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U.S. Department of Housing and Urban Development San Francisco Regional Office-Region IX 600 Harrison Street San Francisco, California 94107-1387 espanol.hud.gov

Environmental Assessment for HUD-funded Proposals Recommended format per 24 CFR 58.36, revised March 2005

Project Identification:

Lugonia Avenue Housing Project City of Redlands, California 92374 Specific Plan No. 61, Conditional Use Permit No.955 Tentative Tract Map No.18762

Preparer:

Shellie Zias-Roe, Associate Planner

Responsible Entity:

County of San Bernardino Land Use Services Department 385 North Arrowhead Ave. First Floor San Bernardino, CA 92415

Month/Year:

September, 2011

ENVIRONMENTAL ASSESSMENT Responsible Entity: [24 CFR 58.2(a) (7)]

County of San Bernardino Land Use Services Department

Certifying Officer: [24 CFR 58.2(a)(2)]

Christine Kelly, Director

Project Name:

Lugonia Avenue Housing Project

Project Location:

Northeast corner of Lugonia Avenue (SR 38) and Orange Street. (See Exhibit 1)

Estimated Total Project Cost:

$50,000,000

Grant Recipient: [24 CFR 58.2(a) (5)]

Housing Authority of the County of San Bernardino.

Recipient Address:

Housing Authority of the County of San Bernardino 715 East Brier Drive San Bernardino, CA 92408

Project Representative:

Gus Joslin, Chief Operating Officer

Telephone Number:

(909) 890-0644

Conditions of Approval: (List all mitigation measures adopted by the responsible entity to eliminate or minimize adverse environmental impacts. These conditions must be included in project contracts and other relevant documents as requirements). [24 CFR 58.40(d), 40 CFR 1505.2(c)] Air Quality: 1. The applicant shall require that the maximum amount of soil disturbance during grading shall be limited to 5 acres per day. 2. The applicant shall require that the demolition of existing structures and mass grading soil disturbances include watering of demolition debris and disturbed graded areas three times per day. 3. The applicant shall require that mass grading activities during Phase A not occur at the same time as the demolition activities during Phase B. 4. Prior to the commencement of the demolition activities, the proposed project would be required to comply with SCAQMD Rule 1403 which specifies work practice requirements to limit asbestos emissions from building demolition and renovation activities including the removal and associated disturbance of asbestos-containing materials.

Climate Change: 5. The project applicant shall consider and explore the feasibility of a community garden within the neighborhood open space during the design phase of the project. Proof of consideration shall be provided by the City of Redlands Building Official prior to one year after project buildout. 6. The applicant shall demonstrate that the residential units contain the following energy efficiency measures. a) A minimum of two deciduous shade trees shall be planted on the south and west sides of each of the residential units, where feasible. b) Fluorescent or equivalently efficient lighting shall be used. c) Point of use tankless and/or solar water heaters shall be installed in the residential units in lieu of conventional water heaters. d) Energy Star or equivalent energy efficient appliances shall be installed where the developer/applicant is installing the equipment. e) All onsite buildings shall exceed by at least fifteen percent Title 24, Part 6, of the California Code of Regulations, Energy Efficiency Standards for Residential and Nonresidential Buildings. f) Solar panels shall be utilized onsite to provide energy for a portion of the common area. 7. The project shall divert at least 25 percent of non-hazardous construction and demolition materials taken off the construction site from landfills and incinerators. The percentage shall be calculated using either weight or volume but must be consistent in all calculations. In addition, the existing trees on the property that are to be removed during construction/demolition shall be reused or recycled. The reusable items in the existing residential units shall be given away or sold. Documentation of compliance with this measure shall be verified by the City of Redlands Building Official prior to issuance of a building permit. 8. The project shall integrate spaces for storage of recyclables during project operation. The storage shall be located near trash receptacles to encourage recycling. Recycling shall be provided to all residential units. This measure shall be verified by the City of Redlands Building Official prior to issuance of a building permit (this measure must be shown in the project site plan) and shall be verified prior to a Certificate of Occupancy. 9. Maintenance on the air conditioning units in the multi-family housing shall be conducted at least once per year to ensure minimal refrigerant leakage. Maintenance records shall be stored onsite for review and inspection by the City of Redlands. This measure would reduce leakage emissions from the air conditioning units. 10. Any irrigation system(s) installed shall use weather-driven controls, which monitor evapotranspiration (plant water lost). The maximum amount of turf allowed in the single-family residential lots (not including the park area) shall be 25 percent of the landscaping area. The landscaping shall use drought-resistant, low-water-use plants (with the exception of grass/turf in the park area). The trees shall be native or drought-resistant and/or fruit trees. Compliance with this measure shall be verified by the City of Redlands Building Official prior to issuance of a Certificate of Occupancy.

11. Safe and convenient pedestrian connections to Lugonia Elementary School shall be provided from the project site. Vegetation or walls shall not impede the pedestrian paths. Hazardous Materials: 12. Perform soil sampling to check for the presence of pesticides and herbicides at the site. Samples shall be analyzed for organochlorine pesticides, organophosphate pesticides, and chlorinated herbicides. 13. With respect to the perchlorate and TCE plumes, information regarding contamination and remediation efforts is well documented, and remediation efforts are being monitored by the Water Board. Information obtained indicates that the PRPs have been identified and are currently conducting monitoring under regulatory agency oversight. SCA recommends that the monitoring reports are to be reviewed annually to determine if any changes in concentrations at the project site are reported. 14. Workers handling PCB lighting ballasts shall be trained in the safe handling and disposal of these ballasts, as required under 40 CFR 761 and state regulations. 15. Follow local, state, and federal regulations regarding asbestos materials. Prior to renovation or demolition work, perform a survey of all structures to determine the presence of asbestoscontaining materials. Incorporate asbestos abatement planning into the project. Asbestos containing materials are required to be abated prior to demolition. 16. Follow local, state, and federal regulations regarding lead materials. Prior to renovation or demolition work, incorporate lead stabilization planning into the project. 17. Train construction workers to safely and legally handle and dispose of fluorescent lamps. 18. Sampling of the soils is required to determine if hazardous constituents are present in excess of relevant screening levels. 19. At least Thirty (30) days prior to the start of demolition activities, the applicant shall notify the Redlands Unified School District that asbestos removal activities will be taking place and provide the date(s) and times(s) of the asbestos removal activities. Noise: 20. The project shall provide STC 26 glazing for all rooms with any view toward Lugonia Avenue or Orange Street from the multi-family buildings nearest these two roadways and the installation of STC 34 exterior doors and glazing to all rooms with any view of Lugonia Avenue from the single family units. 21 All grading and construction activities shall be limited to the hours from 7:00 a.m. to 6:00 p.m., Monday through Friday and prohibited on Saturdays, Sundays and Federal Holidays. Public Safety: 22. The applicant shall be required to submit a construction site security plan approved by the police department providing adequate security measures such as lights, video cameras, vehicle transponders, locks, alarms, trained security personnel, fencing etc. The nature of the measures will depend on the specific requirements of the site, and may vary with the different stages of

construction. The developer shall be responsible for the compliance of all sub-contractors working on the site. Transportation/Traffic: 23 The applicant shall require the project to widen Lugonia Avenue along the project frontage and stripe for westbound right turn lane at the intersection of Lugonia Avenue and Orange Street. 24. The applicant shall require the project to provide eastbound and westbound left turn lanes at the intersection of Lugonia Avenue and 6th Street and to restrict northbound and southbound left turns from 6th Street at Lugonia Avenue and that the existing pedestrian/school crosswalk be removed. 25. The applicant shall require the project to provide westbound, northbound and southbound left turn lanes at the intersection of Orange Street and Delaware Avenue. 26. The applicant shall require the project to Install raised median on Orange Street from the south of proposed secondary driveway to the north of the driveway Utilities and Service Systems: 27. The applicant shall require the project to submit a recycling plan for construction and demolition debris and implementation of recycling programs post occupancy. Water Quality: 28. The applicant shall require the project to comply with all requirements of the NPDES permit issued by the Santa Ana Regional Water Quality Control Board and the City of Redlands. The project shall also provide the appropriate Best Management Practices (BMPs) within the project site to stop first flush of accumulated pollutants from entering the City storm drain system. The project may also incorporate other measures such as bio-swales in planter areas which can also eliminate the first flush of accumulated pollutants on street surfaces. 29. The applicant shall be required to comply with the submitted Water Quality Management Plan (WQMP) prepared in accordance with Santa Ana Regional Water Quality Control Board guidelines to be reviewed and approved by the City prior to issuance of a grading permit.

.FINDING: [58.40(g)] _X_

Finding of No Significant Impact (The project will not result in a significant impact on the quality of the human environment)

___

Finding of Significant Impact (The project may significantly affect the quality of the human environment)

Preparer Signature: _____________________________________Date: ________ Name/Title/Agency: Shellie Zias-Roe, Associate Planner Land Use Services Department County of San Bernardino 385 North Arrowhead Avenue First Floor San Bernardino, CA 92415-0182 Ernest Perea, Project Manager Romo Planning Group Inc. 2560 North Lomitas Way Covina, CA 91724

RE Approving Official Signature: __________________________Date: ________ Name/Title/Agency: Christine Kelly, Director Land Use Services Department County of San Bernardino 385 North Arrowhead Avenue First Floor San Bernardino, CA 92415-0182 Statement of Purpose and Need for the Proposal: [40 CFR 1508.9(b)] The subject property was planned and developed by the Housing Authority of the County of San Bernardino in the late 1940â€™s, and has been operated for low-income families for over 60 years. The Housing Authority has embarked on a housing development and modernization effort to improve public and affordable housing opportunities and living conditions through the revitalization of the subject property. Through Low-Income Housing Tax Credits and the Capital Fund Program, the Housing Authority is revitalizing the project into a neo-traditional neighborhood, integrating mixed income levels through offering various product mixes, including for rent and for sale dwelling units. Description of the Proposal: Include all contemplated actions which logically are either geographically or functionally a composite part of the project, regardless of the source of funding. [24 CFR 58.32, 40 CFR 1508.25] The approximately 19 acre site contains an existing 115-unit housing project (almost all of which are duplexes), as well as community service and preschool buildings (See Exhibit 2). In order to develop the new project, all structures will be demolished and the entire site will be cleared. In

addition, four existing interior public streets (Sharon Road, Holly Lane, Delaware Avenue, and Sixth Street) found within the development will be vacated to allow for reconfiguration of the entire site. The project proposes to develop a 228-unit planned residential development which will consist of 39 detached single family residences and 189 apartment units The 39 single family residences are to be arranged in clusters located on the south half of the project site, with the 189 apartment units occupying the remaining portions of the site. It will be served by private streets and will contain approximately 5 acres of open space. The open space includes a large “Village Green” area that is the focal point of community. The Village Green will include a recreation building that will also house administrative offices and community services. A swimming pool, kiddie pool and tot lot will be located in the patio area adjacent to the recreation center. The density of the project is 11.8 dwelling units per acre. (See Exhibit 3). Existing Conditions and Trends: Describe the existing conditions of the project area and its surroundings, and trends likely to continue in the absence of the project. [24 CFR 58.40(a)] The existing project site consists of approximately 19 acres located at the northeast intersection of Lugonia Avenue and Orange Street, in the City of Redlands, CA. Exhibit 2 depicts the existing project conditions. The existing project consists of 115 duplex dwelling units operated by the HACSB for low-income families. The project was developed in the late 1940’s and 1950’s and has been operated and managed by the Housing Authority for well over 60 years. The surrounding area is generally residential in character. The property is surrounded by Lugonia Elementary School to the north, single family residences to the south and northeast and Redlands Unified School District offices to the west and a vacant lot to the east. Absent the revitalization of the project site, the existing affordable housing would remain and HACSB would continue to manage and operate the project. The project site would continue to deteriorate despite on-going maintenance by the HACSB due to the age of the structures.

Exhibit 1

REGIONAL LOCATION MAP LUGONIA AVENUE PROJECT

Exhibit 2

EXISTING SITE PLAN

LUGONIA AVENUE PROJECT

Exhibit 3

APPROVED SITE PLAN LUGONIA AVENUE PROJECT

STATUTORY CHECKLIST [24CFR ยง58.5] Record the determinations made regarding each listed statute, executive order or regulation. Provide appropriate source documentation. Note reviews or consultations completed as well as any applicable permits or approvals obtained or required. Note dates of contact or page references. Provide compliance or consistency documentation. Attach additional material as appropriate. Note conditions, attenuation or mitigation measures as required. Factors Historic Preservation [36 CFR 800]

Determination and Compliance Documentation According to the City of Redlands Building and Safety Department, the structures on the property were constructed in 1943 with the second phase east of Sixth Street constructed 1960. An historical/archaeological records search, archival research, field survey and building evaluations were conducted as part of the Cultural Resources Assessment prepared for the project by Archaeological Associates, October 20, 2009. (See Appendix A). The architectural evaluations concluded that none of the 26 buildings appear eligible for inclusion into the National Register of Historic Places or the California Register of Historical Resources. Pursuant to Section 106 of the National Historic Preservation Act (NHPA), the California Office of Historic Preservation did not object to the determination that no historic properties would be affected by the undertaking. (See Appendix B). The results of the records search conducted at the Archaeological Information Center, San Bernardino County Museum in Redlands failed to identify any prehistoric resources on or adjacent to the Area of Potential Effects. The results of the field study were also negative. No prehistoric resources of any kind were identified during the course of the investigation. Research also indicated that two irrigation ditches and two dwellings dating to the late 1800's once lay on or immediately adjacent to the Area of Potential Effects. Both the ditches and buildings were removed long ago and no vestiges of them remain today. Given the degree of disturbance connected with past development, it is unlikely that any subsurface remnants of the ditches or buildings have survived. Based on these findings, and pursuant to 36 CFR 800.4(d) (1), it is concluded that no historic properties will be affected by the proposed undertaking. Source: Cultural Resources Assessment of the Lugonia Avenue Project Site (Tentative Tract No. 18762), A 20+Acre Parcel Located

at the Northeast Corner of Orange Street and East Lugonia Avenue City of Redlands, San Bernardino County by Archaeological Associates, October 20, 2009; Office of Historic Preservation, Reply to HUD: 110609H, July 1, 2011

Floodplain Management [24 CFR 55, Executive Order 11988]

The project is not located within a 100-year flood hazard as mapped by FEMA Flood Insurance Rate Map (FIRM), Panel 8708 of 9400, Map Number 06071C8708 H. The property is Located in Zone X. The Flood Zone X designation indicates minimal flood potential and no flood insurance requirement. Source: United States Federal Emergency Management Administration. Public Flood Map. Internet Website: http://www.msc.fema.gov/webapp/wcs/stores/servlet/FemaWelcomeV iew?storeId=10001&catalogId=10001&langId=-1.Accessed September 12, 2011.

Wetlands Protection [Executive Order 11990]

The project site is currently developed. A review of the National Wetlands Inventory Map (Redlands Quadrangle) as well as field observation resulted in no jurisdictional wetlands located on or nearby the subject property. Because the project site is currently developed and the National Inventory of Wetlands does not identify wetlands at or near the site, no adverse effects on wetlands or wetland protection would result from the proposed project. Source: United States Fish and Wildlife Service, Division of Habitat and Resource Conservation, Wetlands Geodatabase. Internet Website:http://www.fws.gov/wetlands/data/WebMapServices.html. Accessed September 12, 2011

Coastal Zone Management Act [Sections 307(c), (d)]

The project site is not located within a Coastal Zone, as identified on the Local Coastal Program Status Maps for South Coast Areas, effective July 1, 2009. The project site is located more than 50 miles from the nearest coastline. No adverse effects related to the Coastal Zone or the Coastal Zone Management would result from the proposed project. Source: California Coastal Commission Technical Services Division, LCP Status South Coast Area As of July 1, 2009. Internet Website: http://www.coastal.ca.gov/lcp/lcpstatus-map-sc.pdf Accessed on September 10, 2011.

Sole Source Aquifers [40 CFR 149]

According to the Environmental Protection Agency (EPA) Sole Source Aquifer Protection Program, the City of Redlands does not use groundwater from a Designated Sole Source Aquifer. Therefore, the proposed project would not affect an EPA Designated Sole Source Aquifer. Source: United States Environmental Protection Agency. Sole Source Aquifers in Region 9. Internet Website:http://www.epa.gov/region09/water/groundwater/ssa.html. Accessed September 6, 2011.

Endangered Species Act [50 CFR 402]

The proposed project would include the development of new residential units on existing developed property. There is no existing vegetation on site (other than ornamental landscaping). A review of federal designated and proposed critical

habitat maps showed that the project site is located outside any area identified as critical habitat for any plant or animal species listed as threatened or endangered, by the US Fish and Wildlife Service. Therefore, development of the project site will not interfere with the recovery of any federally listed threatened or endangered species. Source: Natural Diversity Database, CNDDB-Inter Website: http://www.dfg.ca.gov/biogeodata/cnddb.Accessed September 12, 2011.

Wild and Scenic Rivers Act [Sections 7(b), (c)]

The proposed project is not located in the vicinity of a listed wild or scenic river. No adverse effects related to a wild or scenic river or on the Wild Scenic Rivers Act would result from the proposed project. Source: United States Fish and Wildlife Service, National Wild and Scenic Rivers System. Internet Website: http://www.rivers.gov/wildriverslist.html#ca. Accessed September 6, 2011.

Air Quality [Clean Air Act, Sections 176(c) and (d), and 40 CFR 6, 51, 93]

The area in which the proposed project is located currently exceeds the state and federal standards for ozone, PM10 and PM2.5.Per guidelines set forth by HUD, because the project is located in a nonattainment area for ozone, PM10 and PM2.5, conformity with the State Implementation Plan (SIP) must be demonstrated. A project is shown to conform to the SIP if it does not exceed the National Ambient Air Quality Standards (NAAQS). The SIP incorporates the individual plans for regional air districts [in this case the South Coast Air Quality Management Districtâ€™s 2007 Air Quality Management Plan (AQMP)]. For a project to be consistent with the AQMP adopted by the South Coast Air Quality Management District (SCAQMD) and thus the SIP, the pollutants emitted from the project should : 1) Not exceed emission significance thresholds or cause a significant impact on air quality by; or 2) The project must already have been included in the AQMP projections used to prepare the plan. Exceedance of Significance Thresholds (Criterion 1) The potential for violation of National Ambient Air Quality Standards (NAAQS) was judged based on two criterion: Criterion 1: The localized significance threshold analysis for the projectâ€™s construction and operational emissions; and

Criterion 2: The CO hotspot assessment for operational emissions. With regard to Criterion 1, the localized construction analysis uses thresholds that represent the maximum emissions from a proposed project that would not cause or contribute to an exceedance of the most stringent applicable federal or state ambient air quality standard. If the proposed project results in emissions below these thresholds, it follows that the project would not cause or contribute to an exceedance of the standard. The proposed projectâ€™s construction emissions would not exceed the SCAQMD localized significance thresholds for NO2, CO, PM10 or PM2.5.Further, the residential nature of the proposed project would not result in operational emissions that exceed the SCAQMDâ€™s operational localized significance thresholds. Therefore, the project meets Criterion 1. With regard to Criterion 2, the CO emissions from the project-related traffic in combination with existing and forecasted traffic would not result in a localized CO hotspot and, thus, not result in an exceedance of federal or state ambient air quality standards for CO. Therefore, the projectâ€™s operational emissions meet Criterion 2. Inclusion in the Air Quality Management Plan (Criterion 2) The AQMP uses the assumptions and projections of local planning agencies to determine control strategies for regional compliance. Since the AQMP is based in large part on local general plans, projects that are deemed consistent with the general plan are found to be consistent with the AQMP The General Plan designation for the project site is currently Medium Density Residential (0 to 15 units per gross acre). The proposed project consists of the replacement of exiting residential housing units at a density consistent with the City of Redlands General, and as such, is consistent with the current General Plan for the proposed project site. Therefore, the project meets this criterion. Even though the project does not exceed emission thresholds and is consistent with the AQMP. Conditions of Approval Nos. 1-3 have been required of the project to mitigate air quality impacts to the maximum extent feasible. (See page 1). With regard to asbestos, demolition activities are covered under National Emission Standards for

Hazardous Air Pollutants (NESHAP) program (40 Code of Federal Regulation (CFR), Part 61, Subpart M) under section 112 of the Clean Air Act. The SCAQMD was delegated authority by the EPA to implement Part 61, which is accomplished through the adoption of and periodic amendments to Regulation X – National Emission Standards for Hazardous Air Pollutants. This delegated authority is established as SCAQMD Rule 1403. Condition of Approval No.4 is required to mitigate impacts from asbestos. (See page 1). In addition, because of the proximity of the Lugonia Elementary School which is located adjacent to the northern boundary of the project site, Condition of Approval No. 19 requires the applicant to notify the school district of 30 days prior to the start of demolition activities. Based on the above, no adverse impacts related to air quality would result from the project. Source: Air Quality Impact Analysis Report Lugonia Avenue Housing Project Redlands, California by Michael Brandman Associates, May 26, 2009; South Coast Air Quality Management District. 2007 Air Quality Management Plan. Internet Website: http://www.abag.ca.gov/bayarea/eqmaps/mapsba.html. Accessed September 12, 2011.

Farmland Protection Policy Act [7 CFR 658]

The project site is currently developed, and is not designated as Prime Farmland or Farmland of Statewide Importance. By the Farmland Mapping and Monitoring Program. No impacts to the Farmland Protection Policy Act will occur. Source: California Department of Conservation, Farmland Mapping & Monitoring Program Internet Website:ftp://ftp.consrv.ca.gov/pub/dlrp/FMMP/pdf. Accessed September, 12, 2011.

Environmental Justice [Executive Order 12898]

Environmental Justice applies in low-income or minority neighborhoods where the grantee proposes the acquisition of housing, the acquisition of land for development, and new construction. Environmental Justice issues may include, but are not limited to new, continued or historically disproportionate potential for high and adverse human health and environmental effects on minority or low-income populations. Based on information obtained from “EJView” and this Environmental Assessment, the project site and surrounding area was not identified as a site or neighborhood that suffers from disproportionate adverse health and environmental effects relative to the community at large. Source: U.S. EPA EJView. Internet Website: http://epamap14.epa.gov/ejmap/entry.html. Accessed September 12, 2011.

HUD Environmental Standards Determination and Compliance Documentation Noise Abatement and Exterior noise levels up to 71 dBA CNEL will occur in the Control [24 CFR 51 B] private exterior spaces of the single family units along Lugonia Avenue. Private exterior living spaces of the multi-family buildings will be exposed to exterior noise levels up to 66 dBA CNEL. HUD uses the Day-night average sound level (symbolized as Ldn) as opposed to the CNEL. The value of the Ldn calculated from a set of measurements taken over a given 24-hour period will be slightly lower than CNEL values by approximately 1.5 dB. Thus the Ldn values for the project are 69.5 dB for the private exterior spaces of the single family units along Lugonia Avenue and 64.5 dB for the exterior living spaces of the multi-family buildings. HUD Site Acceptability Standards are considered “Acceptable” for an Ldn not exceeding 65 dB and “Normally Unacceptable” for a dB above 65 dB but not exceeding 75 dB. Thus the multi-family units are considered to be “Acceptable” because exterior noise levels are 64.5 Ldn and do not exceed the 65 dB threshold. The singlefamily units are considered to be “Normally Unacceptable” because the exterior noise levels are 69.5 dB and exceed the 65 dB threshold. In a situation where the ambient noise is calculated at 66 DNL, a combined Sound Transmission Class value of 24.5 dB’s or greater is required for the single-family home elevations facing Lugonia Avenue. The 24.5 dB STC will bring down the 69.5 exterior noise to a level of 45 dB in the interior living areas which will ensure a healthy living environment. The construction minimum characteristics of the singlefamily unit are as follows: Exterior Wall: Siding or stucco, 2" x 4" studs, R-13 fiberglass insulation, 1/2" drywall Windows: Double pane Sliding Glass Door: Double pan Roof: Shingle over 1/2" plywood, fiberglass insulation, 5/8" drywall, vented Floor: Carpeted except kitchen and baths Since the construction minimum characteristics identified above will yield an approximate 20 dB reduction, interior noise reduction levels as high as 26 dB can be achieved by installing exterior door and window products sound rated at least STC 34.This will result in the single-family

units meeting the HUD noise standards as described above. Condition of Approval No.20 is required to mitigate impacts from noise (See page 3). In addition, Figure 19 [Description of Noise Attenuation Measures (Acoustical Construction)] has been completed by the project architect to verify that the acoustical construction is designed to insure that interior levels do not exceed 45 dB. (Appendix F). Source: 24 CFR Part 51- Environmental Criteria and Standards; Revised Acoustical Analysis Lugonia Avenue Housing Project, City of Redlands by Gordon Bricken & Associates, June 2, 2009 (Appendix G).

Toxic/Hazardous/Radioacti ve Materials, Contamination, Chemicals or Gases [24 CFR 58.5(i)(2)]

It is HUD policy that all property proposed for use in HUD programs to be free of hazardous materials, contamination, toxic chemicals and gasses, and radioactive substances, where a hazard could affect the health and safety of occupants or conflict with the intended utilization of the property. The Phase I Environmental Site Assessment prepared by SCA Environmental Inc., May 22, 2009 (See Appendix D), revealed that the site is: (i) is not listed on an EPA Superfund National Priorities or CERCLA List, or equivalent State list; (ii) is not located within 3,000 feet of a toxic or solid waste landfill site; (iii) does not have an underground storage tank (which is not a residential fuel tank); and (iv) is not known or suspected to be contaminated by toxic chemicals or radioactive materials. However, the Phase I Environmental Site Assessment did identify the following issues: •

The past use of the project site as agricultural land indicates a potential for subsurface contamination.

•

The estimated concentrations of perchlorate and TCE in both HSU-2 and HSU-4 at the project site appear to be between 6-10 ug/L and 0.5-1.0 ug/L, respectively.

•

Lighting ballasts were observed in conjunction with fluorescent lighting fixtures at the project sit

in various locations. A “No PCBs” stamp was not evident on the ballasts, indicating that they are likely to contain PCBs. •

The buildings on the project site may contain asbestos-containing materials.

•

The buildings on the project site may contain lead-containing paints on interior and/or exterior surfaces.

•

Fluorescent lighting elements were found in various locations throughout the building. These elements typically contain mercury in regulated quantities.

•

Fill soils of unknown origin were identified at the Target Property during the geotechnical evaluation.

Even though the proposed project is not listed on an EPA Superfund National Priorities or CERCLA List, or equivalent State list; is not located within 3,000 feet of a toxic or solid waste landfill site; or does not have an underground storage tank (which is not a residential fuel tank); Conditions of Approval Nos.12-19 are required to mitigate impacts to the maximum extent feasible.(See page 3). Based on the above, no adverse impacts related to toxic/hazardous/radioactive materials, contamination, chemicals or gases would result from the project. Source: Phase 1 Environmental Site Assessment APNs: 0167-22113, 0167-221-14, 0167-371-01, 0167-372-01, & 0167-373-01, Redlands, CA by SCA Environmental, Inc. May 22, 2009.

Siting of HUD-Assisted Projects near Hazardous Operations [24 CFR 51 C]

The results of the Phase I Site Assessment which consulted the required hazardous materials databases indicated that there are no hazardous operations on or near the project site. Therefore, there are no adverse effects to the project as a result of proximity to hazardous operations. Source: Phase 1 Environmental Site Assessment APNs: 0167-22113, 0167-221-14, 0167-371-01, 0167-372-01, & 0167-373-01, Redlands, CA by SCA Environmental, Inc. May 22, 2009.

Airport Clear Zones and Accident Potential Zones [24 CFR 51 D]

The subject property is not located within 2,500 feet of the end of a civil airport runway or 8,000 feet of the end of a military airfield runway, which are the distances specified by FAA 14 CFR part 152 and Department of Defense Instructions 4165.57 32 CFR part 256. Redland Municipal Airport is the closes airport to the site

(approximately 3 miles to the east) and the site is not located within the runway Clear Zone or Accident Potential Zone for the airport. Therefore, there will be no adverse effects related to Runway Clear zones and Accident Potential Zones. Source:

Redlands November 2008.

Municipal

Airport

Master

Plan,

adopted

ENVIRONMENTAL ASSESSMENT CHECKLIST [Environmental Review Guide HUD CPD 782, 24 CFR 58.40; Ref. 40 CFR 1508.8 &1508.27] Evaluate the significance of the effects of the proposal on the character, features and resources of the project area. Enter relevant base data and verifiable source documentation to support the finding. Then enter the appropriate impact code from the following list to make a determination of impact. Impact Codes: (1) - No impact anticipated; (2) - Potentially beneficial; (3) - Potentially adverse; (4) - Requires mitigation; (5) - Requires project modification. Note names, dates of contact, telephone numbers and page references. Attach additional material as appropriate. Note conditions or mitigation measures required. Land Development Conformance with Comprehensive Plans and Zoning

Code 1

Source or Documentation The General Plan designation for the property is Medium Density Residential (0 to 15 units per gross acre). The Zoning is Specific Plan No. 61. The density of the project is 11.8 dwellings units per acre which is consistent with the General Plan. The development proposes 39 detached single family residences arranged in clusters located on the south half of the project site and 189 apartment units in 28 multiple family buildings occupying the remaining portions of the site. It will be served by private streets and will contain approximately 5 acres of open space. The neo-traditional concept of planned residential development is patterned after historic neighborhoods found in the City. Adoption of Specific Plan No. 61 was required to allow the type of development proposed. The project was approved by the Redlands City Council on August 4, 2009. Source: City of Redlands Planning Department. General Plan Land Use Map. Internet Website: http://www.ci.redlands.ca.us/community/general_plan_map.htm. Accessed September 12, 2011.

Compatibility and Urban Impact

The project proposes to develop a 228-unit planned residential development which will consist of 39 detached single family residences and 189 apartment units. The 39 single family residences are to be arranged in

clusters located on the south half of the project site, with the 189 apartment units occupying the remaining portions of the site. It will be served by private streets and will contain approximately 5 acres of open space. The open space includes a large “Village Green” area that is the focal point of community. The Village Green will include a recreation building that will also house administrative offices and community services. A swimming pool, kiddie pool and tot lot will be located in the patio area adjacent to the recreation center. The density of the project is 11.8 dwelling units per acre. The surrounding area is generally urban in character. The property is surrounded by Lugonia Elementary School to the north, single family residences to the south and northeast and Redlands Unified School District offices to the west and a vacant lot to the east. The type and intensity of development is compatible with the surrounding area. In addition, because the project will replace housing stock that is 60 years old, it is considered to have a beneficial impact on the surrounding neighborhood. Source: Preparer’s field observations.

Slope 1

The project site is essentially flat, with no potential for landslides or slope failures. Therefore, no impacts are anticipated. Source: Preparer’s field observations.

Erosion 1

The project site is currently developed and erosion control is not a factor. After demolition, the site will be cleared and will consist of vacant disturbed land during the construction phase of the project. The City of Redlands is a Co-Permittee with the County of San Bernardino Flood Control (Principal Permittee), under the National Pollutant Discharge Elimination Sytem (NPDES) General Permit for Storm Water Discharges Associated with Construction and Land Disturbance Activities Order No. 20100014-DWQ, NPDES NO. CAS000002. General Permit Order No. 2010-0014 became effective on February 14, 2011.This General Permit recognizes four distinct phases of construction activities. The phases are Grading and Land Development Phase, Streets and Utilities Phase, Vertical Construction Phase, and Final Landscaping and Site Stabilization Phase. Each phase has activities that can result in different water quality effects from different water quality pollutants. Pursuant to 40 C.F.R. § 131.12 and State Water

Board Resolution No. 68-16,1 which incorporates the requirements of ยง 131.12 where applicable, the State Water Board finds that discharges in compliance with this General Permit will not result in the lowering of water quality standards, and are therefore consistent with those provisions. Compliance with this General Permit will result in improvements in water quality. Therefore no adverse effects would result from erosion related to construction and development of the project. Source:.National Pollutant Discharge Elimination Sytem (NPDES) General Permit for Storm Water Discharges Associated with Construction and Land Disturbance Activities Order No. 2010-0014-DWQ, NPDES NO. CAS000002.

Soil Suitability 1

According to the General Plan MEA/EIR the project site is not located in area of the City that is susceptible to geological hazards. According to Figures 4.3, 4.4, 4.5, and 4.9 the project site is located outside of City areas with potential for generalized erosion, landslide, expansion or generalized liquefaction. Additionally Figure 4.6 of the MEA/EIR identifies the project site as being located outside areas near faults. A geotechnical study for the project site has been submitted analyzing existing site conditions and outlining site preparation and construction measures for the development of the tract map. The applicant shall be required to develop the project in accordance with all the recommendations included in the geotechnical study prepared for the project site. Additionally the proposed project will be constructed to adhere to all federal, state, and local regulations pertaining to seismic safety design. Source: City of Redlands Planning Department. Environmental Review Committee, Environmental Checklist Form, General Plan Amendment No. 123, Specific Plan No. 61, Density Bonus Agreement, Conditional Use Permit No. 955, Tentative Tract Map No 18762, Street Vacations Nos. 149-152. Adopted August 4, 2009.

Hazards and Nuisances including Site Safety

Natural Hazards: The site is not located in an area that is susceptible to geological hazards. There are no slopes that would result in landslides and the underlying soils are suitable for the type of development proposed as they already support residential development. The site is surrounded by urban development and is not susceptible to wildland fires. Built Hazards and Nuisances: The surrounding area is generally urban in character. The property is surrounded by Lugonia Elementary

School to the north, single family residences to the south and northeast and Redlands Unified School District offices to the west and a vacant lot to the east. The adjacent streets are fully improved with curb, gutter, sidewalks, and street lights which are maintained by the City of Redlands. The results of the Phase I Site Assessment which consulted the required hazardous materials databases indicated that there are no hazardous operations on or near the project site. Therefore, there are no adverse effects to the project as a result of proximity to hazardous operations. Source: Preparerâ€™s field observations; Phase 1 Environmental Site Assessment APNs: 0167-221-13, 0167-22114, 0167-371-01, 0167-372-01, & 0167-373-01, Redlands, CA by SCA Environmental, Inc. May 22, 2009.

Energy Consumption

Southern California Edison provides electricity to the project site. The estimated electricity usage of the existing 115 residential units on the project site is 828,000 kWh per year. The proposed 228 units is estimated to use 1,641,600 kWh per year which is approximately double the existing usage. By comparison, the County of San Bernardino uses an estimated 4589.894675 millions of kWh per year. Southern California Gas supplies natural gas to the project site. The estimated natural gas usage of the existing 115 residential units on the project site is 552,000 therms per year. The proposed 228 units is estimated to use 1,094,400 therms per year which is approximately double the existing usage. By comparison, the County of San Bernardino uses an estimated 268.952445 millions of therms per year. Because the fact building construction will exceed Title 24 requirements and the project will use energy efficient appliances as well as implement energy conservation measures, it is not anticipated that the projectâ€™s energy consumption will be above normal for the region. Source: California Energy Consumption Data Management System Internet Website: http://www.ecdms.energy.ca.gov/elecbycounty.aspx Accessed September 22, 2011.

Noise - Contribution to Community Noise Levels

Stationary noise sources would include existing building equipment such as heating and ventilation equipment. The operation of this equipment would be required to comply with the City of Redlands Noise Ordinance. As such, stationary noise sources would not be anticipated to generate significant noise.

Mobile noise sources would include project-related traffic that would result from the development of an additional 113 housing units. According to the Cityâ€™s environmental analysis, the project can be expected to generate 1,630 daily vehicle trips with 125 trips occurring during the AM peak hour and 158 trips occurring during the PM peak hour. The net increase in vehicle trips is therefore 945 daily vehicle trips with 72 additional trips occurring during the AM peak hour and 96 addition trips occurring during the PM peak hour. This number of increased trips is not forecast to, increase noise levels significantly according to the Cityâ€™s environmental analysis. Temporary construction noise would also be generated Construction noise would be subject to limitations established by the City of Redlands Noise Ordinance. Condition of Approval No. 21 is required to mitigate impacts to construction noise.(See page 3). Thus, construction-related noise would not result in environmental impacts. Source: City of Redlands Planning Department. Environmental Review Committee, Environmental Checklist Form, General Plan Amendment No. 123, Specific Plan No. 61, Density Bonus Agreement, Conditional Use permit No. 955, Tentative Tract Map No 18762, Street Vacations Nos. 149-152. Adopted August 4, 2009.

Air Quality Effects of Ambient Air Quality on Project and Contribution to Community Pollution Levels

The following criteria are used to assess cumulative air quality impacts. Criterion 1: Consistency with the regional thresholds for nonattainment pollutants; Criterion 2: Project consistency with existing air quality plans; and Criterion 3: Assessment of the cumulative health effects of the pollutants. With regard to Criterion 1, 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. The South Coast Air Basin is in nonattainment for PM10, PM2.5, and ozone. Therefore, if the proposed

project exceeds the regional thresholds for PM10, PM2.5, NOx or VOC, then it follows that the proposed project would contribute to a cumulatively considerable impact for ozone and particulate matter since both VOC and NOx participate in the formation of particulates. Proposed project impacts on a regional scale may occur many miles away from the project. Emissions from the proposed project when added to the overall emission burden of the SoCAB could result in a cumulatively significant impact. However, the proposed project would not exceed the SCAQMD’s regional emission significance thresholds for VOC and NOx, and CO during construction or operations. Therefore, the project meets Criterion 1. With regard to Criterion 2 the project is consistent with the City of Redlands General Plan and by extension consistent with the SCAQMD Air Quality Management Plan.Therefore, the project meets Criterion 2. With regard to Criterion 3, as noted above, the construction and operational emissions would not exceed any regional or localized significance threshold. Therefore, the proposed project meets Criterion 3. Based on the above, the project would not result in an adverse impact on ambient air quality. Source: Air Quality Impact Analysis Report Lugonia Avenue Housing Project Redlands, California by Michael Brandman Associates, May 26, 2009.

Environmental Design Visual Quality Coherence, Diversity, Compatible Use and Scale

The project proposes to develop a 228-unit planned residential development which will consist of 39 detached single family residences and 189 apartment units The 39 single family residences are to be arranged in clusters located on the south half of the project site, with the 189 apartment units occupying the remaining portions of the site. It will be served by private streets and will contain approximately 5 acres of open space. The open space includes a large “Village Green” area that is the focal point of community. The Village Green will include a recreation building that will also house administrative offices and community services. A swimming pool, kiddie pool and tot lot will be located in the patio area adjacent to the recreation center. The density of the project is 11.8 dwelling units per acre.

The property is surrounded by Lugonia Elementary School to the north, single family residences to the south and northeast and Redlands Unified School District offices to the west and a vacant lot to the east. The project would change the existing character of the immediate vicinity, primarily in that it would replace 60 year old housing stock with new housing. While the proposed project would result in a change from existing conditions, the proposed project’s impacts relating to visual quality and compatibility would be beneficial to the area. Source: Project Plans and Preparer’s knowledge of the area. Socioeconomic Demographic Character Changes

Code Source or Documentation 1 The existing housing project contains 115 low-income housing units.The new project will result in the demolition of the 115 units, to be replaced by 228 forsale and for-rent dwelling units.The estimated population of the City of Redlands in 2011 is 69,231. The estimated numbers of persons per household in the City is 2.73.Given this information, it is reasonable to assume that approximately 622 people would live in the proposed project’s 228 residential units (228 dus x 2.73/pph =622). Based on the same estimates, the existing 115 units have a population of approximately 313 people. Therefore the project would increase the City’s population by 309 people (622- 313 = 309). This represents an overall increase of the City population by approximately 0.43%. This very small proportion of the overall population would not be large enough to result in a significant change in the demographics or character of the City or the neighborhood. Source: California Department of Finance, E-1 Population Estimates for Cities, Counties and the State — January 1, 2010 and 2011.Internet Website: http://www.dof.ca.gov/research/demographic/reports/estimates/e1/view.php Accessed on September 13, 2011.

Displacement

The revitalization of the project site will require the phased displacement of the residents during construction. The Housing Authority of the County of San Bernardino has retained the services of Overland, Pacific & Cutler, Inc. to coordinate this relocation with the existing residents. In most cases, the residents will be given vouchers from the Housing Authority to obtain housing in the immediate vicinity of the project site. In addition, the residents will have first right of refusal for obtaining housing in the revitalized project. The process of educating the residents about this relocation plan is already in place.

It is not anticipated that this will cause a significant adverse impact. Source: Ron Ruhl. Housing Authority County of San Bernardino, Project Manager, September 2011).

Employment and Income Patterns

The project would increase the City’s population by approximately 309 people. This represents an overall increase of the City’s population by approximately 0.43%. This very small proportion of the overall population would not be large enough to result in a significant change in the employment and income patterns of the City. Source: California Department of Finance, E-1 Population Estimates for Cities, Counties and the State — January 1, 2010 and 2011.Internet Website: http://www.dof.ca.gov/research/demographic/reports/estimates/e1/view.php Accessed on September 13, 2011.

Community Facilities and Services Educational Facilities

Code Source or Documentation 4 The proposed housing project will generate additional school children for the Redlands Unified School District. The project will be required to pay the statemandated school fees based on student generation rates in compliance with Senate Bill 50 and section 17260, subdivision (a) (1) of the California Education Code. Currently the School Facility Fees are $2.97 per square foot of accessible space. Compliance with Senate Bill 50 is deemed to be full and complete mitigation for the effects of a development project on school facilities. Therefore, no adverse effects on schools would result from the project. Source: Redlands Unified School District. School Facility Fees Effective June 16, 2008. Internet Website: http://redlandsusd.net/modules/groups/homepagefiles/cms/14429/ File/facility-fee-increase2008.pdf?sessionid=dbfdc4a3ad95b109f3f5645dd8ce4c59 Accessed September 12, 2011.

Commercial Facilities

The project site is conveniently located on two major streets (Orange Street and Lugonia Avenue) with existing commercial development to the north and south. The existing commercial development, along with the convenient access to downtown Redlands will provide ample commercial opportunities to the residents. In addition, the project will not eliminate existing commercial uses. Therefore, the project will not have an adverse effect on commercial facilities. Source: Preparer’s field observations and knowledge of the area.

Health Care

The project site is conveniently located to a number of health care providers, including Redlands Community Hospital, Kaiser Permanente Out-Patient Clinic, Beaver Medical Clinic, and Loma Linda University Medical Center. Given that the proposed project will not result a substantial demographic change for the area and that many project residents are likely to

come from the city's existing population, health care facilities would not be adversely affected by increased demand. Source: Preparer’s field observations and knowledge of the area.

Social Services

Solid Waste

It is expected that the majority of the project’s future residents would be individuals who currently reside in the City. Therefore, it is reasonable to assume that that the proposed project would not attract a substantial number of people who are not currently served by social services in the area. Consequently, it is not anticipated that the project would substantially increase the demand for social services. Source: Preparer’s field observations and knowledge of the area Solid Waste collection will be provided by the City of Redlands. Redlands transports its solid waste to the California Street Landfill and/or the San Timeteo Sanitary Landfill. These landfills have capacity in compliance with State regulations for a minimum of fifteen (15) years including projected growth based on the General Plan Densities. In addition, the project will be required to comply with applicable regulations related to solid waste. Therefore, the project is not anticipated to have an adverse effect on solid waste. Source: City of Redlands Planning Department. Environmental Review Committee, Environmental Checklist Form, General Plan Amendment No. 123, Specific Plan No. 61, Density Bonus Agreement, Conditional Use Permit No. 955, Tentative Tract Map No 18762, Street Vacations Nos. 149-152. Adopted August 4, 2009.

Waste Water

The Redlands Wastewater Treatment Facility will provide wastewater treatment for the project. The facility currently has the ability to process 9.5 million gallons of wastewater per day, and is currently processing about 6 million gallons per day. Assuming a wastewater generation rate of 200 gallons per day (gpd) per unit (common standard used in the project area), the project would generate 45,600 gpd of wastewater. Using the same wastewater generation rate, the existing project is generating 23,000 gpd of wastewater. The project would thus increase the wastewater generated by 22,600 gallons per day. Given that the wastewater treatment plant currently has additional daily capacity for 3.5 million gpd, this increase in not considered significant. Therefore, the project is not anticipated to have an adverse effect on wastewater. Source: City of Redlands. Municipal Utilities and Engineering Department. Internet Website: http://www.ci.redlands.ca.us/utilities/waste_water.htm Accessed September 7, 2011.

Storm Water

The site is currently developed with 115 residential units. Stromwater runoff is being adequately accommodated by the existing storm drain system.

Although the proposed project will create additional impervious surfaces and the volume of stormwater may change, the City requires that the post development runoff not exceed the existing conditions. In addition, the City of Redlands is a Co-Permittee with the County of San Bernardino Flood Control (Principal Permittee) under Order No. R8-20100036NPDES No. CAS618036, National Pollutant Discharge Elimination System (NPDES) Permit and Waste Discharge Requirements for the San Bernardino County Flood Control District" The County of San Bernardino, and the Incorporated Cities of San Bernardino County within the Santa Ana Region Area-Wide Urban Storm Water Runoff Management Program. Order No. R8-2010-0036 became effective on January 29, 201o Each of the Permittees owns and/or operates storm water and urban runoff conveyance systems, including flood control facilities. These conveyance systems are commonly referred to as municipal separate storm sewer systems (MS4) or storm drains, through which storm water and urban runoff are discharged into waters of the United States (Waters of the U.S.) that are located within the Santa Ana Region. This Order regulates the discharge of pollutants in Urban Runoff from anthropogenic (generated from nonagricultural human activities) sources from MS4s that are either under the jurisdiction of the Permittees, and/or where Permittees have MS4 maintenance responsibility, or have authority to approve modifications of the MS4s. Stormwater from these MS4 systems is regulated in order to ensure compliance with Section 402(p) of the federal Clean Water Act (CWA). Therefore, the project will not result in adverse impacts to stormwater. Source: City of Redlands Planning Department. Environmental Review Committee, Environmental Checklist Form, General Plan Amendment No. 123, Specific Plan No. 61, Density Bonus Agreement, Conditional Use Permit No. 955, Tentative Tract Map No 18762, Street Vacations Nos. 149-152. Adopted August 4, 2009; Order No. R8-2010-0036NPDES No. CAS618036, National Pollutant Discharge Elimination System (NPDES) Permit and Waste Discharge Requirements for the San Bernardino County Flood Control District" The County of San Bernardino, and the Incorporated Cities of San Bernardino County within the Santa Ana Region Area-Wide Urban Storm Water Runoff Management Program

Water Supply

The City of Redlands currently, provides water to a

population of approximately 78,000 within its service area via approximately 23,000 water connections. Currently, the majority of water is obtained from the Santa Ana River, Mill Creek, and groundwater. The current annual water usage is 295 gallons per capita daily (gpcd). Base on the existing 115 units this equates to 96,215 gpcd for the project (based on 115 units x 2.73 person per unit x 295 gpcd = 92,615 gpcd). Using the same water usage factor methodology, the proposed project would use 181,203 gpcd. Redlandsâ€™ water supply reliability is expected to be 100 percent of demand through 2030. Therefore, the project will not have an adverse effect on water supply. Source: City of Redlands 2010 Regional Urban Water Management Plan, adopted June 21, 2010.

Public Safety - Police

The vicinity of the project site receives police protection services from the Redlands Police Department. The project would result in an estimated population increase of approximately 309 people. This represents an overall increase of the City population by approximately 0.43%. This population increase would incrementally increase the demand for police services to serve the project site. This very small proportion of the overall population would not be large enough to result in a significant decrease in the level of police protection. Therefore, the project will not have an adverse effect on police services. Source: City of Redlands Planning Department. Environmental Review Committee, Environmental Checklist Form, General Plan Amendment No. 123, Specific Plan No. 61, Density Bonus Agreement, Conditional Use Permit No. 955, Tentative Tract Map No 18762, Street Vacations Nos. 149-152. Adopted August 4, 2009.

- Fire

The project site is provided fire protection by the Redlands Fire Department. A fire station is located one block north of the project site and the response time is one minute. The project would result in an estimated population increase of approximately 309 people. This represents an overall increase of the City population by approximately 0.43%. This population increase would incrementally increase the demand for fire services to serve the project site. This very small proportion of the overall population would not be large enough to result in a significant decrease in the level of police protection. Therefore, the project will not have an adverse effect on fire services. Source: City of Redlands Planning Department. Environmental Review Committee, Environmental Checklist Form, General Plan Amendment No. 123, Specific Plan No. 61, Density Bonus Agreement, Conditional Use Permit No. 955, Tentative Tract Map No 18762, Street Vacations Nos. 149-152. Adopted August 4, 2009.

- Emergency Medical

The Fire Department provides paramedic service from the nearby fire station. Within the City of Redlands, numerous medical facilities exist within close proximity of the project site, including Redlands Community Hospital, Beaver Medical Clinic, and Kaiser Permanente. The project would result in an estimated population increase of approximately 309 people. This population increase would incrementally increase the demand for emergency medical services to serve the project site. This represents an overall increase of the City population by approximately 0.43%. This very small proportion of the overall population would not be large enough to result in a significant decrease in the level of emergency medical services. Therefore, the project will not have an adverse effect on emergency medical services... Source: City of Redlands Planning Department. Environmental Review Committee, Environmental Checklist Form, General Plan Amendment No. 123, Specific Plan No. 61, Density Bonus Agreement, Conditional Use permit No. 955, Tentative Tract Map No 18762, Street Vacations Nos. 149-152. Adopted August 4, 2009.

Open Space and Recreation - Open Space

The City requires 100 square feet of open space per unit which equates to the need for 22,800 square feet of open space. The project will contain approximately 5 acres of open space which exceeds the City’s minimum requirements. Therefore, the project will not have an adverse effect on open space. Source: City of Redlands Planning Department. Environmental Review Committee, Environmental Checklist Form, General Plan Amendment No. 123, Specific Plan No. 61, Density Bonus Agreement, Conditional Use Permit No. 955, Tentative Tract Map No 18762, Street Vacations Nos. 149-152. Adopted August 4, 2009.

- Recreation

The City of Redlands has numerous public parks and recreational facilities within close proximity to the project site, including Community Field, Sylvan Park and the Sports Complex. In addition, the project will contain approximately 5 acres of open space. The open space includes a large “Village Green” area that is the focal point of community. The Village Green will include a recreation building that will also house administrative offices and community services. A swimming pool, kiddie pool and tot lot will be located in the patio area adjacent to the recreation center. Therefore, the project will not have an adverse effect on recreation services... Source: City of Redlands Planning Department. Environmental Review Committee, Environmental Checklist Form, General Plan Amendment No. 123, Specific Plan No. 61, Density Bonus Agreement, Conditional Use Permit No. 955, Tentative Tract Map No 18762, Street Vacations Nos. 149-152. Adopted August 4, 2009.

Cultural Facilities

Cultural facilities within the vicinity of the project area include the: Redlands Historical Museum, located inside the A.K. Smiley Library on the grounds of

Transportation

Smiley Park in downtown Redlands; the San Bernardino County Museum which is a regional museum with exhibits and collections in cultural and natural history; and the San Bernardino de Sena Estancia Redlands Historical Glass Museum. The project would not affect cultural facilities by its operation and residents would have access to cultural facilities. Therefore, the project will not have an adverse impact on cultural facilities. Source: Preparer’s knowledge of area. The existing development of 115 housing units currently generates 685 daily vehicle trips with 53 trips occurring in the AM peak hour and 62 trips occurring in the PM peak hour. The proposed project is expected to generate 1,630 daily vehicle trips with 125 trips occurring during the AM peak hour and 158 trips occurring during the PM peak hour. The net increase in vehicle trips is therefore 945 daily vehicle trips with 72 additional trips occurring during the AM peak hour and 96 addition trips occurring during the PM peak hour. After development of the project, most study intersections will operate at LOS “C” under project conditions with improvements with the exception of Orange and Pioneer which is unchanged at LOS D in the AM peak hour. Because the LOS was already LOS D and did not drop below LOS D it is consistent with the Circulation Element of the General Plan Policy 5.20c. Conditions of Approval Nos. 23-26 are required to mitigate impacts from traffic. (See page 4). The project will also be required to pay development impact fees for cumulative impacts to traffic as determined by the Municipal Utilities and Engineering Department. Therefore, the project will not have an adverse impact on transportation... Source: City of Redlands Planning Department. Environmental Review Committee, Environmental Checklist Form, General Plan Amendment No. 123, Specific Plan No. 61, Density Bonus Agreement, Conditional Use Permit No. 955, Tentative Tract Map No 18762, Street Vacations Nos. 149-152. Adopted August 4, 2009.

Natural Features Water Resources

Source or Documentation There are no natural water resources associated with the project site or in the vicinity. The site and surrounding area is urban and there are no streams or other water resources located in the vicinity. Therefore, the project will not have an adverse impact

on water resources. Source: Preparer’s field observations.

Surface Water

Unique Natural Features and Agricultural Lands

There are no surface waters located with the project site or adjacent to the project. Therefore, the project will not have an adverse impact on surface water. Source: Preparer’s field observations.

The project site is currently developed with 115 residential units and related improvements. No unique natural features exist on-site. The project site is not designated Prime Farmland, nor is zoned for agricultural use and it is not under contract for agricultural land use. Therefore, the project will not have an adverse impact on unique natural features or agricultural lands. Source: California Department of Conservation, Farmland Mapping & Monitoring Program Internet Website:ftp://ftp.consrv.ca.gov/pub/dlrp/FMMP/pdf. Accessed September, 12, 2011; Preparer’s field observations.

Vegetation and Wildlife

The project site is currently developed with 115 residential units and related improvements. No sensitive wildlife species, sensitive plant species, or sensitive plant communities exist on-site or within close proximity. Therefore, the project will not have an adverse impact on vegetation and wildlife. Source: Natural Diversity Database, CNDDB-Inter Web Site: http://www.dfg.ca.gov/biogeodata/cnddb.Accessed September 12, 2011; Preparer’s field observations.

Other Factors Flood Disaster Protection Act [Flood Insurance] [§58.6(a)]

Source or Documentation The project is not located within a 100-year flood hazard as mapped by FEMA Flood Insurance Rate Map (FIRM), Panel 8708 of 9400, Map Number 06071C8708 H. The property is Located in Zone X. The Flood Zone X designation indicates minimal flood potential and no flood insurance requirement. Therefore, the project will not be subject to adverse impacts from flooding. Source: United States Federal Emergency Management Administration. Public Flood Map. Internet Website: http://www.msc.fema.gov/webapp/wcs/stores/servlet/FemaWelco meView?storeId=10001&catalogId=10001&langId=-1.Accessed September 12, 2011.

Coastal Barrier Resources Act/ Coastal Barrier Improvement Act [§58.6(c)]

The Coastal Barrier Resources Act of the United States (CBRA, Public Law 97-348), enacted October 18, 1982, designated various un-developed coastal barriers, depicted by a set of maps adopted by law, for inclusion in the John H. Chafee Coastal Barrier Resources System (CBRS). Areas so designated were made ineligible for direct or indirect Federal national security, navigability, and energy exploration. CBRS areas extend along the coasts of the Atlantic Ocean and the Gulf of Mexico,

Puerto Rico, the U.S. Virgin Islands, and the Great Lakes, and consist of 857 units. There are no Coastal Barrier Resources in California. Therefore, the project will not have an adverse effect on coastal barriers. Source: U.S. Fish and Wildlife Service, John H. Chafee Coastal Barrier Resources System. Internet Webiste:http://www.fws.gov/habitatconservation/coastal_barrier.ht ml. Accessed on September12, 2011.

Airport Runway Clear Zone or Clear Zone Disclosure [ยง58.6(d)]

Other Factors

The project does not involve sale or acquisition of existing property within a civil Airport's Runway Clear Zone or Military Installation's Clear Zone. Therefore, the requirement for disclosure is not applicable to the project. Source: FAA 14 CFR part 152 and Department of Defense Instructions 4165.57 32 CFR part 256.

The site is located within an urbanized area of the city which is served by existing infrastructure and public services. The project is consistent with the City of Redlands General Plan and zoning requirements and has received approval from the Redlands City Council. There are no other known factors associated with the project that have not already been discussed by the analysis contained in this Environmental Assessment.

SUMMARY OF FINDINGS AND CONCLUSIONS 1. The results of the environmental assessment determined that the following environmental factors under the Environmental Assessment Checklist were considered to have No Impact: • • • • • • • • • • • • • • • • • • • • • • • •

Conformance with Comprehensive Plans and Zoning. Slope. Erosion. Soil Suitability. Demographic Character changes. Displacement. Employment Income Patterns. Commercial Facilities. Health Care. Social Services. Solid Waste. Waste Water. Storm Water. Water Supply. Public Safety (Police, Fire, Emergency Medical). Open Space and Recreation (Open Space, Recreation, Cultural Facilities) Water Resources Surface Water. Unique Natural Features and Agricultural Lands. Vegetation and Wildlife. Flood Disaster Protection Act. Coastal Barrier Resources Act/Coastal Barrier Improvement Act. Airport Runway Clear Zone or Clear Zone Disclosure. Other Factors,

2 The results of the environmental assessment determined that the following environmental factors under the Environmental Assessment Checklist were considered to be Potentially Beneficial: • •

Compatibility and Urban Impact. Environment Design.

3. The results of the environmental assessment determined that the following environmental factors under the Environmental Assessment Checklist were considered to Require Mitigation: • • • • •

Hazards and Nuisances including Site Safety. Noise. Air quality. Educational Facilities. Transportation.

With the implementation of the required Mitigation Measures/Conditions of Approval, these environment factors would be less than significant.

ALTERNATIVES TO THE PROPOSED ACTION Alternatives and Project Modifications Considered [24 CFR 58.40(e), Ref. 40 CFR 1508.9] (Identify other reasonable courses of action that were considered and not selected, such as other sites, design modifications, or other uses of the subject site. Describe the benefits and adverse impacts to the human environment of each alternative and the reasons for rejecting it.) The following alternatives were considered: A. Multi-family Alternative â€“ The project would be designed as an entirely multi-family housing project and not contain single-family detached units. Under this alternative, a maximum of 285 units could be developed (assuming maximum buildout under the General Plan). This alternative could potentially add 57 more units to the project. More units would result in more impacts to the environment with regard to noise, traffic, air quality, etc. In addition, this alternative would not offer the residents the opportunity for home ownership for the single-family detached units proposed on the site, and it would not fulfill the Housing Authorityâ€™s intent of creating a mixed income development. B. Alternative Site â€“ The existing site is currently owned and operated by the Housing Authority and all infrastructure and utilities are already in place. In addition, the site is ideally located in close proximity to public services, public facilities and commercial uses. In order to develop an alternative site the Housing Authority would have to locate a site that is similarly situated to public services, public facilities, and commercial uses. In addition, funds would have to be expended for site acquisition in addition to development costs which would increase the cost of the project. C. No Action Alternative [24 CFR 58.40(e)] (Discuss the benefits and adverse impacts to the human environment of not implementing the preferred alternative). The no action alternative would involve maintaining the existing 60 year old housing units on the project site. The benefits of implementing the No Action Alternative would include reduced air pollution and noise generation during construction. Air pollution, traffic, and noise impacts in the immediate vicinity of the site would also be less because only 115 units would be occupied instead of the 228 proposed. However, the No Action Alternative would not allow the HACSB to add 113 affordable housing units to assist in meeting the goal to provide affordable housing to all economic segments of the community. Mitigation Measures Recommended [24 CFR 58.40(d), 40 CFR 1508.20] (Recommend feasible ways in which the proposal or its external factors should be modified in order to minimize adverse environmental impacts and restore or enhance environmental quality.) Air Quality: 1. The applicant shall require that the maximum amount of soil disturbance during grading shall be limited to 5 acres per day. 2. The applicant shall require that the demolition of existing structures and mass grading soil disturbances include watering of demolition debris and disturbed graded areas three times per day.

3. The applicant shall require that mass grading activities during Phase A not occur at the same time as the demolition activities during Phase B. 4. Prior to the commencement of the demolition activities, the proposed project would be required to comply with SCAQMD Rule 1403 which specifies work practice requirements to limit asbestos emissions from building demolition and renovation activities including the removal and associated disturbance of asbestos-containing materials. Climate Change: 5. The project applicant shall consider and explore the feasibility of a community garden within the neighborhood open space during the design phase of the project. Proof of consideration shall be provided by the City of Redlands Building Official prior to one year after project buildout. 6. The applicant shall demonstrate that the residential units contain the following energy efficiency measures. a) A minimum of two deciduous shade trees shall be planted on the south and west sides of each of the residential units, where feasible. b) Fluorescent or equivalently efficient lighting shall be used. c) Point of use tankless and/or solar water heaters shall be installed in the residential units in lieu of conventional water heaters. d) Energy Star or equivalent energy efficient appliances shall be installed where the developer/applicant is installing the equipment. e) All onsite buildings shall exceed by at least fifteen percent Title 24, Part 6, of the California Code of Regulations, Energy Efficiency Standards for Residential and Nonresidential Buildings. f) Solar panels shall be utilized onsite to provide energy for a portion of the common area. 7. The project shall divert at least 25 percent of non-hazardous construction and demolition materials taken off the construction site from landfills and incinerators. The percentage shall be calculated using either weight or volume but must be consistent in all calculations. In addition, the existing trees on the property that are to be removed during construction/demolition shall be reused or recycled. The reusable items in the existing residential units shall be given away or sold. Documentation of compliance with this measure shall be verified by the City of Redlands Building Official prior to issuance of a building permit. 8. The project shall integrate spaces for storage of recyclables during project operation. The storage shall be located near trash receptacles to encourage recycling. Recycling shall be provided to all residential units. This measure shall be verified by the City of Redlands Building Official prior to issuance of a building permit (this measure must be shown in the project site plan) and shall be verified prior to a Certificate of Occupancy. 9. Maintenance on the air conditioning units in the multi-family housing shall be conducted at least once per year to ensure minimal refrigerant leakage. Maintenance records shall be stored onsite for review and inspection by the City of Redlands. This measure would reduce leakage emissions from the air conditioning units.

10. Any irrigation system(s) installed shall use weather-driven controls, which monitor evapotranspiration (plant water lost). The maximum amount of turf allowed in the single-family residential lots (not including the park area) shall be 25 percent of the landscaping area. The landscaping shall use drought-resistant, low-water-use plants (with the exception of grass/turf in the park area). The trees shall be native or drought-resistant and/or fruit trees. Compliance with this measure shall be verified by the City of Redlands Building Official prior to issuance of a Certificate of Occupancy. 11. Safe and convenient pedestrian connections to Lugonia Elementary School shall be provided from the project site. Vegetation or walls shall not impede the pedestrian paths. Hazardous Materials: 12. Perform soil sampling to check for the presence of pesticides and herbicides at the site. samples shall be analyzed for organochlorine pesticides, organophosphate pesticides, and chlorinated herbicides. 13. With respect to the perchlorate and TCE plumes, information regarding contamination and remediation efforts is well documented, and remediation efforts are being monitored by the Water Board. Information obtained indicates that the PRPs have been identified and are currently conducting monitoring under regulatory agency oversight. SCA recommends that the monitoring reports are to be reviewed annually to determine if any changes in concentrations at the project site are reported. 14. Workers handling PCB lighting ballasts shall be trained in the safe handling and disposal of these ballasts, as required under 40 CFR 761 and state regulations. 15. Follow local, state, and federal regulations regarding asbestos materials. Prior to renovation or demolition work, perform a survey of all structures to determine the presence of asbestoscontaining materials. Incorporate asbestos abatement planning into the project. Asbestos containing materials are required to be abated prior to demolition. 16. Follow local, state, and federal regulations regarding lead materials. Prior to renovation or demolition work, incorporate lead stabilization planning into the project. 17. Train construction workers to safely and legally handle and dispose of fluorescent lamps. 18. Sampling of the soils is required to determine if hazardous constituents are present in excess of relevant screening levels. 19. At least Thirty (30) days prior to the start of demolition activities, the applicant shall notify the Redlands Unified School District that asbestos removal activities will be taking place and provide the date(s) and times(s) of the asbestos removal activities. Noise: 20. The project shall provide STC 26 glazing for all rooms with any view toward Lugonia Avenue or Orange Street from the multi-family buildings nearest these two roadways and the installation of STC 34 exterior doors and glazing to all rooms with any view of Lugonia Avenue from the single family units. 21 All grading and construction activities shall be limited to the hours from 7:00 a.m. to 6:00 p.m., Monday through Friday and prohibited on Saturdays, Sundays and Federal Holidays.

Public Safety: 22. The applicant shall be required to submit a construction site security plan approved by the police department providing adequate security measures such as lights, video cameras, vehicle transponders, locks, alarms, trained security personnel, fencing etc. The nature of the measures will depend on the specific requirements of the site, and may vary with the different stages of construction. The developer shall be responsible for the compliance of all sub-contractors working on the site. Transportation/Traffic: 23 The applicant shall require the project to widen Lugonia Avenue along the project frontage and stripe for westbound right turn lane at the intersection of Lugonia Avenue and Orange Street. 24. The applicant shall require the project to provide eastbound and westbound left turn lanes at the intersection of Lugonia Avenue and 6th Street and to restrict northbound and southbound left turns from 6th Street at Lugonia Avenue and that the existing pedestrian/school crosswalk be removed. 25. The applicant shall require the project to provide westbound, northbound and southbound left turn lanes at the intersection of Orange Street and Delaware Avenue. 26. The applicant shall require the project to Install raised median on Orange Street from the south of proposed secondary driveway to the north of the driveway Utilities and Service Systems: 27. The applicant shall require the project to submit a recycling plan for construction and demolition debris and implementation of recycling programs post occupancy. Water Quality: 28. The applicant shall require the project to comply with all requirements of the NPDES permit issued by the Santa Ana Regional Water Quality Control Board and the City of Redlands. The project shall also provide the appropriate Best Management Practices (BMPs) within the project site to stop first flush of accumulated pollutants from entering the City storm drain system. The project may also incorporate other measures such as bio-swales in planter areas which can also eliminate the first flush of accumulated pollutants on street surfaces. 29. The applicant shall be required to comply with the submitted Water Quality Management Plan (WQMP) prepared in accordance with Santa Ana Regional Water Quality Control Board guidelines to be reviewed and approved by the City prior to issuance of a grading permit. Additional Studies/Information Appendix A: Cultural Resources Assessment of the Lugonia Avenue Project Site (Tentative Tract No. 18762), A 20+Acre Parcel Located at the Northeast Corner of Orange Street and East Lugonia Avenue,City of Redlands, San Bernardino County by Archaeological Associates, October 20, 2009. Appendix B: Office of Historic Preservation, Reply to HUD: 110609H, July 1, 2011.

Appendix C: Air Quality Impact Analysis Report Lugonia Avenue Housing Project Redlands, California by Michael Brandman Associates, May 26, 2009. Appendix D: Phase 1 Environmental Site Assessment APNs: 0167-221-13, 0167-221-14, 0167371-01, 0167-372-01, & 0167-373-01, Redlands, CA by SCA Environmental, Inc.May 22, 2009. Appendix E: City of Redlands Planning Department. Environmental Review Committee, Environmental Checklist Form, General Plan Amendment No. 123, Specific Plan No. 61, Density Bonus Agreement, Conditional Use permit No. 955, Tentative Tract Map No 18762, Street Vacations Nos. 149-152. Adopted August 4, 2009. Appendix F: Figure 19, HUD Noise Guidebook. Appendix G: Revised Acoustical Analysis Lugonia Avenue Housing Project, City of Redlands by Gordon Bricken & Associates, June 2, 2009. Appendix H: Order No. R8-2010-0036NPDES No. CAS618036, National Pollutant Discharge Elimination System (NPDES) Permit and Waste Discharge Requirements for the San Bernardino County Flood Control District" The County of San Bernardino, and the Incorporated Cities of San Bernardino County within the Santa Ana Region Area-Wide Urban Storm Water Runoff Management Program. January 29, 2010. List of Sources, Agencies and Persons Consulted [40 CFR 1508.9(b)] City and Redlands 1. City of Redlands Planning Department. General Plan Land Use Map. Internet Website: http://www.ci.redlands.ca.us/community/general_plan_map.htm. Accessed September 12, 2011. 2. City of Redlands Planning Department. Environmental Review Committee, Environmental Checklist Form, General Plan Amendment No. 123, Specific Plan No. 61, Density Bonus Agreement, Conditional Use permit No. 955, Tentative Tract Map No 18762, Street Vacations Nos. 149-152. Adopted August 4, 2009. 3. City of Redlands. Municipal Utilities and Engineering Department. Internet Website: http://www.ci.redlands.ca.us/utilities/waste_water.htm Accessed September 7, 2011. 4. City of Redlands, Proposed Project-City Approved (Letter), October 27,2009. Local Agencies 5. Redlands Unified School District. School Facility Fees Effective June 16, 2008. Internet web Site: http://redlandsusd.net/modules/groups/homepagefiles/cms/14429/File/facility-fee-increase2008.pdf?sessionid=dbfdc4a3ad95b109f3f5645dd8ce4c59 Accessed September 12, 2011. 6. City of Redlands 2010 Regional Urban Water Management Plan, adopted June 21, 2010. Regional Agencies

7. South Coast Air Quality Management District. 2007 Air Quality Management Plan. Internet Web Site: http://www.abag.ca.gov/bayarea/eqmaps/mapsba.html. Accessed September 12, 2011. State of California 8. California Coastal Commission Technical Services Division, LCP Status South Coast Area as of July 1, 2009. Internet Website: http://www.coastal.ca.gov/lcp/lcpstatus-map-ncc.pdf. Accessed on September 12, 2011. 9. Natural Diversity Database, CNDDB-Internet Web Site: http://www.dfg.ca.gov/biogeodata/cnddb.Accessed September 12, 2011. 10. California Department of Finance, E-1 Population Estimates for Cities, Counties and the State â€” January 1, 2010 and 2011.Internet Website: http://www.dof.ca.gov/research/demographic/reports/estimates/e-1/view.php Accessed on September 13, 2011. 11. California Coastal Commission Technical Services Division, LCP Status South Coast Area as of July 1, 2009. Internet Website: http://www.coastal.ca.gov/lcp/lcpstatus-map-sc.pdf Accessed on September 10, 2011. 12. California Department of Conservation, Farmland Mapping & Monitoring Program Internet Website:ftp://ftp.consrv.ca.gov/pub/dlrp/FMMP/pdf. Accessed September, 12, 2011 United States Government 13. United States Federal Emergency Management Administration. Public Flood Map. Internet Web Site: http://www.msc.fema.gov/webapp/wcs/stores/servlet/FemaWelcomeView?storeId= 10001&catalogId=10001&langId=-1. Accessed September 12, 2011. 14. United States Fish and Wildlife Service, Division of Habitat and Resource Conservation, Wetlands Geodatabase. Internet Website: http://www.fws.gov/wetlands/data/WebMapServices.html. Accessed September 12, 2011 15. United States Fish and Wildlife Service, National Wild and Scenic Rivers System. Internet Web Site: http://www.rivers.gov/wildriverslist.html#ca. Accessed September 6, 2011. 16. United States Department of Housing and Urban Development. Siting of HUD-Assisted Projects Near Hazardous Facilities: Acceptable Separation Distances from Explosive and Flammable Hazards. Office of Community Planning and Development, Office of Environment and Energy. Washington, DC. September 1996. 17. United States Environmental Protection Agency. Sole Source Aquifers in Region 9. Internet Web Site: http://www.epa.gov/region09/water/groundwater/ssa.html. Accessed September 6, 2011.

18. National Pollution Discharge Elimination Website:http://cfpub.epa.gov/npdes/npdesreg.cfm?program_id=45. Accessed September 10, 2011.

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Contacts 19. Zias-Roe, Shellie. County of San Bernardino, Land Use Services Department, Associate Planner. Email communications, September 2011. 20. Ruhl, Ron. Housing Authority County of San Bernardino, Project Manager. Email communications, September 2011. 21. Mahmood, Rumi. Environmental Protection Specialist (ARRA) U.S. Department of Housing and Urban Development Region IX - Los Angeles Field Office. Telephone and email communications September 2011.