HomeMy WebLinkAbout01 Addendum to Lytle Creek Apartments EIR for Sobrato
CITY OF FONTANA
ADDENDUM TO THE
LYTLE CREEK APARTMENTS
FINAL ENVIRONMENTAL IMPACT REPORT
(SCH # 2005021054)
SOBRATO PROJECT
May 2022
Prepared By:
Kimley-Horn and Associates, Inc.
3880 Lemon Street, Suite 420
Riverside, CA 92501
Sobrato Project
City of Fontana Table of Contents
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TABLE OF CONTENTS
1 Introduction ............................................................................................................................................ 1
2 Purpose of the Addendum and Summary .............................................................................................. 3
3 Determination ........................................................................................................................................ 5
4 Description of Original Project ............................................................................................................... 7
4.1 Original Project Location and Setting ......................................................................................... 7
5 The Sobrato Project and Overview of Proposed Changes to the Project ............................................ 11
5.1 Surrounding Land Uses ............................................................................................................. 12
5.2 Planned Unit Development (PUD) ............................................................................................ 13
5.3 Proposed Environmental Review/Addendum .......................................................................... 20
5.4 Approvals Requested as Part of the Project ............................................................................. 20
6 Environmental Impact Analysis Summary ............................................................................................ 39
7 Environmental Impact Analysis and Approvals for the Sobrato Project .............................................. 41
Less than Significant Impact/No Changes or No New Information Requiring Preparation of an EIR ..... 42
7.1 Aesthetics, Light, and Glare ...................................................................................................... 43
7.2 Air Quality ................................................................................................................................. 48
7.3 Biological Resources .................................................................................................................. 78
7.4 Cultural Resources .................................................................................................................... 97
7.5 Geology, Soils, and Seismicity ................................................................................................. 106
7.6 Hydrology and Water Quality ................................................................................................. 110
7.7 Land Use and Relevant Planning ............................................................................................. 116
7.8 Noise ....................................................................................................................................... 118
7.9 Population and Housing .......................................................................................................... 147
7.10 Public Services and Utilities .................................................................................................... 149
7.11 Transportation ........................................................................................................................ 158
7.12 Greenhouse Gas Emissions (Global Climate Change) ............................................................. 178
7.13 Mineral Resources .................................................................................................................. 189
7.14 Tribal Cultural Resources ........................................................................................................ 191
7.15 Energy ..................................................................................................................................... 194
7.16 Wildfire.................................................................................................................................... 198
8 Determination of Appropriate CEQA Documentation ....................................................................... 200
9 Conclusion .......................................................................................................................................... 204
10 References .......................................................................................................................................... 206
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City of Fontana Table of Contents
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LIST OF TABLES
Table 1: Lytle Creek Apartments and Sobrato Project Comparison ........................................................... 11
Table 2: Surrounding Land Uses.................................................................................................................. 12
Table 3: Summarized Development Standards ........................................................................................... 14
Table 4: Parking Requirements ................................................................................................................... 16
Table 5: South Coast Air Quality Management District Emissions Thresholds ........................................... 53
Table 6: Local Significance Thresholds for Construction/Operations ......................................................... 54
Table 7: Carcinogenic Risk Assessment Results .......................................................................................... 61
Table 8: Chronic and Acute Hazards ........................................................................................................... 62
Table 9: Construction-Related Emissions.................................................................................................... 63
Table 10: Operational Emissions ................................................................................................................. 64
Table 11: Equipment-Specific Grading Rates .............................................................................................. 71
Table 12: Localized Significance of Construction Emissions ....................................................................... 72
Table 13: Localized Significance of Operational Emissions ......................................................................... 73
Table 14: Cultural Resources and Reports Located within 0.5 Mile of the Project Site ............................. 99
Table 15: Existing Traffic Noise Levels ...................................................................................................... 119
Table 16: Existing Noise Measurements ................................................................................................... 120
Table 17: Typical Construction Noise Levels ............................................................................................. 126
Table 18: Project Construction Noise Levels at Nearest Receptor ........................................................... 127
Table 19: Existing Plus Project Traffic Noise Levels .................................................................................. 130
Table 20: Horizon Year and Horizon Year Plus Project Traffic Noise Levels ............................................. 130
Table 21: Unmitigated On-Site Traffic Noise Levels.................................................................................. 132
Table 22: Mitigated On-Site Traffic Noise Levels ...................................................................................... 137
Table 23: Sound Transmission Class for Windows .................................................................................... 138
Table 24: Typical Construction Equipment Vibration Levels .................................................................... 144
Table 25: Level of Service (LOS) Definitions .............................................................................................. 161
Table 26: Level of Service Criteria for Signalized and Unsignalized Intersections .................................... 161
Table 27: City of Fontana Roadway Capacity Standards ........................................................................... 162
Table 28: City of Fontana Thresholds of Significant Impact ..................................................................... 162
Table 29: Summary of Roadway Segment Analysis for Existing Conditions ............................................. 164
Table 30: Summary of Project Trip Generation ....................................................................................... 165
Table 31: Summary of Roadway Segment Analysis for Existing Plus Project ........................................... 166
Table 32: Summary of Roadway Segment Analysis for Opening Year 2023 Cumulative .......................... 167
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Table 33: Summary of Roadway Segment Analysis for Opening Year 2023 Cumulative Plus Project ...... 168
Table 34: Summary of Roadway Segment Analysis for Horizon Year 2040 .............................................. 169
Table 35: Summary of Roadway Segment Analysis for Horizon Year 2040 Plus Project .......................... 170
Table 36: Summary of Project Trip Generation Comparison ................................................................... 172
Table 37: Construction-Related Greenhouse Gas Emissions .................................................................... 181
Table 38: Project Greenhouse Gas Emissions. .......................................................................................... 181
Table 39: Regional Transportation Plan/Sustainable Communities Strategy Consistency ....................... 183
Table 40: Project Consistency with Applicable CARB Scoping Plan Measures ......................................... 185
LIST OF EXHIBITS
Exhibit 1: Regional Location Map ................................................................................................................ 23
Exhibit 2: Project Vicinity Map .................................................................................................................... 25
Exhibit 3: Conceptual Site Plan ................................................................................................................... 27
Exhibit 4a: Conceptual Elevations – Cluster Units ...................................................................................... 29
Exhibit 4b: Conceptual Elevations – Motorcourt Units ............................................................................... 31
Exhibit 5: Conceptual Landscape Plan ........................................................................................................ 33
Exhibit 6: Conceptual Grading Plan ............................................................................................................. 35
Exhibit 7: Proposed WQMP Exhibit ............................................................................................................. 37
Exhibit 8: Noise Measurement Locations ................................................................................................. 122
Exhibit 9: Traffic Noise Receiver Locations (All Floors) ............................................................................. 134
LIST OF APPENDICES
Appendix A – LCA EIR Summary of Impacts and Mitigation Measures
Appendix B - Air Quality Assessment
Appendix C - Health Risk Assessment
Appendix D – Habitat Assessment
Appendix E – Cultural Resources Assessment
Appendix F – Acoustical Assessment
Appendix G – Traffic Impact Analysis
Appendix H – Greenhouse Gas Emissions Assessment
Appendix I – Energy Assessment
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Sobrato Project
City of Fontana Introduction
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1 INTRODUCTION
The purpose of this Addendum is to review the prior environmental document for the Lytle Creek
Apartments (LCA) Project and evaluate the consistency of a proposed addendum to the project
referred to as the Sobrato Project (Project) in compliance with the California Environmental
Quality Act (CEQA) (California Public Resources Code [PRC] Section 21000 et seq.) and the CEQA
Guidelines (Title 14, California Code of Regulations [CCR] Section 15000 et seq.). The
Environmental Impact Report for the LCA Project was certified by the City of Fontana on
May 31, 2007 (LCA EIR) (State Clearinghouse No. 2005021054). This analysis is in accordance with
CEQA to ensure that the Project would not result in any new significant impacts or a substantial
increase in the severity of previously identified impacts set forth in the prior environmental
document.
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City of Fontana Introduction
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Sobrato Project
City of Fontana Purpose of the Addendum and Summary
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2 PURPOSE OF THE ADDENDUM AND SUMMARY
This Addendum has been prepared for the Sobrato Project in accordance with the provisions of
CEQA; the State CEQA Guidelines; and the rules, regulations, and procedures for implementing
CEQA as set forth by the City of Fontana.
CEQA Guidelines Section 15164(a) states that “the lead agency or a responsible agency shall
prepare an addendum to a previously certified EIR if some changes or additions are necessary,
but none of the conditions described in Section 15162 calling for preparation of a subsequent EIR
have occurred.” (CEQA Guidelines Section 15164(e)). Pursuant to Section 15162(a) of the State
CEQA Guidelines, a subsequent EIR is only required when:
(1) Substantial changes are proposed in the project which will require major revisions of the
previous EIR or negative declaration due to the involvement of new significant
environmental effects or a substantial increase in the severity of previously identified
significant effects;
(2) Substantial changes occur with respect to the circumstances under which the project is
undertaken which will require major revisions of the previous EIR or Negative Declaration
due to the involvement of new significant environmental effects or a substantial increase
in the severity of previously identified significant effects; or
(3) New information of substantial importance, which was not known and could not have
been known with the exercise of reasonable diligence at the time the previous EIR was
certified as complete or the Negative Declaration was adopted, shows any of the
following:
(A) The project will have one or more significant effects not discussed in the previous EIR
or negative declaration;
(B) Significant effects previously examined will be substantially more severe than shown
in the previous EIR;
(C) Mitigation measures or alternatives previously found not to be feasible would in fact
be feasible, and would substantially reduce one or more significant effects of the
project, but the project proponents decline to adopt the mitigation measure or
alternative; or
(D) Mitigation measures or alternatives which are considerably different from those
analyzed in the previous EIR would substantially reduce one or more significant
effects on the environment, but the project proponents decline to adopt the
mitigation measure or alternative.
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City of Fontana Purpose of the Addendum and Summary
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The purpose of this Addendum is to describe the minor changes associated with the Project and
to provide an explanation supported by substantial evidence as to why these proposed changes
will not result in any new significant impacts or an increase in the severity of significant impacts
identified in the EIR. Pursuant to provisions of CEQA and the CEQA Guidelines, the City is the Lead
Agency charged with the responsibility of deciding whether to approve the Project. As part of its
decision-making process, the City is required to review and consider whether the Project would
create new significant impacts or substantially increase the severity of previously identified
significant impacts disclosed in the EIR. An Addendum is the appropriate CEQA document for the
Project if no major revisions to the EIR are necessary and none of the conditions described in
State CEQA Guidelines Section 15162 calling for the preparation of a Subsequent EIR have
occurred. Technical memoranda and studies have been prepared included with this Addendum
that analyze any potential differences between the impacts identified in the EIR.
Sobrato Project
City of Fontana Determination
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3 DETERMINATION
No substantial changes are proposed in the Project and there are no substantial changes in the
circumstances under which the Project would be undertaken that would require major revisions
to the previously-approved certified EIR due to the involvement of new significant environmental
effects or a substantial increase in the severity of previously identified significant effects. Also,
there is no “new information of substantial importance” as that term is used in CEQA Guidelines
Section 15162(a)(3). Therefore, the previously certified EIR adequately discusses the potential
impacts of the Project; however, minor changes require the preparation of an Addendum.
Signature Agency
Printed Name/Title Date
Sobrato Project
City of Fontana Determination
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Sobrato Project
City of Fontana Description of Original Project
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4 DESCRIPTION OF ORIGINAL PROJECT
The following information is as derived from the Lytle Creek Apartments (LCA) Draft EIR dated
January 9, 2006.
4.1 Original Project Location and Setting
The site of the previously proposed Lytle Creek Apartments is in the north-central portion of the
City of Fontana (City), in San Bernardino County, on the southwest corner of the intersection of
Sierra Lakes Parkway and Maloof Avenue. The site is approximately 45 miles east of downtown
Los Angeles, 10 miles west of downtown San Bernardino, and 100 miles north of central San
Diego; see Exhibit 1, Regional Location Map. The 10.4 gross acres site is bordered by Lytle Creek
Road (west); Sierra Lakes Parkway (north); Maloof Avenue (east); and Highland Channel (south).
State Route (SR) 210 parallels the south side of Highland Channel; see Exhibit 2, Project Vicinity
Map.
4.1.1 Existing Land Uses
The project site is currently vacant. Several eucalyptus trees and an abandoned, dilapidated
single-family residence had been present on the site, but were removed in December 2004.
4.1.2 Environmental Setting
This area appears on the U.S. Geological Survey (USGS) Devore 7.5’ Quadrangle (1967, photo
revised 1980, 1988, and 1996) in the southwest quarter of Section 25, Township 1 North, Range 6
West of the San Bernardino Base/Meridian. The elevation of the site is approximately 1,500 feet
(457 meters) above mean seal level.
4.1.3 Existing General Plan and Zoning Designations
The Project site is located in the Multi-Family Residential (R-MF) General Plan land use
designation and in the Multiple Family (R-3) zoning district. The Multi-Family Residential
development (R-MF) density range is 12.4 – 24 dwelling units per acre (du/ac). The Original
Project is consistent with the general plan multi-family residential land use designation and the
General Plan planning policies and met the zoning requirements. The Original Project (LCA)
density is 22.9 du/ac, which is within the density range in the R-MF land use designation.
The zoning and development code serves as the zoning ordinance for the City and contains the
provisions, procedures, and specific use and design standard for each zoning district. All
developments projects within the City must be designed in compliance with the policies,
regulations, and standards of the City’s zoning and development code. The Project would be built
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City of Fontana Description of Original Project
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on land that is currently zoned for multi-family residential uses. Then Section 30-160 of the zoning
and development code set forth the standards for multi-family residential development.
4.1.4 Surrounding Land Uses
The land uses that surrounded the LCA project were residential in character, with SR-210
separating the neighborhood from other residential areas on the south side of the highway. New
single-family residential development was located to the west. Vacant land was north of the
project site and zoned for single-family residential development. A handful of older single-family
homes were to the east on land zoned for multi-family residential development. Highland
Channel and SR-210 were to the south, with the highway located 50 feet south of the site on a
raised embankment of approximately 30 feet. The San Gabriel and San Bernardino mountains
were distinctly visible from the site.
4.1.5 Lytle Creek Apartments Planned Development Project History
On May 31, 2007, the City Council certified the EIR and approved the LCA Planned Development.
The Planned Development was intended to “consist of 238 dwelling units on 10.4 acres of land,
which equates to a density of 22.9 du/ac. The proposed apartment complex would include
17 three-story apartment buildings and three one-story recreation buildings. The buildings would
feature tile roofs, stucco exteriors, stucco covered wood trim, wood siding, decorative wood
brackets, and wrought iron railings. Ten floor plans would be available ranging from one
bedroom/one bathroom to three bedrooms/2.5 bathrooms. Amenities included in the project
would be a community multi-purpose room, business center, fitness center, pool, spa,
demonstration kitchen, tot lot, par course, outdoor fireplace, barbeque area with multiple grills
and picnic benches, and a large open lawn area. The project would have a total of 522 parking
spaces on-site: 238 garage spaces, 140 carport spaces, and 144 open spaces. The buildings would
be 40 feet in height.”
In 2005, an EIR was drafted to evaluate the potential environmental impacts that could occur as
a result of the LCA project implementation. The EIR for the LCA project (SCH No. 2005021054)
was certified on December 5, 2006 by the Planning Commission. The LCA EIR analyzed the
potential impacts from the proposed apartment complex in the following areas:
▪ Aesthetics, Light, and Glare
▪ Air Quality
▪ Biological Resources
▪ Cultural Resources
▪ Geology, Soils, and Seismicity
▪ Hydrology and Water Quality
▪ Land Use and Relevant Planning
▪ Noise
▪ Population and Housing
▪ Public Services and Utilities
▪ Traffic and Circulation
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City of Fontana Description of Original Project
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The LCA EIR concluded that the LCA Project would result in a significant impact with respect to
aesthetics, light, and glare, air quality, cultural resources, noise, public services and utilities, and
traffic and circulation. Appropriate mitigation measures were imposed and adopted as part of
the LCA EIR certification to address the potential significant impacts. Implementation of the
LCA EIR mitigation measures would reduce the impact levels to less than significant. The LCA EIR
also found that the LCA Project would result in significant and unavoidable adverse
environmental impacts with regard to scenic vistas, cumulative air quality, and noise. As such, a
Statement of Overriding Considerations was also prepared and adopted. The Planning
Commission approved the LCA Project and adopted the LCA EIR on December 5, 2006. An appeal
to the Planning Commission decision with regard to the LCA Project and EIR was filed on
December 7, 2006. Due to a large number of opponents and comments received at the Planning
Commission meeting, the City revised and re-circulated Section 3.2: Air Quality and Section 3.11:
Traffic and Circulation for an additional 45-day public review from March 29, 2007 through
May 14, 2007. On May 31, 2007, the City Council denied the appeal, certified the EIR and
approved the Tentative Parcel Map No. 17821, Design Review No. 04-026, and Variance
No. 06-006.
A Mitigation Monitoring and Reporting Program (MMRP) was adopted as a part of the EIR that
minimized impacts associated with implementation of the approved LCA project. The previously
adopted mitigation measures applicable to the LCA project will be imposed as conditions of the
Project, and the LCA EIR Summary of Impacts and Mitigation Measures, as applicable to the
Project, is include in Appendix A.
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Sobrato Project
City of Fontana Project and Overview of Proposed Changes to the Project
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5 THE SOBRATO PROJECT AND OVERVIEW OF PROPOSED CHANGES TO THE
PROJECT
The Sobrato Project applicant proposes to subdivide the existing 17 parcels (parcel numbers
1108-052-01 through -17) via the City’s Subdivision process (Tentative Tract Map) to
accommodate for the construction of a planned unit development (PUD; discussed further
below) that includes two residential products: cluster and motor court single-family homes on
the 10.3-acre site for a total of 143 units with the density of 13.8 du/ac. The cluster development
module would include 47 units consisting of 32 three-bedroom units and 15 four-bedroom units
and the motor court development module would include 96 units consisting of 16 one-bedroom
units, 32 two-bedroom units, and 48 three-bedroom units; see Exhibit 3, Conceptual Site Plan for
further details. The proposed building heights would range from 26 feet to 33 feet (maximum of
35 feet permitted), as depicted in Exhibit 4, Conceptual Elevations. Exhibits 3 and 4 provide
dimensions and planned improvements.
The Project’s buildings would two-story high with Progressive Traditional, Progressive Prairie, or
Modern Farmhouse architectural style for cluster units with Urban Farmhouse and Prairie
Modern architectural styles for the motorcourt units. The buildings would feature concrete tile
or composite asphalt shingle roofs, stucco and brick veneer with board and batten siding
exteriors, stucco covered rigid foam trim, wood fascia, and simulated wood shutters. The Project
would also provide amenities for the residents that include a community recreation center, a
community pool and spa, outdoor seating, barbeque area with two gas grills, and two covered
gazebo structures with picnic table seating. In addition, a total of 397 parking spaces would be
provided on-site, which include 270 garage spaces, 70 open spaces, and 57 guest parking spaces.
Project site improvements would also include pocket parks, surface parking, landscaping, and
internal drive aisles. Access to the Project site would be established through a driveway on the
west side connecting to Lytle Creek Road. An emergency access would be provided through an
Emergency Vehicle Access (EVA) on the east side connecting to Maloof Avenue.
Table 1, Lytle Creek Apartments and Sobrato Project Comparison below, provides a comparison
of elements and improvements proposed by the LCA project and the proposed Sobrato Project.
Table 1: Lytle Creek Apartments and Sobrato Project Comparison
Components Previously Approved (Lytle Creek
Apartments
Proposed (Sobrato Cluster and Motor Court
Homes)
Area 10.4 adjusted gross acres 10.3 adjusted gross acres
Land Use and Zoning Land Use:
Multi-family Residential (R-MF):
12.1-24 DU/AC
Zoning: (R-3):
12-24 DU/AC
Same
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Components Previously Approved (Lytle Creek
Apartments
Proposed (Sobrato Cluster and Motor Court
Homes)
Density 12.1-24 DU/AC per General Plan
22.9 DU/AC (Proposed)
13.8 DU/AC
Total Units 238 total units 143 total units
Floor Plans 10 floor plans 47 “Cluster” units with 4 floorplans
96 “Motor court” units with 5 floorplans
Parking 522 spaces provided Cluster Parking: 144 spaces required and 156
spaces proposed
Motor court Parking: 239.8 spaces required,
and 241 spaces proposed
Total Parking: 384 spaces required and 397
spaces proposed
Open Space Apartment amenities Active Open Space (Amenitized) = 23,793
square feet (sf) (0.54 ac)
Additional Open Space (Non-Amenitized,
Landscaping, etc.) = 18,190 sf (0.41 ac)
Private Open Space (patios, balconies, etc.) =
63,983 sf (1.46 ac)
Lytle Creek Open
Space Area
(easement)
N/A 20,319 sf of open space area for open play,
basketball and a Sobrato neighborhood dog
run/park
CEQA EIR (adopted 2007) Addendum EIR
5.1 Surrounding Land Uses
The surrounding land uses are described in Table 2, Surrounding Land Uses below. The Sobrato
Project site is surrounded by residential uses and vacant land as identified in Table 2.
Table 2: Surrounding Land Uses
Location Land Use District Zoning District Land Use
Project
Site
Multi-Family
Residential (R-MF)
Multiple Family (R-3) Vacant
North Citrus Heights South SP
#21 (R-PC)
Citrus Heights South SP/Residential
Planned Community (R-PC)
Vacant land and single-family
residences.
South California Landings
SP#15 (R-PC)
Specific Plan (SP) 15 – California
Landings
Highland Channel, SR-210, and
single-family development.
East Multi-Family
Residential (R-MF)
(R-3) Single-family residences. City of
Fontana easement.
West Summit Heights SP #18
(R-PC)
Specific Plan (SP) 18 – Summit Heights Single-family development.
Source: City of Fontana. 2021. General Plan Land Use Map. https://www.fontana.org/DocumentCenter/View/28163/General-Plan-Land-
Use-Map-3-2-2021?bidId= (accessed October 2021) and City of Fontana. 2021. Zoning District Map.
https://www.fontana.org/DocumentCenter/View/30623/Zoning-District-Map-3-2-21?bidId= (accessed October 2021).
The residential development as proposed by the Project would be consistent with the existing
land use and zoning designations and therefore, no general plan amendment or zone change
would be required.
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5.2 Planned Unit Development (PUD)
The Sobrato PUD would serve as the underlying standards and requirements and contain design
and development standards, provisions, procedures, and permitted uses for the Project.
Chapter 30 Zoning and Development Code (ZDC) Division 24 – Planned Unit Development
establishes the regulations and procedures for the approval of a planned unit development (PUD)
project.
1) Purpose. The purpose of this division is as follows:
a. To encourage within the density standards of the general plan and ZDC the
development of a more desirable living environment by application of modern site
planning techniques and building groupings or arrangements that are not permitted
through strict application of the present zoning and subdivision ordinances;
b. To encourage the reservation of greater open space and amenities for visual
enjoyment and recreational use;
c. To encourage a more efficient, aesthetic and desirable use of land; and
d. To encourage variety in the physical development patterns of the City.
2) Intent. The intent of this division is to ensure that:
a. Planned unit development permits will be issued only where the subject parcel is large
enough to make innovative and creative site planning possible;
b. Applicants for PUD permits have the professional capability to produce a creative
plan;
c. The public's interest in achieving goals stated in the general plan will be served more
fully through the PUD process than through application of conventional zoning
regulations;
d. The advantages to landowners afforded by the PUD process will be balanced by public
benefits; and
e. Natural or man-made features and resources of the site such as topography, trees,
watercourses, and the like are preserved.
The Project’s PUD would serve as a ‘mini specific plan’ providing development regulations and
design guidelines. The PUD would follow closely to the existing Fontana ZDC’s R-3 standards and
provisions but would also provide additional standards and guidelines that only apply to the
Project site. As such, the Project does not propose a zone change.
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The Project PUD would be prepared to comply with the requirements in the Fontana Municipal
Code (MC), Chapter 30 Article II, Division 24. The PUD would consist of the intent and purpose of
the permitted uses and development regulations for the 10.3-acre site. The development
regulations of the PUD would include but not limited to maximum density, building setbacks,
building height, distance between buildings, parking, walls/fences, landscaping, signs, access, and
amenities.
5.2.1 Proposed Development Regulations
The purpose of these standards is to encourage a high-quality residential development. These
standards establish flexible guidelines to encourage such development, ensure that it is of a
minimum standard of appearance, and compatible with the neighborhoods. The specific
objectives are:
• Allow flexibility in lot size and configuration, and facilitate residential development within
acceptable densities;
• Provide clear development standards that promote compatibility between new and
existing development; and
• Encourage efficient land use by facilitating compact, motorcourt style single-family units.
Table 3, Summarized Development Standards summarizes the development standards present
within the entire Sobrato PUD. These development standards are based on those found in the
Fontana ZDC. However, in the event of discrepancies between the development standards
presented in this document and those in the Fontana ZDC, this document will act as the primary
regulatory document.
Table 3: Summarized Development Standards
Definition Code Standard Project Standard
Lot Standards
Maximum Density 12 – 24 du/ac 13.8 du/ac
Minimum Lot Width 200 feet 582
Minimum Depth 300 feet 809
Minimum Lot Size 5 acres 10.3
Minimum Lot Coverage 50% N/A
Maximum Building Height 55 feet 33 feet (Motorcourt); 26.25 feet (Cluster)
Dwelling Unit Characteristics
Minimum Dwelling Size (Studio) 550 square feet N/A
Minimum Dwelling Size (1 bedroom) 600 square feet 843-891 square feet (Motorcourt)
Minimum Dwelling Size (2 bedroom) 800 square feet 1,400-1,477 square feet (Motorcourt)
Minimum Dwelling Size (3 or more
bedrooms)
900 square feet 1,315-1,924 square feet (Motorcourt);
1,578 square feet (Cluster)
Minimum Building Separation 15 feet 10 feet (Motorcourt); 11.5 feet (Cluster)
Front to Front (building to building) 35 feet 36 feet (Cluster)
Front to Side (building to building) 35 feet N/A
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Definition Code Standard Project Standard
Front to Rear (building to building) 35 feet N/A
Rear to Rear (building to building) 25 feet 15 feet (Motorcourt); 20 feet (Cluster)
Rear to Side (building to building) 25 feet N/A
Side to Side (building to building) 20 feet 10 feet (Motorcourt); 11.5 feet (Cluster)
Parking Requirements
Major or Primary Setback 25 feet 19.9 – 27 feet
Secondary or Collector Setback 20 feet N/A
Local Setback 15 feet 24.5 feet
Minimum Garage Spaces (Studio/1
bedroom)
1 space per unit 16 required/16 provided
Minimum Garage Spaces (2 bedroom) 2 spaces per unit 64 required/64 provided
Minimum Garage Spaces (3 bedroom) 2 spaces per unit 160 required/160 provided
Minimum Garage Spaces (4 bedroom) 2 spaces per unit 30 required/30 provided
Minimum Open Spaces (2/3 bedroom) 0.5 spaces per unit 40 required/49 provided
Minimum Open Spaces (4 bedroom) 0.7 spaces per unit 10.5 required/13 provided
Guest Parking Requirement 1 guest parking space per
3 units
55.3 required/57 provided
Open Space Requirements
Minimum Private Open Space 150 square feet (ground
floor); 100 square feet
(upper floor)
63,983 square feet (14%)
Minimum Common Open Space 35% 9.3%
Minimum Usable Open Space 40% 23.6%
Ancillary Amenities/Open Space
Lytle Creek Open Space Recreation Area 0% 20,319 sf
Parking
The City’s required parking spaces are based on the number of bedrooms provided for each unit.
Parking requirements as outlined in the Fontana ZDC Table No. 30-685.A: Required Number of
Passenger Car Parking Spaces are as follows:
Multiple-Family Apartments Dwelling, Condominium, or Townhouse
• Studio/One Bedroom: One garage space with one-half open parking space is required for
each unit
• Two Bedroom: Two garage spaces is required for each unit
• Three Bedrooms: Two garage spaces and one-half open parking space is required for each
unit
Detached Condominiums
• Two or Three Bedrooms: Two garage spaces and one-half open parking space required
for each unit. The one-half open space may be located on the driveway or within the
private drive aisles.
• Four Bedrooms: Two garage spaces and 0.7 open parking spaces are required for each
unit; the 0.7 space may be located on the driveway or within the private drive aisles.
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A total of 384 total spaces are required by the Project; see Table 4, Parking Requirements.
The Project is proposed with a total of 397 parking spaces. Of these total spaces, 270 garage
spaces, 70 open spaces, and 57 guest parking spaces.
Table 4: Parking Requirements
Parking Type Number of Units Code Requirement Requirement
(spaces) Provided (spaces)
Motorcourt Units
One Bedroom 16 Units Garage: 1.0/unit
Open: 0.5/unit
Guest: 0.33/unit
16
8
5.3
16
8
6
Two Bedroom 32 Units Garage: 2.0/unit
Guest: 0.33/unit
64
10.6
64
11
Three Bedroom 48 Units Garage: 2.0/unit
Open: 0.5/unit
Guest: 0.33/unit
96
24
15.9
96
24
16
Cluster Units
Three Bedroom 32 Units Garage: 2.0/unit
Open: 0.5/unit
Guest: 0.5/unit
64
16
16
64
25
16
Four Bedroom 15 Units Garage: 2.0/unit
Open: 0.7/unit
Guest: 0.5/unit
30
10.5
7.7
30
13
8
Total 384 397
Walls and Fencing
Walls and fencing will be used to define private spaces around each dwelling unit and around the
perimeter of the Project site. Walls can be used to enhance design, privacy, and help to maintain
boundaries of the open space areas in the development.
Community Walls
Community walls shall include the walls that surround the development along the perimeter of
the Project site. The Community wall shall be designed with materials, colors and finishes to
complement the architecture and theme of the development. These walls would consist of an
8-foot-high perimeter wall along the southern boundary, and a 6-foot-hight perimeter wall along
the northern, eastern, and western boundary constructed of split face block.
Gates at the entry shall be designed to be compatible and complement the design of the
Community wall and entry monumentation for the Project. Walls may also be used to screen
service areas, utilities and trash enclosures.
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Parcel and Retaining Walls
Garden walls separating dwelling units alongside yards and other privacy walls along corner side
yards shall be designed with materials, colors and finishes to complement the development. The
height and location shall be consistent with the requirements of the Development Code.
Detached residential cluster units would be separated by 6-foot high vinyl fencing while
motorcourt buildings would be separated by 42-inch high tubular steel fencing.
Retaining walls may be combined with garden walls or as standalone retaining as determined
necessary by the approved grading plan or with approval by the City.
Landscaping
The Project is anticipated to provide non-amenitized landscaping of approximately four percent
(or 18,190 sf) of the Project site. The Landscape Plan supports and enhances the development
and neighborhood experience. The large central open space and smaller open spaces have
distinctive planting, landscape and amenity features, making them unique and enjoyable to the
residence that surround the smaller open spaces features and larger central opens space square.
The planting palette for the Project was chosen to establish a strong, memorable landscape to
provide a sense of place, provide shade in the summer and protection from the occasional wind
during the seasonal high winds. The landscape and amenities complement Fontana’s agricultural
history, existing plant inventories, streetscapes and planting themes. Intimate greenbelts and
well landscaped pathways lead and invite residents to enjoy the central open space amenities or
smaller pocket parks or create a convenient walking path for evening exercise. Private courtyard
entries provide ample private open space and invite residents into a range of unique floor plans
in the neighborhood. For additional detail, refer to Exhibit 5, Conceptual Landscape Plan.
Open Spaces and Recreational Amenities
The Project proposes to provide both common and private open spaces. All units would be
provided private open space via private yards, patios, and balconies proposed for all floor plans.
All floor plans exceed the open space requirements per the City of Fontana development
standards. The centralized open space area of the Sobrato neighborhood acts as a community
recreation center, providing access to open space and outdoor amenities for the entire
community. Amenities provided in this outdoor area include:
• A 60-foot by 24-foot community swimming pool
• A 12-foot by 16-foot family spa
• Public restrooms
• A sun deck with chaise lounges, table seating, and shade umbrellas
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• Two covered gazebo structures with table seating and countertop barbeque island
Residents would also be able to access mail services from this central area through their own
personal mailbox at two gang mailboxes. Landscaping includes grass edging around the perimeter
of the community area further bordered by a walking path. Canopy and ornamental trees encircle
the community center, providing privacy and separation from the other developed portions of
the neighborhood.
Pocket Parks
Parks have been designed to be both passive with minimal seating areas, amenities and unique
landscape features that embrace the agricultural history of the site with themed edible
landscaping or gardening boxes or have been designed fully amenitized to function as a
programed space for specific uses to complement the character of the Project. Parks have been
designed to be both passive with minimal seating areas, amenities and unique landscape features
that embrace the agricultural history of the site with themed edible landscaping or gardening
boxes or have been designed fully amenitized to function as a programed space for specific uses
to complement the character of the Project.
Two pocket parks will be placed within the Sobrato neighborhood to provide small open spaces
for the community to access. These two pocket parks will be located at Lot C and Lot D
Amenities provided within the Project area will be consistent with the City’s open space
requirements and would even exceed standards in certain cases.
Lytle Creek Open Space Area
A portion of Lytle Creek Road running south from the Sobrato main entrance to an existing cul-
de-sac would act as an additional open space area for Sobrato residents. The Lytle Creek Road
cul-de-sac open space area includes open turf areas with limited structures, allowing residents
to utilize the area in a variety of ways. Amenities include a back-to-back half-court basketball, an
enclosed dog park with decomposed granite surface, and an open lawn with mini soccer goals
that would be accessible to residents of the Sobrato neighborhood. Existing vegetation along the
western edge of Lytle Creek Road would be protected in place along with the existing sidewalk.
Additional paths would complete the sidewalk and connect to the existing sidewalk to create a
looped pathway. The Lytle Creek Road open space area would act as an additional flood control
measure for the Sobrato project by allowing drainage flows to infiltrate naturally into the
landscaped turf areas as well as through existing infrastructure. The Lytle Creek open space area
would continue to be owned by the City of Fontana with exclusive use by the residence of the
Sobrato community through an easement agreement.
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Site Access
Regional access to the Project site is provided via SR-210 approximately 0.03 miles south of the
Project site with the nearest exit/entrance ramp located approximately 0.6 miles southeast of
the Project, at the SR-210’s intersection with Citrus Avenue.
Primary access to the Project site is provided via Lytle Creek Road, which is a collector street that
trends in a north-south direction and Sierra Lakes Parkway, which is classified as a primary
highway that trends in an east-west direction.
Vehicular access to the site would include one decorative paved ingress/egress driveway from
Lytle Creek Road. The main entry includes a gated entry and exit with planted dividers/median
and a traffic island. Both ingress and egress entries would each be 20 feet in width. In addition,
the Project also proposes a secondary emergency vehicle access (EVA) from Maloof Avenue.
Lytle Creek Road Easement/Open Space Area
Lytle Creek Road runs along the western boundary of the Project site and terminates in a
cul-de-sac at the flood control channel and I-210. The full extension of Lytle Creek Road to the
cul-de-sac was required as access to the adjacent neighborhood and to the Project site for future
access/development of driveways. Lytle Creek Road to Ross Way provides access to the existing
single-family development to the west of the Project site. The Project proposes to develop access
to the Project site through a main access gate directly across from Ross Way. Therefore, the
cul-de-sac is no longer required to provide access to the neighborhood to the west or for the
future development of the Project site.
As the cul-de-sac is no longer necessary to provide access to the developments, it was
determined that the cul-de-sac would potentially be an attractive nuisance as there would be
limited access, visibility, and use of this roadway. The Project is a gated community with its
primary activation (window placement, amenities, and community features) facing into the
development and away from Lytle Creek Road. The existing development to the west backs to
Lytle Creek Road and provides little connection or visibility to the cul-de-sac. It is a concern of the
City that this area could become a place for people to park and potentially engage in illicit
activities. Therefore, the City has proposed to establish an easement over the extension of Lytle
Creek Road for the purpose of creating an open space area that would be granted to the
development to improve and maintain as an open space amenity area for the Sobrato
community.
Site Excavation and Grading Activities
The Project site is relatively flat, sloping gently downward from northeast to southwest, with
change in ground surface elevation from approximately 1,510 feet to 1,485 feet. The soil cut
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would be approximately 16,744 cubic yards (cy) and fill would be approximately 19,047 cy. As
such, the Project site is anticipated to import approximately 2,303 cy of soil; refer to Exhibit 6,
Conceptual Grading Plan.
Site Drainage
There are five onsite catch basins which would convey stormwater into three drainage areas
(DMA A, DMA B, and DMA C). DMA A is the largest onsite drainage area with underground
corrugated metal pipe (CMP) detention system providing storage capacity of up to 49,331 cubic
feet (cf) to treat the stormwater. The maximum capacity of the proposed CMP detention system
would be sufficient to store the projected 49,312 cf onsite water quality volume, estimated in
the Preliminary Water Quality Management Plan Exhibit; see Exhibit 7, Proposed WQMP Exhibit.
Construction
The Project site is vacant and therefore construction would not include demolition of any
structures. The Project is anticipated to begin January 2023, and construction is anticipated to
continue for approximately 12-18 months through the last phase of development. New
construction would include: (1) grading/removal of concrete, (2) building construction,
(3) paving, (4) architectural coating, (5) landscaping, and the applicable off-site improvements
conditioned by the City.
5.3 Proposed Environmental Review/Addendum
The Addendum together with all other environmental documents will be incorporated by
reference and serve as the basis for the environmental review of the Sobrato Project. The
Addendum will modify the FEIR for the LCA Development Plan and serve as the City’s CEQA
environmental documentation for the Project. Substantive revisions from the prior approval of
the LCA Development Plan and the Project would authorize the following:
• Decrease in the development density from 22.9 du/ac to 13.8 du/ac.
• Decrease in the number of units from 238 units to 143 units.
• Decrease in the parking provided from 522 spaces to 397 spaces.
5.4 Approvals Requested as Part of the Project
The City is the Lead Agency as set forth in CEQA Statute Section 21067 and is responsible for
reviewing and approving the Addendum to the Lytle Creek Apartments EIR. In addition to the
Addendum, the City will consider the following discretionary approvals for the Project:
• Conditional Use Permit (CUP-21-000024) and Planned Unit Development: TBD
• Design Review (DRP-21-000049): The Design Review of the proposed site plan and
architectural design for the development of 47 cluster detached single family homes, 96
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motor court homes, and associated facilities including open space amenities, utilities, and
site improvements.
• Tentative Tract Map (TTM-21-000010): The Project’s Tentative Tract Map would create the
individual legal lots for Project development, formalize the parcel boundaries, and provide
for public rights‐of‐way for Project access. A TTM has been prepared and would be
considered by the City concurrently with the review of the CUP/PUD.
• Tentative Parcel Map (TPM-21-000026): The Project’s Tentative Parcel Map would create
legal lots for off-site improvements involving undergrounding existing overhead utilities. A
TPM has been prepared and would be considered by the City concurrently with the review
of the CUP/PUD.
• Development Agreement (DA-21-xxxxxx): A statutory development agreement, authorized
pursuant to California Government Code Section 65864 et seq., may be processed
concurrent with the approval of the PUD. The development agreement may include, among
other items, methods for financing acquisition and construction of infrastructure, and
phasing, including future phasing. Such development agreement shall be fully approved
before the issuance of the first building permit for this Project.
• Easement Agreement: An easement agreement between the City of Fontana and XXX for
Lytle Creek Road/Open Space area as defined by the agreement and legal description,
granted to the Sobrato community for the exclusive use as an amenity/open space area to
be maintained by the Homeowners Association (HOA).
Additional permits may be required upon review of construction documents. Other permits
required for the Project may include, but are not limited to, the following: issuance of
encroachment permits for driveways and utilities; security and parking area lighting permits;
building permits; grading permits; tenant improvement permits; and permits for new utility
connections.
Utilities
• Potable and fire protection water (Fontana Water District)
• Wastewater (Inland Empire Utilities Agency)
• Electricity (Southern California Edison [SCE])
• Natural gas (Southern California Gas Company [SoCal Gas])
• Communication systems (AT&T and Charter/Spectrum)
• Solid waste (Burrtec)
The Project is required by the City of Fontana to place underground all new, upgraded or existing
on-site or off-site utilities, in accordance with the Fontana MC Chapter 27 Utilities, Article III
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Utilities Undergrounding Requirements. This includes the existing undergrounding of off-site
overhead utilities lines along Sierra Lakes Parkway, Maloof Avenue, and Lytle Creek Road. All
activities related to undergrounding of off-site overhead utilities will require approval from the
City Engineer, be subject to undergrounding requirements in the Fontana MC Section 27-52 and
be in compliance with the California Public Utilities Commission (CPUC) Rule 20. CPUC Rule 20
sets policies and procedures for the conversion of overhead power lines and other equipment
to underground facilities.
National Pollutant Discharge Elimination System Permit: A National Pollutant Discharge
Elimination System Permit (NPDES) would be sought by the Sobrato Project in order to further
minimize any potential impacts to the local waterways via stormwater discharge and wastewater
conveyance. NPDES permits include provisions for mitigating actions, like the creation of a
Stormwater Pollution Prevention Plan (SWPPP) and best management practices that minimize
impacts to public waterways. The NPDES permit would allow the Sobrato Project to comply with
City regulations and policies regarding wastewater/stormwater discharge.
Water Quality Management Plan: The Water Quality Management Plan (WQMP) for the Sobrato
Project would comply with the policies presented in the City’s code. The WQMP also includes
best practices intended to reduce potential impacts to the City’s stormwater conveyance system
due to the Sobrato Project’s stormwater discharge. The statutes and best practices presented in
the WQMP would apply in the construction phase of the Sobrato Project and throughout the
duration of its operation.
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Exhibit 1: Regional Location Map
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Exhibit 2: Project Vicinity Map
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Exhibit 3: Conceptual Site Plan
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Exhibit 4a: Conceptual Elevations – Cluster Units
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Exhibit 4b: Conceptual Elevations – Motorcourt Units
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Exhibit 5: Conceptual Landscape Plan
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Exhibit 6: Conceptual Grading Plan
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Exhibit 7: Proposed WQMP Exhibit
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6 ENVIRONMENTAL IMPACT ANALYSIS SUMMARY
The environmental impact findings of the LCA EIR are summarized below.
No Impact: The LCA EIR determined that no impact would occur with respect to the following
environmental topic areas below.
• Aesthetics, Light, and Glare (Impact 3.1-2)
• Air Quality (Impact 3.2-5)
• Biological Resources (Impacts 3.3-2, 3.3-3 through 3.3-7)
• Geology, Soils, and Seismicity (Impact 3.5-5)
• Hydrology and Water Quality (Impacts 3.6-2, 3.6-7 through 3.6-10)
• Land Use and Relevant Planning (Impacts 3.7-1 and 3.7-3)
• Noise (Impacts 3.8-5 and 3.8-6)
• Population and Housing (Impacts 3.9-2 through 3.9-3)
• Public Services and Utilities (Impact 3.10-4)
The following impacts were included in the LCA EIR’s “Effects Found Not to Be Significant
(EFNTBS)” section (Section 6.0 of the Draft EIR) and therefore, these resources were not analyzed
in this Addendum EIR.
• Agricultural Resources
• Hazards and Hazardous Materials
Less Than Significant Impact: The LCA EIR identified less than significant impacts in the following
environmental topic areas:
• Aesthetics, Light, and Glare (Impact 3.1-3)
• Air Quality (Impacts 3.2-1, 3.2-3, and 3.2-4)
• Biological Resources (Impacts 3.3-1)
• Geology, Soils, and Seismicity (Impacts 3.5-1 through 3.5-4 and 3.5-6 and 3.5-7)
• Hydrology and Water Quality (Impacts 3.6-1, 3.6-3 through 3.6-6)
• Land Use and Relevant Planning (Impact 3.7-2)
• Noise (Impact 3.8-2)
• Population and Housing (Impact 3.9-1)
• Public Services and Utilities (Impacts 3.10-1(b) through 3.10-1(d), 3.10-2, 3.10-3, and
3.10-5 through 3.10-12)
• Traffic and Circulation (Impacts 3.11-2 through 3.11-7)
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Less Than Significant Impact with Incorporation of Mitigation: The LCA EIR identified impacts
that could be mitigated to less than significant levels with incorporation of mitigation measures in
the following environmental topic areas:
• Aesthetics, Light, and Glare (Impact 3.1-4)
• Air Quality (Impact 3.2-2)
• Cultural Resources (Impacts 3.4-1 through 3.4-4)
• Noise (Impacts 3.8-1 and 3.8-3)
• Public Services and Utilities (Impact 3.10-1(a))
• Traffic and Circulation (Impact 3.11-1)
Significant and Unavoidable Impact: The LCA EIR identified significant and unavoidable impacts
in the following environmental topic areas:
• Aesthetics, Light, and Glare (Impact 3.1-1)
• Noise (Impacts 3.8-1 and 3.8-4)
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7 ENVIRONMENTAL IMPACT ANALYSIS AND APPROVALS FOR THE SOBRATO
PROJECT
The scope of the City’s review of the Project is limited by the provisions set forth in CEQA and the
State CEQA Guidelines. This review is limited to evaluating the environmental effects associated
with the Project relative to those analyzed in the LCA EIR. This Addendum also reviews new
information, if any, of substantial importance that was not known and could not have been
known with the exercise of reasonable due diligence at the time the LCA EIR was certified, as well
as any substantial changes which may have occurred with respect to the circumstances under
which the Project is being undertaken. This evaluation includes a determination as to whether
the changes identified because of the Project would result in any new significant impacts or a
substantial increase in the severity of a previously identified significant impact.
Although CEQA Guidelines Section 15164 does not stipulate the format or content of an
Addendum, the topical areas identified in the Appendix G of the CEQA Guidelines were used as
guidance for this Addendum, which also analyzes all environmental issue areas that were
included in the EIR. This comparative analysis provides the City with the factual basis for
determining whether any changes in the Project, any changes in circumstances, or any new
information since the LCA EIR was certified that would require additional environmental review
or preparation of a Subsequent or Supplemental EIR.
Pursuant to CEQA Guidelines Section 15162, the City has determined, on the basis of substantial
evidence in the light of the whole record, that the Project would not result in substantial changes
to the environmental impacts of the LCA EIR, no substantial changes in circumstances have
occurred which would require major revisions to the LCA EIR, and no new information of
substantial importance which could not have been known with the exercise of reasonable
diligence when the LCA EIR was certified has been revealed that would result in either new
significant effects or an increase in the severity of previously analyzed significant effects.
A Mitigation Monitoring and Reporting Program (MMRP) was adopted as a part of the LCA EIR
that minimized impacts associated with LCA EIR development. The previously adopted LCA EIR
mitigation measures applicable to the Project will be imposed as conditions of the Project, and
the LCA EIR Summary of Impacts and Mitigation Measures, as applicable to the Project, is
contained in Appendix A in this Addendum EIR.
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Less than Significant Impact/No Changes or No New Information Requiring
Preparation of an EIR
This Addendum evaluates the potential for the Sobrato Project to result in new or substantially
greater significant impacts compared to the impacts disclosed in the certified LCA EIR. The
Sobrato and the LCA projects are both residential uses in nature and the Sobrato Project would
not involve any changes to the existing land use or zoning designations of the site. The Project
proposes to develop 143 residential units with the density of 13.8 du/ac. The cluster
development module would include 47 units consisting of 32 three-bedroom units and 15 four-
bedroom units and the motor court development module would include 96 units consisting of
16 one-bedroom units, 32 two-bedroom units, and 48 three-bedroom units.
When compared to the LCA Project, which proposed to develop 238 apartment units with the
density of 22.9 du/ac, the Sobrato Project would develop approximately 95 less units at a much
lower density and would not intensify the use of the Project site. As such, the Project does not
have the potential to change the regulatory framework, impact discussion, mitigation measures,
significance conclusions, or cumulative impacts for the following environmental topics analyzed
in the adopted LCA EIR: Aesthetics, Light, and Glare; Air Quality; Biological Resources; Cultural
Resources; Geology and Soils; Hydrology and Water Quality; Land Use and Relevant Planning;
Noise; Population and Housing; Public Services and Utilities; and Traffic and Circulation.
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7.1 Aesthetics, Light, and Glare
7.1.1 Summary of Previous Environmental Analysis
The LCA EIR concluded that the development of the LCA would result in a significant and
unavoidable impact to the scenic vista (Impact 3.1-1). The LCA proposed to construct three (3)-
story high buildings that could have the potential to obstruct views of the San Gabriel and San
Bernardino Mountains from the surrounding residences, the Highland Channel trail, and the SR-
210. No mitigation proposed in the LCA EIR to reduce the potential impact to less than significant
and a Statement of Overriding Considerations was prepared. Further, the LCA was anticipated to
result in a less than significant impact with mitigation incorporated with regard to light and glare.
Mitigation Measures 3.1-4a and 3.1-4b would help reduce the significant impact to less than
significant level. Lastly, impacts associated with scenic resources and visual character were
determined to have no impact and a less than significant impact, respectively.
7.1.2 Analysis of Proposed Project
EIR Impact 3.1-1: Would the project have a substantial adverse effect on a scenic vista?
No New or More Severe Impacts: The Project would not have a more severe or substantial
adverse effect on a scenic vista than what was originally analyzed in the LCA EIR. As previously
discussed, existing surrounding residences could potentially have their views of the San Gabriel
and San Bernardino Mountains be obstructed by the proposed three-story buildings for the LCA.
These impacts would be considered significant and unavoidable related to the proposed LCA.
However, the Project proposes the development of two-story buildings, which would be shorter
than the previously proposed LCA buildings and also be consistent and compatible with the
existing two-story single-family homes, located to the west and northwest of the Project site.
Development of amenities in the existing extension of Lytle Creek Road/Open Space area would
utilize the existing cul-de-sac and would provide a dog park, half-court basketball and open play
grass areas. These amenity improvements would not impact scenic vistas and would enhance the
existing paved street conditions by adding additional landscaping, walking paths, trees, and open
play areas.
Further, development of the Project would be required to comply with established City
regulations regarding development and building dimensions. This includes those presented in
Fontana ZDC Article V for Residential Zoning Districts. Therefore, no new impacts relative to
adverse effects on a scenic vista or a substantial increase in the severity of a previously identified
significant impact evaluated in the LCA EIR would occur. Additionally, no new information of
substantial importance that was not known and could not have been known at the time the
LCA EIR was certified is available that would impact the prior finding of no significant impact.
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Mitigation Program
None identified in the LCA EIR.
Conclusion
The Project would not result in new or more severe impact on a scenic vista(s). A significant and
unavoidable impact was identified in the LCA EIR with respect to scenic vistas. The Project would
have lower heights and would be designed consistent with the applicable guidelines and
standards within the Fontana GP, Fontana MC, and Fontana ZDC. Therefore, no new and/or
modified mitigation measures are required for issues related to scenic vistas.
EIR Impact 3.1-2: Would the project substantially damage scenic resources, including, but
not limited to, trees, rock outcroppings, and historic buildings within a state
scenic highway?
EIR Impact 3.1-3: Would the project conflict with applicable zoning and other regulations
governing scenic quality?
No New or More Severe Impact: Based on the CalTrans State Scenic Highway Map, there is only
one Officially Designated Highway, Route 38, which is approximately 38 miles east of the
proposed Project.1 In addition, according to the Fontana GP, there are no historic buildings
located near the Project site.2 The Project site is not within or adjacent to a scenic highway. No
eligible or officially designated highways exist within the City.3 The LCA was found to have no
impact with respect to Impact 3.1-2 and a less than significant impact with regard to Impact 3.1-3.
The Project site is located in an urbanized area, surrounded by residential developments to the
west, single-family residences to the north and east, and the SR-210 freeway to the south. The
10.3-acre site is currently vacant and undeveloped and zoned as R-3 Multiple Family. The visual
character or quality of public views of the site would change from vacant land to a medium
density residential development. The maximum height of the proposed buildings would not
exceed the maximum required 35 feet. The Project would be similar in visual character, height,
and architectural style as surrounding existing residential developments. The Project proposes
PUD standards and regulations, specific to the Project site. The Project would be required to
comply with all applicable development standards within the PUD, the Fontana GP, and the
Fontana MC; as well as policies presented in the Fontana GP Community Design element.
Development standards include building scale, frontage and site layout, street scape, open space,
1 California Department of Transportation (CalTrans). 2018. California State Scenic Highway System Map. Available at
https://dot.ca.gov/programs/design/lap-landscape-architecture-and-community-livability/lap-liv-i-scenic-highways. Accessed October 2021.
2 City of Fontana. 2019. Fontana Forward General Plan Update 2015-2035. Available at https://www.fontana.org/2632/General-Plan-Update-
2015---2035. Accessed October 2021.
3 California Department of Transportation (CalTrans). (2018). California State Scenic Highway System Map. Available at
https://dot.ca.gov/programs/design/lap-landscape-architecture-and-community-livability/lap-liv-i-scenic-highways. Accessed October 2021.
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parking, signage, and architecture. Development of amenities in the existing extension of Lytle
Creek Road/Open Space area would develop in the existing paved cul-de-sac area and therefore
would not create new impacts. Additionally, compliance with the provisions of the Community
Design Element would ensure that the Project would be developed with not only modern
architectural design sensibilities and materials, but also consistent with the established visual
character of the area. Therefore, with adherence to these standards, the Project would not
impact scenic resources in the area and would not conflict with applicable zoning and other
regulations governing scenic quality. Accordingly, no new impacts or a substantial increase in the
severity of a previously identified significant impact evaluated in the LCA EIR would occur.
Mitigation Program
None identified in the LCA EIR.
Conclusion
The Project would result in no new or more severe impacts on the City’s visual character or
quality. No impact was identified in the LCA EIR with respect to scenic vistas. The Project would
be designed consistent with the applicable guidelines and standards within the Fontana GP,
Fontana MC, and Fontana ZDC Therefore, no new and/or modified mitigation measures are
required for issues related to aesthetics.
EIR Impact 3.1-4: Would the project create a new source of substantial light or glare, which
would adversely affect day or nighttime views in the area?
No New or More Severe Impact: As stated in the LCA EIR, impacts regarding light and glare was
anticipated to be significant with mitigation incorporated. Mitigation Measures 3.1-4a and 3.1-4b
from the LCA EIR would also apply to the Project.
Mitigation Program
Mitigation Measures from the LCA EIR
• Mitigation 3.1-4a: Prior to the issuance of building permits, the developer shall obtain
approval of the City of Fontana of a lighting plan for the project and shall show outdoor
lighting on the site plan and elevations. Outdoor light intensity shall be limited to that
necessary for adequate security and safety and shall be directed and/or shielded to
prevent spillage onto adjacent properties.
• Mitigation 3.1-4b: To the extent feasible, the amount of highly reflective building
materials that would cast glare at adjacent residences shall be minimized. Non-reflective
windows shall be used to the extent feasible on sides facing residents. Prior to project
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approval, the developer shall obtain approval of all building materials from the City of
Fontana Planning Division.
The Project proposes to develop 143 single-family homes, which would be approximately 95 units
less than the number of units proposed in the LCA. The Project would also be lower by one (1)
story in heights. In addition, the Project would be consistent with the applicable Fontana ZDC
that all exterior lighting shall be adequately controlled and shielded to prevent glare and
undesirable illumination to adjacent properties or streets. Adequate lighting levels shall be
provided to ensure a safe environment, while not creating areas of intense light or glare. Light
fixtures and poles shall also be designed and placed in a manner consistent and compatible with
overall site and building design, and high-intensity security lighting fixtures shall not be
substituted for site or landscape lighting or general building exterior illumination but shall be
limited to loading and storage locations or other similar service areas. In addition, all lighting
provided to illuminate parking areas or buildings shall be positioned so as to direct light away
from adjoining properties. These regulations are considered to be either design measures or
existing regulations pursuant to CEQA standards. Incorporation of such features into the Project
would ensure proper design, installation, and operation of all exterior lighting, thereby reducing
the potential for glare effects or light spillover onto adjacent properties. As such, compliance with
Mitigation Measures 3.1-4a and 3.1-4b and consistency with the Fontana MC and Fontana ZDC
would ensure that potential impacts associated with light and glare would be less than significant
and no new mitigation measures are required. Development of amenities in the existing
extension of Lytle Creek Road/Open Space area would be developed consistent the applicable
Fontana ZDC including new lighting consistent with current code, tree/landscape standards and
outdoor play equipment. Therefore, development of the roadway with open space amenities
would not create new impacts.
Accordingly, no new or more severe impacts relative to adverse aesthetic impacts would occur.
Additionally, no new information of substantial importance that was not known and could not
have been known at the time the LCA EIR was certified is available that would create a more
severe impact to the prior finding of significant impact.
Conclusion
The Project would not result in new or more severe impacts from light or glare identified in the
LCA EIR. The Project would be designed consistent with the applicable guidelines and standards
within the Fontana MC and Fontana ZDC. Therefore, no new and/or modified mitigation
measures are required for issues related to light and glare.
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7.1.3 Overall Aesthetics Impact Conclusion
With regard to CEQA Statute Section 21166 and the CEQA Guidelines Section 15162(a), the
Project would not result in any new or more severe impacts with respect to aesthetics. Therefore,
the preparation of a SEIR is not warranted.
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7.2 Air Quality
7.2.1 Summary of Previous Environmental Analysis
The LCA EIR concluded that implementation of the LCA would result in a significant impact from
short-term construction activities. Therefore, Mitigation Measure 3.2-2 was implemented to
reduce emission impacts to less than significant. Further, the LCA EIR determined that impacts
from long-term operation of the LCA would be less than significant. The LCA EIR also found that
the LCA Project would not exceed the Southern California Association of Governments (SCAG)
and South Coast Air Quality Management District (SCAQMD) growth and development
projections, nor would it SCAQMD thresholds. Therefore, the LCA Project would not be in conflict
with the Air Quality Management Plan (AQMP) at full buildout and impacts would be less than
significant. The LCA EIR also determined that CO concentrations at sensitive receptors generated
by the LCA Project would be less than significant.
In addition, in 2007 an Air Quality Assessment (2007 AQA) was prepared to analyze the LCA’s
short-term and long-term air quality impacts. The 2007 AQA concluded that with the
incorporation of recommended mitigation measures, the LCA Project implement would not
exceed the SCAQMD thresholds of significance with respect to temporary short-term
construction impacts. For long-term impacts, the LCA Project implementation would result in a
less than significant impact as emission from the LCA Project would not exceed SCAQMD
operation air quality thresholds. A Health Risk Assessment (HRA, Appendix C) was also conducted
and based on the results of the HRA, the LCA Project would have a chronic hazard index of 1.0,
which was well below the threshold of 10, resulting in a less than significant impact. As for
cumulative impacts, the LCA Project would be consistent with the 2003 Air Quality Management
Plan, the goals and policies of the General Plan, and would not exceed the SCAQMD’s short- and
long-term significance criteria. However, based upon cumulative development within the area,
the LCA Project would result in a significant and unavoidable impact for cumulative short- and
long-term impacts.
7.2.2 Analysis of Proposed Project
An Air Quality Assessment and HRA were prepared for the Project by Kimley-Horn and Associates
(November 2021). The results are summarized herein and included as Appendices B and C to this
Addendum.
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Air Quality Assessment
Air Pollutants of Concern
The air pollutants emitted into the ambient air by stationary and mobile sources are regulated
by state and federal laws. These regulated air pollutants are known as “criteria air pollutants”
and are categorized into primary and secondary pollutants.
Primary air pollutants are emitted directly from sources. Carbon monoxide (CO), reactive organic
gases (ROG), nitrogen oxide (NOX), sulfur dioxide (SO2), coarse particulate matter (PM10), fine
particulate matter (PM2.5), and lead (Pb) are primary air pollutants. Of these, CO, NOX, SO2, PM10,
and PM2.5 are criteria pollutants. ROG and NOX are criteria pollutant precursors and form
secondary criteria pollutants through chemical and photochemical reactions in the atmosphere.
For example, the criteria pollutant ozone (O3) is formed by a chemical reaction between ROG and
NOX in the presence of sunlight. O3 and nitrogen dioxide (NO2) are the principal secondary
pollutants.
Toxic Air Contaminants
Toxic air contaminants (TACs) are airborne substances that can cause short‐term (acute) or
long-term (i.e., chronic, carcinogenic, or cancer-causing) adverse human health effects
(i.e., injury or illness). TACs include both organic and inorganic chemical substances. They may be
emitted from a variety of common sources including gasoline stations, automobiles, dry cleaners,
industrial operations, and painting operations. The current California list of TACs includes more
than 200 compounds, including particulate emissions from diesel‐fueled engines.
The California Air Resource Board (CARB) identified diesel particulate matter (DPM) as a TAC.
DPM differs from other TACs in that it is not a single substance but rather a complex mixture of
hundreds of substances. Diesel exhaust is a complex mixture of particles and gases produced
when an engine burns diesel fuel. DPM is a concern because it causes lung cancer; many
compounds found in diesel exhaust are carcinogenic. DPM includes the particle-phase
constituents in diesel exhaust. The chemical composition and particle sizes of DPM vary between
different engine types (heavy-duty, light-duty), engine operating conditions (idle, accelerate,
decelerate), fuel formulations (high/low sulfur fuel), and the year of the engine. Some short-term
(acute) effects of diesel exhaust include eye, nose, throat, and lung irritation, and diesel exhaust
can cause coughs, headaches, light-headedness, and nausea. DPM poses the greatest health risk
among the TACs. Almost all diesel exhaust particle mass is 10 microns or less in diameter. Due to
their extremely small size, these particles can be inhaled and eventually trapped in the bronchial
and alveolar regions of the lung.
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Ambient Air Quality
CARB monitors ambient air quality at approximately 250 air monitoring stations across the State.
These stations usually measure pollutant concentrations ten feet above ground level; therefore,
air quality is often referred to in terms of ground-level concentrations. Existing levels of ambient
air quality, historical trends, and projections near the Project are documented by measurements
made by the SCAQMD, the air pollution regulatory agency in the South Coast Air Basin (SoCAB)
that maintains air quality monitoring stations which process ambient air quality measurements.
Pollutants of concern in the SoCAB include O3, PM10, and PM2.5. The closest air monitoring station
to the Project that monitors ambient concentrations of these pollutants is the Fontana-Arrow
Monitoring Station (located 4.03 miles to the southwest).
Sensitive Receptors
Sensitive populations are more susceptible to the effects of air pollution than is the general
population. Sensitive receptors that are in proximity to localized sources of toxics are of particular
concern. Land uses considered sensitive receptors include residences, schools, playgrounds,
childcare centers, long‐term health care facilities, rehabilitation centers, convalescent centers,
and retirement homes. Sensitive land uses near the Project include existing single-family
residential uses immediately to the north and east, and future residential uses (currently under
construction) directly to the west. There are also single-family residences and Sierra Lakes
Elementary School to the southeast of the Project site (southeast of the Citrus Avenue and
Summit Avenue intersection).
South Coast Air Quality Management District
The SCAQMD is the air pollution control agency for Orange County and the urban portions of Los
Angeles, Riverside, and San Bernardino counties. The agency’s primary responsibility is ensuring
that state and federal ambient air quality standards are attained and maintained in the SoCAB.
The SCAQMD is also responsible for adopting and enforcing rules and regulations concerning air
pollutant sources, issuing permits for stationary sources of air pollutants, inspecting stationary
sources of air pollutants, responding to citizen complaints, monitoring ambient air quality and
meteorological conditions, awarding grants to reduce motor vehicle emissions, conducting public
education campaigns, and many other activities. All projects are subject to SCAQMD rules and
regulations in effect at the time of construction.
The SCAQMD is also the lead agency in charge of developing the AQMP, with input from the SCAG
and CARB. The AQMP is a comprehensive plan that includes control strategies for stationary and
area sources, as well as for on-road and off-road mobile sources. SCAG has the primary
responsibility for providing future growth projections and the development and implementation
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of transportation control measures. CARB, in coordination with federal agencies, provides the
control element for mobile sources.
The 2016 AQMP was adopted by the SCAQMD Governing Board on March 3, 2017. The purpose
of the AQMP is to set forth a comprehensive and integrated program that would lead the SoCAB
into compliance with the federal 24-hour PM2.5 air quality standard, and to provide an update to
the SCAQMD’s commitments towards meeting the federal 8-hour O3 standards. The AQMP
incorporates the latest scientific and technological information and planning assumptions,
including the 2016-2040 Regional Transportation Plan/Sustainable Communities Strategy
(RTP/SCS) and updated emission inventory methodologies for various source categories.
The SCAQMD has published the CEQA Air Quality Handbook (approved by the SCAQMD
Governing Board in 1993 and augmented with guidance for Local Significance Thresholds [LST] in
2008). The SCAQMD guidance helps local government agencies and consultants to develop
environmental documents required by California Environmental Quality Act (CEQA) and provides
identification of suggested thresholds of significance for criteria pollutants for both construction
and operation (see discussion of thresholds below). With the help of the CEQA Air Quality
Handbook and associated guidance, local land use planners and consultants are able to analyze
and document how proposed and existing projects affect air quality in order to meet the
requirements of the CEQA review process. The SCAQMD periodically provides supplemental
guidance and updates to the handbook on their website.
The SCAG is the regional planning agency for Los Angeles, Orange, Ventura, Riverside,
San Bernardino, and Imperial counties and serves as a forum for regional issues relating to
transportation, the economy, community development, and the environment. Under federal law,
SCAG is designated as a Metropolitan Planning Organization and under State law as a Regional
Transportation Planning Agency and a Council of Governments.
The following is a list of SCAQMD rules that are required of construction activities associated with
the Project:
• Rule 402 (Nuisance) – This rule prohibits the discharge from any source whatsoever such
quantities of air contaminants or other material which cause injury, detriment, nuisance,
or annoyance to any considerable number of persons or to the public, or which endanger
the comfort, repose, health, or safety of any such persons or the public, or which cause,
or have a natural tendency to cause, injury or damage to business or property. This rule
does not apply to odors emanating from agricultural operations necessary for the growing
of crops or the raising of fowl or animals.
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• Rule 403 (Fugitive Dust) – This rule requires fugitive dust sources to implement best
available control measures for all sources, and all forms of visible particulate matter are
prohibited from crossing any property line. This rule is intended to reduce PM10 emissions
from any transportation, handling, construction, or storage activity that has the potential
to generate fugitive dust. PM10 suppression techniques are summarized below.
a) Portions of a construction site to remain inactive longer than a period of three
months will be seeded and watered until grass cover is grown or otherwise
stabilized.
b) All on-site roads will be paved as soon as feasible or watered periodically or
chemically stabilized.
c) All material transported off-site will be either sufficiently watered or securely
covered to prevent excessive amounts of dust.
d) The area disturbed by clearing, grading, earthmoving, or excavation operations
will be minimized at all times.
e) Where vehicles leave a construction site and enter adjacent public streets, the
streets will be swept daily or washed down at the end of the workday to remove
soil tracked onto the paved surface.
• Rule 1113 (Architectural Coatings) – This rule requires manufacturers, distributors, and
end users of architectural and industrial maintenance coatings to reduce ROG emissions
from the use of these coatings, primarily by placing limits on the ROG content of various
coating categories
Air Quality Thresholds
Based upon the criteria derived from Appendix G of the CEQA Guidelines, a Project normally
would have a significant effect on the environment if it would:
• Conflict with or obstruct implementation of the applicable air quality plan.
• Result in a cumulatively considerable net increase of any criteria pollutant for which the
Project region is in nonattainment under an applicable state or federal ambient air quality
standard.
• Expose sensitive receptors to substantial pollutant concentrations.
• Result in other emissions (such as those leading to odors) adversely affecting a substantial
number of people.
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SCAQMD Thresholds
The significance criteria established by SCAQMD may be relied upon to make the above
determinations. According to the SCAQMD, an air quality impact is considered significant if the
Project would violate any ambient air quality standard, contribute substantially to an existing or
projected air quality violation, or expose sensitive receptors to substantial pollutant
concentrations. The SCAQMD has established thresholds of significance for air quality during
construction and operational activities of land use development projects, as shown in Table 5,
South Coast Air Quality Management District Emissions Thresholds.
Table 5: South Coast Air Quality Management District Emissions Thresholds
Criteria Air Pollutants and
Precursors
Maximum Pounds Per Day
Construction-Related Operational-Related
Reactive Organic Gases (ROG) 75 55
Carbon Monoxide (CO) 550 550
Nitrogen Oxides (NOX) 100 55
Sulfur Oxides (SOX) 150 150
Coarse Particulates (PM10) 150 150
Fine Particulates (PM2.5) 55 55
Source: South Coast Air Quality Management District, South Coast AQMD Air Quality Significance Thresholds, April 2019.
Localized Carbon Monoxide
In addition to the daily thresholds listed above, development associated with the Project would
also be subject to the ambient air quality standards. These are addressed through an analysis of
localized CO impacts. The significance of localized impacts depends on the levels of ambient CO
near the Project and whether they are above state and federal CO standards (the more stringent
California standards are 20 ppm for 1-hour and 9 ppm for 8-hour). The SoCAB has been
designated as attainment under the 1-hour and 8-hour standards.
Localized Significance Thresholds
In addition to the CO hotspot analysis, the SCAQMD developed LSTs for emissions of NO2, CO,
PM10, and PM2.5 generated at new development sites (off-site mobile source emissions are not
included in the LST analysis). LSTs represent the maximum emissions that can be generated at a
project without expecting to cause or substantially contribute to an exceedance of the most
stringent state or federal ambient air quality standards. LSTs are based on the ambient
concentrations of that pollutant within the Project source receptor area (SRA), as demarcated by
the SCAQMD, and the distance to the nearest sensitive receptor. LST analysis for construction is
applicable for all projects that disturb five acres or less on a single day. The City of Fontana is
located within SCAQMD SRA 34 (Central San Bernardino Valley). Table 6, Local Significance
Thresholds for Construction/Operations, shows the LSTs for a one-acre, two-acre, and five-acre
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project in SRA 34 with sensitive receptors located within 25 meters of the Project. LSTs associated
with all acreage categories are provided in Table 6 for informational purposes. Table 6 shows
that the LSTs increase as acreages increase. It should be noted that LSTs are screening thresholds
and are therefore conservative. The construction LST acreage is determined based daily acreage
disturbed. The operational LST acreage is based on the total area of the Project site. Although
the Project site is greater than five acres, the five-acre operational LSTs are conservatively used
to evaluate the Project.
Table 6: Local Significance Thresholds for Construction/Operations
Project Size
Maximum Pounds Per Day
Nitrogen Oxide
(NOx)
Carbon Monoxide
(CO)
Coarse Particulates
(PM10)
Fine Particulates
(PM2.5)
1 Acre 118/118 667/667 4/1 3/1
2 Acres 170/170 972/972 7/2 4/1
5 Acres 270/270 1,746/1,746 14/4 8/2
Source: South Coast Air Quality Management District, Localized Significance Threshold Methodology, July 2009.
Methodology (Air Quality)
This air quality impact analysis considers construction and operational impacts associated with
the Project. Where criteria air pollutant quantification was required, emissions were modeled
using the California Emissions Estimator Model (CalEEMod) version 2020.4.0. CalEEMod is a
Statewide land use emissions computer model designed to quantify potential criteria pollutant
emissions associated with both construction and operations from a variety of land use projects.
Air quality impacts were assessed according to methodologies recommended by CARB and the
SCAQMD.
Construction equipment, trucks, worker vehicles, and ground-disturbing activities associated
with Project construction would generate emissions of criteria air pollutants and precursors. Daily
regional construction emissions are estimated by assuming construction occurs at the earliest
feasible date (i.e., a conservative estimate of construction activities) and applying off-road,
fugitive dust, and on-road emissions factors in CalEEMod.
Project operations would result in emissions of area sources (consumer products), energy
sources (natural gas usage), and mobile sources (motor vehicles from Project generated vehicle
trips). Project-generated increases in operational emissions would be predominantly associated
with motor vehicle use. The increase of traffic over existing conditions as a result of the Project
was obtained from the VMT Screening Memorandum for the Proposed Sobrato Residential
Project in the City of Fontana (Kimley-Horn, 2021) (Traffic Impact Study). Other operational
emissions from area, energy, and stationary sources were quantified in CalEEMod based on land
use activity data.
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As discussed above, the SCAQMD provides significance thresholds for emissions associated with
proposed Project construction and operations. The proposed Project’s construction and
operational emissions are compared to the daily criteria pollutant emissions significance
thresholds in order to determine the significance of a Project’s impact on regional air quality.
The localized effects from the Project’s on-site emissions were evaluated in accordance with the
SCAQMD’s LST methodology, which uses on-site mass emissions rate look-up tables and Project-
specific modeling. LSTs represent the maximum emissions from a project that are not expected
to cause or contribute to an exceedance of the most stringent applicable federal or state ambient
air quality standards and are developed based on the ambient concentrations of that pollutant
for each source receptor area and distance to the nearest sensitive receptor.
Health Risk Assessment
Health Risk Analysis Thresholds
Project health risks are determined by examining the types and levels of air toxics generated and
the associated impacts on factors that affect air quality. While the final determination of
significance thresholds is within the purview of the lead agency pursuant to the State CEQA
Guidelines, the SCAQMD recommends that the following air pollution thresholds be used by lead
agencies in determining whether the impacts from the Project are significant. If the lead agency
finds that the Project has the potential to exceed the air pollution thresholds, the Project should
be considered significant. The thresholds for air toxic emissions are as follows.
• Cancer Risk: Emit contaminants that exceed the maximum individual cancer risk of 10 in
one million.
• Non‐Cancer Risk: Emit contaminants that exceed the maximum hazard quotient of 1 in
one million.
Cancer risk is expressed in terms of expected incremental incidence per million population. The
SCAQMD has established an incidence rate of 10 persons per million as the maximum acceptable
incremental cancer risk due to DPM exposure. This threshold serves to determine whether or not
a given project has a potentially significant development‐specific incremental impact. The 10 in
one million standards is a health‐protective significance threshold. A risk level of 10 in one million
implies a likelihood that up to 10 persons, out of one million equally exposed people would
contract cancer if exposed continuously (24 hours per day) to the levels of TAC over a specified
duration of time. This risk would be an excess cancer that is in addition to any cancer risk borne
by a person not exposed to these air toxics. To put this risk in perspective, the risk of dying from
accidental drowning is 1,000 in a million which is 100 times more than the SCAQMD’s threshold
of 10 in one million.
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The SCAQMD has also established non‐carcinogenic risk parameters for use in HRAs.
Noncarcinogenic risks are quantified by calculating a "hazard index," expressed as the ratio
between the ambient pollutant concentration and its toxicity or Reference Exposure Level (REL).
An REL is a concentration at or below which health effects are not likely to occur. A hazard index
of less than 1.0 means that adverse health effects are not expected. Within this analysis, non‐
carcinogenic exposures of less than 1.0 are considered less than significant.
Methodology
The air dispersion modeling for the HRA was performed using the U.S. Environmental Protection
Agency (EPA) AERMOD dispersion model. AERMOD is a steady‐state, multiple‐source, Gaussian
dispersion model designed for use with emission sources situated in terrain where ground
elevations can exceed the stack heights of the emission sources (not a factor in this case).
AERMOD requires hourly meteorological data consisting of wind vector, wind speed,
temperature, stability class, and mixing height. Surface and upper air meteorological data is
provided by the SCAQMD. Surface and upper air meteorological data from the Fontana-Arrow
Highway Monitoring Station was selected as being the most representative for meteorology
based on proximity to the project site.
The Project site is approximately 158 feet north of SR-210. Due to the traffic volumes on the
freeway, the resulting emissions could result in pollutant concentrations at the project site.
Emissions from vehicle traffic along SR-210 were calculated using information derived from traffic
count, vehicle fleet profile, vehicle speed data collected by the California Department of
Transportation (Caltrans) 2019 Annual Average Daily Traffic (AADT) census.4 An emission rate for
PM10 (DPM) and Total Organic Gases (TOG) were calculated using 2019 Caltrans traffic census
data and a CARB 2021 EMission FACtor model (EMFAC)5 model run for San Bernardino County;
refer to Appendix B. To quantify the TACs associated with the TOG fraction, the CARB speciation
profile provided was used. The emissions rate was calculated using 2023 emissions factors since
Project construction would be completed in late-2023. The third trimester exposure used
opening year (2023) emissions factors, two-year factors (for infant exposure) reflect years 2024
and 2025 using 2024 emissions factors, 13-year average factors (for child exposure during years
2-15) reflect emissions during the first 13 years of operation after infancy (2026 to 2038) using
2026 emissions factors, and the second 15 years of exposure (years 2039-2053) using 2039
emissions factors were used for assessment of exposure during years 15 to 30 and were derived
for the South Coast Portion of San Bernardino County.
4 Caltrans, Traffic Census Program – Traffic Volumes, https://dot.ca.gov/programs/traffic-operations/census, October 2021.
5 California Air Resources Board, EMFAC 2021 Web Database, https://arb.ca.gov/emfac/, October 2021.
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The emission source in the model are line volume sources along SR-210. For mobile sources, two
sets of volume sources were created. One set to characterize light-, medium-, and heavy-duty
truck DPM (PM10) emissions and another set for gasoline powered automobiles TOG emissions.
Heavy duty vehicle emissions were assigned a release height of 12 feet (3.7 meters), a plume
height of 21 feet (6.29 meters). A release height of 12 feet resembles the average stack height
for trucks and the plume height is based on U.S. EPA guidance for vehicle volume sources. For
automobile sources, a release height of two feet (0.60 meters) and a plume height of 3.34 feet
(1.02 meters) was used.
AERMOD was run to obtain the peak 1‐hour and annual average concentration in micrograms
per cubic meter (μg/m3) of PM10 at the future potential on-site sensitive receptors. According to
the SCAQMD’s Supplemental Guidelines for Preparing Risk Assessments for Assembly Bill (AB)
2588, air dispersion modeling is required to estimate annual average concentrations to calculate
the Maximum Individual Cancer Risk (MICR), the maximum chronic HI, the zones of impact, and
excess cancer burden, as well as peak hourly concentrations to calculate the health impact from
substances with acute non‐cancer health effects. To achieve these goals, a receptor grid was
placed over the project site to cover the zone of impact. According to the SCAQMD, in order “to
identify the maximum impacted receptors (i.e., peak cancer risk and peak hazard indices), a grid
spacing of 100 meters or less must be used” (see page 16 of SCAQMD’s Supplemental Guidelines).
Due to the size of the Project site, on-site receptors were modeled with a 20-meter grid spacing.
In addition, National Elevation Dataset (NED) terrain data was imported into AERMOD for the
Project. The modeling and analysis was prepared in accordance with the SCAQMD Modeling
Guidance for AERMOD.6
Note that the concentration estimate developed using this methodology is conservative and is
not a specific prediction of the actual concentrations that would occur at the project site any one
point in time. Actual 1-hour and annual average concentrations are dependent on many
variables, particularly the number and type of equipment working at specific distances during
time periods of adverse meteorology.
Residents could occupy the proposed on-site housing for over 30 years. A health risk computation
was performed to determine the risk of developing an excess cancer risk calculated on these
worst-case exposure duration scenarios. The chronic and carcinogenic health risk calculations are
based on the standardized equations contained in the OEHHA Guidance Manual. Only the risk
associated with the worst-case location of the site was assessed.
6 South Coast Air Quality Management District, SCAQMD Modeling Guidance for AERMOD, http://www.aqmd.gov/home/air-
quality/meteorological-data/modeling-guidance, October 2021.
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Risk and Hazard Assessment
Cancer Risk
Based on the OEHHA methodology, residential inhalation cancer risk from annual average DPM
concentrations are calculated by multiplying the daily inhalation dose, cancer potency factor, age
sensitivity factor (ASF), frequency of time spent at home, and exposure duration divided by
averaging time, yielding the excess cancer risk. These factors are discussed in more detail below.
It is important to note that exposure duration is based on continual heavy truck operation along
nearby roadways. Exposure through inhalation (Dose‐air) is a function of breathing rate,
exposure frequency, and concentration of substance in the air. To estimate cancer risk, the dose
was estimated by applying the following formula to each ground‐level concentration:
Dose-air = Cair*(BR/BW)*A*EF*10-6
Dose-air = dose through inhalation (mg/kg/day)
Cair = air concentration (μg/m3) from air dispersion model
(DBR/BW) = daily breathing rate normalized to body weight (L/kg bodyweight-day)
A = inhalation absorption factor (unitless)
EF = exposure frequency (approximately 350 days per year for residential)
10-6 = conversion factor (micrograms to milligrams, liters to cubic meters)
OEHHA developed ASFs to consider the increased sensitivity to carcinogens during early‐life
exposure. Fraction of time at home (FAH) during the day is used to adjust exposure duration and
cancer risk from a specific facility’s emissions, based on the assumption that exposure to the
facility’s emissions are not occurring away from home.
To estimate the cancer risk, the dose is multiplied by the cancer potency factor, the ASF, the
exposure duration divided by averaging time, and the frequency of time spent at home
(for residents only):
Riskinh‐res = (Doseair*CPF*ASF*(ED/AT)*FAH)
Riskinh-res = residential inhalation cancer risk (potential chances per million)
Doseair = daily dose through inhalation (mg/kg-day)
CPF = inhalation cancer potency factor (mg/kg-day-1)
ASF = age sensitivity factor for a specified age group (unitless)
ED = exposure duration (years)
AT = averaging time of lifetime cancer risk (years)
FAH = fraction of time spent at home (unitless)
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Chronic Non‐Cancer Hazard
Non‐cancer chronic impacts are calculated by dividing the annual average concentration by the
REL for that substance. The REL is defined as the concentration at which no adverse non‐cancer
health effects are anticipated. The following equation was used to determine the non‐cancer risk:
Hazard Quotient = Ci/RELi
Ci = concentration in the air of substance i (annual average concentration in μg/m3)
RELi = chronic noncancer Reference Exposure Level for substance (μg/m3)
Acute Non-Cancer Hazard
The potential for acute non-cancer hazards is evaluated by comparing the maximum short-term
exposure level to an acute REL. RELs are designed to protect sensitive individuals within the
population. The calculation of acute non-cancer impacts is similar to the procedure for chronic
non-cancer impacts. The equation is as follows:
Acute HQ = Maximum Hourly Air Concentration (μg/m3) / Acute REL (μg/m3)
Health Risk Computation
A health risk computation was performed to determine the risk of developing an excess cancer
risk calculated on a 30‐year exposure scenario using CARB’s Risk Assessment Stand Alone Tool
(RAST). Health risk were analyzed at the point of maximum impact and are a conservative
estimate. The pollutant concentrations are then used to estimate the long-term cancer health
risk to an individual as well as the non-cancer chronic health index.
The off-site impacts would occur from the diesel trucks accessing the proposed Project. The
cancer and chronic health risks are based on the annual average concentration of PM10 (used as
a proxy for DPM). As DPM does not have short-term toxicity values, acute risks were
conservatively evaluated using hourly PM10 concentrations and the REL for acrolein. The chronic
and carcinogenic health risk calculations are based on the standardized equations contained in
the U.S. EPA Human Health Evaluation Manual (1991) and the OEHHA Guidance Manual (2015).
Potential Health Risk Impacts
CARB identified DPM as a TAC in 1998. Mobile sources (including trucks, buses, automobiles,
trains, ships, and farm equipment) are by far the largest source of diesel emissions. The exhaust
from diesel engines includes hundreds of different gaseous and particulate components, many
of which are toxic. Diesel exhaust is composed of two phases, either gas or particulate – both
contribute to the risk. The gas phase is composed of many of the urban TACs, such as
acetaldehyde, acrolein, benzene, 1,3‐butadiene, formaldehyde, and polycyclic aromatic
hydrocarbons. The particulate phase has many different types that can be classified by size or
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composition. The sizes of diesel particulates of greatest health concern are fine and ultrafine
particles. These particles may be composed of elemental carbon with adsorbed compounds such
as organics, sulfates, nitrates, metals, and other trace elements. Diesel exhaust is emitted from
a broad range of on‐ and off‐road diesel engines. As the Project is proposed near existing
residences, an analysis of DPM was performed using the U.S. EPA‐approved AERMOD model.
Carcinogenic Risk
Vehicle DPM emissions were estimated using emission factors for course particulate matter less
than 10 microns in diameter (PM10) generated with the EMFAC developed by CARB. EMFAC is a
mathematical model that was developed to calculate emission rates from motor vehicles that
operate on highways, freeways, and local roads in California and is commonly used by CARB to
project changes in future emissions from on‐road mobile sources. EMFAC, incorporates regional
motor vehicle data, information and estimates regarding the distribution of vehicle miles traveled
(VMT) by speed, and number of starts per day. The model includes the emissions benefits of the
truck and bus rule and the previously adopted rules for other on‐road diesel equipment.
For this Project, annual average PM10 emission factors were generated by running EMFAC for
vehicles in the SCAQMD within the South Coast portion of San Bernardino County. EMFAC
generates emission factors in terms of grams of pollutant emitted per vehicle activity and can
calculate a matrix of emission factors at specific values of vehicle speed, temperature, and
relative humidity. The model was run for vehicles traveling along SR-210.
The pollutant concentrations modeled in AERMOD represent the exposure levels outdoors.
OEHHA conservatively does not include indoor exposure adjustments for residents. However, the
typical person spends the majority of time indoors rather than remaining outdoors in the same
location for 24 hours a day.7 Therefore, the AERMOD outdoor pollutant concentrations are not
representative of actual exposure at the project site. CCR Title 24 Part 6 requires new
development to use MERV 13 air filtration on space conditioning systems and ventilation systems
that provide outside air to the occupiable space of a dwelling. A MERV 13 filter has a particle
removal efficiency in the range of 80-90 percent. An 80 percent removal efficiency was
conservatively used for the purposes of this study. According to the U.S. EPA’s Exposure Factor
Handbook (2011), on average, people spend 90 percent of their time indoors. As residents are
not always indoors, the filtration’s overall effectiveness accounts for the time spent outdoors,
which equates to approximately three hours per day. It is noted that this is a conservative
assumption for this Project, as all of the time spent outdoors would not occur at the Project site.
7 California Air Resources Board Research Division and University of California, Berkeley, Activity Patterns of California Residents, May 1991. The
study indicates that on average, adults and adolescents in California spent almost 15 hours per day inside their homes, and 6 hours in other
indoor locations, for a total of 21 hours (87% of the day). Approximately two hours per day were spent in transit, and just over one hour per
day was spent in outdoor locations.
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Based on the AERMOD outputs, the highest expected annual average diesel PM10 emission
concentrations from diesel truck traffic at the closest residential receptor on the project site
would be 0.0378 µg/m3 during opening year. The Project’s MERV 13 air filtration systems have
an average particle size removal efficiency of approximately 75 percent for 0.3 to 1.0 µg/m3
(DPM) and 90 percent for 1.0 to 10 µg/m3 (PM10 and PM2.5) based on ASHRAE Standard 52.2. The
filters would be installed in residential units prior to occupancy, and maintenance with filters of
the same value would be included in the Project’s operation and maintenance manual. The
Project’s MERV 13 air filtration systems would reduce the highest expected annual average diesel
PM10 emission concentrations conservatively by 75 percent to 0.00945 µg/m3 during opening
year. The highest expected hourly TOG emission concentrations from automobile traffic at the
Project site would be 0.8498 μg/m3 (no reduction was applied to TOG concentrations).
Table 7, Carcinogenic Risk Assessment Results shows the calculated carcinogenic risk at the
Project site from DPM and TOG due to freeway emissions is 9.92 per million for residents.
Therefore, the carcinogenic risk associated with the Project would be less than significant.
Table 7: Carcinogenic Risk Assessment Results
Exposure Scenario Maximum Cancer Risk
(Risk per Million)1, 2
Significance Threshold
(Risk per Million)
Exceeds Significance
Threshold?
Residents 9.92 10 No
1. Refer to Appendix A: Modeling Data.
2. The maximum cancer would be experienced onsite would be located along the southern edge of the Project site based on worst-case
exposure durations for the Project, 95th percentile breathing rates, and 30-year averaging time.
Non‐Carcinogenic Hazards
The significance thresholds for TAC exposure also require an evaluation of non‐cancer risk known
as hazard index. Non‐cancer chronic impacts are calculated by dividing the annual average
concentration by the REL for that substance. The REL is defined as the concentration at which no
adverse non‐cancer health effects are anticipated. The potential for acute non‐cancer hazards is
evaluated by comparing the maximum short‐term exposure level to an acute REL. RELs are
designed to protect sensitive receptors. The calculation of acute non‐cancer impacts is similar to
the procedure for chronic non‐cancer impacts.
Acute and chronic impacts are shown in Table 8, Chronic and Acute Hazards. An acute or chronic
hazard index of 1.0 is considered individually significant. The hazard index is calculated by dividing
the acute or chronic exposure by the reference exposure level. The highest maximum chronic
and acute hazard index associated with both DPM and TOG emissions at the Project site would
be 0.01 and 0.005, respectively. Therefore, non‐carcinogenic hazards are within acceptable limits
and less than significant.
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Table 8: Chronic and Acute Hazards
Emissions Source Chronic Hazard Acute Hazard
I-210 Freeway 0.01 0.05
SCAQMD Threshold 1.0 1.0
Threshold Exceeded? No No
Refer to Appendix A: Modeling Data of the Air Quality Assessment.
Impact Analysis
EIR Impact 3.2-1: Would the project conflict with or obstruct implementation of the
applicable air quality plan?
EIR Impact 3.2-2: Would the project violate any air quality standard or contribute
substantially to an existing or projected air quality violation. [No longer
included in CEQA Appendix G Thresholds]
No New or More Severe Impact: As part of its enforcement responsibilities, the U.S. EPA requires
each state with nonattainment areas to prepare and submit a State Implementation Plan (SIP)
that demonstrates the means to attain the federal standards. The State Implementation Plan
must integrate federal, state, and local plan components and regulations to identify specific
measures to reduce pollution in nonattainment areas, using a combination of performance
standards and market-based programs. Similarly, under State law, the California Clean Air Act
requires an air quality attainment plan to be prepared for areas designated as nonattainment
regarding the state and federal ambient air quality standards. Air quality attainment plans outline
emissions limits and control measures to achieve and maintain these standards by the earliest
practical date.
The Project is located within the SoCAB, which is under the jurisdiction of the SCAQMD. The
SCAQMD is required, pursuant to the Federal Clean Air Act (FCAA), to reduce emissions of criteria
pollutants for which the SoCAB is in nonattainment. To reduce such emissions, the SCAQMD
drafted the 2016 AQMP. The 2016 AQMP establishes a program of rules and regulations directed
at reducing air pollutant emissions and achieving state (California) and national air quality
standards. The 2016 AQMP is a regional and multi-agency effort including the SCAQMD, the
CARB, the SCAG, and the U.S. EPA. The plan’s pollutant control strategies are based on the latest
scientific and technical information and planning assumptions, including SCAG’s growth
projections and RTP/SCS, updated emission inventory methodologies for various source
categories, and SCAG’s latest growth forecasts. SCAG’s latest growth forecasts were defined in
consultation with local governments and with reference to local general plans. The Project is
subject to the SCAQMD’s AQMP.
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Criteria for determining consistency with the AQMP are defined by the following indicators:
• Consistency Criterion No. 1: The Project will not result in an increase in the frequency or
severity of existing air quality violations, or cause or contribute to new violations, or delay
the timely attainment of air quality standards or the interim emissions reductions
specified in the AQMP.
• Consistency Criterion No. 2: The Project will not exceed the assumptions in the AQMP or
increments based on the years of the Project build-out phase.
According to the SCAQMD’s CEQA Air Quality Handbook, the purpose of the consistency finding
is to determine if a project is inconsistent with the assumptions and objectives of the regional air
quality plans, and thus if it would interfere with the region’s ability to comply with CAAQS and
NAAQS.
The violations to which Consistency Criterion No. 1 refers are CAAQS and NAAQS. As shown in
Table 9 and Table 10 below, the Project would not exceed the construction and operation
emission standards set by SCAQMD. Thus, the project would be consistent with the first criterion.
Table 9: Construction-Related Emissions
Construction Year
Maximum Pounds Per Day
Reactive
Organic
Gases
(ROG)
Nitrogen
Oxide
(NOx)
Carbon
Monoxide
(CO)
Sulfur
Dioxide
(SO2)
Coarse
Particulate
Matter
(PM10)
Fine
Particulate
Matter
(PM2.5)
2022 4.10 53.81 33.57 0.13 10.21 5.85
2023 17.18 46.64 39.91 0.12 7.47 3.53
SCAQMD Threshold 75 100 550 150 150 55
Exceed SCAQMD
Threshold? No No No No No No
Notes: SCAQMD Rule 403 Fugitive Dust applied. The Rule 403 reduction/credits include the following: properly maintain mobile and other
construction equipment; replace ground cover in disturbed areas quickly; water exposed surfaces three times daily; cover stock piles with
tarps; water all haul roads twice daily; and limit speeds on unpaved roads to 15 miles per hour. Reductions percentages from the SCAQMD
CEQA Handbook (Tables XI-A through XI-E) were applied. No mitigation was applied to construction equipment. Refer to Appendix A for Model
Data Outputs.
Source: CalEEMod version 2020.4.0. Refer to Appendix A in the Air Quality Assessment for model outputs.
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Table 10: Operational Emissions
Source
Maximum Pounds Per Day
Reactive
Organic Gases
(ROG)
Nitrogen
Oxide
(NOx)
Carbon
Monoxide
(CO)
Sulfur
Dioxide
(SO2)
Coarse
Particulate
Matter
(PM10)
Fine
Particulate
Matter
(PM2.5)
Area Source Emissions 3.68 2.08 12.64 0.01 0.22 0.22
Energy Emissions 0.09 0.76 0.32 <0.01 0.06 0.06
Mobile Emissions 3.46 4.72 33.88 0.07 7.61 2.07
Total Emissions 7.23 7.56 46.84 0.08 7.89 2.35
SCAQMD Threshold 55 55 550 150 150 55
Exceeds SCAQMD
Threshold? No No No No No No
Source: CalEEMod version 2020.4.0. Refer to Appendix A in the Air Quality Assessment for model outputs.
Concerning Consistency Criterion No. 2, the AQMP contains air pollutant reduction strategies
based on SCAG’s latest growth forecasts, and SCAG’s growth forecasts were defined in
consultation with local governments and with reference to local general plans. The Project site is
designated as Multi-Family Residential (R-MF). The Project is consistent with the City’s General
Plan Land Use Designations and the Zoning Designations and would not require a General Plan
Amendment (GPA) or a Zone Change. As such, the Project is consistent with SCAG’s latest growth
forecasts. Thus, the Project is consistent with the second criterion. The Project would be
consistent with both criterion and thus impacts would be less than significant, and no mitigation
measure required. Therefore, the Project would not create a new or more severe impact than
previously analyzed in the LCA in this regard.
Mitigation Program
Mitigation Measure from the LCA EIR
• Mitigation 3.2-2: Prior to the issuance of grading permits, the proposed project shall
include a dust control plan as part of the construction contract standard specifications.
The dust control plan shall include measures to meet the requirements of SCAQMD
Rules 402 and 403. Such measures shall include, but are not limited to, the following:
▪ Attempt to phase and schedule activities to avoid operation on high-ozone days and
first-stage smog alerts.
▪ Discontinue operation during second-stage smog alerts.
▪ Cover haul trucks prior to leaving the site to prevent dust from impacting the
surrounding areas.
▪ Comply with AQMD Rule 403, particularly to minimize fugitive dust impacts to
surrounding areas.
▪ Moisten soil each day prior to commencing grading to depth of soil cut.
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▪ Water exposed surfaces at least twice a day under calm conditions, and as often as
needed on windy days or during very dry weather in order to maintain a surface crust
and minimize the release of visible emissions from the construction site.
▪ Treat any area that will be exposed for extended periods with a soil conditioner to
stabilize soil or temporarily plant with vegetation.
▪ Wash mud-covered tires and undercarriages of trucks leaving construction sites.
▪ Provide street sweeping, as needed, on adjacent roadways to remove dirt dropped by
construction vehicles or mud that would otherwise be carried off by trucks departing
project sites.
▪ Securely cover all loads of fill coming to the site with a tight-fitting tarpaulin.
▪ Cease grading during periods when winds exceed 25 miles per hour.
▪ Permanently seal all graded areas, as applicable, at the earliest practicable time after
soil disturbance.
▪ Maintain construction equipment in peak operating condition so as to reduce
operating missions.
▪ Use low-sulfur diesel fuel in all equipment.
▪ Use electric equipment whenever practicable.
▪ Shut off engines when not in use.
Mitigation Measures from the 2007 Air Quality Assessment (AQA)
AQ-1: During clearing, grading, earth moving, or excavation operations, excessive
fugitive dust emissions shall be controlled by regular watering or other dust
preventive measures using the following procedures, as specified in the South
Coast Air Quality Management District’s Rules and Regulations.
• All material excavated or graded shall be sufficiently watered to prevent
excessive amounts of dust. Watering shall occur at least twice daily with
complete coverage, preferably in the morning and after work is done for the
day.
• All material transported on-site or off-site shall be either sufficiently watered
or securely covered to prevent excessive amounts of dust.
• The area disturbed by clearing, grading, earth moving, or excavation
operations shall be minimized so as to prevent excessive amounts of dust.
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• These control techniques shall be indicated in the Project specifications.
Compliance with this measure shall be subject to periodic site inspections by
the City.
• Visible dust beyond the property line emanating from the Project shall be
prevented to the maximum extent feasible.
AQ-2: Project grading plans shall show the duration of construction. Ozone precursor
emissions from construction equipment vehicles shall be controlled by
maintaining equipment engines in good condition and in proper tune per
manufacturer’s specifications, to the satisfaction of the City Engineer. Compliance
with this measure shall be subject to periodic inspections of construction
equipment vehicles by the County.
AQ-3: All trucks that are to haul excavated or graded material on-site shall comply with
State Vehicle Code Section 23114, with special attention to Sections 23114(b)(F),
(e)(2) and (e)(4) as amended, regarding the prevention of such material spilling
onto public streets and roads.
AQ-4: Prior to approval of the project plans and specifications, the Planning Division shall
confirm that the construction bid packages specify:
• Contractors shall use high pressure low volume (HPLV) paint applicators with
a minimum transfer efficiency of at least 50 percent.
• Coatings and solvents that will be utilized have VOC content lower than
required under SCAQMD Rule 1113; and
• To the extent feasible, construction/building with materials shall be composed
of pre-painted materials.
Conclusion
The Project would result in no new or more severe impact pertaining to conflict with or
obstructing implementation of the AQMP. Although impacts identified within the certified LCA
EIR were found to be significant and unavoidable with no mitigation found feasible, the Project’s
would not result in new or more severe impacts pertaining to conflict with or obstruction of the
implementation of the AQMP. Further, the Project would not exceed relevant thresholds of
significance. Therefore, no new or more severe impacts relative to air quality emissions from the
previously identified significant impact evaluated in the LCA EIR would occur with
implementation of the Project and identified mitigation measures from the LCA EIR. Additionally,
no new information of substantial importance that was not known and could not have been
known at the time the LCA EIR was certified is available that would change the significance
determination in the LCA EIR.
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EIR Impact 3.2-3: Would the project result in a cumulatively considerable net increase of any
criteria pollutant for which the project region is in non-attainment under
an applicable Federal or state ambient air quality standard (including
releasing emissions which exceed quantitative thresholds for ozone
precursors)?
Construction Emissions
No New or More Severe Impact: Construction associated with the Project would generate short-
term emissions of criteria air pollutants. The criteria pollutants of primary concern within the
Project area include O3-precursor pollutants (i.e., ROG and NOX) and PM10 and PM2.5.
Construction-generated emissions are short term and of temporary duration, lasting only as long
as construction activities occur, but would be considered a significant air quality impact if the
volume of pollutants generated exceeds the SCAQMD’s thresholds of significance. Construction
associated with the Project would generate short-term emissions of criteria air pollutants. The
criteria pollutants of primary concern within the Project area include O3-precursor pollutants
(i.e., ROG and NOX) and PM10 and PM2.5. Construction-generated emissions are short term and of
temporary duration, lasting only as long as construction activities occur, but would be considered
a significant air quality impact if the volume of pollutants generated exceeds the SCAQMD’s
thresholds of significance.
Construction results in the temporary generation of emissions resulting from site grading, road
paving, motor vehicle exhaust associated with construction equipment and worker trips, and the
movement of construction equipment, especially on unpaved surfaces. Emissions of airborne
particulate matter are largely dependent on the amount of ground disturbance associated with
site preparation activities as well as weather conditions and the appropriate application of water.
The duration of construction activities associated with the Project is estimated to last
approximately 12 months. Construction-generated emissions associated the Project were
calculated using the CARB-approved CalEEMod computer program, which is designed to model
emissions for land use development projects, based on typical construction requirements. See
Appendix A: Air Quality Modeling Data of the Air Quality Assessment for more information
regarding the construction assumptions used in this analysis. Predicted maximum daily
construction-generated emissions for the Project are summarized in Table 9 above.
Fugitive dust emissions may have a substantial, temporary impact on local air quality. In addition,
fugitive dust may be a nuisance to those living and working in the Project vicinity. Uncontrolled
dust from construction can become a nuisance and potential health hazard to those living and
working nearby. SCAQMD Rules 402 and 403 (prohibition of nuisances, watering of inactive and
perimeter areas, track out requirements, etc.), are applicable to the Project and were applied in
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CalEEMod to minimize fugitive dust emissions. Standard Condition (SC) AQ-1 requires the
implementation of Rule 402 and 403 dust control techniques to minimize PM10 and PM2.5
concentrations. While impacts would be considered less than significant, Project would be
subject to SCAQMD Rules for reducing fugitive dust, described in the Regulatory Framework
subsection above and identified in SC AQ-1.
As shown in Table 9 above, all criteria pollutant emissions would remain below their respective
thresholds. While impacts would be considered less than significant, the Project would be subject
to SCAQMD Rules 402, 403, and 1113, described in the Regulatory Framework subsection above
and required by SC AQ-1.
Operational Emissions
The Project’s operational emissions would be associated with area sources (i.e., landscape
maintenance equipment, architectural coatings, off-road equipment, etc.), energy sources,
mobile sources (i.e., motor vehicle use), and off-road equipment. Primary sources of operational
criteria pollutants are from motor vehicle use and area sources. Long-term operational emissions
attributable to the Project are summarized in Table 10 above. The operational emissions sources
are described below.
• Area Source Emissions. Area source emissions would be generated due to on-site
equipment, architectural coating, and landscaping that were previously not present on
the site.
• Energy Source Emissions. Energy source emissions would be generated due to electricity
and natural gas usage associated with the Project. Primary uses of electricity and natural
gas by the Project would be for space heating and cooling, water heating, ventilation,
lighting, appliances, and electronics.
• Mobile Source. Mobile sources are emissions from motor vehicles, including tailpipe and
evaporative emissions. Depending upon the pollutant being discussed, the potential air
quality impact may be of either regional or local concern. For example, ROG, NOX, PM10,
and PM2.5 are all pollutants of regional concern. NOX and ROG react with sunlight to form
O3, known as photochemical smog. Additionally, wind currents readily transport PM10 and
PM2.5. However, CO tends to be a localized pollutant, dispersing rapidly at the source.
Project-generated vehicle emissions are based on the trip generation within the Project
Traffic Impact Study and incorporated into CalEEMod as recommended by the SCAQMD.
Based on the trip rates from the Traffic Impact Study, the Project would generate
1,047 daily trips.
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As shown in Table 10 above, all criteria pollutant emissions would remain below their respective
thresholds during Project operations. Therefore, the Project would result in a less than significant
impact.
Cumulative Construction Emissions
The SoCAB is designated nonattainment for O3, PM10, and PM2.5 for State standards and
nonattainment for O3 and PM2.5 for Federal standards. Appendix D of the SCAQMD White Paper
on Potential Control Strategies to Address Cumulative Impacts from Air Pollution (2003) notes
that projects that result in emissions that do not exceed the project-specific SCAQMD regional
thresholds of significance should result in a less than significant impact on a cumulative basis
unless there is other pertinent information to the contrary. The mass-based regional significance
thresholds published by the SCAQMD are designed to ensure compliance with both NAAQS and
CAAQS and are based on an inventory of projected emissions in the SoCAB. Therefore, if a project
is estimated to result in emissions that do not exceed the thresholds, the project’s contribution
to the cumulative impact on air quality in the SoCAB would not be cumulatively considerable. As
shown in Table 9 above, Project construction-related emissions by themselves would not exceed
the SCAQMD significance thresholds for criteria pollutants. Therefore, the proposed Project
would not generate a cumulatively considerable contribution to air pollutant emissions during
construction.
The SCAQMD has developed strategies to reduce criteria pollutant emissions outlined in the
AQMP pursuant to the FCAA mandates. The analysis assumed fugitive dust controls would be
utilized during construction, including frequent water applications. SCAQMD rules, mandates,
and compliance with adopted AQMP emissions control measures would also be imposed on
construction projects throughout the SoCAB, which would include related projects. Compliance
with SCAQMD rules and regulations would further reduce the Project construction-related
impacts. Therefore, Project-related construction emissions, combined with those from other
projects in the area, would not substantially deteriorate local air quality. Construction emissions
associated with the Project would not result in a cumulatively considerable contribution to
significant cumulative air quality impacts.
Cumulative Operational Impacts
The SCAQMD has not established separate significance thresholds for cumulative operational
emissions. The nature of air emissions is largely a cumulative impact. As a result, no single project
is sufficient in size to, by itself, result in nonattainment of ambient air quality standards. Instead,
individual project emissions contribute to existing cumulatively significant adverse air quality
impacts. The SCAQMD developed the operational thresholds of significance based on the level
above which individual project emissions would result in a cumulatively considerable
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contribution to the SoCAB’s existing air quality conditions. Therefore, a project that exceeds the
SCAQMD operational thresholds would also be a cumulatively considerable contribution to a
significant cumulative impact.
As shown in Table 10 above, the Project operational emissions from mobile sources alone would
not exceed the SCAQMD thresholds. Therefore, the Project would not substantially deteriorate
local air quality in its operational phase.
Standard Conditions and Requirements:
SC AQ-1 Prior to the issuance of grading permits, the City Engineer shall confirm that the
Grading Plan, Building Plans and Specifications require all construction contractors to
comply with South Coast Air Quality Management District’s (SCAQMD’s) Rules 402
and 403 to minimize construction emissions of dust and particulates. The measures
include, but are not limited to, the following:
• Portions of a construction site to remain inactive longer than a period of three
months will be seeded and watered until grass cover is grown or otherwise
stabilized.
• All on-site roads will be paved as soon as feasible or watered periodically or
chemically stabilized.
• All material transported off-site will be either sufficiently watered or securely
covered to prevent excessive amounts of dust.
• The area disturbed by clearing, grading, earthmoving, or excavation operations
will be minimized at all times.
• Where vehicles leave a construction site and enter adjacent public streets, the
streets will be swept daily or washed down at the end of the work day to remove
soil tracked onto the paved surface.
Mitigation Program
Mitigation Measures from the LCA EIR
See Mitigation Measures 3.2-2 and 2007 AQA AQ-1 through AQ-4 from the LCA EIR above.
Conclusion
Air quality impacts related to the Project are within the limit of impacts identified by the
SCAQMD. No new impact relative to air quality or a substantial increase in the severity of a
previously identified significant impact evaluated in the LCA EIR would occur. Additionally, no
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new information of substantial importance that was not known and could not have been known
at the time the LCA EIR was certified is available that would alter the LCA EIR’s significance finding.
EIR Impact 3.2-4: Would the project expose sensitive receptors to substantial pollutant
concentrations?
No New or More Severe Impact:
Localized Construction Significance Analysis
The nearest sensitive receptors are the single-family residences located approximately 60 feet
(18 meters) to the east and west of the Project. To identify impacts to sensitive receptors, the
SCAQMD recommends addressing LSTs for construction. LSTs were developed in response to
SCAQMD Governing Boards' Environmental Justice Enhancement Initiative (I-4). The SCAQMD
provided the Final Localized Significance Threshold Methodology (dated June 2003
[revised 2008]) for guidance. The LST methodology assists lead agencies in analyzing localized
impacts associated with Project-specific emissions.
Since CalEEMod calculates construction emissions based on the number of equipment hours and
the maximum daily soil disturbance activity possible for each piece of equipment, Table 11,
Equipment-Specific Grading Rates, is used to determine the maximum daily disturbed acreage
for comparison to LSTs. The appropriate SRA for the localized significance thresholds is the
Central San Bernardino Valley (SRA 34) since this area includes the Project. LSTs apply to CO, NO2,
PM10, and PM2.5. The SCAQMD produced look-up tables for projects that disturb areas less than
or equal to five acres in size. Project construction is anticipated to disturb a maximum of 4.0 acres
in a single day.
Table 11: Equipment-Specific Grading Rates
Construction
Phase
Equipment
Type
Equipment
Quantity
Acres Graded
per 8-Hour Day
Operating
Hours
per Day
Acres Graded
per Day
Grading
Scrapers 2 1 8 2.0
Graders 1 0.5 8 0.5
Rubber Tired Dozers 1 0.5 8 0.5
Tractors/Loaders/Backhoes 2 0.5 8 1.0
Total Acres Graded per Day 4.0
Source: CalEEMod version 2020.4.0. Refer to Appendix A of the Air Quality Assessment for model outputs.
The SCAQMD’s methodology states that “off-site mobile emissions from the Project should not
be included in the emissions compared to LSTs.” Therefore, only emissions included in the
CalEEMod “on-site” emissions outputs were considered. The nearest sensitive receptors are the
single-family residences located 60 feet (18 meters) to the east and west of the Project site. LST
thresholds are provided for distances to sensitive receptors of 25, 50, 100, 200, and 500 meters.
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Therefore, LSTs for receptors located at 25 meters were utilized in this analysis. Table 12,
Localized Significance of Construction Emissions, presents the results of localized emissions
during construction.
Table 12: Localized Significance of Construction Emissions
Construction Activity
(Maximum Pounds Per Day)
Nitrogen
Oxide
(NOx)
Carbon
Monoxide
(CO)
Coarse
Particulate
Matter
(PM10)
Fine
Particulate
Matter
(PM2.5)
Site Preparation (2022) 33.08 19.70 10.02 5.80
Grading (2022) 38.84 29.04 5.61 3.07
Grading (2023) 34.52 28.05 5.40 2.88
Building Construction (2023) 14.38 16.24 0.70 0.66
Paving (2023) 10.19 14.58 0.51 0.47
Architectural Coating (2023) 1.30 1.81 0.07 0.07
Maximum Daily Emissions 38.84 29.04 10.02 5.80
SCAQMD Localized Screening Threshold
(4 acres at 25 meters) 237 1,488 12 7
Exceed SCAQMD Threshold? No No No No
Source: CalEEMod version 2020.4.0. Refer to Appendix A of the Air Quality Assessment for model outputs.
Table 12 shows that emissions of these pollutants on the peak day of construction would not
result in significant concentrations of pollutants at nearby sensitive receptors. Significant impacts
would not occur concerning LSTs during construction.
Localized Operational Significance Analysis
According to the SCAQMD LST methodology, LSTs would apply to the operational phase of a
project only if it includes stationary sources or attracts mobile sources that may spend long
periods queuing and idling at the site (i.e., warehouse or transfer facilities). Since the Project is a
residential area, the operational phase LST protocol is conservatively applied to both the area
source and all the mobile source emissions. As the nearest receptors are located approximately
60 feet (18 meters) from the Project site, LSTs for receptors located at 25 meters for SRA 34 were
used in this analysis. Although the Project is 10.3-acres, the five-acre LST threshold was
conservatively for the Project, as the LSTs increase with the size of the site.
The LST analysis only includes on-site sources. However, the CalEEMod model outputs do not
separate on- and off-site emissions for mobile sources. For a worst-case scenario assessment,
the emissions shown in Table 13, Localized Significance of Operation Emissions, conservatively
include all on-site Project-related stationary sources and five percent of the Project-related
vehicle emissions since a portion of mobile sources would include vehicles maneuvering and
idling on-site. Table 13 shows that the maximum daily emissions of these pollutants during
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operations would not result in significant concentrations of NOx, CO, PM10 or PM2.5 pollutants at
nearby sensitive receptors. Therefore, significant impacts would not occur concerning LSTs
during operational activities.
Table 13: Localized Significance of Operational Emissions
Activity
(Maximum Pounds Per Day)
Nitrogen
Oxide
(NOx)
Carbon
Monoxide
(CO)
Coarse
Particulate
Matter
(PM10)
Fine
Particulate
Matter
(PM2.5)
On-site and Mobile Source Emissions 2.32 14.15 0.60 0.32
SCAQMD Localized Screening Threshold
(5 acres at 25 meters) 270 1,746 4 2
Exceed SCAQMD Threshold? No No No No
Source: CalEEMod version 2020.4.0. Refer to Appendix A of the Air Quality Assessment for model outputs.
Criteria Pollutant Health Impacts
On December 24, 2018, the California Supreme Court issued an opinion identifying the need to
provide sufficient information connecting a project’s air emissions to health impacts or explain
why such information could not be ascertained (Sierra Club v. County of Fresno [Friant Ranch,
L.P.] [2018] Cal. 5th, Case No. S219783). The SCAQMD has set its CEQA significance thresholds
based on the FCAA, which defines a major stationary source (in extreme ozone nonattainment
areas such as the South Coast Air Basin) as emitting 10 tons per year. The thresholds correlate
with the trigger levels for the federal New Source Review (NSR) Program and SCAQMD Rule 1303
for new or modified sources. The NSR Program8 was created by the FCAA to ensure that
stationary sources of air pollution are constructed or modified in a manner that is consistent with
attainment of health-based federal ambient air quality standards. The federal ambient air quality
standards establish the levels of air quality necessary, with an adequate margin of safety, to
protect the public health. Therefore, projects that do not exceed the SCAQMD’s LSTs and mass
emissions thresholds would not violate any air quality standards or contribute substantially to an
existing or projected air quality violation and no criteria pollutant health impacts.
NOX and ROG are precursor emissions that form ozone in the atmosphere in the presence of
sunlight where the pollutants undergo complex chemical reactions. It takes time and the
influence of meteorological conditions for these reactions to occur, so ozone may be formed at
a distance downwind from the sources. Breathing ground-level ozone can result health effects
that include; reduced lung function, inflammation of airways, throat irritation, pain, burning, or
discomfort in the chest when taking a deep breath, chest tightness, wheezing, or shortness of
8 Code of Federal Regulation (CFR) [i.e., PSD (40 CFR 52.21, 40 CFR 51.166, 40 CFR 51.165 (b)), Non-attainment NSR (40 CFR 52.24, 40 CFR 51.165,
40 CFR part 51, Appendix S)
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breath. In addition to these effects, evidence from observational studies strongly indicates that
higher daily ozone concentrations are associated with increased asthma attacks, increased
hospital admissions, increased daily mortality, and other markers of morbidity. The consistency
and coherence of the evidence for effects upon asthmatics suggests that ozone can make asthma
symptoms worse and can increase sensitivity to asthma triggers.
According the SCAQMD’s 2016 AQMP, ozone, NOX, and ROG have been decreasing in the Basin
since 1975 and are projected to continue to decrease in the future. Although vehicle miles
traveled in the Basin continue to increase, NOX and ROG levels are decreasing because of the
mandated controls on motor vehicles and the replacement of older polluting vehicles with lower-
emitting vehicles. NOX emissions from electric utilities have also decreased due to the use of
cleaner fuels and renewable energy. The 2016 AQMP demonstrates how the SCAQMD’s control
strategy to meet the 8-hour ozone standard in 2023 would lead to sufficient NOX emission
reductions to attain the 1-hour ozone standard by 2022. In addition, since NOX emissions also
lead to the formation of PM2.5, the NOX reductions needed to meet the ozone standards will
likewise lead to improvement of PM2.5 levels and attainment of PM2.5 standards.
The SCAQMD’s air quality modeling demonstrates that NOX reductions prove to be much more
effective in reducing ozone levels and will also lead to significant improvement in PM2.5
concentrations. NOX-emitting stationary sources regulated by the SCAQMD include Regional
Clean Air Incentives Market (RECLAIM) facilities (e.g., refineries, power plants, etc.), natural gas
combustion equipment (e.g., boilers, heaters, engines, burners, flares) and other combustion
sources that burn wood or propane. The 2016 AQMP identifies robust NOX reductions from new
regulations on RECLAIM facilities, non-refinery flares, commercial cooking, and residential and
commercial appliances. Such combustion sources are already heavily regulated with the lowest
NOX emissions levels achievable but there are opportunities to require and accelerate
replacement with cleaner zero-emission alternatives, such as residential and commercial
furnaces, pool heaters, and backup power equipment. The AQMD plans to achieve such
replacements through a combination of regulations and incentives. Technology-forcing
regulations can drive development and commercialization of clean technologies, with future year
requirements for new or existing equipment. Incentives can then accelerate deployment and
enhance public acceptability of new technologies.
The 2016 AQMP also emphasizes that beginning in 2012, continued implementation of previously
adopted regulations will lead to NOX emission reductions of 68 percent by 2023 and 80 percent
by 2031. With the addition of 2016 AQMP proposed regulatory measures, a 30 percent reduction
of NOX from stationary sources is expected in the 15-year period between 2008 and 2023. This is
in addition to significant NOX reductions from stationary sources achieved in the decades prior
to 2008.
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As previously discussed, localized effects of on-site Project emissions on nearby receptors were
found to be less than significant (refer to Table 12 and Table 13). The LSTs represent the
maximum emissions from a project that are not expected to cause or contribute to an
exceedance of the most stringent applicable state or federal ambient air quality standard. The
LSTs were developed by the SCAQMD based on the ambient concentrations of that pollutant for
each SRA and distance to the nearest sensitive receptor. The ambient air quality standards
establish the levels of air quality necessary, with an adequate margin of safety, to protect public
health, including protecting the health of sensitive populations. However, as discussed above,
neither the SCAQMD nor any other air district currently have methodologies that would provide
Lead Agencies and CEQA practitioners with a consistent, reliable, and meaningful analysis to
correlate specific health impacts that may result from a proposed project’s mass emissions.
Information on health impacts related to exposure to ozone and particulate matter emissions
published by the U.S. EPA and CARB have been summarized above and discussed in the
Regulatory Framework section. Health studies are used by these agencies to set the NAAQS and
CAAQS. Ozone concentrations are dependent upon a variety of complex factors, including the
presence of sunlight and precursor pollutants, natural topography, nearby structures that cause
building downwash, atmospheric stability, and wind patterns. Because of the complexities of
predicting ground-level ozone concentrations in relation to the NAAQS and CAAQS, none of the
health-related information can be directly correlated to the pounds/day or tons/year of
emissions estimated from a single, proposed project. Because it is impracticable to accurately
isolate the exact cause of a human disease (for example, the role a particular air pollutant plays
compared to the role of other allergens and genetics in cause asthma), the City has determined
that existing scientific tools cannot accurately estimate health impacts of the Project’s air
emissions without undue speculation. It should also be noted that this analysis identifies health
concerns related to NOX emissions. Thus, this analysis is reasonable and intended to foster
informed decision making.
Carbon Monoxide Hotspots
An analysis of CO “hot spots” is needed to determine whether the change in the level of service
of an intersection resulting from the Project would have the potential to result in exceedances of
the CAAQS or NAAQS. It has long been recognized that CO exceedances are caused by vehicular
emissions, primarily when vehicles are idling at intersections. Vehicle emissions standards have
become increasingly stringent in the last 20 years. Currently, the CO standard in California is a
maximum of 3.4 grams per mile for passenger cars (requirements for certain vehicles are more
stringent). With the turnover of older vehicles, introduction of cleaner fuels, and implementation
of control technology on industrial facilities, CO concentrations have steadily declined.
Accordingly, with the steadily decreasing CO emissions from vehicles, even very busy intersections
do not result in exceedances of the CO standard.
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The SoCAB was re-designated as attainment in 2007 and is no longer addressed in the SCAQMD’s
AQMP. The 2003 AQMP is the most recent version that addresses CO concentrations. As part of
the SCAQMD CO Hotspot Analysis, the Wilshire Boulevard/Veteran Avenue intersection, one of
the most congested intersections in Southern California with an average daily traffic (ADT)
volume of approximately 100,000 vehicles per day, was modeled for CO concentrations. This
modeling effort identified a CO concentration high of 4.6 ppm, which is well below the 35-ppm
Federal standard. The Project considered herein would not produce the volume of traffic
required to generate a CO hot spot in the context of SCAQMD’s CO Hotspot Analysis. As the
CO hotspots were not experienced at the Wilshire Boulevard/Veteran Avenue intersection even
as it accommodates 100,000 vehicles daily, it can be reasonably inferred that CO hotspots would
not be experienced at any vicinity intersections resulting from 1,047 additional vehicle trips
attributable to the Project. Therefore, impacts would be less than significant.
Mitigation Program
Mitigation Measures from the LCA EIR
See Mitigation Measures 3.2-2 and 2007 AQA AQ-1 through AQ-4 from the LCA EIR above.
Conclusion
Air quality impacts related to the Project are within the limit of impacts identified by the
SCAQMD. No new impact relative to air quality or a substantial increase in the severity of a
previously identified significant impact evaluated in the LCA EIR would occur. Additionally, no
new information of substantial importance that was not known and could not have been known
at the time the LCA EIR was certified is available that would alter the LCA EIR’s significance finding.
EIR Impact 3.2-5: Would the project create objectionable odors affecting a substantial
number of people?
The SCAQMD CEQA Air Quality Handbook identifies certain land uses as sources of odors. These
land uses include agriculture (farming and livestock), wastewater treatment plants, food
processing plants, chemical plants, composting facilities, refineries, landfills, dairies, and
fiberglass molding. The Project would not include any of the land uses that have been identified
by the SCAQMD as odor sources.
During construction-related activities, some odors (not substantial pollutant concentrations) that
may be detected are those typical of construction vehicles (i.e., diesel exhaust from grading and
construction equipment). These odors are a temporary short-term impact that is typical of
construction projects and would disperse rapidly. The Project would not include any of the land
uses that have been identified by the SCAQMD as odor sources. Therefore, the Project would not
create objectionable odors.
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Mitigation Program
Mitigation Measures from the Final EIR
None identified in the LCA EIR.
Conclusion
There are no new potentially significant impacts associated with the Project; therefore, no new
and/or refined mitigation measures are required for issues related to air quality.
7.2.3 Overall Air Quality Impact Conclusion
With regard to CEQA Statute Section 21166 and CEQA Guidelines Section 15162(a), the changes
proposed by the Project would not result in any new impacts, or increase the severity of the
previously identified impacts, with respect to air quality. Therefore, preparation of a SEIR is not
warranted.
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7.3 Biological Resources
7.3.1 Summary of Previous Environmental Analysis
A Biological Constraints Survey (BCS) was prepared by BonTerra Consulting (November 2001) in
connection with the LCA EIR for the LCA Project and included in Appendix D of the LCA EIR. The
BCS found that due to the site’s highly disturbed condition, the LCA site only contained ruderal
vegetation and no Special Status plant species were expected on site. In Addition, the LCA site
was found to be unsuitable habitats for potential wildlife, aquatic wildlife, and Delhi sands flower-
loving fly. During the survey, no nesting habitat or activity existed on the LCA site. The LCA EIR
concluded that no State or federally threatened or endangered plants or animals were expected
to occur on the LCA site and the implementation of the LCA Project would result in a less than
significant impact to no impact with regard to biological resources.
7.3.2 Analysis of Proposed Project
A Habitat Assessment Report was prepared for the Sobrato Project by ELMT Consulting
(October 2021), and a Biological Resources Records Search was prepared by Brian F. Smith and
Associates, Inc. (BFSA) (May 2021). The Habitat Assessment was conducted to document baseline
conditions and assess the potential for Special-Status plant and wildlife species to occur within
the Project boundaries that could pose a constraint to implementation of the Project. The ELMT
Report is included as Appendix D in this Addendum EIR and the results are summarized herein.
BFSA conducted a due diligence biological resources review of the proposed Sobrato Project
which includes Assessor’s Parcel Numbers (APNs) 1108-052-01 through -17. This due diligence
study focused upon the potential of the property to contain significant biological resources that
could represent a constraint to its development.
Methodology
A literature review and records search were conducted to determine which special-status
biological resources have the potential to occur on or within the general vicinity of the Project
site. In addition to the literature review, a general habitat assessment or field investigation of the
Project site was conducted to document existing conditions and assess the potential for special-
status biological resources to occur within the Project site.
Existing biological resource conditions within and adjacent to the Sobrato Project were initially
investigated through review of pertinent scientific literature. Federal register listings, protocols,
and species data provided by the United States Fish and Wildlife Service (USFWS) were reviewed
in conjunction with federally listed species potentially occurring in the area of the Project
property. The California Natural Diversity Database (CNDDB), a California Department of Fish and
Wildlife (CDFW) Natural Heritage Division species account database, was also reviewed for all
pertinent information regarding the locations of known occurrences of sensitive species in the
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vicinity of the property. In addition, numerous regional floral and faunal field guides were utilized
in the identification of species and suitable habitats. Combined, the sources reviewed provided
an excellent baseline from which to assess the biological resources potentially occurring in the
area. Other sources of information included the review of unpublished biological resource letter
reports, jurisdictional delineations, permit applications, and assessments. Other CDFW reports
and publications consulted include the following:
• Special Animals
• State and Federally Listed Endangered and Threatened Animals of California
• Endangered, Threatened, and Rare Plants of California
• Special Vascular Plants and Bryophytes List
A reconnaissance survey of the Project was conducted on May 18, 2021 (USFWS Permit
780566-14, CDFW Permit 02243) in order to characterize and identify potential wildlife habitats,
and to establish the accuracy of the data identified in the literature search and previous surveys.
Geologic and soil maps were examined to identify local soil types that may support sensitive taxa.
Aerial photographs, topographic maps, and vegetation and rare plant maps prepared by previous
studies in the region were used to determine community types and other physical features that
may support sensitive plants, wildlife, uncommon taxa, or rare communities that occur within
the project.
Based upon the initial review of the USFWS and CNDDB databases, habitat assessments were
conducted for the following species:
• Sensitive plants
• Delhi sand flower-loving fly (Rhaphiomidas terminatus abdominalis) – Federally
Endangered
• Burrowing owl (Athene cunicularia) – California State Species of Special Concern
• San Bernardino kangaroo rat (Dipodomys merriami parvus) – Federally Endangered /
California State Species of Special Concern
• Protected (“Heritage”) trees (as defined in City of Fontana Municipal Code Ordinance
No. 1126 Section 1, 8-16-94)
Literature Review
Prior to conducting the habitat assessment, a literature review and records search was conducted
for special-status biological resources potentially occurring on or within the vicinity of the Project
site. Previously recorded occurrences of special-status plant and wildlife species and their
proximity to the Project site were determined through a query of the CDFW QuickView Tool in
the Biogeographic Information and Observation System (BIOS), CNDDB Rarefind 5, the California
Native Plant Society’s (CNPS) Electronic Inventory of Rare and Endangered Vascular Plants of
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California, Calflora Database, compendia of special-status species published by CDFW, and the
U.S. Fish and Wildlife Service (USFWS) species listings.
All available reports, survey results, and literature detailing the biological resources previously
observed on or within the vicinity of the Project site were reviewed to understand existing site
conditions and note the extent of any disturbances that have occurred within the Project site
that would otherwise limit the distribution of special-status biological resources. Standard field
guides and texts were reviewed for specific habitat requirements of special-status and non-
special-status biological resources, as well as the following resources:
• Google Earth Pro historic aerial imagery (1985-2021);
• United States Department of Agriculture (USDA) Natural Resource Conservation Service
(NRCS) Soil Survey;
• USFWS Critical Habitat designations for Threatened and Endangered Species; and
• USFWS Endangered Species Profiles.
The literature review provided a baseline from which to inventory the biological resources
potentially occurring within the Project site. The CNDDB database was used, in conjunction with
ArcGIS software, to locate the nearest recorded occurrences of special-status species and
determine the distance from the Project site.
Results of Field Survey
The Project is bordered by high-density and rural existing residential development, high traffic
roads, and the County of San Bernardino County Flood Control channel/SR-210 to the south.
Based upon a review of historic aerial photographs, the project parcel has been mowed annually.
Habitat on the Project is characterized primarily as non-native grassland/ruderal vegetation and
is dominated by wild oat (Avena fatua), ripgut grass (Bromus diandrus), puncture vine
(Tribulus terrestris), cocklebur (Xanthium strumarium), cheeseweed (Malva parviflora),
red-stemmed filaree (Erodium cicutarium), tumbling pigweed (Amaranthus albus), black mustard
(Brassica nigra), Russian thistle (Kali tragus), horseweed (Conyza canadensis), and common
fiddleneck (Amsinckia menziesii).
The entire Project is characterized as having Tujunga gravelly loamy sand, 0 to 9 percent slopes
(TvC).
Habitat Assessment/Field Investigation
Following the literature review and reconnaissance survey of the Project, biologist Jacob H. Lloyd
Davies inventoried and evaluated the condition of the habitat within the Project site on
August 17, 2021. Plant communities and land cover types identified on aerial photographs during
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the literature review were verified by walking meandering transects throughout the Project site.
In addition, aerial photography was reviewed prior to the site investigation to locate potential
natural corridors and linkages that may support the movement of wildlife through the area.
These areas identified on aerial photography were then walked during the field investigation.
All plant and wildlife species observed, as well as dominant plant species within each plant
community, were recorded. Plant species observed during the field investigation were identified
by visual characteristics and morphology in the field. Unusual and less familiar plant species were
photographed during the field investigation and identified in the laboratory using taxonomical
guides. Wildlife detections were made through observation of scat, trails, tracks, burrows, nests,
and/or visual and aural observation. In addition, site characteristics such as soil condition,
topography, hydrology, anthropogenic disturbances, indicator species, condition of on-site plant
communities and land cover types, and presence of potential jurisdictional drainage and/or
wetland features were noted.
Soil Series Assessment
On-site and adjoining soils were researched prior to the field investigation using the USDA NRCS
Soil Survey for San Bernardino County, Southwestern Part. In addition, a review of the local
geological conditions and historical aerial photographs was conducted to assess the ecological
changes that the Project site has undergone.
Plant Communities
Plant communities were mapped using 7.5-minute USGS topographic base maps and aerial
photography. The plant communities were classified in accordance with Sawyer, Keeler-Wolf and
Evens (2009), delineated on an aerial photograph, and then digitized into GIS Arcview. The
Arcview application was used to compute the area of each plant community and/or land cover
type in acres.
Plants
Common plant species observed during the field investigation were identified by visual
characteristics and morphology in the field and recorded in a field notebook. Unusual and less
familiar plants were photographed in the field and identified in the office using taxonomic guides.
Taxonomic nomenclature used in this study follows the 2012 Jepson Manual.
Wildlife
Wildlife species detected during the field investigation by sight, calls, tracks, scat, or other sign
were recorded during surveys in a field notebook. Field guides were used to assist with
identification of wildlife species during the survey included The Sibley Field Guide to the Birds of
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Western North America, A Field Guide to Western Reptiles and Amphibians, and A Field Guide to
Mammals of North America.
Jurisdictional Drainages and Wetlands
Aerial photography was reviewed prior to conducting a field investigation in order to locate and
inspect any potential natural drainage features, ponded areas, or water bodies that may fall
under the jurisdiction of the U.S. Army Corps of Engineers (USACE), Regional Water Quality
Control Board (RWQCB), or CDFW. In general, surface drainage features indicated as blue-line
streams on USGS maps that are observed or expected to exhibit evidence of flow are considered
potential riparian/riverine habitat and are also subject to state and federal regulatory
jurisdiction. In addition, ELMT reviewed jurisdictional waters information through examining
historical aerial photographs to gain an understanding of the impact of land-use on natural
drainage patterns in the area. The USFWS National Wetland Inventory (NWI) and U.S. EPA Water
Program “My Waters” data layers were also reviewed to determine whether any hydrologic
features and wetland areas have been documented on or within the vicinity of the Project site.
Existing Site Conditions
The Project site occurs in an area that has undergone a conversion from natural habitats into
agriculture and residential land uses in the City of Fontana southeast of I-15 and north of SR-210.
The site is bordered to the north by Sierra Lakes Parkway with undeveloped, vacant land and
residential development to the north, to the west by Lytle Creek Road with residential
development beyond; to the east by Maloof Avenue with undeveloped, vacant land and
residential development beyond; and to the south by a San Bernardino County Flood Control
channel with SR-210 beyond.
Topography and Soils
The Project site is relatively flat with no areas of significant topographic relief, and ranges in
elevation from 1,487 to 1,513 feet above mean sea level. Generally, the Project site slopes from
northeast to southwest. Based on the NRCS USDA Web Soil Survey, the Project site is underlain
entirely by Tujunga gravelly loamy sand (0 to 9 percent slopes). Refer to Exhibit 4, Soils in
Attachment A of the Habitat Assessment in Addendum EIR Appendix D. Soils on-site have been
mechanically disturbed and heavily compacted from historic land uses (i.e., grading and weed
abatement activities).
Vegetation
Due to historic and existing land uses, no native plant communities or natural communities of
special concern were observed on or adjacent to the Project site. The Project site consists of
vacant, undeveloped that has been subjected to a variety of anthropogenic disturbances
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including grading, routine weed abatement activities, vehicular traffic, and on-site surrounding
development. These disturbances have eliminated and/or greatly disturbed the natural plant
communities that historically occurred within the immediate vicinity of the Project site. Refer to
Attachment C, Site Photographs of the Habitat Assessment in Addendum EIR Appendix D, for
representative site photographs. No native plant communities would be impacted from
implementation of the Project.
The site supports one plant community: non-native grassland. In addition, two land cover types
are present that would be classified as disturbed and developed. Refer to Exhibit 5, Vegetation
in Attachment A of the Habitat Assessment in Addendum EIR Appendix D. The majority of the
Project site supports a non-native grassland plant community that is dominated by non-native
grass species such as bromes (Bromus sp.) and oats (Avena sp.) and it subjected to routine weed
abatement activities. Common species observed in the non-native grassland plant community
include Mediterranean mustard (Hirschfeldia incana), Russian thistle (Salsola tragus), and
puncturevine (Tribulus terrestris).
The disturbed portions of the site occur along site boundaries and are vegetated with a limited
variety of weedy/early successional species. Common plant species observed in disturbed areas
of the site include non-native grasses, Mediterranean mustard, Russian thistle, puncture vine,
horseweed (Erigeron sp.), common sunflower (Helianthus annuus), western ragweed (Ambrosia
psilostachya), telegraph weed (Heterotheca grandiflora), and Spanish lotus (Acmispon
americanus).
Developed areas generally encompass all buildings/structures or any paved or otherwise
impervious surfaces. Developed portions of the site include a portion of the southeast corner
within Maloof Avenue. This area is unvegetated.
Wildlife
Plant communities provide foraging habitat, nesting/denning site, and shelter from adverse
weather or predation. This subsection provides a discussion of those wildlife species that were
observed or are expected to occur within the Project site. The discussion is to be used a general
reference and is limited by the season, time of day, and weather conditions in which the field
investigation was conducted. Wildlife detections were based on calls, songs, scat, tracks,
burrows, and direct observation. The Project site provides limited habitat for wildlife species
except those adapted to a high degree of anthropogenic disturbances and development.
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Fish
No fish or hydrogeomorphic features (e.g., perennial creeks, ponds, lakes, reservoirs) that would
provide suitable habitat for fish were observed on or within the vicinity of the Project site.
Therefore, no fish are expected to occur and are presumed absent from the Project site.
Amphibians
No amphibians or hydrogeomorphic features (e.g., perennial creeks, ponds, lakes, reservoirs)
that would provide suitable habitat for amphibian species were observed on or within the vicinity
of the Project site. Therefore, no amphibians are expected to occur and are presumed absent
from the Project site.
Reptiles
The Project site provides limited foraging and cover habitat for reptile species adapted to a high
degree of anthropogenic disturbance. The only reptile species observed during the field
investigation was western side-blotched lizard (Uta stansburiana elegans). Common reptilian
species adapted to a high degree of anthropogenic disturbances that have the potential to occur
on-site include Great Basin fence lizard (Sceloporus occidentalis longipes) and alligator lizard
(Elgaria multicarinata). Due to the high level of anthropogenic disturbances on-site, and
surrounding development, no special-status reptilian species are expected to occur within
Project site.
Birds
The Project site provides limited foraging and nesting habitat for bird species adapted to a high
degree of anthropogenic disturbance. Bird species detected during the field investigation
included mourning rock pigeon (Columba liva), western meadowlark (Sturnella neglecta), and
house finch (Haemorhous mexicanus).
Mammals
The Project site provides limited foraging and cover habitat for mammalian species adapted to a
high degree of anthropogenic disturbance. The only mammalian species observed during the
field investigation were pocket gopher (Thomomys sp.) and kangaroo rat (Dipodomys sp.).
Common mammalian species adapted to a high degree of anthropogenic disturbance that could
be expected to occur include coyote (Canis latrans), opossum (Didelphis virginiana), and raccoon
(Procyon lotor).
Nesting Birds
No active nests or birds displaying nesting behavior were observed during the field survey, which
was conducted at the end of the bird nesting season. Although subjected to routine disturbance,
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the ornamental trees found on-site has the potential to provide suitable nesting habitat for year-
round and seasonal avian residents, as well as migrating songbirds that could occur in the area
that are adapted to urban environments. Additionally, the open, disturbed habitat on-site also
provides nesting opportunities for ground-nesting species such as killdeer (Charadrius vociferus).
No raptors are expected to nest on-site due to lack of suitable nesting opportunities.
Nesting birds are protected pursuant to the Migratory Bird Treaty Act (MBTA) and California Fish
and Game Code (Sections 3503, 3503.5, 3511, and 3513 prohibit the take, possession, or
destruction of birds, their nests or eggs).
Migratory Corridors and Linkages
Habitat linkages provide connections between larger habitat areas that are separated by
development. Wildlife corridors are similar to linkages but provide specific opportunities for
animals to disperse or migrate between areas. A corridor can be defined as a linear landscape
feature of sufficient width to allow animal movement between two comparatively undisturbed
habitat fragments. Adequate cover is essential for a corridor to function as a wildlife movement
area. It is possible for a habitat corridor to be adequate for one species yet still inadequate for
others. Wildlife corridors are features that allow for the dispersal, seasonal migration, breeding,
and foraging of a variety of wildlife species. Additionally, open space can provide a buffer against
both anthropogenic disturbance and natural fluctuations in resources.
According to the San Bernardino County General Plan, the Project site has not been identified as
occurring within a Wildlife Corridor or Linkage. As designated by the San Bernardino County
General Plan Open Space Element, major open space areas documented in the vicinity of the
Project site include the Lytle Creek Wash, located approximately 3.2 miles to the northeast, which
is separated from the Project by existing developments.
Jurisdictional Areas
There are three key agencies that regulate activities within inland streams, wetlands, and riparian
areas in California. The USACE Regulatory Branch regulates discharge of dredge or fill materials
into “waters of the United States” pursuant to Section 404 of the Clean Water Act (CWA) and
Section 10 of the Rivers and Harbors Act. Of the State agencies, the CDFW regulates alterations
to streambed and bank under Fish and Wildlife Code Sections 1600 et seq., and the RWQCB
regulates discharges into surface waters pursuant to Section 401 of the CWA and the California
Porter-Cologne Water Quality Control Act.
Special-Status Biological Resources
The CNDDB Rarefind 5 and the CNPS Electronic Inventory of Rare and Endangered Vascular Plants
of California were queried for reported locations of special-status plant and wildlife species as
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well as special-status natural plant communities in the Devore USGS 7.5-minute quadrangle. The
habitat assessment evaluated the conditions of the habitat(s) within the boundaries of the
Project site to determine if the existing plant communities, at the time of the survey, have the
potential to provide suitable habitat(s) for special-status plant and wildlife species. Only one
quadrangle was searched since the Project site is located near the middle of the quadrangle and
is surrounding be existing development.
The literature search identified 20 special-status plant species, 42 special-status, and three
special-status plant communities as having potential to occur within the Devore USGS 7.5-minute
quadrangle. Special-status plant and wildlife species were evaluated for their potential to occur
within the Project site based on habitat requirements, availability and quality of suitable habitat,
and known distributions. Species determined to have the potential to occur within the general
vicinity of the Project site is presented in Table D-1: Potentially Occurring Special-Status Biological
Resources, provided in Attachment D of the Habitat Assessment (Appendix D).
Special-Status Plants
According to the CNDDB and CNPS, 20 special-status plant species have been recorded in the
Devore quadrangle. No special-status plant species were observed on-site during the field
investigation. The Project site consists of developed land and undeveloped, vacant land that has
been subject to a variety of anthropogenic disturbances from on-site historic agricultural
activities and residential development, grading, and routine weed abatement activities, and is
largely surrounded by existing development. These disturbances have eliminated the natural
plant communities that once occurred on-site which has removed ability of the habitat on the
Project site to provide suitable habitat for special-status plant species known to occur in the
general vicinity.
Special-Status Wildlife
According to the CNDDB, 42 special-status wildlife species have been reported in the Devore
quadrangle. No special-status wildlife species were observed on-site during the habitat
assessment. The Project site consists of developed land and vacant, undeveloped land that has
been subject to a variety of anthropogenic disturbances from historic grading and stockpiling
activities, on-site and surrounding development, and routine weed abatement activities, and is
largely surrounded by existing development. These disturbances have eliminated the natural
plant communities that once occurred on-site which has greatly reduced potential foraging
opportunities for wildlife species.
Based on regional significance, the potential occurrence of California gnatcatcher (Polioptila
californica), burrowing owl, and San Bernardino kangaroo rat within the Project site are described
in further detail below:
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California Gnatcatcher
California gnatcatcher is a federally threatened species with restricted habitat requirements,
being an obligate resident of sage scrub habitats that are dominated by California sagebrush. This
species generally occurs below 750 feet elevation in coastal regions and below 1,500 feet inland.
According to J. Atwood and J. Bolsinger, 99 percent of all California gnatcatcher observations are
in areas with elevations below 950 feet. There are reported occurrences of California gnatcatcher
at 1,600 feet elevation (500 meters).
California gnatcatcher ranges from Ventura County south to San Diego County and northern Baja
California and is less common in sage scrub with a high percentage of tall shrubs. It prefers habitat
with more low-growing vegetation. California gnatcatchers breed between mid-February and the
end of August, with peak activity from mid-March to mid-May. Population estimates indicate that
there are approximately 1,600 to 2,290 pairs of coastal California gnatcatcher remaining.
Declines are attributed to loss of sage scrub habitat due to development, as well as cowbird nest
parasitism.
California gnatcatcher are ground and shrub-foraging insectivores. They feed on small insects and
other arthropods. A California gnatcatcher’s territory is highly variable in size and seems to be
correlated with distance from the coast, ranging from less than one (1) hectare (ha) to over 9 ha.
In a 1998 study, biologist Patrick Mock concluded that California gnatcatcher in the inland region
require a larger territory than those on the coast in order to meet the nutritional requirements
needed for survival and breeding.
The Primary Constituent Elements (PCEs) essential to support the biological needs of foraging,
reproducing, rearing of young, intra-specific communication, dispersal, genetic exchange, or
sheltering for California gnatcatcher that were surveyed for include:
1. Dynamic and Successional sage scrub Habitats and Associated Vegetation (Diegan Coastal
Sage Scrub, Coastal Sage-Chaparral Scrub, etc.) that provide space for individual and
population growth, normal behavior, breeding, reproduction, nesting, dispersal and
foraging; and
2. Non-sage scrub habitats such as chaparral, grassland, and riparian areas, in proximity to
sage scrub habitats have the potential to provide linkages to help with dispersal, foraging
and nesting.
The Project site ranges in elevation from 1,487 to 1,513 feet above mean sea level, which
coincides with the maximal known elevational range of California gnatcatcher. The preferred
habitat for California gnatcatcher is coastal sage scrub dominated by California sage brush. The
Project site does not support coastal sage scrub habitat, nor does it support any vegetation
alliances capable of providing suitable habitat for California gnatcatcher. In addition, the site is
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isolated from California gnatcatcher occupied coastal sage scrub habitats and linkage areas in the
region by surrounding development. Given the highly degraded condition of the site, plus the
lack of any observation of California gnatcatcher in north Fontana and isolation of the site due to
the recent development of surrounding properties, it is highly unlikely that the site supports this
species. The site is presumed to be unoccupied and focused surveys are not recommended.
Burrowing Owl
The burrowing owl is currently listed as a California Species of Special Concern. It is a grassland
specialist distributed throughout western North America where it occupies open areas with short
vegetation and bare ground within shrub, desert, and grassland environments. Burrowing owls
use a wide variety of arid and semi-arid environments with well-drained, level to gently sloping
areas characterized by sparse vegetation and bare ground. Burrowing owls are dependent upon
the presence of burrowing mammals (such as ground squirrels) whose burrows are used for
roosting and nesting. The presence or absence of colonial mammal burrows is often a major
factor that limits the presence or absence of burrowing owls. Where mammal burrows are scarce,
burrowing owls have been found occupying man-made cavities, such as buried and
non-functioning drainpipes, standpipes, and dry culverts. Burrowing mammals may burrow
beneath rocks and debris or large, heavy objects such as abandoned cars, concrete blocks, or
concrete pads. They also require open vegetation allowing line-of-sight observation of the
surrounding habitat to forage as well as watch for predators.
No burrowing owls or recent sign (i.e., pellets, feathers, castings, or whitewash) was observed
during the field investigation. The Project site is unvegetated and/or vegetated with a variety of
low-growing plant species that allow for line-of-sight observation favored by burrowing owls and
does not support any suitable burrows (> four inches in diameter) capable of providing roosting
and nesting opportunities. In addition, the site is surrounded by buildings, trees, and utility poles
which decrease the likelihood that burrowing owls would occur on the Project site as these
features provide perching opportunities for larger raptor species (i.e., red-tailed hawk
[Buteo jamaicensis]) that prey on burrowing owls. Further, the Project site is entirely surrounded
by existing development and is thoroughly isolated from nearby suitable habitats. Based on the
results of the field investigation, it was determined that the Project site has a low potential to
provide suitable habitat for burrowing owls and focused surveys are not recommended.
San Bernardino Kangaroo Rat
The San Bernardino kangaroo rat, federally listed as endangered, is one of several kangaroo rat
species in its range. The Dulzura (Dipodomys simulans), the Pacific kangaroo rat
(Dipodomys agilis) and the Stephens kangaroo rat (Dipodomys stephensi) occur in areas occupied
by the San Bernardino kangaroo rat, but these other species have a wider habitat range.
San Bernardino kangaroo rat historically ranged from the San Bernardino Valley in
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San Bernardino County to southwest Perris, Bautista Canyon, and Murrieta Hot Springs in
Riverside County, with at least 25 separate localities identified. Currently, populations of the San
Bernardino kangaroo rat are limited to seven widely separated locations in San Bernardino and
Riverside counties, four of which (City Creek, Etiwanda, Reche Canyon, and South Bloomington)
support only small, remnant populations. The Santa Ana River, Lytle and Cajon washes, and the
San Jacinto River support the largest extant concentrations of San Bernardino kangaroo rat and
the largest areas of habitat for this species (approximately 3,200 acres total). The total area of
occupied habitat occurs across a mosaic of approximately 13,697 acres of potential habitat;
however, all but the 3,215 occupied areas are currently more mature than the open, early
successional habitat types preferred by the San Bernardino kangaroo rat.
San Bernardino kangaroo rat is found primarily on sandy and loamy sand substrates, where they
can readily excavate simple, shallow burrows. This is typically associated with Riversidean Alluvial
Fan Sage Scrub (RAFSS) habitat, a relatively uncommon desert-influenced plant community in
southern California that develops on alluvial fans and floodplains subjected to scouring and
deposition. Adjacent upland habitat provide refuge for San Bernardino kangaroo rat during flood
events. Animals occupying this refugia habitat are able to repopulate core habitat areas within
the floodplain following major flood events. Most of the drainages have been historically altered
as a result of flood control efforts and the resulting increased use of river resources, including
mining, off-road vehicle use, and road and housing development. This increased use of river
resources has resulted in a reduction in both the amount and quality of habitat available for the
San Bernardino kangaroo rat. The past habitat losses and potential future losses prompted the
emergency listing of the San Bernardino kangaroo rat as an endangered species.
The Project site has not supported a natural plant community since at least 1994, and the existing
plant community and land cover types do not exhibit the species diversity or distribution of RAFFS
habitat. In addition, the Project site and surrounding area are no longer exposed to fluvial
processes needed to maintain the intermediate RAFSS habitat that would be required for long-
term San Bernardino kangaroo rat conservation since the site has been isolated from the
influences of nearby waterways and alluvial fans extending out of the San Gabriel Mountains
since the mid-1980s to early-2000s. Due to the history of regular disruption and manipulation of
the native soils, the loss of fluvial scouring due to flood control activities, and isolation from
known occupied habitat, it was determined that the Project site does not provide suitable habitat
for San Bernardino kangaroo rat. No further studies are recommended.
Special-Status Plant Communities
According to the CNDDB, three special-status plant communities have been reported in the
Devore USGS 7.5-minute quadrangle: Riversidean Alluvial Fan Sage Scrub, southern riparian
forest, and Southern Sycamore Alder Riparian Woodland. Based on the results of the field
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investigation, no special-status plant communities were observed onsite. Therefore, no special-
status plant communities would be impacted by Project implementation.
Critical Habitat
Under the federal Endangered Species Act, “Critical Habitat” is designated at the time of listing
of a species or within one year of listing. Critical Habitat refers to specific areas within the
geographical range of a species at the time it is listed that include the physical or biological
features that are essential to the survival and eventual recovery of that species. Maintenance of
these physical and biological features requires special management considerations or protection,
regardless of whether individuals or the species are present or not. All federal agencies are
required to consult with the USFWS regarding activities they authorize, fund, or permit which
may affect a federally listed species or its designated Critical Habitat. The purpose of the
consultation is to ensure that Projects would not jeopardize the continued existence of the listed
species or adversely modify or destroy its designated Critical Habitat. The designation of Critical
Habitat does not affect private landowners, unless a Project they are proposing is on federal
lands, uses federal funds, or requires federal authorization or permits (e.g., funding from the
Federal Highways Administration or a CWA Permit from the USACE). If a there is a federal nexus,
then the federal agency that is responsible for providing the funding or permit would consult
with the USFWS.
The Project site is not located within federally designated Critical Habitat. The nearest Critical
Habitat designation is located approximately 0.25 mile north of the site for San Bernardino
kangaroo rat. Therefore, no impacts to federally designated Critical Habitat would occur from
implementation of the Project.
North Fontana Conservation Program
The North Fontana Conservation Program (previously referred to as the North Fontana Interim
Multiple Species Habitat Conservation Plan) was prepared to address lands in north Fontana and
the listed and special-status species that have the potential to occur on these lands. To
adequately mitigate for the loss of sensitive habitats, as required by CEQA, a tiered development
mitigation fee was created for new development in north Fontana. The mitigation fee is based
on the quality of the habitat on the development site and a site’s potential to support San
Bernardino kangaroo rat, coastal California gnatcatcher, or other special-status species occurring
in the vicinity. The mitigation fee is charged for each acre of land proposed for development
based on the habitat quality rating.
The North Fontana Conservation Program mitigation fee areas (habitat quality ratings) were
overlain over the Project site boundaries in ArcGIS in order to calculate the acreage of impacts to
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the various habitat qualities occurring on the Project site. From this, the mitigation fee for the
Project was calculated.
The Project site is not located within the North Fontana Conservation Program boundaries.
Therefore, the Project implementation is not subject to the mitigation fee.
Project Impact Analysis
EIR Impact 3.3-1: Would the 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 California Department of Fish and Game or U.S. Fish
and Wildlife Service?
No New or More Severe Impact: As discussed above, the ELMT’s Habitat Assessment determined
that the Project site is in an area that has been heavily disturbed and undergone a conversion
from natural habitats into agriculture and residential land uses and are isolated from regional
wildlife corridors and linkages. The Project would not 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 CDFW or USFWS.
Further, the Habitat Assessment also found that the Project site has a low potential to provide
suitable habitats for both wildlife and sensitive vegetation.
Based on the Habitat Assessment, it was determined that the Project site has a high potential to
provide suitable habitat for Cooper’s hawk (Accipiter cooperii), California horned lark (Eremophila
alpestris actia); and a low potential to support burrowing owl (Athene cunicularia) and Costa’s
hummingbird (Calypte costae). However, the site has been heavily disturbed with grading
activities, routine weed abatement, and vehicular traffic on the site. The site is located in an area
that is surrounded by residentially developed property and surrounded by roadways to the west
and south. It was also determined that the Project site does not provide suitable habitat for any
of the special-status plant species known to occur in the area and all are presumed to be absent.
No focused surveys are recommended.
Based on literature review and field survey, and existing site conditions, implementation of the
Project would have no significant impacts on federally or State listed species known to occur in
the general vicinity of the Project site. Additionally, the Project would have no effect on
designated Critical Habitat, since there is no federal nexus, or regional wildlife corridors/linkage
existing within the area. No jurisdictional drainage and/or wetland features were observed on
the Project site during the field investigation. No further surveys are recommended.
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Although no active nests or birds displaying nesting behavior were observed during the field
survey, which was conducted at the end of the bird nesting season, there is remaining potential
for nesting birds to be encountered during construction activities. This is especially true during
the observed nesting period. The disturbance of nesting birds during construction activity would
need to be actively avoided during construction for the duration of the nesting season. It is
therefore recommended that if construction occurs during the established nesting season
(between February 1st and August 31st), a pre-construction clearance survey for nesting birds
should be conducted within three (3) days of the start of any vegetation removal or ground
disturbing activities to ensure that no nesting birds will be disturbed during construction; see
standard condition SC BIO-1 below. Therefore, no new or more severe impact is anticipated with
regard to nesting birds.
Further, ELMT was contacted on February 8, 2022 regarding the development of amenities in the
extension of Lytle Creek Road/Open Space area and determined that if building within the
existing cul-de-sac/roadway and right of way, no impacts to resources would occur.
Mitigation Program
None identified in the LCA EIR. However, the ELMT’s Habitat Assessment provides a Standard
Condition with regard to nesting birds. Standard condition SC BIO-1 is a standard protocol should
the construction for the Project occur between February 1st and August 31st.
Nesting Birds Standard Condition
SC BIO-1 If construction occurs between February 1st and August 31st, a pre-construction
clearance survey for nesting birds should be conducted within three (3) days of
the start of any vegetation removal or ground disturbing activities to ensure that
no nesting birds will be disturbed during construction. The biologist conducting
the clearance survey should document a negative survey with a brief letter report
indicating that no impacts to active avian nests will occur. If an active avian nest is
discovered during the pre-construction clearance survey, construction activities
should stay outside of a no-disturbance buffer. The size of the no disturbance
buffer will be determined by the wildlife biologist and will depend on the level of
noise and/or surrounding anthropogenic disturbances, line of sight between the
nest and the construction activity, type and duration of construction activity,
ambient noise, species habituation, and topographical barriers. These factors will
be evaluated on a case-by-case basis when developing buffer distances. Limits of
construction to avoid an active nest will be established in the field with flagging,
fencing, or other appropriate barriers; and construction personnel will be
instructed on the sensitivity of nest areas. A biological monitor should be present
to delineate the boundaries of the buffer area and to monitor the active nest to
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ensure that nesting behavior is not adversely affected by the construction activity.
Once the young have fledged and left the nest, or the nest otherwise becomes
inactive under natural conditions, construction activities within the buffer area
can occur. As part of the nesting bird clearance, it is recommended that a
burrowing owl pre-construction clearance survey be conducted prior to any
ground disturbance or vegetation removal activities to ensure that burrowing owls
remain absent from the project site.
Conclusion
The Project would result in no new or more severe impact on natural habitats and sensitive
species. A less than significant impact was identified in the LCA EIR with respect to natural
habitats and sensitive species. The Project would be designed consistent with the applicable
guidelines and standards within the Fontana GP, Fontana MC, and Fontana ZDC. The Project
would follow the nesting birds and burrowing owl pre-construction clearance survey
recommendations as identified in the Habitat Assess
EIR Impact 3.3-2: Would the 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 California Department of Fish and
Wildlife or U.S. Fish and Wildlife Service?
EIR Impact 3.3-3: Would the Project have a substantial adverse effect on state or Federally
protected wetlands (including, but not limited to, marsh, vernal pool,
coastal, etc.) through direct removal, filling, hydrological interruption, or
other means?
EIR Impact 3.3-4: Would the 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 native wildlife
nursery sites?
No New or More Severe Impact: The ELMT’s Habitat Assessment determines that the Project
site is in an area that has been heavily disturbed and undergone a conversion from natural
habitats into agriculture and residential land uses and are isolated from regional wildlife corridors
and linkages. In addition, there are no riparian corridors, creeks, or useful patches of
steppingstone habitat (natural areas) within or connecting the site to a recognized wildlife
corridor or linkage. As such, implementation of the Project is not expected to impact wildlife
movement opportunities. Therefore, impacts to wildlife corridors or linkages are not expected to
occur.
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Further, the Project site does not support any discernible drainage courses, inundated areas,
wetland features, or hydric soils that would be considered jurisdictional by the USACE, RWQCB,
or CDFW. A query of the NWI database found on potential blueline streams, riverine, or other
aquatic resources within or adjacent to the Project site. Therefore, Project activities would not
result in impacts to USACE, RWQCB, or CDFW jurisdictional areas and regulatory approvals would
not be required. As such, the Project would not 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 CDFW or USFWS, nor would it have a substantial adverse effect on state or
Federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.)
through direct removal, filling, hydrological interruption, or other means.
However, it should be noted that a flood control channel is located along the southern boundary
of the Project site. If any impacts occur to the flood control channel from implementation of the
Project, further review would likely be needed to map the jurisdictional extent of the channel.
Additionally, the Applicant would likely need to obtain the following regulatory approvals prior
to impacts occurring within the identified jurisdictional areas, USACE CWA Section 404 Permit,
RWQCB CWA Section 401 Water Quality Certification, and/or CDFW Section 1602 Streambed
Alteration Agreement (SAA). Impact to this channel are not anticipated. Additionally, the Lytle
Creek open space area would act as a supplementary flood control area providing additional
drainage infiltration through the landscaped area.
Further, ELMT was contacted on February 8, 2022 regarding the development of amenities in the
extension of Lytle Creek Road/Open Space area and determined that if building within the
existing cul-de-sac/roadway and right of way, and no changes to the existing inlet structures in
Lytle Creek Road or to the existing drainage, no impacts to jurisdictional waters would occur. The
existing inlet structure is only conveying flows from the street to the drainage to the south and
therefore, the inlet is not considered jurisdictional.
The Project would not 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 native wildlife nursery sites. Therefore, no new or more severe
impact is anticipated to occur as a result of the Project Implementation.
Although no active nests or birds displaying nesting behavior were observed during the field
survey, which was conducted at the end of the bird nesting season, it is still recommended that
if construction occurs between February 1st and August 31st, a pre-construction clearance survey
for nesting birds should be conducted within three (3) days of the start of any vegetation removal
or ground disturbing activities to ensure that no nesting birds will be disturbed during
construction; see Standard Condition SC BIO-1 above. SC BIO-1 is recommended to reduce any
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potential impacts with respect to nesting that may occur. Therefore, no new or more severe
impact is anticipated with regard to nesting birds.
Mitigation Program
None identified in the LCA EIR. However, the ELMT’s Habitat Assessment provides a Standard
Condition with regard to nesting birds. Standard condition SC BIO-1 is a standard protocol should
the construction for the Project occur between February 1st and August 31st.
Conclusion
The Project would result in no new or more severe impact on aquatic habitats and resources, or
wildlife movement. No impact was identified in the LCA EIR. The Project would follow the nesting
birds and burrowing owl pre-construction clearance survey recommendations as identified in the
Habitat Assessment and in SC BIO-1 above. The Project would be designed consistent with the
applicable guidelines and standards within the Fontana GP, Fontana MC, and Fontana ZDC.
EIR Impact 3.3-5: Would the Project conflict with any local policies or ordinances related to
protecting biological resources, such as a tree preservation policy or
ordinance?
EIR Impact 3.3-6: Would the Project conflict with the provisions of an adopted Habitat
Conservation Plan, Natural Community Conservation Plan, or other
approved local, regional, or state habitat conservation plan?
No New or More Severe Impact: The Fontana MC Chapter 28, Article III – Preservation of
Heritage, Significant and Specimen Trees establishes regulations for the preservation and
protection of heritage, significant and/or specimen trees within the City. The Project site contains
ornamental trees that are not considered heritage or significant. The Project implementation
would result in the removal of these the trees that are not protected under the Preservation of
Heritage, Significant and Specimen Trees Ordinance. Therefore, the Project would not conflict
with any local policies or ordinances protecting biological resources, such as a tree preservation
policy or ordinance.
The City of Fontana is currently finalizing the North Fontana Conservation Program (previously
referred to as the North Fontana Interim MSHCP). As previously discussed, the Project is not
within the North Fontana Conservation Program boundaries and would not conflict with the
provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or
other approved local, regional, or state habitat conservation plan. No new or more severe impact
would occur in this regard.
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Mitigation Program
None identified in the LCA EIR.
Conclusion
The Project would not result in new or more severe impact on conservation plans and policies
and would be subject to payment of mitigation fee. The LCA EIR did not contain mitigation
measures with respect to biological resources. In addition, the Project would be designed
consistent with the applicable guidelines and standards within the Fontana GP, Fontana MC, and
Fontana ZDC. Therefore, no new and/or modified mitigation measures are required for issues
related to biological resources.
EIR Impact 3.3-7: Would the Project result in the conversion of oak woodlands that will have
a significant impact on the environment?
No New or More Severe Impact: The Project site contains ornamental trees and does not have
oak woodlands. Therefore, the Project would not result in the conversion of oak woodland.
Mitigation Program
None identified in the LCA EIR.
Conclusion
The LCA EIR determined that there was no oak woodlands within the site. Similarly, during the
survey conducted by ELMT, only ornamental trees were found on site. Therefore, the Project
would not result in new or more severe impact with regard to conversion of oak woodlands. The
Project would be designed consistent with the applicable guidelines and standards within the
Fontana GP, Fontana MC, and Fontana ZDC. Therefore, no new and/or modified mitigation
measures are required for issues related to biological resources.
7.3.3 Overall Biological Resources Impacts Conclusion
With regard to CEQA Section 21166 and CEQA Guidelines Section 15162(a), the changes
proposed by the Project would not result in any new impacts, or increase the severity of the
previously identified impacts, with respect to biological resources. Therefore, preparation of a
SEIR is not warranted.
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7.4 Cultural Resources
7.4.1 Summary of Previous Environmental Analysis
The LCA EIR concluded that implementation of the Fontana GP would result in potential impacts
to the City’s historical resources. This is attributed to the potential demolition of Tier III resources,
since the Fontana GP would strongly encourage the preservation of Tier II resources and require
the preservation of Tier I resources. As well, the LCA EIR found that while impacts to archeological
resources would be low, there is the potential to encounter previously unknown paleontological
resources. As well, Bellevue Cemetery was identified as a Native American burial site. Potential
impacts to Native American resources were found to be potentially significant but not
unavoidable with the proper use of mitigation.
7.4.2 Analysis of Proposed Project
A Cultural Resources Assessment was prepared by BCR Consulting LLC (BCR) (November 2021) to
address potential impacts to historic and archaeological resources associated with
implementation of the proposed Project. The report is summarized below and is included as
Appendix E of this Addendum.
Historical Resources
Historical resources consist of any object, building, structure, site, area, place, record, or
manuscript which a lead agency determines to be historically significant or significant in the
architectural, engineering, scientific, economic, agricultural, educational, social, political,
military, or cultural annals of California. Generally, a resource shall be considered by the lead
agency to be ‘historically significant’ if the resource meets the criteria for listing in the California
Register of Historical Resources” (Cal. Code Regs. tit. 14(3), Section 15064.5(a)(3)).
By statute, the CEQA is primarily concerned with two classes of cultural resources: “historical
resources,” which are defined in PRC Section 21084.1 and CEQA Guidelines Section 15064.5, and
“unique archaeological resources,” which are defined in PRC Section 21083.2. Tribal cultural
resources are generally described as sites, features, places, cultural landscapes, sacred places,
and objects with cultural value to a California Native American tribe and are further defined in
PRC Section 21074(a)(1)(A) and (B).
Archaeological Resources
Archaeological resources are materials from past human activities that are more than 50 years
old. The Archaeological Resources Protection Act of 1979 governs the excavation of
archaeological sites on federal and Indian lands in the United States, and the removal and
disposition of archaeological collections from those sites.
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Paleontological Resources
Paleontology, exclusive of the study of human fossils, is a natural science closely associated with
geology and biology. In geologically diverse California, vertebrate, invertebrate, and plant fossils
are usually found in sedimentary and metasedimentary deposits. CEQA provides guidance
relative to significant impacts on paleontological resources, indicating that a project would have
a significant impact on paleontological resources if it disturbs or destroys a unique
paleontological resource or site or unique geologic feature. Section 5097.5 of the California PRC
specifies that any unauthorized removal of paleontological remains is a misdemeanor.
Furthermore, California Penal Code Section 622.5 sets the penalties for damage or removal of
paleontological resources.
CEQA provides guidance relative to significant impacts on paleontological resources, indicating
that a project would have a significant impact on paleontological resources if it disturbs or
destroys a unique paleontological resource or site or unique geologic feature. Section 5097.5 of
the California PRC specifies that any unauthorized removal of paleontological remains is a
misdemeanor. Further, California Penal Code Section 622.5 sets the penalties for damage or
removal of paleontological resources. CEQA documentation prepared for projects would be
required to analyze paleontological resources as a condition of the CEQA process to disclose
potential impacts. As of January 2018, paleontological resources are considered in the geological
rather than cultural category. Therefore, paleontological resources are discussed in Geology and
Soils discussion.
Methodology9
Records Search
Prior to fieldwork, an archaeological records search was conducted by SCCIC staff using data on
file at California State University, Fullerton. This included a review of all recorded historic and
prehistoric cultural resources, as well as a review of known cultural resources within 0.5miles of
the Project site. In addition, a review was conducted of the National Register of Historic Places
(NRHP), the California Register of Historical Resources (CRHR), and documents and inventories
from the California Office of Historic Preservation including the lists of California Historical
Landmarks, California Points of Historical Interest, Listing of National Register Properties, and the
Inventory of Historic Structures.
Field Survey
An intensive-level cultural resources field survey of the Project site was conducted on
September 2, 2021. The survey was conducted by walking parallel transects spaced
approximately 15 meters apart across 100 percent of the project site, where accessible. Cultural
9 BCR Consulting LLC. (2021). Cultural Resources Assessment; Methodology. Accessed December 2021.
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resources were recorded on DPR 523 forms. Ground visibility averaged approximately 50 percent
within Project boundaries. These included overviews as well as detail photographs of all cultural
resources.
Results10
Records Search
Records search results conducted by SCCIC staff using data on file at California State University,
Fullerton indicated that 17 previous cultural resources studies have taken place resulting in the
recording of 14 all historic-period cultural resources within a 0.5-mile radius of the Project site,
resulting in the recordation of three historic-period cultural resources. Of these, two of the
previous studies assessed the project site for cultural resources but did not identify any cultural
resources within its boundaries. Results are summarized in Table 14, Cultural Resources and
Reports Located within 0.5 Mile of the Project Site, and a comprehensive records search
bibliography is in Appendix B of the Cultural Resources Assessment Report, provided as
Appendix E of this Initial Study.
Table 14: Cultural Resources and Reports Located within 0.5 Mile of the Project Site
USGS 7.5 Min
Quad.
Cultural Resources Within 0.5 Miles of Project Site Studies Within One Mile
Devore, Calif.
(1988)
P-36-7326: Historic-Period Foundations/Refuse (1/4 Mile S)
P-36-9366: Historic-Period Road (1/2 Mile SW)
P-36-9367: Historic-Period Well/Cistern (1/2 Mile NW)
P-36-14191: Historic-Period Standing Structure (1/4 Mile S)
P-36-14192: Historic-Period Standing Structure (1/4 Mile SE)
P-36-14193: Historic-Period Standing Structure (1/4 Mile SE)
P-36-14194: Historic-Period Standing Structure (1/4 Mile E)
P-36-14195: Historic-Period Standing Structure (1/4 Mile E)
P-36-14196: Historic-Period Standing Structure (1/4 Mile ESE)
P-36-15376: Grapeland Homesteads (1/2 Mile NE)
P-36-20915: Historic-Period Standing Structure (1/4 Mile E)
P-36-20916: Historic-Period Standing Structure (1/4 Mile E)
P-36-20917: Historic-Period Standing Structure (1/8 Mile E)
P-36-20918: Historic-Period Standing Structure (1/8 Mile E)
SB-0398, 1611, 1611A,
2621*, 2765, 2766, 3172,
3173, 3174, 4209, 4547,
4548*, 5095, 6016, 6392,
6414, 6450
*Previously assessed for the Project site for cultural resources.
Source: BCR Consulting, LLC. November 2021. Cultural Resources Assessment.
Sacred Lands File Search
BCR Consulting conducted a Sacred Lands File (SLF) search with the Native American Heritage
Commission (NAHC). Findings were positive during the SLF search with the NAHC. The NAHC has
recommended contacting the Gabrieleno Band of Mission Indians – Kizh Nation (GBMI) for more
information regarding this finding. BCR Consulting emailed the GBMI nation and did not received
a response.
10 BCR Consulting LLC. (2021). Cultural Resources Assessment; Results. Accessed November 2021.
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Field Survey
During the field survey, BCR Consulting staff carefully inspected the Project site, and identified
no cultural resources within its boundaries. Surface visibility was 80 percent within the Project
site. Sediments consisted of light grayish brown, dry clayey silt with moderate gravel that was
subrounded. The property vegetation was mainly dried seasonal grasses and weeds.
Significance Evaluations
CEQA calls for the evaluation and recordation of historic and archaeological resources. The
criteria for determining the significance of impacts to cultural resources are based on Section
15064.5 of the CEQA Guidelines and Guidelines for the Nomination of Properties to the CRHR.
Properties eligible for listing in the CRHR and subject to review under CEQA are those meeting
the criteria for listing in the CRHR, or designation under a local ordinance.
The revised CEQA Guidelines include a new separate discussion for Tribal Cultural Resources
(TCRs). This section briefly examines potential impacts related to TCRs that could result from
implementation of the Project. The analysis is based primarily on confidential cultural resource
studies conducted for the Project. PRC language relevant to the TCR thresholds is below:
PRC Section 21074 defines a TCR as follows:
(a) “Tribal cultural resources” are either of the following:
(1) Sites, features, places, cultural landscapes, sacred places, and objects with cultural
value to a California Native American tribe that are either of the following:
(A) Included or determined to be eligible for inclusion in the California Register of
Historical Resources.
(B) Included in a local register of historical resources as defined in subdivision (k) of
Section 5020.1.
(2) A resource determined by the lead agency, in its discretion and supported by
substantial evidence, to be significant pursuant to criteria set forth in subdivision (c)
of Section 5024.1. In applying the criteria set forth in subdivision (c) of Section 5024.1
for the purposes of this paragraph, the lead agency shall consider the significance of
the resource to a California Native American tribe.
(b) A cultural landscape that meets the criteria of subdivision (a) above is a tribal cultural
resource to the extent that the landscape is geographically defined in terms of the size
and scope of the landscape.
(c) A historical resource described in Section 21084.1, a unique archaeological resource as
defined in subdivision (g) of Section 21083.2, or a “nonunique archaeological resource”
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as defined in subdivision (h) of Section 21083.2 may also be a tribal cultural resource if it
conforms with the criteria of subdivision (a).
Subdivision (k) of PRC Section 5020.1 is as follows:
(k) “Local register of historical resources” means a list of properties officially designated or
recognized as historically significant by a local government pursuant to a local ordinance
or resolution.
California Register of Historical Resources. The CRHR criteria are based on NRHP criteria
(Subdivision (c) of PRC Section 5024.1). For a property to be eligible for inclusion on the CRHR,
one or more of the following criteria must be met:
(1) Is associated with events that have made a significant contribution to the broad patterns
of California’s history and cultural heritage.
(2) Is associated with the lives of persons important in our past.
(3) 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 values.
(4) Has yielded, or may be likely to yield, information important in prehistory or history.
In addition to meeting one or more of the above criteria, the CRHR requires that sufficient time
has passed since a resource’s period of significance to “obtain a scholarly perspective on the
events or individuals associated with the resources.” (CCR 4852 [d][2]). The CRHR also requires
that a resource possess integrity. This is defined as the ability for the resource to convey its
significance through seven aspects: location, setting, design, materials, workmanship, feeling,
and association.
Finally, CEQA requires that significant effects on unique archaeological resources be considered
and addressed. CEQA defines a unique archaeological resource as any archaeological artifact,
object, or site about which it can be clearly demonstrated that, without merely adding to the
current body of knowledge, there is a high probability that it meets any of the following criteria:
1. Contains information needed to answer important scientific research questions and there
is a demonstrable public interest in that information.
2. Has a special and particular quality such as being the oldest of its type or the best available
example of its type.
3. Is directly associated with a scientifically recognized important prehistoric or historic
event or person.
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BCR Report Conclusion
Due to a lack of historical resources located within the Project site, BCR Consulting recommends
that no additional cultural resources work, or monitoring is necessary for any proposed Project
activities.
EIR Impact 3.4-1 and EIR Impact 3.4-2: Would the Project cause a substantial adverse
change in the significance of a historical and an
archeological resource, as defined in § 15064.5?
No New or More Severe Impact. Based on the CRHR significance criteria, research has failed to
associate the historic-period utility alignment with any important events or persons (Criteria 1
and 2). The site does not embody any distinctive characteristics, represent the work of a master,
or possess high artistic values (Criterion 3). Intensive survey has not identified any potential for
the site to yield information important to the prehistory or history of the local area, California,
or the nation (Criterion 4). As such, the Project site does not meet any of the CRHR significance
criteria and is not recommended a historical resource under CRHR. Therefore, it is not a unique
archaeological resource and is also not recommended a historical resource under CEQA and does
not warrant further consideration. Based on these results BCR Consulting recommends that no
additional cultural resource work or monitoring is necessary for any earthmoving proposed
within the Project site. However, if previously undocumented cultural (historical or
archaeological) resources are identified during earthmoving activities, a qualified archaeologist
should be contacted to assess the nature and significance of the find, diverting construction
excavation if necessary. Additionally, mitigation measures 3.4-1 and 3.4-2 from the LCA EIR will
be applied to the Project in order to reduce potential impacts to archeological resources.
Therefore, implementation of the Project would not result in any new or more severe impact
than previously analyzed and would adhere to any applicable mitigation measures identified in
the LCA EIR. Furthermore, the Project would be required to comply with the City’s established
standard conditions regarding cultural and tribal resources.
Mitigation Program
Mitigation Measures from the LCA EIR
• Mitigation 3.4-1 A qualified historical resources monitor shall be present at the project
site during grading. If evidence of subsurface historic resources are found during
construction, excavation in the vicinity of the find shall cease and a professional
archaeologist shall evaluate findings in accordance with standard practice and applicable
regulations.
• Mitigation 3.4-2 A qualified archaeological monitor shall be present at the project site
during grading. If evidence of subsurface prehistoric or historic archaeological resources
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are found during construction, excavation in the vicinity of the find shall cease and a
professional archaeologist shall evaluate findings in accordance with standard practice
and applicable regulations.
Conclusion
The Project would not result in new or more severe impact on a historic or archaeological
resource. No new or more severe impact from previously identified in the LCA EIR would occur
as a result of Project implementation. Further, no new information of substantial importance
that was not known and could not have been known at the time the LCA EIR was certified is
available that would impact the prior finding of less than significant impact with mitigation
incorporated under these impact thresholds. Although the BCR Report determined that the
Project site does not contain cultural or historical resources or that no additional cultural
resources work, or monitoring would be necessary for any proposed project activities, mitigation
measures 3.4-1 and 3.4-2 from the LCA EIR would be applied to the Project in order to reduce
potential impacts to archeological resources. Mitigation measures from the LCA EIR are
applicable in the event of accidental discovery of previously undocumented cultural (historical or
archaeological) resources are identified during earthmoving activities, a qualified archaeologist
should be contacted to assess the nature and significance of the find, diverting construction
excavation if necessary.
EIR Impact 3.4-3: Would the Project directly or indirectly destroy a unique paleontological
resource or site or unique geologic feature? [No longer included in this
section per the 2022 CEQA Appendix G Thresholds]
EIR Impact 3.4-4: Would the Project disturb any human remains, including those interred
outside of formal cemeteries?
No New or More Severe Impact. The Project site is not located within a known or suspected
cemetery and the field survey did not come across human remains within the Project site.
Additionally, the results of the records search conducted through the Western Science Center
(WSC) concluded that the Project area is mapped entirely as alluvial fan deposits dating from the
Holocene period. While Holocene alluvial units are considered to be of high preservation value,
material found is unlikely to be fossil material due to the relatively modern associated dates of
the deposits. The WSC does not have localities within the Project area or within a one-mile radius.
While the presence of any fossil material is unlikely, if excavation activity disturbs deeper
sediment dating to the earliest parts of the Holocene or Late Pleistocene periods, the material
would be scientifically significant. Based on the WSC results and history of the general Project
area, excavation activity associated with the development of the Project area is unlikely to be
paleontologically sensitive and a less than significant impact on human remains is anticipated.
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The BCR recommended the Project implement the standard condition (Standard Condition SC
CUL-1) in compliance with PRC Section 5097.98 which would be carried out during Project
construction to reduce any potential impact. The LCA EIR mitigation measures 3.4-4 would apply
to the Project and therefore the SC is a duplicative measure or condition. Further, mitigation
measure 3.4-3 from the LCA EIR would be applied to the Project in order to reduce potential
impacts to paleontological resources and any discovered human remains. Furthermore, the
Project would be required to comply with the City’s established standard conditions regarding
cultural and tribal resources.
Standard Condition
SC CUL-1 If human remains are encountered during the undertaking, State Health and
Safety Code Section 7050.5 states that no further disturbance shall occur until the
County Coroner has made a determination of origin and disposition pursuant to
PRC Section 5097.98. The County Coroner must be notified of the find
immediately. If the remains are determined to be prehistoric, the Coroner will
notify the Native American Heritage Commission (NAHC), which will determine
and notify a Most Likely Descendant (MLD). With the permission of the landowner
or his/her authorized representative, the MLD may inspect the site of the
discovery. The MLD shall complete the inspection within 48 hours of notification
by the NAHC.
Mitigation Program
Mitigation Measures from the LCA EIR
• Mitigation 3.4-3 A qualified paleontological monitor shall be present at the project site
during grading. If evidence of subsurface paleontological resources are found during
construction, excavation in the vicinity of the find shall cease and a professional
archaeologist shall evaluate findings in accordance with standard practice and applicable
regulations. Paleontological resources shall be evaluated for their significance, depth,
extent and integrity, as appropriate consistent with local, State, and federal guidelines.
• Mitigation 3.4-4 If human remains are discovered during any activities that involve
subsurface ground disturbance, there shall be no further excavation or disturbance of the
site or any nearby area reasonably suspected to overlie human remains until:
(1) The San Bernardino County Coroner has been informed and has determined that no
investigation of the cause of death is required, and
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(2) If the remains are of Native American origin, the Native American Heritage
Commission is contacted within 24 hours of the discovery, and the descendants from
the deceased native Americans have made a recommendation to the landowner or
the project proponent, for means of treating or disposing of, with appropriate dignity,
the human remains and any associated grave goods as provided in California Public
Resources Code Section 5097.98.
Conclusion
The Project would result in no new or more severe impact pertaining to the disturbance of human
remains. The Project is consistent with the LCA EIR. The WSC record search and BCR Report did
not find new potentially significant impacts associated with the Project regarding human
remains. Mitigation measures 3.4-3 and 3.4-4 from the LCA EIR will be applied to the Project in
order to reduce potential impacts to paleontological resources and potential impacts to
discovered human remains.
7.4.3 Overall Cultural Resources Impacts Conclusion
With regard to CEQA Statute Section 21166 and CEQA Guidelines Section 15162(a), the changes
proposed by the Project, with implementation of the LCA EIR MM 3.4-1 through MM 3.4-4 and
the City’s standard conditions of approval regarding Cultural Resources and Tribal Cultural
Resources, the Project would not result in any new or more severe impacts with respect to
cultural resources. Therefore, preparation of an SEIR is not warranted.
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7.5 Geology, Soils, and Seismicity
7.5.1 Summary of Previous Environmental Analysis
The LCA EIR concluded that implementation of the LCA would not result in significant impacts
relative to geology and soils, and no mitigation was identified as necessary to reduce potential
impacts.
7.5.2 Analysis of Proposed Project
EIR Impact 3.5-1: Would the project expose people or structures to potential adverse effects,
including the risk loss, injury, or death involving:
(a) Rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo
Earthquake Fault Zoning Map issued by the State Geologist for the area or based on
other substantial evidence of a known fault? Refer to Division of Mines and Geology
Special Publication 42.
No New or More Severe Impact: The Alquist-Priolo Zones Special Studies Act defines active faults
as those that have experienced surface displacement or movement during the last 11,000 years.
The Act dictates that cities and counties withhold development permits for projects within an
Earthquake Fault Zone within their jurisdiction until geologic investigations demonstrate that the
projects are not threatened by surface displacements from future earthquakes. According to the
LCA EIR, there are no active faults known to traverse the Project site and the site is not located
within the Alquist-Priolo Fault Study Zone. The Cucamonga and San Jacinto faults, two of the
most active faults in southern California, extend across the northern portion of the City of
Fontana.11 Further, the Sobrato development would comply with the applicable Federal, State,
and local regulations regarding seismicity and fault hazards such as the California Building Code
(CBC) which was adopted on January 1, 2020. The CBC includes detailed design requirements
related to structural design, soils and foundations, and grading to ensure that public safety risks
due to seismic shaking are minimized to levels below significant. The Project would not result in
a new or more severe impact in this regard and would be consistent with the previous impact
analysis in the EIR.
(b) Strong seismic ground shaking?
No New or More Severe Impact: Ground shaking is a general term referring to all aspects of
motion of the earth’s surface resulting from an earthquake that can cause major damage in
seismic events. The extent of ground shaking results from the magnitude and intensity of the
earthquake, distance from the epicenter, and local geologic conditions. Due to the strong natural
11 City of Fontana. (2017). Local Hazard Mitigation Plan. Available at https://www.fontana.org/DocumentCenter/View/28274/2017-Local-
Hazard-Mitigation-Plan. Accessed on October 4, 2021.
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seismic activities of Southern California, the Project site is susceptible to seismic ground shaking.
For this reason, all structures, including the proposed residential buildings, would be exposed to
potential strong seismic ground shaking throughout their lifespan. As such, the design and
construction of the Project would be required to be in conformance with the most recent CBC,
Fontana MC, the City’s 2017 Local Hazard Mitigation Plan (2017 LHMP), and other applicable local
or state standards. Adherence to these standards and regulations would reduce the potential
substantial adverse effects, caused by strong seismic ground shaking to less than significant. The
Project would not result in a new or more severe impact in this regard and would be consistent
with the previous impact analysis in the EIR.
(c) Seismic-related ground failure, including liquefaction?
No New or More Severe Impact: The LCA EIR found the soils on the site to be predominantly
excessively drained, course-textured/rocky-texture soils and the water table was more than 130
feet below ground surface and therefore the potential for liquefaction was very low to
nonexistent and would be considered less than significant. Because the Sobrato Project is located
on the same site with the same soil conditions, there would be no new or more severe impact in
this regard and would be consistent with the previous impact analysis in the EIR.
(d) Landslides?
No New or More Severe Impact: The LCA EIR found no impact with respect to landslides as the
Project area was flat and not located in an area that would be subject to landslides or mudflows.
Because the Sobrato Project is located on the same site, there would be no new or more severe
impact in this regard and would be consistent with the previous impact analysis in the EIR.
Mitigation Program
None identified in the LCA EIR.
Conclusion
The Project would result in no new or more severe impact due to susceptibility to landslides,
liquefaction, or seismic effects. A less than significant impact or no impact was identified in the
LCA EIR. The Project would be designed consistent with the applicable guidelines and standards
within the Fontana GP, Fontana MC, the LHMP, and Fontana ZDC. Therefore, no new mitigation
measures are required for issues related to geological hazards.
EIR Impact 3.5-2: Would the project result in substantial erosion or loss of topsoil?
EIR Impact 3.5-3: Would the 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
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result in on- or off-site landslide, lateral spreading, subsidence, liquefaction
or collapse?
EIR Impact 3.5-4: Would the project be located on expansive soil, as defined in Table 18-1-B
of the Uniform Building Code, creating substantial direct or indirect risks to
life or property?
No New or More Severe Impact for EIR Impacts 3.5-2 through 3.5-4: The LCA EIR concluded that
the implementation of the LCA would result in less than significant impacts with regard to hazards
in the form of ground subsistence, erosion, and unstable soils. Compliance with the City and
California RWQCB requirements, and Storm Water Pollution Prevention Plan (SWPPP) would
reduce any potential impacts to less than significant. The Sobrato Project would not result in
significant soil erosion or loss of topsoil. Grading increases the potential for erosion by removing
protective vegetation, changing natural drainage patterns, and constructing slopes. For this
reason, the City requires an erosion/dust control plan for projects located within this area. The
Project would also be required to comply with all requirements set forth in the NPDES permit for
construction activities (e.g., implementation of Best Management Practices [BMPs] through
preparation of a SWPPP), reducing potential impacts to less than significant levels. Additionally,
the Project would also be required to comply with the CBC and undergo review of grading plans
by the City Engineer who would ensure no significant impacts would occur. There would be no
new or more severe impact in this regard and would be consistent with the previous impact
analysis in the EIR.
Mitigation Program
None identified in the LCA EIR.
Conclusion
The Project would result in no new or more severe impact due to susceptibility to hazards from
land failure and erosion. A less than significant impact was identified in the LCA EIR. The Project
would be designed consistent with the applicable guidelines and standards within the Fontana
GP, Fontana MC, and Fontana ZDC. Therefore, no new and/or modified mitigation measures are
required for issues related to geological hazards.
EIR Impact 3.5-5: Would the project have soils incapable of adequately supporting the use of
septic tanks or alternative wastewater disposal systems where sewer are
not available for the disposal of waste water?
No New or More Severe Impact: The LCA EIR noted the LCA development would be required to
connect to the City’s existing sewer system as part of the review and approval process. There
would be no impact in this regard. Being on the same site, the Project would also be required to
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connect to the City’s sewer system and would not require the support of septic tank usage.
Therefore, the Project would not result in a new or more severe impact and would be consistent
with the previous impact analysis in the EIR.
Mitigation Program
None identified in the LCA EIR.
Conclusion
The Project would result in no new or more severe impact due to the presence of septic tanks. A
less than significant impact was identified in the LCA EIR. The Project would be designed
consistent with the applicable guidelines and standards within the Fontana GP, Fontana MC, and
Fontana ZDC. Therefore, no new and/or modified mitigation measures are required for issues
related to soil hazards in relation to septic systems.
EIR Impact 3.5-6: Would the 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?
[No longer included in this section per the 2022 CEQA Appendix G
Thresholds]
EIR Impact 3.5-7: Would the project result in the loss of a locally important mineral resource
recovery site delineated on a local general plan, specific plan, or other land
use plan? [No longer included in this section per the 2022 CEQA
Appendix G Thresholds]
No new or More Significant Impact: Mineral resources are discussed in Section 7.13 of this
Addendum.
7.5.3 Overall Geology and Soils Impacts Conclusion
With regard to CEQA Section 21166 and CEQA Guidelines Section 15162(a), the changes
proposed by the Project would not result in any new impacts, or increase the severity of the
previously identified impacts, with respect to geology and soils. Therefore, preparation of a SEIR
is not warranted.
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7.6 Hydrology and Water Quality
7.6.1 Summary of Previous Environmental Analysis
The LCA EIR concluded that implementation of the LCA would not result in significant impacts
relative to hydrology and water quality, and no mitigation is necessary to reduce potential
impacts.
7.6.2 Analysis of Proposed Project
EIR Impact 3.6-1: Would the project violate any water quality standards or waste discharge
requirements?
No New or More Severe Impact: According to the LCA EIR, the LCA would be required to connect
to the existing nearby sewer lines and therefore no waste discharge requirements were
anticipated. The LCA would also be required to comply with NPDES requirements would
effectively minimize impacts associated with water quality. As such, the Sobrato Project would
also be connected to existing sewer lines and required to comply with NPDES requirements,
Federal, State, and local regulations with regards the maintenance of water quality standards.
This includes obtaining an NPDES permit and the associated SWPPP. BMPs included in these
permits may include actions such as:
• Site design standards that maximize permeable areas, use porous pavements, and focus
on natural drainage systems;
• Structural source control that minimizes pollution of stormwater by such means as paving
trash storage areas and fueling areas with impervious surfaces, and grading such areas to
block run-off; and
• Treatment Control measures that Remove pollutants from stormwater by filtration,
media absorption, or other means.
There are five onsite catch basins which would convey stormwater into three drainage areas
(DMA A, DMA B, and DMA C). DMA A is the largest onsite drainage area with underground
corrugated metal pipe (CMP) detention system providing storage capacity of up to 49,331 cubic
feet (cf) to treat the stormwater. The maximum capacity of the proposed CMP detention system
would be sufficient to capture and store the projected 49,312 cf onsite water quality volume,
estimated in the Preliminary Water Quality Management Plan Exhibit; see Exhibit 7, Proposed
WQMP Exhibit.
No changes to the inlet structure in the extension of Lytle Creek Road/Open Space area are
proposed as part of the open space improvements and therefore no impacts to jurisdictional
waters would occur. The existing inlet structure is only conveying flows from the street to the
drainage to the south.
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Therefore, no new and/or modified mitigation measures are required for issues related to
potential water degradation through Project implementation.
Mitigation Program
None identified in the LCA EIR.
Conclusion
The Project would result in no new or more severe impact due to water quality degradation. A
less than significant impact was identified in the LCA EIR. The Project would be designed
consistent with the applicable guidelines and standards within the Fontana GP, Fontana MC, and
Fontana ZDC. Therefore, no new and/or modified mitigation measures are required for issues
related to water quality.
EIR Impact 3.6-2: Would the 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 ground water 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)?
No New or More Severe Impact: According to the LCA EIR, the LCA would not involve in direct
addition or withdrawal of groundwater resources and there are no wells planned on-site.
Therefore, no impact would occur in this regard. The Project would not introduce a new
inconsistent use to the Project area which would exceed the usages estimated with the land use
designation associated with the Project. Therefore, the Project would not deplete or otherwise
substantially degrade surface or groundwater quality, nor would it substantially decrease
groundwater supplies or interfere substantially with groundwater recharge such that the Project
may impede sustainable groundwater management of the basins. The Project therefore would
not result in new or more severe impacts related to groundwater. Accordingly, the Project would
not significantly impact local groundwater recharge and would be consistent with the previous
impact analysis in the EIR.
Mitigation Program
None identified in the LCA EIR.
Conclusion
The Project would result in no new or more severe impact due to groundwater degradation. A
less than significant impact was identified in the LCA EIR. No new information of substantial
importance that was not known and could not have been known at the time the LCA EIR was
certified is available that would change the impact determination. The Project would be designed
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consistent with the applicable guidelines and standards within the Fontana GP, Fontana MC, and
Fontana ZDC. Therefore, no new and/or modified mitigation measures are required for issues
related to groundwater.
EIR Impact 3.6-3: Would the project substantially alter the existing drainage pattern of the
site or area, including through the alteration of the course of a stream or
river, in a manner which would result in a substantial erosion or siltation
on- or off-site?
EIR Impact 3.6-4: Would the project substantially alter the existing drainage pattern of the
site or area, including through the alteration of the course of a stream or
river, or substantially increase the rate or amount of surface runoff in a
manner which would result in flooding on- or offsite?
EIR Impact 3.6-5: Would the project create or contribute runoff water that would exceed the
capacity of existing or planned storm water drainage systems or provide
substantial additional sources of polluted runoff?
EIR Impact 3.6-6: Would the project otherwise substantially degrade water quality?
No New or More Severe Impact for Impacts 3.6-3 through 3.6-6: As stated in the LCA EIR, the
LCA would be required to comply with the NPDES, Area-Wide Urban Storm Water Permit, issued
by the RWQCB, and the City’s Municipal Storm Water Management Plan to reduce any potential
impact of erosion or siltation to less than significant. The LCA would include detention facilities
to direct LCA runoff to the Highland Channel that would prevent on- and off-site flooding.
Therefore, the implementation of the LCA would result in less than significant impact with regard
to these issues.
As previously discussed in Section 7.5, Geology, Soils, and Seismicity in this Addendum EIR, the
Project would be required to attain an NPDES permit and associated SWPPP. These two processes
and the associated BMPs would adequately minimize potential off-site water quality impacts.
Construction-related BMPs would be identified based on site-specific conditions during
preparation of a SWPPP for the future development project. Long term operational BMPs would
be identified through issuance of an NPDES permit through the RWQCB and would include water
quality features to ensure that runoff is treated prior to discharge into the storm drain or regional
conveyance facilities.
As discussed above, there are five onsite catch basins which would convey stormwater into three
CMA drainage areas. The proposed underground CMP detention system in CMA A would provide
sufficient storage for the projected 49,312 cf onsite water quality volume, estimated in the
Preliminary Water Quality Management Plan Exhibit; see Exhibit 7. Additionally, the Lytle Creek
open space area located at the southern end of Lytle Creek Road would provide additional
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drainage infrastructure by allowing for further stormwater infiltration through the landscaped
areas.
No changes to the inlet structure in the extension of Lytle Creek Road/Open Space area are
proposed as part of the open space improvements and therefore no impacts to jurisdictional
waters would occur. The existing inlet structure is only conveying flows from the street to the
drainage to the south.
As such, the Project would result in no new or more severe impact from erosion or siltation and
would not create or contribute runoff water that would exceed the capacity of existing drainage
systems. Based on the LCA EIR findings, the Project site is not located in an area prone to the
previously mentioned natural or manmade disasters. Thus, the Project would not substantially
alter the existing drainage pattern of the site or area, including through the alteration of the
course of a stream or river or through the addition of impervious surfaces, in a manner which
would create the above-mentioned disasters. A less than significant impact is anticipated from
Project implementation. No new impact or increase in the severity of an identified impact would
therefore occur with implementation of the Project.
Mitigation Program
None identified in the LCA EIR.
Conclusion
The Project would result in no new or more severe impact with regards to alteration of existing
drainage patterns and water quality issues. A less than significant impact was identified in the
LCA EIR. The Project would be designed consistent with the applicable guidelines and standards
within the Fontana GP, Fontana MC, and Fontana ZDC and be in compliance with RWQCB and
NPDES requirements. Therefore, no new and/or modified mitigation measures are required for
issues related to flooding.
EIR Impact 3.6-7: Would the 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?
EIR Impact 3.6-8: Would the project place within a 100-year flood hazard area structures that
would impede or redirect flood flows?
EIR Impact 3.6-9: Would the 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?
EIR Impact 3.6-10: Would the project inundation by seiche, tsunami, or mudflow?
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No New or More Severe Impact: According to LCA EIR, the Project site is not located within a
Federal Emergency Management Agency (FEMA) designated 100-year floodplain. Further, the
current FEMA Flood Insurance Rate Map for the Project area shows that it lies outside of known
flood hazard zones. Additionally, the Project site is not located downstream from any dams or
levees and would not 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.
Although the Project would result in additional impervious surfaces on-site, the Project would
construct a water quality infiltration basin which would capture low flow storm water runoff from
the site. Accordingly, the proposed Project would not significantly impact local groundwater
recharge and is not anticipated to conflict with or obstruct implementation of a water quality
control plan or sustainable groundwater management plan. The Project would be subject to the
WQMP via the County’s SWPPP. Impacts would be less than significant.
The Project would not result in new or more severe impacts pertaining to flood hazard, tsunami,
or seiche zones, or risk the release of pollutants due to Project inundation. Based on the LCA EIR
findings, the Project site is not located in an area prone to the previously mentioned natural or
manmade disasters. Thus, no pollutants would be released due to inundation by seiche, tsunami,
or mudflow. Therefore, the Project would not involve the development of residential structures
or impede flood flows.
Impact Not in EIR: Would the project conflict with or obstruct implementation of a water
quality control plan or sustainable groundwater management plan?
The Project would be served with potable water by the Fontana Water Company (FWC). Domestic
water from this service provider is supplied via the groundwater from multiple sources. This
includes the Chino Groundwater Basin, the Rialto Groundwater Basin, the Lytle Groundwater
Basin, and the No-Man’s Land Groundwater Basin. These sources provide the City with the
majority of its water needs, with room for expansion. As well, all municipal water entities that
exceed their safe yield incur a groundwater replenishment ligation, which is used to recharge the
groundwater basin with State Water Project. Thus, the Project’s demand for domestic water
service would not conflict with or obstruct implementation of a water quality control plan or
sustainable groundwater management plan.
Mitigation Program
None identified in the LCA EIR.
Conclusion
The Project would not result in new or more severe impact due to flood risks. A less than
significant impact was identified in the LCA EIR. In addition, the Project would not conflict with
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or obstruct implementation of a water quality control plan or sustainable groundwater
management plan. The Project would be designed consistent with the applicable guidelines and
standards within the Fontana GP, Fontana MC, and Fontana ZDC. Therefore, no new and/or
modified mitigation measures are required for issues related to flooding.
7.6.3 Overall Hydrology and Water Quality-Related Impacts Conclusion
With regard to CEQA Section 21166 and CEQA Guidelines Section 15162(a), the changes
proposed by the Project would not result in any new impacts, or increase the severity of the
previously identified impacts, with respect to hydrology and water quality. Therefore,
preparation of a SEIR is not warranted.
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7.7 Land Use and Relevant Planning
7.7.1 Summary of Previous Environmental Analysis
According to the LCA EIR, implementation of the LCA would not divide an established community.
Additionally, the LCA EIR concluded that implementation of the LCA would not result in significant
impacts relative to land use and planning, and no mitigation is necessary to reduce potential
impacts.
7.7.2 Analysis of Proposed Project
EIR Impact 3.7-1: Would the project physically divide an established community?
No New or More Severe Impact: According to the EIR, the LCA would be built on vacant land
zoned for multi-family development and be surrounded by residential. Thus, the LCA
implementation would not physically divide an established community. The Sobrato Project
would be developed on the same site and be similar and consistent with surrounding uses and is
not anticipated to create additional physical barriers between these uses. Therefore, there are
no new or more severe impacts.
Mitigation Program
None identified in the LCA EIR.
Conclusion
The Project would not result in new or more severe land use impacts. No impact was identified
in the LCA EIR. The Project would be designed consistent with the applicable guidelines and
standards within the Fontana GP, Fontana MC, and Fontana ZDC. Therefore, no new and/or
modified mitigation measures are required for issues related to land use.
EIR Impact 3.7-2: Would the project cause a significant environmental impact due to a
conflict with any land use plan, policy, or regulation adopted for the
purpose of avoiding or mitigating an environmental effect?
No New or More Severe Impact: Less than significant impacts related to land use and planning
are identified in the LCA EIR. Per the EIR, the LCA would not introduce an incompatible land use
to the surrounding area, nor would it cause a significant environmental impact due to a conflict
with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an
environmental effect.
Development of amenities in the easement in the existing extension of Lytle Creek Road/Open
Space area would be developed consistent the applicable Fontana ZDC. Therefore, development
of the roadway with open space amenities would not create new impacts.
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The Sobrato Project would not require an amendment to the Fontana GP Land Use Element,
because residential uses are permitted uses by right within R-MF. As such, the Project would be
consistent with applicable land use plans, including the Fontana GP.
Mitigation Program
None identified in the LCA EIR.
Conclusion
The Project would result in no new or more severe land use impacts. A less than significant impact
was identified in the LCA EIR. The Project would be designed consistent with the applicable
guidelines and standards within the Fontana GP, Fontana MC, and Fontana ZDC. Therefore, no
new and/or modified mitigation measures are required for issues related to land use.
EIR Impact 3.7-3: Would the project conflict with any applicable habitat conservation plan or
natural community conservation plan. [No longer included in this section
of the 2022 CEQA Appendix G Thresholds]
See Section 7.3, Biological Resources in this Addendum EIR.
Mitigation Program
None identified in the LCA EIR.
Conclusion
The Project would result in no new or more severe land use impacts. A less than significant impact
was identified in the LCA EIR. The Project would be designed consistent with the applicable
guidelines and standards within the Fontana GP, Fontana MC, and Fontana ZDC. Therefore, no
new and/or modified mitigation measures are required for issues related to land use.
7.7.3 Overall Land Use and Planning Impacts Conclusion
With regard to CEQA Section 21166 and CEQA Guidelines Section 15162(a), the changes
proposed by the Project would not result in any new impacts, or increase the severity of the
previously identified impacts, with respect to land use and planning. Therefore, preparation of a
SEIR is not warranted.
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7.8 Noise
7.8.1 Summary of Previous Environmental Analysis
The LCA EIR considered noise from construction activities as well as noise from operations for
the LCA, including vehicle traffic the potential exposure of nearby residents and other sensitive
receptors to noise. With implementation of Mitigation 3.8-1, noise impacts related to short-term
construction were determined to remain significant and unavoidable. Impacts from ground-
borne vibrations and noise levels during construction and long-term operation were determined
to be less than significant. In addition, no impact was anticipated to occur with respect to airport
related noise impacts due to the Project being located approximately ten miles north of the
Ontario International Airport. Operation noise impacts generated from electrical and mechanical
equipment would be mitigated to less than significant levels through compliance with
Mitigation 3.8-3.
7.8.2 Analysis of Proposed Project
An Acoustical Assessment (Noise Study) was prepared for the Project by Kimley-Horn and
Associates (November 2021). The Study is in included as Appendix F to this Addendum EIR. The
results from the Noise Study are summarized herein:
Existing Noise Sources
The City is impacted by various noise sources. Mobile sources of noise, especially cars, trucks,
and trains are the most common and significant sources of noise. Other noise sources are the
various land uses (i.e., residential, commercial, institutional, and recreational and parks activities)
throughout the City that generate stationary-source noise.
Mobile Sources
Existing roadway noise levels were calculated for the roadway segments in the Project vicinity.
This task was accomplished using the Federal Highway Administration (FHWA) Highway Traffic
Noise Prediction Model (FHWA-RD-77-108) and Existing (2017) ADT Volumes from the Fontana
Forward General Plan Update 2015-2035 Draft Environmental Impact Report.12 The noise
prediction model calculates the average noise level at specific locations based on traffic volumes,
average speeds, roadway geometry, and site environmental conditions. The average vehicle
noise rates (also referred to as energy rates) used in the FHWA model have been modified to
reflect average vehicle noise rates identified for California by the California Department of
Transportation (Caltrans). The Caltrans data indicates that California automobile noise is 0.8 to
12 City of Fontana, Fontana Forward General Plan Update 2015-2035 Draft Environmental Impact Report,
https://www.fontana.org/DocumentCenter/View/29524/Draft-Environmental-Impact-Report-for-the-General-Plan-Update, accessed
November 2, 2021.
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1.0 dBA higher than national levels and that medium and heavy truck noise is 0.3 to 3.0 dBA lower
than national levels. The average daily noise levels along local roadway segments in proximity to
the Project site are included in Table 15, Existing Traffic Noise Levels. As shown in Table 15,
existing traffic noise levels along local roadways in the Project vicinity range between 53.6 dBA
CNEL and 60.9 dBA CNEL.
Table 15: Existing Traffic Noise Levels
In addition, according to the on-site traffic noise modeling results provided in Section 6.1,
Acoustical Impacts (On-Site Traffic Noise) of the Noise Study, noise levels from SR-210 traffic
range from approximately 57.6 dBA CNEL to 72.8 dBA CNEL (at ground level) at the Project site.
Stationary Sources
The primary sources of stationary noise in the Project vicinity are those associated with
residential properties surrounding the Project. The noise associated with these sources may
represent a single-event noise occurrence or short-term noise. Other noises include mechanical
equipment (e.g., heating ventilation and air conditioning [HVAC] equipment), dogs barking, idling
vehicles, and residents talking.
Noise Measurements
The Project site is currently vacant and unoccupied. To quantify existing ambient noise levels in
the Project area, Kimley-Horn conducted four short-term noise measurements on
October 7, 2021; see Appendix A: Noise Data in the Acoustical Assessment (Appendix F of this
Addendum). The noise measurement sites were representative of typical existing noise exposure
within and immediately adjacent to the Project site. The 10-minute measurements were taken
between 8:37 a.m. and 9:30 a.m. Measurements of Leq are considered representative of the noise
levels throughout the day. The average noise levels and sources of noise measured at each
location are listed in Table 16, Existing Noise Measurements and shown on Exhibit 8, Noise
Measurement Locations.
Roadway Segment ADT dBA CNEL1
Sierra Lakes Parkway
Lytle Creek Road to Maloof Avenue 16,000 60.9
Lytle Creek Road
South of Sierra Lakes Parkway Road 3,000 53.6
ADT = average daily trips; dBA = A-weighted decibels; CNEL= Community Equivalent Noise Level
Notes:
1. Traffic data obtained from the Fontana Forward General Plan Update 2015-2035 Draft Environmental Impact Report, 2018.
2. Traffic noise levels are at 100 feet from the roadway centerline. Noise levels modeled using the FHWA-RD-77-108 Highway Traffic Noise
Prediction Model; see Appendix A of the Acoustical Assessment for traffic noise modeling results.
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Table 16: Existing Noise Measurements
Site Location Measurement Period Duration
Daytime
Average Leq
(dBA)
1 Southwest corner of Ross Way and
Lytle Creek Road 8:37 – 8:47 a.m. 10 Minutes 62.1
2
Western side of Lytle Creek Road,
near the intersection of Jocelyn
Way and Lytle Creek Road
8:51 – 9:01 a.m. 10 Minutes 62.8
3 Along the south side of Sierra Lake
Parkway, east of the Project site 9:06 – 9:16 a.m. 10 Minutes 71.6
4 At the southern end of Malouf
Avenue 9:20 – 9:30 a.m. 10 Minutes 70.6
Source: Noise measurements taken by Kimley-Horn, October 7, 2021. See Appendix A of the Acoustical Assessment for noise measurement
results.
Sensitive Receptors
Noise exposure standards and guidelines for various types of land uses reflect the varying noise
sensitivities associated with each of these uses. Land uses considered sensitive receptors include
residences, schools, playgrounds, childcare centers, long‐term health care facilities,
rehabilitation centers, convalescent centers, and retirement homes. Sensitive land uses
surrounding the Project consist mostly of residential communities. Sensitive land uses near the
Project include single-family uses north, east, and west of the site. There are also residences
located to the south of the Project site (south of SR-210); however, these uses are heavily
influenced by traffic noise on SR-210 and would not be influenced by noise-generating activities
at the Project site.
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Exhibit 8: Noise Measurement Locations
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CEQA Thresholds of Significance
Appendix G of the CEQA Guidelines contains analysis guidelines related to noise impacts. These
guidelines have been used by the City to develop thresholds of significance for this analysis. A
project would create a significant environmental impact if it would:
• Generate a substantial temporary or permanent increase in ambient noise levels in the
vicinity of the project in excess of standards established in the local general plan or noise
ordinance, or applicable standards of other agencies;
• Generate excessive ground-borne vibration or ground-borne noise levels; and
• For a project located within the vicinity of a private airstrip or 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, expose people residing or working in the Project area to excessive noise
levels.
Methodology
Construction
Construction noise levels were based on typical noise levels generated by construction
equipment published by the Federal Transit Administration (FTA) and FHWA. Construction noise
is assessed in dBA Leq. This unit is appropriate because Leq can be used to describe noise level
from operation of each piece of equipment separately, and levels can be combined to represent
the noise level from all equipment operating during a given period.
FHWA’s Roadway Construction Noise Model was used to estimate construction noise at nearby
sensitive receptors. For modeling purposes, construction equipment has been distributed evenly
between the center of the construction site and the nearest receptor. To be conservative, the
loudest and most used equipment was placed nearest the sensitive receptor. Noise level
estimates do not account for the presence of intervening structures or topography, which may
reduce noise levels at receptor locations. Therefore, the noise levels presented herein represent
a conservative, reasonable worst-case estimate of actual temporary construction noise.
Operations
The analysis of the Without Project and With Project noise environments is based on noise
prediction modeling and empirical observations. Reference noise level data are used to estimate
the Project operational noise impacts from stationary sources. Noise levels are collected from
field noise measurements and other published sources from similar types of activities are used
to estimate noise levels expected with the Project’s stationary sources. The reference noise levels
are used to represent a worst-case noise environment as noise level from stationary sources can
vary throughout the day. Operational noise is evaluated based on the standards within the City’s
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Noise Ordinance and General Plan. The Without Project and With Project traffic noise levels in
the Project vicinity were calculated using the FHWA Highway Noise Prediction Model
(FHWA-RD-77-108).
Vibration
Ground-borne vibration levels associated with construction-related activities for the Project were
evaluated utilizing typical ground-borne vibration levels associated with construction equipment,
obtained from FTA published data for construction equipment. Potential ground-borne vibration
impacts related to building/structure damage and interference with sensitive existing operations
were evaluated, considering the distance from construction activities to nearby land uses and
typically applied criteria.
For a building that is constructed with reinforced concrete with no plaster, the FTA guidelines
show that a vibration level of up to 0.20 in/sec is considered safe and would not result in any
vibration damage. Human annoyance is evaluated in vibration decibels (VdB) (the vibration
velocity level in decibel scale) and occurs when construction vibration rises significantly above
the threshold of human perception for extended periods of time. The FTA Transit Noise and
Vibration Impact Assessment Manual (FTA, 2018) (FTA Noise and Vibration Manual) identifies 80
VdB as the threshold for buildings where people normally sleep.
Impact Analysis
EIR Impact 3.8-1: Would the project result in 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?
No New or More Severe Impact.
Construction
Construction noise typically occurs intermittently and varies depending on the nature or phase
of construction (e.g., land clearing, grading, excavation, paving). Noise generated by construction
equipment, including earth movers, material handlers, and portable generators, can reach high
levels. During construction, exterior noise levels could affect the residential neighborhoods
surrounding the construction site. The nearest sensitive receptors to the Project construction
area are existing residential uses located approximately 325 feet to the west of the Project site’s
acoustic center. Following FTA methodology, when calculating construction noise, all equipment
is assumed to operate at the center of the Project because equipment would operate throughout
the Project site and not at a fixed location for extended periods of time.
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Construction activities would include site preparation, grading, building construction, paving, and
architectural coating. Such activities would require dozers and tractors during site preparation;
excavators, graders, and dozers during grading; cranes, forklifts, generators, tractors, and
welders during building construction; pavers, rollers, mixers, and paving equipment during
paving; and air compressors during architectural coating. Typical operating cycles for these types
of construction equipment may involve 1 or 2 minutes of full power operation followed by 3 to 4
minutes at lower power settings. Other primary sources of acoustical disturbance would be
random incidents, which would last less than one minute (such as dropping large pieces of
equipment or the hydraulic movement of machinery lifts). Noise generated by construction
equipment, including earth movers, material handlers, and portable generators, can reach high
levels. Typical noise levels associated with individual construction equipment are listed in
Table 17, Typical Construction Noise Levels.
The City’s Municipal Code does not establish quantitative construction noise standards. Instead,
the Municipal Code establishes limited hours of construction activities. Municipal Code
Section 18-63 states that construction activities may only take place between the hours of
7:00 a.m. and 6:00 p.m. on weekdays and between the hours of 8:00 a.m. and 5:00 p.m. on
Saturdays, except in the case of urgent necessity or otherwise approved by the City of Fontana.
However, this analysis conservatively uses the FTA’s threshold of 80 dBA (8-hour Leq) for
residential uses to evaluate construction noise impacts.13 The noise levels calculated in Table 18,
Project Construction Noise Levels at Nearest Receptor, show estimated exterior construction
noise levels at the nearest sensitive uses (residences located approximately 325 to the north of
the Project site’s acoustic center) without accounting for attenuation from physical barriers or
topography.
Table 17: Typical Construction Noise Levels
Equipment Typical Noise Level (dBA) at 50 feet from Source
Air Compressor 81
Backhoe 80
Compactor 82
Concrete Mixer 85
Concrete Pump 82
Concrete Vibrator 76
Crane, Derrick 88
Crane, Mobile 83
Dozer 85
Generator 81
Grader 85
Impact Wrench 85
Jack Hammer 88
Loader 85
13 Federal Transit Administration, Transit Noise and Vibration Impact Assessment Manual, Table 7-2, Page 179, September 2018.
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Equipment Typical Noise Level (dBA) at 50 feet from Source
Paver 89
Pneumatic Tool 85
Pump 76
Roller 74
Saw 76
Scraper 89
Shovel 82
Truck 88
Note:
1. Calculated using the inverse square law formula for sound attenuation: dBA2 = dBA1+20Log(d1/d2)
Where: dBA2 = estimated noise level at receptor; dBA1 = reference noise level; d1 = reference distance; d2 =
receptor location distance
Source: Federal Transit Administration, Transit Noise and Vibration Impact Assessment Manual, September
2018.
Table 18: Project Construction Noise Levels at Nearest Receptor
Construction Phase
Modeled Exterior
Construction Noise Level
(dBA Leq)
Noise Threshold
(dBA Leq) Exceed Threshold?
Site Preparation 73.3 80 No
Grading 68.7 80 No
Building Construction 67.7 80 No
Paving 63.7 80 No
Architectural Coating 61.4 80 No
Note: Equipment distributed evenly between the center of the construction site and the nearest sensitive receptor.
Source: Federal Highway Administration, Roadway Construction Noise Model, 2006. Refer to Appendix A of the Acoustical Assessment for
noise modeling results.
Table 18 depicts a worst-case scenario for each phase of construction, with all equipment
operating simultaneously while located as close to the nearest sensitive receptor as possible.
However, during construction, equipment would operate throughout the Project site and the
associated noise levels would not occur at a fixed location for extended periods of time. As
indicated in Table 18, Project construction noise levels would not exceed the FTA’s 80 dBA
threshold at the nearest residential uses.
In addition, compliance with the Municipal Code would further minimize impacts from
construction noise, as construction would be limited to daytime hours on weekdays and
Saturdays. Therefore, because Project construction noise levels would not exceed FTA noise
standards and construction activities would be required to comply with Municipal Code
provisions, noise impacts would be less than significant noise impact in this regard.
Operations
Implementation of the proposed Project would create new sources of noise in the Project vicinity.
The major noise sources associated with the Project that would potentially impact existing
nearby residences include stationary noise equipment (i.e., trash compactors, air conditioners,
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etc.); parking areas (i.e., car door slamming, car radios, engine start-up, and car pass-by); and off-
site traffic noise.
The Lytle Creek Open Space area would create new sources of noise associated with the use of
the amenities and outdoor play equipment. The noise would be similar to what is anticipated in
a park setting and generally during daytime hours that would be regulated by the HOA.
Additionally, this noise would be less than what is anticipated with traffic, freeway noise, radios,
etc. associated with cars in the cul-de-sac. Therefore, development of the Lytle Creek Open Space
area with open space amenities would not create new impacts.
Mechanical Equipment
The nearest sensitive receptors to the Project site are the single-family residences located 30 feet
east and west of the Project site. Potential stationary noise sources related to long-term
operation of the Project would include mechanical equipment. Mechanical equipment
(e.g., HVAC equipment) typically generates noise levels of approximately 52 dBA at 50 feet.14
Based on Project site plans, the nearest potential location for a HVAC unit would be located
approximately 70 feet from the nearest residential property. At this distance, HVAC noise levels
would attenuate by the distance to approximately 49.10 dBA, which is below the City’s 65 dBA
noise standard for residential uses.
Additionally, standard construction practices, such as wall assemblies and windows, would result
in an exterior-interior noise level reduction of approximately 25 dBA.15 As such, interior HVAC
noise levels would be approximately 24.08 dBA, which is below the City’s 45 dBA interior noise
standard for residential uses. Operation of mechanical equipment would not increase ambient
noise levels beyond the acceptable compatible land use noise levels. Further, it is noted that
noise from stationary sources at the Project site would primarily occur during the daytime activity
hours of 7:00 a.m. to 10:00 p.m. Therefore, the proposed Project would result in a less than
significant impact related to stationary noise levels.
Parking Noise
The Project would provide 397 parking stalls. Parking spaces would be a combination of ground-
floor garage spaces for each unit, and open parking spaces throughout the Project site. Nominal
parking noise would occur within the on-site parking facilities. Traffic associated with parking lots
is typically not of sufficient volume to exceed community noise standards, which are based on a
time-averaged scale such as the CNEL scale. The instantaneous maximum sound levels generated
by a car door slamming, engine starting up, and car pass-bys range from 53 to 61 dBA16 and may
14 Elliott H. Berger, Rick Neitzel, and Cynthia A. Kladden, Noise Navigator Sound Level Database with Over 1700 Measurement Values, 2015.
15 U.S. Environmental Protection Agency, Protective Noise Levels (EPA 550/9-79-100), November 1979.
16 Kariel, H. G., Noise in Rural Recreational Environments, Canadian Acoustics 19(5), 3-10, 1991.
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be an annoyance to adjacent noise-sensitive receptors. It should be noted that parking lot noises
are instantaneous noise levels compared to noise standards in the hourly Leq or 24-hour CNEL
metrics, which are averaged over the entire duration of a time period.
Additionally, parking noise also occurs at the adjacent properties surrounding the site under
existing conditions. Parking and driveway noise would be consistent with existing noise in the
vicinity and would be partially masked by background traffic noise from motor vehicles traveling
along SR-210 to the south and Sierra Lakes Avenue to the north. Actual noise levels over time
resulting from parking activities will be far below the City’s noise standards. Therefore, noise
impacts associated with parking would be less than significant.
Off-Site Traffic Noise
Implementation of the Project would generate increased traffic volumes along nearby roadway
segments. Using the trip rates from the Trip Generation and VMT Screening Memorandum for
the Proposed Citrus East Residential Project in the City of Fontana (Kimley-Horn, 2021)
(Traffic Impact Study), the proposed Project would generate approximately 1,047 daily trips
which would result in noise increases on Project area roadways. In general, a traffic noise increase
of less than 3 dBA is barely perceptible to people, while a 5-dBA increase is readily noticeable.17
Generally, traffic volumes on Project area roadways would have to approximately double for the
resulting traffic noise levels to increase by 3 dBA. Therefore, permanent increases in ambient
noise levels of less than 3 dBA are considered to be less than significant.
Traffic noise levels for roadways primarily affected by the Project were calculated using the
FHWA’s Highway Noise Prediction Model (FHWA-RD-77-108). Traffic noise modeling was
conducted for conditions with and without the Project, based on traffic volumes from the Traffic
Impact Study. As indicated in the Traffic Impact Study, Existing Conditions Plus Project traffic-
generated noise levels on Project area roadways would range between 54.9 dBA CNEL and
61.1 dBA CNEL at 100 feet from the centerline, and the Project would result in a maximum
increase of 1.3 dBA CNEL along Lytle Creek Road. As such, the Project would result in an increase
of less than 3.0 dBA CNEL for the roadway segments analyzed and traffic noise impacts from off-
site traffic would be less than significant.
Traffic noise levels for roadways primarily affected by the Project were calculated using the
FHWA’s Highway Noise Prediction Model (FHWA-RD-77-108). Traffic noise modeling was
conducted for conditions with and without the Project, based on traffic volumes from the Traffic
Impact Study. As indicated in Table 19, Existing Plus Project Traffic Noise Levels, Existing
Conditions Plus Project traffic-generated noise levels on Project area roadways would range
17 Federal Highway Administration, Highway Traffic Noise Analysis and Abatement Policy and Guidance, Noise Fundamentals,
https://www.fhwa.dot.gov/environMent/noise/regulations_and_guidance/polguide/polguide02.cfm, accessed November 2, 2021.
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between 54.9 dBA CNEL and 61.2 dBA CNEL at 100 feet from the centerline, and the Project would
result in a maximum increase of 1.3 dBA CNEL along Lytle Creek Road. As such, the Project would
result in an increase of less than 3.0 dBA CNEL for the roadway segments analyzed and traffic
noise impacts from off-site traffic would be less than significant.
Table 19: Existing Plus Project Traffic Noise Levels
Roadway Segment
Existing
Conditions
Existing
Conditions Plus
Project
Project
Change
from No
Build
Conditions
Significant
Impact?
ADT1 dBA
CNEL2 ADT dBA
CNEL2
Sierra Lakes Parkway
Lytle Creek Road to Maloof Avenue 16,000 60.9 17,047 61.2 0.3 No
Lytle Creek Road
South of Sierra Lakes Parkway 3,000 53.6 4,047 54.9 1.3 No
ADT = average daily trips; dBA = A-weighted decibels; CNEL= Community Equivalent Noise Level
Notes:
1. Traffic data obtained from the Fontana Forward General Plan Update 2015-2035 Draft Environmental Impact Report, 2018.
2. Traffic noise levels are at 100 feet from the roadway centerline. Noise levels modeled using the FHWA-RD-77-108 Highway Traffic Noise
Prediction Model; see Appendix A of the Acoustical Assessment for traffic noise modeling results.
The Horizon Year “2040 Without Project” and “2040 Plus Project” scenarios were also compared.
As shown in Table 20, Horizon Year and Horizon Year Plus Project Traffic Noise Levels, roadway
noise levels would range between 54.9 dBA CNEL and 61.4 dBA CNEL at 100 feet from the
centerline, and the Project would result in a maximum increase of 1.3 dBA CNEL. As such, the
Project would result in an increase of less than 3.0 dBA CNEL for the roadway segments analyzed
and traffic noise. Noise impacts from off-site traffic would be less than significant in this regard.
Table 20: Horizon Year and Horizon Year Plus Project Traffic Noise Levels
Roadway Segment
Horizon Year
(2040)
Horizon Year
(2040) Plus Project
Project
Change from
No Build
Conditions
Significant
Impact? ADT1 dBA
CNEL2 ADT dBA
CNEL2
Sierra Lakes Parkway
Lytle Creek Road to Maloof Avenue 17,000 61.1 18,010 61.4 0.3 No
Lytle Creek Road
South of Sierra Lakes Parkway 3,000 53.6 4,010 54.9 1.3 No
ADT = average daily trips; dBA = A-weighted decibels; CNEL= Community Equivalent Noise Level
Notes:
1. Traffic data obtained from the Fontana Forward General Plan Update 2015-2035 Draft Environmental Impact Report, 2018.
2. Traffic noise levels are at 100 feet from the roadway centerline. Noise levels modeled using the FHWA-RD-77-108 Highway Traffic Noise
Prediction Model; see Appendix A for traffic noise modeling results.
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On-Site Traffic Noise
A noise impact analysis has been completed to determine the noise exposure levels that would
result from off-site transportation noise sources, and to identify potential noise reduction
measures that would achieve acceptable exterior and interior noise levels. The primary source of
traffic noise affecting the Project site is from SR-210. This analysis addresses on-site exterior and
interior noise levels at proposed residential receptors.
The California Supreme Court in a December 2015 opinion (California Building Industry
Association v. Bay Area Air Quality Management District, 62 Cal. 4th 369 [No. S 213478])
confirmed that CEQA, with several specific exceptions, is concerned with the impacts of a project
on the environment, not the effects the existing environment may have on a project. Therefore,
this section is not required under CEQA and is included for informational purposes only. The
evaluation of the significance of project impacts in the following discussion is provided to ensure
compliance with City and State Building Code noise standards.
Predicted On-Site Traffic Noise
Traffic volumes along SR-210 were obtained from the Caltrans Traffic Census Program.18 Truck
ADT and fleet mix data was also obtained from the Caltrans Traffic Census. Roadways and
receivers were digitized in the FHWA Traffic Noise Model, Version 2.5 (TNM 2.5) based on the
Project site plan layout. The model also accounted for the differences in elevation between the
roadway and each receptor. Noise levels were calculated at the exterior receptor locations for
each of the proposed two stories with residential units.
Table 21, Unmitigated On-Site Traffic Noise Levels provides the results of the modeling and
Exhibit 9, Traffic Noise Receiver Locations (All Floors) depicts the location of the modeled noise
receivers. As shown in Table 21, unmitigated exterior noise levels on-site would range from 57.6
dBA CNEL to a maximum of 72.8 dBA CNEL at first floor receptors, and from 68.0 dBA CNEL to a
maximum of 77.8 dBA CNEL at second floor receptors. Unmitigated interior noise levels on-site
would range from 32.6 dBA CNEL to a maximum of 47.8 dBA CNEL at first floor receptors, and
from 43.0 dBA CNEL to a maximum of 52.8 dBA CNEL at second floor receptors; see Table 21.
Noise levels would be lower at the receivers further away from SR-210. Proposed residential units
would have outdoor (patio) space on the first floor that are exposed to traffic noise from SR-210.
18 California Department of Transportation, Traffic Census Program, https://dot.ca.gov/programs/traffic-operations/census, accessed
November 2, 2021.
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Table 21: Unmitigated On-Site Traffic Noise Levels
Receiver No. Exterior Noise Levels (dBA CNEL)1 Interior Noise Levels (dBA CNEL)2
First Floor Second Floor First Floor Second Floor
1 72.4 76.9 47.4 51.9
2 72.8 76.8 47.8 51.8
3 72.7 76.9 47.7 51.9
4 69.5 76.2 44.5 51.2
5 66.1 74.9 41.1 49.9
6 61.9 73.0 36.9 48.0
7 61.2 71.8 36.2 46.8
8 69.2 77.8 44.2 52.8
9 67.5 74.8 42.5 49.8
10 67.3 70.3 42.3 45.3
11 67.0 71.8 42.0 46.8
12 64.9 70.9 39.9 45.9
13 64.8 68.4 39.8 43.4
14 61.5 70.0 36.5 45.0
15 63.1 68.0 38.1 43.0
16 57.6 71.6 32.6 46.6
17 58.9 71.2 33.9 46.2
18 66.5 76.7 41.5 51.7
Notes:
1. Refer to Exhibit 8 for modeled receiver locations. Receivers in Bold text exceed applicable noise standards. TNM 2.5 input and output files
are provided in Appendix A of the Acoustical Assessment.
2. A 25 dBA noise attenuation rate was utilized to determine the interior noise standards (U.S. Environmental Protection Agency, Protective
Noise Levels (EPA 550/9-79-100), November 1979). Each of the receivers in the table would be required to use mechanical ventilation to
ensure a “closed window” condition is satisfied.
As indicated in Table 21, unmitigated on-site traffic noise levels from SR-210 would exceed the
City’s 65 dBA CNEL exterior noise standard at the outdoor patio areas of 11 of the 18 modeled
receivers on the first floor and at all receivers on the second floor (Exhibit 9: Traffic Noise Receiver
Locations (All Floors)). In addition, the City’s 45 dBA CNEL noise standard would be exceeded at
3 of the 18 modeled receivers on the first floor, and at 15 of the 18 modeled receivers on the
second floor assuming an exterior-interior sound reduction of 25 dBA from standard construction
practices. The Governor’s Office of Planning and Research (OPR) employs noise/land use
compatibility standards in Appendix D: Noise Element Guidelines of the State of California
General Plan Guidelines (OPR, 2017) (OPR Guidelines) of the Noise Study that establishes a
conditionally acceptable noise standard of 70 dBA CNEL for multi-family residential uses (noise
levels over 70 dBA CNEL are considered normally unacceptable and new development is
discouraged). For new multi-family residential projects located in areas with conditionally
acceptable noise levels, the OPR Guidelines state that “New construction or development should
be undertaken only after a detailed analysis of the noise reduction requirements is made and
needed noise insulation features included in the design. Conventional construction, but with
windows closed and fresh air supply systems or air conditioning will normally suffice.” Thus, noise
reduction measures are recommended to reduce on-site traffic noise levels from SR-210 at the
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Project site to comply with the conditionally acceptable land use compatibility standard in the
OPR Guidelines.
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Exhibit 9: Traffic Noise Receiver Locations (All Floors)
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Architectural Conditions/Techniques
Based on the TNM 2.5 modeling results, 10 modeled receivers at the Project site (Receivers 1
through 5, 8 through 11, and 18) would require noise abatement to reduce exterior noise levels
at the first floor outdoor residential patio areas in compliance with the conditionally acceptable
noise standard of 70 dBA CNEL; three modeled receivers on the first floor would require noise
abatement to reduce interior noise levels to meet the 45 dBA CNEL noise standard; all
18 receivers would require noise abatement for exterior noise levels on the second floor; and
15 receivers on the second floor would require noise abatement to reduce interior noise levels
below 45 dBA CNEL. Recommendations would include the use of an 8-foot-high masonry wall
along the rear of the Project, upgraded windows, prohibiting outdoor balcony areas on the
second floors of residential units, and including HVAC systems at each residence.
Concrete Masonry Wall
In order to reduce traffic noise at the outdoor patio areas of on-site residential units, an 8-foot-
high perimeter wall along the southern boundary, and a 6-foot-hight perimeter wall along the
northern, eastern, and western boundary is recommended in compliance with Recommendation
1 (REC-1); the approximate wall location is depicted in Exhibit 9. Acceptable materials for the
construction of the wall shall have a weight of 2.5 pounds per square foot of surface area. The
barrier may be composed of the following: masonry block, stucco veneer over wood framing
(or foam core), glass, Plexiglass or Lexan (1/4-inch thick) and may be constructed out of a
combination of the above listed materials. Table 22, Mitigated On-Site Traffic Noise Levels, shows
the on-site traffic noise levels with implementation of the recommended perimeter walls.
As indicated in Table 22, exterior noise levels at the first-floor outdoor patio areas would range
from 57.3 dBA CNEL to 68.9 dBA CNEL with the recommended eight-foot-high perimeter wall and
would be below the OPR Guideline’s conditionally acceptable compatibility standard of 70 dBA
CNEL. Interior noise levels at the first-floor receivers would range from 32.3 dBA CNEL to 43.9 dBA
CNEL with the recommended eight-foot-high perimeter wall and would not exceed the interior
noise standard of 45 dBA CNEL. However, exterior noise levels at 16 of the 18 receivers on the
second floor would exceed the conditionally acceptable noise compatibility standard of 70 dBA
CNEL, and interior noise levels at 15 of the 18 modeled receivers on the second floor would
exceed the 45 dBA CNEL interior noise standard; see Table 22. Due to the elevation difference
between the building and SR-210, the eight-foot-high perimeter wall would not be effective for
upper story receivers. Thus, additional noise abatement and attenuation features are needed.
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Table 22: Mitigated On-Site Traffic Noise Levels
Receiver No. Exterior Noise Levels (dBA CNEL)1 Interior Noise Levels (dBA CNEL)2
First Floor Second Floor First Floor Second Floor
1 66.7 76.9 41.7 51.9
2 66.8 76.9 41.8 51.9
3 66.9 76.9 41.9 51.9
4 68.8 76.3 43.8 51.3
5 62.4 74.9 37.4 49.9
6 59.6 73.0 34.6 48.0
7 57.6 71.8 32.6 46.8
8 68.9 77.8 43.9 52.8
9 63.1 74.8 38.1 49.8
10 60.6 70.3 35.6 45.3
11 58.8 71.8 33.8 46.8
12 64.6 70.9 39.6 45.9
13 64.6 68.4 39.6 43.4
14 60.9 70.0 35.9 45.0
15 63.1 68.0 38.1 43.0
16 57.3 71.6 32.3 46.6
17 57.9 71.2 32.9 46.2
18 66.4 76.7 41.4 51.7
Notes:
1. Refer to Exhibit 8 for modeled receiver locations. Receivers in Bold text exceed applicable noise standards. TNM 2.5 input and output files
are provided in Appendix A of the Acoustical Assessment.
2. A 25 dBA noise attenuation rate was utilized to determine the interior noise standards (U.S. Environmental Protection Agency, Protective
Noise Levels (EPA 550/9-79-100), November 1979). Each of the receivers in the table would be required to use mechanical ventilation to
ensure a “closed window” condition is satisfied.
Window Treatments
Although sound insulation varies with frequency and is very different for various types of
partitions, it is convenient to compare the effectiveness of two partitions using a method of rating
insulation that can be represented by a single number. In North America, the most commonly
used single number rating is the Sound Transmission Class (STC). A STC rating of 0 indicates that
a partition provides no airborne sound insulation.
Typical values of sound insulation ratings provided by various types of window constructions are
presented in Table 23, Sound Transmission Class for Windows. For high sound insulation, the
purchase of commercially available windows that have been rated by a recognized testing
laboratory provides better performance for a given cost than individually designed units. To
obtain a sound transmission class rating above 45, it is necessary to select acoustical windows
with specially designed frames, and glass mounting is recommended.
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Table 23: Sound Transmission Class for Windows
STC1 Single Glazed
Glass Thickness
Dual Glazed Glass (Airspace Between Glass)
Inches (mm)
Sealed
Window
Operable
Window Inches (mm) Both 1/8-Inch
(3-mm) Glass
Both 1/4-Inch
(6-mm) Glass
1/4-Inch (6-mm) Laminated
9/32-Inch (7-mm) Glass
30 27 1/8 (3), 5/32 (4) 1/4 (6) NA NA
32 29 1/4 (6) 3/8 (10) NA NA
34 31 1/4 (6) L2 3/4 (20) 5/16 (8) NA
36 32 1/2 (12) 1-1/4 (30) 1/2 (13) NA
38 34 1/2 (12) L2 2 (50) 3/4 (20) 3/8 (10)
40 36 NA 2-3/4 (70) 1-1/4 (30) 5/8 (16)
42 37 NA 4 (100) 2 (50) 1 (25)
44 39 NA 6 (150) 3-1/4 (80) 1-1/2 (40)
46 41 NA NA 4-3/4 (120) 2-7/8 (60)
48 43 NA NA NA 4 (100)
mm = millimeter; NA = Not Applicable
Notes:
1. STC ratings assume that windows have effective weather stripping.
2. L denotes laminated glass. For example 1/4 (6) L is 1/4-inch (6 mm) thick laminated glass.
Source: Cyril M. Harris, Noise Control in Buildings – A Practical Guide for Architects and Engineers, 1994.
Transmission of sound through a hollow window frame can significantly reduce the sound
insulation, especially for windows with very high STC. This reduction can be minimized by drilling
one or more holes in the hollow frame and pumping a mastic material to fill the hollow frame.
The following is a listing of various window types that are utilized on typical residential structures:
• Single Glazing (Unlaminated). The sound insulation provided by single glazing improves
with increasing glass thickness. However, the increase is limited in the mid-frequency
range by the stiffness of the glass. As indicated in Table 23, a single, unlaminated layer of
solid glass usually does not provide an STC rating above 32 for a sealed window and 29
for an operable window.
• Laminated Glass. aminated glass is two or more layers of glass bonded together by thin
plastic interlayers. It can provide higher values of sound transmission class than solid glass
of equal thickness. This is because the sound insulation versus thickness of single sheets
of glass exhibits a dip at a frequency determined by the stiffness of the glass. The
improvement in sound insulation is primarily due to damping by the plastic interlayers
that reduce the magnitude of the dip.
• Dual Glazing. Dual glazing is two panes of glass with airspace between them. Dual glazing
provides greater sound insulation at high frequencies than single glazed laminated glass.
Table 23 compares typical values of STC for sealed windows, with corresponding values for
operable windows, and for single-glazed windows of various thicknesses. These STC values
increase with the increasing thickness of glass. For glass of a given thickness, sealed windows
provide greater sound insulation than operable windows. The overall improvement provided by
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dual glazing depends on the separation of the layers and glass thickness. For each doubling of the
airspace, there is an increase in STC rating of about 3. There is some advantage in using two panes
of laminated glass, especially for glass thicker than ¼ inch (6 mm).
As discussed above, interior noise levels experienced on the second floors at Receivers 1 through
12 and 16 through 18 would exceed the interior standard of 45 dBA CNEL with standard
construction practices; refer to Table 23. Therefore, the minimum STC ratings shall be provided
for second floor windows as identified on Exhibit 6 of Appendix F in order to ensure interior noise
levels are below the 45 dBA CNEL interior requirement at the Project site.
Balcony Treatments
In general, second floor receivers on the eastern, southern, and western facades of the
motorcourt buildings would be exposed to exterior noise levels exceeding the City’s conditionally
acceptable noise standard of 70 dBA CNEL for multi-family uses. Therefore, it is recommended
that outward facing balconies on the second floors of the motorcourt buildings incorporate noise
attenuating balcony or patio treatments to reduce exterior noise levels below the City’s 70 dBA
CNEL standard, as recommended in REC-3.
Heating Ventilation and Air Conditioning
In a HVAC system, the components that generate the most sound power are the supply fan (in
the air supply system) and the return fan (in the return air system). By definition, a fan is a device
for moving air, which utilizes a power-driven rotating impeller. A fan has at least one inlet opening
and at least one outlet opening. The opening may or may not be provided with connections to
ductwork.
If an HVAC system does not have good aerodynamic design and efficient operation of the various
components, the noise level of fan noise sources may increase in level. The airflow at the
entrance and exit of a fan should be as smooth as possible to minimize the generation of
turbulence; turbulence results in the generation of noise and an increased static pressure drop
in the system. It is recommended that the following measures would be implemented to reduce
noise levels associated with HVAC equipment:
• Fittings (such as elbows and transitions) should not be placed closer than 3 to 6 duct
diameters downstream from a fan;
• For an HVAC system having a constant volume of airflow, operate the fans generally close
to their maximum efficiency;
• For a variable-volume system, a variable-speed drive should be considered to maintain
operating efficiency for low volume;
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• Avoid any obstruction close to the fan inlet or fan outlet;
• Provide a minimum space of 1.5 duct diameters at the fan inlet or fan outlet;
• Consider the installation of bell-shaped inlet to provide better airflow conditions at the
fan; and
• Avoid offsets, abrupt or nonsymmetrical transitions, or offset flexible duct connectors in
ductwork since they will be source of turbulence and therefore noise sources.
These measures are required as part of REC-4 and REC-5.
Conclusion
Based on TNM 2.5 traffic noise modeling for future receivers at the Project site, the Project should
include an eight-foot-high perimeter wall, and windows with a minimum STC rating of 31 to 38
at the receivers/dwelling units identified above in the “Window Treatments” section in order to
ensure interior noise levels are below the 45 dBA CNEL interior standard. In addition, each
residence/dwelling unit should include an HVAC system to allow for a closed windows condition,
and balconies should be prohibited on the second floor to avoid exposure to excessive noise
levels for on-site residents.
Upon final site design and development of architectural schematic and building plans, the Project
engineer shall ensure that the building construction specifications for windows and entry doors
include the STC-rated windows and eight-foot-high perimeter wall identified above. The STC
ratings for the Project shall be specified upon final site design and shall be submitted to and
approved by the City of Fontana prior to issuance of building permits.
Recommendations:
REC-1 The Project should include an eight-foot-high perimeter wall along the southern
boundary and a 6 foot height perimeter wall along the northern, eastern, and western
boundary, identified in Appendix F, to reduce exterior noise levels in outdoor
residential areas. Acceptable materials for the construction of the wall barrier shall
have a weight of 2.5 pounds per square foot of surface area. The barrier may be
composed of the following: masonry block, stucco veneer over wood framing (or foam
core), glass, Plexiglass or Lexan (1/4-inch think) and may be constructed out of a
combination of the above listed materials. The final recommendations for design shall
be submitted and approved by the City of Fontana Community Development Director.
REC-2 After the final architectural drawings have been developed, and prior to the issuance
of building permits, the Project Applicant shall demonstrate, to the satisfaction of the
City of Fontana Community Development Director (or designee) that the applicable
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Project plans and specifications include sound-rated windows and entry doors on the
residential facades identified in Exhibit 6.
REC-3 Prior to the issuance of building permits, the Project Applicant shall demonstrate, to
the satisfaction of the City of Fontana Building Official that the outward-facing
balconies on the eastern, southern, and western facades of second floor motorcourt
units shall incorporate noise attenuating balcony and/or patio treatments. Balconies
more than 6 feet deep shall include a barrier that is at least 42 inches high as
measured from the floor. Acceptable materials for the construction of the barrier shall
have a weight of 2.5 pounds per square foot of surface area. The barrier may be
composed of the following: masonry block, stucco veneer over wood framing (or foam
core), glass, Plexiglass or Lexan (1/4-inch thin) and may be constructed out of a
combination of the above listed materials.
REC-4 The final site design should implement centralized heating, ventilation, and air-
conditioning units (HVAC) on all of the affected units to ensure noise levels will be
below 45 dBA with the windows and doors closed. Additionally, the mechanical
ventilation units shall be designed to supply two air changes per hour for each
habitable room, with a minimum of 15 cubic feet per minute of outside air per
occupant. The fresh air inlet duct shall be of sound attenuating construction and shall
consist of ten feet of straight or curved ducts plus one sharp 90-degree bend.
REC-5 The Project Applicant shall include the following recommendations in the design of
the HVAC equipment:
• Fittings (such as elbows and transitions) should not be placed closer than 3 to 6
duct diameters downstream from a fan;
• For an HVAC system having a constant volume of airflow, operate the fans
generally close to their maximum efficiency;
• For a variable-volume system, a variable-speed drive should be considered to
maintain operating efficiency for low volume;
• Avoid any obstruction close to the fan inlet or fan outlet;
• Provide a minimum space of 1.5 duct diameters at the fan inlet or fan outlet;
• Consider the installation of bell-shaped inlet to provide better airflow conditions
at the fan; and
• Avoid offsets, abrupt or nonsymmetrical transitions, or offset flexible duct
connectors in ductwork since they will be source of turbulence and therefore
noise sources.
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Mitigation Program
Mitigation Measures from the LCA EIR
MM 3.8-1 Prior to Grading Permit issuance, the Applicant shall demonstrate, to the
satisfaction of the City of Fontana, that the Project complies with the
following:
• All construction equipment, fixed or mobile, shall be equipped with
properly operating and maintained mufflers;
• Construction noise reduction methods such as shutting off idling
equipment, installing temporary acoustic barriers around stationary
construction noise sources, maximizing the distance between
construction equipment staging areas and occupied residential areas,
and use of electric air compressors and similar power tools, rather than
diesel equipment, shall be used where feasible;
• During construction, stationary construction equipment shall be
placed such that emitted noise is directed away from sensitive noise
receivers;
• During construction, stockpiling and vehicle staging areas shall be
located as far as practical from noise sensitive receptors;
• Operate earthmoving equipment on the construction site, as far away
from vibration sensitive sites as possible; and
• Construction hours, allowable workdays, and the phone number of the
job superintendent shall be clearly posted at all construction entrances
to allow for surrounding owners and residents to contact the job
superintendent. If the City or the job superintendent receives a
complaint, the superintendent shall investigate, take appropriate
corrective action, and report the action taken to the reporting party.
• Construction activities shall be limited to the hours of 7:00 a.m. and
6:00 p.m. on weekdays.
Conclusion
No new impacts or a substantial increase in the severity of a previously identified significant
impact evaluated in the LCA EIR would occur. Additionally, no new information of substantial
importance that was not known and could not have been known at the time the LCA EIR was
certified is available that would impact the prior finding of no significant impact under this issue
area.
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EIR Impact 3.8-2: Would the project result in exposure of persons to or generation of
excessive groundborne vibration or groundborne noise levels?
No New or More Severe Impact. Increases in ground-borne vibration levels attributable to the
proposed Project would be primarily associated with short‐term construction‐related activities.
The FTA has published standard vibration velocities for construction equipment operations in the
FTA Noise and Vibration Manual. The types of construction vibration impacts include human
annoyance and building damage.
Building damage can be cosmetic or structural. Ordinary buildings that are not particularly fragile
would not experience cosmetic damage (e.g., plaster cracks) at distances beyond 30 feet. This
distance can vary substantially depending on soil composition and underground geological layer
between vibration source and receiver. In addition, not all buildings respond similarly to vibration
generated by construction equipment. For example, for a building that is constructed with
reinforced concrete with no plaster, the FTA guidelines show that a vibration level of up to 0.20
in/sec is considered safe and would not result in any vibration damage. Human annoyance is
evaluated in vibration decibels (VdB) (the vibration velocity level in decibel scale) and occurs
when construction vibration rises significantly above the threshold of human perception for
extended periods of time. The FTA Transit Noise and Vibration Manual identifies 80 VdB as the
approximate threshold for annoyance.
The nearest sensitive receptors are the single-family residences located approximately 30 feet to
the east and west of the Project site. However, since construction activity would be intermittent
and the use of heavy construction equipment would be spread throughout the Project site and
not concentrated at one specific location for an extended period of time, it is assumed the
concentration of construction activity for the purposes of this vibration analysis would occur no
closer than 50 feet from the nearest sensitive receptors. Table 24, Typical Construction
Equipment Vibration Levels, lists vibration levels at 25 and 50 feet for typical construction
equipment. Ground-borne vibration generated by construction equipment spreads through the
ground and diminishes in magnitude with increases in distance. As indicated in Table 24, based
on FTA data, vibration velocities from typical heavy construction equipment operations that
would be used during Project construction range from 0.001 to 0.032 in/sec PPV at 50 feet from
the source of activity, which is below the FTA’s 0.20 PPV threshold for building damage and 80
VdB threshold for human annoyance. Therefore, vibration impacts associated with the Project
construction would be less than significant.
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Table 24: Typical Construction Equipment Vibration Levels
Equipment
Peak Particle
Velocity at 25 Feet
(in/sec)
Peak Particle
Velocity at 50 Feet
(in/sec)
Approximate VdB
at 25 Feet
Approximate VdB
at 50 Feet
Large Bulldozer 0.089 0.032 87 78
Loaded Trucks 0.076 0.027 86 77
Jackhammer 0.035 0.012 79 70
Small Bulldozer/Tractors 0.003 0.001 58 49
Notes:
1. Calculated using the following formula: PPVequip = PPVref x (25/D)1.5, where: PPVequip = the peak particle velocity in in/sec of the equipment
adjusted for the distance; PPVref = the reference vibration level in in/sec from Table 7-4 of the Federal Transit Administration, Transit Noise
and Vibration Impact Assessment Manual, 2018; D = the distance from the equipment to the receiver.
2. Calculated using the following formula: Lv(D) = Lv(25 feet) - (30 x log10(D/25 feet)) per the FTA Transit Noise and Vibration Impact
Assessment Manual (2018).
Source: Federal Transit Administration, Transit Noise and Vibration Impact Assessment Manual, 2018.
Once operational, the Project would not be a significant source of ground-borne vibration.
Ground-borne vibration surrounding the Project currently result from heavy-duty vehicular travel
(e.g., refuse trucks, heavy duty trucks, delivery trucks, and transit buses) on the nearby local
roadways. Operations of the proposed Project would include truck deliveries. Due to the rapid
drop-off rate of ground-borne vibration and the short duration of the associated events,
vehicular traffic-induced ground-borne vibration is rarely perceptible beyond the roadway right-
of-way, and rarely results in vibration levels that cause damage to buildings in the vicinity.
According to the FTA’s Transit Noise and Vibration Impact Assessment, trucks rarely create
vibration levels that exceed 70 VdB (equivalent to 0.012 inches per second PPV) when they are
on roadways. Therefore, trucks operating at the Project site or along surrounding roadways
would not exceed FTA thresholds for building damage or annoyance. Impacts would be less than
significant in this regard and no mitigation is required.
Mitigation Program
Mitigation Measures from the LCA EIR
No mitigation measures were identified in the LCA EIR.
Conclusion
No new impacts or a substantial increase in the severity of a previously identified significant
impact evaluated in the LCA EIR would occur. Additionally, no new information of substantial
importance that was not known and could not have been known at the time the LCA EIR was
certified is available that would impact the prior finding of no significant impact under this issue
area.
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EIR Impact 3.8-3: Would the project result in a substantial permanent increase in ambient
noise levels in the project vicinity above existing levels without the project?
[No longer included in CEQA Appendix G Thresholds]
EIR Impact 3.8-3: Would the project result in a substantial temporary or periodic increase in
ambient noise levels in the project vicinity above existing levels without the
project? [No longer included in CEQA Appendix G Thresholds]
No New or More Severe Impact. Development of the Project would generate approximately
1,047 daily vehicle trips, which would be significantly less than trips resulting from
implementation of the LCA Project. The LCA EIR estimated approximately 1,667 daily trip rates.
The LCA EIR determined that the LCA Project could potentially result in a substantial permanent
increase in ambient noise levels in the Project vicinity above existing levels without the Project
due increases in traffic and residential activities. As such Mitigation Measure 3.8-3 was proposed
to ensure any potential impacts in this regard would be less than significant. The Sobrato Project
would develop approximately 40 percent less units and generate less vehicle trips. In addition,
development of the Project would comply with all applicable design and regulations per Fontana
GP and ZDC. The Project would also adhere to LCA EIR Mitigation Measure 3.8-3. As such, a less
than significant impact is anticipated, and the Project would not result in a new or more severe
impact. No new mitigation measure is required.
Impacts regarding temporary or periodic increase in ambient noise levels would be generated
during short-term construction of the Project. As previously discussed in LCA EIR Impact 3.8-1,
the short-term construction impacts would remain significant and unavoidable after
implementation of Mitigation Measure 3.8-1. The Project would not create any new or more
severe impact in this regard.
Mitigation Program
Mitigation Measures from the LCA EIR
MM 3.8-3 Electrical and mechanical equipment (i.e., ventilation and air conditioning
units) and trash compactors shall be located as far away as feasible from
habitable areas of the residential units (i.e., living sleeping rooms).
Additionally, the following shall be considered prior to installation: proper
selection and sizing' of equipment, installation of equipment with proper
acoustical shielding, and incorporating the use of parapets into the
building design. All stationary equipment shall be designed to meet the
noise criteria as specified in the City of Fontana Zoning and Development
Code and will be subject to approval by the City Planning Department.
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Conclusion
No new impacts or a substantial increase in the severity of a previously identified significant
impact evaluated in the LCA EIR would occur. Additionally, no new information of substantial
importance that was not known and could not have been known at the time the LCA EIR was
certified is available that would impact the prior finding of no significant impact under this issue
area.
EIR Impact 3.8-5: 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 project expose people residing or working in the project
area to excessive noise levels?
EIR Impact 3.8-6: For a project located within the vicinity of a private airstrip, would the
project expose people residing or working in the project area to excessive
noise levels?
No New or More Severe Impact: The nearest airport to the Project site is the Ontario
International Airport located approximately 8.34 miles to the southwest. Thus, the Project is not
located within an airport land use plan or within two miles of an airport and would not expose
people residing or working in the Project area to excessive noise levels. No impact would occur
in this regard.
Mitigation Program
Mitigation Measures from the LCA EIR
No mitigation measures were identified in the LCA EIR.
Conclusion
No new impacts or a substantial increase in the severity of a previously identified significant
impact evaluated in the LCA EIR would occur. Additionally, no new information of substantial
importance that was not known and could not have been known at the time the LCA EIR was
certified is available that would impact the prior finding of no significant impact under this issue
area.
7.8.3 Overall Noise Impact Conclusion
With regard to CEQA Statute Section 21166 and CEQA Guidelines Section 15162(a), the changes
proposed by the Project would not result in any new impacts, or increase the severity of the
previously identified impacts, with respect to noise. Therefore, preparation of a SEIR is not
warranted.
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7.9 Population and Housing
7.9.1 Summary of Previous Environmental Analysis
According to the LCA EIR, implementation of the LCA would not result in any significant impacts
to existing residential units within the City and would not result in the potential for displacement
of residential uses. As such, the LCA EIR concluded that impacts in this regard would be less than
significant and no mitigation measures were recommended.
7.9.2 Analysis of Proposed Project
EIR Impact 3.9-1: Would the project induce substantial unplanned population growth in an
area, either directly (for example, by proposing new homes and businesses)
or indirectly (for example, through extension of roads or other
infrastructure)?
No New or More Severe Impact: The LCA EIR concluded that the implementation of the 238-unit
LCA would result in an increase of 951 resident. At the time of the EIR certification, this increase
would represent approximately 0.59 percent of the City’s 2004 population of 160,015 persons.
However, the population growth would be less than significant as the LCA would be developed
on land designated for residential uses and would be consistent with applicable zoning and land
use designations. Therefore, the potential growth, resulting from the LCA, was already
anticipated in the Fontana GP and impacts would be less than significant.
The Project proposes to develop 143 single-family homes on the same site and would result in
100 less units being constructed and a lower density. In Fontana, the current average household
size is 4.02 persons per household.19 Given an average household size of 4.02 persons per
household Project could potentially add an estimated 575 residents to the City, or approximately
60 percent of the LCA’s population estimate. Therefore, the Project would result in approximately
40 percent lower population growth and would not create new or more severe impact, when
compared to the LCA and therefore impacts would be less than significant and be consistent with
the previous impact analyzed in the EIR.
Mitigation Program
Mitigation Measures from the Final EIR
No mitigation measures were identified in the LCA EIR.
Conclusion
There are no new potentially significant impacts associated with the Project; therefore, no new
and/or refined mitigation measures are required.
19 California Department of Finance. 2021. E-5 Population and Housing Estimates for Cities, Counties, and the State, 2011-2020 with 2010 Census
Benchmark. Available at https://www.dof.ca.gov/forecasting/demographics/estimates/e-5/. Accessed on October 5, 2021.
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EIR Impact 3.9-2: Would the project displace substantial numbers of existing housing,
necessitating the construction of replacement housing elsewhere?
EIR Impact 3.9-3: Would the project displace substantial numbers of existing people,
necessitating the construction of replacement housing elsewhere?
No New or More Severe Impact: The LCA EIR concluded that no impact would occur with regard
to the LCA displacing substantial numbers of existing people and housing, necessitating the
construction of replacement housing elsewhere.
The Project site is vacant and undeveloped. The development of new single-family residential
would not remove currently occupied housing, or reduce the City’s capacity for housing, the
provision of replacement housing would not be necessary. No impact would occur in this regard,
consistent with the previous impact analyzed in the EIR.
Senate Bill (SB) 330, the Housing Accountability Act, which is part of the Planning and Zoning Law,
prohibits a local agency from disapproving, or conditioning approval in a manner that renders
infeasible, a housing development project for very low, low-, or moderate-income households or
an emergency shelter unless the local agency makes specified written findings based on a
preponderance of the evidence in the record. SB 330 also sets a temporary five-year prohibition
of residential density reduction associated with a “housing development project,” from
January 1, 2020, to January 1, 2025. The Project site is currently vacant and undeveloped. The
development of the Project would not replace an existing residential and/or result in density
reduction.
Mitigation Program
Mitigation Measures from the Final EIR
No mitigation measures were identified in the LCA EIR.
Conclusion
There are no new potentially significant impacts associated with the Project; therefore, no new
and/or refined mitigation measures are required.
7.9.3 Overall Population and Housing Impact Conclusion
With regard to CEQA Statute Section 21166 and CEQA Guidelines Section 15162(a), the changes
proposed by the Project would not result in any new impacts, or increase the severity of the
previously identified impacts, with respect to population and housing. Therefore, preparation of
a SEIR is not warranted.
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7.10 Public Services and Utilities
7.10.1 Summary of Previous Environmental Analysis
The LCA EIR concluded that there is potential for service needs to increase relative to fire
protection, police protection, and schools with the implementation of the Fontana GP. However,
these increases in population would still remain within the City’s service capacity. The LCA EIR
also concluded that implementation of the Fontana GP would not significantly increase the
demand for library services that would require construction of additional library facilities.
EIR Impact 3.10-1a through 3.10-1d: Would the project result in a substantial adverse physical
impact associated with the provision of 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
services, fire protection services, school services, parks
services, and other public facilities?
No New or More Severe Impact: The LCA EIR concluded that payment of development impact
fees along with compliance with Mitigation Measures 3.10-1a and 3.10-1b would reduce the
impacts affected by the population growth resulting from the LCA.
The Project implementation would consequently increase the demand for all public services in
the area. However, the Project does not include or require construction of any new or physically
altered fire protection, police protection, school, or other public facilities. Prior to
commencement of construction activities, the Project plans would be reviewed by applicable
local agencies to ensure compliance with the Fontana MC and Fontana ZDC, as well as all
applicable regulations to ensure adequate site signage, lighting, and other crime safety
preventative measures. This includes fair use fees which are sourced from developers that are
distributed to City services such as fire and police protection facilities. Fire Station 78 is the
nearest fire station and is located approximately 1 mile southeast of the Project site. The nearest
Fontana Police Department (FPD) is approximately 3 miles southeast of the Project site.
Construction of the Project would not result in adverse physical impacts associated with the
provision of or need for new or physically altered public facilities, and would not adversely affect
service ratios, response times, or other performance objectives. Further, the proposed
modification to Lytle Creek Road for an open space amenity would further reduce potential safety
concern by eliminating the cul-de-sac as a potential nuisance and creating an amenity for the
Sobrato neighborhood. Compliance with applicable local regulations would ensure that Project
construction would result in a less than significant impact to public services.
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Mitigation Program
Mitigation Measures identified in the LCA EIR:
• Mitigation 3.10-1a: Prior to the approval of final design, the Fontana Police Department
shall review the design in accordance with the principles of the Crime Prevention Through
Environmental design program. Modifications to the project design suggested by the
Fontana Police Department shall be incorporated where feasible.
• Mitigation 3.10-1b: The completed project shall participate in the Fontana Police
Department Crime Free Multi-Housing Program.
Conclusion
No new information of substantial importance that was not known and could not have been
known at the time the LCA EIR was certified is available. Impacts to fire protection, police
protection, schools, and other public facilities are anticipated to be less than significant. Lastly,
the Project’s payment of the General City Development Impact Fees (DIF), a portion of which is
allocated to the fire department(s), would aid in offsetting any potential impacts. There are no
new potentially significant impacts associated with the Project; therefore, no new and/or refined
mitigation measures are required. Mitigation Measures 3.10-1a and 3.10-1b from the EIR would
apply to the Project.
EIR Impact 3.10-2: Would the 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? [No longer
included in this section per the 2022 CEQA Appendix G Thresholds]
No New or More Severe Impact: The LCA EIR concluded that implementation of the LCA would
increase demand on the City parks in the vicinity of the site due to the estimated 951 persons in
population growth. Payment of DIF would offset the potential impact and reduce to less than
significant.
The Project implementation would consequently increase the demand for all public services in
the area due to the estimated population growth of 575 persons. However, the population
growth resulting from the Project would be 40 percent less than the growth resulting from the
LCA. Further, the Project would provide amenities for the community including a community
pool, open play spaces, wellness walk, and creative gathering spaces. Additionally, the Project
would develop the Lytle Creek Open Space area with open space play areas and amenities
including a dog park, half-court basketball, and open play grass areas. These amenity
improvements would reduce the impacts to the City facilities. Therefore, the Project would not
create a new or more severe impact than the previous impact analyzed in the EIR.
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Mitigation Program
None identified in the LCA EIR
Conclusion
No new information of substantial importance that was not known and could not have been
known at the time the LCA EIR was certified is available. Impacts to public services and facilities
are anticipated to be less than significant. Lastly, the Project’s payment of the City Development
Impact Fees would help offset any potential costs associated with the impacts. There are no new
potentially significant impacts associated with the Project; therefore, no new and/or refined
mitigation measures are required.
EIR Impact 3.10-3: Does the project include recreational facilities or require the construction
or expansion of recreational facilities which might have an adverse physical
effect on the environment? [No longer included in this section per the 2022
CEQA Appendix G Thresholds]
No New or More Severe Impact: The LCA EIR discussed that the LCA Project would include on-
site recreational facilities that would only be available to the LCA residents. The EIR concluded
that implementation of the LCA would increase demand on the recreational facilities in the
vicinity of the site due to the estimated 951 persons in population growth. Payment of
development impact fees would offset the potential impact and reduce to less than significant.
The Project implementation would consequently increase the demand for all public services and
facilities in the area due to the estimated population growth of 551 persons. However, the
population growth, resulting from the Project, would be 42 percent less than the growth resulting
from the LCA. As well, increased recreation demand on nearby parks would be further minimized
by the inclusion of approximately 126,430 sf of private recreation and open space facilities within
the Project area. These additional open space and recreation facilities would specifically serve
the members of the Project community. Therefore, the Project would not create a new or more
severe impact than the previous impact analyzed in the EIR.
Mitigation Program
None identified in the LCA EIR
Conclusion
No new information of substantial importance that was not known and could not have been
known at the time the LCA EIR was certified is available. The Project would be subject to the City
Development Impact Fees. The DIF would aid in offsetting any potential impacts. Also, the Project
would include recreational facilities to be used by its residents. There are no new potentially
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significant impacts associated with the Project; therefore, no new and/or refined mitigation
measures are required.
EIR Impact 3.10-4: Would the project exceed wastewater treatment requirements of the
applicable Regional Water Quality Control Board? [No longer included in
this section per the 2022 CEQA Appendix G Thresholds]
No New or More Severe Impact: The LCA EIR concluded the LCA would be required to connect
to the City’s existing wastewater infrastructure system and no impact would occur. The Project
would result in an increase in wastewater generation. However, because the Project would result
in a lower number of residents at buildout, when compared to the LCA, the rate of wastewater
generation from the Project would be less than the rate assumed in the EIR for the LCA.
Therefore, the Project would not create a new or more severe impact than the previous impact
analyzed in the EIR.
Mitigation Program
None identified in the LCA EIR.
Conclusion
No new information of substantial importance that was not known and could not have been
known at the time the LCA EIR was certified is available. The Project would be subject to the City
DIF. The DIFs would aid in offsetting any potential impacts. There are no new potentially
significant impacts associated with the Project; therefore, no new and/or refined mitigation
measures are required.
EIR Impact 3.10-5: Would the 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? [No
longer included in this section per the 2022 CEQA Appendix G Thresholds]
No New or More Severe Impact: The LCA EIR concluded the LCA would be required to pay the
DIFs and be in compliance with the FWD and the Inland Empire Utilities Agency (IEUA) regulations
to reduce any significant impacts to less than significant. The Project would result in an increase
in wastewater generation and water use. However, because the Project would result in a lower
number of residents at buildout, when compared to the LCA, the rates of wastewater generation
and water use from the Project would be less than the rates assumed in the EIR for the LCA. The
Project would not require ore result in the construction of new water or wastewater treatment
facilities or expansion of existing facilities. Therefore, the Project would not create a new or more
severe impact than the previous impacts analyzed in the EIR.
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Mitigation Program
None identified in the LCA EIR
Conclusion
No new information of substantial importance that was not known and could not have been
known at the time the LCA EIR was certified is available. The Project would be subject to the City
Development Impact Fees. The DIFs would aid in offsetting any potential impacts. There are no
new potentially significant impacts associated with the Project; therefore, no new and/or refined
mitigation measures are required.
EIR Impact 3.10-6: Would the 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? [No longer included
in this section per the 2022 CEQA Appendix G Thresholds]
No New or More Severe Impact: The LCA EIR concluded the LCA would be required to include
both on-site drainage and off-site improvements and be subject to DIFs. Therefore, impacts in
this regard would be less than significant. The Project would result in a lower number of residents
at buildout, when compared to the LCA. The Project would also be required to pay the DIFs.
Therefore, the Project would not create a new or more severe impact than the previous impacts
analyzed in the EIR.
Mitigation Program
None identified in the LCA EIR
Conclusion
No new information of substantial importance that was not known and could not have been
known at the time the LCA EIR was certified is available. The Project would be subject to the City
Development Impact Fees. The DIFs would aid in offsetting any potential impacts. There are no
new potentially significant impacts associated with the Project; therefore, no new and/or refined
mitigation measures are required.
EIR Impact 3.10-7: Would the project have sufficient water supplies available to serve the
project from existing entitlements and resources, or are new or expanded
entitlements needed? [No longer included in this section per the 2022 CEQA
Appendix G Thresholds]
No New or More Severe Impact: The LCA EIR concluded the LCA residents would consume
approximately 76,160 gallons per day (gpd) and 27,798,400 gallons per year of water, using the
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rate of 320 gpd per residential unit. The FWC indicated that it would be able to serve the LCA and
did not expect the LCA to result in any adverse impacts to water supply. Therefore, the LCA
Project would result in less than significant impact to water supplies. Using the same rate, the
Sobrato residents would consume approximately 45,760 gpd and 16,702,400 gallons per year of
water. The Sobrato residents would consume approximately 40 percent less water when
compared to the LCA residents. Therefore, the Project would not create a new or more severe
impact than the previous impacts analyzed in the EIR.
Mitigation Program
None identified in the LCA EIR
Conclusion
No new information of substantial importance that was not known and could not have been
known at the time the LCA EIR was certified is available. The Project would be subject to the City
Development Impact Fees. The DIFs would aid in offsetting any potential impacts. There are no
new potentially significant impacts associated with the Project; therefore, no new and/or refined
mitigation measures are required.
EIR Impact 3.10-8: Would the project result in a determination by the wastewater treatment
provider that serves or may serve the project that it has inadequate
capacity to serve the project’s projected demand in addition to the
provider’s existing commitments? [No longer included in this section per
the 2022 CEQA Appendix G Thresholds]
No New or More Severe Impact: The LCA EIR concluded that the project would increase
wastewater generation. However, the IEUA had sufficient capacity to serve the LCA Project.
Compliance with City and IEUA standards would reduce impacts to less than significant. The
Sobrato residents would generate less wastewater when compared to the LCA residents.
Therefore, the Project would not create a new or more severe impact than the previous impacts
analyzed in the EIR.
Mitigation Program
None identified in the LCA EIR
Conclusion
No new information of substantial importance that was not known and could not have been
known at the time the LCA EIR was certified is available. The Project would be subject to the City
Development Impact Fees. The DIFs would aid in offsetting any potential impacts. There are no
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new potentially significant impacts associated with the Project; therefore, no new and/or refined
mitigation measures are required.
EIR Impact 3.10-9: Would the project be served by a landfill with sufficient permitted capacity
to accommodate the project’s solid waste disposal needs? [No longer
included in this section per the 2022 CEQA Appendix G Thresholds]
No New or More Severe Impact: Solid waste service for the City is provided by the Mid-Valley
Sanitary Landfill located in the northern portion of the City. The LCA EIR discussed that Burrtec
would be able to serve the site and the Mid-Valley Sanitary Landfill would have sufficient capacity
to accommodate solid waste generated from the LCA. The Sobrato residents would generate less
solid waste when compared to the LCA residents due having 42 percent less residents. Therefore,
the Project would not create a new or more severe impact than the previous impacts analyzed in
the EIR.
Mitigation Program
None identified in the LCA EIR
Conclusion
No new information of substantial importance that was not known and could not have been
known at the time the LCA EIR was certified is available. The Project would be subject to the City
Development Impact Fees. The DIFs would aid in offsetting any potential impacts. There are no
new potentially significant impacts associated with the Project; therefore, no new and/or refined
mitigation measures are required.
EIR Impact 3.10-10: Would the project comply with federal, state, and local statutes and
regulations related to solid waste? [No longer included in this section per
the 2022 CEQA Appendix G Thresholds]
No New or More Severe Impact: The LCA EIR discussed that Burrtec did not foresee any issues
concerning compliance with Federal, state, and locate statutes and impacts would be less than
significant. The Project would also comply with federal, state, and local statutes and regulations
related to solid waste. Therefore, the Project would not create a new or more severe impact than
the previous impacts analyzed in the EIR.
Mitigation Program
None identified in the LCA EIR
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Conclusion
No new information of substantial importance that was not known and could not have been
known at the time the LCA EIR was certified is available. The Project would be subject to the City
Development Impact Fees. The DIFs would aid in offsetting any potential impacts. There are no
new potentially significant impacts associated with the Project; therefore, no new and/or refined
mitigation measures are required.
EIR Impact 3.10-11: Would the project be served by an electrical provider with adequate
capacity to serve the project? [No longer included in this section per the
2022 CEQA Appendix G Thresholds]
No New or More Severe Impact: The Project would be served by the Southern California Edison
(SCE). LCA EIR discussed that SCE did not anticipate that the demand for electricity from the LCA
would be significant. The Sobrato residents would demand less electricity when compared to the
LCA residents due having 42 percent less residents. In addition, the Project would be required to
comply with the current California Building Code (CBC), Title 24 (California Code of Regulations),
as well as the 2019 California Green Building Standard Code (Part 11 of Title 24, California Code
of Regulations). Therefore, the Project would not create a new or more severe impact than the
previous impacts analyzed in the EIR.
The Project is required by the City of Fontana to place underground all new, upgraded or existing
on-site or off-site utilities, in accordance with the Fontana MC Chapter 27 Utilities, Article III
Utilities Undergrounding Requirements. This includes the existing undergrounding of off-site
overhead utilities lines along Sierra Lakes Parkway, Maloof Avenue, and Lytle Creek Road. All
activities related to undergrounding of off-site overhead utilities will require approval from the
City Engineer, be subject to undergrounding requirements in the Fontana MC § 27-52 and be in
compliance with the California Public Utilities Commission (CPUC) Rule 20. CPUC Rule 20 sets
policies and procedures for the conversion of overhead power lines and other equipment to
underground facilities.
The undergrounding of existing overhead utilities would not create a new or more severe
impact. According to the CPUC, “[u]ndergrounding electric distribution and transmission lines
can beautify major thoroughfares, civic areas, scenic highways, and residential and commercial
areas, elevate property value in communities, reduce urban and industrial blight, enhance
electric reliability and make wildfire prone areas safer.” As such, the associated
undergrounding of existing utilities along Sierra Lakes Parkway, Maloof Avenue, and Lytle Creek
Road, as required by the City, would not cause the implementation of the Project to create a
new or more severe impact with regard to utilities when compared to the impact previously
analyzed in the LCA EIR.
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Mitigation Program
None identified in the LCA EIR
Conclusion
No new information of substantial importance that was not known and could not have been
known at the time the LCA EIR was certified is available. Therefore, no new and/or refined
mitigation measures are required.
EIR Impact 3.10-12: Would the project be served by a natural gas provider with adequate
capacity to serve the project? [No longer included in this section per the
2022 CEQA Appendix G Thresholds]
No New or More Severe Impact: The LCA EIR discussed that Southern California Gas Company
(SoCal Gas) indicated that it would serve the LCA and did not anticipate the demand for natural
gas serve would create significant impacts. The Sobrato residents would demand less natural gas
when compared to the LCA residents due having 42 percent less residents. Therefore, the Project
would not create a new or more severe impact than the previous impacts analyzed in the EIR.
Mitigation Program
None identified in the LCA EIR
Conclusion
No new information of substantial importance that was not known and could not have been
known at the time the LCA EIR was certified is available. Therefore, no new and/or refined
mitigation measures are required.
7.10.2 Overall Public Services and Utilities Impact Conclusion
With regard to CEQA Statute Section 21166 and CEQA Guidelines Section 15162(a), the changes
proposed by the Project would not result in any new or more severe impacts from the previously
identified impacts, with respect to public services. Therefore, preparation of an SEIR is not
warranted.
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7.11 Transportation
7.11.1 Summary of Previous Environmental Analysis
The most recent revisions to the State CEQA Guidelines include changes in the Transportation
impact questions to reflect State policy changes related to vehicle miles traveled, including SB743
and the new CEQA Guidelines §15064.3. Subsection (b) of this section includes new criteria for
analyzing the VMT impacts of land development projects:
“(1) Land Use Projects. Vehicle miles traveled exceeding an applicable threshold of
significance may indicate a significant impact. Generally, projects within one-half mile of
either an existing major transit stop or a stop along an existing high-quality transit corridor
should be presumed to cause a less than significant transportation impact. Projects that
decrease vehicle miles traveled in the project area compared to existing conditions should
be presumed to have a less than significant transportation impact.”
As explained above, new CEQA Guidelines, including newly adopted thresholds of significance,
do not govern review of whether modifications to a previously approved project trigger
subsequent environmental review under CEQA Guidelines §15162. See Concerned Dublin
Citizens, 214 Cal. App. 4th at 1320.20 The LCA EIR traffic-related impacts were thoroughly
assessed in the FEIR using a “level of service” analysis for measuring potential impacts.
The LCA EIR referred to this Section as Traffic and Circulation and determined all study
intersections to be operating at an acceptable level of service (LOS) C or better, according to the
City performance criteria. Two study intersections were forecasted to operate at a deficient LOS
(LOS D or worse) for forecast year 2006 without project conditions, according to City of Fontana
performance criteria:
• Citrus Avenue/Sierra Lakes Parkway (PM peak hour only); and
• Citrus Avenue/SR-210 Eastbound Ramps (PM peak hour only).
The proposed LCA Project was forecasted to generate approximately 1,667 daily trips, which
include 127 AM peak hour trips and 154 PM peak hour trips. With the addition of project-
generated trips, the same two study intersections were forecasted to continue to operate at a
deficient LOS (LOS D or worse) for year 2006 with project conditions, according to City of Fontana
performance criteria:
• Citrus Avenue/Sierra Lakes Parkway (PM peak hour only); and
• Citrus Avenue/SR-210 Eastbound Ramps (PM peak hour only).
20 CEQA Guidelines § 15064.3(c) states that this Guidelines section applies prospectively to CEQA documents circulated for public review on or
after July 1, 2020.
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The LCA EIR concluded that without any intersection improvements, the proposed project would
exacerbate deficient intersection operation conditions at the Citrus Avenue/Sierra Lakes Parkway
intersection and at the Citrus Avenue/SR-210 Eastbound Ramps intersection beyond the
Year 2006 Without Project conditions. The City of Fontana GP EIR identified the deterioration of
a roadway segment to LOS E or F as a significant impact. Therefore, Mitigation Measures 3.11-1a
and 3.11-1b would be required to reduce the potentially significant impact to a level of less than
significant.
7.11.2 Analysis of Proposed Project
A Traffic Impact Analysis (TIA) has been prepared by Kimley-Horn and Associates, in January 2022.
The TIA report is summarized below and is included as Appendix G of this Addendum.
Scope of the Transportation Evaluation and New CEQA Requirements
In 2018, the California state legislature, in approving SB 743, directed the Office of Planning and
Research (OPR) to develop guidelines for assessing transportation impacts based on vehicle miles
traveled, or VMT. In response to SB 743, CEQA and its implementing guidelines (CEQA Guidelines)
were significantly amended regarding the methods by which lead agencies are to evaluate a
project’s transportation impacts. As described in CEQA Guidelines Section 15064.3(a):
Generally, vehicle miles traveled is the most appropriate measure of transportation impacts. For
the purposes of this section, “vehicle miles traveled” refers to the amount and distance of
automobile travel attributable to a project. Other relevant considerations may include the effects
of the project on transit and non-motorized travel. Except as provided in subdivision (b)(2) below
(regarding roadway capacity), a project’s effect on automobile delay shall not constitute a
significant environmental impact.
As of July 1, 2020, all lead agencies, including the City of Fontana, were required to implement
the new SB 743 CEQA mandates and to analyze a project’s transportation impacts using VMT.
Intersection level of service (LOS) is no longer considered as a basis for CEQA significance but
rather relies on an operational analysis. These operational analyses are the basis for
recommending improvements to intersection controls, lane management, and other
appurtenant traffic systems. These improvements are not considered mitigation and are
operational enhancements. However, within the City of Fontana, intersection LOS is still
considered applicable to projects which proceed via addendums to previous environmental
analyses adopted prior to July 2020. Therefore, the “level of service” or “LOS” methodology will
be used during this analysis.
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Although this section of the Addendum contains a VMT analysis and has been prepared based on
these new requirements, this is provided for informational purposes only, as additional delay –
to an intersection or roadway segment – formed the basis of analysis for the LCA EIR.
Trip Generation Comparison/Analysis Scenarios
Based on the City of Fontana’s TIA guidelines, the project will be evaluated in the morning and
evening peak hours for the following conditions:
• Existing Conditions
• Existing Plus Project
• Opening Year 2023 Cumulative
• Opening Year 2023 Cumulative Plus Project
• Horizon Year 2040
• Horizon Year 2040 Plus Project
Intersection Analysis – HCM Methodology
This study includes evaluation of morning and evening peak hour operations at six existing
intersections located in the City of Fontana. Peak hour intersection operations at signalized and
unsignalized intersections were evaluated using the methods prescribed in the Highway Capacity
Manual (HCM) 6th Edition, consistent with the City of Fontana TIA Guidelines for VMT and Level
of Service Assessment (October 2020).
The City of Fontana’s TIA guidelines require analysis of traffic operations to be based on the
vehicular delay methodologies of the HCM (Transportation Research Board Special Report 209).
The City does not designate a specific software to be used in the analysis but allows the use of
one of several software packages that are consistent with the HCM methodologies. The
intersection analysis for the proposed project has been accomplished using the Vistro software
program and using the specified input parameters outlined in the City’s TIA guidelines.
Per the HCM Methodology, Level of Service (LOS) for signalized intersections is defined in terms
of average vehicle delay. Specifically, LOS criteria are stated in terms of the average control delay
per vehicle for the peak 15-minute period within the hour analyzed. The average control delay
includes initial deceleration delay, queue move-up time, and final acceleration time in addition
to the stop delay. The tables on the following page provide a description of the operating
characteristics of each Level of Service and define the LOS in terms of average seconds of delay
for signalized and unsignalized intersections.
For unsignalized intersections, the HCM methodology analysis determines the average total
delay for each vehicle making any movement from the stop-controlled minor street, as well as
left turns from the major street. Delay values are calculated based on the relationship between
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traffic on major street and the availability of acceptable gaps in the traffic stream through which
conflicting traffic movements can be made.
Level of Service Standards and Measure of Significance
Level of service (LOS) is a measure of the quality of operational conditions within a traffic stream
and is generally expressed in terms of such measures as speed and travel time, freedom to
maneuver, traffic interruptions, and comfort and convenience. Levels range from A to F, with LOS
A representing excellent (free-flow) conditions and LOS F representing extreme congestion.
Consistent to the guidelines, the Highway Capacity Manual (HCM) procedures have been used to
evaluate levels of service. This section discusses the LOS definitions, procedures, and thresholds
used in this report. Tables 25 and 26 provide further detail related to LOS.
Table 25: Level of Service (LOS) Definitions
Level of
Service Description
A No approach phase is fully utilized by traffic and no vehicle waits longer than one red indication. Typically, the
approach appears quite open, turns are made easily and nearly all drivers find freedom of operation.
B
This service level represents stable operation, where an occasional approach phase
is fully utilized and a substantial number are approaching full use. Many drivers begin to feel restricted within
platoons of vehicles.
C
This level still represents stable operating conditions. Occasionally drivers may have to wait through more
than one red signal indication, and backups may develop behind turning vehicles. Most drivers feel somewhat
restricted but not objectionably so.
D
This level encompasses a zone of increasing restriction, approaching instability at the intersection. Delays to
approaching vehicles may be substantial during short peaks within the peak period; however, enough cycles
with lower demand occur to permit periodic clearance of developing queues, thus preventing excessive
backups.
E
Capacity occurs at the upper end of this service level. It represents the most vehicles that any particular
intersection approach can accommodate. Full utilization of every signal cycle is seldom attained no matter
how great the demand.
F
This level describes forced flow operations at low speeds, where volumes exceed capacity. These conditions
usually result from queues of vehicles backing up from a restriction downstream. Speeds are reduced
substantially, and stoppages may occur for short or long periods of time due to the congestion. In the extreme
case, both speed and volume can drop to zero.
Table 26: Level of Service Criteria for Signalized and Unsignalized Intersections
Level of Service
Signalized Intersection (Average delay per
vehicle, in seconds)1
Unsignalized Intersections (Average delay
per vehicle, in seconds)2
A ≤10 0-10
B >10 – 20 >10 – 20
C >20 – 35 >15 – 25
D >35 – 55 >25 – 35
E >55 – 80 >35 – 50
F >80 >50
2 Source: Highway Capacity Manual (HCM 6th Edition), Exhibit 18-4.
3 Source: Highway Capacity Manual (HCM 6th Edition), Exhibits 19-1 and 20-2.
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Roadway Segment Analysis
The roadway segment analysis will address the project’s impact on daily operating conditions on
roadway segments within the project vicinity. Roadway segments are evaluated by comparing
the daily traffic volume to the daily capacity of that segment, to determine the volume-to-
capacity (v/c) ratio. Daily capacity is based on the roadway classification, as shown in the
following Table 27, City of Fontana Roadway Capacity Standards:
Table 27: City of Fontana Roadway Capacity Standards
Roadway Classification Number of Lanes
Daily Capacity
(Vehicles per
day)
Major Highway 6 54,000
Primary Highway 4 36,000
Secondary Highway 4 24,000
Collector Street 2 12,000
Source: Fontana Forward General Plan 2015-2035 Draft EIR
Level of Service Standards and Measure of Significance
The Level of Service standard in the City of Fontana for an intersection is LOS C or better.
According to the City of Fontana’s TIA guidelines, a significant traffic impact would occur when
the project causes the Level of Service to fall below LOS C, or causes the peak hour delay to
increase as follows (Table 28, City of Fontana Thresholds of Significant Impact):
Table 28: City of Fontana Thresholds of Significant Impact
With Project LOS Significant Impact Threshold
A/B 10.0 Seconds
C 8.0 Seconds
D 5.0 Seconds
E 3.0 Seconds
F 1.0 Seconds
Study Area
This traffic study includes documentation of existing conditions, future conditions, and
identification of project-related impacts at the following study locations:
Intersections:
1. Lytle Creek Road at Sierra Lakes Parkway
2. Lytle Creek Road at Ross Way/Project Driveway
3. Citrus Avenue at Sierra Lakes Parkway
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4. Citrus Avenue at SR-210 WB Ramps
5. Citrus Avenue at SR-210 EB Ramps
6. Beech Avenue at SR-210 HOV Ramps
Roadway Segments:
1. Sierra Lakes Parkway from Lytle Creek Road to Knox Avenue
The study locations were established in consultation with City staff through the Scoping Letter
Agreement process. A copy of the approved Scoping Letter Agreement is provided in Appendix A
of the TIA.
Existing Street System
Regional access to the site is provided primarily by the Ontario Freeway (I-15) and the
Foothill Freeway (SR-210). The I-15 Freeway is located approximately 1.5 miles to the west of the
site and access to the SR-210 Freeway via Citrus Avenue is located approximately 0.6 miles east
of the project site. Other facilities that provide regional access to the site include the
San Bernardino Freeway (SR- 10), located approximately 5 miles to the south of the site; and the
I-215 Freeway, located approximately 8.5 miles to the east of the project site.
Transit Service
Transit service to the project area is provided via the OmniTrans transit lines, which serve many
San Bernardino cities in the area. Bus stops in the project vicinity are located along Sierra Lakes
Parkway, Citrus Avenue, Curtis Avenue, and Beech Avenue. A description of the bus route serving
the project area is provided below.
Route 10 operates between the City of Fontana and the City of San Bernardino, traveling through
Fontana along Sierra Lakes Parkway, Citrus Avenue, Curtis Avenue, and Beech Avenue in the
project vicinity. Route 10 operates on weekdays from approximately 5:10 AM to 8:30 PM with
approximately 30-minute headways (the time between bus arrivals), on Saturdays from
approximately 6:15 AM to 7:10 PM with approximately 1-hour headways, and on Sundays from
approximately 7:15 AM to 6:10 PM with approximately 1-hour headways.
Existing Traffic Volumes
Existing morning peak period (7:00 to 9:00 AM) and evening peak period (4:00 to 6:00 PM)
turning movement counts were collected for all study intersections. The counts were completed
in October 2021.
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Peak Hour Operating Conditions
Intersection LOS analysis was conducted for the morning and evening peak hours using the
analysis procedures and assumptions described previously in this report. The intersection LOS
analysis indicates that all the study intersections currently operate at an acceptable LOS except
for the following:
• #3 – Citrus Avenue at Sierra Lakes Parkway: PM – LOS D
Daily Roadway Operating Conditions
Roadway Level of Service analysis was conducted based on the roadway capacities presented
previously in this report. The results of the roadway analysis for Existing Conditions are shown in
Table 29 below. The roadway LOS analysis indicates that the study roadway segment is currently
operating at an acceptable Level of Service on a daily basis.
Table 29: Summary of Roadway Segment Analysis for Existing Conditions
Roadway Segment Existing
Configuration
Existing ADT LOS E
Capacity1
V/C LOS
Sierra Lakes
Parkway
Lytle Creek Road to Knox
Avenue
2-Lane Collector
Street
4,734 12,000 0.395 A
Notes:
LOS = Level of Service
ADT = Average Daily Traffic
V/C = Volume to Capacity
1Source: City of Fontana. Fontana Forward General Plan Update 2015-2035 Draft Environmental Impact Report.
Project Traffic
Project Trip Generation
Trip generation estimates for the Project are based on daily and peak hourly trip generation rates
obtained from the Institute of Transportation Engineers (ITE) Trip Generation Manual (10th
Edition). ITE trip generation estimates for the project are based on the trip generation rates for
Multifamily Housing (Low Rise) (Land Use 220). Trip generation rates and the resulting trip
generation estimates for the Lennar Sobrato Residential Project are summarized in Table 30
below.
The project is estimated to generate 1,047 daily trips, with 66 trips (15 inbound and 51 outbound)
in the morning peak hour and 80 trips (50 inbound and 30 outbound) in the evening peak hour.
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Table 30: Summary of Project Trip Generation
Land Use ITE Code Unit
Trip Generation Rates
Daily AM Peak Hour PM Peak Hour
In Out Total In Out Total
Multifamily Housing (Low Rise) 220 DU 7.320 0.106 0.354 0.46 0.353 0.207 0.56
PROJECT TRIP GENERATION USING 2017 ITE CODE
Project Land Use Quantity Unit
Project Trip Generation
Daily AM Peak Hour PM Peak Hour
In Out Total In Out Total
Sobrato Project 143 DU 1,047 15 51 66 50 30 80
Total Project Trips 1,047 15 51 66 50 30 80
Source: Institute of Transportation Engineers (ITE) Trip Generation Manual, 10th Edition (2017)
Trip Distribution and Assignment
Project trip distribution assumptions for the project site were developed taking into account the
proposed site uses, existing travel patterns, and routes to and from the freeway system. Trip
distribution assumptions are shown on Figure 6 in the TIA. Based on the trip distribution and
assignment assumptions, the new trips to be added to the street system by the proposed project
were calculated and are shown on Figure 7 in the TIA.
Existing Plus Project
Project-related traffic was added to the Existing traffic volumes, and the resulting traffic volumes
at the study locations are shown on Figure 8 of the TIA.
Peak Hour Operating Conditions
Intersection Level of Service analysis was conducted for the morning and evening peak hours for
the Existing Plus Project conditions. The results of the intersection analysis are shown on TIA
Table 4. Intersection analysis worksheets are provided in Appendix C of the TIA. Review of this
table indicates that, with the addition of project traffic, the following study intersections would
continue to operate at an unacceptable Level of Service:
• #3 – Citrus Avenue at Sierra Lakes Parkway: PM – LOS D
Intersection #3 currently experiences an average delay of 46.5 seconds per vehicle. After
implementation of the Project, intersection #3 would experience a delay increase to 47.9 seconds
per vehicle. However, this increase would not be substantial enough to change the overall LOS
for the intersection. The intersection would therefore remain at an LOS D designation. Although
the intersection would remain at an inefficient LOS, Project implementation would not
substantially decrease the intersections efficiency. Additionally, none of the other study
intersections would experience decreased roadway efficiency to levels below LOS C. Therefore,
the Project would not create significant impact to roadway LOS levels.
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Daily Roadway Operating Conditions
Roadway Level of Service analysis was conducted based on the roadway capacities presented
previously in this report. The results of the roadway analysis for Existing Plus Project conditions
are shown in Table 31 below. Review of this table indicates that the study roadway segment
would continue to operate at an acceptable Level of Service on a daily basis.
Table 31: Summary of Roadway Segment Analysis for Existing Plus Project
Roadway Segment Existing
ADT
Project
ADT
Existing Plus
Project ADT
LOS E
Capacity1 V/C LOS
Sierra Lakes
Parkway
Lytle Creek Road to
Knox Avenue
4,734 785 5,519 12,000 0.460 A
Notes:
LOS = Level of Service
ADT = Average Daily Traffic
V/C = Volume to Capacity
1Source: City of Fontana. Fontana Forward General Plan Update 2015-2035 Draft Environmental Impact Report.
Future Conditions
Opening Year 2023 Cumulative
The Project Opening Year (the year the project would be constructed and occupied) is anticipated
to be Year 2023. Based on consultation with City staff, an ambient growth rate of 2.0 percent per
year to Opening Year 2023 was applied to existing traffic volumes. Cumulative Project traffic was
also added to Opening Year 2023 volumes and is explained below.
Cumulative Projects
Information about Cumulative Projects in the area was provided by the City of Fontana.
Cumulative Projects consist of any project that has been approved but is not yet
constructed/occupied, and projects that are in various stages of the application and approval
process but have not yet been approved. A summary of Cumulative Projects in the project vicinity
and the trip generation associated with each is provided on Table 6 in the TIA. The locations of
the Cumulative Projects are shown on Figure 9 in the TIA.
Cumulative Projects Trip Generation
Trip generation information for Cumulative Projects was derived either from approved traffic
studies, where available; or developed by Kimley-Horn if approved traffic studies were not
available.
Cumulative Projects Trip Distribution and Assignment
Trip distribution and assignment for the Cumulative Projects were either derived from approved
traffic studies, where available; or were developed by Kimley-Horn if approved traffic studies
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were not available. Project information and trip distribution assumptions for Cumulative Projects
are provided in Appendix D of the TIA.
Ambient growth and Cumulative Project trips were added to existing traffic to develop Opening
Year 2023 Cumulative forecasts. The resulting peak hour turning movement volumes at the study
locations are shown in Figure 10 in the TIA.
Peak Hour Operating Conditions
Intersection Level of Service analysis was conducted for the morning and evening peak hours for
the Opening Year 2023 Cumulative conditions. The results are shown on Table 7 in the TIA.
Intersection analysis worksheets are provided in Appendix C of the TIA.
Review of the intersection LOS analysis indicates that, with the addition of ambient growth and
cumulative project traffic, the following study intersections would operate at an unacceptable
LOS:
• #3 – Citrus Avenue at Sierra Lakes Parkway: AM – LOS D, PM – LOS E
Daily Roadway Operating Conditions
The results of the roadway analysis for Opening Year 2023 Cumulative conditions are shown on
Table 32 below. Review of this table indicates that the study roadway segment would continue
to operate at an acceptable Level of Service on a daily basis.
Table 32: Summary of Roadway Segment Analysis for Opening Year 2023 Cumulative
Roadway Segment Existing
ADT
Opening
Year 2023
Base ADT
Cumulative
Projects
Opening Year
2023
Cumulative ADT
LOS E
Capacity1 V/C LOS
Sierra Lakes
Parkway
Lytle Creek Road
to Knox Avenue 4,734 4,923 50 4,973 12,000 0.414 A
Notes:
LOS = Level of Service
ADT = Average Daily Traffic
V/C = Volume to Capacity
1Source: City of Fontana. Fontana Forward General Plan Update 2015-2035 Draft Environmental Impact Report.
Future Conditions Plus Project
Opening Year 2023 Cumulative Plus Project
Project-related traffic was added to the Opening Year 2023 Cumulative traffic volumes, and the
resulting peak hour turning movement volumes at the study intersections are shown on Figure 11
in the TIA.
Peak Hour Operating Conditions
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Intersection LOS analysis was conducted for the morning and evening peak hours for the Opening
Year 2023 Cumulative Plus Project conditions. The results of the intersection analysis are shown
on Table 9 in the TIA. Copies of intersection analysis worksheets for this scenario are provided in
Appendix C of the TIA.
Review of the intersection LOS analysis indicates that, with the addition project traffic, the
following study intersections would continue to operate at an unacceptable Level of Service:
• #3 – Citrus Avenue at Sierra Lakes Parkway: AM – LOS D, PM – LOS E
As previously stated, the significant impacts to roadway intersections occur when roadway LOS
is decreased below LOS C. Although, intersection LOS would remain at unacceptable levels (LOS
D and LOS E), none of the study intersections would experience a project-related effect due to
the increase in delay caused by the addition of project traffic.
Daily Roadway Operating Conditions
The results of the roadway analysis for Opening Year 2023 Cumulative Plus Project conditions are
shown on Table 33 below. Review of this table indicates that the study roadway segment would
continue to operate at an acceptable Level of Service on a daily basis.
Table 33: Summary of Roadway Segment Analysis for Opening Year 2023 Cumulative Plus
Project
Roadway Segment
Opening Year
2023 Cumulative
ADT
Project
ADT
Opening Year
2023 Plus
Project ADT
LOS E
Capacity1 V/C LOS
Sierra Lakes
Parkway
Lytle Creek Road
to Knox Avenue 4,973 785 5,758 12,000 0.480 A
Horizon Year Conditions
Horizon Year 2040
To develop the Horizon Year 2040 intersection turning movement forecasts, the San Bernardino
Transportation Analysis Model (SBTAM) Base Year 2012 and Horizon Year 2040 future traffic
projections were used. The raw forecasts obtained from the model output were post-processed
by determining the annual growth between the base model year and the future model year and
applying the resulting growth to existing count volumes. The B-Turns analysis worksheets,
developed by the FHWA, translate the grown volumes into peak hour turning movements. As a
conservative approach, if a turning movement volume produced by this model was less than
Opening Year 2023 Cumulative volumes for that movement, manual adjustments were made to
assure that all forecast Horizon Year volumes would be equal to or greater than the Opening Year
2023 Cumulative turning movement volumes. Both SBTAM Model plots and B-Turns analysis
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worksheets are provided in Appendix E of the TIA. The resulting traffic volumes for Horizon Year
2040 condition are shown on Figure 12 in the TIA.
The Horizon Year lane geometries for the study intersections and roadways are assumed to be
the same as Existing conditions, previously shown on Figure 3 in the TIA.
Peak Hour Operating Conditions
Intersection Level of Service analysis was conducted for the morning and evening peak hours for
the Horizon Year 2040 conditions. The results of the intersection analysis are shown on Table 11
in the TIA. Copies of intersection analysis worksheets for this scenario are provided in Appendix C
of the TIA.
Review of the intersection LOS Analysis indicates that under Horizon Year 2040 conditions, the
following study intersections would operate at an unacceptable Level of Service:
• #3 – Citrus Avenue at Sierra Lakes Parkway: AM – LOS D, PM – LOS E
• #6 – Beech Avenue at SR-210 HOV Ramps: PM – LOS D
Daily Roadway Operating Conditions
The results of the roadway analysis for Horizon Year 2040 conditions are shown on Table 34
below Review of this table indicates that the study roadway segment would continue to operate
at an acceptable Level of Service on a daily basis.
Table 34: Summary of Roadway Segment Analysis for Horizon Year 2040
Roadway Segment General Plan
Configuration
Horizon Year 2040
ADT
LOS E
Capacity1 V/C LOS
Sierra Lakes Parkway Lytle Creek Road
to Knox Avenue
4-Lane Primary
Highway 8,026 36,000 0.223 A
Notes:
LOS = Level of Service
ADT = Average Daily Traffic
V/C = Volume to Capacity
1Source: City of Fontana. Fontana Forward General Plan Update 2015-2035 Draft Environmental Impact Report.
Horizon Year 2040 Plus Project
Project-related traffic was added to the Horizon Year 2040 traffic volumes. Horizon Year 2040
Plus Project peak hour turning movement volumes at study intersections and daily roadway
volumes are shown on Figure 13 in the TIA.
Peak Hour Operating Conditions
Intersection Level of Service analysis was conducted for the morning and evening peak hours for
the Horizon Year 2040 Plus Project conditions. The results of the intersection analysis are shown
on Table 13 in the TIA. Copies of intersection analysis worksheets for this scenario are provided
in Appendix C of the TIA.
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Review of the intersection LOS analysis indicates that, with the addition of project traffic, the
following study intersections would operate at an unacceptable Level of Service:
• #3 – Citrus Avenue at Sierra Lakes Parkway: AM – LOS D, PM - LOS E
• #6 – Beech Avenue at SR-210 HOV Ramps: PM – LOS D
As previously stated, the significant impacts to roadway intersections occur when roadway LOS
is decreased below LOS C. Although LOS for intersections #3 and #6 would remain at
unacceptable levels (LOS D and LOS E), none of the study intersections would experience a
project-related effect due to the increase in delay caused by the addition of project traffic.
Therefore, the Project would not have created significant reductions in roadway efficiency.
Daily Roadway Operating Conditions
The results of the roadway analysis for Horizon Year 2040 Plus Project conditions are shown on
Table 35 below. Review of this table indicates that the study roadway segment would continue
to operate at an acceptable Level of Service on a daily basis.
Table 35: Summary of Roadway Segment Analysis for Horizon Year 2040 Plus Project
Roadway Segment Horizon Year
2040 ADT
Project
ADT
Horizon Year
2040 Plus
Project ADT
LOS E
Capacity1 V/C LOS
Sierra Lakes
Parkway
Lytle Creek Road
to Knox Avenue 8,026 785 8,811 36,000 0.245 A
Notes:
LOS = Level of Service
ADT = Average Daily Traffic
V/C = Volume to Capacity
1Source: City of Fontana. Fontana Forward General Plan Update 2015-2035 Draft Environmental Impact Report.
Improvements and Recommendations
Intersection Improvements
Based on the LOS standards and significant impact criteria discussed previously, the Project
would not have any Project-related effects at any of the study intersections. Therefore,
intersection improvements are not required. However, the Project will continue to contribute
fair share payments in keeping with LCA EIR mitigation measures 3.11-1a and 3.11-1b.
Roadway Improvements
Based on the roadway capacity standards and significant impact criteria discussed previously,
roadway improvements are not required at the study roadway segment.
Project Vehicle Miles Traveled (VMT) Analysis
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As previously discussed, SB 743 was approved by California legislature in September 2013. SB 743
requires changes to CEQA, specifically directing the Governor’s OPR to develop alternative
metrics to the use of vehicular LOS for evaluating transportation projects. OPR has prepared a
technical advisory for evaluating transportation impacts in CEQA and has recommended that
VMT replace LOS as the primary measure of transportation impacts. The Natural Resources
Agency has adopted updates to CEQA Guidelines to incorporate SB 743 that requires VMT for the
purposes of determining a significant transportation impact under CEQA.
The City of Fontana’s Traffic Impact Analysis (TIA) Guidelines for Vehicle Miles Traveled (VMT)
and Level of Service Assessment (October 2020) provides details on appropriate screening
thresholds that can be used to identify when a proposed land use project is anticipated to result
in a less than significant impact without conducting a more detailed level analysis. Screening
thresholds are broken down into the following four steps:
1. Projects in a Transit Priority Area (TPA)
2. Low VMT Area
3. Low Project Type
4. Project Net Daily Trip Less Than 500 ADT
Land development projects that have one or more of the above screening thresholds may be
presumed to create a less than significant impact on transportation and circulation.
Based on San Bernardino County Transportation Authority (SBCTA) VMT Screening Tool, the
project is not located in a Transit Priority Area (TPA). The TPA screening criteria is not met.
Additionally, the traffic analysis zone (“TAZ”) that the project is in and the San Bernardino County
Traffic Analysis Model (SBTAM) travel forecast model, the low VMT area screening criteria is not
met. As well, the Project meets neither the low VMT project type screening nor the less than 500
average daily trip (ADT) screening criteria.
Trip Generation Comparison Between Sobrato and Lytle Creek Apartments
The Lytle Creek Apartments was approved in January 2006 and RBF Consulting prepared a Draft
EIR. The LCA Draft EIR analyzed the trip generation and traffic impacts associated with the Lytle
Creek Apartments project. The LCA Project consisted of 238 multi-family dwelling units (DU).
Based on the Traffic and Circulation section of the Draft EIR, the LCA Project would generate
approximately 1,599 trips on a daily basis, with 122 trips (24 inbound and 98 outbound) during
the morning peak hour and 147 trips (95 inbound and 52 outbound) during the evening peak
hour. In comparison, the Sobrato’s trip generation estimates were based on the Institute of
Transportation Engineers (ITE) Trip Generation Manual (10th Edition) trip rates for Multifamily
Housing (Low-Rise) (ITE Code – 220).
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Trip generation rates and the resulting trip generation estimates for the proposed Project are
summarized on Table 36 below. Based on Table 36, the project is estimated to generate 1,047
daily trips, with 66 trips (15 inbound and 51 outbound) in the morning peak hour and 80 trips
(50 inbound and 30 outbound) in the evening peak hour.
Compared to the previously approved Lytle Creek Apartments Project, the Sobrato Project would
generate 552 fewer trips on a daily basis, with 56 fewer trips in the morning peak hour, and
67 fewer trips in the evening peak hour; refer to Table 36 for additional details.
Table 36: Summary of Project Trip Generation Comparison
Land Use ITE Code Unit
Trip Generation Rates1
Daily AM Peak Hour PM Peak Hour
In Out Total In Out Total
Multifamily Housing (Low Rise) 220 DU 7.320 0.106 0.354 0.46 0.353 0.207 0.56
Project Land Use Quantity Unit
Project Trip Generation
Daily AM Peak Hour PM Peak Hour
In Out Total In Out Total
Sobrato Project 143 DU 1,047 15 51 66 50 30 80
Lytle Creek Apartments
Project2 238 DU 1,599 24 98 122 95 52 147
Total Project Trips 1,047 15 51 66 50 30 80
Trip Differential (Sobrato – Lytle Creek Apartments) -552 -9 -47 -56 -45 -22 -67
Source:
1Institute of Transportation Engineers (ITE) Trip Generation Manual, 10th Edition (2017)
2Lytle Creek Apartments Draft Environmental Impact Report.
Impact Analysis
EIR Impact 3.11-1: Would the project 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)? [Not
included in the 2021 CEQA Appendix G Thresholds]
EIR Impact 3.11-2: Would the project exceed either individually or cumulatively, level of
service standard established by the county congestion management
agency for designated roads or highways. either individually or
cumulatively, level of service standard established by the county
congestion management agency for designated roads or highways? [Not
included in the 2021 CEQA Appendix G Thresholds]
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No New or More Severe Impact: The LCA EIR concluded that without any intersection
improvements, the proposed project would exacerbate deficient intersection operation
conditions at the Citrus Avenue/Sierra Lakes Parkway intersection and at the
Citrus Avenue/SR-210 Eastbound Ramps intersection beyond the Year 2006 Without Project
conditions. The City of Fontana GP EIR identified the deterioration of a roadway segment to LOS E
or F as a significant impact. Therefore, Mitigation Measures 3.11-1a and 3.11-1b would be
required to reduce the potentially significant impact to a level of less than significant. As
previously noted, LOS is no longer considered as a basis for CEQA significance but rather relies
on an operational analysis. Based on the supplementary VMT analysis. It has been estimated that
the Project would generate 552 fewer trips on a daily basis, with 56 fewer trips in the morning
peak hour, and 67 fewer trips in the evening peak hour than the LCA Project. Therefore, the
proposed Project would not create a new or more severe impact in this regard.
Mitigation Program
• Mitigation 3.11-1a The applicant shall pay a fair share contribution to improve the traffic
signal phasing for eastbound Sierra Lakes Parkway and northbound Citrus Avenue
approach to implement right-turn overlaps prior to issuance of certificate of occupancy.
• Mitigation 3.11-1 b The applicant shall pay a fair share contribution to the widening of
eastbound 1-210 Eastbound Ramps approach from one left-turn lane, one shared
through/right-turn lane, and one dedicated right-turn lane to consist of two left-turn
lanes, one shared through/left-turn lane, and one free right-turn lane prior to issuance of
certificate of occupancy. In addition, the applicant shall pay a fair share contribution to
the widening of northbound Citrus Avenue approach from two through lanes and a de
facto right-turn lane to consist of two through lanes and a shared through/right-turn lane
prior to issuance of certificate of occupancy.
Conclusion
The Project would not result in new or more severe impact in this regard. The Project would
substantially reduce total daily traffic and will not cause new or more severe traffic-related
impacts. More specifically, compared to the originally approved Project, the daily traffic trips
associated with the redevelopment of the Sobrato Project is less than what was analyzed the LCA
EIR and therefore consistent with the EIR. Since LOS analysis is no longer used in CEQA, the VMT
analysis determines that the Project would generate fewer trips compared to the LCA Project and
no mitigation measures with respect to VMT are necessary.
EIR Impact 3.11-3: Would the 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? [Not included in the 2022 CEQA Appendix G Thresholds]
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No New or More Severe Impact: The LCA EIR concluded that the LCA Project would not contain
any attributes that could potentially change air traffic patterns increase traffic levels or change a
location that results in a substantial aviation safety risk and no impacts would occur in this regard.
The Sobrato Project would be located at the same site and the proposed two-story cluster and
motorcourt buildings would be lower in heights when compared the three-story LCA buildings.
Therefore, the Project would be consistent with the LCA EIR findings and no impacts would occur.
Mitigation Program
None identified in the LCA EIR.
Conclusion
No new impact relative to air traffic patterns or a substantial increase in the severity of a
previously identified significant impact evaluated in the LCA EIR would occur. Additionally, no
new information of substantial importance that was not known and could not have been known
at the time the LCA EIR was certified is available that would impact the prior finding of no impact.
EIR Impact 3.11-4: Would the project substantially increase hazards due to a design feature
(e.g., sharp curves or dangerous intersections) or incompatible uses (e.g.,
farm equipment)?
EIR Impact 3.11-5: Would the project result in inadequate emergency access?
No New or More Severe Impact: The LCA EIR concluded that no new public roads were proposed
as part of the LCA Project. The LCA Project would be subject to and designed in accordance with
the standards of the Fontana ZDC, which would ensure that the LCA Project would provide
adequate emergency access and any potential impacts would be reduced to less than significant
level. The Project’s geometric design features, including the entrances and internal driveway
system, have been designed to meet the City standards and regulations and would not result in
inadequate emergency access. Therefore, the Project would not create a new or more severe
traffic hazard impact, and no mitigation would be required.
The Project proposes to develop access to the Project site through a main access gate directly
across from Ross Way. Therefore, the Lytle Creek cul-de-sac is no longer required to provide
access to the neighborhood to the west or for the future development of the Project site.
Development of the cul-de-sac for the open space/amenity space for the Project would not
impact access to the existing development or to the Project as the Project would provide three
points of access. The existing development to the west also has multiple points of access.
Therefore, no further impacts would occur from development of the open space area.
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Project construction activities could require the restriction of public access in its duration.
Standard construction safety measures would also be applied which would include appropriate
signage and flagmen visible to approaching motorists and pedestrians indicating access options
and warnings. Therefore, impacts would be less than significant.
Mitigation Program
None identified in the LCA EIR.
Conclusion
The Project would result in no or more severe new impact as it pertains to geometric design
feature or incompatible uses. No new impacts or a substantial increase in the severity of a
previously identified significant impact evaluated in the LCA EIR would occur. Additionally, no
new information of substantial importance that was not known and could not have been known
at the time the LCA EIR was certified is available that would impact the prior finding of no
significant impact under this issue area.
EIR Impact 3.11-6: Would the project result in inadequate parking capacity? [Not included in
the 2022 CEQA Appendix G Thresholds]
No New or More Severe Impact: The LCA EIR concluded that the LCA Project would provide
sufficient parking consistent with the Fontana ZDC parking requirements. Per Fontana ZDC, the
Sobrato Project would be required to provide a total of 384 parking spaces. The Project proposes
to include 397 parking spaces and would exceed the required parking for the Project site and
result in a less than significant impact.
Mitigation Program
None identified in the LCA EIR.
Conclusion
The Project would result in no or more severe new impact as it pertains to parking capacity. No
new impacts or a substantial increase in the severity of a previously identified significant impact
evaluated in the LCA EIR would occur. Additionally, no new information of substantial importance
that was not known and could not have been known at the time the LCA EIR was certified is
available that would impact the prior finding of no significant impact under this issue area.
EIR Impact 3.11-7: Would the project conflict with adopted policies, plans or programs
supporting alternative transportation (e.g., bus turnouts, bicycle racks)?
No New or More Severe Impact. The LCA EIR concluded that the LCA Project would comply with
all of the applicable requirements of Section 30-385, Trip Reduction Measures of the Fontana
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ZDC. Therefore, impacts would be less than significant The Sobrato Project would be required to
comply with any applicable traffic and circulation regulation set forth by the City of Fontana. The
Project site will be utilizing existing roads; Lytle Creek Road, Sierra Lakes Parkway, and Maloof
Avenue. As determined in the TIA, the Project would generate 552 fewer trips on a daily basis,
with 56 fewer trips in the morning peak hour, and 67 fewer trips in the evening peak hour than
the LCA Project. Therefore, the Project would not create a new or more severe impact in this
regard. The Project would result in a less than significant impact.
Mitigation Program
None identified in the LCA EIR.
Conclusion
No new impacts associated with non-vehicular transportation or a substantial increase in the
severity of a previously identified significant impact evaluated in the LCA EIR would occur.
Additionally, no new information of substantial importance that was not known and could not
have been known at the time the LCA EIR was certified is available that would impact the prior
finding.
7.11.3 Overall Traffic Impact Conclusion
With regard to CEQA Section 21166 and CEQA Guidelines Section 15162(a), the changes
proposed by the Project would not result in any new impacts, or increase the severity of the
previously identified impacts, with respect to traffic. Therefore, preparation of a subsequent
environmental analysis is not warranted.
Updates to the CEQA Guidelines
The CEQA Guidelines have been amended since the City certified the LCA FEIR respectively. The
most recent revisions to the CEQA Guidelines by the State of California became effective in
February 2019. Pursuant to CEQA Guidelines Section 15007(d), the City of Fontana generally must
comply with the new Guidelines 120 days after they become effective, which in this case was
April 28, 2018. However, under CEQA Guidelines Section 15007(b), amendments to the CEQA
Guidelines apply “prospectively only.” An amendment to the CEQA Guidelines does not apply to
an environmental document that is circulated for public review before the amendment was
issued. Id. at Section 15007(c).21 This Addendum does not need to be circulated for public
comment and relies on the FEIR of which was circulated for public review. See CEQA Guidelines
Section 15164(c). As such, amendments to the CEQA Guidelines adopted after certification of
21 “If a document meets the content requirements in effect when the document is set out for public review, the document shall not need to be
revised to conform to any new content requirements in guideline amendments taking effect before the document is finally approved.” Id.
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the prior environmental review document, including newly adopted thresholds for measuring the
significance of an environmental impact, do not govern the City’s determination of whether the
Sobrato Project triggers subsequent environmental review under CEQA Guidelines
Section 15162. See, e.g., Concerned Dublin Citizens v. City of Dublin, 214 Cal. App. 4th 1301, 1320
(2013); CREED v. City of San Diego, 196 Cal. App. 4th 515 (2011).
Nonetheless, certain revisions to the CEQA Guidelines made after approval of the LCA are
discussed below in the context of providing substantial evidence demonstrating that no
conditions triggering subsequent environmental review of the Sobrato Project have occurred.
See CEQA Guidelines Sections 15162 and 15164.
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7.12 Greenhouse Gas Emissions (Global Climate Change)
The revised CEQA Guidelines include a new separate discussion for greenhouse gas emissions.
This section uses impact thresholds in Appendix G of the CEQA Guidelines and briefly examines
potential impacts related to greenhouse gas emissions that could result from implementation of
the Project.
7.12.1 Summary of Previous Environmental Analysis
Greenhouse gas emissions was not analyzed in the LCA EIR.
7.12.2 Analysis of Proposed Project
A Greenhouse Gas Emissions Assessment (GHG Assessment) was prepared for the Project by
Kimley-Horn and Associate; see Appendix H. The results from the analysis in the GHG Assessment
are summarized herein.
Certain gases in the earth’s atmosphere classified as GHGs, play a critical role in determining the
earth’s surface temperature. Solar radiation enters the earth’s atmosphere from space. A portion
of the radiation is absorbed by the earth’s surface and a smaller portion of this radiation is
reflected back toward space. This absorbed radiation is then emitted from the earth as low-
frequency infrared radiation. The frequencies at which bodies emit radiation are proportional to
temperature. Because the earth has a much lower temperature than the sun, it emits lower-
frequency radiation. Most solar radiation passes through GHGs; however, infrared radiation is
absorbed by these gases. As a result, radiation that otherwise would have escaped back into
space is instead “trapped,” resulting in a warming of the atmosphere. This phenomenon, known
as the greenhouse effect, is responsible for maintaining a habitable climate on earth.
The primary GHGs contributing to the greenhouse effect are carbon dioxide (CO2), methane
(CH4), and nitrous oxide (N2O). Fluorinated gases also make up a small fraction of the GHGs that
contribute to climate change. Examples of fluorinated gases include chlorofluorocarbons (CFCs),
hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), sulfur hexafluoride (SF6), and nitrogen
trifluoride (NF3); however, it is noted that these gases are not associated with typical land use
development. Human-caused emissions of GHGs exceeding natural ambient concentrations are
believed to be responsible for intensifying the greenhouse effect and leading to a trend of
unnatural warming of the Earth’s climate, known as global climate change or global warming.
GHGs are global pollutants, unlike criteria air pollutants and TACs, which are pollutants of
regional and local concern. Whereas pollutants with localized air quality effects have relatively
short atmospheric lifetimes (about one day), GHGs have long atmospheric lifetimes (one to
several thousand years). GHGs persist in the atmosphere for long enough time periods to be
dispersed around the globe. Although the exact lifetime of a GHG molecule is dependent on
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multiple variables and cannot be pinpointed, more CO2 is emitted into the atmosphere than is
sequestered by ocean uptake, vegetation, or other forms of carbon sequestration. Of the total
annual human-caused CO2 emissions, approximately 55 percent is sequestered through ocean
and land uptakes every year, averaged over the last 50 years, whereas the remaining 45 percent
of human-caused CO2 emissions remains stored in the atmosphere.22
South Coast Air Quality Management District Thresholds
The SCAQMD formed a GHG CEQA Significance Threshold Working Group to provide guidance to
local lead agencies on determining significance for GHG emissions in their CEQA documents. In
September 2010, the SCAQMD is proposing to adopt a tiered approach for evaluating GHG
emissions for development projects where SCAQMD is not the lead agency.
Southern California Association of Governments
On September 3, 2020, the SCAG Regional Council adopted the 2020-2045 RTP/SCS. The 2020
RTP/SCS charts a course for closely integrating land use and transportation so that the region can
grow smartly and sustainably. The strategy was prepared through a collaborative, continuous,
and comprehensive process with input from local governments, county transportation
commissions, tribal governments, non-profit organizations, businesses and local stakeholders
within the counties of Imperial, Los Angeles, Orange, Riverside, San Bernardino, and Ventura. The
RTP/SCS is a long-range vision plan that balances future mobility and housing needs with
economic, environmental, and public health goals. The SCAG region strives toward sustainability
through integrated land use and transportation planning. The SCAG region must achieve specific
federal air quality standards and is required by state law to lower regional GHG emissions.
Thresholds and Significance Criteria
Based upon the criteria derived from Appendix G of the CEQA Guidelines, a project normally
would have a significant effect on the environment if it would:
• Generate GHG emissions, either directly or indirectly, that may have a significant impact
on the environment, based on any applicable threshold of significance; or
• Conflict with any applicable plan, policy or regulation of an agency adopted for the
purpose of reducing the emissions of GHGs.
South Coast Air Quality Management District Thresholds
The SCAQMD has not announced when staff is expecting to present a finalized version of its GHG
thresholds to the governing board. On September 28, 2010, the SCAQMD recommended an
22 Intergovernmental Panel on Climate Change, Carbon and Other Biogeochemical Cycles. In: Climate Change 2013: The Physical Science Basis,
Contribution of Working Group I to the Fifth Assessment Report of the Intergovernmental Panel on Climate Change, 2013,
https://www.ipcc.ch/report/ar5/wg1/.
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interim screening level numeric “bright‐line” threshold of 3,000 metric tons per year of CO2e for
residential land uses. These efficiency-based thresholds were developed as part of the SCAQMD
GHG CEQA Significance Threshold Working Group. The numeric “bright line” was developed to
be consistent with CEQA requirements for developing significance thresholds, are supported by
substantial evidence, and provides guidance to CEQA practitioners in determining whether GHG
emissions from a proposed project are significant.
The screening threshold for residential projects is 3,000 MTCO2e per year according to both the
City of Fontana and SCAQMD. Therefore, the GHG threshold of 3,000 MTCO2e per year will be
the threshold utilized to evaluate GHG emissions from the proposed residential Project.
Methodology
The Project’s construction and operational emissions were calculated using the California
Emissions Estimator Model version 2020.4.0 (CalEEMod). Details of the modeling assumptions
and emission factors are provided in Appendix A: Greenhouse Gas Emissions Data of the Project
Greenhouse Gas Emissions Assessment in Appendix H. For construction, CalEEMod calculates
emissions from off-road equipment usage and on-road vehicle travel associated with haul,
delivery, and construction worker trips. GHG emissions during construction were forecasted
based on the proposed construction schedule and applying the mobile-source and fugitive dust
emissions factors derived from CalEEMod. The Project’s construction-related GHG emissions
would be generated from off-road construction equipment, on-road hauling and vendor
(material delivery) trucks, and worker vehicles. The Project’s operational-related GHG emissions
would be generated by vehicular traffic, area sources (e.g., landscaping maintenance, consumer
products), electrical generation, natural gas consumption, water supply and wastewater
treatment, and solid waste.
Impact Analysis
Threshold (a) Would the project generate greenhouse gas emissions, either directly or
indirectly, that may have a significant impact on the environment, based
on any applicable threshold of significance.
Short-Term Construction Greenhouse Gas Emissions
The Project would result in direct emissions of GHGs from construction. The approximate
quantity of daily GHG emissions generated by construction equipment utilized to build the
Project is depicted in Table 37, Construction-Related Greenhouse Gas Emissions.
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Table 37: Construction-Related Greenhouse Gas Emissions
Category MTCO2e
2022 Construction 68.56
2023 Construction 777.23
Total Construction Emissions 845.79
30-Year Amortized Construction 28.19
Source: CalEEMod version 2020.4.0. Refer to Appendix A of the Greenhouse Gas Emissions Assessment for model outputs.
As shown, the Project would result in the generation of approximately 845.79 MTCO2e over the
course of construction. Construction GHG emissions are typically summed and amortized over
the lifetime of the Project (assumed to be 30 years), then added to the operational emissions.23
The amortized Project construction emissions would be 28.19 MTCO2e per year. Once
construction is complete, the generation of these GHG emissions would cease.
Long-Term Operational Greenhouse Gas Emissions
Operational or long-term emissions occur over the life of the Project. GHG emissions would result
from direct emissions such as Project generated vehicular traffic, on-site combustion of natural
gas, and operation of any landscaping equipment. Operational GHG emissions would also result
from indirect sources, such as off-site generation of electrical power, the energy required to
convey water to, and wastewater from the Project, the emissions associated with solid waste
generated from the Project, and any fugitive refrigerants from air conditioning or refrigerators.
Total GHG emissions associated with the Project are summarized in Table 38, Project Greenhouse
Gas Emissions. As shown in Table 38, the Project would generate approximately 1,599.48
MTCO2e annually from both construction and operations and the Project. Project-related GHG
emissions would not exceed the City’s 3,000 MTCO2e per year threshold. Therefore, the Project
would have a less than significant impact on GHG emissions.
Table 38: Project Greenhouse Gas Emissions.
Emissions Source MTCO2e per Year
Construction Amortized Over 30 Years 28.19
Area Source 30.72
Energy 282.48
Mobile 1,187.60
Waste 31.95
23 The project lifetime is based on the standard 30-year assumption of the South Coast Air Quality Management District (South Coast Air Quality
Management District, Minutes for the GHG CEQA Significance Threshold Stakeholder Working Group #13, August 26, 2009).
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Emissions Source MTCO2e per Year
Water and Wastewater 38.53
Total 1,599.48
SCAQMD Project Threshold 3,000
Exceeds Threshold? No
Source: CalEEMod version 2020.4.0. Refer to Appendix A of the Greenhouse Gas Emissions Assessment for model outputs.
Threshold (b) Would the project conflict with any applicable plan, policy or regulation of an
agency adopted for the purpose of reducing the emissions of greenhouse gases.
SCAG RTP/SCS Consistency
On September 3, 2020, SCAG’s Regional Council adopted Connect SoCal (2020 RTP/SCS). The
RTP/SCS is a long-range visioning plan that balances future mobility and housing needs with
economic, environmental, and public health goals. The RTP/SCS embodies a collective vision for
the region’s future and is developed with input from local governments, county transportation
commissions, tribal governments, nonprofit organizations, businesses, and local stakeholders in
the counties of Imperial, Los Angeles, Orange, Riverside, San Bernardino, and Ventura. SCAG’s
RTP/SCS establishes GHG emissions goals for automobiles and light-duty trucks for 2020 and
2035 as well as an overall GHG target for the Project region consistent with both the target date
of AB 32 and the post-2020 GHG reduction goals of Executive Orders 5-03-05 and B-30-15.
The RTP/SCS contains over 4,000 transportation projects, ranging from highway improvements,
railroad grade separations, bicycle lanes, new transit hubs and replacement bridges. These future
investments were included in county plans developed by the six county transportation
commissions and seek to reduce traffic bottlenecks, improve the efficiency of the region’s
network, and expand mobility choices for everyone. The RTP/SCS is an important planning
document for the region, allowing project sponsors to qualify for federal funding.
The plan accounts for operations and maintenance costs to ensure reliability, longevity, and cost
effectiveness. The RTP/SCS is also supported by a combination of transportation and land use
strategies that help the region achieve state GHG emissions reduction goals and Federal Clean
Air Act (FCAA) requirements, preserve open space areas, improve public health and roadway
safety, support our vital goods movement industry, and utilize resources more efficiently. GHG
emissions resulting from development-related mobile sources are the most potent source of
emissions, and therefore Project comparison to the RTP/SCS is an appropriate indicator of
whether the Project would inhibit the post-2020 GHG reduction goals promulgated by the state.
The Project’s consistency with the RTP/SCS goals is analyzed in detail in Table 39, Regional
Transportation Plan/Sustainable Communities Strategy Consistency.
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Table 39: Regional Transportation Plan/Sustainable Communities Strategy Consistency
SCAG Goals Compliance
GOAL 1: Encourage regional economic
prosperity and global competitiveness.
N/A. This is not a project-specific policy and is therefore not
applicable. However, the Project is located on a vacant site
and development of the site would contribute to regional
economic prosperity.
GOAL 2: Improve mobility, accessibility,
reliability, and travel safety for people
and goods.
Consistent. Although this Project is not a transportation
improvement project, the Project is located near existing
Omnitrans transit routes (Route 82) on Citrus Avenue and
Curtis Avenue.
GOAL 3: Enhance the preservation, security, and
resilience of the regional
transportation system.
N/A. This is not a transportation improvement project and is
therefore not applicable.
GOAL 4: Increase person and goods movement
and travel choices within the
transportation system.
N/A. This is not a transportation improvement project and is
therefore not applicable.
GOAL 5: Reduce greenhouse gas emissions and
improve air quality.
Consistent. The Project is located within a suburban area in
proximity to existing employment centers and community
services. Location of the Project within a developed area
would reduce trip lengths, which would reduce GHG and air
quality emissions.
GOAL 6: Support healthy and equitable
communities
Consistent. The Project does not exceed state and localized
thresholds. Based on the Friant Ranch decision, projects that
would exceed the SCAQMD’s LSTs would not violate any air
quality standards or contribute substantially to an existing or
projected air quality violation and result in no criteria
pollutant health impacts.
GOAL 7: Adapt to a changing climate and
support an integrated regional
development pattern and
transportation network.
N/A. This is not a project-specific policy and is therefore not
applicable.
GOAL 8: Leverage new transportation
technologies and data-driven solutions
that result in more efficient travel.
N/A. This is not a project-specific policy and is therefore not
applicable.
GOAL 9: Encourage development of diverse
housing types in areas that are
supported by multiple transportation
options.
Consistent. The Project involves development of residential
housing that will provide the community with more housing
options. The Project is located within a relatively short
walking distance to local bus routes and is surrounded by
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SCAG Goals Compliance
connected sidewalks and bicycle lanes to allow for
multimodal transportation.
GOAL 10: Promote conservation of natural and
agricultural lands and restoration of
habitats.
N/A. This the Project is located on an undeveloped site
surrounded by residential neighborhoods and is unlikely to
house natural resources. Additionally, the Project is not
located on agricultural lands.
Source: Southern California Association of Governments, Regional Transportation Plan/Sustainable Communities Strategy, 2020.
Compliance with applicable State standards would ensure consistency with State and regional
GHG reduction planning efforts. The goals stated in the RTP/SCS were used to determine
consistency with the planning efforts previously stated. As shown in Table 39, the proposed
Project would be consistent with the stated goals of the RTP/SCS. Therefore, the proposed
Project would not result in any significant impacts or interfere with SCAG’s ability to achieve the
region’s post-2020 mobile source GHG reduction targets.
Consistency with the CARB Scoping Plan
The California State Legislature adopted AB 32 in 2006. AB 32 focuses on reducing GHGs
(CO2, CH4, N2O, HFCs, PFCs, and SF6) to 1990 levels by the year 2020. Pursuant to the
requirements in AB 32, CARB adopted the Climate Change Scoping Plan (Scoping Plan) in 2008,
which outlines actions recommended to obtain that goal. The Scoping Plan provides a range of
GHG reduction actions that include direct regulations, alternative compliance mechanisms,
monetary and non-monetary incentives, voluntary actions, market-based mechanisms such as
the cap-and-trade program, and an AB 32 implementation fee to fund the program. The
2017 Scoping Plan Update identifies additional GHG reduction measures necessary to achieve
the 2030 target. These measures build upon those identified in the first update to the Scoping
Plan in 2013. Although a number of these measures are currently established as policies and
measures, some measures have not yet been formally proposed or adopted. It is expected that
these actions to reduce GHG emissions will be adopted as required to achieve statewide GHG
emissions targets.
As shown in Table 40, Project Consistency with Applicable CARB Scoping Plan Measures, the
Project is consistent with most of the strategies, while others are not applicable to the Project.
As such, impacts related to consistency with the CARB Scoping Plan would be less than significant.
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Table 40: Project Consistency with Applicable CARB Scoping Plan Measures
Scoping Plan
Sector
Scoping Plan
Measure
Implementing
Regulations Project Consistency
Transportation California Cap-and-
Trade Program
Linked to Western
Climate Initiative
Regulation for the
California Cap on GHG
Emissions and Market-
Based Compliance
Mechanism October
20, 2015 (CCR 95800)
Consistent. The Cap-and-Trade Program applies to
large industrial sources such as power plants,
refineries, and cement manufacturers. However, the
regulation indirectly affects people who use the
products and services produced by these industrial
sources when increased cost of products or services
(such as electricity and fuel) are transferred to the
consumers. The Cap-and-Trade Program covers the
GHG emissions associated with electricity consumed in
California, generated in-state or imported.
Accordingly, GHG emissions associated with CEQA
projects’ electricity usage are covered by the Cap-and-
Trade Program. The Cap-and-Trade Program also
covers fuel suppliers (natural gas and propane fuel
providers and transportation fuel providers) to address
emissions from such fuels and combustion of other
fossil fuels not directly covered at large sources in the
Program’s first compliance period.
California Light-Duty
Vehicle GHG
Standards
Pavley I 2005
Regulations to Control
GHG Emissions from
Motor Vehicles
Pavley I 2005
Regulations to Control
GHG Emissions from
Motor Vehicles
Consistent. This measure applies to all new vehicles
starting with model year 2012. The Project would not
conflict with its implementation as it would apply to all
new passenger vehicles purchased in California.
Passenger vehicles, model year 2012 and later,
associated with construction and operation of the
Project would be required to comply with the Pavley
emissions standards.
2012 LEV III California
GHG and Criteria
Pollutant Exhaust and
Evaporative Emission
Standards
Consistent. The LEV III amendments provide
reductions from new vehicles sold in California
between 2017 and 2025. Passenger vehicles
associated with the site would comply with LEV III
standards.
Low Carbon Fuel
Standard
2009 readopted in
2015. Regulations to
Achieve GHG Emission
Reductions Subarticle
7. Low Carbon Fuel
Standard CCR 95480
Consistent. This measure applies to transportation
fuels utilized by vehicles in California. The Project
would not conflict with implementation of this
measure. Motor vehicles associated with construction
and operation of the Project would utilize low carbon
transportation fuels as required under this measure.
Regional
Transportation-
Related GHG
Targets.
SB 375. Cal. Public
Resources Code §§
21155, 21155.1,
21155.2, 21159.28
Consistent. The Project would provide development in
the region that is consistent with the growth
projections in the RTP/SCS.
Goods Movement Goods Movement
Action Plan January
2007
N/A. The Project does not propose any changes to
maritime, rail, or intermodal facilities or forms of
transportation.
Medium/Heavy-Duty
Vehicle
2010 Amendments to
the Truck and Bus
Regulation, the
Drayage Truck
Regulation and the
Tractor-Trailer GHG
Regulation
Consistent. This measure applies to medium and
heavy-duty vehicles that operate in the state. The
Project would not conflict with implementation of this
measure. Medium and heavy-duty vehicles associated
with construction and operation of the Project would
be required to comply with the requirements of this
regulation.
High Speed Rail Funded under SB 862 N/A. This is a statewide measure that cannot be
implemented by a project applicant or Lead Agency.
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Scoping Plan
Sector
Scoping Plan
Measure
Implementing
Regulations Project Consistency
Electricity and
Natural Gas
Energy Efficiency Title 20 Appliance
Efficiency Regulation
Consistent. The Project would not conflict with
implementation of this measure. The Project would
comply with the latest energy efficiency standards. Title 24 Part 6 Energy
Efficiency Standards for
Residential and Non-
Residential Building
Title 24 Part 11
California Green
Building Code
Standards
Renewable Portfolio
Standard/Renewable
Electricity Standard.
2010 Regulation to
Implement the
Renewable Electricity
Standard (33% 2020)
Consistent. The Project would obtain electricity from
the electric utility, Southern California Edison (SCE).
SCE obtained 36 percent of its power supply from
renewable sources in 2018. Therefore, the utility
would provide power when needed on-site that is
composed of a greater percentage of renewable
sources.
Million Solar Roofs
Program
SB 350 Clean Energy
and Pollution
Reduction Act of 2015
(50% 2030)
Million Solar Roofs
Program
Tax Incentive Program Consistent. This measure is to increase solar
throughout California, which is being done by various
electricity providers and existing solar programs. The
program provides incentives that are in place at the
time of construction.
Water Water Title 24 Part 11
California Green
Building Code
Standards
Consistent. The Project would comply with the
CalGreen standards, which requires a 20 percent
reduction in indoor water use. The Project would also
comply with the City’s Water-Efficient Landscaping
Regulations (Chapter 28, Article IV of the Fontana
Municipal Code).
SBX 7-7—The Water
Conservation Act of
2009
Model Water Efficient
Landscape Ordinance
Green Buildings Green Building
Strategy
Title 24 Part 11
California Green
Building Code
Standards
Consistent. The State is to increase the use of green
building practices. The Project would implement
required green building strategies through existing
regulation that requires the Project to comply with
various CalGreen requirements. The Project includes
sustainability design features that support the Green
Building Strategy.
Industry Industrial Emissions 2010 CARB Mandatory
Reporting Regulation
N/A. The Mandatory Reporting Regulation requires
facilities and entities with more than 10,000 MTCO2e
of combustion and process emissions, all facilities
belonging to certain industries, and all electric power
entities to submit an annual GHG emissions data
report directly to CARB. The Project proposes a
residential development and therefore this regulation
would not apply.
Recycling and
Waste
Management
Recycling and Waste Title 24 Part 11
California Green
Building Code
Standards
Consistent. The Project would not conflict with
implementation of these measures. The Project is
required to achieve the recycling mandates via
compliance with the CALGreen code. The City has
consistently achieved its state recycling mandates. AB 341 Statewide 75
Percent Diversion Goal
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Scoping Plan
Sector
Scoping Plan
Measure
Implementing
Regulations Project Consistency
Forests Sustainable Forests Cap and Trade Offset
Projects
N/A. The Project is not located in a forested area.
High Global
Warming
Potential
High Global
Warming Potential
Gases
CARB Refrigerant
Management Program
CCR 95380
N/A. The regulations are applicable to refrigerants
used by large air conditioning systems and large
commercial and industrial refrigerators and cold
storage system. The Project would not conflict with the
refrigerant management regulations adopted by CARB.
Agriculture Agriculture Cap and Trade Offset
Projects for Livestock
and Rice Cultivation
N/A. No grazing, feedlot, or other agricultural activities
that generate manure occur currently exist on-site or
are proposed to be implemented by the Project.
Source: California Air Resources Board, California’s 2017 Climate Change Scoping Plan, November 2017 and CARB, Climate Change Scoping
Plan, December 2008.
As seen in Table 39 and Table 40, the Project would be consistent with all applicable plan goals.
As previously shown in Table 38 above the Project is estimated to emit approximately 1,599.48
MTCO2e per year directly from on‐site activities and would not exceed the SCAQMD’s 3,000
MTCO2e per year threshold.
The majority of the GHG reductions from the Scoping Plan would result from continuation of the
Cap-and-Trade regulation. Assembly Bill 398 (2017) extends the state’s Cap-and-Trade program
through 2030 and the Scoping Plan provide a comprehensive plan for the state to achieve its GHG
targets through a variety of regulations enacted at the state level. Additional reductions are
achieved from electricity sector standards (i.e., utility providers to supply 60 percent renewable
electricity by 2030 and 100 percent renewable by 2045), doubling the energy efficiency savings
at end uses, additional reductions from the LCFS, implementing the short-lived GHG strategy
(e.g., hydrofluorocarbons), and implementing the Mobile Source Strategy and Sustainable Freight
Action Plan.
Several of the State’s plans and policies would contribute to a reduction in mobile source
emissions from the Project. These include the CARB’s Advanced Clean Truck Regulation,
Executive Order N-79-20, CARB’s Mobile Source Strategy, CARB’s Sustainable Freight Action Plan,
and CARB’s Emissions Reduction Plan for Ports and Goods Movement. CARB’s Advanced Clean
Truck Regulation in June 2020 requiring truck manufacturers to transition from diesel trucks and
vans to electric zero-emission trucks beginning in 2024. By 2045, every new truck sold in
California is required to be zero-emission. The Advanced Clean Truck Regulation accelerates the
transition of zero-emission medium-and heavy-duty vehicles from Class 2b to Class 8. Executive
Order N-79-20 establishes the goal for all new passenger cars and trucks, as well as all
drayage/cargo trucks and off-road vehicles and equipment, sold in California, will be zero-
emission by 2035 and all medium and heavy-duty vehicles will be zero-emission by 2045. It also
directs CARB to develop and propose rulemaking for passenger vehicles and trucks, medium-and
heavy-duty fleets where feasible, drayage trucks, and off-road vehicles and equipment “requiring
increasing volumes” of new ZEVs “towards the target of 100 percent.”
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CARB’s Mobile Source Strategy which include increasing ZEV buses and trucks and their
Sustainable Freight Action Plan which improves freight system efficiency, utilizes near-zero
emissions technology, and deployment of ZEV trucks. This Plan applies to all trucks accessing the
Project site and may include existing trucks or new trucks that are part of the statewide goods
movement sector. CARB’s Emissions Reduction Plan for Ports and Goods Movement identifies
measures to improve goods movement efficiencies such as advanced combustion strategies,
friction reduction, waste heat recovery, and electrification of accessories. While these measures
are not directly applicable to the Project, any commercial activity associated with goods
movement would be required to comply with these measures as adopted.
The Project would not obstruct or interfere with efforts to increase ZEVs or state efforts to
improve system efficiency. As discussed above, the Project’s operational and construction
emissions would not exceed local thresholds. Therefore, the Project would only benefit from
implementation of these State programs and measures, which would reduce future GHG
emissions from trucks.
The Project’s long-term operational and short-term construction GHG emissions would not
exceed the City’s threshold of 3,000 MTCO2e per year. Additionally, the Project would be
consistent with applicable regulations and goals. Therefore, the Project would have a less than
significant impact.
Mitigation Program
Mitigation Measures from the LCA EIR
No mitigation measures were identified in the LCA GP EIR.
Conclusion
No new or more significant impact from GHG emissions would occur.
7.12.3 Overall Greenhouse Gas Emissions Impacts Conclusion
With regard to CEQA Section 21166 and CEQA Guidelines Section 15162(a), the changes
proposed by the Project would not result in any new impacts, or increase the severity of the
previously identified impacts, with respect to GHG emissions. Therefore, preparation of a SEIR is
not warranted.
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7.13 Mineral Resources
Revisions to the CEQA Guidelines made after approval of the LCA EIR Project created a new
separate CEQA checklist topic for “Mineral Resources,” consistent with Appendix G of the State
CEQA Guidelines. While FEIR did not specifically address mineral resources, Mineral resources
thresholds were previously discussed in Geology, Soils, and Seismicity Section. This section
examines potential impacts related to mineral resources that could result from implementation
of the Project.
7.13.1 Summary of Previous Environmental Analysis
Mineral resources were previously discussed in Section 3.5: Geology, Soils, and Seismicity in the
LCA EIR. According to the LCA EIR, project site is located within an area classified as an Aggregate
Resource Area in the Fontana GP and Fontana GP EIR and as an MRZ-2 area, by the California
Geological Survey, for aggregate under the California Surface Mining and Reclamation Act of
1975. However, in consideration of the nominal size of the site, the availability of substantial
other areas for aggregate mining (including nearby Lytle Creek, as well as Santa Ana River and
the Antelope Valley), the lack of current applications in the City for mining projects, and the
difficulty in permitting new mining operations in the urbanized portion of Fontana, this impact is
not considered significant, and no mitigation measures were implemented.
7.13.2 Analysis of Proposed Project
EIR Impact 3.5-6: Would the 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?
EIR Impact 3.5-7: Would the project 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?
No New or More Severe Impact: Consistent with the EIR conclusions, the Project site is located
within an area classified as an Aggregate Resource Area in the Fontana GP and Fontana GP EIR
and as an MRZ-2 area, by the California Geological Survey, for aggregate under the California
Surface Mining and Reclamation Act of 1975. However, in consideration of the nominal size of
the site, the availability of substantial other areas for aggregate mining, the lack of current
applications in the City for mining projects, and the difficulty in permitting new mining operations
in the urbanized portion of Fontana, the impacts would be less than significant. Additionally, the
Project would be located on the same site previously evaluated in the LCA EIR and the Project
implementation would not result in the loss of availability of a locally important mineral
resources recovery site delineated on the general plan, specific plan, or other land use plan. No
new or more severe impact relative to mineral resources not already evaluated in the EIR would
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occur with implementation of the Project. A less than significant impact would occur, consistent
with the previous impact analysis in the LCA EIR.
Mitigation Program
Mitigation Measures from the EIR
None identified in the EIR
7.13.3 Overall Mineral Resources Impacts Conclusion
The Project would result in no new or more severe impact to mineral resources. Therefore, no
new and/or refined mitigation measures are required for issues related to mineral resources.
With regard to CEQA Section 21166 and CEQA Guidelines Section 15162(a), the changes
proposed by the Project would not result in any new or more severe impacts from the previously
identified impacts, with respect to mineral resources. Therefore, preparation of an SEIR is not
warranted.
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7.14 Tribal Cultural Resources
Revisions to the CEQA Guidelines after approval of LCA EIR Project created a new separate CEQA
checklist topic for “Tribal Cultural Resources,” (TCRs) consistent with Appendix G of the State
CEQA Guidelines. The FEIR did not separately analyze Tribal Cultural Resources. However, the
FEIR did evaluate cultural and paleontological resources and this section uses impact thresholds
in Appendix G of the CEQA Guidelines and examines potential impacts related to TCRs that could
result from implementation of the Project. The analysis is based primarily on confidential cultural
resource studies conducted for the Project. PRC language relevant to the TCR thresholds is below:
PRC Section 21074 defines a TCR as follows:
(a) “Tribal cultural resources” are either of the following:
(1) Sites, features, places, cultural landscapes, sacred places, and objects with
cultural value to a California Native American tribe that are either of the
following:
(A) Included or determined to be eligible for inclusion in the California
Register of Historical Resources.
(B) Included in a local register of historical resources as defined in
subdivision (k) of Section 5020.1.
(2) A resource determined by the lead agency, in its discretion and supported
by substantial evidence, to be significant pursuant to criteria set forth in
subdivision (c) of Section 5024.1. In applying the criteria set forth in
subdivision (c) of Section 5024.1 for the purposes of this paragraph, the
lead agency shall consider the significance of the resource to a California
Native American tribe.
(b) A cultural landscape that meets the criteria of subdivision (a) above is a tribal
cultural resource to the extent that the landscape is geographically defined in
terms of the size and scope of the landscape.
(c) A historical resource described in Section 21084.1, a unique archaeological
resource as defined in subdivision (g) of Section 21083.2, or a “nonunique
archaeological resource” as defined in subdivision (h) of Section 21083.2 may also
be a tribal cultural resource if it conforms with the criteria of subdivision (a).
Subdivision (k) of PRC Section 5020.1 is as follows:
(k) “Local register of historical resources” means a list of properties officially
designated or recognized as historically significant by a local government pursuant to a
local ordinance or resolution.
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Subdivision (c) of PRC Section 5024.1 is as follows:
(c) A resource may be listed as an historical resource in the California Register if it
meets any of the following National Register of Historic Places criteria:
(1) Is associated with events that have made a significant contribution to the
broad patterns of California’s history and cultural heritage.
(2) Is associated with the lives of persons important in our past.
(3) 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 values.
(4) Has yielded, or may be likely to yield, information important in prehistory
or history.
7.14.1 Analysis of Proposed Project
Would the project cause a substantial adverse change in the significance of a tribal cultural
resource, defined in PRC Section 21074 as either a site, feature, place, cultural landscape that is
geographically defined in terms of the size and scope of the landscape, sacred place, or object
with cultural value to a California Native American tribe, and that is:
Threshold (a) Listed or eligible for listing in the California Register of Historical Resources,
or in a local register of historical resources as defined in Public Resources
Code section 5020.1(k), or
Threshold (b) A resource determined by the lead agency, in its discretion and supported
by substantial evidence, to be significant pursuant to criteria set forth in
subdivision (c) of Public Resources Code Section 5024.1. In applying the
criteria set forth in subdivision (c) of Public Resources Code Section 5024.1,
the lead agency shall consider the significance of the resource to a
California Native American tribe?
A Cultural Resource Assessment was prepared for the Project in November 2021 by BCR
Consulting, LLC. As previously discussed in Section 7.4: Cultural Resources, the BCR Report
included a cultural resources records search described in Section 7.4, intensive-level cultural
resources survey, and SLF Search with the NAHC. Findings were positive during the SLF search
with the NAHC. The NAHC has recommended contacting the GBMI for more information
regarding this finding. BCR Consulting emailed the GBMI nation and did not received a response.
AB 52, does not apply to this Project as the CEQA document is an Addendum to the LCA EIR and
not subject to the provisions of AB 52. Further, record searches and the field survey did not reveal
the presence of tribal cultural resources or burial sites within the area.
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Evidence collected during field survey indicated a lack of tribal cultural resources, thereby
minimizing potential for the discovery of previously undocumented cultural resources within the
Project area. However, Standard Condition No. 1 from PRC Section 5097.98 would be
implemented to ensure that any tribal cultural resource encountered during Project
development would be handled correctly and respectfully. Furthermore, the Project would be
required to comply with the City’s established standard conditions regarding tribal cultural
resources. Based on the above, a less than significant impact would occur.
Mitigation Program
Mitigation Measures from the LCA EIR
The LCA EIR did not include tribal cultural resources in its analysis and no mitigation measures
are proposed within the LCA EIR. However, compliance with PRC Section 5097.98 (Standard
Condition No. 1) is proposed in the Ontario GP EIR to ensure no significant impacts.
Conclusion
No new impact related to tribal cultural resources would occur.
7.14.2 Overall Tribal Cultural Resources Impacts Conclusion
With regard to CEQA Statute Section 21166 and CEQA Guidelines Section 15162(a), the changes
proposed by the Project would not result in any new or more severe impacts with respect to
tribal cultural resources. Therefore, preparation of an SEIR is not warranted.
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7.15 Energy
Revisions to the CEQA Guidelines after approval of the LCA EIR created a new separate CEQA
checklist topic for “Energy,” consistent with Appendix G of the CEQA Guidelines. The FEIR did not
specifically address energy; however, it did discuss energy conservation with regards to air
quality. This section uses impact thresholds in Appendix G of the CEQA Guidelines and briefly
examines potential impacts related to energy resources that could result from implementation
of the Project.
An Energy Assessment was prepared for the Project by Kimley-Horn and Associates
(November 2021). The Energy Assessment is included as Appendix I in this Addendum.
Threshold (a) Would the project result in potentially significant environmental impact
due to wasteful, inefficient, or unnecessary consumption of energy
resources, during project construction or operation?
Threshold (b) Would the project conflict with or obstruct a state or local plan for
renewable energy or energy efficiency?
Energy usage was briefly analyzed in the LCA EIR Section 3.10, Public Services and Utilities. The
LCA EIR concluded that the although the LCA development would inevitably increase energy
demand within the City, energy demands would be able to be accommodated by existing service
providers Southern California Edison (SCE) for electricity and Southern California Gas Company
(SoCal Gas) for natural gas. The LCA EIR determined that the impacts with respect to energy
resources would be less than significant and no mitigation measure required.
Summary of the Energy Assessment Results for the Project
Electricity. SCE provides electricity to the Project area. The Project’s annual energy demand
would total approximately 0.71 GWh.24 According to the California Energy Commission, the total
electricity usage for San Bernardino County was approximately 15,968.52 GWh in 2020.25 The
Project’s increase in electricity demand would represent an insignificant percent increase
(less than one percent) compared to overall consumption in San Bernardino County. Therefore,
projected electrical demand would not significantly affect SCE’s level of service. In addition, the
Project design and materials would be subject to compliance with the most current Building
Energy Efficiency Standards. The Project would also be required adhere to CALGreen provisions,
which establish planning and design standards for sustainable site development, energy
24 Based on the CalEEMod version 2020.4.0 output data.
25 California Energy Commission, San Bernardino County Electricity Consumption, 2020, available at:
http://ecdms.energy.ca.gov/elecbycounty.aspx.
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efficiency (in excess of the California Energy Code requirements), water conservation, material
conservation, and internal air contaminants.
Project development would not interfere with achievement of the 60 percent Renewable
Portfolio Standard set forth in SB 100 for 2030 or the 100 percent standard for 2045. These goals
apply to SCE and other electricity retailers. As electricity retailers reach these goals, emissions
from end user electricity use would decrease from current emission estimates. Therefore, Project
impacts on electric energy resources would be less than significant.
Natural Gas. Southern California Gas (SoCal Gas) provides natural gas service to the Project area.
The CalEEMod modeling outputs estimates that the Project’s annual natural gas demand would
total approximately 2,911,800 KBtu.26 The total natural gas consumption for San Bernardino
County was approximately 15,448,085,922 KBtu in 2020. According to the 2020 California Gas
Report, from 2020 to 2035, statewide annual gas requirements will decline from 4,194 (MMcf/d)
to 3,594 (MMcf/d), while supplies remain constant.27 Therefore, the Project’s natural gas
demand would represent a nominal percentage (less than one percent) of overall demand in the
County and State. Therefore, the Project would result in a less than significant impact regarding
natural gas.
Fuel. During construction, transportation energy use depends on the type and number of trips,
vehicle miles traveled, fuel efficiency of vehicles, and travel mode. Transportation energy use
during construction would be associated with the transport and use of construction equipment,
delivery vehicles and haul trucks, and construction employee vehicles that would use diesel
fuel/gasoline. The Project would use 15,444 gallons of gasoline and 69,923 gallons of diesel fuel,
which would increase the County’s fuel consumption by less than one percent. Most construction
equipment during demolition and grading would be gas-powered or diesel-powered, however
the later construction phases would require electricity-powered equipment. Impacts related to
transportation energy use during construction would be temporary and would not require
expanded energy supplies or the construction of new infrastructure; impacts would be less than
significant.
During operations, fuel consumption would be associated with residential activities such as
driving cars and heating and cooling homes. The Project would result in an additional 1,047
vehicle trips; however, vehicle fuel efficiency is expected to increase. Additionally, electric and
hybrid vehicles are becoming more commonplace and are likely to become a larger part of future
fleet mixes, which will lower the demand for and usage of gasoline or diesel fuel. The Project is
close to public transportation, further reducing the need to drive. The City and surrounding areas
are highly urbanized with numerous gasoline fuel facilities and infrastructure. Consequently, the
26 Based on the CalEEMod version 2020.4.0 output data.
27 California Gas and Electric Utilities, 2020 California Gas Report, 2020-2035 Table 7, accessed October 27, 2021.
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proposed Project would not result in a substantial demand for energy that would require
expanded supplies or the construction of other infrastructure or expansion of existing facilities.
Existing rules and regulations concerning vehicle fuel consumption efficiencies would ensure that
vehicle trips generated by the proposed Project would not be considered as inefficient, wasteful,
or unnecessary. Therefore, the proposed Project would not result in wasteful, inefficient, or
unnecessary consumption of energy resources. Impacts are less than significant, and no
mitigation is required.
The Infrastructure and Green Systems City Element of the Fontana GP Chapter 10 provides a
framework for the City to achieve its energy goals. Goals and policies under Goal 7 addresses
plans to reduce GHGs, promote energy conservation, and incorporate sustainable building
practices. Additionally, State and local plans for renewable energy and energy efficiency include
the California Public Utilities Commission (CPUC) Energy Efficiency Strategic Plan, the 2019
California Building Energy Efficiency Standards (Title 24), and the 2019 CALGreen standards.
Compliance with these standards would ensure the Project incorporates energy efficient
windows, insulation, lighting, ventilation systems, and other energy efficient design features to
reduce energy consumption.
Further, the Project would recycle and/or salvage a minimum of 65 percent of the nonhazardous
construction and demolition waste per the 2019 CalGreen standards. Adherence to the CPUC’s
energy requirements as well as the 2019 California Building Energy Efficiency Standards (Title 24)
and the 2019 CALGreen standards would ensure conformance with the State’s goal of promoting
energy and lighting efficiency compliance with the applicable goals and policies of the General
Plan. Therefore, the proposed Project would result in less than significant impacts associated
with renewable energy or energy efficiency plans.
The Sobrato Project would result in construction of 143 units, approximately 40 percent less than
the proposed LCA. As such, the Project would create a lower demand for energy resources than
previously analyzed in the LCA EIR. In addition, construction and operation of the Project would
be required to comply with all relevant Federal, State, and local regulations involving energy
usage, including the CBC.
Therefore, the Project is not anticipated to result in an impact on the environment due to
wasteful, inefficient, or unnecessary consumption of energy resources or a conflict with or
obstruct a state or local plan for renewable energy or energy efficiency. A less than significant
impact would occur from energy resources consumption from the Project implementation.
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Mitigation Program
Mitigation Measures from the LCA EIR
No mitigation measures were identified in the LCA GP EIR.
Conclusion
No new or more significant impact from energy consumption would occur.
7.15.1 Overall Energy Impact Conclusion
With regard to CEQA Section 21166 and CEQA Guidelines Section 15162(a), the changes
proposed by the Project would not result in any new impacts, or increase the severity of the
previously identified impacts, with respect to energy. Therefore, preparation of a SEIR is not
warranted.
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7.16 Wildfire
Revisions to the CEQA Guidelines after approval of the LCA EIR Project include a new separate
CEQA checklist topic for “Wildfire Hazards,” consistent with Appendix G of the State CEQA
Guidelines. The FEIR did not analyze wildfire hazards. However, as part of the Public Services
evaluation, the FEIR included an evaluation of the development on public services including
impacts on Fire Services and construction. This section uses impact thresholds in Appendix G of
the CEQA Guidelines and examines potential impacts related to wildfire hazards that could result
from implementation of the Project.
7.16.1 Analysis of Proposed Project
Would the Project:
Threshold (a) Substantially impair an adopted emergency response plan or emergency
evacuation plan?
Threshold (b) Due to slope, prevailing winds, and other factors, exacerbate wildfire risks,
and thereby expose project occupants to pollutant concentrations from a
wildfire or the uncontrolled spread of a wildfire?
Threshold (c) Require the installation or maintenance of associated infrastructure (such
as roads, fuel breaks, emergency water sources, power lines or other
utilities) that may exacerbate fire risk or that may result in temporary or
ongoing impacts to the environment?
Threshold (d) Expose people or structures to significant risks, including downslope or
downstream flooding or landslides, as a result of runoff, post-fire slope
instability, or drainage changes?
The LCA EIR assessed that the City was at increased risk of wildfire hazards due to its location
within Southern California. This risk was attributed to the region’s lower rate of precipitation,
topography, and native vegetation. However, the development modern fire-resistant materials
and tools have greatly reduced these risks. As well, the City’s continued compliance with State
Fire Codes further reduce the risks of wildfire.
According to the California Department of Forestry and Fire Projection’s Fire and Resources
Assessment Program (FRAP), the Project site is not located within or adjacent to land designated
as a very high fire hazard severity zone (VHFHSZ).28 Furthermore, the Project site is located in a
flat/leveled area which does not include wild habitat and is not located near hillsides. The Project
site is surrounded by a residential development to the north, west, and east and the Highland
Channel and SR-210 to the south. Finally, as previously discussed, the Project site is not exposed
28 CAL FIRE FRAP (2021). Fire Hazard Severity Zone Viewer. Available at https://egis.fire.ca.gov/FHSZ/. Accessed October 2021.
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to flooding, landslides, runoff conditions. Therefore, a less than significant impact is expected to
occur.
Mitigation Program
Mitigation Measures from the Ontario GP EIR
No mitigation measures were identified in the Ontario GP EIR.
Conclusion
No new or more significant impacts due to wildfire risks would occur.
7.16.2 Overall Wildfire Impact Conclusion
With regard to CEQA Statute Section 21166 and CEQA Guidelines Section 15162(a), the changes
proposed by the Project would not result in any new or more severe impacts with respect to
Wildfire. Therefore, preparation of an SEIR is not warranted.
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8 DETERMINATION OF APPROPRIATE CEQA DOCUMENTATION
The following discussion lists the appropriate subsections of Sections 15162 and 15164 of the
State CEQA Guidelines and provides justification for the City to determine that the Addendum is
the appropriate CEQA document for the Project, based on the environmental analysis provided
above.
This section also includes a discussion of the revisions to the State CEQA Guidelines that have
occurred since certification of the EIR, including the most recently adopted 2018 revisions. In
2018, the OPR transmitted its proposal for the comprehensive updates to the CEQA Guidelines
to the California Natural Resources Agency. Included were proposed updates related to analyzing
transportation impacts pursuant to SB 743, proposed updates to the analysis of GHG emissions,
and revised Section 15126.2(a) in response to the California Supreme Court’s decision in
California Building Industry Association v. Bay Area Air Quality Management District (2015)
62 Cal.4th 369. The updated Guidelines became effective on December 28, 2018.
CEQA Guidelines Section 15162 ‒ Subsequent EIRs and Negative Declarations
(a) When an EIR has been certified or a negative declaration adopted for a project, no
subsequent EIR shall be prepared for that Project unless the lead agency determines, on
the basis of substantial evidence in light of the whole record, one or more of the following:
(1) Substantial changes are proposed in the Project which will require major revisions of
the previous EIR or negative declaration due to the involvement of new significant
environmental effects or a substantial increase in the severity of previously identified
significant effects.
The City proposes to implement the Project within the context of the LCA EIR, as described in this
Addendum. As discussed in the Environmental Impact Analysis section of this Addendum, no new
or more severe significant environmental effects beyond what was evaluated in the LCA EIR
would occur.
(2) Substantial changes occur with respect to the circumstances under which the project
is undertaken which will require major revisions of the previous EIR or negative
declaration due to the involvement of new significant environmental effects or a
substantial increase in the severity of previously identified significant effects.
As documented herein, no circumstances associated with the location, type, setting, or
operations of the Project have substantively changed beyond what was evaluated in the LCA EIR;
and none of the Project elements would result in new or more severe significant environmental
effects than previously identified. No major revisions to the LCA EIR are required.
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(3) New information of substantial importance, which was not known and could not have
been known with the exercise of reasonable diligence at the time the previous EIR was
certified as complete or the negative declaration was adopted, shows any of the
following:
(A) The project will have one or more significant environmental effects not discussed
in the previous EIR or negative declaration;
No new significant environmental effects beyond those addressed in the LCA EIR were identified.
(B) Significant effects previously examined will be substantially more severe than
shown in the previous EIR;
Significant Project-related effects previously examined would not be more severe than were
disclosed in the LCA EIR as a result of the Project. Impacts associated with all environmental
resource areas would be the same as or less than disclosed in the adopted LCA EIR.
Implementation of the Project within the context of the LCA EIR would not substantially increase
the severity of previously identified impacts.
(C) Mitigation measures or alternatives previously found not to be feasible would in
fact be feasible, and would substantially reduce one or more significant effects of
the project, but the project proponents decline to adopt the mitigation measure or
alternative; or
No mitigation measures or alternatives were found infeasible in the certified LCA EIR.
(D) Mitigation measures or alternatives which are considerably different from those
analyzed in the previous EIR would substantially reduce one or more significant
effects on the environment, but the project proponents decline to adopt the
mitigation measure or alternative.
No other mitigation measures or feasible alternatives have been identified that would
substantially reduce significant impacts.
(b) If changes to a project or its circumstances occur or new information becomes available
after adoption of a negative declaration, the lead agency shall prepare a subsequent EIR
if required under subsection (a). Otherwise, the lead agency shall determine whether to
prepare a subsequent negative declaration, an addendum, or no further documentation.
Subsequent to certification of the LCA EIR in 2007, additional technical analyses were performed
for the Project and are the subject of this Addendum. Based on the analyses in this document,
the Project would not result in any new significant environmental effects nor would it increase
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the severity of significant effects previously identified in the LCA EIR. None of the conditions listed
under subsection (a) would occur that would require preparation of a subsequent EIR.
(c) Once a project has been approved, the lead agency’s role in project approval is completed,
unless further discretionary approval on that project is required. Information appearing
after an approval does not require reopening of that approval. If after the project is
approved, any of the conditions described in subsection (a) occurs, a subsequent EIR or
negative declaration shall only be prepared by the public agency which grants the next
discretionary approval for the project, if any. In this situation, no other Responsible Agency
shall grant an approval for the project until the subsequent EIR has been certified or
subsequent negative declaration adopted.
None of the conditions listed in subsection (a) would occur as a result of the Project. No SEIR is
required.
CEQA Guidelines Section 15164 ‒ Addendum to an EIR or Negative Declaration
(a) The lead agency or responsible agency shall prepare an addendum to a previously certified
EIR if some changes or additions are necessary, but none of the conditions described in
Section 15162 calling for preparation of a subsequent EIR have occurred.
As described above, none of the conditions described in the CEQA Guidelines Section 15162
calling for the preparation of a SEIR have occurred.
(b) An addendum to an adopted negative declaration may be prepared if only minor technical
changes or additions are necessary or none of the conditions described in Section 15162
calling for the preparation of a subsequent EIR or negative declaration have occurred.
None of the conditions described in Section 15162 calling for preparation of a subsequent EIR
would occur as a result of the Project. Therefore, an addendum to the certified LCA EIR is the
appropriate CEQA document for the Project.
(c) An addendum need not be circulated for public review but can be included in or attached
to the LCA EIR or adopted negative declaration.
This Addendum will be attached to the LCA EIR and maintained in the administrative record files
at the City.
(d) The decision-making body shall consider the addendum with the LCA EIR or adopted
negative declaration prior to making a decision on the project.
The City will consider this Addendum with the LCA EIR prior to making a decision on the Project.
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(e) A brief explanation of the decision not to prepare a subsequent EIR pursuant to Section
15162 should be included in an addendum to an EIR, the lead agency’s required findings
on the Project, or elsewhere in the record. The explanation must be supported by
substantial evidence.
This document provides substantial evidence for City records to support the preparation of this
Addendum for the Project.
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9 CONCLUSION
This Addendum has been prepared in accordance with the provisions of the State CEQA
Guidelines to document the finding that none of the conditions or circumstances that would
require preparation of a Subsequent EIR, pursuant to Sections 15162 and 15164 of the State
CEQA Guidelines, exist in connection with the Project. No major revisions would be required to
the LCA EIR as a result of the Project. No new significant environmental impacts have been
identified, nor is there a substantial increase in the severity of a previously identified significant
impact. Since the certification of the LCA EIR, there has been no new information showing that
mitigation measures or alternatives once considered infeasible are now feasible or showing that
there are feasible new mitigation measures or alternatives substantially different from those
analyzed in the EIR that the City declined to adopt. Therefore, preparation of a Subsequent EIR is
not required and the appropriate CEQA document for the Project is this Addendum to the LCA
EIR. No additional environmental impact report is required for the Project. This document will be
maintained in the administrative record files at the City.
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