a complete and accurate reporting of the
unavoidable impacts and benefits of the proposed Project as detailed in the Statement of Overriding
Considerations. The City finds that the EIR was prepared in compliance with CEQA and that the City
complied with CEQA's procedural and substantive requirements.
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Related to the Final Environmental impact Report
b) Independent Judgment of Lead Agency: The EIR for the Project reflects the City's independent
judgment. The City has exercised independent judgment in accordance with Public Resources Code
section 21082.1(c)(3)in managing as appropriate the environmental consultant, and directing the
consultant in the preparation of the EIR. The City has independently reviewed and analyzed the EIR
and accompanying studies and finds that the report reflects the independent judgment of the City of
Redlands.
c) Significant Unavoidable Impacts/Statement of Overriding Considerations: The Project would
have the potential for creating significant adverse impacts. These significant adverse environmental
impacts have been identified in the EIR and will require mitigation as set forth in the Findings.
Significant adverse impacts which cannot be mitigated to a less than significant level after mitigation
include traffic and circulation, air quality, and noise, as discussed in the Findings. The City has
eliminated or substantially reduced environmental impacts where feasible as described in the Findings,
and the City determines that the remaining unavoidable significant adverse impacts are acceptable due to
the reasons set forth in the preceding Statement of Overriding Considerations.
2. Conclusions:
• Except as to those impacts stated above relating to air quality and traffic and circulation, all other
significant environmental impacts from the implementation of the proposed Project have been
identified in the EIR and, with implementation of the mitigation measures identified, will be
mitigated to a less than significant level.
• Alternatives to the proposed Project, which could potentially achieve the basic objectives of the
proposed Project,have been considered and rejected in favor of the proposed Project.
• Environmental, economic, social, and other considerations and benefits derived from the
development of the proposed Project override and make infeasible any alternatives to the
proposed Project or further mitigation measures beyond those incorporated into the proposed
Project.
VIII. ADOPTION OF MITIGATION MONITORING AND REPORTING PROGRAM
Pursuant to Public Resources Code section 21081.6, the City of Redlands as the Lead Agency hereby
adopts the Mitigation Monitoring and Reporting Program attached to these Findings. In the event of any
inconsistencies between the mitigation measures as set forth herein and the Mitigation Monitoring and
Reporting Program,the Mitigation Monitoring and Reporting Program shall control.
Section 2. Based on the entire record before the City of Redlands, including the above Findings
and Statement of Overriding Considerations and all written and oral evidence presented to the City, the
City of Redlands as the Lead Agency hereby approves the Project with all the mitigation measures and
the Mitigation Monitoring and Reporting Program, as set forth in these findings.
Section 3. The documents and other materials that constitute the record of proceedings on which
the City of Redlands as the Lead Agency has based the Findings contained herein are located at the City
of Redlands, Development Services Department, 210 East Citrus Avenue, Redlands, California 92373.
The custodian for these documents is Robert D. Dalquest, AICD and Assistant Development Services
Director for the City of Redlands. This information is provided in compliance with Public Resources
Code §21081.6(a)(2)and State CEQA Guidelines §15091(e).
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City of Redlands-Redlands Crossing Project
Facts,Findings,and Statement of Overriding Considerations
Related to the Final Environmental Impact Report
ADOPTED, SIGNED AND APPROVED this 16th day of October, 2012.
T1
Pete Aguilarl"I'Mayor
ATTEST:
Sam Irwin, City"Ck
1, Sam Irwin, City Clerk of the City of Redlands, hereby certify that the foregoing resolution was duly
adopted by the City Council at a regular meeting thereof held on the 16th day of October, 2012 by the
following vote:
AYES: Councilmembers Foster, Harrison, Bean and Gardner
NOES: Mayor Aguilar
ABSTAIN: None
ABSENT: None
Sam Irwin,City rle&
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