HomeMy WebLinkAboutPublic Comments- 9-02-2026
VIA EMAIL
August 31, 2026
Helen Tran, Mayor
Kim Knaus, Mayor Pro Tem
Theodore Sanchez, Council Member
Sandra Ibarra, Council Member
Juan Figueroa, Council Member
Fred Shorett, Council Member
Mario Flores, Council Member
Dr. Treasure Ortiz, Council Member
San Bernardino City Council
290 North D Street, 3rd Floor
San Bernardino, CA 92401
council@sbcity.org
Chantel Choice, Senior Planner
Community Development & Housing Department
City of San Bernardino
201 North E Street, 3rd Floor
San Bernardino, CA 92401
cityofsbplanning@sbcity.org
choice_ch@sbcity.org
Telicia Lopez, City Clerk
San Bernardino City Clerk’s Office
201 North E Street, Building 201A
San Bernardino, CA 92401
sbcityclerk@sbcity.org
Re: Appeal Comment on the Initial Study/Mitigated Negative Declaration for the
Verdemont Heights Residential Development Project (Tentative Parcel Map
No. 20707)
Dear Mayor Tran, Honorable Members of the San Bernardino City Council, Ms. Lopez, and Ms.
Choice:
This comment is submitted on behalf of Supporters Alliance for Environmental
Responsibility (“SAFER”) and its members living or working in and around the City of San
Bernardino (“City”), in support of SAFER’s appeal of the San Bernardino Planning
Commission’s July 14, 2026 decision to approve the Initial Study/Mitigated Negative
Declaration (“MND”) prepared for the Verdemont Heights Residential Development Project
(Tentative Parcel Map No. 20707) (“Project”). The Project is scheduled to be heard at the San
Bernardino City Council meeting on September 2, 2026 at 5pm.
This comment supplements SAFER’s written comments previously submitted to the City
on April 15, 2026 and June 24, 2026. SAFER remains concerned that the MND fails to comply
with the California Environmental Quality Act (“CEQA”), Pub. Res. Code (“PRC”) § 21000, et
seq., because it inadequately analyzes and mitigates the Project’s potentially significant
environmental impacts on air quality and noise. Therefore, SAFER respectfully requests that the
City Council grant its appeal and require the City to prepare and circulate an EIR before Project
approval pursuant to the CEQA to properly address the Project’s potentially significant adverse
SAFER Appeal Comment Re: Verdemont Heights Project
August 31, 2026
Page 2 of 6
impacts.
SAFER’s review of the MND has been assisted by expert environmental engineer Patrick
Sutton, P.E., from Baseline Environmental Consulting. Mr. Sutton’s written comments and CV
are attached hereto as Exhibit A and are incorporated herein by reference in their entirety.
PROJECT DESCRIPTION
The Project involves the subdivision of a vacant, 107.7-acre site into 105 single-family
residential lots and five lettered lots. The Project site is located north of Verdemont Drive, east of
Antique Street, and west of Escena Street in Verdemont Heights in the City of San Bernardino.
LEGAL STANDARD
As the California Supreme Court held, “[i]f no EIR has been prepared for a nonexempt
project, but substantial evidence in the record supports a fair argument that the project may result
in significant adverse impacts, the proper remedy is to order preparation of an EIR.”
(Communities for a Better Env’t v. South Coast Air Quality Mgmt. Dist. (2010) 48 Cal.4th 310,
319-20.) “Significant environmental effect” is defined very broadly as “a substantial or
potentially substantial adverse change in the environment.” (PRC § 21068; see also 14 Cal. Code
Regs. [“CCR”] § 15382.) An effect on the environment need not be “momentous” to meet the
CEQA test for significance; it is enough that the impacts are “not trivial.” (No Oil, Inc. v. City of
Los Angeles (1974) 13 Cal.3d 68, 83.) “The ‘foremost principle’ in interpreting CEQA is that the
Legislature intended the act to be read so as to afford the fullest possible protection to the
environment within the reasonable scope of the statutory language.” (Communities for a Better
Env’t v. Cal. Res. Agency (2002) 103 Cal.App.4th 98, 109.)
The EIR is the very heart of CEQA. (Bakersfield Citizens for Local Control v. City of
Bakersfield (2004) 124 Cal.App.4th 1184, 1214; Pocket Protectors v. City of Sacramento (2004)
124 Cal.App.4th 903, 927.) The EIR is an “environmental ‘alarm bell’ whose purpose is to alert
the public and its responsible officials to environmental changes before they have reached the
ecological points of no return.” (Bakersfield Citizens, 124 Cal.App.4th at 1220.) The EIR also
functions as a “document of accountability,” intended to “demonstrate to an apprehensive
citizenry that the agency has, in fact, analyzed and considered the ecological implications of its
action.” (Laurel Heights Improvements Assn. v. Regents of Univ. of Cal. (1988) 47 Cal.3d 376,
392.) The EIR process “protects not only the environment but also informed self-government.”
(Pocket Protectors, 124 Cal.App.4th 903, 927.)
An EIR is required if “there is substantial evidence, in light of the whole record before
the lead agency, that the project may have a significant effect on the environment.” (PRC §
21080(d); see also Pocket Protectors, 124 Cal.App.4th at 927.) An MND instead of an EIR is
proper only if project revisions would avoid or mitigate the potentially significant effects
identified in the initial study “to a point where clearly no significant effect on the environment
would occur, and . . . there is no substantial evidence in light of the whole record before the
public agency that the project, as revised, may have a significant effect on the environment.”
SAFER Appeal Comment Re: Verdemont Heights Project
August 31, 2026
Page 3 of 6
(Mejia v. City of Los Angeles (2005) 130 Cal.App.4th 322, 331 [quoting PRC §§ 21064.5,
21080(c)(2)].) In that context, “may” means a reasonable possibility of a significant effect on the
environment. (PRC §§ 21082.2(a), 21100, 21151(a); Pocket Protectors, 124 Cal.App.4th at 927;
League for Protection of Oakland’s etc. Historic Res. v. City of Oakland (1997) 52 Cal.App.4th
896, 904-05.)
An EIR must be prepared rather than an MND “whenever it can be fairly argued on the
basis of substantial evidence that the project may have a significant environmental impact.” (No
Oil, Inc., 13 Cal.3d at 75.) Under this “fair argument” standard, an EIR is required if any
substantial evidence in the record indicates that a project may have an adverse environmental
effect—even if contrary evidence exists to support the agency’s decision. (14 CCR §
15064(f)(1); Pocket Protectors, 124 Cal.App.4th at 931; Stanislaus Audubon Society v. Cnty. of
Stanislaus (1995) 33 Cal.App.4th 144, 150-51; Quail Botanical Gardens Found., Inc. v. City of
Encinitas (1994) 29 Cal.App.4th 1597, 1602.) The “fair argument” standard creates a “low
threshold” favoring environmental review through an EIR rather than through issuance of
negative declarations or notices of exemption from CEQA. (Pocket Protectors, 124 Cal.App.4th
at 928.)
The “fair argument” standard is virtually the opposite of the typical deferential standard
accorded to agencies. As a leading CEQA treatise explains:
This ‘fair argument’ standard is very different from the standard normally followed by
public agencies in making administrative determinations. Ordinarily, public agencies
weigh the evidence in the record before them and reach a decision based on a
preponderance of the evidence. [Citations]. The fair argument standard, by contrast,
prevents the lead agency from weighing competing evidence to determine who has a
better argument concerning the likelihood or extent of a potential environmental impact.
The lead agency’s decision is thus largely legal rather than factual; it does not resolve
conflicts in the evidence but determines only whether substantial evidence exists in the
record to support the prescribed fair argument.
(Kostka & Zishcke, Practice Under CEQA, § 6.29, pp. 273-74.) The Courts have explained that
“it is a question of law, not fact, whether a fair argument exists, and the courts owe no deference
to the lead agency’s determination. Review is de novo, with a preference for resolving doubts in
favor of environmental review.” (Pocket Protectors, 124 Cal.App.4th at 928.)
DISCUSSION
I. There is substantial evidence of a fair argument that the Project may have
significant adverse air quality and greenhouse gas impacts.
Mr. Sutton reviewed the MND and other relevant documents regarding the Project’s air
quality and greenhouse gas (“GHG”) impacts. He concluded that the Project may have
significant adverse air quality and GHG impacts for which further CEQA review through an EIR
is necessary. (Ex. A at 7.)
SAFER Appeal Comment Re: Verdemont Heights Project
August 31, 2026
Page 4 of 6
A. There is substantial evidence of a fair argument that the Project may have
significant adverse air quality impacts.
Mr. Sutton found that the MND’s analysis of the Project’s construction emissions of
criteria air pollutants is flawed. The MND assumes that Project construction would occur over
sixteen years, based on the default construction schedule and equipment activity parameters in
the MND’s California Emissions Estimator Model (“CalEEMod”) Report. (Id. at 1.). The MND
uses this assumption to conclude that the Project’s construction emissions of criteria air pollutant
emissions would fall below South Coast Air Quality Management District (“SCAQMD”),
significance thresholds However, Mr. Sutton found that the default sixteen-year construction
schedule “substantially underestimates the pace of construction activities and associated
emissions.” (Id.) He calculated that, more realistically, site grading could be completed in a
fourth of the time provided in the default construction schedule, but “the amount of daily
emissions from the graders would be four times higher than the default scenario.” (Id. at 1-2
[emphasis included].) For example, completing construction in four years instead of sixteen
years would increase the Project’s nitrogen oxide emissions by four times, far exceeding the
SCAQMD’s significance threshold. (Id. at 2.) Based on Mr. Sutton’s realistic projections for
construction, there is substantial evidence supporting a fair argument that the Project may result
in significant nitrogen oxide emissions requiring the preparation of an EIR.
In addition, the MND lacks substantial evidence to conclude that the Project would not
result in a significant health risk to nearby sensitive receptors due to the Project’s construction
emissions of diesel particulate matter (“DPM”), a toxic air contaminant and human carcinogen.
The MND claims that the Project’s construction emissions would not result in a significant
health risk because these emissions would not exceed the SCAQMD localized significance
thresholds (“LSTs”). (MND at 18.) However, as Mr. Sutton explains, “LSTs only apply to
criteria air pollutants and were not designed to evaluate localized health risks from exposure to
DPM.” (Ex. A at 3.) To adequately analyze the health risk posed by DPM exposure, the Office of
Environmental Health Hazard Assessment recommends the preparation of a health risk
assessment (“HRA”). (Id. at 3.) Thus, until the City prepares an HRA for the Project, the MND’s
analysis of the Project’s health risk posed by DPM exposure remains insufficient, and
unsupported by substantial evidence.
Moreover, the Project subdivision is separated into three different phases, which Mr.
Sutton notes generally indicates that certain project phases would become operational while the
other phases are still under construction. (Id. at 2.) However, the MND fails to explain the
relevance of the phases and whether construction and operation would overlap. (Id.) If Project
construction and operation overlap, the City must assess the cumulative daily emissions of
criteria air pollutants for each overlapping phase against the SCAQMD’s operational
significance thresholds. (Id.) Therefore, the City thus prepare an EIR to explain the relevance of
the phases and evaluate and mitigate the combined emissions of the criteria air pollutants
associated with overlapping phases. (Id.)
B. There is substantial evidence of a fair argument that the Project may have
significant adverse greenhouse gas impacts.
SAFER Appeal Comment Re: Verdemont Heights Project
August 31, 2026
Page 5 of 6
Mr. Sutton found that the MND’s analysis of the Project’s GHG impacts deficient. For
example, he found the MND’s claim that the Project complies with the California Air Resources
Board’s current 2022 Scoping Plan for Achieving Carbon Neutrality (“Scoping Plan”) is
unsupported by substantial evidence. (MND at 38; Ex. A at 4.) Instead, he concluded that the
Project is inconsistent with most of the key attributes of a residential project that meets the
Scoping Plan’s long-term climate goals in three priority areas: (1) transportation electrification,
(2) vehicle miles traveled (“VMT”) reduction, and (3) building decarbonization. (Ex. A at 4-5.)
First, Mr. Sutton found that the Project is inconsistent with the Scoping Plan’s
transportation electrification goals because the Project has not committed to implementing the
voluntary Tier 1/2 electric vehicle (“EV”) infrastructure requirements of the 2025 California
Green Building Standards, the most ambitious current voluntary standards a residential project
would need to implement to be considered consistent with the Scoping Plan’s transportation
electrification goals. (Id. at 4.) Second, Mr. Sutton found that the Project is inconsistent with the
Scoping Plan’s VMT reduction goals because the Project would convert existing natural lands
into 105 single-family homes on 108 acres of land, which does not meet the Scoping Plan’s
minimum threshold of twenty residential dwelling units per acre, and the Project has not
committed to designating at least twenty percent of the homes affordable under the Scoping Plan.
(Id. at 4-5.) Third, Mr. Sutton found that the Project is inconsistent with the Scoping Plan’s
building decarbonization goals because there is no condition of approval or clear commitment in
the MND that the Project would use all-electric appliances without natural gas connections and
would refrain from use of propane or other fossil fuels for space heating, water heating, or indoor
cooking. (Id. at 5.)
Thus, by conflicting with the Scoping Plan’s carbon neutrality goals, the Project would
have potentially significant GHG impacts. (Id.) Thus, the City must prepare an EIR to adequately
mitigate the Project’s GHG emissions to align with the State’s carbon neutrality goals. (Id.)
II. There is substantial evidence of a fair argument that the Project may have
significant adverse construction noise impacts.
Mr. Sutton also reviewed the MND and other relevant documents regarding the Project’s
noise impacts. Mr. Sutton concluded that the Project may have significant adverse construction
noise impacts for which further CEQA review through an EIR is required. (Id. at 7.)
First, Mr. Sutton found that the MND’s construction noise analysis misrepresented the
Project’s actual construction noise impacts on the nearest sensitive receptor. (Id. at 6.) Pursuant
to guidance from the Federal Transit Administration (“FTA”), the MND’s noise analysis
assumed that all off-road equipment for each phase of Project construction would operate
simultaneously at the geographic center of the Project site, which was assumed to be 578 feet
from the nearest residential receptor. (Id.) However, Mr. Sutton notes that the FTA guidance was
developed for construction of transportation projects that are typically represented by linear
highway corridors. (Id.) Furthermore, the Project would include construction as close as 30 feet
from existing residential receptors to the south. (Id.) Therefore, the MND’s evaluation of
construction noise levels at 578 feet from the nearest receptor is inaccurate and not supported by
SAFER Appeal Comment Re: Verdemont Heights Project
August 31, 2026
Page 6 of 6
substantial evidence. (Id.)
Mr. Sutton prepared an updated construction noise analysis for the Project in accordance
with the Construction Noise and Vibration Guidelines for the City of Los Angeles (“LA Noise
Guidelines”), which modified the FTA’s guidelines to more accurately estimate noise level
impacts for land use developments such as this Project. (Id. at 6-7.) Assuming that construction
of each subdivision phase would occur separately, Mr. Sutton found that, for Phase 1, the
geographic center of construction is about 300 feet from the nearest existing residence to the
south, and construction equipment would operate as close as just 30 feet from the nearest
resident. (Id. at 7.) He calculated that Phase 1 Project construction would generate noise levels as
high as 86 dBA Leq (8-hour), exceeding the FTA’s 80 dBA Leq (8-hour) threshold, thereby
constituting a significant impact. (Id.) Based on this updated analysis, Mr. Sutton concluded that
construction of the later subdivision phases could generate significant noise impacts for future
residents occupying the completed subdivision phases. (Id.)
Based on Mr. Sutton findings, there is substantial evidence supporting a fair argument
that the Project may result in significant noise impacts requiring the preparation of an EIR. He
also emphasized that, if there are overlapping phases of construction and operation on the Project
site, the EIR should also consider the noise impacts to future residents occupying the homes
adjacent to the ongoing construction activities. (Id.) Additionally, the EIR’s noise mitigation
measures should include the installation of temporary noise barriers to reduce potential
construction noise levels by approximately 3 to 8 dBA at receptors near active work areas. (Id.)
An EIR is therefore required to properly analyze and mitigate the Project’s significant
noise impacts.
CONCLUSION
For the foregoing reasons, SAFER respectfully requests that the City Council grant its
appeal and require the City to prepare and circulate an EIR to adequately analyze and mitigate
the Project’s significant adverse air quality and noise impacts, before Project approval. Thank
you for your consideration.
Sincerely,
Kylah Staley
LOZEAU DRURY LLP
EXHIBIT A
388 17th Street, Suite 230, Oakland, CA 94612 | (510) 420-8686 | www.baseline-env.com
Mailing Address: PO Box 18586, Oakland, CA 94619
May 17, 2026
26231-00
Kylah Staley
Lozeau Drury LLP
1939 Harrison St., Suite 150
Oakland, CA 94612
Subject: Review of Air Quality, Greenhouse Gas Emissions, and Noise Analyzed for the
Verdemont Heights Residential Development Project.
Dear Ms. Yundt:
Baseline Environmental Consulting (Baseline) has reviewed the Draft Initial Study/Mitigated
Negative Declaration (IS/MND) for the proposed Verdemont Heights Residential Development
Project (project) in the City of San Bernardino north of Verdemont Drive. The proposed project
would construct 105 single-family homes on approximately 108 acres of vacant land. The primary
purpose of our review was to determine whether potential environmental impacts related to air
quality, greenhouse gas (GHG) emissions, and noise were adequately evaluated, mitigated, and
disclosed to the public. Based on our review, we have identified flaws in the analyses used to
support the significance determinations for the IS/MND, as described in detail below.
AIR QUALITY IMPACTS
Construction Criteria Air Pollutants
On page 15 of the IS/MND, it is stated that emissions of criteria air pollutants during project
construction would be below the South Coast Air Quality Management District’s (SCAQMD)
thresholds of significance. The analysis assumed that project construction would occur over
16 years based on the default construction schedule and equipment activity parameters included in
the California Emissions Estimator Model (CalEEMod). However, the IS/MND did not evaluate if
project buildout could be completed in a shorter period nor identify any conditions that would limit
the pace of construction. As explained below, completing construction in a shorter period can be
achieved by increasing in the amount of daily construction equipment activity and associated
emissions.
Based on review of the CalEEMod report included in Appendix A of the IS/MND, the default 16-year
construction schedule appears to substantially underestimate the pace of construction activities
and associated emissions. For example, the default equipment activity and schedule for grading the
project site assumed that one grader would operate 8 hours per day for 310 workdays (2,480 hours
total) prior to starting any building construction. It is highly unlikely that a construction contractor
May 17, 2026
Page 3
Construction Health Risk Assessment
Project construction would generate diesel particulate matter (DPM) emissions from the exhaust of
off-road diesel equipment that could pose health risks to nearby sensitive receptors. The California
Air Resources Board (CARB) has identified DPM as a toxic air contaminant (TAC) based on its
potential to cause cancer and other adverse health effects.1 Adverse health effects associated with
particulate matter can vary based on factors such as particle size, source, and chemical composition.
DPM is typically composed of carbon particles and a variety of organic compounds including more
than 40 known cancer-causing organic substances. The closest sensitive receptors to the project site
that could be exposed to DPM emissions during construction are single-family homes located
adjacent to the south.
According to the Office of Environmental Health Hazard Assessment (OEHHA),2 there is valid
scientific concern regarding the health effects on children exposed to airborne carcinogens such as
DPM from short-term construction activities lasting more than two months. This is because infants
and children are generally more susceptible to health effects from exposure to carcinogens than
adults. In addition, when accounting for the higher breathing rate per body mass and higher fraction
of time at home for a child versus an adult, the estimated cancer risk for a child can be up to 48
times higher than an adult exposed to the same concentration of DPM.
According to page 18 of the IS/MND, the project’s construction criteria air pollutant emissions
would not exceed the SCAQMD’s localized significance thresholds (LSTs). However, it should be
noted that the LSTs only apply to criteria air pollutants and were not designed to evaluate localized
health risks from exposure to DPM. This is because the toxicities of DPM and ambient particulate
matter are not equal. As stated in the SCAQMD’s Localized Significance Threshold Methodology,3
the local significance thresholds “represent the maximum emissions from a project that will not
cause or contribute to an exceedance of the most stringent applicable federal or state ambient air
quality standard." In California, only about 8 percent of the average ambient fine particulate matter
(PM2.5) concentration in outdoor air is comprised of DPM.4 While the federal and state ambient air
quality standards established for coarse particulate matter (PM 10) and PM2.5 were designed to be
protective of human health for ambient conditions, these standards are not representative of
particulate matter emissions from construction that contain significantly higher concentrations of
DPM than typical ambient concentrations due to the exhaust from diesel-powered construction
equipment.
1 California Air Resources Board, 1998. Initial Statement of Reasons for Rulemaking; Proposed Identification of Diesel
Exhaust as a Toxic Air Contaminant, June.
2 Office of Environmental Health Hazard Assessment (OEHHA). 2015. Air Toxics Hot Spots Program Guidance Manual for
Preparation of Health Risk Assessments. February.
3 South Coast Air Quality Management District (SCAQMD), 2003 (revised 2008). Final Localized Significance Threshold
Methodology. July.
4 California Air Resources Board (CARB), 2023. Overview: Diesel Exhaust & Health.
https://ww2.arb.ca.gov/resources/overview-diesel-exhaust-and-health. Accessed April 1,2023.
May 17, 2026
Page 4
Baseline recommends that the City requires the preparation of an Environmental Impact Report to
estimate, disclose, and mitigate (if necessary) the health risks to nearby sensitive receptors exposed
to DPM emissions during project construction. The health risks should be evaluated in accordance
with OEHHA guidance. If there are overlapping phases of construction and operation on the project
site, the health risk assessment should also consider the health risks to future residents occupying
the homes adjacent to the ongoing construction activities.
CLIMATE CHANGE IMPACTS
According to page 38 of the IS/MND, the project would not conflict with the CARB’s current 2022
Scoping Plan for Achieving Carbon Neutrality (2022 Scoping Plan) because “All of the post-2020
reductions in GHG emissions are addressed via regulatory requirements at the State level, and the
Proposed Project would be required to comply with these regulations as they come into effect.”
This claim of consistency with the 2022 Scoping Plan is not supported by substantial evidence.
Appendix D of the 2022 Scoping Plan provides guidance for residential projects to demonstrate
alignment with the State’s long-term climate goals, with a focus on the following three priority
areas:
Transportation electrification,
Vehicle miles travelled (VMT) reduction, and
Building decarbonization.
In the absence of a climate action plan that adequately addresses the State’s long-term climate
goals, Appendix D of the 2022 Scoping Plan indicates that residential projects with all the key
project attributes summarized in Table 2 would accommodate growth in a manner consistent with
the State’s long-term climate goals. These project attributes are intended as a guide to help local
jurisdictions qualitatively identify those residential projects that are clearly consistent with the
State’s climate goals, since these attributes address the largest sources of operational emissions for
residential projects.
The project would be required to comply with the 2025 California Green Building Standards
(CALGreen), which includes mandatory requirements for installing electric vehicle (EV) capable
parking spaces. However, the project has not committed to the voluntary Tier 1/2 EV ready
requirements in CALGreen, which are currently the most ambitious voluntary standards that a
residential project would need to implement to be considered consistent with the goals of the 2022
Scoping Plan. Because the proposed project has not committed to implementing the Tier 1/2 EV
infrastructure requirements (or any voluntary requirements), the project does not appear to be
consistent with the transportation electrification goals of the 2022 Scoping Plan described in
Table 2.
The project would convert existing natural lands into 105 single-family homes on 108 acres of land,
which does not meet the minimum threshold of 20 residential dwelling units per acre recommend
in the 2022 Scoping Plan. While not explicitly stated, it is presumed that each home would have an
May 17, 2026
Page 7
the receptor. This additional loudest-equipment calculation reflects consideration for such a
potentially dominant acoustical contributor to overall construction noise for a defined phase to be
closer to the studied off-site receptor than the approximate geographic center of the project site.
Baseline has prepared an updated construction noise analysis for the project in accordance with the
LA Noise Guidelines (Attachment A). Baseline assumed that construction of each subdivision phase
(Phase 1, Phase 2, and Phase 3) would occur separately. For Phase 1, the geographic center of
construction is approximately 300 feet from the nearest existing resident to the south, and
equipment would operate as close at approximately 30 feet from the nearest resident. During
grading of Phase 1, project construction would generate noise levels as high as 86 dBA Leq (8-hour),
which exceeds the FTA’s 80 dBA Leq (8-hour) threshold. Based on this updated analysis, it would
also be reasonable to assume that construction of the later subdivision phases (Phases 2 and 3)
could potentially generate significant noise impacts for future residents occupying the completed
subdivision phases.
Baseline recommends that the City requires the preparation of an Environmental Impact Report to
estimate, disclose, and mitigate the noise impacts to nearby receptors. The noise impacts should be
evaluated in accordance with the LA Nosie Guidelines or similar guidance that is representative of
typical land use development projects (i.e., not the FTA guidance for linear highway improvement
projects). If there are overlapping phases of construction and operation on the project site, the
noise assessment should also consider the impacts to future residents occupying the homes
adjacent to the ongoing construction activities. Mitigation should include the installation of
temporary noise barriers to reduce potential construction noise levels at receptors near active work
areas. Depending on the location of the construction equipment and the height of the receptors
relative to the temporary noise barriers, this mitigation measure can reduce the average
construction noise levels by approximately 3 to 8 dBA.7
CONCLUSIONS
Based on our review of the IS/MND, construction and operation of the proposed project would
result in potentially significant impacts related to air quality, GHG emissions, and noise. Therefore,
Baseline recommends that the City requires the preparation of an Environmental Impact Report to
properly evaluate, disclose, and mitigate impacts during construction and operation of the project.
Sincerely,
Patrick Sutton
Principal Environmental Engineer
7 Federal Highway Administration, 2006. FHWA Roadway Construction Noise Model User’s Guide, Appendix A: Best
Practices for Calculating Estimated Shielding for Use in RCNM. January.
ATTACHMENT A
Construction Noise Modeling Calculations
ATTACHMENT B
Staff Resume
From:Kristi Moore
To:Helen Tran; MayorsEvents; Council; PublicComments
Subject:‼URGENT‼ Regarding Euthanasia Deadline for Today at San Bernardino City Shelter
Date:Wednesday, August 26, 2026 7:35:20 AM
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Hello:
I am demanding answers as to why San Bernardino City Shelter staff are actively discouraging
adoption of animals. On 8/22/26 a German shepherd dog, animal ID #594800 had a public
adopter at the shelter and the employees told the adopter not to adopt this dog because he was
“snappy” despite the dog being available for public adoption and no notes on his kennel card
reflecting aggressive tendencies even though the shelter staff told him there were.
Additionally, this dog has been hidden from public view (again) despite being available for
public adoption. The practices of Jasmine Glover-McNamara and her staff are hindering dogs
from being adopted or rescued and frankly are down right appalling. The shelter should be
advocating for adoptions not interfering with them.
The public is demanding a change in practices by shelters administration and staff!
A concerned citizen,
Kristi Moore
Sent from my iPhone
From:Kristi Moore
To:AS-SBCityPets
Cc:PublicComments; Jasmine Glover-McNamara
Subject:Deadlined Dogs Being Hidden From View
Date:Saturday, August 22, 2026 7:40:09 PM
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consistent. - Use caution when opening attachments.
Hello,
I am writing to formally complain about dogs being hidden once they are given a euthanasia deadline. How are the
dogs supposed to be seen and adopted by members of the public who come in looking for a dog without first looking
on your website. These dogs deserve to been seen by the public, rescuers and networkers until the end. This practice
is unfair and prevents perfectly good, healthy dogs from having a chance to be adopted when they are in their final
days. Please explain your reasoning for this practice.
Kristi Moore
Sent from my iPhone=
From:James Spears
To:PublicComments
Date:Wednesday, August 19, 2026 3:06:57 PM
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I think a deeper audit should be done on the Shandon hills golf course, and I feel that the Wins
managing Shandon hills and owning Arrowhead Country Club is a definite conflict of interest.
I also feel that the employee should be interviewed. We have opinions also