Glendale City Council
June 14, 2022

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(“FAR”) is 7.25 and the building height is 266 feet. The Project includes 373 subterranean parking spaces for the residential use and 129 above-ground, replacement parking spaces for the existing commercial bank building, as well as a publicly accessible open space plaza fronting Brand Boulevard and residential amenity spaces throughout the project. No changes are proposed to the existing commercial bank building at 620 N. Brand Boulevard. The building was identified as a potential historic resource in the 2019 South Glendale Historic Resources Survey and is therefore considered a historic resource under CEQA. The Applicant has also requested a Development Agreement to secure a six-year entitlement period for the project and to lock in the current Development Impact Fees.

The proposed Project requires discretionary approval of Design Review pursuant to Glendale Municipal Code (“GMC”) Chapter 30.47, and a Development Agreement.

I. INTRODUCTION
The SCEA prepared for the Project is significantly flawed and does not comply with the requirements of CEQA. Moreover, the City lacks substantial evidence to support the City’s conclusion that the Project will result in less than significant impacts. In addition, substantial evidence shows that the Project would result in significant impacts on air quality, public health, and noise. The City may not approve the Project until the City prepares a sustainable communities environmental impact report (“SCEIR”) that adequately analyzes the Project’s significant and potentially significant impacts and incorporates all feasible mitigation measures to reduce those impacts to less than significant levels.

We prepared these comments with the assistance of air quality expert James Clark. Ph.D., and noise expert Derek Watry. Dr. Clark and Mr. Watry’s technical comments and curriculum vitae are attached hereto as Exhibit A3 and Exhibit B4 respectively and are fully incorporated herein. 3 Exhibit A Dr. James Clark, Comments on Draft Sustainable Communities Environmental Assessment (SCEA) For Stage II Final Design Review Case No. PDR 2119308, Development Agreement Case No. PDA1806045 (March 3, 2022).
4 Exhibit B Derek Watry, Lucia Park Project Glendale, California Review and Comment on SCEA Noise Analysis (March 2, 2022).
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We urge the City to reject the SCEA and direct staff to prepare an SCEIR to evaluate the Project’s unmitigated, significant and potentially significant impacts.

II. STATEMENT OF INTEREST
CREED LA is an unincorporated association of individuals and labor organizations that may be adversely affected by the potential public and worker health and safety hazards, and the environmental and public service impacts of the Project. The coalition includes the Sheet Metal Workers Local 105, International Brotherhood of Electrical Workers Local 11, Southern California Pipe Trades District Council 16, and District Council of Iron Workers of the State of California, along with their members, their families, and other individuals who live and work in the City of Glendale.

Individual members of CREED LA and its member organizations include City of Glendale residents Bryan Gonzalez, Jose Carmen Cortez, Daniel Torres, Loren Brown, and Axel Brutz. These individuals live, work, recreate, and raise their families in the City of Glendale and surrounding communities. Accordingly, they would be directly affected by the Project’s environmental and health and safety impacts. Individual members may also work on the Project itself. They will be first in line to be exposed to any health and safety hazards that exist onsite.

In addition, CREED LA has an interest in enforcing environmental laws that encourage sustainable development and ensure a safe working environment for its members. Environmentally detrimental projects can jeopardize future jobs by making it more difficult and more expensive for business and industry to expand in the region, and by making the area less desirable for new businesses and new residents. Indeed, continued environmental degradation can, and has, caused construction moratoriums and other restrictions on growth that, in turn, reduce future employment opportunities.
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III. LEGAL BACKGROUND
CEQA requires that an agency analyze the potential environmental impacts of its proposed actions in an environmental impact report (“EIR”) (except in certain limited circumstances).5 The EIR is the very heart of CEQA.6 “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.”7
CEQA has two primary purposes. First, CEQA is designed to inform decision makers and the public about the potential, significant environmental effects of a project.8 “Its purpose is to inform the public and its responsible officials of the environmental consequences of their decisions before they are made. Thus, the EIR “protects not only the environment but also informed self-government.” 9 The EIR
has been described as “an environmental ‘alarm bell’ whose purpose it is to alert the public and its responsible officials to environmental changes before they have reached ecological points of no return.”10
Second, CEQA requires public agencies to avoid or reduce environmental damage when “feasible” by requiring “environmentally superior” alternatives and all feasible mitigation measures.11 The EIR serves to provide agencies and the public with information about the environmental impacts of a proposed project and to “identify ways that environmental damage can be avoided or significantly reduced.”12 If the project will have a significant effect on the environment, the agency may approve the project only if it finds that it has “eliminated or substantially lessened all significant effects on the environment where feasible” and that any unavoidable significant effects on the environment are “acceptable due to overriding concerns.”13
5 See, e.g., CEQA § 21100.
6 Dunn-Edwards v. BAAQMD (1992) 9 Cal.App.4th 644, 652. 7 Comtys. for a Better Env’ v. Cal. Res. Agency (2002) 103 Cal. App.4th 98, 109 (“CBE v. CRA”). 8 14 CCR § 15002(a)(1).
9 Citizens of Goleta Valley v. Board of Supervisors (1990) 52 Cal. 3d 553, 564. 10 Berkeley Keep Jets Over the Bay v. Bd. of Port Comm’rs. (2001) 91 Cal. App. 4th 1344, 1354 (“Berkeley Jets”); County of Inyo v. Yorty (1973) 32 Cal.App.3d 795, 810. 11 14 CCR § 15002(a)(2) and (3); see also Berkeley Jets, 91 Cal.App.4th at 1354; Citizens of Goleta Valley, 52 Cal.3d at 564.
12 14 CCR §15002(a)(2).
13 CEQA § 21081; 14 CCR § 15092(b)(2)(A) & (B).
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A Transit Priority Project (“TPP”) is a type of CEQA project that was created by Senate Bill 375. CEQA Section 21155 sets forth the requirements for a project to qualify as a TPP, including consistency with the general use designations, density, building intensity, and applicable policies specified for the project area in an approved Sustainable Communities Strategy, as well as minimum density and residential requirements and proximity to a major transit stop or transit corridor.14 A TPP may be reviewed using a Sustainable Communities Environmental Assessment (“SCEA”) or a Sustainable Communities Environmental Impact Report (“SCEIR”), two forms of CEQA documents that were established by SB 375.15 The goal of this streamlined review is not to undercut or circumvent CEQA’s requirements, but to provide incentives for TPPs that are consistent with a larger effort to reduce greenhouse gas emissions by providing a streamlined channel for such projects. Thus, the SCEA or SCEIR must comply with CEQA’s informational goal, as well as with CEQA’s goal to reduce or avoid adverse environmental impacts when feasible.

An SCEA must include:

1. An Initial Study that:
a. identifies all significant or potentially significant impacts of the TPP, except those not required for review under 21159.2816
b. Identifies any cumulative effects that have been adequately addressed and mitigated in prior applicable and certified EIRs;

2. Measures that either avoid or mitigate to a level of insignificance all potentially significant or significant effects of the project17 The SCEA must be circulated for a 30-day notice and comment period, and notice must be provided as required for an EIR, pursuant to Public Resources Section 21092.18 The lead agency must consider all comments received,19 and can 14 CEQA § 21155(a).
15 CEQA §§ 21155.2, 21155.3.
16 Id. Pursuant to Pub. Resources Code, section 21159.28, the SCEA need not analyze (1) growth inducing impacts or (2) any specific or cumulative impacts from cars and light duty truck trips generated by the project on global warming or the regional transportation network. 17 Pub. Ressources Code, § 21155.2 (b).
18 Id.; Pub. Resources Code, section 21092 also requires that all materials referred to or relied upon in the environmental review document be made available for the full public comment period. 19 Id.
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only approve the SCEA after holding a public hearing, and finding that all potentially significant impacts have been identified and analyzed, and mitigation measures have been implemented to reduce the Project’s significant effects to a level of insignificance.20 The lead agency’s decision will be reviewed under the substantial evidence standard.21
The lead agency shall conduct the public hearing, or a planning commission may conduct the public hearing, if local ordinances permit direct appeal of the Planning Commission’s decision for a fee of $500.00 or less.22 Here, the City must make the following findings in order to determine that the Project complies with the requirements of CEQA for using an SCEA pursuant to PRC Section 21155.2(b):

1. The proposed Project is consistent with the general use designations, density, building intensity, and applicable policies specified for the project area in the Regional Transportation Plan/Sustainable Communities Strategy (“RTP/SCS”) prepared by the Southern California Association of Governments (“SCAG”);

2. The State Air Resources Board, pursuant to subparagraph (H) of paragraph (2) of subdivision (b) of Section 65080 of the Government Code, has accepted SCAG’s determination that the sustainable communities strategy adopted by SCAG in the 2020–2045 RTP/SCS would, if implemented, achieve the greenhouse gas emission reduction targets;

3. The proposed Project qualifies as a transit priority project pursuant to PRC Section 21155(b);

4. The proposed Project is a residential or mixed-use project as defined by PRC Section 21159.28(d);
20 Pub. Resources Code, § 21152.2(b)(5).
21 Pub. Resources Code, § 21155.2(b)(7); see also Sacramentans for Fair Planning v. City of Sacramento (2019) 37 Cal. App. 5th 698, 722.
22 Pub. Res. Code, § 21155.2(b)(6).
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5. The proposed Project incorporates all relevant and feasible mitigation measures, performance standards, or criteria set forth in prior environmental reports, including the RTP/SCS Program Environmental Impact Report;

6. All potentially significant or significant effects required to be identified and analyzed pursuant to CEQA have been identified and analyzed in an initial study; and

7. The proposed Project, as mitigated, either avoids or mitigates to a level of insignificance all potentially significant or significant effects of the proposed Project required to be analyzed pursuant to CEQA. 23 The City is not excused from analyzing the air quality, public health, and noise impacts of the Project by relying on an SCEA. While Section 21155 allows a lead agency to exclude analysis of the Project’s GHG and transportation cumulative impacts, the Project’s other impacts must undergo a full analysis, and the SCEA must identify and analyze all potentially significant impacts from the Project and implement mitigation to reduce impacts to less than significant levels. In this case, the City failed to conduct a proper analysis of the Project’s noise, air quality, and public health impacts. Furthermore, the SCEA fails to mitigate the significant effects of the Project rendering the SCEA incomplete.

IV. THE SCEA FAILS TO ANALYZE AND MITIGATE POTENTIALLY

SIGNIFICANT IMPACTS
An SCEA must fully disclose all potentially significant impacts of a Project and implement all feasible mitigation to reduce those impacts to less than significant levels. The lead agency’s significance determination with regard to each impact must be supported by accurate scientific and factual data.24 An agency cannot conclude that an impact is less than significant unless it produces rigorous analysis and concrete substantial evidence justifying the finding.25 Moreover, the failure to provide information required by CEQA is a failure to proceed in the manner required by CEQA.26 Challenges to an agency’s failure to 23 Pub. Resources Code § 21155.2(b) (emphasis added).
24 14 CCR § 15064(b).
25 Kings Cty. Farm Bur. v. Hanford (1990) 221 Cal.App.3d 692, 732. 26 Sierra Club v. State Bd. Of Forestry (1994) 7 Cal.4th 1215, 1236. 2-4
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proceed in the manner required by CEQA, such as the failure to address a subject required to be covered in an EIR or to disclose information about a project’s environmental effects or alternatives, are subject to a less deferential standard than challenges to an agency’s factual conclusions.27 In reviewing challenges to an agency’s approval of an environmental document based on a lack of substantial evidence, the court will ‘determine de novo whether the agency has employed the correct procedures, scrupulously enforcing all legislatively mandated CEQA requirements.’28
Even when the substantial evidence standard is applicable to agency decisions to certify an environmental document and approve a project, reviewing courts will not ‘uncritically rely on every study or analysis presented by a project proponent in support of its position. A clearly inadequate or unsupported study is entitled to no judicial deference.’”29
A. The City Failed to Provide Access to Documents Relied Upon in the SCEA
Despite multiple written requests, the City declined to provide CREED LA with the unlocked air quality analysis modeling files used to perform the Project’s Health Risk Assessment (“HRA”), including the American Meteorological Society/Environmental Protection Agency Regulator Model (“AERMOD”) files. This is a violation of CEQA’s requirement that all documents referenced or relied upon in an SCEA be made available for public review during the CEQA public comment period.30
CREED LA submitted several letters during the public comment period requesting the production of the AERMOD input files, so that Dr. Clark could review the accuracy of the air modeling for the Project.31 The City expressly 27 Vineyard Area Citizens for Responsible Growth, Inc. v. City of Rancho Cordova (2007) 40 Cal.4th 412, 435.
28 Id., Madera Oversight Coal., Inc. v. County of Madera (2011) 199 Cal. App. 4th 48, 102. 29 Berkeley Jets, 91 Cal.App.4th at 1355.
30 PRC §§ 21092(b)(1), 21155.2(b)(3).
31 Letter from ABJC, Request for Immediate Access to Documents Referenced in the Sustainable Communities Environmental Assessment – Lucia Park Project (Case Nos. PDR 2119308, PDA1806045) (January 3, 2022); Letter from ABJC, Request for Extension of CEQA Review Period for the Sustainable Communities Environmental Assessment – Lucia Park Project (Case Nos. PDR 2119308, PDA1806045) (February 8, 2022); letter from ABJC, Second Request for Immediate Access 2-5
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declined to provide access to the unlocked emissions files, based on an assertion that the citations and assumptions used in the SCEA’s air modeling calculations were provided in a manner that allows review and evaluation by a technical practitioner.32 This is incorrect. Without access to the input files, Dr. Clark was forced to recreate the City’s HRA modeling based on the scattered information provided in Appendix B, as described below.

The City’s failure to provide access to the SCEA’s air pollution emissions modeling files violates CEQA. A CEQA document may not rely on missing information because it “must contain facts and analysis, not just the bare conclusions of a public agency.”
33 Documents held by the lead agency, as well as by
its outside consultant, are treated as being in the agency’s possession and are required to be disclosed in response to record request and included in the CEQA record for a project if the agency relies on the studies to support the project’s CEQA review.34 In such instances, the agency is deemed to have direct or constructive possession of that evidence.35 In this case, the CalEEMod input files relied on in SCEA Appendix A and the unlocked AERMOD input files relied on in SCEA Appendix B are used to support the SCEA’s significance conclusions regarding the Project’s air quality and public health impacts. The City therefore has a duty to produce these files to CREED LA and any other requesting members of the public, as part of the CEQA public review period on the SCEA.

B. The SCEA’s Health Risk Analysis Is Inaccurate, Out-of-Date, and Unsupported
Dr. Clark reviewed the modeling assumptions used in SCEA Appendix B, and concludes that the City’s modeling suffers from major flaws which render its significance conclusions unsupported.
to Project Emissions Data for Sustainable Communities Environmental Assessment – Lucia Park Project (Case Nos. PDR 2119308, PDA1806045) (February 16, 2022). 32 Exhibit C: Email from City of Glendale, Response to Re: Second Request for Immediate Access to Project Emissions Data for Sustainable Communities Environmental Assessment (February 18, 2022)
33 Santiago County Water Dist. v. County of Orange (1981) 118 Cal.App.3d 818, 831. 34 Consolidated lrrig. Dist. v. Superior Court (2012) 205 Cal.App.4th 697, 710; See also City of San Jose v Superior Court (2017) 2 Cal.App.5th 608, 623.
35 Id.
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As a preliminary matter, Dr. Clark notes in his comments that, according to Appendix B, the air dispersion modeling was conducted using AERMOD version

10.0.1.36 According to the July 2021 AERMOD Implementation Guide from U.S.

EPA is the current version of AERMOD is version 21112.37 Dr. Clark explains that the modeling software utilized by the City is more than a decade old and lacks modeling capability for many relevant emissions factors. For example, Dr. Clark explains that the software lacks the capability to import background concentrations, calculate hourly emissions using multi-year assessments, or process large postfiles.38 Dr. Clark suggests that the City may be referring to version 10.0.1 of the graphical user interface used to run AERMOD.
39 Even if true, Dr. Clark
explains that that version 10.0.1 does not correct the SCEA’s modeling errors, and demonstrates a lack of understanding of the modeling program.

Despite the City’s clear misunderstanding of the AERMOD program, Dr.

Clark was able to independently identify the geographic location of all of the sources included in the mobile source dispersion model.
40 The sources are shown below as
red volume boxes in the figure below.
36 SCEA, Appendix B, p. 18.
37 U.S. EPA. 2021. AERMOD Implementation Guide. Dated July, 2021. Pg. 1. https://gaftp.epa.gov/Air/aqmg/SCRAM/models/preferred/aermod/aermod_implementation_guide.pdf 38 Clark Comments, p. 2.
39 Clark Comments, p. 3.
40 Clark Comments, p. 3.
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Dr. Clark explains that the yellow crosses indicate the receptors at groundlevel across the project site.41 According to Appendix B, diesel vehicle traffic was modeled as a line source comprised of separate volume sources along the stretch of SR-134.42 Ten sources are identified on the east bound lanes of State Route 134.43 Ten sources are identified on the west bound lanes of State Route 134.44 41 Clark Comments, p. 3.
42 SCEA, Appendix B, p. 18.
43 Clark Comments, p. 3.
44 Clark Comments, p. 3
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Eight sources are identified from the off-ramp to Brand Avenue from west bound lanes of State Route 134.45
Finally, eight sources are identified as using the on-ramp to east bound lanes of State Route 134. 46
Dr. Clark proceeded to use the diesel exhaust emissions parameters as detailed in Appendix B. When recreating the model using the City’s data, Dr. Clark found that Appendix B describes the use of “digital elevation model (DEM) data for the Pasadena and Mount Wilson 7.5-minute quadrangles obtained through the 45 Clark Comments, p. 4.
46 Clark Comments, p. 4.
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AERMOD program.”47 As Dr. Clark points out in his comments, AERMOD does not have a component that stores 7.5-minute quadrangles. Quadrangles can be obtained through the California Air Resources Board’s (“CARB”) HARP Digital Elevation Model Files.
48 Despite this error, Dr. Clark was able to download comparable Pasadena and Mt. Wilson DEMs and upload them to the AERMOD model. Upon uploading the DEMs, Dr. Clark found that neither of the DEMs were useful because no sources for the model were associated with either DEM rendering them useless for analysis of the Project.
49 47 Clark Comments, p. 5.
48 Clark Comments, p. 5.
49 Clark Comments, p. 5.
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Dr. Clark ultimately found that the only DEM required in the model is the Burbank DEM because no receptors are identified as being present in the Pasadena or Mt. Wilson DEMs.50 The output from the re-analysis of the impacts from SR-134 are included in Exhibit B to Dr. Clark’s comment letter. As discussed below, Dr.

Clark’s analysis demonstrates that the Project has significant health impacts.

Finally, Appendix B to the SCEA’s Appendix B is labeled “AERMOD Output Sheets”.51 However, review of the appendix clearly shows that Appendix B to the Health Risk Assessment contains the Emission Inventory from the EMFAC2021 (v

1.0.1) analysis of the Los Angeles region. The City must correctly label the information in the report.

C. The SCEA Fails to Disclose, Analyze and Mitigate Potentially Significant Air Quality Impacts
The SCEA fails to disclose and analyze potentially significant impacts of the Project and does not implement all feasible mitigation to reduce those impacts to less than significant levels, in violation of CEQA. The SCEA concludes that no additional project-specific mitigation measures are necessary in order to reduce the Project’s air quality impacts.52 However, as detailed below, Dr. Clark found potentially significant air quality impacts that are not mitigated through incorporation of the proposed mitigation measures, performance standards, or criteria from prior applicable environmental impact reports including those required under SCAG 2020-2045 RTP/SCS Program EIR; South Glendale Community Plan EIR; and Downtown Specific Plan EIR.

1. The SCEA Fails to Disclose and Analyze the Potentially Significant Health Risk from Exposure to Diesel
Particulate Matter
The City performed a Health Risk Assessment (“HRA”) to assess the impact of pollutants on individuals residing at the Project site resulting from exposure to diesel exhaust emissions generated by vehicles on the SR-134 and the on-ramp from Brand Boulevard adjacent to the Project site.53 The HRA found that the Project 50 Clark Comments, p. 5.
51 SCEA, Appendix B, p. 32.
52 SCEA, p. 5.0-40.
53 SCEA, p. 5.0-28.
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would not result in a significant impact with mitigation as it would result in a maximally exposed individual receptor (“MEIR”) of 1.06 in 1,000,000 residents, and

7.55 in 100,000,000 workers.54 Based on the City’s analysis, the SCEA concludes that the cancer risk for residents at the site would not exceed SCAQMD’s significance criteria of 10 per 1,000,000 million. However, in his review, Dr. Clark discovered that the City’s analysis failed to measure all the potential impacts of the Project and improperly found that the Project will result in a less than significant impact.

Using the input values from the City’s air model, Dr. Clark found that the health impacts to the future residents would be 19.9 in one million, in excess of the SCAQMD threshold of significance of 10 in one million, and substantially higher than the SCEA concludes.
55 Dr. Clark concludes that the impact remains
significant, despite the mitigation measures described in the SCEA. 56 A lead agency’s significance determination must be supported by accurate scientific and factual data.57 An agency cannot conclude that an impact is less than significant unless it produces rigorous analysis and concrete substantial evidence justifying the finding.58 These standards apply to an SCEA’s analysis of the air quality impacts of a Project.

In Sierra Club v. County of Fresno, the California Supreme Court affirmed CEQA’s mandate to protect public health and safety by holding that an EIR fails as an informational document when it fails to disclose the public health impacts from air pollutants that would be generated by a development project.59 In Sierra Club, the Supreme Court held that the EIR for the Friant Ranch Project—a 942-acre master-planned, mixed-use development with 2,500 senior residential units, 250,000 square feet of commercial space, and open space on former agricultural land in north central Fresno County—was deficient as a matter of law in its informational discussion of air quality impacts as they connect to adverse human 54 Ibid.
55 Clark Comments, pp. 7-8; SCAQMD, Air Quality Significance Thresholds (2019) http://www.aqmd.gov/docs/default-source/ceqa/handbook/scaqmd-air-quality-significancethresholds.pdf. 56 Clark Comments, p. 8.
57 14 C.C.R. § 15064(b).
58 Kings County Farm Bureau, 221 Cal.App.3d at 732.
59 Sierra Club v. County of Fresno (2018) 6 Cal.5th 502, 518–522. 2-9
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health effects.60 As the Court explained, “a sufficient discussion of significant impacts requires not merely a determination of whether an impact is significant, but some effort to explain the nature and magnitude of the impact.”61 The Court concluded that the County’s EIR was inadequate for failing to disclose the nature and extent of public health impacts caused by the project’s air pollution. The EIR failed to comply with CEQA because the public, after reading the EIR, “would have no idea of the health consequences that result when more pollutants are added to a nonattainment basin.”62 CEQA mandates discussion, supported by substantial evidence, of the nature and magnitude of impacts of air pollution on public health.63 In Berkeley Jets, the Court of Appeal held that an EIR must analyze the impacts from human exposure to toxic substances.64 In that case, the Port of Oakland approved a development plan for the Oakland International Airport.65 The EIR admitted that the Project would result in an increase in the release of TACs and adopted mitigation measures to reduce TAC emissions, but failed to quantify the severity of the Project’s impacts on human health.66 The Court held that mitigation alone was insufficient, and that the Port had a duty to analyze the health risks associated with exposure to TACs.67 As the CEQA Guidelines explain, “[t]he EIR serves not only to protect the environment but also to demonstrate to the public that it is being protected.”68
The failure to provide information required by CEQA makes meaningful assessment of potentially significant impacts impossible and is presumed to be prejudicial.69 Challenges to an agency’s failure to proceed in the manner required 60 Id. at 507–508, 518–522.
61 Id. at 519, citing Cleveland National Forest Foundation v. San Diego Assn. of Governments (2017) 3 Cal.5th 497, 514–515.
62 Id. at 518. CEQA’s statutory scheme and legislative intent also include an express mandate that agencies analyze human health impacts and determine whether the “environmental effects of a project will cause substantial adverse effects on human beings, either directly or indirectly.” (Public Resources Code § 21083(b)(3) (emphasis added).) Moreover, CEQA directs agencies to “take immediate steps to identify any critical thresholds for the health and safety of the people of the state and take all coordinated actions necessary to prevent such thresholds being reached.” (Public Resources Code § 21000(d) (emphasis added).) 63 Sierra Club v. County of Fresno (2018) 6 Cal.5th 502, 518–522. 64 Berkeley Jets, 91 Cal.App.4th at 1369–1371.
65 Id. at 1349–1350.
66 Id. at 1364–1371.
67 Id.
68 14 C.C.R. § 15003(b).
69 Sierra Club v. State Bd. Of Forestry (1994) 7 Cal.4th 1215, 1236–1237. 2-9
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by CEQA, such as the failure to address a subject required to be covered in an EIR or to disclose information about a project’s environmental effects or alternatives, are subject to a less deferential standard than challenges to an agency’s factual conclusions.70 Courts reviewing challenges to an agency’s approval of an EIR based on a lack of substantial evidence will “determine de novo whether the agency has employed the correct procedures, scrupulously enforcing all legislatively mandated CEQA requirements.”71
Here, the HRA contains substantial errors and omissions which resulted in an inaccurate and incomplete health risk analysis, and an incorrect and unsupported significance determination. A corrected HRA for the Project shows that the Project will result in cancer risk to future residents that exceed the threshold of significance, and requires additional mitigation.

Appendix B to the SCEA states that the building façades facing towards SR134 freeway and the on-ramp from Brand Boulevard would be nearest to traffic volumes and would be exposed to higher amounts of DPM emissions than those located further away from the road; the cancer risk and chronic hazard indices for the on-site receptors would gradually decrease as their distance from the freeway increases across the Project site. 72 In Table 4 of the Appendix, the text states that the maximum cancer risk from DPM emissions generated by diesel-vehicle travel along SR-134 Freeway for residents was calculated to be 1.06 in one-million.73 The maximum cancer risk from DPM emissions generated by diesel-vehicle travel along SR-134 Freeway for workers on site was calculated to be 0.0755 in one-million.74 70 Vineyard Area Citizens for Responsible Growth, Inc. v. City of Rancho Cordova (2007) 40 Cal.4th 412, 435.
71 Id. (internal quotations omitted).
72 SCEA, Appendix B, p. 13.
73 SCEA, Appendix B, p. 13.
74 SCEA, Appendix B, p. 13.
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Upon re-running the air dispersion model, Dr. Clark found that the annual average ground level concentration of DPM across the Project site was calculated to range from 0.01258 ug/m3 to 0.02387 ug/m3.
75 Dr. Clark then used CARB’s HARP
Standalone Risk Assessment Tool and determined that the minimum cancer risk from inhalation of DPM emitted from sources on SR-134 and the adjacent roadways is 1.11 x 10-5 or 11.1 in one million.76 For the maximum concentration modeled, the cancer risk from inhalation of DPM emitted from sources on SR-134 and the adjacent roadways was calculated to be 1.99 x 10-5 or 19.9 in one million.77 In both scenarios, Dr. Clark’s analysis shows that the Project will expose residents to TAC DPM concentrations that result in cancer risk in excess of the SCAQMD threshold of significance of 10 in one million.78 Dr. Clark’s analysis of the Project’s air modeling shows a significant impact that the City has failed to disclose and mitigate. The re-analysis of the health risks for the Project from SR-134 are provided in Exhibit C to this letter.

Dr. Clark states in his comments that the SCEA’s mitigation measures, including the use of MERV 13 filters in HVAC equipment79, will not result in a reduction of the minimum cancer risk for the Project’s future residents to less than significant levels because the SCEA would need to include a mitigation measure requiring residents to keep their windows closed over 50% of the time in perpetuity.80 Dr. Clark notes that the only way to ensure a mitigation measure of this type would be effective would be to ensure that all windows on site were not able to be opened.81 Additional mitigation measures are necessary in order for the City to reduce the Project’s air quality impacts to less than significant levels. The City must correct the HRA and show that the impacts from SR-134 are more significant than was outlined in the draft SCEA in an SCEIR. 75 Clark Comments, p. 7.
76 Clark Comments, p. 7.
77 Clark Comments, p. 7.
78 SCAQMD, Air Quality Significance Thresholds (2019) http://www.aqmd.gov/docs/defaultsource/ceqa/handbook/scaqmd-air-quality-significance-thresholds.pdf 79 SCEA, p. 5.0-32.
80 Clark Comments, p. 8.
81 Clark Comments, p. 8.
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2. The SCEA Fails to Disclose and Analyze the Potential Air Quality Impacts from the Use of Backup Generators
The City failed to account for the reasonably foreseeable use of backup generators (“BUG”) during Project operations. Dr. Clark explains that, given the size of the Project, and the need for continuous electrical supply, a BUG must be installed on site.82 Operational emissions from BUGs due to testing and maintenance along unscheduled events, including but not limited to Public Safety Power Shutoff (“PSPS”) events and extreme heat events must be analyzed by the City.
83 Extreme heat events are defined as periods where the temperatures throughout California exceed 100 degrees Fahrenheit.84 The total duration of the PSPS events lasted between 141 hours to 154 hours in 2019.85 In 2021, the Governor of California declared that during extreme heat events the use of stationary generators shall be deemed an emergency use.86 The number of Extreme Heat Events is likely to increase in California with the continuing change in climate the State is currently undergoing.87
During a PSPS or an extreme heat event, power is expected to come from engines regulated by CARB and California’s 35 air pollution control and air quality management districts (air districts). 88 Additionally, Dr. Clark states that the health effects related to emissions from diesel BUGs are a particular concern during PSPS and extreme heat events.89
According to the California Public Utilities Commission (“CPUC”) deenergization report, in October 2019, there were almost 806 PSPS events (emphasis added) that impacted almost 973,000 customers (~7.5% of households in California) of which ~854,000 of them were residential customers, and the rest were 82 Clark Comments, p. 8.
83 Clark Comments, p. 8.
84 Governor of California, Proclamation of a State of Emergency (June 17, 2021) available at https://www.gov.ca.gov/wp-content/uploads/2021/06/6.17.21-Extreme-Heat-proclamation.pdf 85 Clark Comments, p. 7.
86 17 C.C.R. § 93115.4 sub. (a) (30) (A)(2).
87 Clark Comments, p. 7.
88 CARB, 2019, Use of Back-up Engines For Electricity Generation During Public Safety Power Shutoff Events (October 25, 2019) available at https://ww2.arb.ca.gov/sites/default/files/2019- 10/PSPS_Back-up_Power_Guidance.pdf
89 Clark Comments, p. 7.
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commercial, industrial, medical baseline, or other customers.90 CARB’s data also indicated that on average each of these customers had about 43 hours of power outage in October 2019. 91 Using the actual emission factors for each diesel BUG engines in the air district’s stationary BUGs database, CARB staff calculated that the 1,810 additional stationary generators running during a PSPS in October 2019 generated 126 tons of NOx, 8.3 tons or particulate matter, and 8.3 tons of DPM.92 As Dr. Clark explains in his comments, testing and maintenance of BUGs along with each PSPS or extreme heat event that occurs during the operational phase of the project will result in significant concentrations of DPM to be released that are not accounted for in the City’s analysis.93 In 2021, two extreme heat events were declared.94 For the June 17, 2021 extreme heat event, the period for which stationary generator owners were allowed to use their BUGs lasted 48 hours.95 For the July 9, 2021 extreme heat event, the period for which stationary generator owners were allowed to use their BUGs lasted 72 hours.96 Had the Project been in operation during these two extreme heat events, the Project would have run the BUGs for 120 hours, in addition to the 50 hours of use accounted for in the DEIR’s air quality analysis. Furthermore, CARB notes though that the number of Extreme heat events is likely to increase, and thereby PSPS events, with the continuing change in climate that the State is currently undergoing.97 While the City is not required to analyze the worst-case scenarios, there is substantial evidence demonstrating that PSPS events and extreme heat events are reasonably foreseeable events which will require the use of the BUGs beyond just 50 hours of routine testing during Project operations. A detailed analysis of the emissions from these additional hours of the BUGs operation should be included in an SCEIR, including an analysis of the extra time the BUGs will need to run to account for extreme heat events and PSPS.
90 California Public Utilities Commission (“CPUC”), Emission Impact: Additional Generator Usage associated With Power Outage (January 30, 2020) available at https://ww2.arb.ca.gov/sites/default/files/2020-01/Emissions_Inventory_Generator_Demand%20Usage_During_Power_Outage_01_30_20.pdf. 91 Ibid.
92 Ibid.
93 Clark Comments, p. 8.
94 Ibid.
95 Ibid.
96 Ibid.
97 CARB, California’s 2017 Climate Change Scoping Plan (November 2017) p. 6. Available at https://ww2.arb.ca.gov/sites/default/files/classic/cc/scopingplan/scoping_plan_2017.pdf 2-10
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An SCEIR must be written for the Project that includes an analysis of the additional operation of the BUGs that will occur at the project site that is not accounted for in the current air quality analysis.

D. The SCEA Fails Analyze and Mitigate Potentially Significant Noise Impacts
The SCEA’s review of potential noise impacts from the Project identified potentially significant noise impacts from the Project’s construction. It concludes that all the potentially significant impacts will be mitigated below level of significance.

Noise expert, Derek Watry reviewed the SCEA’s analysis and found that it fails to properly disclose, analyze and mitigate the Project’s potentially significant construction noise impacts.

Mr. Watry states the construction noise analysis for the Project references the Federal Transit Administration (“FTA”) Transit Noise and Vibration Impact Assessment Manual.
98 Section 7 of the FTA Manual addresses noise and vibration during construction, and, although the Manual states expressly that “. . . it is not the purpose of this manual to specify standardized criteria for construction noise impact, the following guidelines can be considered reasonable criteria for assessment”, its methodology and criteria have come into widespread use.99 Mr.

Watry explains that the FTA methodology is commonly completed using the Roadway Construction Noise Model (“RCNM”) published by the Federal Highway Administration (“FHWA”).100
Mr. Watry states that the FTA Manual presents two options for assessing construction noise: Option A – General Assessment and Option B – Detailed Assessment. Regarding these options, the Manual states:101 • A general assessment of construction noise is warranted for projects in an early assessment stage when the equipment roster and schedule are undefined and only a rough estimate of construction noise levels is practical. 98 Watry Comments, p. 3.
99 Watry Comments, p. 3.
100 Watry Comments, p. 3.
101 Watry Comments, p. 3.
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• A detailed analysis of construction noise is warranted when many noisesensitive sites are adjacent to a construction project or where contractors are faced with stringent local ordinances or heightened public concerns expressed in early outreach efforts.

The General Assessment makes more conservative assumptions which results in higher noise level estimates, but also has higher criteria.102 Conversely, the Detailed Assessment makes more realistic assumptions (lower estimates), but has lower criteria.103
Here, the SCEA uses the Detailed Assessment prediction methodology, but uses the General Assessment criteria. Upon further investigation, Mr. Watry found that if the City used the Detailed Assessment criteria, it would have concluded that construction noise will cause a significant and unavoidable impact on the neighboring commercial building.104
The basis of the General Assessment methodology is that it is based on only the two loudest pieces of equipment and those are assumed to run at full power 100% of the time thereby creating the most noise possible. 105 The Detailed
Assessment considers all of the reasonably foreseeable equipment, but accounts for the typical amounts of time that that equipment operates at full power (the “usage factor”).106 The calculations in the City’s construction noise survey includes five foreseeable pieces of equipment - concrete saw, dozer, tractor, backhoe and front end loader - and their respective usage factors.107 This is a Detailed Assessment and, as Mr. Watry points out, should use the corresponding criteria.108 Mr. Watry applied the appropriate Detailed Assessment criteria to the five pieces of equipment listed in the Project’s noise study and found that the Project’s construction noise will exceed the applicable criterion by 13.9 dBA, resulting in a 102 Watry Comments, p. 3.
103 Watry Comments, p. 3.
104 Watry Comments, p. 3.
105 Watry Comments, p. 3.
106 Watry Comments, p. 3.
107 SCEA, Appendix D, p. 49.
108 Watry Comments, p. 3.
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significant impact.109 The City must revise its construction noise analysis and present its findings in an SCEIR for public review.

Despite the fact that the SCEA incorrectly concludes that no mitigation would be required for construction noise, it discusses a number of means and methods to reduce construction noise. Mr. Watry states that many of the mitigation measures are not applicable to the Project, while others are not practical, and would therefore not reduce the significant noise impact which he identified to less than significant levels.
110 Mr. Watry explains the inadequacies of many of the Project’s mitigation measures, as detailed below:
• “. . . optimal muffler systems on all equipment would reduce construction noise levels by 10 dBA or more”. 111
Mr. Watry states that the language of this mitigation measure is based on language from Construction Noise; Specification, Control, Measurement, and Mitigation. Technical Report E-53, Construction Engineering Research Laboratory, published in April 1975. Construction equipment was not commonly muffled in 1975. However, in the last 47 years mufflers have become standard equipment. 112
The SCEA uses the FHWA Roadway Construction Model which uses source data from modern, muffled equipment, therefore additional noise attenuation from mufflers may be expected.113
• “. . . the use of a noise barrier can achieve a 5-dBA noise level reduction when it is tall enough to break the line-of-sight to the receiver.”114 Mr. Watry states that while the above statement is technically correct, “the line-of-sight to the receiver” does not apply to the multi-story office buildings that are immediately next to the Project site.115
109 Watry Comments, p 5.
110 Watry Comments, p. 5.
111 SCEA, 5.0-156.
112 Watry Comments, p. 6.
113 Watry Comments, p. 6.
114 SCEA, 5.0-156.
115 Watry Comments, p. 6.
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• “Modifications such as dampening of metal surfaces or the redesign of a particular piece of equipment can achieve noise reduction of up to 5 dBA.”116 Mr. Watry points out that the language quoted in the SCEA is taken out of context.117 The full quote from the FHWA report cited by the SCEA as the source for this statement is:

Modifications such as dampening of metal surfaces is quite effective in reducing noise due to vibration. Another possibility is the redesign of a particular piece of equipment to achieve quieter noise levels. These modifications can usually only be done by the manufacturer or with factory assistance and can be costly, time consuming, and possibly ineffective in reducing the overall noise levels.
118
Mr. Watry states that the measure would require contractors to find and use equipment that is demonstrably quieter than equipment that is currently in common use.119 Because this would require the use of non-standard equipment, the SCEA should substantiate that it, in fact, is a reasonable and feasible, and the specifics of the quieter equipment should be incorporated into the formal mitigation measures of the project.
• “Moving stationary equipment away from sensitive receptors will reduce noise levels at the receptor as every doubling of distance will reduce noise by 4 to 6 dBA.”120
This is a correct statement, but, as Mr. Watry observes, the sources of construction noise used in the Noise Study calculations are mobile, not stationary.

Therefore, the equipment could not feasibly be moved away from the sensitive receptors as they must be able to move about the site to complete the Project. 116 SCEA, 5.0-156.
117 Watry Comments, p. 6.
118 FHWA, Special Report - Measurement, Prediction, and Mitigation, Chapter 4 Mitigation (June 28, 2017) https://www.fhwa.dot.gov/Environment/noise/construction_noise/special_report/hcn04.cfm Accessed March 7, 2022 (emphasis added).
119 Watry Comments, p. 6.
120 SCEA, 5.0-156.
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The City must prepare an SCEIR to properly analyze the potentially significant construction noise impacts from the Project, disclose the Project’s potentially significant noise impacts, and propose feasible, effective, mitigation measures to reduce the Project’s significant impacts.

V. CONCLUSION
There is substantial evidence supporting a fair argument that the Project may result in potentially significant air quality and noise impacts that were not identified in the SCEA, and thus have not been adequately analyzed or mitigated.

We urge the City to fulfill its responsibilities under CEQA by withdrawing the SCEA and preparing a legally adequate SCEIR to address the potentially significant impacts described in this comment letter and the attached expert comments. This is the only way the City and the public will be able to ensure that the Project’s significant environmental impacts are mitigated to less than significant levels.

Sincerely,
Kevin T. Carmichael
KTC:ljl
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EXHIBIT A
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March 9, 2022
Adams Broadwell Joseph & Cardozo
520 Capitol Mall, Suite 350
Sacramento, CA 95814
Attn: Mr. Kevin T. Carmichael
Subject: Comments On Draft Sustainable Communities
Environmental Assessment (SCEA) For Stage II Final
Design Review Case No. PDR 2119308, Development
Agreement Case No. PDA1806045
Dear Mr. Carmichael:

At the request of Adams Broadwell Joseph & Cardozo (ABJC), Clark and Associates (Clark) has reviewed materials related to the 2022 City of Glendale SCEA of the above referenced project.

Clark’s review of the materials in no way constitutes a validation of the conclusions or materials contained within the plan. If we do not comment on a specific item this does not constitute acceptance of the item.

Project Description:

According to the City of Glendale’s Notice of Intent/Notice of Availability, Adelfia Properties II, LLC has submitted a Stage II Final Design Review application for the construction of a new 294-unit, 24- story multi-family residential building on a 63,760 SF (1.48 acre) project site zoned DSP Gateway District. The Project, entitled Lucia Park, will be located at 620 North Brand Blvd and 625 North Maryland Avenue in Glendale, adjacent to State Route 134. The proposed Floor Area Ratio is 7.25 and the building height is 266 feet (7.25 FAR and 275 feet maximum by right). The Project includes 373 subterranean parking spaces for the residential use and 129 above-ground, replacement parking spaces for existing commercial bank building, as well as a publicly accessible open space plaza fronting Brand Boulevard OFFICE
12405 Venice Blvd
Suite 331
Los Angeles, CA 90066
PHONE
310-907-6165
FAX
310-398-7626
EMAIL
[email protected]
Clark & Associates
Environmental Consulting, Inc.
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and residential amenity spaces throughout the project. No changes are proposed to the existing commercial/bank building at 620 N. Brand Boulevard; this building was identified as a potential historic resource in the 2019 South Glendale Historic Resources Survey and is therefore considered a historic resource under the California Environmental Quality Act (CEQA). The existing parking structure and two-story commercial building fronting Maryland Place (625 N. Maryland Avenue) will be demolished. The SCEA states that the Project complies with all of the development standards and no variances are proposed. A Development Agreement is also being requested for a six-year entitlement period for the Project and to lock in the current Development Impact Fees.

The conclusion from the City that all other potential impacts would be less than significant is in fact without merit. There are substantial impacts that are not addressed in the City’s analysis that must be addressed in an environmental impact report (EIR).

Specific Comments:

1. The Description Of The Air Dispersion Model In Appendix B Is Vague And Has A Number Of Omissions/Errors The Must Be Corrected.

After reconstructing the AERMOD dispersion model from the information compiled in Appendix B to the SCEA, it is clear that the there are several flaws in the description to the model presented in the Appendix. According to the text of Appendix B, the air dispersion modeling was conducted using the American Meteorological Society/Environmental Protection Agency Regulator Model (AERMOD v. 10.0.1).1
This reference is out of date According to the July 2021 AERMOD Implementation Guide from U.S. EPA, the current version of AERMOD is 21112.2 This would make
the version utilized by the City more than a decade old, and would not have the capability to import background concentrations, calculate hourly emissions using multi-year assessments, or process large postfiles. If the reference to version 10.0.1 is to the graphical user interface (GUI) used to run AERMOD, the City must correct the text in the SCEA. Either way it is clear the author of Appendix 1 Appendix B to SCEA. 2022. Health Risk Assessment. Pg 18 of 39. 2 U.S. EPA. 2021. AERMOD Implementation Guide. Dated July, 2021. Pg. 1. https://gaftp.epa.gov/Air/aqmg/SCRAM/models/preferred/aermod/aermod_implementation_guide.pdf 2-13
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B is unaware of what version of AERMOD was being utilized, how it functioned, or what the outputs from the model mean. The City must correctly identify the model version utilized in this analysis.

From the table on page 31 of 39 of Appendix B, it is possible to identify the geographic location of all of the sources included in the mobile source dispersion mode. The sources are shown below as red volume boxes in the figure below.

The yellow crosses indicate the receptors at ground-level across the Project site. According to Appendix B, diesel vehicle traffic was modeled as a line source comprised of separate volume sources along the stretch of SR-134. Ten sources are identified on the east bound lanes of State Route 134.

Ten sources are identified on the west bound lanes of State Route 134. 2-14
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Eight sources are identified from the off-ramp to Brand Avenue from west bound lanes of State Route 134.

An additional eight sources are identified as using the on-ramp to east bound lanes of State Route 134.
“Diesel exhaust emissions were modeled using a release height of 7.41 feet (2.26 meters), which is the weighted average height of an exhaust stack above ground level for the combined diesel car and truck traffic along this stretch of freeway. The plume height and width used for each volume source along the SR-134 was 14.83 feet and 88.58 feet (4.52 and 27 meters), respectively. The plume height and width used for each volume source along the on-ramp from Brand Boulevard was 14.83 feet and 39.37 feet (4.52 and 12.0 meters), respectively. The plume height and width used for each volume source along off-ramp to Brand Boulevard was 14.83 feet and 45.93 feet (4.52 and 14.00 meters), respectively. Based on guidance, the plume height was determined by multiplying the average stack height by a factor of 2, while the plume width was determined by adding 19.69 feet (6 meters) 2-14
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to the freeway width.” 3 The text does not restrict to the emissions on an hourly basis during the day or week, therefore in this re-analysis the emissions were assumed to occur all day, every day of the year.

Under the section of Appendix B labeled Terrain Data on page 20 of 39, the City describes the use of “digital elevation model (DEM) data for the Pasadena and Mount Wilson 7.5-minute quadrangles obtained through the AERMOD program.” AERMOD does not have a component that stores 7.5-minute quadrangles. Quadrangles can be obtained through the California Air Resources Board’s (CARB) HARP Digital Elevation Model Files (ww2.arb.ca.gov/resources/documents/harpdigital-elevation-model-files). After downloading the Pasadena and Mt. Wilson DEMs and uploading them to the AERMOD model, neither the Pasadena Quadrangle DEM or the Mt. Wilson DEM are useful in the model domain. The Pasadena DEM is to the east of the receptors for the Project location.

The Mt. Wilson DEM is to the east of the Pasadena DEM and no sources for the model were associated with that DEM.
3 Appendix B to SCEA. 2022. Health Risk Assessment. Pg 18 of 39. 2-14
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The only DEM required in the model is the Burbank DEM. No receptors are identified as being present in the Pasadena or Mt. Wilson DEMs.

The City must update the model to correctly identify the DEM that contains the receptors at the project site.

According to Appendix B, “discrete receptors were placed inside the boundary of the Project site at areas where future residences would be located. Based on SCAQMD’s AERMOD modeling guidance, all receptors should be set to a height of 0 feet (0 meters), so that ground level concentrations are analyzed. In order to fulfill SCAQMD’s requirements and accurately characterize the risk throughout the Project site, a 32.81 foot by 32.81 foot (10 meter by 10 meter) receptor grid was placed over the Project site (including site boundaries). The receptor grid was then converted to discrete receptors to maintain spacing and provide for ease in determining the maximum exposed individual (MEI).” 4
4 Appendix B to SCEA. 2022. Health Risk Assessment. Pg 20 of 39. 2-14
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Appendix B of Appendix B is labeled “AERMOD Output Sheets”. A review of the appendix clearly shows that Appendix B to the Health Risk Assessment contains the Emission Inventory from the EMFAC2021 (v 1.0.1) analysis of the Los Angeles region. The City must correctly label the information in the report. The output from the re-analysis of the impacts from SR-134 are included in Exhibit A to this letter.

2. The HRA For Mobile Sources In The SCEA Underestimates The Potential Health Risk From Diesel Particulate Matter (DPM)
According to Appendix B to the SCEA, the building façades facing towards SR-134 freeway and the on-ramp from Brand Boulevard would be nearest to traffic volumes and would be exposed to higher amounts of DPM emissions than those located further away from the road; the cancer risk and chronic hazard indices for the on-site receptors would gradually decrease as their distance from the freeway increases across the Project site. 5
In Table 4 of the Appendix, the text states that the
maximum cancer risk from DPM emissions generated by diesel-vehicle travel along SR-134 Freeway for residents was calculated to be 1.06 in one-million. The maximum cancer risk from DPM emissions generated by diesel-vehicle travel along SR-134 Freeway for workers on site was calculated to be

0.0755 in one-million.

After re-running the air dispersion model, the annual average ground level concentration of DPM across the Project site was calculated to range from 0.01258 ug/m3 to 0.02387 ug/m3. Using the
CARB’s HARP Standalone Risk Assessment Tool, the minimum cancer risk from inhalation of DPM emitted from sources on SR-134 and the adjacent roadways was calculated to be 1.11 x 10-5 or 11.1 in one million. For the maximum concentration modeled, the cancer risk from inhalation of DPM emitted from sources on SR-134 and the adjacent roadways was calculated to be 1.99 x 10-5 or 19.9 in one 5 Appendix B to SCEA. 2022. Health Risk Assessment. Pg 13 of 39. 2-14
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million. The re-analysis of the health risks for the Project from SR-134 are provided in Exhibit B to this letter.

Even with the mitigation measures outlined in the SCEA (MERV 14 through 16 filters), the residents will need to keep their windows and doors closed to the outside at least 50% of the time in perpetuity. The only way the mitigation measures will be effective are to ensure that no windows or doors are allowed to open to the outside. This is an unrealistic and unenforceable expectation to impose on future residents. This mitigation measure could also create a potential fire hazard or health hazard for residents of the structure if they were required to keep their windows and doors closed the majority of their time indoors. The City must correct the HRA and show that the impacts from SR134 are more significant than was outlined in the draft SCEA in an EIR, and must impose additional mitigation beyond the MERV 14 through MERV 16 filtration evaluated in the Air Quality Analysis and Health Risk Analysis of the Project. Additional mitigation measures could include modifying HVAC systems to ensure that intake air flow is taken from areas farthest away from SR-134, and/or inclusion of oxidative catalysts on HVAC systems to further reduce the Project’s operational health risk to residents.

3. The Air Quality Analysis For The Project Fails To Include Impacts From The Emergency Generator(s) That Will Be Installed Onsite.

The City has failed to include all sources of DPM in its analysis. Given the size of the Project and the need for continuous electrical supply, a back-up generator (BUG) must be installed on site.

The site drawings for the SCEA fail to detail where the BUG will be specifically located. Operational emissions from BUGs due to testing and maintenance along unscheduled events, including but not limited to Public Safety Power Shutoff (PSPS) events and extreme heat events, must be analyzed by the City. Extreme heat events are defined as periods wherein the temperatures throughout California exceed 100 degrees Fahrenheit.6
The total duration of the PSPS events lasted between 141 hours to 154 hours in 2019. In 2021, the Governor of California declared that, during extreme heat events, the use of stationary generators shall be deemed an emergency use under California Code of Regulations 6 Governor of California. 2021. Proclamation of a state of emergency. June 17, 2021. 2-16
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(CCR), title 17, section 93115.4 sub. (a) (30) (A)(2). The number of Extreme Heat Events is likely to increase in California with the continuing change in climate the State is currently undergoing.

Power produced during PSPS or extreme heat events is expected to come from engines regulated by CARB and California’s 35 air pollution control and air quality management districts (air districts). 7
Of particular concern are health effects related to emissions from diesel back-up engines.

Diesel particulate matter (DPM) has been identified as a toxic air contaminant, composed of carbon particles and numerous organic compounds, including over forty known cancer-causing organic substances. The majority of DPM is small enough to be inhaled deep into the lungs and make them more susceptible to injury.

According to the California Public Utilities Commission (CPUC) de-energization report, 8 in
October 2019, there were almost 806 PSPS events (emphasis added) that impacted almost 973,000 customers (~7.5% of households in California) of which ~854,000 of them were residential customers, and the rest were commercial/industrial/medical baseline/other customers. CARB’s data also indicated that, on average, each of these customers had about 43 hours of power outage in October 2019. 9 Using the actual emission factors for each diesel BUG engines in the air district’s stationary BUGs database, CARB staff calculated that the 1,810 additional stationary generators (like those proposed for the Project) running during a PSPS in October 2019 generated 126 tons of NOx, 8.3 tons or particulate matter, and 8.3 tons of DPM. In addition to creating an onsite source of DPM which will affect the residents of the structure, the additional NOx emissions could increase the daily emission rate above the regional threshold depending on the size of the BUG utilized by the Project.

An EIR must be written for the Project that includes an analysis of the additional operation of the BUG that will occur at the project site that is not accounted for in the current air quality analysis. 7 CARB. 2019. Use of Back-up Engines For Electricity Generation During Public Safety Power Shutoff Events.

October 25, 2019.
8 https://www.cpuc.ca.gov/deenergization/ as cited in CARB, 2020. Potential Emission Impact of Public Safety Power Shutoff (PSPS), Emission Impact: Additional Generator Usage associated With Power Outage.. 9 CARB, 2020. Potential Emission Impact of Public Safety Power Shutoff (PSPS), Emission Impact: Additional Generator Usage associated With Power Outage..
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Conclusion
The facts identified and referenced in this comment letter lead me to reasonably conclude that the Project could result in significant unmitigated impacts if the SCEA is approved. The City must re-evaluate the significant impacts identified in this letter by requiring the preparation of a revised draft environmental impact report.

Sincerely,
2-17
Responses to Comments
Comment Letter No. 2
Lucia Park Project
Sustainable Communities Environmental Assessment
City of Glendale
March 2022
2023 of 2287

EXHIBIT
CV
Responses to Comments
Comment Letter No. 2
Lucia Park Project
Sustainable Communities Environmental Assessment
City of Glendale
March 2022
2024 of 2287
James J. J. Clark, Ph.D.

Principal Toxicologist
Toxicology/Exposure Assessment Modeling
Risk Assessment/Analysis/Dispersion Modeling
Education:

Ph.D., Environmental Health Science, University of California, 1995 M.S., Environmental Health Science, University of California, 1993 B.S., Biophysical and Biochemical Sciences, University of Houston, 1987 Professional Experience:

Dr. Clark is a well-recognized toxicologist, air modeler, and health scientist. He has 30 years of experience in researching the effects of environmental contaminants on human health including environmental fate and transport modeling (SCREEN3, AEROMOD, ISCST3, Johnson-Ettinger Vapor Intrusion Modeling, RESRAD, GENII); exposure assessment modeling (partitioning of contaminants in the environment as well as PBPK modeling); conducting and managing human health risk assessments for regulatory compliance and risk-based clean-up levels; and toxicological and medical literature research.

Significant projects performed by Dr. Clark include the following:

LITIGATION SUPPORT
Case: Pamela Butler Vs. Mallinckrodt, Inc. & Cotter Corporation. Case No.:
4:2018cv01701 United States District Court Eastern District of Missouri Eastern Division
Case: Kenneth Edward Koterba Vs. Mallinckrodt, Inc. & Cotter Corporation.

Case No.: 4:2018cv01702 United States District Court Eastern District of Missouri Eastern Division
Case: Anthony Hines Vs. Mallinckrodt, Inc. & Cotter Corporation. Case No.:
4:2018cv01703 United States District Court Eastern District of Missouri Eastern Division
Clark & Associates
Environmental Consulting, Inc
Office
12405 Venice Blvd.

Suite 331
Los Angeles, CA 90066
Phone
310-907-6165
Fax
310-398-7626
Email
[email protected]
Responses to Comments
Comment Letter No. 2
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Sustainable Communities Environmental Assessment
City of Glendale
March 2022
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Case: Emery David Walick, III Vs. Mallinckrodt, Inc. & Cotter Corporation. Case No.: 4:2018cv01704 United States District Court Eastern District of Missouri Eastern Division
Client: Humphrey, Farrington & McClain, P.C., Independence, Missouri Dr. Clark performed a historical dose reconstruction for community members exposed to radioactive waste released into the environment from the St. Louis Air Port Site (SLAPS) and the Hazelwood Interim Storage Site (HISS). The releases resulted in impacts to soils, sediments, surface waters, and groundwater in the vicinity of the SLAPS and HISS sites.

The analysis was performed in general accordance with the methods outlined by the Agency for Toxic Substances Control (ATSDR) for assessing radiation doses from historical source areas in North St. Louis County, Missouri.

Case Result: Trial Pending
Case: Don Strong, et al. vs. Republic Services, Inc., Bridgeton Landfill, LLC, vs.

Cotter Corporation, N.S.L., Case No.: 17SL-CC01632-01 Circuit Court of St. Louis County, State of Missouri, Division 17
Client: Humphrey, Farrington & McClain, P.C., Independence, Missouri Dr. Clark performed a historical dose reconstruction for community members from radiologically impacted material (RIM) releases from the adjacent West Lake Landfill.

The analysis was performed in general accordance with the methods outlined by the Agency for Toxic Substances Control (ATSDR) for assessing radiation doses from historical source areas in North St. Louis County, Missouri.

Case Result: Settlement in favor of plaintiff.

Case: Arnold Goldstein, Hohn Covas, Gisela Janette La Bella, et al.. vs. Exxon Mobil Corporation, PBF Energy Inc., Torrance Refining Company LLC, et al., Case No.: 2:17-cv-02477DSF United States District Court for the Central District of California
Client: Sher Edlging, LLP, San Francisco, California and Matern Law Group , PC., El Segundo, California
Responses to Comments
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Sustainable Communities Environmental Assessment
City of Glendale
March 2022
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Dr. Clark performed a historical dose reconstruction for community members from an active 700 acre petroleum refinery in Los Angeles. The analysis included a multi-year dispersion model was performed in general accordance with the methods outlined by the U.S. EPA and the SCAQMD for assessing the health impacts in Torrance, California. The results of the analysis are being used as the basis for injunctive relief for the communities surrounding the refinery.

Case Result: Trial Pending
Case: Scott D. McClurg, et al. v. Mallinckrodt Inc. and Cotter Corporation.

Lead Case No.: 4:12CV00361 AGF United States District Court Eastern District of Missouri Eastern Division
Client: Environmental Law Group, Birmingham, AL.

Dr. Clark performed a historical dose reconstruction for community members and workers exposed to radioactive waste released into the environment from the St. Louis Air Port Site (SLAPS) and the Hazelwood Interim Storage Site (HISS). The releases resulted in impacts to soils, sediments, surface waters, and groundwater in the vicinity of the SLAPS and HISS sites. The analysis included the incorporation of air dispersion modeling across the community to determine ground-level air concentrations and deposition of thorium and uranium isotopes and their respective daughter products. The dose reconstruction considered all relevant pathways to determine total doses of radiation received across the community from 1946 through 2017.

Case Result: Settlement in favor of plaintiff.

Case: Mary Ann Piccolo V. Headwaters Incorporated, et al. Seventh Judicial Court In and For Carbon County, State of Utah. Case No. 130700053 Client: Law Offices of Roy L. Mason. Annapolis, MD
Dr. Clark performed a dose assessment of an individual occupationally exposed to metals and silica from fly ash who later developed cancer. A review of the individual’s medical and occupational history was performed to prepare opinions regarding his exposure and later development of cancer.

Responses to Comments
Comment Letter No. 2
Lucia Park Project
Sustainable Communities Environmental Assessment
City of Glendale
March 2022
2027 of 2287
Case Result: Settlement in favor of plaintiff.

Case: Tracey Coleman V. Headwaters Incorporated, et al. Seventh Judicial Court In and For Carbon County, State of Utah. Case No. 140902847 Client: Law Offices of Roy L. Mason. Annapolis, MD
Dr. Clark performed a dose assessment of an individual occupationally exposed to metals and silica from fly ash who later developed cancer. A review of the individual’s medical and occupational history was performed to prepare opinions regarding his exposure and later development of cancer.

Case Result: Settlement in favor of plaintiff.

Case: David Dominguez and Amanda Dominguez V. Cytec Industries, Inc et al.

Superior Court of the State Of California for the County Of Los Angeles – Central Civil West. Civil Action. BC533123
Client: Rose, Klein, Marias, LLP, Long Beach, California Dr. Clark performed a toxicological assessment of an individual occupationally exposed to hexavalent chromium who later developed cancer. A review of the individual’s medical and occupational history was performed to prepare opinions regarding her exposure and later development of cancer.

Case Result: Settlement in favor of plaintiff.

SELECTED AIR MODELING RESEARCH/PROJECTS
Client(s) – Multiple
Indoor Air Evaluations, California: Performed multiple indoor air screening evaluations and risk characterizations consistent with California Environmental Protection Agency’s (Cal/EPA) Department of Toxic Substances Control (DTSC) and Regional Water Quality Control Board (RWQCB) methodologies. Characterizations included the use of DTSC’s modified Johnson & Ettinger Model and USEPA models, as well as the attenuation factor model currently advocated by Cal/EPA’s Office of Environmental Health and Hazard Assessment (OEHHA).

Responses to Comments
Comment Letter No. 2
Lucia Park Project
Sustainable Communities Environmental Assessment
City of Glendale
March 2022
2028 of 2287
Client – Confidential
Dr. Clark performed a comprehensive evaluation of criteria pollutants, air toxins, and particulate matter emissions from a carbon black production facility to determine the impacts on the surrounding communities. The results of the dispersion model were used to estimate acute and chronic exposure concentrations to multiple contaminants and were be incorporated into a comprehensive risk evaluation.

Client – Confidential
Dr. Clark performed a comprehensive evaluation of air toxins and particulate matter emissions from a railroad tie manufacturing facility to determine the impacts on the surrounding communities. The results of the dispersion model have been used to estimate acute and chronic exposure concentrations to multiple contaminants and have been incorporated into a comprehensive risk evaluation.

EMERGING/PERSISTENT CONTAMINANT RESEARCH/PROJECTS
Client: City of Santa Clarita, Santa Clarita, California Dr. Clark managed the oversight of the characterization, remediation and development activities of a former 1,000 acre munitions manufacturing facility for the City of Santa Clarita. The site is impacted with a number of contaminants including perchlorate, unexploded ordinance, and volatile organic compounds (VOCs). The site is currently under a number of regulatory consent orders, including an Immanent and Substantial Endangerment Order. Dr. Clark assisted the impacted municipality with the development of remediation strategies, interaction with the responsible parties and stakeholders, as well as interfacing with the regulatory agency responsible for oversight of the site cleanup.

Client – Confidential, Los Angeles, California
Dr. Clark is performing a comprehensive review of the potential for pharmaceuticals and their by-products to impact groundwater and surface water supplies. This evaluation will include a review if available data on the history of pharmaceutical production in the United States; the chemical characteristics of various pharmaceuticals; environmental fate and transport; uptake by xenobiotics; the potential effects of pharmaceuticals on water treatment systems; and the potential threat to public health. The results of the evaluation may be used as a briefing tool for non-public health professionals.

Responses to Comments
Comment Letter No. 2
Lucia Park Project
Sustainable Communities Environmental Assessment
City of Glendale
March 2022
2029 of 2287

PUBLIC HEALTH/TOXICOLOGY
Client: Brayton Purcell, Novato, California
Dr. Clark performed a toxicological assessment of residents exposed to methyl-tertiary butyl ether (MTBE) from leaking underground storage tanks (LUSTs) adjacent to the subject property. The symptomology of residents and guests of the subject property were evaluated against the known outcomes in published literature to exposure to MTBE. The study found that residents had been exposed to MTBE in their drinking water; that concentrations of MTBE detected at the site were above regulatory guidelines; and, that the symptoms and outcomes expressed by residents and guests were consistent with symptoms and outcomes documented in published literature.

Client: Covanta Energy, Westwood, California
Evaluated health risk from metals in biosolids applied as soil amendment on agricultural lands. The biosolids were created at a forest waste cogeneration facility using 96% whole tree wood chips and 4 percent green waste. Mass loading calculations were used to estimate Cr(VI) concentrations in agricultural soils based on a maximum loading rate of 40 tons of biomass per acre of agricultural soil. The results of the study were used by the Regulatory agency to determine that the application of biosolids did not constitute a health risk to workers applying the biosolids or to residences near the agricultural lands.

Client: Kaiser Venture Incorporated, Fontana, California Prepared PBPK assessment of lead risk of receptors at a 1,100-acre former steel mill. This evaluation was used as the basis for granting closure of the site by lead regulatory agency.

RISK ASSESSMENTS/REMEDIAL INVESTIGATIONS
Kaiser Ventures Incorporated, Fontana, California
Prepared health risk assessment of semi-volatile organic chemicals and metals for a fiftyyear old wastewater treatment facility used at a 1,100-acre former steel mill. This evaluation was used as the basis for granting closure of the site by lead regulatory agency.

Responses to Comments
Comment Letter No. 2
Lucia Park Project
Sustainable Communities Environmental Assessment
City of Glendale
March 2022
2030 of 2287
ANR Freight - Los Angeles, California
Prepared a comprehensive Preliminary Endangerment Assessment (PEA) of petroleum hydrocarbon and metal contamination of a former freight depot. This evaluation was as the basis for reaching closure of the site with lead regulatory agency.

Kaiser Ventures Incorporated, Fontana, California
Prepared comprehensive health risk assessment of semi-volatile organic chemicals and metals for 23-acre parcel of a 1,100-acre former steel mill. The health risk assessment was used to determine clean up goals and as the basis for granting closure of the site by lead regulatory agency. Air dispersion modeling using ISCST3 was performed to determine downwind exposure point concentrations at sensitive receptors within a 1 kilometer radius of the site. The results of the health risk assessment were presented at a public meeting sponsored by the Department of Toxic Substances Control (DTSC) in the community potentially affected by the site.

Unocal Corporation - Los Angeles, California
Prepared comprehensive assessment of petroleum hydrocarbons and metals for a former petroleum service station located next to sensitive population center (elementary school).

The assessment used a probabilistic approach to estimate risks to the community and was used as the basis for granting closure of the site by lead regulatory agency.

Client: Confidential, Los Angeles, California
Managed oversight of remedial investigation most contaminated heavy metal site in California. Lead concentrations in soil excess of 68,000,000 parts per billion (ppb) have been measured at the site. This State Superfund Site was a former hard chrome plating operation that operated for approximately 40-years.

Client: Confidential, San Francisco, California
Coordinator of regional monitoring program to determine background concentrations of metals in air. Acted as liaison with SCAQMD and CARB to perform co-location sampling and comparison of accepted regulatory method with ASTM methodology.

Responses to Comments
Comment Letter No. 2
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City of Glendale
March 2022
2031 of 2287
Client: Confidential, San Francisco, California
Analyzed historical air monitoring data for South Coast Air Basin in Southern California and potential health risks related to ambient concentrations of carcinogenic metals and volatile organic compounds. Identified and reviewed the available literature and calculated risks from toxins in South Coast Air Basin.

IT Corporation, North Carolina
Prepared comprehensive evaluation of potential exposure of workers to air-borne VOCs at hazardous waste storage facility under SUPERFUND cleanup decree. Assessment used in developing health based clean-up levels.

Professional Associations
American Public Health Association (APHA)
Association for Environmental Health and Sciences (AEHS) American Chemical Society (ACS)
International Society of Environmental Forensics (ISEF) Society of Environmental Toxicology and Chemistry (SETAC) Publications and Presentations:

Books and Book Chapters
Sullivan, P., J.J. J. Clark, F.J. Agardy, and P.E. Rosenfeld. (2007). Synthetic Toxins In The Food, Water and Air of American Cities. Elsevier, Inc. Burlington, MA.

Sullivan, P. and J.J. J. Clark. 2006. Choosing Safer Foods, A Guide To Minimizing Synthetic Chemicals In Your Diet. Elsevier, Inc. Burlington, MA.

Sullivan, P., Agardy, F.J., and J.J.J. Clark. 2005. The Environmental Science of Drinking Water. Elsevier, Inc. Burlington, MA.

Sullivan, P.J., Agardy, F.J., Clark, J.J.J. 2002. America’s Threatened Drinking Water:

Hazards and Solutions. Trafford Publishing, Victoria B.C.

Clark, J.J.J. 2001. “TBA: Chemical Properties, Production & Use, Fate and Transport, Toxicology, Detection in Groundwater, and Regulatory Standards” in Oxygenates in the Environment. Art Diaz, Ed.. Oxford University Press: New York.

Clark, J.J.J. 2000. “Toxicology of Perchlorate” in Perchlorate in the Environment.

Edward Urbansky, Ed. Kluwer/Plenum: New York.

Clark, J.J.J. 1995. Probabilistic Forecasting of Volatile Organic Compound Concentrations At The Soil Surface From Contaminated Groundwater. UMI.

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Lucia Park Project
Sustainable Communities Environmental Assessment
City of Glendale
March 2022
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Baker, J.; Clark, J.J.J.; Stanford, J.T. 1994. Ex Situ Remediation of Diesel Contaminated Railroad Sand by Soil Washing. Principles and Practices for Diesel Contaminated Soils, Volume III. P.T. Kostecki, E.J. Calabrese, and C.P.L. Barkan, eds. Amherst Scientific Publishers, Amherst, MA. pp 89-96.

Journal and Proceeding Articles
Tam L. K.., Wu C. D., Clark J. J. and Rosenfeld, P.E. (2008) A Statistical Analysis Of Attic Dust And Blood Lipid Concentrations Of Tetrachloro-p-Dibenzodioxin (TCDD) Toxicity Equialency Quotients (TEQ) In Two Populations Near Wood Treatment Facilities. Organohalogen Compounds, Volume 70 (2008) page 002254.

Tam L. K.., Wu C. D., Clark J. J. and Rosenfeld, P.E. (2008) Methods For Collect Samples For Assessing Dioxins And Other Environmental Contaminants In Attic Dust: A Review. Organohalogen Compounds, Volume 70 (2008) page 000527 Hensley A.R., Scott, A., Rosenfeld P.E., Clark, J.J.J. (2007). “Attic Dust And Human Blood Samples Collected Near A Former Wood Treatment Facility.” Environmental Research. 105:194-199.

Rosenfeld, P.E., Clark, J. J., Hensley, A.R., and Suffet, I.H. 2007. “The Use Of An Odor Wheel Classification For The Evaluation of Human Health Risk Criteria For Compost Facilities” Water Science & Technology. 55(5): 345-357.

Hensley A.R., Scott, A., Rosenfeld P.E., Clark, J.J.J. 2006. “Dioxin Containing Attic Dust And Human Blood Samples Collected Near A Former Wood Treatment Facility.” The 26th International Symposium on Halogenated Persistent Organic Pollutants – DIOXIN2006, August 21 – 25, 2006. Radisson SAS Scandinavia Hotel in Oslo Norway.

Rosenfeld, P.E., Clark, J. J. and Suffet, I.H. 2005. “The Value Of An Odor Quality Classification Scheme For Compost Facility Evaluations” The U.S. Composting Council’s 13th Annual Conference January 23 - 26, 2005, Crowne Plaza Riverwalk, San Antonio, TX.

Rosenfeld, P.E., Clark, J. J. and Suffet, I.H. 2004. “The Value Of An Odor Quality Classification Scheme For Urban Odor” WEFTEC 2004. 77th Annual Technical Exhibition & Conference October 2 - 6, 2004, Ernest N. Morial Convention Center, New Orleans, Louisiana.

Clark, J.J.J. 2003. “Manufacturing, Use, Regulation, and Occurrence of a Known Endocrine Disrupting Chemical (EDC), 2,4-Dichlorophnoxyacetic Acid (2,4-D) in California Drinking Water Supplies.” National Groundwater Association Southwest Focus Conference: Water Supply and Emerging Contaminants. Minneapolis, MN.

March 20, 2003.

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March 2022
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Rosenfeld, P. and J.J.J. Clark. 2003. “Understanding Historical Use, Chemical Properties, Toxicity, and Regulatory Guidance” National Groundwater Association Southwest Focus Conference: Water Supply and Emerging Contaminants. Phoenix, AZ. February 21, 2003.

Clark, J.J.J., Brown A. 1999. Perchlorate Contamination: Fate in the Environment and Treatment Options. In Situ and On-Site Bioremediation, Fifth International Symposium. San Diego, CA, April, 1999.

Clark, J.J.J. 1998. Health Effects of Perchlorate and the New Reference Dose (RfD).

Proceedings From the Groundwater Resource Association Seventh Annual Meeting, Walnut Creek, CA, October 23, 1998.

Browne, T., Clark, J.J.J. 1998. Treatment Options For Perchlorate In Drinking Water.

Proceedings From the Groundwater Resource Association Seventh Annual Meeting, Walnut Creek, CA, October 23, 1998.

Clark, J.J.J., Brown, A., Rodriguez, R. 1998. The Public Health Implications of MtBE and Perchlorate in Water: Risk Management Decisions for Water Purveyors.

Proceedings of the National Ground Water Association, Anaheim, CA, June 3-4, 1998.

Clark J.J.J., Brown, A., Ulrey, A. 1997. Impacts of Perchlorate On Drinking Water In The Western United States. U.S. EPA Symposium on Biological and Chemical Reduction of Chlorate and Perchlorate, Cincinnati, OH, December 5, 1997.

Clark, J.J.J.; Corbett, G.E.; Kerger, B.D.; Finley, B.L.; Paustenbach, D.J. 1996. Dermal Uptake of Hexavalent Chromium In Human Volunteers: Measures of Systemic Uptake From Immersion in Water At 22 PPM. Toxicologist. 30(1):14.

Dodge, D.G.; Clark, J.J.J.; Kerger, B.D.; Richter, R.O.; Finley, B.L.; Paustenbach, D.J. 1996. Assessment of Airborne Hexavalent Chromium In The Home Following Use of Contaminated Tapwater. Toxicologist. 30(1):117-118.

Paulo, M.T.; Gong, H., Jr.; Clark, J.J.J. (1992). Effects of Pretreatment with Ipratroprium Bromide in COPD Patients Exposed to Ozone. American Review of Respiratory Disease. 145(4):A96.

Harber, P.H.; Gong, H., Jr.; Lachenbruch, A.; Clark, J.; Hsu, P. (1992). Respiratory Pattern Effect of Acute Sulfur Dioxide Exposure in Asthmatics. American Review of Respiratory Disease. 145(4):A88.

McManus, M.S.; Gong, H., Jr.; Clements, P.; Clark, J.J.J. (1991). Respiratory Response of Patients With Interstitial Lung Disease To Inhaled Ozone. American Review of Respiratory Disease. 143(4):A91.

Gong, H., Jr.; Simmons, M.S.; McManus, M.S.; Tashkin, D.P.; Clark, V.A.; Detels, R.; Clark, J.J. (1990). Relationship Between Responses to Chronic Oxidant and Acute Responses to Comments
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Ozone Exposures in Residents of Los Angeles County. American Review of Respiratory Disease. 141(4):A70.

Tierney, D.F. and J.J.J. Clark. (1990). Lung Polyamine Content Can Be Increased By Spermidine Infusions Into Hyperoxic Rats. American Review of Respiratory Disease. 139(4):A41.

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Comment Letter No. 2
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Sustainable Communities Environmental Assessment
City of Glendale
March 2022
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EXHIBIT A

AERMOD ANALYSIS RESULTS
Responses to Comments
Comment Letter No. 2
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Sustainable Communities Environmental Assessment
City of Glendale
March 2022
2036 of 2287
DPM concentrations across site.txt
* AERMOD (21112 ): NO TITLE SPECIFIED 03/02/22
* AERMET ( 16216): 10:35:57
* MODELING OPTIONS USED: RegDFAULT CONC ELEV RURAL ADJ_U* * PLOT FILE OF ANNUAL VALUES AVERAGED ACROSS 5 YEARS FOR SOURCE GROUP: ALL * FOR A TOTAL OF 60 RECEPTORS.
* FORMAT: (3(1X,F13.5),3(1X,F8.2),2X,A6,2X,A8,2X,I8.8,2X,A8)

* X Y AVERAGE CONC ZELEV ZHILL ZFLAG AVE GRP NUM YRS NET ID * ____________ ____________ ____________ ______ ______ ______ ______ ________ ________ ________ 384376.70000 3780080.90000 0.00566 176.36 514.00 0.00 ANNUAL ALL 00000005 384386.70000 3780080.90000 0.00566 176.65 514.00 0.00 ANNUAL ALL 00000005 384396.70000 3780080.90000 0.00566 176.94 514.00 0.00 ANNUAL ALL 00000005 384406.70000 3780080.90000 0.00566 177.00 514.00 0.00 ANNUAL ALL 00000005 384336.70000 3780090.90000 0.00592 175.93 514.00 0.00 ANNUAL ALL 00000005 384346.70000 3780090.90000 0.00594 176.12 514.00 0.00 ANNUAL ALL 00000005 384356.70000 3780090.90000 0.00597 176.28 514.00 0.00 ANNUAL ALL 00000005 384366.70000 3780090.90000 0.00600 176.44 514.00 0.00 ANNUAL ALL 00000005 384376.70000 3780090.90000 0.00600 176.61 514.00 0.00 ANNUAL ALL 00000005 384386.70000 3780090.90000 0.00601 176.79 514.00 0.00 ANNUAL ALL 00000005 384396.70000 3780090.90000 0.00602 176.96 514.00 0.00 ANNUAL ALL 00000005 384406.70000 3780090.90000 0.00601 177.00 514.00 0.00 ANNUAL ALL 00000005 384336.70000 3780100.90000 0.00633 175.93 514.00 0.00 ANNUAL ALL 00000005 384346.70000 3780100.90000 0.00635 176.21 514.00 0.00 ANNUAL ALL 00000005 384356.70000 3780100.90000 0.00638 176.48 514.00 0.00 ANNUAL ALL 00000005 384366.70000 3780100.90000 0.00639 176.75 514.00 0.00 ANNUAL ALL 00000005 384376.70000 3780100.90000 0.00641 176.86 514.00 0.00 ANNUAL ALL 00000005 384386.70000 3780100.90000 0.00642 176.92 514.00 0.00 ANNUAL ALL 00000005 384396.70000 3780100.90000 0.00641 176.99 514.00 0.00 ANNUAL ALL 00000005 384406.70000 3780100.90000 0.00641 177.00 514.00 0.00 ANNUAL ALL 00000005 384336.70000 3780110.90000 0.00679 175.93 514.00 0.00 ANNUAL ALL 00000005 384346.70000 3780110.90000 0.00681 176.23 514.00 0.00 ANNUAL ALL 00000005 384356.70000 3780110.90000 0.00684 176.51 514.00 0.00 ANNUAL ALL 00000005 384366.70000 3780110.90000 0.00685 176.80 514.00 0.00 ANNUAL ALL 00000005 384376.70000 3780110.90000 0.00687 176.90 514.00 0.00 ANNUAL ALL 00000005 384386.70000 3780110.90000 0.00687 176.94 514.00 0.00 ANNUAL ALL 00000005 384396.70000 3780110.90000 0.00687 176.99 514.00 0.00 ANNUAL ALL 00000005 384406.70000 3780110.90000 0.00684 177.04 514.00 0.00 ANNUAL ALL 00000005 384336.70000 3780120.90000 0.00733 175.93 514.00 0.00 ANNUAL ALL 00000005 384346.70000 3780120.90000 0.00735 176.14 514.00 0.00 ANNUAL ALL 00000005 384356.70000 3780120.90000 0.00738 176.31 514.00 0.00 ANNUAL ALL 00000005 384366.70000 3780120.90000 0.00740 176.49 514.00 0.00 ANNUAL ALL 00000005 384376.70000 3780120.90000 0.00741 176.65 514.00 0.00 ANNUAL ALL 00000005 384386.70000 3780120.90000 0.00741 176.81 514.00 0.00 ANNUAL ALL 00000005 384396.70000 3780120.90000 0.00739 176.97 514.00 0.00 ANNUAL ALL 00000005 384406.70000 3780120.90000 0.00735 177.12 514.00 0.00 ANNUAL ALL 00000005 384336.70000 3780130.90000 0.00797 175.93 514.00 0.00 ANNUAL ALL 00000005 384346.70000 3780130.90000 0.00798 176.05 514.00 0.00 ANNUAL ALL 00000005 384356.70000 3780130.90000 0.00801 176.12 514.00 0.00 ANNUAL ALL 00000005 384366.70000 3780130.90000 0.00804 176.18 514.00 0.00 ANNUAL ALL 00000005 384376.70000 3780130.90000 0.00806 176.40 514.00 0.00 ANNUAL ALL 00000005 384386.70000 3780130.90000 0.00803 176.67 514.00 0.00 ANNUAL ALL 00000005 384396.70000 3780130.90000 0.00800 176.94 514.00 0.00 ANNUAL ALL 00000005 384406.70000 3780130.90000 0.00795 177.21 514.00 0.00 ANNUAL ALL 00000005 384336.70000 3780140.90000 0.00875 175.93 514.00 0.00 ANNUAL ALL 00000005 384346.70000 3780140.90000 0.00876 176.00 514.00 0.00 ANNUAL ALL 00000005 384356.70000 3780140.90000 0.00880 176.00 514.00 0.00 ANNUAL ALL 00000005 384366.70000 3780140.90000 0.00884 176.00 514.00 0.00 ANNUAL ALL 00000005 384376.70000 3780140.90000 0.00884 176.26 514.00 0.00 ANNUAL ALL 00000005 384386.70000 3780140.90000 0.00879 176.59 514.00 0.00 ANNUAL ALL 00000005 384396.70000 3780140.90000 0.00872 176.93 514.00 0.00 ANNUAL ALL 00000005 384406.70000 3780140.90000 0.00866 177.26 514.00 0.00 ANNUAL ALL 00000005 384336.70000 3780150.90000 0.00977 175.93 514.00 0.00 ANNUAL ALL 00000005 384346.70000 3780150.90000 0.00973 176.00 514.00 0.00 ANNUAL ALL 00000005 384356.70000 3780150.90000 0.00979 176.00 514.00 0.00 ANNUAL ALL 00000005 384366.70000 3780150.90000 0.00983 176.00 514.00 0.00 ANNUAL ALL 00000005 384376.70000 3780150.90000 0.00984 176.26 514.00 0.00 ANNUAL ALL 00000005 384386.70000 3780150.90000 0.00971 176.59 514.00 0.00 ANNUAL ALL 00000005 384396.70000 3780150.90000 0.00961 176.93 514.00 0.00 ANNUAL ALL 00000005 384406.70000 3780150.90000 0.00956 177.26 514.00 0.00 ANNUAL ALL 00000005

Responses to Comments
Comment Letter No. 2
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Sustainable Communities Environmental Assessment
City of Glendale
March 2022
2037 of 2287
8 hour modeled DPM concentrations.txt
* AERMOD (21112 ): NO TITLE SPECIFIED 03/02/22
* AERMET ( 16216): 11:34:19
* MODELING OPTIONS USED: RegDFAULT CONC ELEV RURAL ADJ_U* * PLOT FILE OF HIGH 1ST HIGH 8-HR VALUES FOR SOURCE GROUP: ALL * FOR A TOTAL OF 60 RECEPTORS.
* FORMAT: (3(1X,F13.5),3(1X,F8.2),3X,A5,2X,A8,2X,A5,5X,A8,2X,I8)

* X Y AVERAGE CONC ZELEV ZHILL ZFLAG AVE GRP RANK NET ID DATE(CONC) * ____________ ____________ ____________ ______ ______ ______ ______ ________ ________ ________ ________ 384376.70000 3780080.90000 0.08208 176.36 953.00 0.00 8-HR ALL 1ST 12090208 384386.70000 3780080.90000 0.08317 176.65 953.00 0.00 8-HR ALL 1ST 12090208 384396.70000 3780080.90000 0.08365 176.94 953.00 0.00 8-HR ALL 1ST 12090208 384406.70000 3780080.90000 0.08399 177.00 953.00 0.00 8-HR ALL 1ST 12090208 384336.70000 3780090.90000 0.08608 175.93 953.00 0.00 8-HR ALL 1ST 12090208 384346.70000 3780090.90000 0.08750 176.12 953.00 0.00 8-HR ALL 1ST 12090208 384356.70000 3780090.90000 0.08825 176.28 953.00 0.00 8-HR ALL 1ST 12090208 384366.70000 3780090.90000 0.08893 176.44 953.00 0.00 8-HR ALL 1ST 12090208 384376.70000 3780090.90000 0.09009 176.61 953.00 0.00 8-HR ALL 1ST 12090208 384386.70000 3780090.90000 0.09060 176.79 953.00 0.00 8-HR ALL 1ST 12090208 384396.70000 3780090.90000 0.09101 176.96 953.00 0.00 8-HR ALL 1ST 12090208 384406.70000 3780090.90000 0.09129 177.00 953.00 0.00 8-HR ALL 1ST 12090208 384336.70000 3780100.90000 0.09449 175.93 953.00 0.00 8-HR ALL 1ST 12090208 384346.70000 3780100.90000 0.09593 176.21 953.00 0.00 8-HR ALL 1ST 12090208 384356.70000 3780100.90000 0.09670 176.48 953.00 0.00 8-HR ALL 1ST 12090208 384366.70000 3780100.90000 0.09796 176.75 953.00 0.00 8-HR ALL 1ST 12090208 384376.70000 3780100.90000 0.09854 176.86 953.00 0.00 8-HR ALL 1ST 12090208 384386.70000 3780100.90000 0.09900 176.92 953.00 0.00 8-HR ALL 1ST 12090208 384396.70000 3780100.90000 0.09933 176.99 953.00 0.00 8-HR ALL 1ST 12090208 384406.70000 3780100.90000 0.09953 177.00 953.00 0.00 8-HR ALL 1ST 12090208 384336.70000 3780110.90000 0.10455 175.93 953.00 0.00 8-HR ALL 1ST 13010908 384346.70000 3780110.90000 0.10641 176.23 953.00 0.00 8-HR ALL 1ST 13010908 384356.70000 3780110.90000 0.10747 176.51 953.00 0.00 8-HR ALL 1ST 13010908 384366.70000 3780110.90000 0.10908 176.80 953.00 0.00 8-HR ALL 1ST 13010908 384376.70000 3780110.90000 0.10983 176.90 953.00 0.00 8-HR ALL 1ST 13010908 384386.70000 3780110.90000 0.11050 176.94 953.00 0.00 8-HR ALL 1ST 13010908 384396.70000 3780110.90000 0.11095 176.99 953.00 0.00 8-HR ALL 1ST 13010908 384406.70000 3780110.90000 0.11180 177.04 953.00 0.00 8-HR ALL 1ST 13010908 384336.70000 3780120.90000 0.11815 175.93 953.00 0.00 8-HR ALL 1ST 13010908 384346.70000 3780120.90000 0.12006 176.14 953.00 0.00 8-HR ALL 1ST 13010908 384356.70000 3780120.90000 0.12112 176.31 953.00 0.00 8-HR ALL 1ST 13010908 384366.70000 3780120.90000 0.12207 176.49 953.00 0.00 8-HR ALL 1ST 13010908 384376.70000 3780120.90000 0.12349 176.65 953.00 0.00 8-HR ALL 1ST 13010908 384386.70000 3780120.90000 0.12412 176.81 953.00 0.00 8-HR ALL 1ST 13010908 384396.70000 3780120.90000 0.12461 176.97 953.00 0.00 8-HR ALL 1ST 13010908 384406.70000 3780120.90000 0.12525 177.12 953.00 0.00 8-HR ALL 1ST 13010908 384336.70000 3780130.90000 0.13420 175.93 953.00 0.00 8-HR ALL 1ST 13010908 384346.70000 3780130.90000 0.13617 176.05 953.00 0.00 8-HR ALL 1ST 13010908 384356.70000 3780130.90000 0.13713 176.12 953.00 0.00 8-HR ALL 1ST 13010908 384366.70000 3780130.90000 0.13792 176.18 953.00 0.00 8-HR ALL 1ST 13010908 384376.70000 3780130.90000 0.13888 176.40 953.00 0.00 8-HR ALL 1ST 13010908 384386.70000 3780130.90000 0.14011 176.67 953.00 0.00 8-HR ALL 1ST 13010908 384396.70000 3780130.90000 0.14065 176.94 953.00 0.00 8-HR ALL 1ST 13010908 384406.70000 3780130.90000 0.14097 177.21 953.00 0.00 8-HR ALL 1ST 13010908 384336.70000 3780140.90000 0.13697 175.93 953.00 0.00 8-HR ALL 1ST 13010908 384346.70000 3780140.90000 0.13744 176.00 953.00 0.00 8-HR ALL 1ST 13010908 384356.70000 3780140.90000 0.13589 176.00 953.00 0.00 8-HR ALL 1ST 13010908 384366.70000 3780140.90000 0.13539 176.00 953.00 0.00 8-HR ALL 1ST 13010908 384376.70000 3780140.90000 0.13498 176.26 953.00 0.00 8-HR ALL 1ST 13010908 384386.70000 3780140.90000 0.14519 176.59 953.00 0.00 8-HR ALL 1ST 13010908 384396.70000 3780140.90000 0.14292 176.93 953.00 0.00 8-HR ALL 1ST 13010908 384406.70000 3780140.90000 0.14074 177.26 953.00 0.00 8-HR ALL 1ST 13010908 384336.70000 3780150.90000 0.12671 175.93 953.00 0.00 8-HR ALL 1ST 13010908 384346.70000 3780150.90000 0.14918 176.00 953.00 0.00 8-HR ALL 1ST 13010908 384356.70000 3780150.90000 0.14803 176.00 953.00 0.00 8-HR ALL 1ST 13010908 384366.70000 3780150.90000 0.13598 176.00 953.00 0.00 8-HR ALL 1ST 13010908 384376.70000 3780150.90000 0.13419 176.26 953.00 0.00 8-HR ALL 1ST 13010908 384386.70000 3780150.90000 0.13124 176.59 953.00 0.00 8-HR ALL 1ST 13010908 384396.70000 3780150.90000 0.15518 176.93 953.00 0.00 8-HR ALL 1ST 13010908 384406.70000 3780150.90000 0.15069 177.26 953.00 0.00 8-HR ALL 1ST 13010908

Responses to Comments
Comment Letter No. 2
Lucia Park Project
Sustainable Communities Environmental Assessment
City of Glendale
March 2022
2038 of 2287

EXHIBIT B
HARP Standalone Health Risk Analysis Results
Responses to Comments
Comment Letter No. 2
Lucia Park Project
Sustainable Communities Environmental Assessment
City of Glendale
March 2022
2039 of 2287
*HARP - HRACalc v21081 3/3/2022 1:47:27 PM - Cancer Risk - Input File: C:\Users\jclar\OneDrive\Desktop\Clark and Associates\Project 148 - ABJC - Lucia Park Project\AERMOD Output\Max Cancer Risk DPMHRAInput.hra INDEX GRP1 GRP2 POLID POLABBREV CONC RISK_SUM SCENARIO DETAILS INH_RISK SOIL_RISK DERMAL_RISK MMILK_RISK WATER_RISK FISH_RISK CROP_RISK BEEF_RISK DAIRY_RISK 1 9901 DieselExhPM 0.02387 2.11E-05 30YrCancerDerived_Inh * 2.11E-05 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 PIG_RISK CHICKEN_RISK EGG_RISK 1ST_DRIVER 2ND_DRIVER PASTURE_CONC FISH_CONC WATER_CONC

0.00E+00 0.00E+00 0.00E+00 INHALATION 0.00E+00 0.00E+00 0.00E+00 *HARP - HRACalc v21081 3/3/2022 1:46:49 PM - Cancer Risk - Input File: C:\Users\jclar\OneDrive\Desktop\Clark and Associates\Project 148 - ABJC - Lucia Park Project\AERMOD Output\Min Cancer Risk DPMHRAInput.hra INDEX GRP1 GRP2 POLID POLABBREV CONC RISK_SUM SCENARIO DETAILS INH_RISK SOIL_RISK DERMAL_RISK MMILK_RISK WATER_RISK FISH_RISK CROP_RISK BEEF_RISK DAIRY_RISK 1 9901 DieselExhPM 0.01258 1.11E-05 30YrCancerDerived_Inh * 1.11E-05 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 PIG_RISK CHICKEN_RISK EGG_RISK 1ST_DRIVER 2ND_DRIVER PASTURE_CONC FISH_CONC WATER_CONC

0.00E+00 0.00E+00 0.00E+00 INHALATION 0.00E+00 0.00E+00 0.00E+00 Responses to Comments
Comment Letter No. 2
Lucia Park Project
Sustainable Communities Environmental Assessment
City of Glendale
March 2022
2040 of 2287

EXHIBIT B
Responses to Comments
Comment Letter No. 2
Lucia Park Project
Sustainable Communities Environmental Assessment
City of Glendale
March 2022
2041 of 2287
WI #22-005.04
10 March 2022
Kevin T. Carmichael, Esq.

Adams Broadwell Joseph & Cardozo
520 Capitol Mall, Suite 350
Sacramento, California 95814
Subject: Lucia Park Project
Glendale, California
Review and Comment on SCEA Noise Analysis
Dear Mr. Carmichael,
As requested, we have reviewed the information and noise impact analyses in the following documents:

Draft Sustainable Communities Environmental Assessment
for the Lucia Park Project (SCEA)
City of Glendale Community Development Department
January 2022
Noise Technical Study for the Lucia Park Project (Noise Study) Meridian Consultants
January 2022
(Appendix D of the SCEA)
This letter reports our comments on the noise analysis in the subject document.

Wilson Ihrig, Acoustical Consultants, has practiced exclusively in the field of acoustics since 1966.

During our 56 years of operation, we have prepared hundreds of noise studies for Environmental Impact Reports and Statements. We have one of the largest technical laboratories in the acoustical consulting industry. We also utilize industry-standard acoustical programs such as Environmental Noise Model (ENM), Traffic Noise Model (TNM), Roadway Construction Noise Model (RCNM), SoundPLAN, and CADNA. In short, we are well qualified to prepare environmental noise studies and review studies prepared by others.
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Responses to Comments
Comment Letter No. 2
Lucia Park Project
Sustainable Communities Environmental Assessment
City of Glendale
March 2022
2042 of 2287
Lucia Park Project, Glendale, Calif.

Review of SCEA Noise Analysis
2 Adverse Effects of Noise1
Although the health effects of noise are not taken as seriously in the United States as they are in other countries, they are real and, in many parts of the country, pervasive.

Noise-Induced Hearing Loss. If a person is repeatedly exposed to loud noises, he or she may experience noise-induced hearing impairment or loss. In the United States, both the Occupational Health and Safety Administration (OSHA) and the National Institute for Occupational Safety and Health (NIOSH) promote standards and regulations to protect the hearing of people exposed to high levels of industrial noise.

Speech Interference. Another common problem associated with noise is speech interference. In addition to the obvious issues that may arise from misunderstandings, speech interference also leads to problems with concentration fatigue, irritation, decreased working capacity, and automatic stress reactions. For complete speech intelligibility, the sound level of the speech should be 15 to 18 dBA higher than the background noise. Typical indoor speech levels are 45 to 50 dBA at 1 meter, so any noise above 30 dBA begins to interfere with speech intelligibility. The common reaction to higher background noise levels is to raise one’s voice. If this is required persistently for long periods of time, stress reactions and irritation will likely result. The problems and irritation that are associated with speech disturbance have become more pronounced during the COVID-19 pandemic because many people find themselves and the people they live with trying to work and learn simultaneously in spaces that were not designed for speech privacy.

Sleep Disturbance. Noise can disturb sleep by making it more difficult to fall asleep, by waking someone after they are asleep, or by altering their sleep stage, e.g., reducing the amount of rapid eye movement (REM) sleep. Noise exposure for people who are sleeping has also been linked to increased blood pressure, increased heart rate, increase in body movements, and other physiological effects. Not surprisingly, people whose sleep is disturbed by noise often experience secondary effects such as increased fatigue, depressed mood, and decreased work performance.

Cardiovascular and Physiological Effects. Human’s bodily reactions to noise are rooted in the “fight or flight” response that evolved when many noises signaled imminent danger. These include increased blood pressure, elevated heart rate, and vasoconstriction. Prolonged exposure to acute noises can result in permanent effects such as hypertension and heart disease.

Impaired Cognitive Performance. Studies have established that noise exposure impairs people’s abilities to perform complex tasks (tasks that require attention to detail or analytical processes) and it makes reading, paying attention, solving problems, and memorizing more difficult. This is why there are standards for classroom background noise levels and why offices and libraries are designed to provide quiet work environments. While sheltering-in-place during the COVID-19 pandemic, many people are finding working and learning more difficult because their home environment is not as quiet as their office or school was.
1 More information on these and other adverse effects of noise may be found in Guidelines for Community Noise, eds B Berglund, T Lindvall, and D Schwela, World Health Organization, Geneva, Switzerland, 1999. (https://www.who.int/docstore/peh/noise/Comnoise-1.pdf) 2-19
Responses to Comments
Comment Letter No. 2
Lucia Park Project
Sustainable Communities Environmental Assessment
City of Glendale
March 2022
2043 of 2287
Lucia Park Project, Glendale, Calif.

Review of SCEA Noise Analysis
3 Comments on Construction Noise Analysis
For the construction noise analysis, the SCEA preparers reference the Federal Transit Administration (FTA) Transit Noise and Vibration Impact Assessment Manual (FTA Report 0123, September 2018).

Section 7 of the FTA Manual addresses noise and vibration during construction, and, although the Manual states expressly that “. . . it is not the purpose of this manual to specify standardized criteria for construction noise impact, the following guidelines can be considered reasonable criteria for assessment”, its methodology and criteria have come into widespread use. [FTA Manual at p. 172] As is often the case, the FTA methodology is executed using the Roadway Construction Noise Model (RCNM) published by the Federal Highway Administration (FHWA).2 The FTA Manual presents two options for assessing construction noise: Option A – General Assessment and Option B – Detailed Assessment. Regarding these options, the Manual states:
• A general assessment of construction noise is warranted for projects in an early assessment stage when the equipment roster and schedule are undefined and only a rough estimate of construction noise levels is practical.
• A detailed analysis of construction noise is warranted when many noise-sensitive sites are adjacent to a construction project or where contractors are faced with stringent local ordinances or heightened public concerns expressed in early outreach efforts. [FTA Manual at p. 177]
Each option has its own methodology and assessment criteria. In general, the General Assessment makes more conservative assumptions (resulting in higher noise level estimates), but also has higher criteria. Conversely, the Detailed Assessment makes more realistic assumptions (lower estimates), but has lower criteria. The SCEA errs in that is uses the Detailed Assessment prediction methodology, but uses the General Assessment criteria. Had it used the Detailed Assessment criteria, as it should have, it would have concluded that construction noise will cause a significant and unavoidable impact on the neighboring commercial building. The error and correction are spelled out in detail in the paragraphs that follow.

The hallmark of the General Assessment methodology is that it is based on only the two loudest pieces of equipment and those are assumed to run at full power 100% of the time (when they produce the maximum amount of noise). In contrast, the Detailed Assessment considers all of the reasonably foreseeable equipment, but accounts for the typical amounts of time that that equipment operates at full power (the “usage factor”). Attachment B of the Noise Study provides the construction noise calculation worksheets. Figure 1 shows an excerpt from Attachment B. Note that the calculation includes five foreseeable pieces of equipment and their respective usage factors. This is a Detailed Assessment and, as such, should use the corresponding criteria. 2 https://www.fhwa.dot.gov/environment/noise/construction_noise/rcnm/ 2-20
Responses to Comments
Comment Letter No. 2
Lucia Park Project
Sustainable Communities Environmental Assessment
City of Glendale
March 2022
2044 of 2287
Lucia Park Project, Glendale, Calif.

Review of SCEA Noise Analysis
4 Figure 1 Excerpt from Noise Study Showing Construction Noise Calculations Because the construction of Lucia Park is proposed to occur only during the daytime, the appropriate criteria are those highlighted in Figure 2 which shows the table from the FTA Manual containing the Detailed Analysis Construction Noise Criteria.
3,4
Figure 2 Table 7-3 of the FTA Manual – Detailed Assessment Noise Criteria 3 Federal Transit Administration, Transit Noise and Vibration Impact Assessment Manual, FTA Report No. 0123, September 2018, p. 179.
4 “Leq,equip(8hr)” denotes the energy equivalent level over an 8-hour workday. The equivalent level is the steady noise level that has the same amount of acoustical energy as the actual, time-varying noise levels. It is essentially the average noise level.
2-20
Responses to Comments
Comment Letter No. 2
Lucia Park Project
Sustainable Communities Environmental Assessment
City of Glendale
March 2022
2045 of 2287
Lucia Park Project, Glendale, Calif.

Review of SCEA Noise Analysis
5 Table 5.13-3 of the SCEA presents the SCEA’s construction noise level estimates and ostensibly assesses them. Figure 3 presents a copy of Table 5.13-3 in which I have inserted the Detailed Assessment noise criteria and revised the assessment accordingly.

Figure 3 Table 5.13-3 of the SCEA – Construction Noise Estimates and Assessment As can be seen in Figure 3, the construction noise estimate at the commercial building adjacent to the Project site will exceed the applicable criterion by 13.9 dBA.

Comments on Means and Methods to Reduce Construction Noise Despite the fact that the SCEA incorrectly concluded that no mitigation would be required for construction noise, it nonetheless discusses a number of means and methods to reduce construction noise. Some of those measures are not applicable and others are not practical. All of the following quotes are from the SCEA at page 5.0-156:
• “. . . optimal muffler systems on all equipment would reduce construction noise levels by 10 dBA or more”.
o The source for this quote is:

P.D. Schomer and B. Homans, Construction Noise; Specification, Control, Measurement, and Mitigation. Technical Report E-53, Construction Engineering Research Laboratory, April 1975
Note the date: 1975. Construction equipment was not commonly muffled in 1975, but that has changed in the ensuing 47 years. The SCEA uses the FHWA Roadway 2-20
2-21
Responses to Comments
Comment Letter No. 2
Lucia Park Project
Sustainable Communities Environmental Assessment
City of Glendale
March 2022
2046 of 2287
Lucia Park Project, Glendale, Calif.

Review of SCEA Noise Analysis
6 Construction Model which uses source data from modern, muffled equipment. No additional noise attenuation from mufflers may be expected. • “. . . the use of a noise barrier can achieve a 5-dBA noise level reduction when it is tall enough to break the line-of-sight to the receiver.”
o This is correct, however, the qualifier - when it is tall enough to break the line-of-sight to the receiver – does not apply to the multi-story office buildings that are immediately next to the development site.
• “Modifications such as dampening of metal surfaces or the redesign of a particular piece of equipment can achieve noise reduction of up to 5 dBA.”
o The full quote from the FHWA report cited by the SCEA as the source for this statement is:

Modifications such as dampening of metal surfaces is quite effective in reducing noise due to vibration. Another possibility is the redesign of a particular piece of equipment to achieve quieter noise levels. These modifications can usually only be done by the manufacturer or with factory assistance and can be costly, time consuming, and possibly ineffective in reducing the overall noise levels.
5 [emphasis added]
This measure effectively means, “Find and use equipment that is demonstrably quieter than equipment that is currently in common use.” Because this would require the use of non-standard equipment, the SCEA should substantiate that the use and availability of such equipment is, in fact, reasonable and feasible. The specifics of the quieter equipment should be incorporated into the formal mitigation measures of the project.
• “Moving stationary equipment away from sensitive receptors will reduce noise levels at the receptor as every doubling of distance will reduce noise by 4 to 6 dBA.” o This is a correct statement, but, for the most part, the construction noise calculations in Attachment B of the Noise Study are mobile, not stationary.

In addition to these project-specific comments, the SCEA also reiterates numerous “mitigation measures” from various regional and area plan EIRs in Section 6.5 Mitigation Monitoring ad Reporting Program [SCEA at pp. 6.0-27 to 6.0-33].6 Not all of these pertain to construction noise.

Those that do are either similar to those just discussed, e.g., “install temporary noise barriers during construction”, or are similarly ineffectual at reducing actual noise levels, e.g., “post . . . who to notify 5 https://www.fhwa.dot.gov/Environment/noise/construction_noise/special_report/hcn04.cfm 6 The referenced EIRs are:
• SCAG 2020-2045 RTP/SCS Program EIR
• City of Glendale South Glendale Community Plan EIR
• City of Glendale Downtown Specific Plan EIR
2-21
Responses to Comments
Comment Letter No. 2
Lucia Park Project
Sustainable Communities Environmental Assessment
City of Glendale
March 2022
2047 of 2287
Lucia Park Project, Glendale, Calif.

Review of SCEA Noise Analysis
7 in the event of a problem”. If people in the office building find it difficult to work when the average noise level outside the building is 99 dBA (see Figure 3), calling someone to report that as a problem will not lead to any abatement of the noise levels unless some of the equipment is not functioning properly and the noise levels are actually higher than 99 dBA. This is not to say that the generic measures listed in Section 6.5 are not good “best practices” that should be followed; I’m simply pointing out that the determination of significance is based on quantified noise levels and criteria, and that there is, unfortunately, nothing the project can do to reduce those noise levels given the close proximity and height of the noise-sensitive receivers in the building on the adjoining lot.

Conclusion
The SCEA uses the FTA Detailed Assessment calculation methodology for construction noise, but then assesses those calculations using the less restrictive General Assessment criteria. When the correct Detailed Assessment criteria are used, the construction noise levels are revealed to be significant at the office buildings immediately adjacent to the project site. Despite concluding incorrectly that construction noise would not cause a significant impact, the SCEA discusses several means and methods to reduce the noise. All of these are either inapplicable or impractical for the situation at hand. Additionally, the SCEA includes generic noise mitigation measures from three regional and area EIR documents, but none of those measures would be capable of reducing the noise levels presented in the SCEA due to the proximity and height of the affected building. Therefore, the construction noise impact will be significant and unavoidable should this project proceed. ⧫ ⧫ ⧫ ⧫ ⧫
Please contact me if you have any question about this review of the noise analysis in the Lucia Park Project SCEA noise analysis.

Very truly yours,

WILSON IHRIG
Derek L. Watry
Principal
2022-03-10 - lucia park - noise - d watry.docx
2-21
2-22
Responses to Comments
Comment Letter No. 2
Lucia Park Project
Sustainable Communities Environmental Assessment
City of Glendale
March 2022
2048 of 2287
Wilson Ihrig Resume – Derek Watry – Page 1
DEREK L. WATRY
Principal
Since joining Wilson Ihrig in 1992, Derek has gained experienced in many areas of practice including environmental, construction, forensic, architectural, and industrial. For all of these, he has conducted extensive field measurements, established acceptability criteria, and calculated future noise and vibration levels. In the many of these areas, he has prepared CEQA and NEPA noise technical studies and EIR/EIS sections. Derek has a thorough understanding of the technical, public relations, and political aspects of environmental noise and vibration compliance work. He has helped resolve complex community noise issues, and he has also served as an expert witness in numerous legal matters.

Education
• M.S. Mechanical Engineering, University of California, Berkeley • B.S. Mechanical Engineering, University of California, San Diego • M.B.A. Saint Mary’s College of California
Project Experience
12th Street Reconstruction, Oakland, CA
Responsible for construction noise control plan from pile driving after City received complaints from nearby neighbors. Attendance required at community meetings. 525 Golden Gate Avenue Demolition, San Francisco, CA
Noise and vibration monitoring and consultation during demolition of a multi-story office building next to Federal, State, and Municipal Court buildings for the SFDPW. 911 Emergency Communications Center, San Francisco, CA
Technical assistance on issues relating to the demolition and construction work including vibration monitoring, developing specification and reviewing/recommending appropriate methods and equipment for demolition of Old Emergency Center for the SFDPW.

Central Contra Costa Sanitary District, Grayson Creek Sewer, Pleasant Hill, CA Evaluation of vibration levels due to construction of new sewer line in hard soil.

City of Atascadero, Review of Walmart EIR Noise Analysis, Atascadero, CA Review and Critique of EIR Noise Analysis for the Del Rio Road Commercial Area Specific Plan.

City of Fremont, Ongoing Environmental Services On-Call Contract, Fremont, CA Work tasks primarily focus on noise insulation and vibration control design compliance for new residential projects and peer review other consultant’s projects.

City of Fremont, Patterson Ranch EIR, Fremont, CA
Conducted noise and vibration portion of the EIR.

City of King City, Silva Ranch Annexation EIR, King City, CA Conducted the noise portion of the EIR and assessed the suitability of the project areas for the intended development. Work included a reconnaissance of existing noise sources and receptors in and around the project areas, and long-term noise measurements at key locations.

Responses to Comments
Comment Letter No. 2
Lucia Park Project
Sustainable Communities Environmental Assessment
City of Glendale
March 2022
2049 of 2287
Wilson Ihrig Resume – Derek Watry – Page 2
Conoco Phillips Community Study and Expert Witness, Rodeo, CA Investigated low frequency noise from exhaust stacks and provided expert witness services representing Conoco Phillips. Evaluated effectiveness of noise controls implemented by the refinery.

Golden Gate Park Concourse Underground Garage, San Francisco, CA Noise and vibration testing during underground garage construction to monitor for residences and an old sandstone statue during pile driving for the City of San Francisco.

Laguna Honda Hospital, Clarendon Hall Demolition, San Francisco, CA Project manager for performed vibration monitoring during demolition of an older wing of the Laguna Honda Hospital.

Loch Lomond Marina EIR, San Rafael, CA
Examined traffic noise impacts on existing residences for the City of San Rafael. Provided the project with acoustical analyses and reports to satisfy the requirements of Title 24.

Mare Island Dredge and Material Disposal, Vallejo, CA
EIR/EIS analysis of noise from planned dredged material off-loading operations for the City of Vallejo.

Napa Creek Vibration Monitoring Review, CA
Initially brought in to peer review construction vibration services provided by another firm, but eventually was tapped for its expertise to develop a vibration monitoring plan for construction activities near historic buildings and long-term construction vibration monitoring.

San Francisco DPW, Environmental Services On-Call, CA
Noise and vibration monitoring for such tasks as: Northshore Main Improvement project, and design noise mitigation for SOMA West Skate Park.

San Francisco PUC, Islais Creek Clean Water Program, San Francisco, CA Community noise and vibration monitoring during construction, including several stages of pile driving. Coordination of noise and ground vibration measurements during pile driving and other construction activity to determine compliance with noise ordinance. Coordination with Department of Public Works to provide a vibration seminar for inspectors and interaction with Construction Management team and nearby businesses to resolve noise and vibration issues.

San Francisco PUC, Richmond Transport Tunnel Clean Water Program, San Francisco, CA Environmental compliance monitoring of vibration during soft tunnel mining and boring, cut-andcover trenching for sewer lines, hard rock tunnel blasting and site remediation. Work involved long-term monitoring of general construction activity, special investigations of groundborne vibration from pumps and bus generated ground vibration, and interaction with the public (homeowners).

Santa Clara VTA, Capitol Expressway Light Rail (CELR) Bus Rapid Transit (BRT) Update EIS, CA Reviewed previous BRT analysis and provide memo to support EIS.

Responses to Comments
Comment Letter No. 2
Lucia Park Project
Sustainable Communities Environmental Assessment
City of Glendale
March 2022
2050 of 2287
Wilson Ihrig Resume – Derek Watry – Page 3
Shell Oil Refinery, Martinez, CA
Identified source of community noise complaints from tonal noise due to refinery equipment and operations. Developed noise control recommendations. Conducted round-the-clock noise measurements at nearby residence and near to the property line of the refinery and correlated results. Conducted an exhaustive noise survey of the noisier pieces of equipment throughout the refinery to identify and characterize the dominant noise sources that were located anywhere from a quarter to three-quarters of a mile away. Provided a list of actions to mitigate noise from the noisiest pieces of refinery equipment. Assisted the refinery in the selection of long-term noise monitoring equipment to be situated on the refinery grounds so that a record of the current noise environment will be documented, and future noise complaints can be addressed more efficiently.

Tyco Electronics Corporation, Annual Noise Compliance Study, Menlo Park, CA Conducted annual noise compliance monitoring. Provided letter critiquing the regulatory requirements and recommending improvements.

University of California, San Francisco Mission Bay Campus Vibration Study, CA Conducted measurements and analysis of ground vibration across site due to heavy traffic on Third Street. Analysis included assessment of pavement surface condition and propensity of local soil structure.

Responses to Comments
Comment Letter No. 2
Lucia Park Project
Sustainable Communities Environmental Assessment
City of Glendale
March 2022
2051 of 2287
Responses to Comments
Lucia Park Project 22 City of Glendale
Sustainable Communities Environmental Assessment Responses to Comments June 2022 COMMENT LETTER NO. 2:

Coalition for Responsible Equitable Economic Development Los Angeles (“CREED LA”) Kevin T. Carmichael
Attorney, Adams Broadwell Joseph & Cardozo
520 Capitol Mall, Suite 350
Sacramento, CA 95814
Response to Comment 2-1
The comment includes a description of the proposed Project. As this comment does not address the information, analysis, or conclusions in the SCEA, no further response is necessary.

Response to Comment 2-2
The comment incorrectly states the SCEA is significantly flawed and does not comply with CEQA because the proposed Project would result in significant impacts on air quality, public health, and noise. The comment does not provide specific analysis to support the claim that impacts would be significant. As discussed in Responses to Comments 2-4 through 2-22, the SCEA and its appendices provided facts, reasonable assumptions based on facts, and expert opinion supported by facts that constitute substantial evidence, as defined by CEQA, all of which supports the conclusions in the SCEA that the impacts Project would either be less than significant or mitigated to less than significant. As such, the City correctly relied on this substantial evidence to support its determination to prepare an SCEA.

Response to Comment 2-3
The comment includes a statement of interest from CREED LA. As this comment does not address the information, analysis, or conclusions in the SCEA, no further response is necessary.

Response to Comment 2-4
The comment includes legal background on the purpose of CEQA, the definition of a Transit Priority Project, and the requirements for an SCEA. The comment states that a SCEA must include a full analysis of Project impacts including air quality, public health, and noise. The comment incorrectly claims that the City failed to conduct a proper analysis of the proposed Project’s noise, air quality, and public health impacts. The comment makes this claim with no substantial evidence. Section 5.0 of the SCEA included full analyses of the proposed Project’s noise, air quality, and health impacts. 2052 of 2287
Responses to Comments
Lucia Park Project 23 City of Glendale
Sustainable Communities Environmental Assessment Responses to Comments June 2022 Response to Comment 2-5
The comment states a SCEA must fully disclose all potentially significant impacts of a project and implement all feasible mitigation to reduce those impacts to less than significant levels, as well as presents additional information related to CEQA requirements. The comment claims the SCEA fails to analyze and mitigate potentially significant impacts but does not provide specific examples. The SCEA and its appendices provided facts, reasonable assumptions based on facts, and expert opinion supported by facts that constitute substantial evidence, as defined by CEQA, all of which supports the conclusions in the SCEA that the Project impacts would either be less than significant or mitigated to less than significant. The City can rely on this substantial evidence to support its determination.

Response to Comment 2-6
The comment incorrectly states that CEQA requires the City to provide the unlocked air quality analysis modeling files used for the Air Quality and Greenhouse Gas Study and Health Risk Assessment (Appendices A and B to the SCEA), but it does not state that all of that input data used in the air quality analysis was already in the SCEA document. There is no CEQA requirement to provide duplicative information and this is not a CEQA violation. Dr. Clark was able to recreate the City’s HRA modeling using the City’s input data.

In order to amplify and clarify this response to comments, despite the fact that providing the “unlocked air quality analysis modeling files” is duplicative, the unlocked files are being provided in response to this comment. The unlocked data files unequivocally demonstrate (testifying to that which has already been demonstrated), that all of the appropriate parameters were used as input for generating the air quality model run and output by using valid versions of the air quality models (See Response to Comment 2-7 regarding the use of correct air quality models). The comment also claims not providing the unlocked air quality analysis modeling files violated CEQA standards as a CEQA document may not rely on missing information or only present the conclusions of an agency. As stated in the Meridian Consultants LLC memorandum on February 18, 2022 (Appendix A), the Air Quality/Greenhouse Gas (AQ/GHG) Technical Report included a detailed description on methodology and assumptions. Information disclosed included type and versions of modeling software used, project data used to estimate emissions, and all additional assumptions made in the absence of project-specific data. This information was provided for all phases of the proposed Project analyzed, including construction and operations. This is what Dr. Clark used to generate his version of the air quality analysis, albeit with modified inputs, so as to produce results showing Project air quality impacts.

All parties reviewing the SCEA are easily able to review the City’s input data/information to understand the methodology and assumptions used in the analysis. The CalEEMod output files provide a table showing changes to default model assumptions that includes the reason for each change from a default 2053 of 2287
Responses to Comments
Lucia Park Project 24 City of Glendale
Sustainable Communities Environmental Assessment Responses to Comments June 2022 assumption in the model (Section 1.3 of the CalEEMod output files). In addition, the AQ/GHG report identified data inputs for operational emissions, e.g., trip generation factors for each use, and data sources and/or assumptions used to estimate operational emissions. Adjustments to trip generation rate model inputs were made based on the traffic study prepared for the Project, which is also appended to the SCEA.

For these reasons, the unlocked input files are not required to review the emissions modeling to confirm or comment on the results as all the input data was provided.

Similarly, the technical study for the Mobile Health Risk Assessment identifies input parameters and specific citations for the sources for information used (e.g., annual average daily trips on SR-134 Freeway) and a description of the modeling methodology. The description of the modeling methodology in the technical study identifies the models used, meteorological data sources, source treatment (e.g., line source for roadways), receptor treatment (i.e., receptor grid and number of receptors), and equations used to estimate cancer and non-cancer risk. The methodology and technical appendices include the modeling results including the data to support the results and findings of the analysis. The unlocked input files are not needed to complete a technical review of the modeling to confirm or comment on the modeling and the results of the modeling. The air quality and HRA conclusions were based on facts and analysis contained in the Air Quality and Greenhouse Gas Study and Health Risk Assessment and the appended output files, not just bare conclusions. Therefore, the City did not violate any applicable CEQA requirements. The foregoing notwithstanding, all the input data used (e.g., the unlocked air quality analysis modeling files) are provided with these Responses to Comments. This data demonstrates that sufficient information and data was already available, amplifies the SCEA analysis and conclusions, and clarifies any confusion the commenter may have concerning the Health Risk Assessment and Air Quality analysis in the SCEA.

Response to Comment 2-7
The comment incorrectly states that the air dispersion modeling software utilized in the Health Risk Assessment is more than a decade old and lacks modeling capability. This comment is not correct. The AERMOD software used for the analysis is Lakes Software AERMOD View Version 10.0.1, which utilizes the latest US EPA AERMOD model version 21112. This software incorporates the U.S. EPA’s preferred regulatory air dispersion model into an easy-to-use interface. Contrary to the commenter’s assertions, this software imports background concentrations, provided hourly emissions using multi-year assessments and processes large postfiles.

The comment further provides explanation related to difference in the use of digital elevation model (DEM) data for the Pasadena Mt. Wilson station and the Burbank station. It is important to note that the dispersion modeling in the HRA utilized preprocessed meteorological data obtained from SCAQMD from 2054 of 2287
Responses to Comments
Lucia Park Project 25 City of Glendale
Sustainable Communities Environmental Assessment Responses to Comments June 2022 the Burbank Airport Meteorological Station, which is the station nearest to the Project site.33 This comment has no merit as the comment suggests the proposed Project’s HRA analysis should have used the Burbank DEM which was already included in the proposed Project HRA modeling as detailed within Appendix B.

The comment states that the cover page to Appendix B of the HRA is labeled incorrectly. Although the cover page title is incorrect, there is no missing information from the HRA report. The HRA table of contents indicates that the report includes EMFAC worksheets and AERMOD Output Sheets. All of these documents are attached to the HRA and the error on the appendix cover page does not change the analysis or conclusion of the HRA analysis.

Response to Comment 2-8
The comment incorrectly states the proposed Project would result in potentially significant impacts and does not implement all feasible mitigation to reduce impacts to less than significant. As discussed in Table

5.3-1 of the SCEA, construction impacts would not exceed the SCAQMD regional construction thresholds.

More specifically, the emissions provided in Table 5.3-1 of the SCEA do not reflect the reductions that would result from compliance with existing regulations and, for this reason, provides a conservative analysis. Therefore, mitigation measures are not required as the Project will not result in significant impacts.34 Additionally, as shown in Table 5.3-2, operational emissions would also not exceed SCAQMD emissions thresholds and would not result in a cumulatively considerable net increase of any criteria pollutant.35 Therefore, mitigation measures would not be required. Table 5.3-3 of the SCEA provides localized emissions related to both construction and operation. As shown, emissions would not exceed the localized significance thresholds.36 Additionally, the localized construction emission estimates (which includes particulate matter from equipment exhaust)37 also do not reflect the reductions in emissions that would result from existing regulations, thus providing a worst-case analysis. Therefore, project specific mitigation would not be required.
33 SCAQMD Meteorological Data for AERMOD, www.aqmd.gov/home/library/air-quality-data-studies/meteorologicaldata/data-for-aermod 34 City of Glendale, Community Development Department. Draft Sustainable Communities Environmental Assessment for the Lucia Park Project. SCH Number 2022010297. Page 5.0-24. Available at:
https://www.glendaleca.gov/home/showpublisheddocument/65609/637781200347330000. Accessed March 2022. 35 City of Glendale, Community Development Department. Draft Sustainable Communities Environmental Assessment for the Lucia Park Project. SCH Number 2022010297. Page 5.0-25. Available at:
https://www.glendaleca.gov/home/showpublisheddocument/65609/637781200347330000. Accessed March 2022. 36 City of Glendale, Community Development Department. Draft Sustainable Communities Environmental Assessment for the Lucia Park Project. SCH Number 2022010297. Page 5.0-27. Available at:
https://www.glendaleca.gov/home/showpublisheddocument/65609/637781200347330000. Accessed March 2022. 37 CalEEMod User Guide, Appendix A: Calculation Details for CalEEMod, http://www.aqmd.gov/caleemod/user's-guide.

Accessed June 2022.
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Responses to Comments
Lucia Park Project 26 City of Glendale
Sustainable Communities Environmental Assessment Responses to Comments June 2022 Response to Comment 2-9
The comment states that HRA performed by the City failed to measure all the potential impacts of the Project and improperly found that the Project will result in a less than significant impact. Furthermore, the comment states that the HRA contains substantial errors and omissions which resulted in an inaccurate and incomplete health risk analysis, and an incorrect and unsupported significance determination. However, the comment does not identify any specific errors or emissions to the HRA modeling. As discussed under Response 2-7, the City’s HRA utilized the correct model and data in its analysis.

The comment states by using the input values from the City’s air model, 38 different emission results were
obtained that would result in potentially significant impacts. To the contrary, the input summaries for the dispersion model and calculation sheets provided in the Appendix of the HRA (Appendix B of the SCEA) support the results identified in the SCEA.

Additionally, the comment incorrectly states that the mitigation measure including Minimum Efficiency Reporting Value (MERV) 13 filters in HVAC equipment would require residents to keep their windows closed over 50 percent of the time to be effective. This statement is incorrect as the modeling provides a risk assessment for windows to be open/closed for: 25 percent of the time; 50 percent of the time; 75 percent of the time; and 100 percent of the time. As provided in the risk calculations (See Appendix B to the SCEA), the results for all of these scenarios are less than significant for all levels of MERV filters assessed.

Response to Comment 2-10
This comment makes the incorrect assumption that the proposed Project is required to include a backup generator. No reference is provided for this claim and the comment letter mentions that a backup generator is not included in the proposed Project’s site plan. Moreover, the comment letter recognizes that analysis of this worst-case scenario is not required.

Response to Comment 2-11
The comment incorrectly states the SCEA analysis fails to properly disclose, analyze, and mitigate the proposed Project’s potentially significant construction noise impacts. 38 Please note that in Comment 2-6 the commenter alleges the City refused to provide input data, and in response to the request for such data the City stated that all the input information was available in the SCEA (See Response to Comment 2- 6). This is indeed true as the commenter here uses the very City’s input data it alleges was not disclosed to generate different emission results.
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Responses to Comments
Lucia Park Project 27 City of Glendale
Sustainable Communities Environmental Assessment Responses to Comments June 2022 The comment claims the proposed Project utilized incorrect thresholds in the construction noise analysis conducted for the proposed Project. The comment states that the FTA Manual presents two options for assessing construction noise: Option A – General Assessment and Option B – Detailed Assessment.

Regarding these options, the Manual states:39
• A general assessment of construction noise is warranted for projects in an early assessment stage when the equipment roster and schedule are undefined and only a rough estimate of construction noise levels is practical.
• A detailed analysis of construction noise is warranted when many noise-sensitive sites are adjacent to a construction project or where contractors are faced with stringent local ordinances or heightened public concerns expressed in early outreach efforts.

The comment incorrectly assumes that the construction noise analysis requires as a detailed analysis per the FTA Manual descriptions above. However, the proposed Project does not meet this criterion. First, the proposed Project does not have “many” noise-sensitive sites adjacent to the proposed Project. The analysis analyzed one on-site receptor with the nearest off-site receptor being located over 200 feet from the Project site. Moreover, the City does not have local ordinances that define construction noise regulations. Section 1.3 of the Glendale General Plan Noise Element states that “Noise generation can also be reviewed during the evaluation of environmental effects of new construction. Mitigation measures or conditions of approval, if needed, can then be incorporated into the design of the project to reduce noise impacts. Finally, having an adopted noise ordinance allows Glendale to enforce standards adopted by the City Council. Glendale employs all these techniques to manage the noise environment of the City.” Pursuant to Section 4.4.3 of the Noise Element of the City’s General Plan, construction noise is exempted from compliance with the City’s Noise Ordinance in Section 8.36.080. It states, “The noise ordinance exempts construction activities from compliance with the noise ordinance limits under certain circumstances. If construction occurs within 500 feet of a residential zone, then construction is prohibited from 7 p.m. to 7 a.m. every night and from 7 p.m. on Saturday to 7 a.m. on Monday (i.e., no Sunday construction). Construction on certain holidays is also prohibited.” The Project will comply with these General Plan restrictions which are echoed in the Glendale Municipal Code (GMC) restricts operation of noise generating construction equipment from occurring between the hours of 7:00 PM on one day and 7:00 AM of the next day, or from 7:00 PM on Saturday to 7:00 AM on Monday, or from 7:00 PM preceding a holiday. As stated in the SCEA, the proposed Project would comply with this regulation.40 39 Federal Transit Administration, Transit Noise and Vibration Impact Assessment Manual, September 2018, https://www.transit.dot.gov/sites/fta.dot.gov/files/docs/research-innovation/118131/transit-noise-and-vibration-impactassessment-manual-fta-report-no-0123_0.pdf. 40 City of Glendale, Community Development Department. Draft Sustainable Communities Environmental Assessment for the Lucia Park Project. SCH Number 2022010297. Page 5.0-156. Available at:
https://www.glendaleca.gov/home/showpublisheddocument/65609/637781200347330000. Accessed March 2022. 2057 of 2287
Responses to Comments
Lucia Park Project 28 City of Glendale
Sustainable Communities Environmental Assessment Responses to Comments June 2022 Furthermore, a general assessment is more applicable to the proposed Project for several reasons.

Although a general construction schedule has been laid out for the proposed Project, the construction equipment list for each phase of construction is based on the CalEEMod air emission modeling provided in Appendix A to the SCEA. The final construction equipment list is currently not known. As such, the CalEEMod analysis relied on model defaults to generate the mix of equipment during each phase of construction. Therefore, the noise analysis relied on a generalized assumption for equipment based on model defaults. Moreover, the noise analysis conservatively assumed all pieces of equipment would be operating simultaneously as a worst-case scenario. In reality, equipment operation would be staggered through the construction period.

Moreover, the comment’s claim that the detailed assessment thresholds are more conservative is incorrect. The detailed assessment thresholds are expressed in terms of Leq-8hour (average noise levels over an 8-hour period) while the general assessment thresholds are expressed in terms of Leq-1hour (average noise levels over an 1-hour period). The construction noise analysis conducted for the proposed Project expressed noise levels in terms of Leq-1hour. As such, the proposed Project correctly compares these noise levels to the general assessment thresholds. The comment’s claim the proposed Project would exceed the detailed assessment threshold by 13.9 dBA is baseless as it compares the proposed Project’s Leq-1hour data to an Leq-8hour threshold.

For these reasons, the proposed Project’s analysis is classified as a general assessment.

It is important to note that the City’s General Plan and Municipal Code do not establish numeric maximum acceptable source noise levels or noise level increases at potentially affected receivers. Chapter 8.36 of the Glendale Municipal Code (GMC) prohibits construction activities within 500 feet of a residential zone between the hours of 7:00 PM on one date and 7:00 AM of the next day or from 7:00 PM on Saturday to 7:00 AM on Monday or from 7:00 PM preceding a holiday. Moreover, Section 8.36.290(K) of the GMC provides an exemption from the Noise Ordinance for any activity, operation, or noise, which cannot be brought into compliance (with the Noise Ordinance) because it is technically infeasible to do so. “Technical infeasibility” means that noise limitations cannot be complied with despite the use of mufflers, shields, sound barriers, and/or any other noise reduction devices or techniques during the operation of the equipment. Therefore, for purposes of analysis, the SCEA utilizes the thresholds obtained from the FTA Transit Noise and Vibration Impact Assessment Manual.
41 As stated in the SCEA, the FTA General
Assessment Construction Noise Criteria identifies daytime and nighttime thresholds for residential, 41 Federal Transit Administration, Transit Noise and Vibration Impact Assessment Manual, September 2018. Available at:
https://www.transit.dot.gov/sites/fta.dot.gov/files/docs/research-innovation/118131/transit-noise-and-vibration-impactassessment-manual-fta-report-no-0123_0.pdf. Accessed March 2022. 2058 of 2287
Responses to Comments
Lucia Park Project 29 City of Glendale
Sustainable Communities Environmental Assessment Responses to Comments June 2022 commercial, and industrial land uses, which are considered reasonable criteria for use in assessing the potential for adverse community reaction to noise generated by construction activities.

The construction noise criteria threshold for residential uses is 90 dBA (Leq-1hour) during the daytime and 80 dBA (Leq-1hour) during the nighttime period. Additionally, construction noise thresholds for commercial and industrial uses are 100 dBA (Leq-1hour) during both the daytime and nighttime periods.

The SCEA analysis concludes construction noise levels would range between 62.8 dBA (Leq-1hour) at the multi-family residential uses on the corner of Sanchez Drive and Central Avenue (Site 4) to a high of 98.9 dBA (Leq-1hour) at commercial use adjacent to the Project site (Site 1). Noise levels due to construction would not exceed the daytime 90 dBA Leq threshold for residential uses and 100 dBA Leq threshold for commercial uses.42 As such, the comment’s claim that the SCEA requires mitigation measures for construction noise is incorrect.

The comment identifies several reasons why these techniques are not applicable to the proposed Project.

The comment claims that additional noise attenuation from mufflers would not be applicable to the proposed Project as the FHWA Roadway Construction Model used to analyze proposed Project noise impacts already accounts for muffled equipment. As mentioned, the proposed Project does not require mitigation to reduce impacts to less than significant and did not rely on additional noise reduction techniques outside of the FHWA Roadway Construction Model noise analysis to make this determination.

As mufflers are relevant to the proposed Project, it was appropriately discussed in the SCEA as a feasible method to reduce noise. The claim in the comment that the use of a barrier would not apply to the adjacent multi-story office building is unfounded as heavy-duty equipment would remain on ground-level where these barriers would be located. Higher levels of the adjacent building would not experience the same levels of noise as ground level floors due to distance. The use of barriers would serve to reduce noise levels at ground-floor levels where construction noise would be highest. As such, this technique is applicable to the proposed Project. The claim in the comment that the dampening of metal surfaces should be incorporated as formal mitigation to the SCEA is unfounded as mitigation is not required to achieve a less than significant impact for construction noise. The comment’s claim that moving stationary equipment away from sensitive receptors is not a valid form of reducing noise is unfounded. First, the comment claims this noise reduction technique is correct but states it is not applicable to the proposed Project as most heavy-duty equipment is mobile, not stationary. However, the proposed Project would utilize stationary equipment such as generators and cranes where this technique is feasible. As such, this technique can be applied to the proposed Project.
42 City of Glendale, Community Development Department. Draft Sustainable Communities Environmental Assessment for the Lucia Park Project. SCH Number 2022010297. Page 5.0-156. Available at:
https://www.glendaleca.gov/home/showpublisheddocument/65609/637781200347330000. Accessed March 2022. 2059 of 2287
Responses to Comments
Lucia Park Project 30 City of Glendale
Sustainable Communities Environmental Assessment Responses to Comments June 2022 Therefore, the SCEA analysis properly discloses construction noise levels and accurately concludes the proposed Project would result in less than significant impacts prior to mitigation. The SCEA also identifies appropriate measures from prior EIRs to be incorporated, which would further reduce noise levels caused by construction.

Response to Comment 2-12
The comment incorrectly concludes that the proposed Project may result in potentially significant air quality and noise impacts that were not identified in the SCEA. The comment summarizes the previous comments (refer to Responses to Comments 2-1 through 2-11), therefore no response is warranted.

Response to Comment 2-13
The comment includes a description of the proposed Project. As this comment does not address the information, analysis, or conclusions in the SCEA, no further response is necessary.

Response to Comment 2-14
This comment discusses the reconstruction of the AERMOD dispersion model and claims there are several flaws in the description to the model presented in the HRA. Please refer to Response to Comment 2-7.

Response to Comment 2-15
This comment asserts the HRA for mobile sources underestimates the potential health risk from DPM and that the HRA must be corrected to show the more significant impacts from SR-134. Additionally, this comment states that even with mitigation such as MERV filters, the Project will result in a significant impact. Please refer to Response to Comment 2-9.

Response to Comment 2-16
This comment claims all sources of DPM were not included in the analysis, including emergency generators back up generates installed onsite. Please see Response to Comment 2-10.

Response to Comment 2-17
This comment is a conclusion that claims the proposed Project could result in significant unmitigated impacts if the SCEA is approved. As discussed in Responses to Comments 2-1 through 2-16, these claims are unfounded. The analysis in the SCEA, Air Quality and Greenhouse Gas Study (Appendix A to the SCEA), 2060 of 2287
Responses to Comments
Lucia Park Project 31 City of Glendale
Sustainable Communities Environmental Assessment Responses to Comments June 2022 and HRA (Appendix B to the SCEA) are sound and provide substantial evidence that the proposed Project would not result in significant unmitigated impacts.

Response to Comment 2-18
The comment includes an introductory statement about Wilson Ihrig, Acoustical Consultants. As this comment does not address the information, analysis, or conclusions in the SCEA, no further response is necessary.

Response to Comment 2-19
The comment includes background information on adverse effects of noise. As this comment does not address the information, analysis, or conclusions in the SCEA, no further response is necessary.

Response to Comment 2-20
As discussed in Response to Comment 2-11, the analysis in the SCEA utilized the correct construction noise thresholds and included appropriate noise reduction techniques that are applicable to the proposed Project even though they are not required to reduce noise impacts to less than significant. 2061 of 2287
Responses to Comments
Lucia Park Project 32 City of Glendale
Sustainable Communities Environmental Assessment Responses to Comments June 2022 Response to Comment 2-21
As discussed in Response to Comment 2-11, the analysis in the SCEA utilized the correct construction noise thresholds. Therefore, the claim in this comment that the SCEA incorrectly concluded that no mitigation would be required for construction noise is incorrect. Moreover, the comment incorrectly claims that measures are not applicable, and others are not practical. As explained previously in Response to Comment 2-11, these noise reduction techniques are applicable to the proposed Project even though they are not required to reduce noise impacts to less than significant.

Response to Comment 2-22
This comment concludes the comment letter reiterating incorrect claims that the construction noise levels would be significant, inapplicable, or impractical methods to reduce noise were used in the SCEA, and inclusion of generic noise mitigation measures from previous EIRs. Please see Response to Comment 2-

11. Additionally, a SCEA must incorporate all feasible mitigation measures from prior applicable certified EIRs. The SCEA incorporated all feasible mitigation measures from prior EIRs (SCAG 2020–2045 RTP/SCS Program EIR, City of Glendale South Glendale Community Plan EIR, and City of Glendale Downtown Specific Plan EIR) as required by CEQA.
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Public
P.O. Box 4173 Glendale CA 91202
www.GlendaleHistorical.org
March 9, 2022
Villa Zemaitaitis
Community Development Department
Planning Division Office
633 East Broadway, Room 103
Glendale, CA 91206
Re: Comment on Sustainable Communities Environmental Assessment (SCEA) for 620 N Brand and 625 N Maryland Ave, Glendale CA 91203
Dear Ms Zemaitaitis:

Thank you for the opportunity to comment on this important project.

The Glendale Historical Society observes with disappointment that the 620 North Brand Boulevard Parking Garage (Parking Garage), which is an original component of the larger Home Savings & Loan property (Home Savings), and is both functionally related to the main building and was designed specifically by the architects to reflect features of the larger commercial building and to serve the office building, is proposed for demolition as part of the project without any mention or recognition of historic resource impacts.

The main issues are: ignoring that the Home Savings Parking Garage is a character-defining feature of the 620 N. Brand Boulevard historic resource, the proposed project’s lack of conformance with the Secretary of the Interior’s Standards for Rehabilitation, the fact that it is not consistent with the current requirements in the Downtown Specific Plan, and the use of a Sustainable Communities Environmental Assessment (SCEA).

Parking Garage
The proposed project would destroy the setting of the property and importantly demolish the functionally related, matching Parking Garage at 620 North Brand, which must be considered a contributing feature of the Home Savings property.

The Glendale Historical Society (TGHS) advocates for the preservation of important Glendale landmarks, supports maintaining the historic character of Glendale’s neighborhoods, educates the public about and engages the community in celebrating and preserving Glendale’s history and architectural heritage, and operates the Doctors House Museum. TGHS is a tax-exempt, not-for-profit 501(c)(3) organization, and donations to TGHS are tax-deductible to the extent permitted by law. 3-1
3-2
Responses to Comments
Comment Letter No. 3
Lucia Park Project
Sustainable Communities Environmental Assessment
City of Glendale
June 2022
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Public

TGHS believes that the Parking Garage is “functionally related” to the main Home Savings Building. The National Park Service directs “Buildings may be functionally related historically if they “…were located on the same property historically (thus, lack of individual lot lines historically could indicate a relationship); were designed as an overall composition around a common landscape feature and are reasonably proximate” (Technical Preservation Services, National Park Service, Functionally Related Structures – General Criteria 2007). The Parking Garage meets each of these stated general criteria.

TGHS notes that the City of Glendale, to date, has not considered the Parking Garage a contributor to or a significant part of the historical resource. However, the Home Savings Parking Garage is part of, and contributes to, the significance of the historical resource. This assertion is based on facts (e.g. the date of the Parking Garage construction and as the project architect’s design), reasonable assumption predicated on facts (if the main building is significant under the themes Commercial Development, Post‐World War II Commercial Development, Architecture & Design: Post‐ World War II Modernism (1919-2000), Post‐World War II Commercial Development (1945‐1969), then so is its matching, functionally-related Parking Garage) and expert opinion supported by facts. The evaluation was made by Francesca Smith, who meets the Secretary of the Interior’s Professional Qualification Standards in History and Architectural History and has a substantial design review record. Demolition of the Parking Garage at 620 North Brand Boulevard is expected to cause substantial adverse change to the significance of the National Register-eligible historical resource. Substantial adverse change includes demolition, destruction, relocation, or alteration such that the significance of a historical resource would be impaired (California Public Resources Code Section 5020.1(q)). The Parking Garage was specifically designed to correspond to the design of the main building, which since its completion has relied on the Parking Garage for the retail and office uses. Its low-scale concrete-finished exterior reflects the filleted exterior design of the larger building. Both have cornices, and the Parking Garage exterior even corresponds to the effect of the vertical exterior window arrangement.
3-2
Responses to Comments
Comment Letter No. 3
Lucia Park Project
Sustainable Communities Environmental Assessment
City of Glendale
June 2022
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Public

We note the close correspondence in the Character Defining Features section, Overall Visual Character and Exterior Materials and Craftsmanship between the Home Savings Building and its Parking Garage using the consultant-prepared Historical Resource Technical Report (January 2022, p. 32).

In the table below, review of the Overall Visual Character of the Home Savings Building and the Parking Garage reveals that the Parking Garage shares the main building’s most important characteristics and materials. “Yes” in the tables below means that a concept applies to the Parking Garage as well:

Figure 1: Parking Garage at 620 North Brand Boulevard, view east. Note the simple base, filleted shaft separated by screens and the bracketed, wide upper frieze. The stepped out, framed entry portal on the right-hand side further echoes the Corporate Modern design style of the main building it was constructed to serve. Photograph January 2022.

Overall Visual Character
Home Savings Building Home Savings Building Parking Garage • Proximity to freeway YES
• Setback from west property line that
continues around the office building
Not applicable (NA), but consistent setbacks on east and west sides
• Six story height NA two-story height, executed in proportion • Rectangular form YES
• Vertical orientation YES despite its low height
• Symmetrical composition of each
façade
YES on Maryland side, one of two primary facades
3-3
Responses to Comments
Comment Letter No. 3
Lucia Park Project
Sustainable Communities Environmental Assessment
City of Glendale
June 2022
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Public

The consultant states the garage is not part of the resource because it was built outside the period of significance, which is 1969, the year the Homes Savings Building was completed. Let us leave aside the unjustifiably narrow period of significance that excludes a functionally related and moreover matching structure. The Parking Garage was built in 1970, and was designed Homolka and Associates, who were associated with the construction of the main building, which was designed by Heusel, Homolka and Associates. The senior partner, Francis J. Heusel died in 1968.

The Home Savings Building itself was not completed until 1970. The Inspection Record establishes final inspection completed by a Glendale City Building Inspector bearing the initials “AUR” on March 10, 1970 (Building Permit No. 40497, Inspection Record). It makes even less sense to consider the functionally related Parking Garage that was completed in 1970 not historically significant on the grounds it was completed after the main building, which was completed the same year. The consultant further erred in evaluating the Parking Garage separately, as though it were not an integral part of and moreover a contributor to the larger Home Savings property.

Based on these facts and our evaluation prepared by a qualified architectural historian, the Parking Garage is part of, and contributes to, the significance of the historic resource. Because of the proposed Parking Garage demolition and the setting impacts, the proposed project is expected to cause a significant effect on the environment, which should have been the conclusion by the Lead Agency.

Substantial adverse change in the significance of a historical resource is considered a significant impact on the environment (CEQA Guidelines Section 15064.5(b).). Substantial adverse changes means demolition, destruction, relocation or alteration of the resource or its immediate surround- • Flat roof with parapet YES flat top deck with flat parapet • Wide frieze YES
• Narrow window bays YES narrow openings with screens
• Centrally located entrances NO but symmetrical entrances on Maryland side Exterior Materials and Craftsmanship
Home Savings Building Home Savings Building Parking Garage • Precast exposed concrete aggregate
piers and paving
YES precast exposed concrete piers and vertical fillets Concrete paving is normally poured-in-place
• Metal framed doors and windows NA
• Two-toned window and spandrel glass NA
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ings resulting in the significance of the resource being materially impaired. Significance of a resource materially impaired when the physical characteristics that convey its historical significance and that justify its designation as a historical resource are demolished or materially altered in an adverse manner.

The Lead Agency must prepare an Environmental Impact Report when substantial evidence in the record demonstrates that a project may have a significant effect on the environment.

Compliance with the Secretary of the Interior’s Standards for Rehabilitation TGHS was dismayed to note that the consultant and the Staff reports prepared for the project applied only one of ten of the Secretary of the Interior’s Standards for Rehabilitation (Standards) to the proposed project, which is a serious oversight, a procedural omission and is absolutely necessary for any proposed project that would be built on the property of and abutting other historic resources. The cursory reference in the consultant’s report to Standard 9, with the puzzling equivocation that “the project could be considered ‘related new construction’” (p. 45, emphasis added), as though that were not precisely what a 24-story building would be, is simply not adequate and does not make sense (p. 41).

Nor does the assertion that the Standards “are not directly applicable because they are not the threshold for impacts” (p. 41). The Standards are codified both in the Glendale Municipal Code under definitions (Chapter 15.20 Historic Preservation, Section 15.20.020) as well as in the California Environmental Quality Act (CEQA). Indeed, rehabilitation projects that meet the Standards are generally, but not always considered categorically exempt from CEQA review. The Standards are nationally recognized and used as the best measurement to gauge potential impacts of a project, are always applicable for a project involving a historic resource under CEQA. Whether or not the Standards are the “threshold for impacts” is irrelevant. This project does not meet the Standards because it would result in substantial adverse impacts to a historic resource, not the other way around.

We note that nothing in the Staff Report addresses either historical resources’ setting or the massive changes proposed to those settings.

Absent a local or state definition for setting, it is a term of art specifically defined in National Register guidance as:
the physical environment of a historic property. Whereas location refers to the specific place where a property was built or an event occurred, setting refers to the character of the place in which the property played its historical role. It involves how, not just where, the property is situated and its relationship to surrounding features and open space.

Setting often reflects the basic physical conditions under which a property was built and the functions it was intended to serve. In addition, the way in which a property is positioned in its environment can reflect the designer’s concept of nature and aesthetic preferences.

The physical features that constitute the setting of a historic property can be either natural or manmade, including such elements as…vegetation; simple manmade features (paths or fences); and relationships between buildings and other features or open space. 3-4
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These features and their relationships should be examined not only within the exact boundaries of the property, but also between the property and its surroundings (National Park Service “How to Apply the National Register Criteria for Evaluation” 1990, revised 1995, emphasis added).

The current proposed project would permanently destroy the character of the property, including but not limited to its relationship to surrounding contributing features and its integral internal open space.

While each of the Standards applies to the proposed project, Standards 1, 2, 4, 5, 9 and 10 are particularly germane and, as demonstrated below, would not be met or followed in the proposed project:

1. A property will be used as it was historically or be given a new use that requires minimal change to the distinctive materials, features, spaces, and spatial relationships.

The Home Savings Building and its property include the landscaped surface parking lot and its functionally related, original, and matching Parking Garage (Parking Garage). Elements of the Home Savings Building’s property (Assessor’s Parcel No. 5643-018-032) and its distinctive matching contributing garage would be subject to demolition, which would clearly alter not only the Parking Garage itself, but the spaces between buildings, landscaping, parking lot and spatial relationships associated with the property. Each of those characteristics would be permanently lost by the construction of the out-of-scale new project.

2. The historic character of a property will be retained and preserved. The removal of distinctive materials or alteration of features, spaces, and spatial relationships that characterize a property will be avoided.

Likewise, the currently proposed project would demolish both the extant open space and its original, functionally related, coordinated Parking Garage which clearly cannot be understood as retaining or preserving those contributing and character-defining features.

4. Changes to a property that have acquired historic significance in their own right will be retained and preserved.

Despite the consultant’s suggestions to the contrary, the Parking Garage is an original feature of the Home Savings property. While there is no clear known record of the landscaping in the related parking lot, its current planting plan and arrangements of lawn, foundation planting and trees with low, stepped stacked Roman blocks or bricks should be considered the historic baseline.

5. Distinctive materials, features, finishes, and construction techniques or examples of craftsmanship that characterize a historic property will be preserved.

The Parking Garage’s distinctive features, as well as the concrete exterior features and finishes, including the board-formed concrete mushroom interior columns’ construction techniques, the stack bond concrete masonry unit end walls as well as other examples of that craftsmanship which characterize the Home Savings Parking Garage would be permanently lost. 3-7
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9. New additions, exterior alterations, or related new construction will not destroy historic materials, features, and spatial relationships that characterize the property. The new work will be differentiated from the old and will be compatible with the historic materials, features, size, scale and proportion, and massing to protect the historic integrity of the property and its environment.

The proposed more than 460,000 square-foot (SF) new “addition” would certainly be related new construction. It would demolish, thereby destroying, the historic materials that characterize the property including the landscaped parking lot and the functionally-related Parking Garage.

Figure 2: Parking Garage interior view north. Note the fitted screens in the exterior openings (left) archaic stack bond endwalls (center and right), and square, full height support columns at center and right with yellow bases.

Photograph January 2022.
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10. New additions and adjacent or related new construction will be undertaken in such a manner that if removed in the future, the essential form and integrity of the historic property and its environment would be unimpaired.

The latest design for the proposed nearly half-a million SF “new addition,” which is both adjacent and undeniably related new construction, would require that all of Home Savings integral parking be destroyed. If the more than 460,000 SF addition was removed in the future, the essential form and integrity of the Home Saving Building property and its environment would be more than impaired; they would have more than four-story below-grade pits. The Home Savings Building would have no parking whatsoever, and worse, its related setting including the Parking Garage would be forever lost.

Another important historic resource impact we see has not been addressed is the very real potential for vibration-related damage to both historic properties (including differential settlement) during and in the immediate years following construction. Protection from other construction-related activities, such as equipment and vehicles striking buildings, over-spray of various materials, overexcavation of the soil and pile driving depths and methods will present a serious threat to the historic properties. Without a complete study by a qualified structural engineer who has a demonstrated specialty in the protection of historic buildings before and during construction directed by clear, concise mitigation measures that would ensure structural investigations, pre-construction surveys, continuous vibration monitoring with related stop-work orders that would trigger less vibrationintense equipment or methods, we can only assume that damage may well occur to the historic resources, which would be extremely close to the proposed project, its subterranean garage and whatever types of pilings will be proposed. This concern was voiced by Design Review Board Caro Minas, CE, GE, a geotechnical engineer, in the DRB meeting on January 13.

For these reasons, we believe this project as currently proposed does not comply with even the most basic principles in the Standards for Rehabilitation. This analysis was thoroughly reviewed for adequacy and accuracy by former Board of Directors and former Design Review Board member Francesca Smith, who meets and exceeds the Secretary of the Interior’s Professional Qualification Standards.

Downtown Specific Plan Compliance
The Glendale Downtown Specific Plan (DSP) contains Standards that direct:

B. The bulk of buildings shall be reduced through the articulation of building massing and building facades.

Articulation emphasizes the different visible aspects of the various parts of a building. Sometimes the effect completely obscures the sense of the whole, breaking it down into too many pieces, but in most cases, articulation creates a balance between the two. Articulation can also be expressed in recessed bays, which require giving up small amounts of valuable real estate. The modest articulation in the following figures emphasize the proposed building's nearly indefinable parts (Figure 1).

There are three basic components, the base, equal and repetitive “grid” bay types on the left and right sides and the off-center, top and far left bays proposed as “dark gray spandrel glass.” The 3-13
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only visible proposed enunciation of components, other than the obvious differences in materials, is in the difference in heights at the top floors of the proposed project, see Figures 3, 4, 5 and 6.

We also note that the proposed differences in color on the exterior of a high-rise, which is generally a difficult long-term maintenance choice, does not provide the necessary articulation. The proposed busy color scheme would provide some animation at an unnecessary long-term cost, but not the necessary articulation of massing required. Note that the differences in color are nearly lost at the scale depicted in the figures below.

D. High-rise facades (as defined in Chapter 30.33 of the Zoning Code) shall provide a substantial modulation or change of materials every 150 feet in length.

The material presented does not clearly show 150 foot intervals nor does it provide adequate scale to determine those measurements. Based on our 150 foot estimates used in review of elevations, the proposed design does not comply with the standard for the required substantial modulation in continuous walls or the requisite differences in materials.

Figure 3: Excerpt from East Elevation, page 57.

Note the parsimonious difference in heights on the
left and right three bays. Source: Lucia Park 625
Maryland Ave, Glendale CA Stage II Design Review
by John Freidman Alice Kimm Architects, 2019, not
for publication (Lucia Park).

Figure 4: Excerpt from South Elevation, page 58. Note
the limited heights on the left and right bases (one or two bays). There is no recognition of the Home Savings
Building’s frieze or of its termination in lower middle section of the addition. The Fidelity Savings Building at 600 North Brand Boulevard, a historic resource which is six stories high is not depicted. Source: Lucia Park.
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G. To improve the consistency of scale on the streets, new buildings shall respond to the scale and placement of design features of earlier buildings adjacent to them. Such design features include but are not limited to cornice lines, colonnades, fenestration, and materials.

Review of the full design packet as well as Exhibit 1 and Figures 3, 4 and 5 reveals that that the project, as currently proposed, does not respond to the modest scale of the existing historic resources. The Home Savings Building has, among other character-defining features:
• a prominent cornice line,
• a raised, continuous exterior podium with low open, wide stairs, • deep, full height exterior fins,
• a Parking Garage designed as a miniature interpretation of the main building, and • an existing open parking lot.

Although the proposed design does incorporate some features of the Home Savings Building, there are opportunities to strengthen the connection with additional modifications.

K. Projects built adjacent to historic structures that are smaller in scale shall step down at the street wall to align with the existing cornice.

We see inadequate evidence in the proposed 24-story building design of any such response to the existing, established low-rise scale on the subject property block. To that end, little human scale is expressed in the proposed design.

Because the proposed cornice lines would not align with the historic buildings on either side, the proposed window bay rhythm and fenestration bear no relation to the existing, elegantly modulated Home Savings Building.

The proposed building at 24 stories would not “step down” as described to align with the existing cornices (see Figure 6). A string course or “a horizontal band… in a building forming a part of the design” is not a step, except on three bays at the slim north side which notably faces the freeway (Merriam-Webster.com Dictionary, Merriam-Webster, https://www.merriam-webster.com/dictionary/stringcourse. Accessed 9 Jan. 2022). In the section entitled “Building Design: Massing and Scale,” the Downtown Specific Plan directs in a diagram that “High rise massing should be divided to reduce overall bulk and step graciously down towards lower adjacent structures” (page 4-11).

We see little stepping and no demonstrated evidence of design courtesy or deference toward the existing, low-rise historic resources.
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The project Staff Report asserts “The project effectively utilizes off-set building forms, step-backs, façade modulations and floor plate reductions to lessen the appearance of its mass. The end volumes also step down at their outside corners in order to break down their overall massing, similar to several taller commercial buildings just to the south on the same side of Brand Boulevard (400-550 N. Brand, [Figure 7]).” The project provides the absolute minimum step-backs and doesn’t compare to those in the block to the immediate south.

Figure 6: Annotated excerpt from page 8 of Exhibit 1,
Stage II Final Design Review Packet. Proposed project
string course is highlighted in a dashed red, the historic buildings at 600 and 620 North Brand in green. Note
that the building immediately south of the proposed
project (top right) has stepped volumes at beginning at the base which diminish in size sequentially from the
wide base to the top floors, thus allowing the much
taller, larger building to fit into the existing low-rise context. Source: “high aerial from northwest- looking
south on Brand Blvd” Lucia Park 625 Maryland Ave,
Clendale CA Stage II Design Review by John Freidman
Alice Kimm Architects, 2019, not for publication.
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Additional details of the proposed “step” in the proposed project In Figures 8 and 9, and on pages 53, 56 and 57 of Exhibit 1, Stage II Final Design Review Packet reveal that the step it is no more than a difference in materials, applied at the same depths, embellished by a horizontal band. The proposed step is more window dressing than a demonstrable difference in dimension.

Figure 7: Rendering of 550 N Brand Boulevard, a 21-
story building designed by HOK, Inc. and completed in
1989. It is located on the block immediately south of
the proposed project. Note the five generous major
steps in the design, as well as the different window
rhythms, shapes and sizes of openings, the inverted
entrance and corners that reduce the perceived mass of
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What review of the design packet reveals is that the proposed project steps “away” from the Home Savings Building by fewer than 15 feet, which is less than the length of standard parking spaces (red arrows, Figures 8 and 9). What the proposed project would actually “step back” from are the low-rise buildings on the east side of Maryland Avenue, by 20 feet (just 2 feet longer than a standard parking space).

Is the Proposed Project Eligible for a SCEA?
TGHS cannot determine whether the proposed project is being considered a Transit Priority Project under Senate Bill 375 (SB 375) and that would be the reason the Lead Agency is preparing a SCEA instead of an Environmental Impact Report (EIR). SB 375 provides several CEQA reform provisions, including streamlined review and analysis of residential or mixed-use projects consistent with the Sustainable Communities Strategy (SCS); modified review and analysis, through an expedited SCEA for Transit Priority Projects (TPPs) that are consistent with the SCS; and a complete CEQA exemption for TPPs that are consistent with the SCS and meet a specific list of other requirements. A project does not qualify for the CEQA streamlining exemption if it can be expected to cause impacts to historic resources, as is the case here.

Figure 8: Excerpted annotated section from page 53,
“step” between the proposed 5th and 6th levels is circled in red (East-West Section 1). Home Savings Building is depicted at left. The wider volume below is the 1st-3rd floor base that is approximately 15 feet larger, shown as a red arrow.

Figure 9: Excerpted, annotated section from page
54, “step” between the proposed 5th and 6th levels is
circled in red (East-West Section 2). Note it bears
no relation to the Home Savings Building, which is
depicted at left. The wider volume below is the
1st-3rd floor base that is approximately 15 feet wider, shown as a red arrow.
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Conclusion
We are grateful for the opportunity to comment. We at TGHS are not opposed to new development as the city desperately needs new housing options for its residents. We do believe that the current proposal is detrimental to current historical resources, including but not limited to demolishing the Home Savings garage that was developed and designed as part of the bank building.

Sincerely,
John Schwab-Sims
Vice President, Advocacy
The Glendale Historical Society

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Sustainable Communities Environmental Assessment Responses to Comments June 2022 COMMENT LETTER NO. 3:

The Glendale Historical Society
John Schwab-Sims
Vice President, Advocacy
P.O. Box 4173
Glendale, CA 91202
March 9, 2022
Response to Comment 3-1
This introductory comment states the parking garage is an original component and character-defining feature of the of the Home Savings & Loan property (Chase Building), the proposed Project does not conform to Secretary of the Interior’s Standards for Rehabilitation, is inconsistent with the Downtown Specific Plan requirements, and the preparation of a Sustainable Communities Environmental Assessment (SCEA) may not have been appropriate.

With respect to the existing parking garage, the construction history of the Project site is documented by the building permit record. The permit for the Chase Building was issued on December 11, 1968, and the permit for the parking garage was issued on June 19, 1970. Thus, the parking garage is not an original component of the Chase Building. Copies of these permits are provided in Appendix H to the SCEA, Appendix C to this Responses to Comments, and also provided on the following pages.

The January 2022 Historical Resources Technical Report (Historic Report; Appendix F of the SCEA) recognizes that the Chase Building and parking garage were designed by the same architect. However, no information was found during the preparation of the Historic Report indicating the Project site was master planned with the Chase Building, parking garage, and surface parking lots conceived as a single architectural entity. The parking garage is an ancillary building that it visually consistent with the Chase Building but does not add meaning to the reason the Chase Building was determined to be a historical resource: its role in the developmental history of downtown Glendale.

The commenter alleges the parking garage was ignored in the 2017-18 South Glendale Historic Resource Survey (“Survey”), prepared as part of the South Glendale Community Plan and was ignored in the Historic Report. That is not the case. In both cases, the documents analyzed the historicity of the parking garage and concluded it was not a significant character-defining feature of the Chase Building or an individually eligible historical resource. The survey consultant has submitted a letter to verify this finding that is provided in Appendix I to the SCEA, Appendix D this Responses to Comments, and provided on the following page.
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HISTORIC RESOURCES GROUP 620 N. Brand Blvd., Glendale 1 June 2, 2022
Jay Platt
Senior Urban Designer
Glendale Community Development Department
633 E. Broadway, Rm. 103
Glendale, CA 91206
RE: Home Savings and Loan, 620 N. Brand Blvd.

Dear Mr. Platt:

This letter provides clarification of the methodology applied by HRG in our 2017 South Glendale Historic Resources Survey finding for the former Home Savings and Loan building located at 620 N. Brand Boulevard. We found the building eligible for listing in the Glendale Register under local Criterion 1 as an example of commercial development associated with the post-World War II growth of Glendale, and under local Criterion 3 as a good example of Corporate Modern commercial architecture.

Our finding applies only to the six-story office building constructed in 1969 and does not include the adjacent surface parking lot and parking structure. Although designed and constructed almost concurrently with the tower, the parking lot and parking structure are standard features of late-20th century commercial development, virtually identical to similar features on any number of contemporary properties. They are not essential elements of a distinctive site composition and do not have a formal relationship to the office building or to each other; they are simply ancillary, utilitarian features located as needed on the property.

The parking structure’s exterior has a pattern of vertical fins that were added to mimic the mullions of the bank building but is otherwise a standard, utilitarian parking structure. National Park Service guidance states that a building is not representative of a particular style, and therefore is not eligible for historic designation, if it has some detailing of the style only as a surface application, rather than fully integrated with the overall design. The parking structure’s minimal exterior detailing was clearly applied to resemble 2089 of 2287
HISTORIC RESOURCES GROUP 620 N. Brand Blvd., Glendale 2 the design of the adjacent Corporate Modern office building, but it is otherwise a typical parking structure; the essential features of Corporate Modern architecture are not fully integrated into its overall design.

The parking structure therefore does not possess high artistic value, does not embody the distinctive characteristics of Late Modern architecture, and does not express Home Savings and Loan’s unique use of architecture to identify and build their brand in communities across Southern California in the 1960s. For these reasons we determined that the parking structure and surface parking lot do not contribute to the historic character and significance of the property, and that only the six-story bank building is eligible for designation. If the parking structure were to be demolished, the historic integrity and significance of the bank building would be unimpaired and the property would remain eligible for designation.

Please do not hesitate to contact me if you have any questions or need any additional information.

Sincerely,
Christine Lazzaretto
Managing Partner
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Sustainable Communities Environmental Assessment Responses to Comments June 2022 The Chase Building was found to be significant because it was an office tower built directly adjacent to the then-new 134 Freeway. This served as a signpost to passing motorists not only for Home Savings & Loan but also for the growth of Glendale’s commercial sector, helping to establish today’s downtown skyline. The parking garage is not visible from the freeway and does not contribute to this aspect of the office tower’s significance. Despite the commenter’s claim that the parking garage “matches” the Chase Building, both its design and material palette reflect a much more modest, visually superficial take on the tower’s Corporate Modern/New Formalist design to the point that it was not found to be a significant feature of the site in either the Survey or the Historic Report.

As defined in Preservation Brief No. 17: Identifying the Visual Aspects of Historic Buildings as an Aid to Preserving Their Character, character-defining features are the architectural components that contribute to a building’s sense of time and place. The Brief explains even when buildings are historically rather than architecturally significant, like the Chase Building, it is the tangible elements that embody the associations with specific events that are character defining and it is those tangible elements both on the exterior and interior that should be preserved.43 The parking garage is not a character-defining feature of the Chase Building because it does not convey the historic associations with postwar commercial development. The parking garage has some of the same visual qualities as the Chase Building but none of the historic associations as a high-rise office building oriented toward the freeway. The parking garage is not individually eligible as a historical resource because it does not meet any of the established criteria for significance under national, State, or local historic registers.

As discussed further in Response to Comment 3-5 below, the Secretary of the Interior’s Standards for Rehabilitation (Standards) provide guidance for the analysis of historical resources under CEQA; however, while the Standards are a series of best practices for the rehabilitation of historical resources, the Standards are not identified or recognized in CEQA or the CEQA Guidelines as the thresholds for determining significant impacts on historical resources.

As discussed in Responses to Comments 3-16 through 3-19, below, the proposed Project conforms with all applicable goals, policies, and standards in the Downtown Specific Plan.

As the parking garage does not meet the CEQA definition of a historical resource because it is not listed and has not been determined to be eligible for listing under national, State, or local historic registers, its demolition would not result in a significant impact as stated in the Historic Report and SCEA. Based on 43 Lee H. Nelson, "Preservation Brief #17: Architectural Character: Identifying the Visual Aspects of Historic Buildings as an Aid to Preserving Their Character,” US Department of the Interior, National Park Service, Cultural Resources, 1.
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Sustainable Communities Environmental Assessment Responses to Comments June 2022 this analysis, the proposed Project would not result in a potentially significant impact on historical resources, and therefore the use of a SCEA for the proposed Project is appropriate under CEQA.

As discussed in Section 5.1, Aesthetics, in the SCEA, the available views in the vicinity of the Project site are largely constrained by existing high-rise buildings surrounding the site, including the six-story Chase Building located on the Project site to the northwest and the 21-story commercial office building located to the south of the Project site. Photographs were taken showing the current views of the Project site, Verdugo Mountains, and Griffith Park. Griffith Park is not currently visible from the portion of downtown Glendale where the Project site is located. The Verdugo Mountains are partially obstructed and only clearly visible along Brand Boulevard in the vicinity of the Project site. As there are no currently unobstructed views of the Verdugo Mountains or Griffith Park from the portion of downtown Glendale where the Project site is located, proposed Project development would not result in a substantial effect on any existing scenic vista.44 For these reasons, the SCEA concluded the proposed Project would result in less than significant impacts to available scenic vistas or the visual character of the area.

Response to Comment 3-2
The Glendale Historical Society (TGHS) suggests the parking garage is a character-defining feature of the Chase Building because it is functionally related. “Functionally related” is a National Park Service (NPS) term from guidelines for reviewing applications for federal rehabilitation tax credits. Even though this is not a tax credit project, the term “functionally related” still has meaning in that the garage was built to provide parking for the Chase Building. This relationship, however, does not automatically connote significance. As discussed in Response to Comment 3-1, the functionally-related parking garage does not contribute to the historic significance of the site and is an ancillary feature rather than a character defining feature that contributes to the historical meaning of the Chase Building.

TGHS states their evaluation was conducted by Francesca Smith, who meets the Secretary of the Interior’s Professional Qualification Standards in History and Architectural History. The Historic Report was prepared by Teresa Grimes of Teresa Grimes Historic Preservation, who also meets the Secretary of the Interior’s Professional Qualification Standards in History and Architectural History (see resume in Appendix F to the SCEA45). Jay Platt, the City’s Principal Planner, also meets these qualifications. 44 City of Glendale, Community Development Department. Draft Sustainable Communities Environmental Assessment for the Lucia Park Project. SCH Number 2022010297. Page 5.0-5. Available at:
https://www.glendaleca.gov/home/showpublisheddocument/65609/637781200347330000. Accessed March 2022. 45 Teresa Grimes Historic Preservation. Lucia Park Project, Glendale California, Historical Resources Technical Report. January 2022. Appendix F. Available at:
https://www.glendaleca.gov/home/showpublisheddocument/65601/637781192094970000. Accessed March 2022. 2092 of 2287
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Sustainable Communities Environmental Assessment Responses to Comments June 2022 Under Public Resources Code Section 21155.2, a SCEA is subject to the substantial evidence standard as defined in CEQA Guidelines Section 15384 as follows:
(a) “Substantial evidence” as used in these guidelines mean enough relevant information and reasonable inferences from this information that a fair argument can be made to support a conclusion, even though other conclusions might also be reached. Whether a fair argument can be made that the project may have a significant effect on the environment is to be determined by examining the whole record before the lead agency. Argument, speculation, unsubstantiated opinion or narrative, evidence which is clearly erroneous or inaccurate, or evidence of social or economic impacts which do not contribute to or are not caused by physical impacts on the environment does not constitute substantial evidence.
(b) Substantial evidence shall include facts, reasonable assumptions predicated upon facts, and expert opinion supported by facts.46
The SCEA and the Historic Report, the latter prepared by Teresa Grimes, provided facts, reasonable assumptions based on facts and Ms. Grimes’ opinion supported by facts that the parking garage is not a contributor to, or a significant part of, the Chase Building as a historical resource defined by CEQA. The City can rely on this substantial evidence to support its determination, even if other opinions are offered by others.47 While Ms. Grimes and Francesca Smith can offer their opinions on the parking garage as discussed above and in Responses to Comments 3-1 through 3-21, where TGHS’s and Francesca Smith’s conclusions are not supported by facts or reasonable assumptions predicated upon facts these conclusions are not considered substantial evidence.

TGHS and Francesca Smith indicate their belief that the parking garage is a “contributor to or significant part of the historical resource.” To make this case, they first claim as a “fact” the date of the parking garage’s construction and its design by the architect of the Chase Building. It is a fact that the construction dates of the office tower and the parking garage are not identical (see Response to Comment 3-1). Even if they were, the fact that they were built close in same time and designed by the same person does not unequivocally establish historic significance. TGHS and Francesca Smith next claim significance for the parking garage with a “reasonable assumption predicated on facts” that “if the main building is significant under the theme of Post-World War II Commercial Development (1945-1969), then so too is its matching, functionally-related Parking Garage.” [commenter’s emphasis] This conditional relationship is 46 CEQA Guidelines Section 15384. Available at: https://www.califaep.org/statute_and_guidelines.php. Accessed March 2022. 47 National Parks & Conserv. Ass'n v County of Riverside (1999) 71 CA4th 1341, 1364 (EIR's methodology for analyzing environmental impact must be upheld if supported by substantial evidence in record even though difference of opinion among experts exists).
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Sustainable Communities Environmental Assessment Responses to Comments June 2022 unsubstantiated and is not borne out in historic preservation practice: a functionally-related ancillary building does not ipso facto contribute to the significance of a site’s primary building, especially where, as here, there is no evidence the Chase Building’s historicity will be materially impaired by demolition of the parking garage for the Project.

The commenter continues with the assertion that the expert opinion of Francesca Smith demonstrates that demolition of the parking garage will have a substantial adverse change on the historical resource.

To make this case, the commenter cites Smith’s assertion that the garage was designed to “correspond to the design of the main building,” going on to mention several design similarities. As discussed in Response to Comment 3-1, the parking garage was clearly designed to be visually consistent with the Chase Building – which is a historical resource - but both the design and material palette of the garage reflect a much more modest, visually superficial take on the Chase Building’s Corporate Modern/New Formalist design.

Aside from the presence of vertical fins at two facades and a cornice band that are evocative of the Chase Building, the parking garage is not a “matching” garage. TGHS’s and Francesca Smith’s focus on visual similarities do not provide any facts or reasonable assumptions based on fact that the garage provides the site with any historic significance beyond that found at the Chase Building, and they do not show that demolition of the garage would cause a significant adverse change to that significance or materially impair the ability of the Chase Building to qualify for listing in national, state, or local historic registers.

Response to Comments 3-3
These comments note the similarities of some design features in the Chase Building and the parking garage. However, the comments do not demonstrate what gives these similarities any historic significance. The table the commenter provides contains a factual error: the vertical fins at the garage are not built of precast concrete units (which implies a stronger similarity to the fins at the Chase Building) but are instead formed from stucco on metal lath. The Historic Report acknowledges that the design of the parking garage is visually consistent to the Chase Building; however, the salient point is that the parking garage does not contribute to the significance of the Chase Building. The Chase Building was determined to be significant under Criterion A/1/1 as an important commercial property type that represents the growth of downtown Glendale. The parking garage has some of the same visual qualities as the Chase Building, but none of the historic associations with high-rise construction along the freeway, 2094 of 2287
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Sustainable Communities Environmental Assessment Responses to Comments June 2022 as discussed in the Historic Report (Appendix F to the SCEA) and the SCEA and elaborated in Response to Comment 3-4.48 49
Response to Comment 3-4
The comment addresses the period of significance of 1969, as identified in the Historic Report, alleging it is “unjustifiably narrow”. Single-year periods of significance are not uncommon. 50 The Chase Building was
identified in the Historic Report as significant for its association with the development of Glendale’s commercial downtown. In this case a single-year period of significance is appropriate as it marks the singular moment when the Chase Building was a new commercial tower built adjacent to the then-new freeway, signaling new downtown growth to passersby. Id. This meaning did not change over time and expanding the period of significance to capture the construction of the parking garage, which the Historic Report has determined is not a character-defining feature of the site, would not be appropriate. Even if the parking garage were an exact contemporary of the office tower, its construction during the latter’s period of significance would not automatically render it significant. According to the Los Angeles County Office of the Assessor, the Chase Building was completed in 1969; however, the Certificate of Occupancy was not issued until March 10, 1970.51 Whether the year is 1969 or 1970 is irrelevant. The period of significance is the date the Chase Building was completed. 52 Based on the in-depth analysis in the Historic Report as supported by the 2017-2018 Survey and 2014 South Glendale Historic Context, the parking garage does not meet the CEQA definition of a historical resource as an individual resource, its demolition would not therefore result in a significant impact. Even if the parking garage was a character-defining feature of the Chase Building and the integrity of setting was partially lost by its demolition, the Chase Building would retain the other six aspects of integrity, along with other aspects of its setting, and continue to convey its significance as an example of a postwar commercial property type and, therefore, would continue to be an eligible historical resource. For this 48 Teresa Grimes Historic Preservation. Lucia Park Project, Glendale California, Historical Resources Technical Report. January 2022. Appendix F. Pg. 33. Available at:
https://www.glendaleca.gov/home/showpublisheddocument/65601/637781192094970000. Accessed March 2022. 49 City of Glendale, Community Development Department. Draft Sustainable Communities Environmental Assessment for the Lucia Park Project. SCH Number 2022010297. Page 5.0-55. Available at:
https://www.glendaleca.gov/home/showpublisheddocument/65609/637781200347330000. Accessed March 2022. 50 Page 44 of National Register Bulletin #16A states: “Some periods of significance are as brief as a single year.” “Base the period of significance on specific events directly related to the significance of the property, for example, the date of construction for a building significant for its design or the length of time a mill operated and contributed to local history.” McClelland, Linda, Carol D. Shull, James Charleton, et al. National Register Bulletin #16A: How to Complete the National Register Registration Form. Washington D.C.: U.S. Department of Interior, 1997, page 44. 51 See Appendix C to this Responses to Comments. 52 McClelland, Linda, Carol D. Shull, James Charleton, et al. National Register Bulletin #16A: How to Complete the National Register Registration Form. Washington D.C.: U.S. Department of Interior, 1997, page 44. Page 44 of Bulletin #16A states:
“Some periods of significance are as brief as a single year.”“Base the period of significance on specific events directly related to the significance of the property, for example, the date of construction for a building significant for its design or the length of time a mill operated and contributed to local history.” 2095 of 2287
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Sustainable Communities Environmental Assessment Responses to Comments June 2022 reason, the proposed Project’s change to the setting of the Chase Building would not constitute a significant impact as defined by CEQA and the CEQA Guidelines.

The urban environment surrounding the Chase Building is already characterized by high-rise buildings and the addition of the proposed Project would not result in substantial adverse change to the setting of the Chase Building because its ability to qualify for listing in national, state, and local historic registers would not be materially impaired. As discussed in Response to Comment 3-2, the SCEA and the Historic Report provided facts, reasonable assumptions based on facts and Ms. Grimes’ expert opinion supported by facts that conclude the parking garage is not a character defining feature or significant contributing element of the Chase Building. Furthermore, the SCEA is not an MND subject to the fair argument standard. The City can rely on this substantial evidence to support its determination in the SCEA, like in an EIR, even if other opinions are offered. National Parks & Conserv. Ass'n v County of Riverside (1999) 71 CA4th 1341, 1364 (EIR's methodology for analyzing environmental impact must be upheld if supported by substantial evidence in record even though difference of opinion among experts exists).

Response to Comment 3-5
This comment suggests that the proposed Project must comply with the Standards, which is not the case.

While the Standards provide guidance for the analysis of historical resources under CEQA, the Standards are not identified or recognized in CEQA or the CEQA Guidelines as the thresholds for determining significant impacts on historical resources. Section 15064.5(b) of the CEQA Guidelines states a project would normally have a significant impact on a historical resource if it would result in a substantial adverse change in the significance of the historic resource and whether a project would materially alter in an adverse manner those physical characteristics of the historical resource that convey its significance. The Historic Report utilized this threshold and, thus, correctly applied the thresholds for significant impacts on historical resources as identified in the CEQA Guidelines. The Historic Report concludes the Chase Building would not be materially impaired by the proposed Project because the Chase Building would continue to convey the significance that justifies its eligibility for inclusion in national, state, and local historic registers. The commenter’s conclusion that the Project would result in substantial adverse change to the Chase Building is predicated on the erroneous premise that the thresholds for significant impacts on historical resources are the Standards.

Response to Comment 3-6
This comment asserts the Standards are the best measurement to gauge the potential impacts of a project and are always applicable for a project involving a historical resource under CEQA and the fact that the Standards are not the threshold for impacts is not relevant. The Standards are not directly applicable 2096 of 2287
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Sustainable Communities Environmental Assessment Responses to Comments June 2022 because they are not the threshold for significant impacts to historical resources as defined in the CEQA Guidelines. The threshold is whether the proposed Project would materially alter in an adverse manner those physical characteristics of the historical resource that convey its significance. The analysis in the SCEA and the Historic Report (Appendix F to the SCEA) support the conclusion that the proposed Project would not materially alter the Chase Building in an adverse manner.53,54 The Chase Building would be preserved, and no physical alterations are proposed by the Project.

Response to Comment 3-7
This comment states the Staff Report (it does not refer to the SCEA analysis specifically) does not address the setting of the Chase Building as a historical resource or changes proposed to the setting. It is assumed this comment is referring to the Staff Report for the Historic Preservation Commission hearing on January 20, 2022. It should be noted that this hearing and the Staff Report for this hearing are not directly related to the CEQA analysis.

The historical resource’s setting and the changes proposed to the setting were addressed in the Historic Report and SCEA. The proposed Project would introduce a new visual element to the broad setting of the Chase Building. The SCEA states that the immediate setting of the Chase Building remains intact from the period of significance, but the broad setting has been changed over time since the Chase Building was completed by the development of taller high-rise office buildings on Brand Boulevard.55 The setting immediately surrounding the Chase Building is comprised of grass lawns with minimal landscaping on all four sides that create a buffer between the sidewalk on the west, SR-134 on-ramp on the north, driveway on the east, and surface parking on the south. The broad setting includes the SR-134 to the north. The immediate setting of the Chase Building would not be negatively affected by the Project. It will continue to be a freestanding building surrounded by a landscaped buffer and open space to the south.

The broad setting, however, has changed significantly since 1969, the period of significance for the Chase Building, with many high-rise office buildings constructed in subsequent decades. Although the parking garage and surface parking lots are part of the setting of the Chase Building now they are not characterdefining features of the Chase Building as a historical resource. As discussed in Responses to Comments 3-1 through 3-4, they do not contribute to its significance. The setting of the Chase Building would not be 53 City of Glendale, Community Development Department. Draft Sustainable Communities Environmental Assessment for the Lucia Park Project. SCH Number 2022010297. Page 5.0-56. Available at:
https://www.glendaleca.gov/home/showpublisheddocument/65609/637781200347330000. Accessed March 2022. 54 Teresa Grimes Historic Preservation. Lucia Park Project, Glendale California, Historical Resources Technical Report. January 2022. Appendix F. Pg. 41. Available at:
https://www.glendaleca.gov/home/showpublisheddocument/65601/637781192094970000. Accessed March 2022. 55 City of Glendale, Community Development Department. Draft Sustainable Communities Environmental Assessment for the Lucia Park Project. SCH Number 2022010297. Page 5.0-49. Available at:
https://www.glendaleca.gov/home/showpublisheddocument/65609/637781200347330000. Accessed March 2022. 2097 of 2287
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Sustainable Communities Environmental Assessment Responses to Comments June 2022 diminished by the Project because it is intended be seen and oriented toward Brand Boulevard and SR134 to the west and north. For this reason, the east viewshed is not as character-defining as the west and north viewsheds and there are already high-rise buildings in these other viewsheds.56 In addition, the viewshed from the south will be largely unaltered.

Response to Comment 3-8
This comment discusses Standard 1 and its application to the proposed Project. As discussed in Responses to Comments 3-5 and 3-6, the Standards are not the threshold for significant impacts on historical resources as defined by CEQA. Thus, this comment does not pertain to the analysis of project impacts under CEQA.

Nevertheless, the Project complies with Standard 1 because the Chase Building will continue to be used as an office building and will continue to have the same spatial relationship to Brand Boulevard and the freeway. As no alterations are proposed to the Chase Building, the distinctive materials, features, and spaces will be preserved. As discussed in the SCEA and Historic Report, the parking garage and surface parking lot do not contribute to the significance of the Chase Building as a historical resource and for this reason Standard 1 would not preclude its demolition. The commenter has not shown that the modifications to the site will materially impair the ability of the Chase Building to qualify for national, state, and local historic registers and, therefore, has not established the Project will result in a significant impact on the historical resource.

Response to Comment 3-9
This comment discusses Standard 2 and its application to the proposed Project. Standard 2 is not applicable because no physical alterations to the Chase Building are proposed. As discussed in Responses to Comments 3-5 and 3-6, the Standards are not the threshold for significant impacts on historical resources as defined by CEQA. Thus, this comment does not pertain to the analysis of project impacts under CEQA.

Response to Comment 3-10
This comment discusses Standard 4 and its application to the proposed Project. Standard 4 is not applicable because no physical alterations to the Chase Building are proposed. As discussed in Responses to Comments 3-5 and 3-6, the Standards are not the threshold for significant impacts on historical resources. Thus, this comment does not pertain to the analysis of project impacts under CEQA. The 56 City of Glendale, Community Development Department. Draft Sustainable Communities Environmental Assessment for the Lucia Park Project. SCH Number 2022010297. Page 5.0-56. Available at:
https://www.glendaleca.gov/home/showpublisheddocument/65609/637781200347330000. Accessed March 2022. 2098 of 2287
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Lucia Park Project 45 City of Glendale
Sustainable Communities Environmental Assessment Responses to Comments June 2022 comment also is premised on the erroneous statement that the parking garage is a character-defining feature of the Chase Building, which is not supported by the building permit and occupancy records. As discussed in Responses to Comments 3-1 to 3-6, the parking garage is not a significant historic feature of the site. Instead it is an ancillary building of complementary, though inferior, design and Standard 4 is, therefore, inapplicable.

Response to Comment 3-11
Standard 5 is not applicable because no physical alterations to the Chase Building are proposed. As discussed in Responses to Comments 3-5 and 3-6, the Standards are not the threshold for significant impacts on historical resources. Thus, this comment does not pertain to the analysis of project impacts under CEQA. In addition, this comment mischaracterizes the materials used to build the parking garage.

Its most notable exterior feature, the vertical fins and horizontal cornice, are constructed of stucco on metal lath, not precast concrete as the commenter suggests. The poured-in-place concrete used for the support columns and parking decks display poor workmanship (showing the results of out-of-plumb plywood formwork and poorly-worked joints) that is not in keeping with the higher quality materials and construction techniques still visible at the Chase Building. The stacked-bond concrete masonry units used at the north, south and portions of the west walls of the garage are utilitarian in nature, do not relate to any aspect of the office tower’s design or material palette and are not distinctive features or examples of craftsmanship that characterize the property.

Response to Comment 3-12
This comment discusses Standard 9 and its application to the proposed Project. The Historic Report analyzed the proposed Project for compliance with Standard 9 because it provides guidance on the relationship between new construction and historic buildings. Thus, it is relevant but not determinative in analyzing significant impacts on historical resources as discussed in Responses to Comments 3-5 and 3-

6. However, the Standards are not prescriptive and are intended to manage change to protect the character of historic properties, not to prevent change. As discussed in the SCEA and Historic Report, the parking garage does not contribute to the significance of the Chase Building as a historical resource and for this reason Standard 9 would not preclude its demolition.

Response to Comment 3-13
This comment discusses Standard 10 and its application to the proposed Project. The Historic Report did not apply Standard 10 because the proposed Project does not propose any physical alterations to the Chase Building. Since the parking garage does not contribute to the significance of the Chase Building as a historical resource based on the analysis in the SCEA and Historic Report, its demolition complies with 2099 of 2287
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Sustainable Communities Environmental Assessment Responses to Comments June 2022 Standard 10. As the proposed new construction would be separated from the Chase Building by an existing driveway, the Chase Building would remain unimpaired if the new construction was removed in the future.

Response to Comment 3-14
This comment asserts that the potential for vibration-related damage to historic properties during and in the years immediately following construction have not been addressed. Potential vibration impacts, including potential impacts to the Chase Building, were analyzed in Section 5.13, Noise of the SCEA and the Noise Study (Appendix D of the SCEA). The SCEA identified the potential for vibration levels to exceed the building damage significance threshold of 0.12 PPV for the Chase Building from use of vibratory rollers, large bulldozers, caisson drilling, and loaded trucks. Implementation of Mitigation Measure MM NOI-1 and MM NOI-2 would require the Applicant to retain a vibration monitor to ensure construction-inducted vibration levels do not expose the existing Chase Building to vibration levels of 0.12 ppv in/sec or greater.

A monitoring plan would be required consisting of measures to reduce vibration levels such as, but not limited to, utilizing quiet pile driving technology (auger displacement installation) to reduce friction thus making penetration for a large range of soils less vibration intensive. It is feasible to assume loaded trucks would not be located 15 feet from the Chase Building as they would be located along local streets to haul materials in and out of the Project site. Utilizing pile driving technology, a fairly standard practice now, indicates vibration inducing equipment, such as bulldozers and vibratory rollers would not be utilized, which would ensure avoidance of significant impacts related to vibration at the Chase Building. The monitoring would also ensure that those noise levels would remain below the significance thresholds.

Implementation of these measures would reduce potential vibration impacts to less than significant.57 Operation of the proposed Project would include typical commercial-grade stationary mechanical and electrical equipment, such as air handling units, condenser units, and exhaust fans, which could produce vibration. Ground-borne vibration generated by each of the above-mentioned activities would generate approximately up to 0.005 inches per second PPV adjacent to the Project site.58 As such, vibration levels at other sensitive receptors would result in vibration levels below perceptible levels of human annoyance.59 Therefore, vibration-related impacts were analyzed in the SCEA and Noise Study and were determined to be less than significant with mitigation. 57 City of Glendale, Community Development Department. Draft Sustainable Communities Environmental Assessment for the Lucia Park Project. SCH Number 2022010297. Page 5.0-162. Available at:
https://www.glendaleca.gov/home/showpublisheddocument/65609/637781200347330000. Accessed March 2022. 58 FTA, Transit Noise and Vibration Impact Assessment Manual, September 2018, https://www.transit.dot.gov/sites/fta.dot.gov/files/docs/research-innovation/118131/transit-noise-andvibrationimpact-assessment-manual-fta-report-no-0123_0.pdf, Accessed January 2020. 59 City of Glendale, Community Development Department. Draft Sustainable Communities Environmental Assessment for the Lucia Park Project. SCH Number 2022010297. Page 5.0-164. Available at:
https://www.glendaleca.gov/home/showpublisheddocument/65609/637781200347330000. Accessed March 2022. 2100 of 2287
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Lucia Park Project 47 City of Glendale
Sustainable Communities Environmental Assessment Responses to Comments June 2022 Response to Comment 3-15
This comment claims the proposed Project does not comply with the Standards based on the analysis reviewed by Francesca Smith. As discussed in Responses to Comments 3-5 through 3-13, the Standards are not the threshold for determining significant impacts on historical resources under CEQA. Thus, this comment does not pertain to the analysis of project impacts under CEQA.

As discussed in Response to Comment 3-2, the SCEA and the Historic Report provided facts, reasonable assumptions based on facts and TGHP’s expert opinion supported by facts, that conclude the parking garage is not a character defining feature or a significant part of the Chase Building as a historical resource defined by CEQA. TGHS and Francesca Smith have provided their own opinions on the parking garage.

However, as discussed above and in Responses to Comments 3-1 through 3-21, TGHS and Francesca Smith’s conclusions are not supported by facts and reasonable assumptions predicated upon facts that constitute substantial evidence as defined by CEQA, and even if there is a difference of opinion, the City’s conclusion will be upheld if supported by substantial evidence. (See Response to Comment 3-4.) National Parks & Conserv. Ass'n v County of Riverside (1999) 71 CA4th 1341, 1364 (EIR's methodology for analyzing environmental impact must be upheld if supported by substantial evidence in record even though difference of opinion among experts exists).

Response to Comment 3-16
This comment asserts the proposed building does not conform to the Downtown Specific Plan (DSP) Standard B, which calls for the bulk of buildings to be reduced through the articulation of building massing and building facades. The three-story podium of the proposed building will be set back approximately 32 feet from the rear façade of 625 N. Brand and the upper residential floors, beginning at the fourth floor, will be set back by approximately 47.5 feet. In addition, the decorative screen of the Brand façade entry is setback approximately 20 feet and the podium is approximately 34 feet from the rear façade of 600 N.

Brand, and approximately 80 feet above the fourth floor.

Expert review of City staff and the Design Review Board found the Project would meet the DSP Standards.

The three-part breakdown of the building form – podium base, repetitive residential floors, and dramatic roof trellises signaling the building’s termination – are reflective of how Classical forms influenced early high-rise construction with a base-shaft-capital configuration and adds to the visual character of the building. This three-part design establishes an appropriate base, with closely spaced vertical fins, and termination at the roof, with more widely spaced vertical columns that support the high trellis garages.

The subtle echo between these elements, which share similar heights but produce strikingly different effects, provides interest in the design. The interplay of the “gridded” walls, with an interweaving of horizontal and vertical elements, with the sections with curtain-wall cladding, which are more monolithic 2101 of 2287
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Lucia Park Project 48 City of Glendale
Sustainable Communities Environmental Assessment Responses to Comments June 2022 in appearance, provides scalar shifts that ultimately produce a harmonious, yet complex, façade patterning that would distinguish the proposed building from the surrounding buildings. Despite TGHS’s design opinions to the contrary, the Project’s design has been determined by the City to be consistent with DSP Standard B.

Response to Comment 3-17
This comment discusses DSP Standard D, which calls for substantial modulation or change of materials every 150 feet in length for high-rise facades and claims the proposed building design does not comply with the standard. The tower features offset volumes that are each less than 150 feet in length, connected at the vertical circulation core, creating a zigzagged floorplate between the north and south half of each floor. This is best seen in the floor plans for levels 5 – 24 and in the aerial perspective drawings (not readily apparent in the building elevation plans). The proposed Project complies with this standard because the modulation occurs at the 60-foot-high podium level, after which the tower steps back 20 feet. After the 19th floor, which is 137’ from the podium (197 feet in total height), the floorplan is constricted/narrowed on the north and south ends, thereby reducing the size of the floorplate by the required 15%. This narrowing of the building form as the garage rises helps to reduce the overall massing of the project, which is consistent with Section C of the DSP. The approximately 250-foot-long west and east elevations feature the required change in material and modulation, which is enhanced by the offset of the volume of the tower that create a zigzagged floorplate between the north and south half of each floor, which connect at the vertical circulation core.

The massing of the proposed building is divided into three basic volumes, both vertically and horizontally.

Vertically, the project features a classic tripartite division: base, middle and top. Composed of the lobby and the two commercial parking levels, the three-story podium, which extends the entire length of the project site from north to south, is the rectangular base. Above this, Levels 4 – 22 act as the middle, while the tall, open-air rooftop terraces (“loggias”) and photovoltaic panels serve as the crowning top to the garage. The tripartite divisions are somewhat less pronounced horizontally: the west and east elevations feature two, expansive, grid-patterned sections, composed of vision glass and blue and white metal panels set within white frames, that are set off from a completely different central volume - a swath of vision glass and gray metal panels that are color-matched to read as one uniform center. This same gray-on-gray treatment is used at levels 4 and 5 to differentiate the base podium from the shaft of the main middle above. For these reasons, the proposed building the City determined the Project conforms to DSP Standard D.

Response to Comment 3-18
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Lucia Park Project 49 City of Glendale
Sustainable Communities Environmental Assessment Responses to Comments June 2022 This comment states the proposed Project does not respond to the more modest scale of the existing historical resource or Standard G of the DSP, but admits the Project does incorporate some features to address the relationship between the buildings. This subsection, requiring that new buildings respond to the scale and placement of design features of earlier buildings adjacent to them in order to improve the consistency of scale on the street, is specifically intended for when buildings are directly adjacent to one another. In that case, a street wall is formed and the concept of reflecting existing patterns, such as ground-floor heights, window patterns, colonnades, and material palettes, at an infill façade becomes important. The project block does not have any consistent pattern or even street front setback. With the new building set back over 140 feet from the street front property line, design consistency along the street wall is not an issue.

Response to Comment 3-19
This comment states the proposed building would not conform to DSP Standard K as it would not “step down” to align with the existing cornices. Subsection K, calling for taller buildings to step down to meet the height of lower adjacent buildings at the street wall, does not apply to the Project for reasons similar to those discussed in Subsection G above. The intent of this section is to guide designs of buildings that share a street wall with existing buildings. This is not the case at the subject property and no stepping of the building mass or alignment of adjoining cornices is required.

This comment also states that the proposed building and the Chase Building would be fewer than 15 feet apart and uses excerpted and annotated plans in an attempt to illustrate its point. In fact, at the ground level, the proposed building would be physically separated from the Chase Building by approximately 32 feet, not 15. The massing of the proposed building steps away from the east façade of the historic building beginning at the fourth and fifth stories to increase the physical separation from the historical resource by another 17 feet. By comparison, the typical width of a residential street with two-way traffic and parking is 40 to 50 feet. Thus, the difference in size and scale is diminished by the distance between the two buildings by 47 feet above the fourth story.

Response to Comment 3-20
This comment incorrectly states that the proposed Project does not qualify for review through the preparation of a SCEA because it is expected to cause impacts to historical resources. As discussed in Responses to Comment 3-1 through 3-21, the SCEA, and the Historic Report, the proposed Project would not cause a significant impact to the Chase Building as a historical resource as defined by CEQA and the parking garage is not a character defining feature of the Chase Building as a historical resource. Therefore, the proposed Project will not cause impacts to historical resources and review through the preparation of a SCEA is consistent with CEQA.
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Lucia Park Project 50 City of Glendale
Sustainable Communities Environmental Assessment Responses to Comments June 2022 Response to Comment 3-21
This comment emphasizes that the proposed Project is detrimental to current historical resources, including the parking garage. As discussed in Response to Comment 3-20, Responses to Comments 3-1 through 3-21, the SCEA, and the Historic Report the proposed Project would not cause a significant impact to the Chase Building as a historical resource as defined by CEQA and the parking garage is not a character defining feature of the Chase Building as a historical resource. For these reasons, the proposed Project is not detrimental to current historical resources.
2104 of 2287

FRANCESCA SMITH
March 10, 2022
Ms. Vilia Zemaitaitis
Community Development Department, Planning Division Office 633 East Broadway, Room 103,
Glendale, CA 91206
Sent via e-mail
RE: Comments on Draft Sustainable Communities Environmental Assessment for the Lucia Park Project
Dear Vilia,
Thank you for the opportunity to comment again on this important project. The Glendale Historical Society (TGHS) previously submitted comments regarding the proposed project to the Design Review Board (DRB) and Historic Preservation Commission (DRB), as well as to City Council for a previous design. The remarks in this letter are consistent with those comments but include specific responses to the Sustainable Communities Environmental Assessment (SCEA) which was only made publicly available one day prior to the January 22, 2022 HPC meeting.

Previous letters from TGHS and its members regarding this project contain comments on the proposed project, most of which still apply to the SCEA. Those are: TGHS letter to City Council, January 20, 2021 (Attachment 2), Francesca Smith letter to City Council, January 21, 2021 (Attachment 3), TGHS letter to DRB (January 13, 2022, incorporated herein by reference) and my letter to HPC January 19, 2022 (Attachment 4). Please carefully consider the comments in those letters as they apply to the project Sustainable Communities Environmental Assessment (SCEA) as applicable.

As a qualified Architectural Historian under the Secretary of the Interior’s Professional Qualifications Standards (36 Code of Federal Regulations Part 61) and Principal Architectural Historian Professionally Qualified Staff for the State of California, I reviewed the SCEA prepared for the proposed project referenced above and have the following comments. Principal issues that TGHS and I have previously raised, and the Lead Agency has not appropriately addressed are:
 Not considering the Home Savings of America property (620 North Brand Boulevard or subject property) Parking Garage to be a contributing resource to that California Environmental Quality Act (CEQA)-defined “historical resource;”
 The improper use of an SCEA for environmental clearance when historic resource impacts expected to be caused by the proposed project have not properly addressed or analyzed, without adequate mitigation measures proposed that would reduce or avoid those impacts.

Home Savings & Loan Property Parking Garage and Setting The historic significance of the Home Savings & Loan property Parking Garage has been both asserted and proven by TGHS but has been repeatedly repudiated by City staff and denied by the project historic consultant. TGHS’s and my position that the Parking Garage is a contributing resource to the historical resource was confirmed by Jay Correia, California Office of Historic Preservation staff in an e-mail message on February 8, 2022. The message to which he responded had the City’s evaluation of the property prepared in 2017 as well as my updated evaluation for TGHS dated January 10, 2022 appended for his review. In my e-mail, I asked him whether the property at 620 North Brand Boulevard should be nominated for listing in the California Register with its Parking Garage. 4-1
4-2
4-3
Responses to Comments
Comment Letter No. 4
Lucia Park Project
Sustainable Communities Environmental Assessment
City of Glendale
March 2022
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Comments on Draft SCEA for the Lucia Park Project
May 10, 2022
2 His response was unambiguous:

By definition, this [620 North Brand Boulevard] is a single property with two contributing resources. For National Register and California Register purposes there is no question in this regard.

According to National Register Bulletin 16A (Page 16), “A contributing building, site, structure… adds to the historic associations…for which a property is significant because: it was present during the period of significance, relates to the documented significance of the property, and possesses historic integrity or is capable of yielding important information about the period” (use of the automobile and growth of automobile culture southern California, for example).

Under “Rules for Counting Resources” on Page 17 of Bulletin 16A, the first rule states: “Count all buildings, structures, sites, and objects located within the property's boundaries that are substantial in size and scale…”
So, as we can see, the parking garage cannot be ignored or dismissed. We would require that it be included in any nomination or evaluation for environmental review (emphasis added, e-mail message from staff Supervisor of the Cultural Resources Programs Registration and Project Review Units at the California Office of Historic Preservation to Francesca Smith, February 8, 2022, see Attachment 1).

Based on this impartial opinion and direction provided by Mr. Correia, California Office of Historic Preservation staff in charge of the Registration Unit, the Parking Garage must be considered a contributing resource for the purposes of this project environmental review and any others.

The project “Historic Resources Technical Report” (Historic Report, SCEA Appendix F), prepared by a consultant in January 2022, provided an intensive level survey and found that the “Chase Building” appeared eligible for listing in the National Register of Historic Places, California Register of Historical Resources and the Glendale Register of Historic Resources without the Parking Garage. That conclusion is inaccurate: the 620 North Brand Boulevard property, in total, including its concurrently designed and built Parking Garage must be considered the historic resource, not merely the main building.

Based on the professional opinion of California Office of Historic Preservation staff, as well as other expert opinion was previously provided to the lead Agency by independent qualified Architectural Historians who corroborated the Parking Garage’s significance, including Sonnier Francisco and Daniel Paul (January 19 and 20, 2022 respectively, Attachment 5), the entire property at 620 North Brand Boulevard with the Parking Garage is eligible for California Register designation. There is no defensible or demonstrable reason that registration requirements for the Glendale Register of Historic Resources would exclude the Parking Garage or somehow be interpreted to be more rigorous in its requisites that state or federal registration requirements. The Lead Agency must treat the historic resource as significant based on the information previously provided and the information provided in this letter. The preponderance of evidence demonstrates that the Lead Agency and their consultants previously made clear errors by not considering the Parking Garage a contributing resource of the Home savings property.

Impact Analysis
The SCEA states that “A transit priority project may be approved if it has been determined that the project will not result in significant and unavoidable environmental impacts” on page 1.0-3. The project, as currently proposed would cause both “significant” and “unavoidable” environmental impacts to a historic resource, Home Savings & Loan property located at 620 North Brand Boulevard including its Parking Garage which contributes to its historic significance.
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3 Because the historic resources identification process was prepared in error, the historic resources Impact Analysis presented in the SCEA must be set aside and re-analyzed based on new information, the fact that the Parking Garage is a contributing resource to the subject property historic resource based the information provided in this letter, Attachment 1 and the referenced and appended previous letters.

As proposed, the Project would have cause direct impacts on historical resources: both the Parking Garage and the immediate setting at 620 North Brand Boulevard would be demolished, destroyed and altered for the project. “Substantial adverse change” is of course, defined as “Physical demolition, destruction, relocation or alteration of the resource or its immediate surroundings such that the significance of an historical resource would be materially impaired” (PRC Section 5020.1(q)). The proposed demolition of the contributing Parking Garage would clearly qualify as substantial adverse change. The CEQA Guidelines provide that a project that demolishes or alters those physical characteristics of an historical resource that convey its historical significance (e.g. its character-defining features) can be considered to materially impair the significance of the resource.

Historic significance is “materially impaired” when a project “demolishes or materially alters in an adverse manner those physical characteristics of an historical resource that convey its historical significance” and that justify its inclusion in the California Register, local register or historic resource survey.” The significance of the subject property, its ability to impart its full history would be materially impaired by the demolition of the corresponding 1970 Parking Garage on which its continued use has been dependent for more than half a century.

CEQA further contains a substantive mandate: “it is the policy of the state that public agencies should not approve projects as proposed if there are feasible alternatives or feasible mitigation measures available which would substantially lessen the significant environmental effects of such projects…” (PRC Section 21002). No such mitigation measures are proposed that would reduce the expected effects in built environment historical resources.

In this letter and its numerous attachments, the Lead Agency has been provided with a fair argument, which is the legal standard for determining the significance of impacts. The fair argument is that substantial adverse change in physical conditions would occur by implementation of the proposed project.

This fair argument is backed by substantial evidence that the Parking Garage is a contributing resource to the Home Saving property and that its demolition would cause substantial adverse change in the significance of the historic resource. It includes facts, reasonable assumption predicated upon facts, and expert opinions supported by facts.

Because the SCEA for this project is based on findings made in error, and because it is expected to cause significant adverse change in the significance of historic resources, the proposed project does not qualify for the CEQA streamlining exemption and additional environmental clearance documents must prepared to appropriately analyze, and hopefully fully mitigate those historical resources impacts.

CEQA Statute Section 21084.1 states that “A project that may cause a substantial adverse change in the significance of an historical resource is a project that may have a significant effect on the environment.” Because the proposed project would cause a change in the significance of the subject property historic resource, I remind the Lead Agency that the proposed project does not qualify for the CEQA streamlining exemption. It is expected to cause impacts to historic resources, as is the case for this project and demonstrated in this comment letter.

Conclusion
I am grateful for the opportunity to comment and participate in review of this project. The subject property parcel may be able accommodate a redesigned, far smaller project that would be more deferential in its design, detailing, height and size to the Home Savings Building including its Parking Garage, setting and the Fidelity Savings Building. In addition, a qualified Historic Preservation Architect should be a collaborative and meaningful part of the team designing any future iterations of this project to 4-5
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4 ensure conformance with the Standards for Rehabilitation. Please ensure that this letter with all its attachments is included in the administrative record for this project.

Very truly yours,
Francesca Smith
Francesca Smith
Architectural Historian
cc: Aram Adjemian, City Clerk
Roubik Golanian, City Manager

Attachments (5)
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From: Correia, Jay@Parks
To: Smith, Francesca@DOT
Subject: RE: Home Savings & Loan: 620 N. Brand Bl., Glendale, CA Date: Tuesday, 8 February, 2022 5:11:23 PM
EXTERNAL EMAIL. Links/attachments may not be safe.

Dear Francesca,
Thank you for the inquiry. The description on the primary record form begins by stating that the resource, or “subject property” (my italics) is a six story midrise office building with (again, my italics) a separate two story parking garage.” By definition, this is a single property with two contributing resources. For National Register and California Register purposes there is no question in this regard.

According to National Register Bulletin 16A (Page 16), “A contributing building, site, structure…adds to the historic associations…for which a property is significant because: it was present during the period
of significance, relates to the documented significance of the property, and possesses historic integrity or is capable of yielding important information about the period” (use of the automobile and growth of automobile culture southern California, for example).

Under “Rules for Counting Resources” on Page 17 of Bulletin 16A, the first rule states: “Count all buildings, structures, sites, and objects located within the property's boundaries that are substantial in size and scale…” So, as we can see, the parking garage cannot be ignored or dismissed. We would require that it be included in any nomination or evaluation for environmental review.

I hope that this helps with your project to nominate the Home Savings and Loan Building.

It is very nice hearing from you.

Sincerely,
Jay
Jay Correia
Supervisor, Cultural Resources Programs
Registration and Project Review Units
California Office of Historic Preservation
(916) 445-7008
From: Smith, Francesca@DOT <[email protected]> Sent: Monday, February 7, 2022 11:41 AM
To: Correia, Jay@Parks <[email protected]>
Cc: Francesca Smith <[email protected]>
Subject: Home Savings & Loan: 620 N. Brand Bl., Glendale, CA ATTACHMENT 1
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Dear Mr. Correia:

I hope you are staying safe. All is well here.

The Glendale Historical Society is considering nominating our local Home Savings & Loan property to the California Register. The property was found in a recent reconnaissance survey to be locally eligible, but the preparers did not notice the functionally related Parking Garage that was completed the same year as the building.

Attached to this message is the City’s evaluation (“Brand Blvd, 620 N.pdf”) which was prepared in 2017.

The update that I recently prepared is also attached for your review (“620 N Brand DPR Update.pdf).

Because we are considering the property’s nomination to the California Register, our real question is whether it should be nominated, as we assume, with the Parking Garage. We know that additional high resolution photographs and other materials would be required as well.

I cc-ed my personal e-mail.

Thanks, in advance for taking a look at this. I look forward to hearing from you.

Sincerely,
Francesca Smith
PQS Principal Architectural Historian
Caltrans District 7
100 S. Main St., MS 16A
Los Angeles, CA 90012
New cell 213-266-3790
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State of California ‐‐ The Resources Agency

DEPARTMENT OF PARKS AND RECREATION

PRIMARY RECORD
Primary #
HRI #
Trinomial
NRHP Status Code   5S3
Other Listings

P1. Other Identifier
*a. County Los Angeles
*P2. Location: Not for Publication       Unrestricted
and (P2c, P2e, and P2b or P2d.     Attach a Location Map as Necessary.) *b USGS 7.5' Quad Burbank Date 2018 T 1N ; R 13W ; of of Sec B. M. c. Address 620 N Brand Blvd City Glendale Zip 91203
d. UTM: , Zone mE/ mN e. Other Locational Data: APN: 5643018032 *P3a. Description
Character‐defining Features
■ Five‐story height
Alterations
ATMs added; awnings added
Integrity
The property retains integrity of location,
design, setting, materials, workmanship,
feeling, and association.
■ Rectangular plan, simple massing, symmetrical composition, vertical emphasis ■
■
Flat roof with parapet
■
Fixed, metal framed, vertical strip windows and spandrels between continuous precast concrete piers ■
Entrances sheltered by cantilevered rectangular canopies and accessed by wide, shallow concrete steps ■
Two pairs of fully glazed metal doors
■
Fixed, metal framed, vertical strip windows and spandrels Wide frieze around top of building
P5a. Photograph or Drawing (Photograph required for buildings, structure, and objects.) *P3b. Resource Attributes:

HP7. 3+ story commercial building
*P4. Resources Present ■ Building
*P5b. Description of Photo
View Northeast, 2017
*P6. Date Constructed/Age and Source
1969, LA County Tax Assessor
*P7. Owner and Address
*P8. Recorded by:

Historic Resources Group
12 S Fair Oaks Ave, Suite 200
Pasadena, CA 91105
*P9. Date Recorded 2017
*P10. Survey Type Intensive
*P11. Report Citation: Historic Resources Group, City of Glendale South Glendale Historic Context Statement,  September 30, 2014. *Attachments: ■Building, Structure, and Object Record
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BUILDING, STRUCTURE, AND OBJECT RECORD
Primary #
HRI #
State of California ‐‐ The Resources Agency

DEPARTMENT OF PARKS AND RECREATION

*Resource Name or #: 620 N Brand Blvd
B1. Historic Name:Home Savings and Loan B2. Common Name: Chase Bank B3. Original Use: Commercial B4. Present Use: Commercial *B5. Architectural Style: Corporate Modern
*B6. Construction History: No permits available.Owner History:

Address not listed in available city directories.
*B7. Moved No Date: Original Location: *B8. Related Features B9a. Architect: Heusel, Homolka and Associates b. Builder:

B10. Significance: Commercial Development (1919‐2000)  : Post‐World War II Commercial Development (1945‐1969); Architecture and Design: Post‐World War II Modernism: Corporate Modern
Area South Glendale
Period of Significance: 1969 Property Type: Commercial Applicable Criteria: 1; 3 This property was evaluated during the 2017 South Glendale historic resources survey. It is eligible for listing in the Glendale Register under local Criterion 1 as an example of post‐World War II commercial development and under local Criterion 3 as a good example of Corporate Modern commercial architecture by architectural firm Heusel, Homolka and Associates. This property retains character‐defining features of its original design, including its five‐story height, flat roof with parapet, and vertical strips of fixed metal frame windows and spandrels between continuous precast concrete piers.

Like all Southern California cities, the end of World War II meant a population surge for Glendale as returning GI’s married, started families and came in search of the California lifestyle. Postwar prosperity also drove demand for consumer goods with a ripple effect on retail sales of everything from automobiles to home goods. As a result, existing commercially‐zoned parcels were quickly developed after the war. New postwar low‐rise commercial buildings began to populate the established commercial corridors of Pacific Avenue and Central Avenue, then gradually expanded southward to streets such as Colorado Street and Chevy Chase Drive. Transportation advancements, including significant development of the freeway system in and around Glendale, along with the further development of Route 66 as an important tourist attraction, also influenced commercial growth in South Glendale in the postwar era.

The city’s second oldest commercial high‐rise building was erected by Home Savings and Loan (1969, Huesel, Holmoka and Associates) at 620 N. Brand Boulevard. Home Savings Towers reflect the company’s use of architecture to build their brand in communities across Southern California. These structures were typically high‐rise buildings, visible from freeways and did not have the characteristic Millard Sheets artwork of the branches. In addition to Glendale, Home Savings Towers were located in Pomona, Covina, and Long Beach (1979, Frank Homolka and Associates, AIA). Each tower expressively used concrete to emphasize strength and permanence, with space at the top for the brand name and usually a place for the Home Savings Shield on the side of the building. Home Savings and Loan Building in operation at this address by 1970.

Long Beach‐based Heusel, Homolka and Associates consisted of Frank Homolka, AIA (1922‐2008) and Francis J. Heusel (1906‐1968). The firm was the precursor to what became Frank Homolka and Associates after Heusel’s passing. The firm’s focus areas included banking and financial services, schools, offices and warehouses. Homolka was the architect for the towers for Home Savings and Loan. In 1969, the firm received an award fro the Southern California Ready Mixed Concrete Association for the “creative use of concrete.”
B11. Additional Resource Attributes:
*B12. References
Historic Resources Group, City of Glendale South Glendale Historic Context Statement,  September 30, 2014.

City of Glendale Building Permits.

Glendale City Directories.

Sanborn Fire Insurance Maps.

B13. Remarks:
*B14. Evaluator: Christine Lazzaretto; Robby Aranguren
*Date of Evaluation: December 2017
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State of California  The Resources Agency Primary # UPDATE DEPARTMENT OF PARKS AND RECREATION HRI #
PRIMARY RECORD Trinomial
NRHP Status Code 5S3
Other Listings South Glendale Survey
Review Code 5S3 Reviewer HRG for City of Glendale Date 2017

P1. Other Identifier: 620 N. Brand Bl. Building and Parking Garage *P2. . Location:  Not for Publication Unrestricted *a. County: Los Angeles and (P2b and P2c or P2d. Attach a Location Map as necessary.) *b. USGS 7.5' Quad: Burbank Date: 1966, revised 1994
c. Address: 620 N. Brand Bl. City: Glendale Zip: 91203
d. UTM: Zone: ; mE/ mN (G.P.S.)
e. Other Locational Data: Assessor’s Parcel Number 5643-018-032 *P3a. Description: (Describe resource and its major elements. Include design, materials, condition, alterations, size, setting, and boundaries.) The subject property is a six-story, midrise office building (Building) with a separate two-story parking garage (Parking Garage).

The buildings are located on an irregularly, C-shaped parcel, which occupies about half a city block. The reinforced concrete, main building is configured in a rectangle, is three bays wide on each side and has a flat, parapeted roof. The main features are continuous, deep fillets which form vertical window bays that span the full height of the Building and creates the appearance of incalculable height. A wide frieze wraps around the top. The Building is Corporate Modern in style, characterized by its boxshaped volume, the visible concrete and glass materials, flat roof, lack of applied ornament, deep vertical concrete fillets, articulated ground story, integral surface parking lot, landscaped plaza and plantings at pedestrian level (HRG 2017). The Building has a simple base, “Mo-sai” exposed concrete aggregate panels that compose the articulated shaft’s deep fillets, with long narrow windows and a stylized, continuous capital. The very slightly raised, three-sided base is comprised of two tone aggregate concrete slabs, accessed by wide, slab treads with no risers, which was typical of the style. The shaft has vertically grouped, deeply inset windows separated at each floor by dark integrally colored, Alucobond spandrel panels. Deep, quarter radius sills at the ground and top floors visually connect the otherwise vertical composition with the ground and sign band. The concrete exterior has been partially overpainted (date unknown). The ground floor and sign band are each 1.5 stories in height which impart simple, understated formality and establish the distinct building scale. First floor set-in, full height windows are butted glass, which enhances the simplicity of the design. All windows are tinted. The central bay axes of the north and south facades are notably finished in book-matched Carrera marble with incised ghost signs. That set-in marble bay was a character-defining feature of Home Savings building program, and was intended to imply luxury and permanence, as befitting a financial institution. (See Continuation Sheet, page 3)
*P3b. Resource Attributes: (list attributes and codes) HP7. 3+story commercial building *P4. Resources Present: Building Structure Object Site District Element of District Other P5b. Photo: (view and date)
View northeast 2019.

Age and Sources: historic
Building - 1970 (Inspection Record).

Parking Garage-1970.
*P7. Owner and Address:
unknown
*P8. Recorded by:

Francesca Smith for TGHS
PO Box 4173
Glendale CA 91202
*P9. Date Recorded:

January 10, 2022
*P10. Survey Type: (Describe)
Intensive
*P11. Report Citation: (Cite survey
report and other sources, or enter
"none.")
Updated Evaluation of 620 N. Brand Bl., The Glendale Historical Society, 2022. *Attachments: None Location Map Sketch Map Continuation Sheet Building, Structure, and Object Record Archaeological Record District Record Linear Feature Record Milling Station Record Rock Art Record Artifact Record Photograph Record Other (list)
DPR 523A (1/95) *Required information
P5a. Photo or Drawing (Photo required for buildings, structures, and objects.) 4-15
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State of California  The Resources Agency Primary # UPDATE DEPARTMENT OF PARKS AND RECREATION HRI#

BUILDING, STRUCTURE, AND OBJECT RECORD

*Resource Name or # Home Savings of America Building and Parking Garage B1. Historic name: Home Savings of America Building and Parking Garage B2. Common name: Washington Mutual (1998-2001), Chase Bank and Coldwell Banker Building (2001-present) B3. Original Use: retail and office B4. Present use: retail and office *B5. Architectural Style: Corporate Modern (Neo Formalist) *B6. Construction History: (Construction date, alterations, and date of alterations) Building, Parking Grage completed 1970 (Building Permit #42816 and Inspection Record). Alterations: entrance doors on east side with security doors and armed panic hardware at west entrance (1977); monument sign (1987); “auto teller” (1988, Homolka); ATM (1990, with removal and replacement of ground floor windows, replaced 1998); light post to match existing (1993); seismic repair (1994); new signs (1999, Chase Bank 2000, Coldwell Banker 2001, aluminum ATM awning and various other signs 2012); ADA modifications and signs (2014). Parking garage completed 1970 (letters to abutting property owner from City and architect 1970). Alterations: carport added (1995). All sources: City of Glendale building permits unless otherwise noted. *B7. Moved? No Yes Unknown Date: Original Location:
*B8. Related Features: 2-story parking garage (see Continuation Sheet 3).

B9a. Architect: Building- Heusel, Holmolka and Associates, Parking Garage-Holmolka and Associates b. Builder: Home Savings & Loan
*B10. Significance: Theme: Commercial Development, Post‐World War II Commercial Development, Architecture & Design: Post‐ World War II Modernism (1919-2000) Area: Glendale Period of Significance: 1970-1998 Property Type: Commercial Mid-Rise and Parking Garage Applicable Criteria: C
The Home Savings of America Building at 602 North Bland Boulevard was designed by Long Beach-based architects Heusel, Holmolka and Associates and was completed in 1970. The main building was one of a quartet of mid-rise towers built for Home Savings of America. The others were in Pomona (Millard Sheets, 1963), Covina (Heusel, Holmolka et al. 1969) and Long Beach (Frank Homolka and Assoc., 1982). The original building permit valued the subject property tower at $950,000 (December 11, 1968). Following Heusel’s death in 1968, the successor firm, Holmolka and Associates designed the Parking Garage which also completed in 1970. With the Parking Garage, the complex was estimated shortly after its completion to be worth $1.3 mm (Snyder 1971).

The subject property Home Savings Main Building and Parking Garage complex were built nearly a decade after Millard Sheets departed from his role establishing the exceptional modern design program for the growing regional financial institution. Sheets was an artist and designer who became their corporate architect beginning in 1946. He was responsible establishing the distinctive Home Savings Style, which was interpreted by Alan Hess as blending “old, new Modern and Traditional” which clearly describes this property (Arenson 2018). Mr. Sheets abruptly resigned in 1963 while the Pomona tower was under construction (ibid). (See Continuation Sheet 3)
B11. Additional Resource Attributes: (List attributes and codes) *B12. References: (See Continuation Sheet 7)
B13. Remarks:
*B14. Evaluator:
*Date of Evaluation:

DPR 523B (1/95) *Required information
Sketch Map subject property in red, no scale  N
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DPR 523L
State of California  The Resources Agency Primary # UPDATE DEPARTMENT OF PARKS AND RECREATION HRI#

CONTINUATION SHEET

*Recorded by: F. Smith *Date: January 10, 2022 Continuation Sheet *P3a. Description: (Continued from page 1)
The central bays on each side are flanked by full-height, checkered motif bronze screens on three sides, and marked by simple cantilevered entrance canopies. The simplified, continuous “capital” or frieze punctuates the composition in the stripped classicist, wide sign band, with a stepped out, quarter radius cornice and architrave. At the corners, the simple inverted base shapes mimic the radiused sill and header forms. The Building is set back on three sides by a nearly uniform perimeter with lawn and low plantings. The low-rise, multi-story building appears to be much higher than its six floors. Its vertical orientation is exaggerated by the filleted, continuous appearing dark window bays and wide central spines. The prim base and lightly detailed horizontal capital provide simple punctuation to the otherwise soaring composition. The resulting Corporate Modern (New Formalist) tower is an unmistakably modern and elegant reinterpretation of the classical column.

The two-story Parking Garage is a wide, low rectangle in plan and mass (Photographs 1 and 2). The ground floor has two parking decks above with an open tope deck. It is a simple, concrete composition with exterior fillets that mimic the Building in simplified forms. The exposed concrete exterior closely mirrors the filleted exterior design treatment of the mid-rise Main Building was constructed to serve. The relationship of solids to voids in the east and west sides are expressed in the fillet columns and fitted metal, full-height screens in place pace of windows. Stepped out, simple frames mark the openings with the second floor parking deck discretely masked behind. At the flat top, a simplified, reduced scale version of the Building’s frieze forms the wide, fulllength sign band. The Parking Garage is the same shape and has the same visual quantities as the Building, executed at a lower height, in smooth-finished concrete. The Building can be compared to a full- height column and the Parking Garage to a low column. The interior has stacked bond, concrete masonry unit endwall and distinctive, geometrical mushroom-type columns with four sided, connected supports.

Photograph 1: Home Savings
Parking Garage, view east. Note the
vertical fins, understated entrance
and continuous sign band at top.

Photograph courtesy of J. Wilson,
January 2022.

The west side of the Parking
Garage faces Maryland Avenue
and possesses the same features
as the east façade (Photograph
2). It has a symmetrical facade,
with simple, stepped-out frames
that note entrances on either
side.

Photograph 2:

Home Savings
Parking Garage,
panoramic view
west. The same
vertical fins,
understated
entrance and
continuous sign
band are that the
top. The Building is
on right with same
sign band.

Photograph J.

Wilson.
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DPR 523L
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CONTINUATION SHEET

*Recorded by: F. Smith *Date: January 10, 2022 Continuation Sheet *P3a. Description: (Continued from page 3)
The Building was constructed using the distinctive, rich blend of materials that Sheets established specifically for the Home Savings building program. Explaining the program, he said “I was concerned about using good materials, using everything from travertine to marble and granite…”The Building, its landscaped front, side and rear yards and corresponding Parking Garage with paved, parking lots and other landscaping are located a reasonably level, irregularly rectangular property that faces both Brand Boulevard and Maryland Avenue. A separate building at 625 N. Maryland Ave. is on the lot north of the Parking Garage. *B10. Significance: (Continued from page 2)
The subject property building contains each of those materials. The costly building finishes were intended to exemplify “timelessness, security and tradition” to retail consumers (Arenson 2018). The Building was aptly described as “present[ing] and aura of strength…” and having a “sleek and orderly appearance” in Long Beach Architecture (Murillo and Volland 2004).

In Banking on Beauty, the author interpreted the significance of the Home Savings’ office building program, of which the subject property is a part, stating that the corporation “embraced its new office tower as a symbol of the business as a whole“(ibid). The architects. Francis J. Heusel (1908-1968) and Frank Homolka, Jr. (1922-2008) were professionally associated in the 1960s as Heusel and Homolka Associates. Other known work by the partners individually and as associates include Marine Officers House, West Los Angeles (1946); California Federal Savings & Loan Association (CalFed) branch, Reseda (1954); residence, Long Beach (1954); CalFed branch, Rancho Park (1955, demolished 1980s); Bixby Knolls Gardens, Long Beach (1957); Pearson House, Long Beach (1962); CalFed office building, Anaheim (1963, demolished 1996); Harbor General Hospital, now Harbor-UCLA, Torrance (1962, no longer extant); Guaranty Bank, Torrance (1963); CalFed office building (now CitiBank), Los Angeles (1964); Colwell Co., Los Angeles (1965, no longer extant); CalFed office building (now CitiBank), Echo Park (1966); Belmont Plaza Olympic Pool/Beach Center, Long Beach (1967, demolished 2014); Long Beach Water Department Administration Building (1967); Mission Viejo Recreation Center (1967); Pasadena Financial Center, Pasadena (1969); Home Savings, Studio City (1968); Sunset Hills Country Club, Thousand Oaks (1969); Ahmanson Bank & Trust, Westwood (1971); Cal Fed, Westwood (1975); Home Savings & Loan, Encino (1976); Long Beach Civic Center and Long Beach Convention and Entertainment Center, Long Beach (1977, with Allied Architects). Allied Architects is described as “composed of a number of noteworthy modernist firms. Headed by Hugh and Donald Gibbs…, its members included Homolka & Associates, Killingsworth, Brady & Associates and Kenneth S. Wing and Associates (LA Conservancy 2020). As part of the consortium with other local architects Long Beach Civic Center included at least three buildings credited partially to Heusel and Homolka Associates: Superior Courts of Los Angeles (1960, addition 1971, demolished 2016), Long Beach Public Safety Building (1960, demolished 2016) and Long Beach City Hall which also included a parking garage (1976, demolished 2020). Of the known projects listed above, at least seven are no longer extant. Heusel and Homolka Associates had an accomplished and successful shared practice until Mr. Heusel’s death in 1968.

The distinctive exterior concrete panels of the tower are notably “Mo-Sai,” exposed aggregate concrete architectural panels, precast in custom, dimensional shapes on metal armatures. The panels formed deep, vertical fillets that nearly span the height of the tower. The decorative concrete aggregate panels were first made popular by John J. Earley (1881-1945), a Washington, D.C. based artisan, designer and builder. The material may have reached its popularity height in the 1960s and ‘70s. It was widely used in Corporate Modern, Brutalist and Neo Formalist applications. Mo-sai achieved different appearances according to the size and color the exposed stones, as well as how much of the stones were exposed and the color of the concrete. In the subject property example, the Mo-Sai panels add depth and dimension to the Building, creating striking shadow effects that alternate with window bays.

Adam Arenson described the Building: “it was nice that the towers could be their own Home Savings icons. These towers reflect the work of Frank Homolka for Home Savings, and their uniformity, with the space for the proud Home Savings name at the top and the shield along the shaft, created their own… recognition” (Arenson 2018). He described the design as “a pared-down modernist aesthetic.”
Other than Home Savings & Loan, which was the original ground floor user in the tower, major tenants in the tower have included Washington Mutual (1998-2008), Coldwell Banker (2001-present) and Chase Bank (estimated 2008-present). A variety of smaller, upper office lessors enumerated in tenant improvement permits have included Baskin & Robbins, IBM, US Gypsum, Adelphia Properties and numerous financial and medical-related businesses. 4-15
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State of California  The Resources Agency Primary # UPDATE DEPARTMENT OF PARKS AND RECREATION HRI#

CONTINUATION SHEET

*Recorded by: F. Smith *Date: January 10, 2022 Continuation Sheet *B10. Significance (Continued from Page 4)
The South Glendale Historic Context Statement described the subject property:

The city’s second oldest commercial high-rise building was erected by… Home Savings and Loan (1969 [sic], Huesel, Holmoka and Associates)... Home Savings Towers were part of the company’s use of architecture to build their brand in communities across Southern California. Unlike the branch offices, these structures were typically high-rise buildings, visible from freeways and did not have the characteristic Millard Sheets artwork of the branches. In addition to Glendale, Home Savings Towers were located in Pomona [Millard Sheets, 1963], Covina [1969], and Long Beach [1982](1979, Frank Homolka and Associates, AIA). Each tower, designed in the New Formalist style [sic, elsewhere described in the document as Corporate Modern], expressively used concrete to emphasize strength and permanence, with space at the top for the brand name and usually a place for the Home Savings [s]hield on the side of the building (HRG 2014).

In a long footnote, the subject property architects were described Long Beach-based Heusel, Holmoka and Associates consisted of Frank Homolka, AIA (1922-2008) and Francis J. Heusel (1906-1968). The firm was the precursor to what became Frank Homolka and Associates after Heusel’s passing. The firm’s focus areas included banking and financial services, schools, offices and warehouses. Homolka was the architect for the towers for Home Savings and Loan. In 1969, the firm received an award fro[m] the Southern California Ready Mixed Concrete Association for the “creative use of concrete.” (Los Angeles Times, March 30, 1969, Footnote 296).

That award was not related to the subject property.

The South Glendale Survey and its separate Context Statement did not mention the Home Savings of America Parking Garage which shares the property, likely by mistake. That evaluation of 620 S. Brand also stated that “No permits [were] available,” when hundreds of pages of building permits and related information are publicly accessible. All building permits for the subject property were reviewed for this evaluation. Those building permits are the purview of City of Glendale, the agency that commissioned South Glendale Survey for which the property was evaluated. The exclusion of the parking garage should be considered an omission of fact rather than a fully-considered finding. The evaluator did not review building permits and entirely missed the Home Savings of America Parking Garage, although it is included in the property’s photograph in the evaluation.

Parking Garage
When Home Savings & Loan established a building committee in the 1960s it was to oversee their numerous construction projects to ensure that their unique requirements were satisfied. Those criteria included site visibility and “centrality,” each of which was met by the subject property’s location at the intersection of Glendale’s main business street with the new State Route 134 freeway (Arenson 2018). The subject property exemplified the prerequisite for “easy parking and surface parking lots, ‘because… of hesitancy on the part of women to go underground for parking’ “(Arenson 2018). The resulting, two-story, reinforced concrete Parking Garage completed in 1970 is a convenient, surprisingly open structure, expressed in stripped down reinterpretation of the Building’s vertical fillets and frieze to respond to the overall design motif.

Home Savings Parking Garage may be the oldest, extant multi-story parking garage in Glendale. One of numerous late 1960s Los Angeles Times articles regarding the issue of parking in the Central Business District, where the subject property was included, one stated “The City has one-multi-deck parking garage in the district on Orange Ave between Broadway and Wilson Avenue” (“OffStreet” 1969). That parking garage is no longer extant; it was replaced by the Glendale Galleria (completed in 1976), which makes the subject property Parking Garage the oldest known property of its type in in Glendale.

The Parking Garage is functionally related to the Building and its property. National Park Service guidance on the subject directs that “Buildings may be functionally related historically if they …were located on the same property historically, …were designed as an overall composition around a common landscape feature, ….are reasonably proximate, had a common entrance through a… single driveway… off the street, [and] were owned and operated/managed by one organization” (2007).

It is not unheard of for a parking garage to be historically significant. There are parking garages that are separately listed in the National Register, including 816 Grand Avenue (built in 1924, listed in 2004) in Los Angeles; Pickwick Hotel, Office Building, Parking Garage and Bus Terminal (built 1930, listed in 2005) in Missouri; Knightley’s Parking Garage, Kansas (built 1949, listed 2016). Other have have been found individually eligible for listing in the California Register, Tinker-Toy Parking Garage #1/Parking Lot 17, Los Angeles (built 1969, demolished 2018 and are locally significant. Colombo’s Parking Garage, Los Angeles, (built 1925, California Office of Historic Preservation 2014). For significant properties with functionally related parking garages, those parking garages contribute to the historic significance of the historic resources or historic properties. 4-15
Responses to Comments
Comment Letter No. 4
Lucia Park Project
Sustainable Communities Environmental Assessment
City of Glendale
June 2022
2117 of 2287
DPR 523L
State of California  The Resources Agency Primary # UPDATE DEPARTMENT OF PARKS AND RECREATION HRI#

CONTINUATION SHEET

*Recorded by: F. Smith *Date: January 10, 2022 Continuation Sheet *B10. Significance (Continued from Page 5)
The Parking Garage is not the only vehicle-focused part of the setting that contributes to the significance of the subject property. In a recent paper, The National Council of Public History recently contended that: “Although the parking lots were considered part of the cultural and historic landscape… planners recommended treatment for the property that privileged preservation of the buildings only… This omission challenges decades of preservation practices that require preservationists to consider the tout ensemble–the entire scene.” In the Vernacular Architecture Forum, Timothy Davis reasoned that “parking lots– should be treated as mid-twentieth century commercial landscapes” (Davis 1997). While the Parking Garage contributes to the significance of the subject property, the surface parking lot and landscaping are less important, but nonetheless are part of the setting, or the physical environment of the historic resource. The setting refers to the character of the place in which the property played its historical role.

The setting, including the main parking lot and its landscaping are related to how the property was historically used, in addition to the way the larger property is situated and its relationship to surrounding features and open space.

The HRG evaluation described “none” under the Related Features category (B8.), which is a factual error. Other inaccuracies in that evaluation are the number of stories, described as “five story height,” when it is six; “Two pairs of fully glazed metal doors” when there is no glazing (it is push-in rubber), there are three sets, two of which are Herculite (estimated to have been added in 2011) as well as the ridiculous assertion that ATMs and awnings with no dates are the only alterations. The addition of the ATM alone in 1990 required removal and infill of a full bay of windows, at what had until then, been the Branch Manager’s office. That evaluation asserts under owner history “Address not listed in available city directories.” The original owner, Home Savings of America is, in fact, listed on page 129, at 6102 N. Brand Bl. under the “Savings & Loan Associations” heading in Polk’s Glendale (Los Angeles County Calif.) City Directory the year after its completion in 1971.

The City’s consultant found the subject property eligible for listing in the Glendale Register in The South Glendale Survey under local Criterion 1 as an example of “post‐World War II commercial development” and under local Criterion 3 as a good example of Corporate Modern commercial architecture by architectural firm Heusel, Homolka and Associates. This property retains character‐ defining features of its original design, including its five‐story height [sic], flat roof with parapet, and vertical strips of fixed metal frame windows and spandrels between continuous precast concrete piers” (HRG 2017). The Parking Garage shares the same significance.

The architect-designed Parking Garage is also an example of postwar commercial development and is a rare example of a Corporate Modern detailed structure designed by Heusel, Homolka and Associates. It is the oldest parking garage building remaining in Glendale. This Parking Garage was notably detailed to correspond to the Building design, and retains those unique details. The City sponsored survey found the Building locally eligible, but made no mention of the related Parking Garage, without which, the building could not have been used for retail or office, based on parking requirements at the time, as well as now.

As described in the City of Glendale “South Glendale Historic Resources Survey” (2017) under the Commercial Development SubTheme: Corporate Modern, requisite character-defining features of Corporate Modern style are part of the Parking Garage • Box-shaped form The Parking Garage is a box-shaped form, shape and volume. • Flat roofs, either with flush eaves or cantilevered slabs The Parking Garage has a nearly flat top deck as its roof. It has no eaves. • Constructed of concrete, steel and glass The Parking Garage is concrete, with rebar or other reinforcing metal, and fitted metal screens at openings. There is no glass because its use is unlike the office building it was built to serve.
• Lack of applied ornament The Parking Garage design does not have applied ornament.

Its exterior structure, the entry frames and sign band mimicking the main building are its only adornments.
• Articulated ground story, often double-height and set back behind columns or pilotis
The Parking Garage ground story is behind the simple vertical fins, which act as columns.
• Integral parking lot, either subterranean above grade The Parking Garage is the integral parking lot (other than the limited surface parking, and is at and above-grade.
• Landscaped plaza or integral plantings at ground floor The very simple landscaped exterior and surface parking lot are part of the setting of the larger Home Savings complex. The Parking Garage is panted in lawn, like the Main Building and has mature, trimmed trees, planted at equal intervals.
4-15
Responses to Comments
Comment Letter No. 4
Lucia Park Project
Sustainable Communities Environmental Assessment
City of Glendale
June 2022
2118 of 2287
DPR 523L
State of California  The Resources Agency Primary # UPDATE DEPARTMENT OF PARKS AND RECREATION HRI#

CONTINUATION SHEET

*Recorded by: F. Smith *Date: January 10, 2022 Continuation Sheet *B10. Significance (Continued from Page 6)
The Parking Garage possesses each of the described Corporate Modern character-defining features as demonstrated on page 6. It would be a futile exercise, based on these facts to make an attempt to justify the Parking Garage not possessing those Corporate Modern character defining features as well as not being an essential component of the larger historic resource.

There is limited state or local direction on establishing periods of significance. California instructions state that a period of significance “refers to a chronological period as it relates to the historic context and is defined as a year or range of years (California “Instructions for Preparing Documentation for Nominating Historical Resources to the California Register of Historical Resources August 1997). The applicable historic contexts identified in the South Glendale Historic Context are Commercial Development, Post‐World War II Commercial Development, Architecture & Design: Post‐World War II Modernism (1919-2000), The Glendale Municipal Code states in the Historic Preservation Ordinance under 15.20.035 “Identification of character-defining features” that
there is a rebuttable presumption that features that conform to the definition of “character-defining feature” included in Section 15.20.020 of this chapter and that date to the property’s original construction and/or to any subsequent historically-significant alteration, will be treated as character-defining features and will be identified as such …pursuant to Section 1520.30 of this chapter” (emphasis added, Ord. 5931 Section 4, 2019).

The Parking Garage date is 1970, the property’s original construction. The period of significance for the property is from 1970 when the Home Savings Building and Parking Garage were completed and closed in 1998 when Washington Mutual acquired Home Savings & Loan. The Parking Garage and larger property retain more than adequate integrity to be recognizable to its period of significance. The only change is the identity of businesses on the signs. Integrity is defined the authenticity of an historical resource’s physical identity evidenced by the survival of characteristics that existed during the resource’s period of significance. The limits of the historic resource are the assessor’s boundaries historically associated with the subject property.

The subject property including the Parking Garage is eligible for the Glendale Register under Criterion C. The Building and Parking Garage embody the distinctive and exemplary characteristics of the Corporate Modern style, the identified Mid-Century Commercial Development, Post‐World War II Commercial Development and Architecture & Design: Post‐World War II Modernism themes, the commercial mid-rise building and concrete parking garage types, the Commercial Development, Post‐ World War II Commercial Development and Architecture & Design: Post‐World War II Modernism (1919-2000) periods, and the property including its setting retains high integrity.
*B12. References: (Continued from page 2)
Arenson, Adam. Banking on Beauty: Millard Sheets and Midcentury Commercial Architecture in California. (Austin: University of Texas Press) 2018.

Arenson, Adam. “Home Savings Towers: Later Efforts at Distinctiveness” at History and Memory on American Borders. 2012. https://adamarenson.com/home-savings-and-millard-sheets/home-savings-towers-later-efforts-at-distinctiveness/ California Office of Historic Preservation. “Directory of Properties in the Historic Property Date File for Los Angeles County” 2012.

Davis, Timothy. “The Miracle Mile Revisited: Recycling, Renovation, and Simulation along the Commercial Strip” Vernacular Architecture Forum. Volume 7, 1997.

Glendale City of. Building Permit #42816, October 8, 1968.

Glendale City of. Inspection Record, Final Inspection March 10, 1970.

Glendale City of. Certificate Use and Occupancy, month and date illegible, 1970.

Historic Resources Group for Glendale, City of. “South Glendale Community Plan, South Glendale Historic Context” Appendix A.1, 2014.

Historic Resources Group for Glendale, City of. “South Glendale Community Plan, South Glendale Historic Resource Survey” Appendix G, 2017.

Los Angeles Conservancy. “Explore LA: Historic Places”2000. https://www.laconservancy.org/locations/long-beach-civic-center Mullio, Cara and Jennifer M. Volland. Long Beach Architecture: The Unexpected Metropolis. (Los Angeles: Hennessy & Ingalls) 2004. “New Design” Los Angeles Times, March 1, 1970: K18. Photograph of Home Savings Building in Glendale.

National Park Service. Technical Preservation Services. ”Functionally Related Structures – General Criteria” 2007. 4-15
Responses to Comments
Comment Letter No. 4
Lucia Park Project
Sustainable Communities Environmental Assessment
City of Glendale
June 2022
2119 of 2287
DPR 523L
State of California  The Resources Agency Primary # UPDATE DEPARTMENT OF PARKS AND RECREATION HRI#

CONTINUATION SHEET