General Plan Amendment – Land Use Diagram Amendment for Lincoln Avenue Specific Plan Attachment D: 2015 General Plan Environmental Impact Report Page 1 City Council March 14, 2022
ATTACHMENT D
2015 GENERAL PLAN ENVIRONMENTAL IMPACT REPORT
August 2015 | Revised Final Environmental Impact Report
PASADENA GENERAL PLAN
for City of Pasadena
State Clearinghouse No. 2013091009
Prepared for:
City of Pasadena
Contact: Arthi Varma, AICP, Principal Planner
Planning and Community Development Department
175 N. Garfield Avenue
Pasadena, California 91101-1704
Prepared by:
PlaceWorks
Contact: Nicole Morse, Esq., Associate Principal
3 MacArthur Place, Suite 1100
Santa Ana, California 92707
714.966.9220
[email protected]
www.placeworks.com
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
Table of Contents
August 2015 Page i
W
Section Page
1. INTRODUCTION...........................................................................................................................1-1
1.1 INTRODUCTION......................................................................................................................................... 1-1
1.2 FORMAT OF THE FEIR............................................................................................................................. 1-1
1.3 CEQA REQUIREMENTS REGARDING COMMENTS AND RESPONSES................................ 1-2
2. GENERAL COMMENTS...............................................................................................................2-1
2.1 TRANSPORTATION METRICS................................................................................................................ 2-1
2.2 STATE DENSITY BONUS LAW............................................................................................................... 2-3
2.3 AIR QUALITY................................................................................................................................................ 2-6
3. RESPONSE TO COMMENTS......................................................................................................3-1
4. REVISIONS TO THE DRAFT EIR ................................................................................................4-1
4.1 INTRODUCTION......................................................................................................................................... 4-1
4.2 DEIR REVISIONS ........................................................................................................................................ 4-1
4.2.2 Scenic Features and Visual Resources .......................................................................................... 4-3
4.3 ADDITIONAL DEIR REVISIONS.........................................................................................................4-11
4.3.2 Level of Significance After Mitigation ....................................................................................... 4-13
5. ERRATA TO FEIR DATED JULY, 2015........................................................................................5-1
5.1 MISCELLANEOUS ADDITIONAL REVISIONS TO THE FEIR.................................................... 5-1
5.2 RESPONSE TO COMMENTS ................................................................................................................... 5-2
6. REFINED PROJECT ENVIRONMENTAL ANALYSIS .................................................................6-1
6.1 REFINED PROJECT.................................................................................................................................... 6-1
6.1.1 Description of Refined Project..................................................................................................... 6-2
6.1.2 Environmental Analysis of the Refined Project ......................................................................... 6-4
6.1.3 CONCLUSION ............................................................................................................................ 6-11
APPENDICES
Appendix A. TIA Current Practice and Guidelines
Appendix B. Caltrans Correspondence
Appendix C. Community Forum Comments
Appendix D. Transportation Analysis Report
Appendix E. Land Use Element Goals and Policies Changes Appendix F. Refined Project Transportation Analysis
Appendix G. Land Use Diagram Revisions
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
Table of Contents
Page ii PlaceWorks
LIST OF TABLES
Table Page
Table 2.2-1 Summary of Approved Density Bonus Concession Projects.....................................................2-4 Table 7-19 Comparison of Alternatives to the Proposed Project............................................................... 3-21 Table A1.1 Internal Consistency of Proposed Land Use Element and Land Use Diagram................... 3-28 Table 5.1-1 Examples of Visual Resources in Pasadena.............................................................................. 3-159 Table C1.1 Impact of Project Alternatives on Regional Jobs-Housing Balance..................................... 3-164 Table 5.1-1 Examples of Visual Resources in Pasadena...................................................................................4-4 Table 7-19 Comparison of Alternatives to the Proposed Project............................................................... 4-11 Table 1-3 Pasadena General Plan Update: Net Projections....................................................................... 4-12 Table 5.10-3 Adopted SCAG Growth Forecasts................................................................................................5-1 Table 1 Comparison of Proposed Project, CD/SFO/LA Alternative, and Refined Project: Net Increase from Existing Conditions.........................................................................6-3 Table 2 Proximity and Quality of Bicycle Network....................................................................................6-9 Table 3 Proximity and Quality of Transit Network................................................................................. 6-10 Table 4 CMP Analysis Results For Freeway Mainline Segments, Refined Project............................. 6-10 Table 5 CMP Analysis Results for Arterial Intersections, Refined Project.......................................... 6-11 August 2015 Page 1-1
1. Introduction
1.1 INTRODUCTION
This Final Environmental Impact Report (FEIR) has been prepared in accordance with the California Environmental Quality Act (CEQA) as amended (Public Resources Code Section 21000 et seq.) and CEQA Guidelines (California Administrative Code Section 15000 et seq.).
According to CEQA Guidelines, Section 15132, the FEIR shall consist of:
(a) The Draft Environmental Impact Report (DEIR) or a revision of the Draft; (b) Comments and recommendations received on the DEIR either verbatim or in summary; (c) A list of persons, organizations, and public agencies comments on the DEIR; (d) The responses of the Lead Agency to significant environmental points raised in the review and consultation process; and
(e) Any other information added by the Lead Agency.
This document contains responses to comments received on the DEIR for the Pasadena General Plan Update during the public review period, which began January 22, 2015, and closed March 24, 2015. This document has been prepared in accordance with CEQA and the CEQA Guidelines and represents the independent judgment of the Lead Agency. This document and the circulated DEIR comprise the FEIR, in accordance with CEQA Guidelines, Section 15132.
1.2 FORMAT OF THE FEIR
This document is organized as follows:
Section 1, Introduction. This section describes CEQA requirements and content of this FEIR.
Section 2, General Comments. This section includes responses to recurring comments.
Section 3, Response to Comments. This section provides a list of agencies and interested persons commenting on the DEIR; copies of comment letters received during the public review period, and individual responses to written comments. This section also includes responses to comments received at a two community forums and 11 commission hearings regarding the DEIR. To facilitate review of the responses, each comment letter has been reproduced and assigned a number (A-1 through A-8 for letters received from agencies and organizations, R-1 through R-10 for letters received from residents, F1 and F2 for comments received during the community forums, and C1 for comments received from the commissions).
Individual comments have been numbered for each letter and the letter is followed by responses with references to the corresponding comment number.
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
1. Introduction
Section 4. Revisions to the DEIR. This section contains revisions to the DEIR text and figures as a result of the comments received by agencies and interested persons as described in Section 3, and/or errors and omissions discovered subsequent to release of the DEIR for public review.
Section 5, Errata to FEIR dated July, 2015. This section is an errata to the FEIR dated July, 2015.
Section 6, Refined Project Environmental Analysis. This section provides an environmental analysis of the Refined Project.
The responses to comments contain material and revisions that will be added to the text of the FEIR. City of Pasadena and expert consultants have reviewed this material and determined that none of this material constitutes the type of significant new information that requires recirculation of the DEIR for further public comment under CEQA Guidelines Section 15088.5. None of this new material indicates that the project will result in a significant new environmental impact not previously disclosed in the DEIR. Additionally, none of this material indicates that there would be a substantial increase in the severity of a previously identified environmental impact that will not be mitigated, or that there would be any of the other circumstances requiring recirculation described in Section 15088.5.
1.3 CEQA REQUIREMENTS REGARDING COMMENTS AND RESPONSES
CEQA Guidelines Section 15204(a) outlines parameters for submitting comments, and reminds persons and public agencies that the focus of review and comment of DEIRs should be “on the sufficiency of the document in identifying and analyzing possible impacts on the environment and ways in which significant effects of the project might be avoided or mitigated. Comments are most helpful when they suggest additional specific alternatives or mitigation measures that would provide better ways to avoid or mitigate the significant environmental effects. At the same time, reviewers should be aware that the adequacy of an EIR is determined in terms of what is reasonably feasible. …CEQA does not require a lead agency to conduct every test or perform all research, study, and experimentation recommended or demanded by commenters. When responding to comments, lead agencies need only respond to significant environmental issues and do not need to provide all information requested by reviewers, as long as a good faith effort at full disclosure is made in the EIR.”
CEQA Guidelines Section 15204(c) further advises, “Reviewers should explain the basis for their comments, and should submit data or references offering facts, reasonable assumptions based on facts, or expert opinion supported by facts in support of the comments. Pursuant to Section 15064, an effect shall not be considered significant in the absence of substantial evidence.” Section 15204(d) also states, “Each responsible agency and trustee agency shall focus its comments on environmental information germane to that agency’s statutory responsibility.” Section 15204(e) states, “This section shall not be used to restrict the ability of reviewers to comment on the general adequacy of a document or of the lead agency to reject comments not focused as recommended by this section.”
In accordance with CEQA, Public Resources Code Section 21092.5, copies of the written responses to public agencies will be forwarded to those agencies at least 10 days prior to certifying the environmental impact report. The responses will be forwarded with copies of this FEIR, as permitted by CEQA, and will conform to the legal standards established for response to comments on DEIRs.
August 2015 Page 2-1
2. General Comments
This section summarizes those environmental issues that were raised by multiple commenters. General responses provide background information to augment the individual responses found in Chapter 3 of this FEIR.
2.1 TRANSPORTATION METRICS
SB 743 Background
SB 743 was signed into law on September 27, 2013. It amended the Public Resources Code and added Section 21099 to change the way transportation impacts are evaluated under the California Environmental Quality Act (CEQA). Traditionally, transportation impacts have been evaluated using a threshold based on auto delay or level of service standard. The level of service standard evaluates a driver’s experience at an intersection or roadway segment. The focus on auto delay often leads to mitigation measures that increase roadway capacity, which may lead to increased vehicle trips and vehicle miles traveled (VMT). The purpose of SB 743 is to focus transportation analysis away from driver delay to reduction of greenhouse gas emissions (GHG), creation of multimodal networks, and promotion of a mix of land uses. A reduction in VMT results in a reduction in GHG emissions.
SB 743 requires the Governor’s Office of Planning and Research (OPR) to identify alternative transportation metrics that “promote the reduction of greenhouse gas emissions, the development of multimodal transportation networks, and a diversity of land uses.” Pursuant to new Public Resources Code Section 21099(b)(1), measurements of transportation impacts may include “vehicle miles traveled, vehicle miles traveled per capita, automobile trip generation rates, or automobile trips generated.” OPR is in the process of reviewing comments received on their “preliminary discussion draft of changes to the CEQA Guidelines.” Once the new CEQA Guidelines are finalized, new Public Resources Code Section 21099(b)(2) prohibits a finding that automobile delay, as described solely by level of service or similar measures of vehicular capacity or traffic congestion, is a significant impact on the environment pursuant to CEQA (unless otherwise provided for in the new Guidelines).
City Adopted Transportation Performance Measures
On November 3, 2014, the City of Pasadena City Council adopted a resolution to replace the City’s transportation performance measures with five new Transportation Performance Measures and new thresholds of significance to determine transportation and traffic impacts under CEQA. The new performance measures and CEQA thresholds are consistent with the adopted and proposed General Plan and SB 743, and include VMT per capita, vehicle trips (VT) per capita, proximity and quality of bicycle network, proximity and quality of transit network, and pedestrian accessibility.
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
2. General Comments
The CEQA Guidelines encourage lead agencies to adopt thresholds of significance to determine the impact of an environmental effect within its jurisdiction. Significance thresholds quantify impacts on a qualitative, quantitative, or performance level basis. CEQA Guidelines Section 15064.7(b) lays out the process for adopting thresholds. The lead agency must adopt environmental thresholds of significance by ordinance, resolution, rule, or regulation through a public review process supported by substantial evidence.
In 2014, the City conducted numerous public hearings with the Transportation Advisory Commission, Planning Commission, and City Council to evaluate and develop new transportation performance measures.
Pasadena’s Department of Transportation presented substantial evidence to the public and decision makers to make an informed decision on the new performance standards. Substantial evidence included but was not limited to: presentations on SB 743 requirements; how new metrics would be better aligned with the vision, goals, and policies of the General Plan; how new metrics would better assess the transportation network and the resident experience; an analysis of several possible metrics and what they evaluate; the pros and cons of the existing and new metrics; and numerous case studies. The following public hearings were held:
Public Hearing on Draft Transportation Performance Measures Transportation Advisory Commission (February and March 2014) Municipal Services Committee (March 2014)
Community Meeting (March 2014)
Planning Commission (April 2014)
Public Hearing on Proposed Transportation Performance Measures Transportation Advisory Commission (May, June, and September 2014) Planning Commission (May, June, July, and September 2014) Community Meetings (June 2014)
Municipal Services Committee (July and October 2014)
City Council (November 2014 to adopt new transportation performance measures and CEQA thresholds of significance)
Based on substantial evidence and numerous public hearings, the City Council adopted a resolution establishing new thresholds of significance to determine transportation and traffic impacts under CEQA.
City Council determined that the new transportation performance measures and CEQA thresholds are better aligned with the City’s General Plan goals and policies and State regulations to create more sustainable transportation systems. They are also better suited to Pasadena’s existing urban, walkable environment, since traditional performance measures (e.g. LOS) often require mitigation that increases roadway width that often cannot be constructed without adversely affecting existing buildings and the pedestrian environment. The performance measures and CEQA thresholds provide a holistic approach by considering the City’s transportation network, including all modes of travel. This approach provides a more comprehensive systems approach that is independent and distinct from traditional traffic thresholds measuring level of service.
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
2. General Comments
August 2015 Page 2-3
Transportation Analysis in the General Plan Update
A few of the commenters suggested that the EIR provide a transportation analysis using the City’s old traffic metrics to compare and contrast that analysis with the adopted metrics. Such an approach is not required by CEQA, nor would it provide meaningful information for CEQA purposes, for the following reasons. First, CEQA requires that the EIR address environmental impacts based on adopted thresholds of significance.
The traffic analysis prepared for the General Plan Update and Section 5.13 of the DEIR uses the City’s adopted thresholds of significance. Since the old traffic metrics based on level of service are no longer applicable adopted thresholds, this analysis is not required in the EIR. Second, a comparison of an analysis using the adopted transportation performance measures and CEQA thresholds, and old performance measures would not provide any meaningful information because the metrics are measuring two completely different and competing performance criteria and policies. Generally, the new performance measures focus on reducing VMT to create more sustainable communities, reducing GHG emissions, and accommodating all modes of travel. In contrast, the old metrics measure auto delay at a particular intersection or street segment, focus on moving more cars quickly at the expense of other modes of travel, and often lead to mitigation that increases roadway capacity to accommodate new vehicle trips. Increased roadway capacity may result in increased VMT, energy consumption, and GHG emissions. Therefore, the old metrics are inconsistent with adopted thresholds, and more importantly, conflict with the overarching goals and policies of the General Plan. Finally, the new metrics bring the City in line with state law. As stated before, upon certification of the upcoming State CEQA Guidelines, a level of service (auto delay) traffic standard “shall not” be used to make a significance determination pursuant to Public Resources Code Section 21099(b)(2). In conclusion, the City Council of the City of Pasadena properly adopted the current CEQA thresholds of significance, thereby doing away with the old metrics as outdated and out of line with the City’s General Plan and evolving state law, and there is no legal requirement or policy justification for a comparison between the new thresholds and the old metrics.1
2.2 STATE DENSITY BONUS LAW
A number of comments were made that relate to the State’s Density Bonus Law (SB 1818) and how it would impact the environment through implementation of the General Plan Update. This response is intended to provide background on SB 1818, how it can be applied, and how it was analyzed in the DEIR.
Background
The State of California enacted changes to the state’s density bonus law, which went into effect on January 1, 2005. The legislation, SB 1818, amended Government Code Sections 65915-65918 to allow a density bonus, concessions or other incentives to development projects that meet certain affordable housing criteria without requiring a discretionary approval. Concessions or other incentives may include a waiver or reduction of 1 Further, CEQA does not require that a lead agency include every study requested by the public, even if the further study might be helpful (which is not the case here). “ ‘[A] project opponent or reviewing court can always imagine some additional study or analysis that might provide helpful information. It is not for them to design the EIR. That further study ... might be helpful does not make it necessary.’ ” (Saltonstall v. City of Sacramento (2015) 234 Cal.App.4th 549, 581, quoting Laurel Heights Improvement Assn. v. Regents of University of California (1988) 47 Cal.3d 376, 415.)
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
2. General Comments
development standards where the standard would physically preclude construction of the project. Pasadena Municipal Code Chapter 17.43 implements Government Code Sections 65915-65918. The City shall grant the concession or incentive for a qualifying development, if it makes written findings, showing that the incentive:
1) is required to provide for affordable housing costs, 2) would not have a specific, adverse impact, upon health, safety or the physical environment for which there is no feasible method to satisfactorily mitigate or avoid the specific adverse impact the project, 3) would not have a “specific adverse impact” on real property listed in the California Register of Historical Resources, and 4) would not be contrary to state or federal law.
Pursuant to Municipal Code Section 17.43.060, the burden is on the applicant to demonstrate the need for the waiver or modification to a development standard.
Since the law was enacted, approximately 10 years ago, there have been a number of affordable housing units approved in the City of Pasadena. However, there have only been eight projects (one of which was superseded by a later application) which have received a density bonus and concessions under SB 1818. Of these projects, the majority of concessions were for minor changes to floor area ratios and setbacks. Of those, only three concessions have allowed for an increase in building height. The table below provides a summary of the projects that have been approved with concessions.
Table 2.2-1 Summary of Approved Density Bonus Concession Projects Case Number Address Concession #1 Concession #2 Concession #3 AHCP #11586
(see AHCP #11751)
496 S. Arroyo Pkwy. FAR Increase:
from 1.5 to 2.2 – –
AHCP #11573 123 S. Los Robles Ave. FAR Increase:
from 2.25 to 2.59 – –
AHCP #11658 877 N. Orange Grove Blvd. Commercial Depth
Decrease:
from 50’-0” to 30’-2”
Commercial Depth
Decrease (corner):
from 50’-0” to 30’-2”
Parking Decrease:
From 14 to 7 spaces
AHCP #11751 496 S. Arroyo Pkwy. FAR Increase:
from 1.5 to 2.3
Height Averaging Increase:
from 50’-0” to 57’-0” –
AHCP #11753 105 S. Los Robles Ave. FAR Increase:
from 2.25 to 2.70 – –
AHCP #11758 196-200 S. Oakland Ave. Front Setback Decrease:
from 26’-0” to 16’-0
Corner Setback Decrease:
from 15’-0” to 8’-0” –
AHCP #11795 60-80 S. Vinedo Ave. Height Increase (rear 40%):
from 32”-0” to 36’-0” – –
AHCP #11817 104-112 E. Orange Grove
Blvd.
Corner Setback Decrease:
from 15'-0" to 5'-0"
Height Increase:
From 36'-0" to 40'-6" –
Source: City of Pasadena, July 2015
Comments were made that the City should assume a 35 percent density bonus in its buildout calculations, in accordance with the maximum that could be allowed by SB 1818. There is no support, however, in the City’s experience for such an assumption. The City reviewed historical trends since the inception of SB 1818 in 2005 to determine the number of affordable housing units that could be allowed over the development caps.
Given the City’s experience over the past 10 years, with an average of a 17 percent density bonus per project, project buildout and the EIR analysis uses this average in addition to the development caps. An assumption
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
2. General Comments
August 2015 Page 2-5
of 35 percent would overstate reasonably foreseeable environmental effects of density bonus, and lead to mitigation or policies that have no nexus to project impacts based on facts. Further, it could end up discouraging the provision of affordable housing in Pasadena, and run counter to other General Plan goals and policies and the state legislative intent of SB 1818.
It is important to note that SB 1818 does not exempt future projects from CEQA. CEQA operates independently from SB 1818. Future site specific development projects will be subject to the applicable environmental review process pursuant to CEQA.
General Plan Update EIR is a Program EIR
The Pasadena General Plan Update EIR is a Program EIR (see Section 1.2.2 of the DEIR). A Program EIR analyzes the impacts of broad based policies and programs (such as general plans and specific plans) and contains a more general description of impacts, alternatives, and mitigation measures than a Project EIR. A Project EIR, on the other hand, analyzes a specific development project and therefore includes a greater level of detail and analyzes all phases of a project. A Program EIR is the most comprehensive tool to analyze impacts of Pasadena’s General Plan Update because it considers citywide impacts, broad policy alternatives, and programmatic mitigation measures.
The General Plan Update does not propose a specific development project, therefore the Program EIR analyzes the impacts associated with total buildout of land uses in the City and goals and policies of the General Plan Update. While the EIR can be used for future tiering (see Section 2.7 of the DEIR), it is not meant to provide full clearance for all future site specific development projects within the City. Following adoption of the General Plan Update, the City will be updating the specific plans to be consistent with the General Plan Update, which will also require future CEQA review.
The DEIR analyzes the environmental impacts of all land uses within the City at buildout. As detailed in Section 3.3.2.1 of the DEIR and described above, General Plan Update buildout takes into account a reasonable, fact based assumption regarding the number of affordable units that may be built beyond the established development caps. The DEIR analyzes the total potential buildout of the City as well as the change in proposed land use throughout the City. However, at this programmatic level of analysis, it would be speculative to analyze the environmental impacts of a future development project that is seeking SB 1818 concessions. Over the past 10 years there have only been eight (one of which was superseded by a later application) approved development projects that have received SB 1818 concessions, three of which included a concession for building height. Of these projects, four (counting one project twice) were within the Central District Specific Plan, two were in Fair Oaks/Orange Grove Specific Plan, and one was in East Colorado Specific Plan.
The EIR Adequately Analyzes Aesthetic and Historic Resource Impacts Relative to SB 1818 Commenters have expressed concern that incentives or concessions obtained under SB 1818 may allow for exceedance of the maximum building height in areas adjacent to historic districts or historic buildings and that these exceedances may have potentially significant environmental effects. There are numerous historic resources throughout the City of Pasadena, and numerous federal, state and local regulations, including the
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
2. General Comments
National Historic Preservation Act and California Register of Historical Resources, operate to ensure that historic resources are protected. The EIR analyzed the change in land uses with respect to these resources in Section 5.1, Aesthetics and 5.4, Cultural Resources. For example, the aesthetic character of new land uses within the City and each specific plan area was provided starting on Page 5.1-42 of the DEIR. In addition, view simulations were generated for areas in the City where development has the potential to occur. For example, a conceptual sketch was provided at North Lake Avenue and Washington Boulevard near Bungalow Heaven in order to determine if changes in the aesthetic character would impact the surrounding area. The view simulations were not meant to be all inclusive or dictate a particular style or development type since the City cannot anticipate what individual projects will be proposed.
Projects seeking a density bonus under SB 1818 may obtain concessions or a waiver of development standards, including an increase in building height. The type of concession or waiver sought is dependent upon the number of affordable units being proposed, its location and parcel size, site constraints, and other uses proposed. These are unique circumstances that must be analyzed for a particular project and site to identify what concession or waiver of development standards would apply. Therefore, it would be unduly speculative to incorporate assumptions regarding concessions in the visual simulations.
Adjacency issues with respect to historic districts were also analyzed in Section 5.4.3 of the DEIR.
Furthermore, a number of General Plan Update policies have been incorporated to ensure that new development is compatible with the character and scale of the surrounding neighborhood (see proposed Land Use Element policies 4.11, 4.12, 6.1, 6.2, 6.3, 6.4, 7.1, 7.3, 7.4, 8.1, 8.2, 8.3, 8.4, 8.5, and 22.1). In consideration of the City’s adopted and proposed General Plan policies and programs protecting historic resources, including the Design Guidelines for Historic Districts, the adopted specific plans, and Municipal Code 17.61.030, impacts were determined to be less than significant.
Future projects seeking a density bonus under SB 1818 that are near or adjacent to historic resources and districts must comply with Government Code Section 65915. Specifically, concessions may be denied when it would result in a “specific adverse impact” (as defined in Government Code Section 65589.5) on the physical environment or on a property listed in the California Register of Historical Resources and for which there is no feasible method to satisfactorily mitigate or avoid that impact without rendering the project unaffordable to low and moderate income households. Additionally, the burden to justify a deviation from development standards is on the applicant to show the development would not be affordable without them. Further, based on the City’s experience over the last 10 years with density bonus projects, there is no reasonable factual basis to support a conclusion that there will be such a large number of projects seeking concessions or incentives that potentially significant environmental impacts or “specific adverse impacts” with regard to historic or other resources will arise. Based on these requirements, no significant impacts beyond those analyzed in the EIR are anticipated.
2.3 AIR QUALITY
Introduction
Several comments expressed concern that the air quality analysis in the DEIR was not adequate because there is not a monitoring station adjacent to the I-210 Freeway in the City of Pasadena or that the DEIR did not
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
2. General Comments
August 2015 Page 2-7
include a provision to include one. While the provision for a new air monitoring station is not within the jurisdiction of the City of Pasadena, the implementation of the Pasadena General Plan Update does not preclude the South Coast Air Quality Management District (SCAQMD) from installing an additional air monitoring station within the City.
SCAQMD Air Monitoring
Air monitoring stations are not installed by SCAQMD on a site-by-site basis. Monitoring of particulate matter and other air pollutants monitoring stations throughout the SCAQMD do not distinguish between ambient concentrations generated by the freeways versus other stationary, area, and non-freeway sources of pollution.
In addition, concentrations of air pollutants within the air basin are dispersed throughout the air basin according to regional meteorological conditions as described in Section 5.2, Air Quality, of the EIR (see pages
5.2-1 through 5.2-2). Air quality monitoring stations are selected by SCAQMD for their ability to monitor ‘regional’ air quality to comply with the Federal Clean Air Act (CAA) and the California CAA for attainment purposes. Hence, air monitoring sites are required to comply with CAA siting criteria and related requirements. As part of the CAA requirements, California is required to submit its annual monitoring network plan, which includes SCAQMD’s network of air quality monitoring stations, to the Environmental Protection Agency (EPA).
SCAQMD currently operates 38 permanent, monitoring stations, and 4 single-pollutant source impact lead (Pb) air monitoring sites. One of these monitoring stations is already within Pasadena (752 S Wilson Avenue), approximately 1.3 miles from the I-210 Freeway. This air monitoring station operated by SCAQMD monitors carbon monoxide (CO), nitrogen dioxide (NO2), ozone (O3), fine inhalable particulate matter (PM2.5), and sulfate (SO4). According to SCAQMD’s air quality monitoring network plan, the existing site in Pasadena is selected to represent the air pollutant concentrations that a populated area is exposed to.
Air Quality Significance Thresholds
The conclusions of the air quality analysis in Section 5.2 of the DEIR can be made irrespective of ambient air quality in the South Coast Air Basin (SoCAB), which has been demonstrated to be in nonattainment under the State and National ambient air quality standards (AAQS) with or without the proposed project. Since the SoCAB is not currently in attainment of the AAQS, SCAQMD developed regional significance thresholds that take into account the incremental increase allowable on a project-by-project basis that would not be cumulatively considerable and would result in less than significant impacts. SCAQMD’s bright-line significance thresholds were developed based on the annual emissions permitting thresholds in the EPA’s Prevention of Significant Deterioration (PSD) of Air Quality regulation. The EPA thresholds are the increment of air pollution an area is allowed to increase. PSD increments prevent the air quality in clean areas from deteriorating to the level set by the National AAQS. Similar to CEQA thresholds, the EPA thresholds require projects that generate regulated sources of emissions to demonstrate that new emissions emitted from a proposed major stationary source or major modification, in conjunction with other applicable emissions increases and decreases from existing sources, will not cause or contribute to a violation of any applicable National AAQS or PSD increment. The thresholds used by air districts in California to determine significant impacts are derived from these health based AAQS. Therefore, the analysis of regional emissions impacts in the EIR addresses whether the additional amount of emissions generated by the project would be considered
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
2. General Comments
significant in the context of the existing cumulative effect, which is based on criteria air pollutant emissions for which the air basin is designated as nonattainment. The regional criteria air pollutant analysis in a CEQA document provides a cumulative impact analysis. The DEIR identified significant and unavoidable adverse impacts related to construction and operation of the General Plan Update.
Mitigation of Air Quality Impacts
To the extent there was a suggestion that placement of an air monitoring station would reduce criteria air pollutant or GHG emissions, it would not, and would not substantially reduce impacts. Per Section 15126.2(b) of the CEQA Guidelines, “significant and unavoidable” impacts are those that cannot be avoided or reduced to a level that is less than significant, even after incorporation of feasible mitigation measures. The installation of additional air quality monitoring stations in Pasadena could benefit future analysis of local air quality by providing additional data on ambient conditions and local effects of freeway pollutants to sensitive receptors. However, this information, alone, would not reduce impacts. Most of the significant and unavoidable air quality impacts of the proposed project are those related to the overall air basin’s nonattainment of pollutant thresholds. The State and regional air districts have established a number of rules and regulations that reduce emissions within the basin, such as motor vehicle standards and building efficiency standards (see DEIR Section 5.2.5). However, the existence of additional air quality data for specific locations in Pasadena would not have a tangible effect on the ability of projects to mitigate air quality impacts to the South Coast Air Basin and would therefore not lead to reduction in the aforementioned impacts to less than “significant and unavoidable.”
The DEIR included several provisions aimed at the mitigation of potential air quality impacts disclosed in the EIR. Most importantly, it identified four mitigation measures whose implementation would reduce the impacts of individual development projects on the health of Pasadena residents:
Measure 2.1: Requires project applicants to prepare project-level technical assessments of construction-related air quality impacts and identify/implement measures that reduce constructionrelated pollutant emissions. Measure 2.2: Requires project applicants to prepare project-level technical assessments of operation-related air quality impacts and identify/implement measures that reduce operational pollutant emissions.
Measure 2.3: Requires project applicants for projects that will generate substantial diesel truck traffic near sensitive land uses (e.g., homes, schools, hospitals) to prepare and submit a health risk assessment (HRA). Health hazards that exceed SCAQMD thresholds must be mitigated using best available control technologies for toxics (T-BACTs).
Measure 2.4: Requires project applicants to prepare HRAs and implement site-specific design measures for sensitive land uses that would be placed in environments with high air quality health risks (as defined by state and SCAQMD regulations).
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
2. General Comments
August 2015 Page 2-9
Although these measures are not specifically tailored to freeway-related air pollution, they focus on “sensitive” land uses (which are often located near freeways) and add layers of public disclosure to the local development process.
In addition to identifying mitigation measures, the DEIR identified and analyzed a project alternative aimed at reducing air quality impacts generated by high-volume roadways: the Reduced Air Quality and Noise Impact Alternative. Although this alternative was found to reduce health risks to sensitive receptors, it did not eliminate the project’s significant and unavoidable air quality impacts, which are largely a function of the community’s size and overall population (with or without the proposed project). Furthermore, buildout of the Reduced Air Quality and Nose Impact Alternative was found to generate greater impacts than the proposed General Plan Update in several topical areas, including Greenhouse Gas Emissions, Hazards and Hazardous Materials, Public Services, Recreation, and Utilities and Service Systems.
Overall Air Quality Trends
Air pollution and overall air quality remain a major concern in the South Coast Air Basin and the region continues to experience some of the worst air quality in the nation. However, due to stricter emissions standards for power plants and automobiles, the basin has experienced multiple decades of overall reductions in hazardous air pollution. In the past two decades, ozone levels and fine particle pollution have dropped dramatically. The executive summary of SCAQMD’s 2015 Multiple Air Toxics Exposure Study (MATES-IV) in the South Coast Air Basin found that:
Compared to previous studies of air toxics in the Basin, this study found decreasing air toxics exposure, with the estimated Basin-wide population-weighted risk down by about 57% from the analysis done for the MATES III time period. The ambient air toxics data from the 10 fixed monitoring locations also demonstrated a similar reduction in air toxic levels and risks. (SCAQMD 2015)
Similarly, SCAQMD’s 2012 Air Quality Management Plan (AQMP) states that air quality in the basin has improved significantly in recent years and the number of days in which the basin exceeds federal standards have decreased dramatically (SCAQMD 2013). These accomplishments, which are largely the result of aggressive regulation, do not diminish the need for additional intervention at the local, state, and federal level.
However, ongoing trends indicate that air quality in Pasadena and Southern California will most likely improve rather than worsen.
Along with emerging technologies in the automotive industry, the continued development of dense, walkable, transit-accessible neighborhoods (which reduce per-capita vehicle trips and trip lengths) is anticipated to reduce auto-related air pollutants in the air basin even as the region’s population grows. Furthermore, the land use pattern associated with the General Plan Update—which encourages the use of transit and nonmotorized transportation—would contribute to the region’s decreasing reliance on the automobile, which has historically been a major source of air pollution. Therefore, although General Plan buildout may place new residents near freeways, impacts of this adjacency would be mitigated (see Measures 2-1 through 2-4, above).
Although the magnitude and scale of growth allowed under the General Plan Update (or under the Adopted General Plan) would result in significant and unavoidable impacts, the resulting land use pattern would have a
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
2. General Comments
positive effect on regional air quality compared to equivalent growth at the region’s sprawling, auto-centric edges.
August 2015 Page 3-1
3. Response to Comments
Section 15088 of the CEQA Guidelines requires the Lead Agency (City of Pasadena) to evaluate comments on environmental issues received from public agencies and interested parties who reviewed the DEIR and prepare written responses. This section provides all written comments received on the DEIR and the City’s responses to all comments on environmental issues.
Comment letters and specific comments are given letters and numbers for reference purposes. Where sections of the DEIR are excerpted in this document, the sections are shown indented. Changes to the DEIR text are shown in underlined text for additions and strikeout for deletions.
The following is a list of agencies and persons that submitted comments on the DEIR during the public review period.
Number
Reference Commenting Person/Agency Date of Comment Page No.
Agencies & Organizations
A1 Bungalow Heaven Neighborhood Association March 20, 2015 3-3 A2 CalTrans March 23, 2105 3-33
A3 City of Pasadena Public Health Department March 24, 2015 3-41 A4 County of Los Angeles Fire Department February 3, 2015 3-47 A5 County of Los Angeles Fire Department February 25, 2015 3-53 A6 Pasadena Chamber of Commerce March 20, 2015 3-57
A7 Pasadena Heritage March 23, 2015 3-61
A8 Playhouse District Association March 24, 2015 3-75
Residents
R1 Joyce Dillard March 24, 2015 3-81
R2 Laura Ellersieck January 28, 2015 3-85
R3 Alon Friedman February 19, 2015 3-89
R4 Lonnee Hamilton February 8, 2015 3-93
R5 Richard Hogge February 10, 2015 3-99
R6 Richard Luczyski (1 of 2) February 11, 2015 3-103
R7 Richard Luczyski (2 of 2) March 24, 2015 3-109
R8 Steve Madison, Councilmember March 12, 2015 3-113
R9 Bryant Mathews March 8, 2015 3-117
R10 North Mentor Avenue Residents Group March 23, 2015 3-121 Community Forums
F1 Forum #1 February 19, 2015 3-131
F2 Forum #2 February 21, 2015 3-135
City Commissions
C1 City Commissions - Consolidated Multiple dates 3-141
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADE N A
3. Response to Comments
Number
Reference Commenting Person/Agency Date of Comment Page No.
Errata (Section 5)
- Vince Farhat, At-Large Commissioner, City of Pasadena Planning Commission March 15, 2015
R11 Robert J. Tait, Ph.D, President, El Rio/Lake Neighborhood Association February 25, 2015
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
3. Response to Comments
August 2015 Page 3-3
LETTER A1 – Bungalow Heaven Neighborhood Association (13 pages)
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADE N A
3. Response to Comments
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
3. Response to Comments
August 2015 Page 3-5
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADE N A
3. Response to Comments
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
3. Response to Comments
August 2015 Page 3-7
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADE N A
3. Response to Comments
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
3. Response to Comments
August 2015 Page 3-9
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADE N A
3. Response to Comments
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
3. Response to Comments
August 2015 Page 3-11
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADE N A
3. Response to Comments
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
3. Response to Comments
August 2015 Page 3-13
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADE N A
3. Response to Comments
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
3. Response to Comments
August 2015 Page 3-15
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADE N A
3. Response to Comments
This page intentionally left blank.
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
3. Response to Comments
August 2015 Page 3-17
A1. Response to Comments from Bungalow Heaven Neighborhood Association, dated March 20, 2015.
A1-1 This comment describes the purpose and mission of the Bungalow Heaven Neighborhood Association and provides comments on the General Plan Update DEIR, Draft Land Use Element, and Draft Mobility Element. Specific comments and concerns are addressed below.
A1-2 Please refer to Section 2.3, Air Quality. The EIR focuses on the potential direct and indirect physical impacts of the General Plan Update on the environment. The California Environmental Quality Act (CEQA) does not require a quality of life analysis.
In addition, social and economic effects shall not be considered “significant effects on the environment” for purposes of the EIR (CEQA Guidelines §15131). However, the City may take these considerations into account when deciding on adoption of the General Plan Update.
Section 5.2 of the EIR analyzed the air quality impacts of the General Plan Update. Air pollutants of concern and associated health effects are provided in Section 5.2.1.2 of the EIR. The City is within the South Coast Air Basin and is subject to the rules and regulations imposed by the South Coast Air Quality Management District (SCAQMD).
The project was analyzed with respect to SCAQMD guidelines and thresholds. As a function of the CEQA air quality analysis methodology established by SCAQMD, additional air quality monitoring would not affect the analysis conducted or conclusions reached in this EIR. It was determined that buildout of the General Plan Update would exceed SCAQMD thresholds and would result in significant unavoidable effects from construction and long-term operational emissions.
The EIR also provided the existing levels of ambient air quality in Table 5.2-3. Data was collected from two monitoring stations, including one in Pasadena located approximately
1.3 miles from the I-210 Freeway. There are also several air monitoring stations along the freeway in the South Coast Air Basin. SCAQMD is responsible for citing and relocating air monitoring stations and are required to conduct an annual review of the air quality monitoring network. Placement of a new air quality station would not result in any new significant impacts for purposes of the EIR. However, the City is willing to cooperate in locating a new air quality monitoring site within the City for informational purposes. Refer also to Section 2.3, Air Quality.
A1-3 The commenter states that General Plan buildout would result in new residents that would exceed the population growth projected for Pasadena by the Southern California Association of Governments (SCAG). Under CEQA, a Program EIR must analyze the environmental effects of “buildout” of a specific plan or general plan, which represents the maximum allowable development intensity of all affected parcels as established by zoning or development caps. The City of Pasadena calculated buildout using
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADE N A
3. Response to Comments
development caps and the total number of affordable housing units expected to be constructed. This is a conservative analysis of buildout potential because it does not factor in market demand, individual site constraints, or more restrictive development standards. Combined, these factors are expected to limit development potential below what is contemplated in the analysis. While the capacity generated in each of the specific plan areas and citywide exceeds growth forecasts, the General Plan Update accommodates SCAG and Department of Finance (DOF) projections for the City while providing flexibility as to where this growth can be accommodated. Population growth in Pasadena under the General Plan Update would likely be much closer to the Department of Finance (DOF) and SCAG projections for the City than under a theoretical buildout scenario.
Furthermore, SCAG growth forecasts are benchmarks calculated using overall demographic trends and growth patterns available at the time of their publication; they do not consider local infrastructure planning, changes in household size or land values, or other factors that allow a planning document generated for a more specific geographic area—such as the General Plan Update—to consider. Some such factors change substantially after publication of SCAG growth projections. As cities update their General Plans, they may adjust their own projections related to housing units, population, and employment based on demographic trends, housing needs, and employment growth occurring in the local community. Such adjustments are then coordinated with SCAG as they prepare their next round of city-level growth projections. Development caps that allow modest increases or decreases in growth compared to SCAG projections are not fundamentally in conflict with regional planning processes. Furthermore, the City’s proposed net increase of 12,312 dwelling units is consistent and slightly less than historical trends that show an increase in approximately 5,400 over a ten year period from 2000 to 2010 (see Table 5.10-1 in the DEIR).
Additionally, as the commenter correctly indicates, the General Plan Update has the potential to provide affordable units well in excess of its Regional Housing Needs Assessment (RHNA) target of 1,332 units for the 2014–2021 period. However, the City’s RHNA target is based on the affordability needs of certain economic segments of the population. The RHNA is an estimation of a jurisdiction’s housing need for a specific period of time, which uses a different horizon year than General Plan buildout.
As discussed in Section 5.10.3, Population and Housing, of the DEIR, the EIR analyzed growth with respect to balancing jobs and housing in the City and the region and determined that impacts related to population growth would be less than significant.
Refer also to response to Comment A1-4.
A1-4 The EIR analysis is required to analyze buildout of the General Plan. Buildout includes development allowed by the development caps for each specific plan area, development allowed in areas outside of the specific plans, and buildout of projects approved but not
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
3. Response to Comments
August 2015 Page 3-19
yet built. In addition, the City added additional units to account for affordable units that may be developed based on historical trends.
See response to Comment A1-3. Although the EIR is required to analyze buildout, actual development is based on various development constraints including but not limited to market demand at the time of development, lot configuration, environmental constraints, more restrictive development standards, parking limitations, among other factors. Therefore, actual growth is anticipated to be less than what was assumed for buildout.
However, even assuming the worst case growth analyzed in the EIR, population increases would not result in a significant environmental impact. As discussed in Section
5.10.3, Population and Housing, of the DEIR, buildout of the General Plan Update accommodates the growth projected for the San Gabriel Valley region. As stated, buildout would result in an increase of 27,473 residents. Although this exceeds population projections for the City, it is within the overall growth assumed in the San Gabriel Valley. Accommodating regional growth within Pasadena’s specific plan areas is supportive of State legislation (AB 32, SB 375, and SB 743) and SCAG’s 2012 Regional Transportation Plan/Sustainable Communities Strategy which aims to place residents near employment centers and transit areas. The General Plan Update places higher density development and mixed use opportunities along major transportation corridors, near transit and employment centers. Furthermore, population growth would provide a more balanced jobs and housing ratio for the region. The environmental impacts of growth in the City are adequately evaluated throughout the DEIR.
A1-5 The commenter states that the General Plan Update allows more growth than current trends and is more growth friendly than the existing General Plan. This comment is noted and will be provided to the decision-making body as part of the consideration of the General Plan Update adoption, as this is not a comment on the adequacy of the environmental analysis.
A1-6 Although Policy 1.4 allows transfer of development capacity, it does not allow exceedance of development caps. If a project transfers development capacity in the form of residential units to another site, that transfer is subject to the development caps and respective Specific Plan requirements and would not be permitted if the caps were to be exceeded.
The General Plan Update is not proposing to relax parking requirements and cannot tie the hands of future legislative action as a matter of law. The parking goals and policies in the proposed Land Use Element are intended to support walkability, healthy and sustainable communities, transit support, and protection of residential neighborhoods, among other goals. These policies will not result in an exceedance of development caps.
Further, this is not a comment on the adequacy of the environmental analysis.
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADE N A
3. Response to Comments
A1-7 The EIR does not mask the environmental impacts of growth associated with the General Plan Update. A comparison of the adopted general plan with the General Plan Update (Preferred Project) was provided as an alternative in Section 7.4 of the EIR, as required by CEQA. The primary source of greenhouse gas (GHG) emissions from project buildout is due to transportation emissions. Mobile source GHG emissions are based on vehicle miles traveled (VMT). Although the no project alternative would result in a reduction in overall building intensity, it would result in an increase in overall VMT as modeled by Fehr & Peers in the Traffic Analysis Report for the General Plan Update (see Appendix I of the EIR).
VMT is a measure of the total distance traveled by automobile, reflecting both the number of auto trips and the length of each auto trip made. Trip length is dependent on a number of factors that are included in the travel demand model, including but not limited to proximity of homes to job generating land uses, proximity to transit centers, socio-economic characteristics, and provision of multimodal transportation infrastructure. The proposed land use diagram and mobility element were developed to allow growth while reducing trip length and overall VMT.
The travel demand model was used to assess the interaction between land uses and the resulting automobile trips. The results of VMT Per Capita and VT Per Capita analysis, presented in the transportation section of the DEIR, were computed using the City of Pasadena's Citywide Travel Demand Model with different land use inputs for each scenario. This model has been calibrated and validated to Caltrans Travel Forecasting Guidelines and exceeded all of the validation standards, resulting in a locally valid model for Pasadena. Travel demand model documentation for the Pasadena model was included in the DEIR appendix.
Additionally, the VMT Per Capita, VT Per Capita CEQA, Bicycle, Pedestrian and Transit metrics and thresholds were adopted by City Council on November 3, 2014. Because these transportation and traffic thresholds are expressed per unit of population and employment, it is reasonable for an increase in residents and employment to result in decreased per-capita values.
Impacts related to hazards and hazardous materials, hydrology and water quality, land use and planning, and population and housing would be similar to the project but slightly greater due to the reasons set forth in Sections 7.4.6, 7.4.7, 7.4.8, and 7.4.10, respectively.
A comparison of air quality impacts are analyzed in Section 7.4.2 of the EIR. As discussed, the No Project/Adopted General Plan Alternative would result in a reduction of air quality emissions from construction and operation emissions. The summary provided in 7.4.15, Conclusion and Table 7-19 of the EIR was incorrect. These typographical errors have been corrected as follows:
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
3. Response to Comments
August 2015 Page 3-21
Section 7.4.15, Conclusion, 1st paragraph (Page 7-15 of the DEIR):
The No Project/Adopted General Plan Alternative would have similar impacts for aesthetics, biological resources, cultural resources, and noise. Impacts would be reduced for air quality, public services, recreation, and utilities and service systems. This alternative would result in an increase in impacts to air quality, GHG emissions, hazards and hazardous materials, hydrology and water quality, land use and planning, population and housing, and transportation and traffic. Significant unavoidable adverse impacts identified by the proposed project for air quality, GHG emissions, and noise would not be eliminated. Although this alternative would eliminate the CMP arterial intersection impact at Pasadena Avenue and California Boulevard, it would create a new significant impact at Rosemead Boulevard and Foothill Boulevard. This alternative would also create a new significant impact by increasing VMT per capita over existing.
Table 7-19 on page 7-39 of the DEIR:
Table 7-19 Comparison of Alternatives to the Proposed Project Environmental
Resource Area Project
No Project/Adopted
General Plan
Alternative
Central District, South Fair
Oaks, and Lincoln Avenue
Alternative
Efficient
Transportation
Alternative
Reduced Air Quality
and Noise Impact
Alternative
Aesthetics LTS 0 0 0 0
Air Quality S/U +- - - -
Biological Resources LTSM 0 0 0 0
Cultural Resources LTSM 0 - 0 0
GHG S/U + - - +
Hazards and Hazardous
Materials LTS + - 0 +
Hydrology and Water
Quality LTS + 0 0 0
Land Use and Planning LTS + 0 0 -
Noise S/U - - - 0
Population and Housing LTS + 0 0 0
Public Services LTS - - - +
Recreation LTS - - - +
Transportation and
Traffic S/U +1 0 0 -
2 Utilities and Service
Systems LTS - - - +
LTS – Less Than Significant
LTSM – Less Than Significant with Mitigation
S/U – Significant and Unavoidable
(+) = Impact considered greater when compared with the proposed project. (0) = Impact considered neutral when compared with the proposed project. (–) = Impact considered less when compared with the proposed project. 1 The No Project/Adopted General Plan Alternative eliminates one significant unavoidable CMP arterial intersection impact at Pasadena Avenue and California Boulevard. However, it would create a new significant unavoidable CMP impact at Rosemead Boulevard and Foothill Boulevard and a new significant impact by increasing VMT per capita over existing. 2 The Reduced Air Quality and Noise Impact Alternative eliminates one significant unavoidable CMP arterial intersection at Pasadena Avenue and California Boulevard. However, like the proposed project this alternative would result in the following significant CMP impacts: a significant impact on I-210 w/o Rte 134/710 in the PM peak hour for westbound lanes and on I-210 w/o Rosemead Boulevard in the AM peak hour for westbound lanes.
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADE N A
3. Response to Comments
A1-8 Refer to Section 2.1, Transportation Metrics. Further, the City must abide by the thresholds of significance approved by the Council and based on the evidence presented by staff throughout the required public review process.
A1-9 Refer to response to Comment A1-7. Although the vehicle miles traveled (VMT) result calculated for the proposed General Plan Update is approximately 0.6 percent less than the VMT result for No Project/Adopted General Plan Alternative, the number of vehicle trips (VT) for the proposed General Plan Update is approximately 1.3 percent greater. The larger population and employment of the proposed General Plan Update would generate more vehicle trips than the No Project/Adopted General Plan, but because more trips can be accomplished within closer proximity, the average trip length for the proposed General Plan Update would be shorter, resulting in fewer total VMT.
No Project/Adopted General Plan is not an intermediate state between present conditions (2014) and the buildout of General Plan Update because the proposed General Plan Update represents a different mix, intensity, and spatial distribution of land uses from No Project/Adopted General Plan.
A1-10 The commenter states that the proposed land uses are more pro-development than the majority of Pasadena residents prefer. This comment relates to the land uses, mobility improvements, and policies proposed by the General Plan Update, not the potential environmental impacts of the project. However, the comment is noted and will be provided to the advisory and decision-making bodies as part of the consideration of the General Plan Update adoption.
A1-11 The City prepared a Draft Bicycle Transportation Action Plan in April 2015, which is anticipated to be adopted following approval of the General Plan Update. The City appreciates the commenter’s observations and input related to improving the bicycle experience on Wilson Avenue. Specific treatments to manage vehicle speeds and volumes on Wilson have not yet been determined and will be the result of significant community input. The comment is noted and will be provided to the decision-making body (City Council) as part of the consideration of the General Plan Update adoption.
A1-12 The road diets and addition of bicycle lanes on Washington Boulevard, Orange Grove Boulevard, and Cordova Street are not inconsistent with the bikeway classifications presented on Figure 5.13-4. The commenter is correct that Figure 5.13-4 does not include a bicycle lane on Washington Boulevard between Altadena Drive and Sierra Madre Boulevard. Per the commenter’s request, Figure 5.13-4, Future Bicycle Network has been revised to reflect this segment (shown below). Please note that this segment was not included in the Proximity and Quality of Bicycle Network calculations. However, adding this segment of Washington Boulevard would improve the value of the metric for all future scenarios and no new impacts would occur. This figure already includes
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
3. Response to Comments
August 2015 Page 3-23
Orange Grove Boulevard between Allen Avenue and Sierra Madre Villa Avenue as a Level 2 Facility, a category that includes Buffered Bike Lanes, Bike Lanes, and Bike Boulevards.
A1-13 The commenter states that the categorization of facilities is confusing and should reconsider the use of standard Caltrans notation (i.e. Class I, Class II, etc). The focus of the proposed categories is to characterize the comfort of the facility for bicyclists, which provides a measure of the quality of the facility for bicyclists. For purposes of the Proximity and Quality of Bicycle Network metric, bicycle facilities are categorized according to the quality of the bicycling environment that they afford people riding bicycles. Bike Paths, Multipurpose Paths, and Cycle Tracks or Protected Bike Lanes are assigned to Level 1 because they offer more protection and amenities to people riding bicycles than Level 2 or Level 3 facilities do. Buffered Bike Lanes, Bike Lanes, and Bike Boulevards are assigned to Level 2 because they provide less separation from traffic than the Level 1 facilities do, but provide a higher-quality bicycling environment than Level 3 facilities (Bike Routes, Enhanced Bike Routes, and Emphasized Bikeways).
A1-14 The commenter is requesting additional information on the City’s plans for east-west bicycle facilities along Orange Grove Boulevard and Washington Boulevard. The proposed General Plan Update includes buffered bike lanes on Orange Grove Boulevard from Sierra Madre Boulevard to the south city limits. To accommodate a buffered bike lane in each direction of Orange Grove Boulevard, a road diet (removal of one vehicle travel lane in each direction) would be implemented along this stretch of Orange Grove Boulevard. The General Plan Update also includes buffered bike lanes on Washington Boulevard between El Molino Avenue and Forest Avenue. To accommodate a buffered bike lane in each direction along this portion of Washington Boulevard a road diet (removal of one vehicle travel lane in each direction) would be implemented along this stretch of Orange Grove Boulevard. See also response to Comment A1-12.
A1-15 The evaluation of aesthetic and historic resources impacts related to land uses changes adjacent to Bungalow Heaven was provided in Sections 5.1 .3 and 5.4.3 of the DEIR.
For example, Page 5.1-44 of Section 5.1.3 discusses how development capacity in the North Lake Specific Plan Area—which is adjacent to Bungalow Heaven—would allow redevelopment in the corridor but at a scale that would not drastically change the neighborhood’s character, overall appearance, or views of the San Gabriel Mountains.
Proposed Land Use Element Policies 4.11, 4.12, 6.2, and 36.4 would ensure that new projects along North Lake Avenue would be designed to be context sensitive. In particular, Land Use Policy 36.4 would require project applicants to design their projects to respond to the character of adjoining lower density residential neighborhoods.
Section 5.4.3 of the DEIR discloses that there would be potential redevelopment near the Bungalow Heaven Landmark District, but also that existing City procedures and proposed Land Use policies would minimize any visual effects on existing historic
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADE N A
3. Response to Comments
resources. In addition to the aforementioned policy regarding compatibility between new projects and adjacent low density residential neighborhoods (Policy 36.4), implementation of Land Use Policy 8.5 would ensure that new structures within landmark and historic districts also are designed to be context-sensitive. The policy requires project applicants to demonstrate that their project is sensitive to its contextual relationship with “land uses and patterns, spatial organization, visual relationships, cultural and historic values, and relationships in height, massing, modulation, and materials.” New development would be required to comply with the City’s Design Guidelines for Historic Districts and new projects in the North Lake corridor would be required to adhere to provisions of the North Lake Specific Plan, which address height, massing, and setbacks via design guidelines and development standards.
A1-16 Refer to Section 2.2, Density Bonus. A significant impact to a historic district would result if the project would result in a substantial adverse change (physical demolition, destruction, relocation, or alteration) such that it would be materially impaired. An impact to a historic district would not occur unless it would destroy the district’s collective integrity. Therefore, even if a new development were constructed adjacent to a historic district or if development affected one element (or building) within a historic district, it would not result in a significant impact unless the project made the district ineligible for historic listing. As discussed in response to Comment A1-15 and DEIR Section 5.4.3, buildout of the General Plan Update in accordance with the proposed Land Use Diagram would not result in a significant impact to a historic district.
A1-17 The City agrees with the commenter’s statement that Bungalow Heaven is a historic resource and Landmark District, as documented throughout the DEIR. No further response is necessary.
A1-18 Impacts to historic resources are well defined in CEQA Guidelines Section 15064.5(b).
A project has a significant impact on a historic resource if it “would result in the physical demolition, destruction, relocation, or alteration of the resource or its immediate surroundings such that the significance of an historical resources would be materially impaired” (CEQA Guidelines Section 15064.5(b)(1)). Material impairment would occur if the project would result in demolition or material alteration of those physical characteristics that convey the resource’s historical significance (CEQA Guidelines Section 15064.5(b)(2)). The integrity of a resource is evaluated based on a number of factors, including location, design, setting, materials, feeling, association, and workmanship.
Edel Mar Blvd
ECalifornia Blvd
N Lake Ave
N Fair Oaks Ave
N Hill Ave
EMountain St
NewYork Dr
N Altadena Dr
E Orange Grove Blvd
San PasqualSt
EWashington Blvd
Linda Vista Ave
EFoothill Blvd
E Green St
L ni co nl Ave
N FigueroaSt
N Los Robles Ave
Meridian St
SLos Robles Ave
Duarte Rd
LidaSt
MadreSt
Foothill Blvd
Colorado Blvd
Virginia Rd
MountWilson Red Box Rd
laLoma Rd
Longden Ave
N Arroyo Blvd
SLake Ave
Highland Dr
Mission St
S Arroyo Blvd
Monterey Rd
Crown Ave
Yosemite Dr
ESierra Madre Blvd
Huntington Dr
EWoodbury Rd
EChevyChase Dr
EMendocinoSt
S Hill Ave
Berksh ire Ave
S Orange Grove Blvd
San Pasqual Ave
Windsor Ave
S Al el n Ave
WAltadena Dr
del Mar Ave
StarlightCrest Dr VenturaSt
N San Gabriel Blvd
S Michill ni da Ave
ELoma Alta Dr
N Rosemead Blvd
N Allen Ave
Wdel Mar Blvd
Arroyo Dr
N Marengo Ave
WGreen St
WGrandview Ave
Fair Oaks Ave
EWalnutSt
Oak Grove Ave
Ave64
N Fair Oaks Ave
Sierra Madre Blvd
S Michillinda Ave
Lake Ave
§¨¦210
§¨¦210
§¨¦210
§¨¦210
·|}þ134
\\fpla1\data\Jobs\Active\2600s\2631 - Pasadena GP EIR\Graphics\GIS\MXD\F5_2035BikeNetwork.mxd 2035 Bicycle Network
Figure 5
Bicycle Facilities Hierarchy
11%
55%
24%
10%
Level 1 - Advanced Facilities Includes BikePaths (P1),MultipurposePaths(PP),CycleTracks/Protected Bike Lanes Level 2 - Dedicated Facilities
Includes Buffered BikeLanes, BikeLanes (2,P2), Bike Boulevards (BB) Level 3 - BasicFacilities
Includes Bike Routes (3,P3),Enhanced Bike Routes (E3,PE3),Emphasized Bikeways (PEB) Source: Fehr & Peers, 2015
5. Environmental Analysis
Figure 5.13-4
Future Bicycle Network
CITY OF PASADENA
GENERAL PLAN UPDATE
DRAFT EIR PRA-06.0L 7/9/2015
NOT TO SCALE
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADE N A
3. Response to Comments
This page intentionally left blank.
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
3. Response to Comments
August 2015 Page 3-27
Bungalow heaven is a landmark district that qualifies as a historic resource pursuant to Section 15064.5. When evaluating whether a new project would impact a historic district a number of factors are considered, including but not limited to, the criteria for its listing on the National or State Register, its boundaries and context, architectural design, and its contributing elements. The City’s Design Guidelines for Historic Districts would address impacts related to the district’s integrity – visual setting, feeling, and association –and policies would ensure that no new project would destroy an essential existing element. Furthermore, SB 1818 concessions cannot be granted if a project impairs a historic resource as set forth in Section 2.2, Density Bonus and response to Comment A1-
20. A1-19 Land use changes allowing mixed uses and affordable housing has been adequately analyzed throughout the entire DEIR and support the proposed Land Use Element goals and policies. The application of the Low and Medium Mixed Use General Plan designations to the North Lake Specific Plan area is designed to provide designations consistent with the existing specific plan development standards. The proposed land use change along North Lake Avenue between East Washington Boulevard and East Mountain Street is not expected to result in a change in the number of affordable housing units from what is currently allowed. This area is currently zoned in the North Lake Specific Plan as SP-1a and SP-1b, which already allows for mixed-use and work/live units.
The proposed General Plan Update does not change the development standards, including height limits in the North Lake Specific Plan. Current zoning and land use categories permit by right mixed use and multi-family development in the two subareas between East Mountain and East Washington. These projects can currently utilize the development concession described in SB1818. Therefore, the General Plan Update is not providing new opportunities for density bonus for these areas that does not already exist. Instead it is supporting the continued use of mixed use and multi-family projects to provide affordable housing, attract investment to create facilities and infrastructure improvements, while imposing a series of strict design and compatibility standards and public participation through the discretionary review and approval process. Impacts related to aesthetics, historic resources, and land use have been adequately analyzed in the DEIR.
A1-20 The commenter states that allowing mixed uses within the North Lake Specific Plan area is inconsistent with many proposed general plan goals and policies. Goals and policies that direct development to specific plan areas and corridors and protect historic neighborhoods are not mutually exclusive and do not conflict. The table below demonstrates the internal consistency between the guiding principles, goals, and policies identified by the commenter.
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADE N A
3. Response to Comments
Table A1.1 Internal Consistency of Proposed Land Use Element and Land Use Diagram Principle, Goal, or Policy Identified by Commenter
Response to Comments Regarding
Internal Consistency
Guiding Principles
Land Use Principle 1: Growth will be targeted to serve community needs and enhance the quality of life. Higher density development will be directed away from residential neighborhoods and into the Central District, Transit Villages, and Neighborhood Villages. These areas will have a diverse housing stock, job opportunities, exciting districts with commercial and recreational uses, and transit opportunities. New development will build upon Pasadena’s tradition of strong sense of place, great neighborhoods, gardens, plazas, parks, and trees.
Consistent. Despite the fact that the Central District comprises only 5.4 percent of Pasadena’s 14,803-acre area, the Central District Specific Plan area would accommodate 50 percent of the City’s net growth at buildout under the General Plan Update. This deliberate targeting of growth into the Central District and adjacent transit villages was designed to direct growth away from lowerdensity residential neighborhoods such as Bungalow Heaven.
At buildout, the North Lake Specific Plan area would represent a small percentage of the City’s projected growth and does not represent a major intensification of uses in north-central Pasadena.
Land Use Principle 2: Pasadena’s historic resources will be preserved. Citywide, new development will be in harmony with and enhance Pasadena’s unique character and sense of place. New construction that could affect the integrity of historic resources will be compatible with, and differentiated from, the existing resource.
Consistent. As discussed in Section 5.4, Cultural Resources, of the DEIR, the City’s historic resources, including those in Bungalow Heaven, are protected by an extensive collection of federal, state, and local regulations. Redevelopment along the North Lake Avenue corridor would be required to comply with design guidelines found in the North Lake Specific Plan, citywide design guidelines, and General Plan policies related to community compatibility. Furthermore, the City has a robust design review process that takes into consideration the historic and aesthetic integrity of existing neighborhoods. The General Plan Update’s proposal to encourage existing Mixed Use opportunities along North Lake Avenue does not, alone, represent a substantial threat to the preservation or integrity of an adjacent historic neighborhood.
Goals and Policies
Policy 1.1: Basic Growth Policy. Accommodate growth that is consistent with community values and that complements the scale and character of Pasadena’s unique residential neighborhoods, business districts, and open spaces.
Consistent. See responses to Land Use Principles 1 and 2. The General Plan Update seeks to align its proposed development intensities and uses with the existing regulations in the Specific Plan. Most of the North Lake Avenue corridor, especially those areas outside of Neighborhood Villages at major intersections, would only accommodate development at an intensity and scale that is compatible with the surrounding neighborhood. The proposed General Plan encourages existing Mixed Use
opportunities at scales that are generally consistent with the existing Specific Plan Development Standards.
Policy 1.2: Targeted Growth. Target growth and new construction in infill areas and away from Pasadena’s residential neighborhoods and open spaces by redeveloping underutilized commercial and industrial properties, especially within the Central District, Transit Villages, Neighborhood Villages, and along selected corridors.
Consistent. As indicated in the response to Land Use Principle 1, the General Plan Update heavily targets growth in areas of the Pasadena that are already heavily urbanized and/or currently dominated by nonresidential uses. Approximately 84 percent of the growth allowed under the General Plan Update would occur in Specific Plan areas, which are almost entirely mutually exclusive from single-family residential neighborhoods. The modest growth allowed in the North Lake Specific Plan area under the proposed General Plan is consistent with Policy 2.1, which clearly states that some growth would be targeted toward underutilized properties “along selected corridors.”
Policy 4.11: Development that is Compatible. Require that development demonstrates a contextual relationship with neighboring structures and sites addressing such elements as building scale, Consistent. As indicated in previous responses, the scale and type of redevelopment allowed in the North Lake Specific Plan area under the General Plan Update is not a substantial departure
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
3. Response to Comments
August 2015 Page 3-29
massing, orientation, setbacks, buffering, the arrangement of shared and private open spaces, visibility, privacy, automobile and truck access, impacts of noise and lighting, landscape quality, infrastructure, and aesthetics.
from existing Specific Plan development standards along the corridor. Furthermore, development and redevelopment would be required to comply with applicable design guidelines and development standards enforced by the City, which devote considerable attention to issues of community compatibility, content-sensitive design, and the other design considerations listed under Policy 4.11.
Policy 4.12: Transitions in Scale. Require that the scale and massing of new development in higher-density centers and corridors provide appropriate transitions in building height and bulk and are sensitive to the physical and visual character of adjoining lowerdensity neighborhoods.
Consistent. Under the General Plan Update, higher-density development is concentrated in the Central District and a handful of other nodes that are already heavily urbanized. As shown in the proposed Land Use Diagram, commercial and mixed uses allowed in the North Lake corridor deliberately step down from Medium Mixed Use (at Villa Street and Washington Boulevard) to Low Commercial and Low Mixed Use along the middle stretch of the corridor as a response to the character of adjoining lower-density neighborhoods. Appropriate transitions in building height and bulk between the North Lake interface and the rear of each applicable parcel would be evaluated by the City on a project-level basis as redevelopment projects are proposed.
Goal 6: Character and Scale of Pasadena. A built environment that evolves while maintaining Pasadena’s unique sense of place, character, and the urban fabric.
Consistent. Throughout the proposed Land Use Element, great attention is devoted to character and scale, as demonstrated by the comprehensiveness of the policies identified in this table. The proposed Land Use Diagram is consistent with these policies by proposing no land use changes in Bungalow Heaven. New
development proposed in the North Lake corridor under the General Plan Update would only result in infill along an existing commercial corridor. It would not dramatically alter the character or urban fabric of the North Lake Avenue Specific Plan area.
Policy 6.1: Sense of Place and History. Require new development and changes to existing development to be located and designed to respect the defining elements of Pasadena’s character and history such as its grid street pattern, block scale, public realm, neighborhoods and districts, building massing and heights, significant architecture, and relationship to the mountains and Arroyo Seco.
Consistent. The North Lake Specific Plan area generally consists of a single row of parcels on either side of North Lake Avenue. Infill development along the corridor would not alter the street pattern, block scale, or neighborhood fabric of the area. Furthermore, the maximum FARs allowed along the corridor would not be expected to affect existing views north to the San Gabriel Mountains.
Policy 6.2: Established Neighborhoods. Preserve, protect, and enhance established residential neighborhoods by providing sensitive transitions between these and adjoining areas. Require new development to respect and respond to the existing physical characteristics that contribute to the overall character and livability of the neighborhood.
Consistent. See response to Policy 4.12, above.
Policy 7.3: Compatibility. Require that new and adaptively re-used buildings are designed to respect and complement the defining built form, massing, scale, modulation, and architectural detailing of their contextual setting.
Consistent. Adoption of the General Plan Update does not involve the approval of specific development projects. Accordingly, the proposed Land Use Diagram itself does not affect the architectural character of the corridor or surrounding neighborhoods. The built form, massing, scale, modulation, and architectural details of individual projects would be evaluated by the City on a projectlevel basis.
Goal 8: Historic Preservation. Preservation and enhancement of Pasadena’s cultural and historic buildings, landscapes, streets and districts as reminders of its past and a source of community identity, and social, ecological, and economic vitality.
Consistent. The General Plan Update does not propose land use changes—or other changes to the urban fabric—in Bungalow Heaven precisely to preserve the community identity of the area as a historically and aesthetically important neighborhood.
Policy 8.1: Identify and Protect Historic Resources. Identify and protect historic resources that represent significant examples of the City’s history.
Consistent. The General Plan Update and the DEIR both identify Bungalow Heaven as an important historic resource. No land use changes are proposed for the district in the proposed Land Use Diagram. Furthermore, as demonstrated by the policies listed in this table, the text of the proposed Land Use Element gives
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADE N A
3. Response to Comments
considerable attention to the protection of historic resources.
Policy 8.5 Scale and Character of New Construction in a Designated Landmark and Historic Districts. Promote an
architecturally sensitive approach to new construction in Landmark and Historic districts. Demonstrate the proposed project’s contextual relationship with land uses and patterns, spatial organization, visual relationships, cultural and historic values, and relationships in height, massing, modulation, and materials.
Consistent. The General Plan Update does not propose new construction projects or increase in development capacity within Bungalow Heaven. Individual projects pursued in the district under the General Plan Update would be evaluated by the City on a project-level basis for their consistency with Policy 8.5 and the broad range of applicable federal, state, and local regulations regarding development in landmark and historic districts.
Policy 21.3: Neighborhood Character. Maintain elements of residential streets that unify and enhance the character of the neighborhood, including parkways, street trees, and compatible setbacks.
Consistent. There are no changes to the physical elements of local streets in Bungalow Heaven proposed in the General Plan Update. Because there is no street widening, reconfiguring of rightof-way, or additional development capacity planned on the streets that traverse the historic district, the parkways, street trees, and setbacks are expected to remain unchanged during the planning period of the General Plan Update.
Goal 22: Single-Family Neighborhoods. Distinct and quality singlefamily residential neighborhoods distinguished by their identity, scale, and character.
Consistent. The General Plan Update was built around the idea of preserving the identity, scale, and character single-family neighborhoods. Accordingly, no land use changes or additional development capacity are planned for Bungalow Heaven.
Policy 25.4: Architecture and Site Design. Require that new development protect community character by providing architecture, landscaping, and urban design of equal or greater quality than existing and by respecting the architectural character and scale of adjacent buildings.
Consistent. The premise of Policy 25.4 is specifically aimed at requiring the design of new projects to be respectful of their surroundings. The General Plan Update does not propose—or involve the approval of—any specific development projects. The proposed Land Use Diagram merely prescribes the overall type and scale of land uses that would be allowed along the North Lake Avenue corridor. The architecture, landscaping, and urban design of new projects would be evaluated by the City on a project-level basis for their consistency with Policy 25.4 and other design guidelines and standards.
Policy 36.4: Neighborhood Compatibility. Require that the types of use and location, scale, and design of development buffer commercial and mixed-use development on Lake Avenue from adjoining lower density residential neighborhoods.
Consistent. The types of uses allowed in the North Lake Specific Plan area were specifically chosen to respond to the character of lower density residential neighborhoods on either side of the corridor. For example, while Medium Mixed Use development is allowed at the major intersections of North Lake/Villa Street and North Lake/Washington Boulevard, most of the 1-mile stretch of corridor between these intersections (which travels between Bungalow Heaven and other single-family residential
neighborhoods to the west) allows lower-scaled development in the Low Mixed Use and Low Commercial land use categories.
Although the proposed Land Use Diagram would allow new uses with specific FARs adjacent to landmark and historic districts, new development would still need to comply with the North Lake Specific Plan and development standards (e.g., height, massing, and setback limitations) in Municipal Code Section 17.34.040 and the Urban Design, Sense of Place, and Architectural policies in the Land Use Element.
A1-21 BHNA submitted a comment letter during the 30-day public review period for the Notice of Preparation (NOP). Formal responses to NOP comment letters were not prepared and are not required by CEQA. Table 1-4 in the DEIR identifies that the BHNA letter dated October 10, 2013 was received, summarizes the issues, and indicates where those issues are addressed in the DEIR. The commenter states that the DEIR
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
3. Response to Comments
August 2015 Page 3-31
fails to address the concerns in the October 10, 2013 but does not explain how. This letter brings up the same issues as discussed in Comment Letter A1, which are being addressed herein. No further response is necessary.
A1-22 Please refer to Section 2.2. The commenter states that allowing higher density, mixeduses within North Lake Specific Plan is inconsistent with General Plan Objectives 1, 3 and 4. However, the proposed land uses is not inconsistent with these objectives because it directs growth near transit opportunities and corridors while preserving established neighborhoods. It is not clear from the comment how the proposed land uses would affect the sense of place or great neighborhoods characterized by Bungalow Heaven.
This comment relates to the General Plan Update and Draft Land Use Element, not the potential environmental impacts of the project. However, the comment is noted and will be provided to the decision-making body (City Council) as part of the consideration of the General Plan Update adoption.
The commenter appears to state that State Density Bonus Law conflicts with Pasadena’s General Plan. State Density Bonus Law applies to all cities in California, including charter cities. In that way, State Density Bonus Law overrides local development plans, goals, policies, and standards for applicable density bonus projects. The City cannot, pursuant to state law and rules of statutory construction, elevate its General Plan goals and policies over State Density Bonus Law.
A1-23 Please refer to Section 2.2, State Density Bonus Law.
A1-24 The General Plan Update would not change land uses within Bungalow Heaven. The aesthetic impacts associated with land use changes along North Lake Avenue were adequately analyzed at Page 5.1-41 and 5.1-44 of the DEIR. Impacts were found to be less than significant; therefore no mitigation measures were required.
A1-25 The commenter is correct in stating that Bungalow Heaven is considered a historical resource according to CEQA Guidelines Section 15064.5.
A1-26 Please refer to Section 2.2, State Density Bonus Law.
A1-27 The proposed Land Use Element contains a number of goals and policies to protect historic resources, including Goal 8 and Policies 8.1 through 8.10. It is the City’s intent to protect historic resources and to ensure that new construction is consistent with the scale and character of designated landmark and historic districts. There is no evidence to show that these policies or the allowance of mixed use in the North Lake Specific Plan would result in a decline in historic integrity or value in Bungalow Heaven. The purpose of the proposed General Plan Policies are to allow development to occur in the higher density areas, corridors, and transit areas, while creating compatibility with established single family residential neighborhoods. Specifically, proposed General Plan Policy 36.4 requires that the type of land use, location, and scale within North Lake Specific Plan
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADE N A
3. Response to Comments
buffers the commercial and mixed-use development from lower density residential neighborhoods.
A1-28 Section 15126.6(a) of the CEQA Guidelines indicates that the purpose of analyzing project alternatives is to identify alternatives that would “…avoid or substantially lessen any of the significant effects of the project.” The DEIR found that aesthetic and historic impacts of the proposed project would be less than significant. Therefore, the range of project alternatives was developed based on their potential ability to reduce impacts to documented potentially significant impacts. For the proposed project, these included impacts related to air quality, greenhouse gas emissions, noise, and traffic (see Chapter 6 of the DEIR for a list of the project’s significant unavoidable adverse impacts). For a comprehensive response to concerns regarding SB 1818, see Section 2.2 of this FEIR.
A1-29 For the reasons enumerated above and the analysis provided in the DEIR and Section
2.2 of this FEIR, the City disagrees that the General Plan Update would result in significant aesthetic and historic impacts to Bungalow Heaven. However, the recommendation to change land uses in the North Lake Specific Plan will be provided to the decision-making body (City Council) as part of the consideration of the General Plan Update adoption.
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
3. Response to Comments
August 2015 Page 3-33
LETTER A2 –CalTrans (3 pages)
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADE N A
3. Response to Comments
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
3. Response to Comments
August 2015 Page 3-35
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADE N A
3. Response to Comments
This page intentionally left blank.
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
3. Response to Comments
August 2015 Page 3-37
A2. Response to Comments from Caltrans, dated March 23, 2015.
A2-1 Caltrans reviewed the General Plan Update and EIR and provided comments related to traffic. Responses are detailed in A2-2 through A2-8 below.
A2-2 Prior to the release of the General Plan Update, the City of Pasadena undertook an extensive process to develop new transportation metrics and CEQA thresholds of significance (refer to Section 2.1). As part of this process, the City evaluated a number of different metrics and thresholds and received community input through a series of public meetings. The City Council subsequently approved a set of CEQA thresholds that were developed to evaluate a wide range of transportation-related impacts. Those CEQA thresholds define what constitutes a significant impact in the City of Pasadena and require land use development not to exceed existing thresholds based on VMT Per Capita, VT Per Capita, service population within a ¼ mile of bicycle or transit facilities, and citywide pedestrian accessibility score.
The VMT Per Capita calculations were based on the use of a locally validated travel demand model (developed per the Caltrans travel demand modeling guidelines) that provides a finer level of detail than a regional model for VMT traveling on Pasadena facilities both for internal trip making and external trips that begin or end in Pasadena.
The regional VMT per Capita is based on a much larger six County area (Los Angeles County, Orange County, Riverside County, Imperial County, San Bernardino County and Ventura County) and as a result the Pasadena Existing VMT Per Capita is more accurate at a local level.
By comparing VMT per capita and VT per capita changes against the existing values for the City, the City is committing to improving its own VMT per capita and VT per capita outcomes, rather than relying on comparisons to regional values, which are influenced by external land use and transportation decisions that are largely beyond the City’s ability to control. Improving the City’s values for these metrics will contribute to improving the regional values.
In order to address Caltrans concerns, the City proposed new General Plan policies as follows:
New Policy City of Pasadena will monitor and evaluate the development and adoption of future VMT per capita thresholds for the SCAG region and Los Angeles County.
New Policy City of Pasadena will involve Caltrans in the revision and update of the existing Transportation Impact Fee.
New Policy City of Pasadena will consider improvements to ITS projects involving Caltrans owned intersections at freeway ramp termini in the development of the
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADE N A
3. Response to Comments
future transportation impact fee, including but not limited to the I-210 Connected Corridors project.
A2-3 The State Office of Planning and Research (OPR) is proposing to add a new Section 15064.3 in the CEQA Guidelines. However, the language is in the draft stage, OPR is in the process of evaluating numerous public comments, and the new guidelines have not yet been adopted. The DEIR was evaluated based on the City’s adopted thresholds of significance, as described in response to Comment A2-2.
The DEIR for the Pasadena General Plan Update is a program level analysis that evaluates transportation impacts associated with a future land use plan. The detail provided in this document is less detailed than a Project EIR, which evaluates impacts of a specific land use development. The program level EIR focuses on the secondary effects that can be expected to follow the adoption of the General Plan, but is not required to be as detailed as individual development project EIRs in its analysis, including queuing on all freeway off-ramps. In order to address Caltrans’ concern that future developments should assess any impacts to increased queuing on freeway offramps, the city will administratively amend the Transportation Analysis Guidelines (see Appendix A of this FEIR) as follows:
All projects of “communitywide significance” (communitywide significance projects are defined as 50,000 square feet of new commercial use, 50 residential units, or any combination of the two) will require consultation with Caltrans to determine whether or not additional analysis is needed regarding off-ramp queuing conditions. The analysis may lead to conditions of approval being placed on the project to reduce the queuing length on the off-ramps.
A2-4 Level of Service (LOS) thresholds F(0), F(1), F(2), and F(3) are reported in the Congestion Management Program (CMP) analysis in accordance with the 2010 Congestion Management Program for Los Angeles County Exhibit D-6 "General Procedure for Freeway Segment (Mainline) Analysis" (page D-39). Therefore, Table 13 will remain as is consistent with the CMP.
A2-5 The City appreciates Caltrans input on innovative strategies to solve transportation impacts on freeways. The City met with Caltrans on May 13, 2015 to address this issue and the City expects ongoing coordination between the jurisdictions.
The City of Pasadena’s Draft Mobility Element has three main objectives:
1. Enhance livability
2. Encourage walking, biking, transit and other alternatives to motor vehicles
3. Create a supportive climate for economic viability
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
3. Response to Comments
August 2015 Page 3-39
The analysis undertaken for the City of Pasadena’s General Plan Update, Draft Mobility Element, and Land Use Element has shown that Vehicle Trips Per Capita and VMT Per Capita are reduced when compared to existing levels. The Mobility Element has a series of policies that are aimed at the promotion and use of alternatives to the automobile, as well as trip reducing policies such as car sharing. The objectives and policies have been developed to provide alternatives for both local and regional trip making, where possible, reducing trips.
Regarding the specific comment on the I-210 congestion, the City will coordinate with Caltrans to explore transportation management measures to address these concerns.
Please note that the Draft Mobility Element also has a specific policy that addresses this comment directly:
Policy 1.26 – Continue to coordinate with other governmental agencies in the area, including municipalities, SCAG, MTA and the San Gabriel Council of Governments to address mutual issues of concern related to the transportation system.
As discussed at the meeting on May 13, 2015, the City of Pasadena and Caltrans are currently cooperating on the development of the 1-210 Connected Corridors project to address congestion relief due to incidents on either freeway or city arterial streets. The goal of the future phases of the project is to also address recurring traffic congestion on freeway and adjacent arterial streets. The City is proposing to introduce the following policy into the Mobility Element to further respond to Caltrans' concern:
New Policy City of Pasadena will work with Caltrans to evaluate access management needs and strategies to better manage traffic operations on arterial streets located within close proximity of freeway on/off-ramps in an effort to reduce traffic backups and frictions at Caltrans ramp signals.
A2-6 Please refer to response to Comments A2-2, A2-3, and A2-5. Additionally, the Draft Mobility Element includes a policy to coordinate with neighboring cities to address cumulative traffic impacts, as follows:
Policy 1.26 – Continue to coordinate with other governmental agencies in the area, including municipalities, SCAG, MTA and the San Gabriel Council of Governments to address mutual issues of concern related to the transportation system.
A2-7 The commenter is correct. To the degree that general plan policies and goals have been evaluated and received CEQA clearance, further environmental processing on those items would not need to be reevaulated.
A2-8 On May 13, 2015 the City of Pasadena Department of Transportation and Fehr & Peers (the City’s traffic consultant) met with Caltrans to address the issues discussed in this letter. The City is committed to working with Caltrans and continuing to coordinate on
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADE N A
3. Response to Comments
these important issues. Following the meeting staff from Caltrans and the City of Pasadena Department of Transportation have had numerous conversations and have worked collaboratively to develop responses to issues raised by Caltrans. Follow up letters detailing the City’s response and Caltrans’ concurrence with the responses is provided in Appendix B of this FEIR.
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
3. Response to Comments
August 2015 Page 3-41
LETTER A3– City of Pasadena Public Health Department (4 pages)
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADE N A
3. Response to Comments
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
3. Response to Comments
August 2015 Page 3-43
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADE N A
3. Response to Comments
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
3. Response to Comments
August 2015 Page 3-45
A3. Response to Comments from City of Pasadena Public Health Department, dated March 24, 2015.
A3-1 The commenter is in support of General Plan Update policies that promote community gardens and access to locally grown foods. Such policies include Policies 2.10, 2.12, 5.3,
6.7, and 10.12. No further response is necessary.
A3-2 The commenter states that the existing zoning code and Lincoln Avenue Specific Plan do not support community gardens. The proposed project is updating the General Plan and does not include an update to the zoning code. The City will begin the process to update the zoning code consistent with the General Plan upon General Plan adoption.
These comments, including the suggestions outlined in the table provided will be forwarded to the decision makers for consideration.
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADE N A
3. Response to Comments
This page intentionally left blank.
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
3. Response to Comments
August 2015 Page 3-47
LETTER A4 – County of Los Angeles Fire Department (3 pages)
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADE N A
3. Response to Comments
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
3. Response to Comments
August 2015 Page 3-49
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADE N A
3. Response to Comments
This page intentionally left blank.
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
3. Response to Comments
August 2015 Page 3-51
A4. Response to Comments from County of Los Angeles Fire Department, dated February 3, 2015.
A4-1 The County of Los Angeles Fire Department reviewed the Pasadena General Plan Update Draft Environmental Impact Report, Draft Land Use Element, and Draft Mobility Element. The Planning Division stated that that project does not impact emergency responsibilities of the department. The Land Development Unit states that since City is within the jurisdiction of the Pasadena Fire Department, there is unlikely to be impacts to the county. Contact information was provided if further correspondence is needed. No further response is necessary.
A4-2 The Forestry Division has no comments. No further response is necessary.
A4-3 The Health Hazardous Materials Division has not comments. No further response is necessary.
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADE N A
3. Response to Comments
This page intentionally left blank.
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
3. Response to Comments
August 2015 Page 3-53
LETTER A5 – County of Los Angeles Fire Department (2 pages)
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADE N A
3. Response to Comments
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
3. Response to Comments
August 2015 Page 3-55
A5. Response to Comments from County of Los Angeles Fire Department, dated February 25, 2015.
A5-1 Two letters were sent from the County of Los Angeles Fire Department. All comments in this letter were addressed in Responses to Comments A4-1 through A4-3. No further response is necessary.
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADE N A
3. Response to Comments
This page intentionally left blank.
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
3. Response to Comments
August 2015 Page 3-57
LETTER A6 – Pasadena Chamber of Commerce (1 page)
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADE N A
3. Response to Comments
This page intentionally left blank.
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
3. Response to Comments
August 2015 Page 3-59
A6. Response to Comments from Pasadena Chamber of Commerce, dated March 20, 2015.
A6-1 The Pasadena Chamber of Commerce expressed their disappointment that an economic analysis was not conducted and an opinion that Pasadena’s downtown can support more housing than proposed in the General Plan Update. In accordance with the California Environmental Quality Act (CEQA), economic effects shall not be treated as significant effects on the environment (CEQA Guidelines Section 15131). However, the City is preparing an economic analysis under a separate process apart from CEQA. The economic analysis will be provided to City Council in its consideration of the General Plan Update adoption.
This comment relates to the land uses and policies proposed by the General Plan Update, not the potential environmental impacts of the project. However, the comment is noted and will be provided to the decision-making body (City Council) as part of the consideration of the General Plan Update adoption.
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADE N A
3. Response to Comments
This page intentionally left blank.
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
3. Response to Comments
August 2015 Page 3-61
LETTER A7– Pasadena Heritage (5 pages)
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADE N A
3. Response to Comments
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
3. Response to Comments
August 2015 Page 3-63
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADE N A
3. Response to Comments
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
3. Response to Comments
August 2015 Page 3-65
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADE N A
3. Response to Comments
This page intentionally left blank.
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
3. Response to Comments
August 2015 Page 3-67
A7. Response to Comments from Pasadena Heritage, dated March 23, 2015.
A7-1 The City appreciates Pasadena Heritage comments on the quality of the analysis and Land Use Element. The commenter provides feedback and recommendations on the General Plan Update and EIR, which are addressed in the following responses.
The response to the comment related to the State’s Density Bonus Law (SB 1818) is provided in Section 2.2, State Density Bonus Law. The City of Pasadena determined the number of affordable housing units that could be developed based on historical trends in the City. The City calculated the number of affordable housing units that have been constructed since 2005, took an average of additional density bonus units constructed per project, and applied that percentage (17 percent) of potential affordable units to the proposed General Plan Update development caps. Using the past 10 years of data to project a reasonable and fact-based potential number of future affordable units provides an accurate methodology for analysis and is not far too conservative as the commenter suggests.
A7-2 Subsection 4.3.1 of Chapter 4 has been revised to reference the historic districts and important sites mentioned by the commenter.
Central District. Pasadena’s Central District is the City’s urban core and includes downtown Pasadena, Old Pasadena, the Civic Center/Midtown area, and the Playhouse District. Colorado Boulevard, which runs east–west through the Central District, is one of the region’s premier retail destinations. The specific plan area features numerous historic and culturally important sites, including City Hall, and the Pasadena Playhouse, Central Park, and Memorial Park. Historic districts include the Old Pasadena, Pasadena Civic Center, Civic Center-Financial, and Pasadena Playhouse historic districts. The Central District is a dense, vibrant, and walkable mix of commercial, residential, and civic land uses. It is divided into seven subdistricts in the Central District Specific Plan.
In general, this subsection is meant to describe Pasadena’s land use pattern, not offer an exhaustive inventory of the land uses found in each area of the City. Additional discussion of aesthetic and cultural resources can be found in Sections 5.1 and 5.4 of the DEIR, respectively.
A7-3 Subsection 4.3.1 of the DEIR has been revised, as follows, to include the facilities and sites mentioned by the commenter:
South Fair Oaks. The South Fair Oaks Specific Plan area is south of downtown Pasadena between South Pasadena Avenue to the west and South Arroyo Parkway (SR-110) to the east. The area is dominated by industrial uses and Huntington Hospital. However, it also features the Glenarm Power Plant with the historic
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADE N A
3. Response to Comments
Electric Fountain, and Art Center College of Design’s south campus on South Raymond Avenue.
A7-4 Subsection 4.3.1 of the DEIR has been revised as requested:
Unlike most of the City, which is dominated by urban development, the western portion of Pasadena is characterized by a sequence of open space areas that are oriented to the Arroyo Seco waterway. From north to south, they include Hahamongna Watershed Park, Central Arroyo Park (including Brookside Park), and Lower Arroyo Seco Park. Recreational and cultural amenities include the Brookside Golf Course, Rose Bowl stadium, Kidspace Children’s Museum, and Rose Bowl Aquatics Center. As with the Arroyo Seco on the west side of the City, Eaton Wash in eastern Pasadena is a seasonal waterway that drains runoff from the San Gabriel Mountains to lower elevations in the City. The Central and Lower Arroyo areas are largely part of the Pasadena Arroyo Parks and Recreation District, which is listed on the National Register of Historic Places under the Cultural Landscape category. In addition, the Rose Bowl is a National Historic Landmark.
A7-5 Please refer to Section 4.2.2.2 of the DEIR on Page 4-3, which describes “High Quality Transit Areas.” This is a defined term used in the Southern California Association of Government’s 2012 Regional Transportation Plan/Sustainable Communities Strategy.
A7-6 The commenter is correct in noting that the following paragraph omits mention of Pasadena’s National Historic Landmarks. A review of the federal database for such resources found that Pasadena has three National Historic Landmarks within the City (the Gamble House, Hale Solar Observatory, and Rose Bowl) and two just outside Pasadena on the Jet Propulsion Laboratory campus (the Space Flight Operations Facility and Twenty-Five-Foot Space Simulator).
Subsection 4.3.4 of the DEIR has been modified, as follows, to 1) mention the three National Historic Landmarks within Pasadena, 2) refer to the Arroyo Seco Parkway by its correct name, 3) correctly spell Craftsman, and 3) clarify that historic buildings in Pasadena represent a wide diversity of architectural styles:
There are three known prehistoric resources in Pasadena, including two sites and a trail. There are also two historic archaeological sites, including an early 20th Century tourist camp and a trash deposit possibly associated with the San Rafael Ranch.
Existing designated historic resources in the City include 131 resources listed on the National Register of Historic Places, including 2016 National Historic Districts and 3 National Historic Landmarks (NPS 2013); 1 State Point of Historical Interest; 2 State Historic Landmarks (OHP 2013); numerous City-designated landmarks, memorials, and monuments (Pasadena 2010); and 2017 City-designated Landmark Districts (Pasadena 2010). Part of SR-110, the Arroyo Seco Parkway Pasadena Freeway, is designated a National Scenic Byway (FHWA 2013). The City is well
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
3. Response to Comments
August 2015 Page 3-69
known for its large inventory of historic buildings, which include historic estates of early 20th Century business magnates, hundreds of Craftsman-style bungalows, and numerous private and public buildings of note representing a wide diversity of architecture styles, including Victorian-era buildings, Period Revival style buildings, and Modern buildings.
A7-7 See above response and associated DEIR revisions. Subsection 4.3.4 of the DEIR has been modified to clarify that historic buildings in Pasadena represent a wide diversity of architectural styles. Pasadena’s cultural resources are discussed in more detail in Section
5.4 of the DEIR. Chapter 4 of the DEIR is intended to provide a brief overview of the City’s existing environmental setting; no additional detail regarding cultural resources is necessary.
A7-8 Subsection 4.3.8 has been modified, as follows, to mention the specific resources indicated by the commenter:
The City of Pasadena affords a variety of views of scenic landscapes and built environments. The San Gabriel Mountains, near the north City boundary, dominate the skyline from most of the City. The San Rafael Hills are along the western City boundary, and the Verdugo Mountains are further to the west. In addition, the Arroyo Seco corridor and Eaton Canyon traverse the western and eastern portions of the City, respectively. The City also offers scenic views of distinct architecture in the built environment, such as the Old Pasadena Historic District, Pasadena City Hall, Castle Green, St. Andrew Catholic Church bell tower, and Bungalow Heaven.
The above paragraph is intended to list only a few examples of how the City’s built environment offers scenic views. Section 5.1, Aesthetics, of the DEIR provides a detailed analysis of the City’s scenic vistas, visual resources, and aesthetic character.
A7-9 The full name of the Pasadena ARTS has been corrected as requested in Section 4.3.9 as follows:
The City is served by numerous bus lines operated by Pasadena ARTS (Pasadena Area Rapid Transit System), Foothill Transit, and Metro. Other alternative modes of transportation in the City include services offered by the Los Angeles Department of Transportation (e.g. park-and-ride lots); Dial-A-Ride; the Gold Line (light rail line that links Pasadena to Union Station in Los Angeles); the LAX FlyAway bus service from Pasadena to LAX; and the City of Sierra Madre Gateway Coach. The Gold Line light-rail line (Metro Rail Service Line 804) extends north–south through the southwestern part of the City and continues eastward in the median of I-210, terminating near the eastern City boundary. The City also provides ample opportunities for bicycling via a network of bikeways, bicycle parking, links to transit, and other accommodations, as detailed in the City’s Bicycle Transportation Plan (adopted in 2000 and last updated in 2011).
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADE N A
3. Response to Comments
A7-10 The bullet mentioned by the commenter has been modified as requested in Section 5.1 as follows:
East Colorado. This area is a three-mile-long corridor extending eastward from Catalina Avenue to the eastern City boundary. It includes Allen Avenue from Colorado Boulevard to the Gold Line station at I-210. East Colorado Boulevard features a broad variety of commercial land uses. The visual character of the corridor varies widely, including auto-oriented areas with deficient pedestrian infrastructure and areas with wide sidewalks and businesses that front the sidewalk. Colorado Boulevard offers substantial eastward and westward views through the Specific Plan area and Pasadena. The area also includes multiple distinctive historic buildings, including the Holliston Avenue Methodist Church, H.G. Loud Auto Building, Howard Motor Company Building, Kindel Building, Saga Motor Hotel, and other auto-oriented uses associated with historic Route
66. A7-11 The bullet mentioned by the commenter has been modified as requested in Section 5.1 as follows:
Fair Oaks/Orange Grove. The Fair Oaks/Orange Grove Specific Plan corridor encompasses approximately 171 acres in northwest Pasadena and is considered the “gateway” to northwest Pasadena. The specific plan divides the area into the La Pintoresca Neighborhood Corridor, Robinson Park, and Renaissance Commercial districts. All three subdistricts feature residential and neighborhood-serving commercial land uses. The Robinson Park district also features an important cluster of civic and community-serving institutions. The area’s character is varied and has many historic residential properties.
A7-12 The bullet mentioned by the commenter has been modified as requested in Section 5.1 as follows:
South Fair Oaks. The South Fair Oaks Specific Plan area is south of downtown Pasadena between South Pasadena Avenue to the west and South Arroyo Parkway (SR-110) to the east. The area is dominated by industrial uses and Huntington Memorial Hospital. Interspersed between industrial uses are commercial and public uses of varying building types and styles, giving the area an eclectic appearance and character. This varied visual environment includes some of the City’s more adventurous and atypical architecture, as well as several important historic structures.
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
3. Response to Comments
August 2015 Page 3-71
A7-13 Table 5.1-1 has been modified as requested:
South Fair Oaks • Industrial/warehouse buildings
• Glenarm Power Plant and Electric
Ffountain
• Unique visual character
• Historic resource
A7-14 In Section 5.1, the bullet indicated by the commenter has been modified, as follows, to mention the Arroyo Seco’s historic value:
Northwest Pasadena. Outside of the Lincoln Avenue Specific Plan area, this section of Pasadena is characterized by a suburban, residential character. The area is bisected from north to south by the portion of the Arroyo Seco that contains the Rose Bowl, Brookside Golf Course, and other recreational amenities. The Rose Bowl, golf course, and Arroyo Seco corridor as a whole have historic value in addition to their recreational and aesthetic value. East of the Arroyo Seco and west of I-210 are residential neighborhoods that are mostly oriented to an orthogonal street grid. This grid and the regular placement of street trees give the area an orderly and modest small-town aesthetic. West of the Arroyo Seco are residential neighborhoods featuring larger homes on larger lots, many in the San Rafael Hills. The topography, scenic vistas, and mature tree canopy distinguish these homes and neighborhoods from other areas of the city.
A7-15 In Section 5.1.1, the bullet mentioned by the commenter has been modified as requested:
Design Commission (Chapter 2.80). This section of the Municipal Code establishes the City’s Design Commission. The Design Commission is tasked with fulfilling the Pasadena City Council’s declaration that the “achievement of quality in the architecture and urban design of the City is required in the interest of the prosperity, social and cultural enrichment, and general welfare of the people” (Pasadena 2014). The Commission is given the authority to develop City policies and standards related to community design, review development and redevelopment projects regarding aesthetic concerns, and make recommendations regarding environmental review documents.
A subsection of Chapter 2.80 establishes the City’s Urban Forestry Advisory Committee. The code gives authority to the Design Commission to delegate review of matters pertaining to trees to the Urban Forestry Advisory Committee. The Design Commission also serves as the Historic Preservation Commission for properties within the Central District.
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADE N A
3. Response to Comments
A7-16 Refer to Section 2.2, State Density Bonus Law. In addition, given the small number of SB 1818 concessions granted in the City and the unique circumstances that must be analyzed for a particular project and site to identify what concession or waiver of development standards would apply, it is not feasible to incorporate these assumptions on to the visual simulations.
A7-17 This language is taken from the adopted Scenic Highways Element and should not be changed.
A7-18 This comment relates to the land use policies proposed by the General Plan Update, not the potential environmental impacts of the project. These suggested changes are noted and will be provided to the decision-making body (City Council) as part of the consideration of the General Plan Update adoption.
A7-19 Analysis under Impact 5.4-1 has been modified, as follows, to correct the stated status of the Pasadena Civic Center as a National Register Historic District.
As shown in Table 5.4-3, there are a number of landmark and historic districts within and adjacent to the specific plan areas. Careful consideration of site specific development must occur within and adjacent to these districts to ensure that there are no conflicts or impacts to the resource’s immediately surrounding area. Specific examples include the potential for new commercial and mixed uses near the Bungalow Heaven and Historic Highlands Landmark Districts; medium mixed use, high density mixed use, and institutional classifications in the Pasadena Playhouse Districts; medium mixed use, high density mixed use, institutional, and high density residential in the Pasadena Civic Center National Register Historic Landmark District; and medium density residential uses in the Ross Grove Landmark District.
A7-20 Analysis under Impact 5.4-1 has been modified as requested:
In addition to compliance with Policy LU 8.5, new development would be required to comply with the City’s Design Guidelines for Historic Districts, which are based on the Secretary of the Interior’s Standards for Historic Preservation. For example, areas along North Lake Avenue adjacent to the Bungalow Heaven National Register District and the Historic Highlands Landmark District would allow for Low Mixed Use (1-1.0 FAR), Low-Medium Mixed Use (0-1.75 FAR), and Low Commercial (0-1.0 FAR). Although the proposed Land Use Diagram would allow new uses with specific FARs adjacent to these landmark and historic districts, new development in this area would still need to comply with the North Lake Specific Plan and development standards (e.g., height, massing, and setback limitations) in Municipal Code Section 17.34.040 and the Urban Design, Sense of Place, and Architectural policies in the land use element. New development in the Pasadena Playhouse, Civic Center-Financial, and Pasadena Civic Center National Register Districts would be required to comply with the Central District Specific Plan
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
3. Response to Comments
August 2015 Page 3-73
and Design Guidelines for Historic Districts. Adherence to these development standards and design guidelines would ensure that infill development would maintain the character and context of the area, incorporate high quality architectural design, and be compatible with adjacent historical structures. Elements of the historic resources and landmarks that are character defining and convey the resources’ significance, including all seven aspects of the resources integrity, would not be altered.
A7-21 This comment relates to the land use policies proposed by the General Plan Update, not the potential environmental impacts of the project. These suggested changes are noted and will be provided to the decision-making body (City Council) as part of the consideration of the General Plan Update adoption.
A7-22 The commenter recommends changes to the Pasadena Green City Action Plan. Since this plan was adopted in 2006, the language cannot be changed as part of this DEIR process. However, this comment is noted and will be provided to the decision makers for consideration.
A7-23 The Noise Element has been adopted and is not being updated as part of the proposed General Plan Update. Therefore, the changes to Noise Element policies are not being contemplated at this time. Nonetheless, this comment is noted and will be provided to the decision makers for consideration.
A7-24 Pursuant to CEQA Guidelines Section 15097, the City will be required to adopt a Mitigation Monitoring and Reporting Program for the Pasadena General Plan Update.
A7-25 The commenter states that they agree with the DEIR analysis that the Central District, South Fair Oaks, and Lincoln Avenue Alternative is the environmentally superior alternative. No further response is necessary.
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADE N A
3. Response to Comments
This page intentionally left blank.
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
3. Response to Comments
August 2015 Page 3-75
LETTER A8– Playhouse District Association (3 pages)
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADE N A
3. Response to Comments
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
3. Response to Comments
August 2015 Page 3-77
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADE N A
3. Response to Comments
This page intentionally left blank.
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
3. Response to Comments
August 2015 Page 3-79
A8. Response to Comments from Playhouse District Association, dated March 24, 2015.
A8-1 The Playhouse District Association (PDA) supports future growth and development in the Central District to ensure a walkable and economically strong City. Responses to the comments on the DEIR are provided below.
A8-2 The PDA supports the growth assumed in the Central District for the General Plan Update, the Efficient Transportation Alternative, and the Reduced Air Quality and Noise Impact Alternative. No further response is necessary.
A8-3 The PDA is correct that all of the alternatives analyzed show lower VMT and VMT per capita than the No Project/Adopted General Plan Alternative. The Central District, South Fair Oaks, Lincoln Avenue Alternative shows a reduction in VMT but a slight increase in VMT per capita compared to the proposed project and the Efficient Transportation Alternative. No further response is necessary.
A8-4 Following adoption of the General Plan Update, the City will implement measures to support the general plan goals and policies. References to pedestrian improvements, in addition to those provided for in the City’s Pedestrian Plan adopted in 2006, may be incorporated. The City’s pedestrian metric requires that future development analyze pedestrian impacts. Additionally, pedestrian improvements will be included as part of the update to the City’s transportation fee.
Please refer to Figures 18 and 20 in the Transportation Analysis Report (Appendix D of the FEIR) for maps showing the quality of pedestrian accessibility under existing and proposed conditions.
The suggestion to create a new policy section entitled “Walkability” is a land use policy issue that will be forwarded to the decision makers for their consideration.
A8-5 The California Environmental Quality Act (CEQA) requires the lead agency to select an environmentally superior alternative (to the proposed project). The proposed project is not one of the options that can be selected as the environmentally superior alternative.
For the reasons stated in Section 7.8 of the DEIR, the Central District, South Fair Oaks, and Lincoln Avenue Alternative would result in reduced impacts in the greatest number of categories of significant effects. The commenter is correct that this alternative does not eliminate any significant and unavoidable adverse effects of the proposed project.
Additionally, the commenter is correct that the Efficient Transportation Alternative would also reduce many of the proposed project’s significant effects. Comments on the prepared alternative will be forwarded to the decision-making body (City Council) for their consideration.
A8-6 The commenter’s opinion regarding the inadequacy of the economic support provided by the Central District, South Fair Oaks and Lincoln Avenue Alternative is duly noted.
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADE N A
3. Response to Comments
The City prepared an economic analysis under a separate process apart from the CEQA process. The economic analysis will be available to the decision makers when deciding whether to adopt the General Plan and will support the Findings of the Final Environmental Impact Report, as necessary.
A8-7 The DEIR must first select the alternative that is environmentally superior to the proposed project. However, once the environmentally superior alternative is selected, the decision-making body (City Council) must decide whether to accept or reject that alternative. Among the factors that may be used to reject an alternative is the inability to meet the project objectives. The commenter’s opinion that the No Project Alternative and the Central District, South Fair Oaks, and Lincoln Avenue Alternative would not meet certain project objectives to the same degree as the proposed General Plan Update or other analyzed alternatives is duly noted.
A8-8 The comment regarding the pivotal role of growth in the Central District, along with the commenter’s opinions and recommendations will be forwarded to the City Council for consideration of the project merits.
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
3. Response to Comments
August 2015 Page 3-81
LETTER R1 –Joyce Dillard (1 page)
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADE N A
3. Response to Comments
This page intentionally left blank.
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
3. Response to Comments
August 2015 Page 3-83
R1. Response to Comments from Joyce Dillard, dated March 24, 2015.
R1-1 Chapter 4, Environmental Setting, of the DEIR has been modified to be consistent with revisions suggested by the commenter:
4.2.2.3 REGIONAL WATER QUALITY CONTROL BOARD
The City of Pasadena and its sphere of influence are in the jurisdictional area of the Los Angeles Regional Water Quality Control Board (LARWQCB). Requirements for avoiding or minimizing stormwater pollution from operation of development projects are in the LARWQCB’s Order No. 01-182 R4-2012-0175, Waste Discharge Requirements for Municipal Separate Storm Sewer System Water and Urban Runoff Discharges in the County of within the Coastal Watersheds of Los Angeles County (“MS4 Permit”) and National Pollution Discharge Elimination System (NPDES) Permit No. CAS004001, most recently amended on April 14, 2011. MS4 permit requirements meet the National Pollution Discharge Elimination System (NPDES) regulations authorized by Section 402 of the Clean Water Act. The City of Pasadena is a copermittee on the MS4 Permit and has adopted a Standard Urban Stormwater Mitigation Plan ordinance (Municipal Code Chapter 8.70) to ensure new developments comply with the MS4 Permit.
Information and analysis in Section 5.7, Hydrology and Water Quality, of the DEIR references the correct water quality permit.
R1-2 The commenter refers to the Area with Restoration Benefits and Opportunities for Revitalization (ARBOR) discussed in the Los Angeles River Ecosystem Restoration Integrated Feasibility Report prepared by the U.S. Army Corps of Engineers in 2013.
Subsection 5.7.1.3 of the DEIR discusses the ongoing collaborative effort by multiple agencies to increase water in the Arroyo Seco, which discharges into the Los Angeles River.
As disclosed in Section 5.7, Hydrology and Water Quality, of the DEIR, buildout of the General Plan Update is anticipated to increase the amount of impervious surfaces in the City, which would increase surface water flows to drainage systems in the City, and ultimately to the Arroyo Seco and Los Angeles River. For this reason, and because the General Plan Update would not alter the course of the Arroyo Seco, result in significant erosion or siltation, or propose new development in the vicinity of the waterway, implementation of the proposed project would not conflict with regional goals to increase flow in the Los Angeles River. Furthermore, policies that address the health of the Los Angeles River watershed are included in the adopted Open Space and Conservation Element and in the proposed Land Use Element. In particular, Policy LU
10.11 seeks to “preserve and maintain the natural character of the Eaton Canyon Corridor and the Arroyo Seco as self-sustaining healthy ecosystems.”
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADE N A
3. Response to Comments
This page intentionally left blank.
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
3. Response to Comments
August 2015 Page 3-85
LETTER R2 –Laura Ellersieck (1 page)
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADE N A
3. Response to Comments
This page intentionally left blank.
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
3. Response to Comments
August 2015 Page 3-87
R2. Response to Comments from Laura Ellersieck, dated January 28, 2015.
R2-1 The DEIR makes no reference to Electric Avenue. However, the Land Use Element will be revised accordingly.
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADE N A
3. Response to Comments
This page intentionally left blank.
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
3. Response to Comments
August 2015 Page 3-89
LETTER R3 – Alon Friedman (1 page)
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADE N A
3. Response to Comments
This page intentionally left blank.
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
3. Response to Comments
August 2015 Page 3-91
R3. Response to Comments from Alon Friedman, dated February 19, 2015.
R3-1 The Pasadena General Plan Update DEIR evaluated the impacts of the Mobility Element and a Transportation Analysis Report was prepared to analyze, among other issues, the quality of bike facilities citywide. The DEIR did not analyze to the level of detail of analyzing parallel bar grates in the roadway as a safety hazard. However, the City is in the process of updating its Bicycle Transportation Action Plan, which addresses the bicycle network and safety throughout the City. A draft plan is available on the City’s website. Suggestions to improve bicycle safety will be forwarded to decisionmaking body (City Council) during consideration of the project.
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADE N A
3. Response to Comments
This page intentionally left blank.
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
3. Response to Comments
August 2015 Page 3-93
LETTER R4 – Lonnee Hamilton (3 pages)
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADE N A
3. Response to Comments
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
3. Response to Comments
August 2015 Page 3-95
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADE N A
3. Response to Comments
This page intentionally left blank.
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
3. Response to Comments
August 2015 Page 3-97
R4. Response to Comments from Lonnee Hamilton, dated February 8, 2015.
R4-1 The proposed General Plan Update does not include changes to the amount or type of events to be held at the Rose Bowl. Therefore, detailed traffic and air pollution studies associated with Rose Bowl events, including swap meets, are not appropriate for the programmatic EIR prepared for the General Plan Update. Citywide air quality, including impacts of the proposed project, is discussed in Section 5.2, Air Quality, of the DEIR.
Traffic impacts are analyzed in Section 5.13, Transportation and Traffic. Because the traffic study and EIR provide program-level analysis for the City as a whole, traffic congestion is studied at key highway segments and roadway intersections identified by the Los Angeles County Congestion Management Program (CMP).
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADE N A
3. Response to Comments
This page intentionally left blank.
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
3. Response to Comments
August 2015 Page 3-99
LETTER R5 –Richard Hogge (2 pages)
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADE N A
3. Response to Comments
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
3. Response to Comments
August 2015 Page 3-101
R5. Response to Comments from Richard Hogge, dated February 10, 2015.
R5-1 The commenter expresses support for components of the General Plan Update. No response is necessary.
R5-2 The commenter supports pedestrian traffic signal syncing at Arroyo Parkway to access the Metro Gold Line stops. The pedestrian pushbuttons are used to change traffic signal timing to accommodate pedestrian street crossings with enough time for pedestrians to cross the street. Pushbuttons are needed at some crossings as traffic signals become more complex. In higher pedestrian zones, pedestrian walk signals are programmed to “pedestrian recall” which means that the pedestrian phase automatically turns on without having to push the button. These signals operate in pedestrian recall mode during high pedestrian peak times. In areas where there is minimal to no pedestrian activity the standard wait time for pedestrian crossing is not needed. Recent traffic signal improvements at at-grade Gold Line crossings led to the adjustment of pedestrian signals which allow pedestrians to cross when the gates are down. Prior to the adjustments the intersections needed to be clear for safety precautions. This comment relates to pedestrian improvements, not the sufficiency of the DEIR. However, the comment is noted and will be provided to the decision-making body (City Council) as part of the consideration of the General Plan Update adoption.
R5-3 Marengo Boulevard currently offers a sharrow, a shared-lane marking for bicyclists, connecting Villa to Cordova. Consideration to add a bicycle lane to connect the gap will be taken into consideration.
Raymond Avenue does not cross the freeway to connect the northern bike lanes to Old Pasadena and Civic Center, because most bicyclist use the bike sharrows on Marengo to connect into Old Pasadena or the Civic Center. South of Del Mar, Raymond Avenue was widened to accommodate four standard width travel lanes as part of State Route 710 Mitigation Project. The project was constructed using federal funding to improve mobility in areas identified as impacted by the gap in the 710 freeway. The receipt of these funds precludes the City from adding any bicycle facilities on Raymond Avenue.
These comments are noted and will be provided to the decision-making body (City Council) as part of the consideration of the General Plan Update adoption.
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADE N A
3. Response to Comments
This page intentionally left blank.
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
3. Response to Comments
August 2015 Page 3-103
LETTER R6 – Richard Luczyski (Letter 1 of 2) (4 pages)
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADE N A
3. Response to Comments
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
3. Response to Comments
August 2015 Page 3-105
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADE N A
3. Response to Comments
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
3. Response to Comments
August 2015 Page 3-107
R6. Response to Comments Richard Luczyski (1 of 2), dated February 11, 2015.
R6-1 Please refer to Section 2.3, Air Quality, of this FEIR. Air quality impacts are analyzed in Section 5.2, Air Quality, of the DEIR. The section discusses the connection between air quality and public health, including the rationale behind adopted ambient air quality standards, which emphasize protection of sensitive receptors—such as young children and the elderly—from negative health outcomes. Air pollutants of concern and related adverse health effects are defined in Subsection 5.2.1.2 of the DEIR.
In any community, multiyear air quality monitoring data is only available from a finite number of sources. CEQA documentation must utilize the most geographically- and chronologically-appropriate data available. For the proposed project, the data that best represents the ambient air quality within the City is data collected by the South Coast Air Quality Management District (SCQAMD) at its Pasadena – North Wilson Avenue and Burbank – West Palm Avenue monitoring stations. For a project the size of the General Plan Update, collecting localized data at or near all major roadways is not feasible.
Furthermore, the DEIR discloses that during the planning period of the General Plan Update, major roadways and intersections throughout the City would generate significant air quality impacts, with or without the proposed project. These impacts are largely a function of regional transportation and land use patterns, which affect the entire basin’s air quality. Although data from additional monitoring stations might reveal minor variations in localized air quality, it would not change conclusions about Pasadena’s overall air quality disclosed in the DEIR.
As described in Section 5.2 of the DEIR and in the response to Comment R7-5 in this FEIR, mitigation has been identified in the EIR (Mitigation Measure 2-4) requiring that health risk assessments (HRAs) be prepared for projects that introduce sensitive receptors in specific air quality buffer zones (as defined by the California Air Resources Board). Preparation of HRAs and implementation of design measures found in those HRAs would substantially reduce localized air quality impacts associated with freeway adjacency.
R6-2 Please refer to Section 2.3, Air Quality, of this FEIR. Section 15370 of the state CEQA Guidelines defines mitigation as 1) avoiding the impact altogether; 2) minimizing any significant impacts by limiting the degree or magnitude of the action and its implementation; or 3) or rectifying those impacts by repairing, rehabilitating, or restoring the impacted environment. In other words, the purpose of mitigation measures is to tangibly reduce or avoid significant adverse impacts. Although additional air quality monitoring stations in the City—including new sites near freeways, as suggested—would increase the amount of localized air quality data available, this information alone would not mitigate air quality impacts.
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADE N A
3. Response to Comments
However, the City is committed to finding new ways to improve air quality in Pasadena.
The proposed Land Use and Mobility Elements include policies and implementation measures that would promote air quality improvement. For example, see Land Use Policies 10.1, 10.2, and 27.5; Mobility Policy 1.9; and Mobility Implementation Measure
1.7. R6-3 This comment and subsequent including emails relate to public meetings that were responded to by email. No further response is necessary.
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
3. Response to Comments
August 2015 Page 3-109
LETTER R7 – Richard Luczyski (Letter 2 of 2) (2 pages)
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADE N A
3. Response to Comments
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
3. Response to Comments
August 2015 Page 3-111
R7. Response to Comments from Richard Luczyski, dated March 24, 2015.
R7-1 The commenter’s previous comments from February 5, 2015 and February 11, 2015, as well as the community forums are included in this FEIR (see response to Comments R6-1 through R6-3, F1-6, F1-7, F-9, F2-8, and F2-12).
R7-2 Per Section 15126.2(b) of the CEQA Guidelines, “significant and unavoidable” impacts are those that cannot be avoided or reduced to a level that is less than significant, even after incorporation of feasible mitigation measures. As discussed in Section 2.3 of this FEIR and response to Comment R6-2, the installation of additional air quality monitoring stations in Pasadena could aid in the future analysis of local air quality.
However, this information, alone, would not mitigate air quality impacts of the City’s buildout. In particular, most of the significant and unavoidable air quality impacts of the proposed project are those related to the overall air basin’s nonattainment of ambient air quality standards and the related SCAQMD’s methodology and significance thresholds for evaluating a project’s impact. The existence of additional air quality data for specific locations in Pasadena would neither have a tangible effect on the air quality of the South Coast Air Basin nor change the methodology or analysis for evaluating the proposed General Plan Update’s impact on the Basin’s air quality. Therefore, the existence of additional air quality monitoring data would not reduce the aforementioned impacts to less than “significant and unavoidable.”
R7-3 This comment relates to an analysis of healthy communities and the proposed Mobility Element policies proposed by the General Plan Update, not the potential environmental impacts of the project. However, the comment is noted and will be provided to the decision-making body (City Council) as part of the consideration of the General Plan Update adoption.
R7-4 As stated in the response to Comment R7-2, increased community and governmental awareness of air quality issues in Pasadena, while potentially beneficial, would not in itself constitute mitigation of a potentially significant impact because it would not result in a tangible reduction of the proposed project’s significant impacts.
R7-5 Mitigation Measure 2-4 identified in the DEIR requires that that City evaluate development proposals for sensitive land uses (such as residences, schools, and day care centers) for potential incompatibilities with regard to the California Air Resources Board’s Air Quality and Land Use Handbook: A Community Health Perspective (April 2005). Mitigation Measure 2-4 requires that, when appropriate, project applicants of such projects prepare health risk assessments and implement project-level mitigation measures that are capable of reducing potential cancer and noncancer risks to acceptable levels. Suggested actions include those that reduce health risks due to air pollutants generated by high volume roadways (such as freeways).
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADE N A
3. Response to Comments
R7-6 The purpose of the public meetings held during the DEIR public review period was to provide an overview of the project, the CEQA process, and to document comments and input from the community on the DEIR. Public comments were received, documented, and responded to in this FEIR, in accordance with CEQA Guidelines Sections 15088, 15088.5, and 15089.
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
3. Response to Comments
August 2015 Page 3-113
LETTER R8 – Steve Madison (1 page)
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADE N A
3. Response to Comments
This page intentionally left blank.
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
3. Response to Comments
August 2015 Page 3-115
R8. Response to Comments from Steve Madison, dated March 12, 2015.
R8-1 This comment relates to the development intensities allowed under the General Plan Update, not the potential environmental impacts of the project. However, the comment is noted and will be provided to the decision-making body (City Council) as part of the consideration of the General Plan Update adoption.
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADE N A
3. Response to Comments
This page intentionally left blank.
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
3. Response to Comments
August 2015 Page 3-117
LETTER R9 –Bryant Mathews (1 page)
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADE N A
3. Response to Comments
This page intentionally left blank.
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
3. Response to Comments
August 2015 Page 3-119
R9. Response to Comments from Bryant Mathews, dated March 8, 2015.
R9-1 The commenter supports mixed use development along the North Lake Corridor. No further response is necessary.
R9-2 This comment relates to the design of future buildings and projects, not the potential environmental impacts of the project. However, the comment is noted and will be provided to the decision-making body (City Council) as part of the consideration of the General Plan Update adoption.
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADE N A
3. Response to Comments
This page intentionally left blank.
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
3. Response to Comments
August 2015 Page 3-121
LETTER R10 – North Mentor Avenue Residents Group (6 pages)
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADE N A
3. Response to Comments
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
3. Response to Comments
August 2015 Page 3-123
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADE N A
3. Response to Comments
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
3. Response to Comments
August 2015 Page 3-125
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADE N A
3. Response to Comments
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
3. Response to Comments
August 2015 Page 3-127
R10. Response to Comments from North Mentor Avenue Residents Group, dated March 23, 2015.
R10-1 The City acknowledges the commenter’s location within the Bungalow Heaven Landmark District. No further response is necessary.
R10-2 The DEIR is tasked with analyzing the environmental impacts of the General Plan Update, which is a programmatic document and does not analyze specific development proposals along North Lake Avenue or elsewhere in Pasadena. Accordingly, the commenter is correct that there are no particular actions to implement the General Plan goals in the EIR, because that is not the legal purpose of the EIR. Future projects would be required to show consistency with the General Plan Update. While the EIR for the General Plan Update can be used for future tiering (see Section 2.7 of the DEIR), it is not meant to provide full clearance for future site specific development projects within the City. Following adoption of the General Plan Update, the City will be updating the specific plans and zoning code to be consistent with the General Plan Update, which will also require future CEQA review. Furthermore, as discussed in Section 5.1-1 of the DEIR, the City implements a robust set of procedures, regulations, and guidelines related to development review of new projects in Pasadena, most of which require consistency with the General Plan. For example, the City evaluates the design of proposed projects for their consistency with its Citywide Design Principles and Design Guidelines, Design Guidelines for Neighborhood Commercial and Multifamily Districts, and the North Lake Specific Plan. These guidelines, as well as the City Municipal Code, address context-sensitive design and land use compatibility. For more information about the programmatic nature of the General Plan Update EIR, see Section 2.2 of this FEIR.
R10-3 This comment relates to the proposed Land Use Diagram and privacy issues, not the potential environmental impacts of the project. However, the comment is noted and will be provided to the decision-making body (City Council) as part of the consideration of the General Plan Update adoption.
R10-4 The commenter expresses appreciation for changes to the Land Use Diagram made during the General Plan Update process. No response is necessary.
R10-5 For a comprehensive response to concerns regarding SB 1818, see Section 2.2 of this FEIR.
R10-6 It is important to note that the analysis of alternatives in the DEIR does not necessarily preclude other land use changes that may be considered or enacted by the decisionmaking body (City Council) during its consideration of project approval.
Section 15126.6(a) of the CEQA Guidelines, as quoted by the commenter, indicates that the purpose of analyzing project alternatives is to identify alternatives that would “…avoid or substantially lessen any of the significant effects of the project.” The DEIR
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADE N A
3. Response to Comments
found that aesthetic impacts of the proposed project would be less than significant. In particular, the amount and scale of development allowed on North Lake Avenue under the General Plan update is not anticipated to “substantially damage scenic resources” or “substantially degrade the existing visual character or quality of the site and its surroundings” as stated by thresholds AE-1 and AE-3. Additionally, the DEIR determined that impacts to historic resources and districts would be less than significant with incorporation of Mitigation Measure 9-4, since the General Plan Update would not allow for development that would result in the material impairment of any historic resource. Therefore, the range of project alternatives was developed based on their potential ability to reduce documented potentially significant impacts. For the proposed project, these included impacts related to air quality, greenhouse gas emissions, noise, and traffic (see Chapter 6 of the DEIR for a list of the project’s significant unavoidable adverse impacts). For a comprehensive response to concerns regarding SB 1818, see Section 2.2 of this FEIR.
R10-7 Since SB 1818 was enacted ten years ago, only eight projects (one of which was superseded by a later application) in Pasadena have received density bonus waivers and concessions under the law. For these projects, the majority of concessions were for minor changes to floor area ratios and setbacks. Continued implementation of SB 1818 is not anticipated to substantially alter the community character of the North Lake Avenue corridor or other area of Pasadena. Furthermore, SB 1818 does not exempt future projects from CEQA or from the City’s development review process. For a comprehensive response to concerns regarding SB 1818, see Section 2.2 of this FEIR.
R10-8 Please refer to Section 2.2 of this FEIR. One point of clarification is that the City shall approve a concession, incentive, or waiver of development standards after it makes a finding that the concession, incentive or waiver is required in order for the designated units to be affordable (Pasadena Municipal Codes 17.43.050[D] and 17.43.060[D]). The onus is on the project applicant to provide evidence to support the applicable findings.
If the findings cannot be supported then the Hearing Officer may deny the concession or waiver, as allowed by Government Code Section 65915.
R10-9 Please refer to Section 2.2, State Density Bonus Law. It is not reasonably foreseeable that implementation of the General Plan Update would result in a significant increase in building height or would increase the number of stories allowed along North Lake Avenue due to implementation of the General Plan Update. First, the General Plan Update would not change the maximum building height allowed within the North Lake Specific Plan. In accordance with the North Lake Specific Plan, the maximum allowable height for buildings east of North Lake Avenue adjacent to Bungalow Heaven is 30 feet.
Second, if a project applicant sought to build affordable housing in that location, there is no guarantee that they would receive a waiver of development standards to add an additional height. Pursuant to Pasadena Municipal Code Section 17.43.060, the project applicant must show that a waiver of development standards is required to construct the
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
3. Response to Comments
August 2015 Page 3-129
affordable housing. In practice, the City of Pasadena has not granted a waiver to maximum building height that would allow for the construction of an additional story since SB 1818 was enacted. Over the past 10 years there have only been eight approved development projects (one of which was superseded by a later application) that have received SB 1818 concessions, three of which included a concession for building height.
The concessions for building height in one instance allowed a seven foot increase with height averaging, in another instance a four foot increase in the rear of the building, and the final permitted an increase of four feet six inches.
Finally, the North Lake Specific Plan allows work/live and mixed-uses adjacent to Bungalow Heaven under the current zoning. A project applicant could therefore seek concessions under SB 1818 under current conditions. Therefore, it is not expected that the General Plan Update allowing mixed use would trigger the influx of new affordable housing development with applicants seeking a waiver of development standards to increase building height.
Section 2.2, State Density Bonus Law in this FEIR addresses impacts related to aesthetics and cultural resources. Impacts related to light, air quality, noise, and traffic are analyzed in the DEIR in Sections 5.1, 5.2, 5.9, and 5.13, respectively. General Plan Update buildout would not result in increased day or nighttime light that would substantially affect views. The commenter alleges that the DEIR did not address air quality, noise and traffic impacts of the General Plan Update, however both construction and operational impacts of General Plan Update buildout were analyzed and mitigation measures were included. There are no new impacts anticipated. CEQA does not require the analysis of impacts related to privacy or parking, therefore these impacts were not addressed in the DEIR.
R10-10 The parcel mentioned by the commenter is approximately 50 feet wide by 150 feet deep.
Based on these dimensions, the site’s allowed density under the General Plan Update, its narrow orientation, and parking requirements, the site could be realistically estimated to accommodate approximately three dwelling units if redeveloped. This scale of development would not be expected to “substantially damage scenic resources” or “substantially degrade the existing visual character or quality of the site and its surroundings.” However, this comment will be forwarded to the decision-making body for consideration.
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADE N A
3. Response to Comments
This page intentionally left blank.
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
3. Response to Comments
August 2015 Page 3-131
LETTER F1 – Forum #1 (2 pages)
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADE N A
3. Response to Comments
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
3. Response to Comments
August 2015 Page 3-133
F1. Response to Comments from Forum # 1, dated February 19, 2015 F1-1 Please refer to Section 2.2, State Density Bonus Law. The comments relate to the proposed General Plan Update and Land Use Element, not the potential environmental impacts of the project. However, the comment is noted and will be provided to the decisionmaking body (City Council) as part of the consideration of the General Plan Update adoption.
F1-2 These comments relate to the proposed General Plan Update, Land Use Element, and Mobility Element, not the potential environmental impacts of the project. However, the comments are noted and will be provided to the decision-making body (City Council) as part of the consideration of the General Plan Update adoption.
F1-3 The EIR process for the General Plan Update has been conducted by the City and its consultants consistent with state law and the state’s CEQA Guidelines. The DEIR was distributed for the maximum amount of time recommended under Section 15105 of the CEQA Guidelines (60 days). Furthermore, beginning on January 22, 2015, the General Plan Update and DEIR were available for review at the Office of the City Clerk, City of Pasadena Permit Center, Central Library, nine branch libraries, and the City’s website.
Above and beyond mandated requirements for public participation, the City held two public forums (February 19, 2015 and February 21, 2015) and collected input from ten City commissions (Arts and Culture, Design, Environment, Historic Preservation, Human Services, Northwest, Planning, Recreation and Parks, Senior, and Transportation) during the public review period of the DEIR. These formats for public participation were in addition to the traditional collection of written comments, which were received by the City of Pasadena via email and regular mail.
F1-4 Table 5.2-3 in the DEIR identifies existing air pollutant concentrations in Pasadena during periods in which adopted pollutant thresholds were exceeded. Table 5.2-4 shows Pasadena’s existing emissions inventory for criteria air pollutants, including ozone, carbon monoxide, nitrogen dioxide, sulfur dioxide, coarse particulate matter, and fine particular matter. Also, please refer to Section 2.3, Air Quality.
F1-5 No land use changes are proposed for the area near the Eaton Wash Reservoir and Dam. Under both the adopted General Plan and the General Plan Update, residential land uses are allowed near the reservoir. However, this area is largely built out and is not expected to experience substantial growth in dwelling units or population.
Additional development intensity (including that for residential land uses) is proposed downstream of the Eaton Wash Dam, primarily in the East Pasadena Specific Plan area.
As shown in Figure 5.7-4 of the DEIR, this area is within the inundation area of the dam. However, as explained under Impact 5.7-3 (see page 5.7-23 of the DEIR), the probability that there would be significant water behind the dam coinciding with a dam breach is extremely low. Eaton Wash Reservoir typically contains water substantially
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADE N A
3. Response to Comments
below its capacity and the facility is specifically engineered to control water and debris generated by storm events. Continued implementation of existing monitoring programs and emergency/evacuation plans would reduce impacts related to failure of the Eaton Wash Dam to a less than significant level. Because this impact is not considered potentially significant, no mitigation is necessary.
F1-6 The CMP congestion analysis in the EIR focuses on peak hour freeway traffic, not total vehicles per day. Table 5.13-9 in the DEIR identifies existing freeway traffic volumes for the three CMP freeway segments located in Pasadena. Table 5.13-10 projects future traffic volumes for the same three segments with implementation of the General Plan Update. As shown in these tables, freeway traffic volumes vary by segment and between AM and PM peak commute hours. Caltrans indicated that the I-210 freeway at Lake Avenue carried an Annual Average Daily Traffic count of 297,000 vehicles in 2013.
F1-7 Section 5.2, Air Quality, of the DEIR, analyzes several different types of air quality impacts. Per CEQA, analysis in the EIR is primarily concerned with impacts of the proposed project on air quality. For this reason, the air pollutant emissions inventory in Section 5.2 (see Table 5.2-9) focuses on the impact of emissions generated by implementation of the General Plan Update, not the overall emissions generated in the City. However, through freeway traffic (including that not generated by land uses in Pasadena) is considered when analyzing the effect of placing sensitive receptors near area freeways. Under Impacts 5.2-4 and 5.2-5, the DEIR analyzes the impact of air pollutants on land uses allowed by the proposed land use plan, which include new residential uses near high-volume roadways.
F1-8 The entirety of Section 5.9, Noise, of the DEIR analyzes the potential noise impacts of General Plan Update implementation. It should be noted that, due to the scale and programmatic nature of the proposed project, the DEIR contains program-level environmental analysis. Major development and infrastructure projects will be subject to project-specific CEQA compliance documents, which would include analysis of projectlevel noise impacts and associated mitigation.
F1-9 Mitigation Measure 2-4 identified in Section 5.2, Air Quality, of the DEIR outlines requirements for the preparation of health risk assessments (HRAs) where sensitive receptors (including residential uses) would be placed near major sources of air pollutants. Mitigation Measure 2-4 lists examples of measures that could be identified in a project-level HRA, including measures that mitigate air quality impacts of high-volume roadways. Implementation of such measures would reduce health risks associated with living near major transportation facilities.
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
3. Response to Comments
August 2015 Page 3-135
LETTER F2 – Forum #2 (2 pages)
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADE N A
3. Response to Comments
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
3. Response to Comments
August 2015 Page 3-137
F2. Response to Comments from Forum #2, dated February 21, 2015 F2-1 Please refer to Section 2.2, State Density Bonus Law. General Plan policy comments relate to the proposed General Plan Update and Land Use Element, not the potential environmental impacts of the project. However, the comment is noted and will be provided to the decision-making body (City Council) as part of the consideration of the General Plan Update adoption. It is important to note that, since SB 1818 is a state law, the City could not adopt a General Plan goal or policy that would impede implementation of state law and the underlying public policy goals of that law.
F2-2 These comments relate to the proposed General Plan Update, Land Use Element, and Mobility Element, not the potential environmental impacts of the project. However, the comments are noted and will be provided to the decision-making body (City Council) as part of the consideration of the General Plan Update adoption.
F2-3 The adopted Noise Element contains objectives, policies, and implementation programs related to unwanted noise, including noise generated by motor vehicles. Upon implementation of the General Plan Update, these objectives, policies, and programs would still apply. The proposed Land Use and Mobility elements are not the appropriate location for new or expanded police enforcement procedures related to noise.
Furthermore, the DEIR determined that implementation of the General Plan Update would not result in long-term operational noise that would substantially elevate the existing noise environment (Impact 5.9-1) and would not expose noise-sensitive land uses to elevated noise levels from transportation sources (Impact 5.9-2). Therefore, no mitigation is needed.
F2-4 It appears that the commenter suggests that the EIR should compare the proposed development caps with the existing development caps. Chapter 7 of the DEIR evaluates the “No Project/Adopted General Plan Alternative,” which is based on the policies, Land Use Diagram, and development caps of the Adopted General Plan. This alternative compares the General Plan Update with the Adopted General Plan. However, for purposes of analyzing environmental impacts and mitigation measures the DEIR must analyze impacts of the proposed project against the existing baseline conditions.
Section 15125 of the CEQA Guidelines establishes the “baseline” conditions for CEQA analysis be the environmental conditions at the time the notice of preparation is published or at the time environmental analysis is commenced. For this reason, the body of the DEIR evaluates the effects of General Plan Update implementation as compared to existing conditions (2013).
F2-5 The DEIR does not identify any potentially significant impacts related to canopies over the I-210 freeway or elsewhere. Therefore, no mitigation is needed.
F2-6 Preparation of CEQA documentation for a development project is required when: 1) a development proposal has been submitted to a public agency, 2) that agency must make
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADE N A
3. Response to Comments
a discretionary action to approve the project, and 3) the project would result in a direct physical change in the environment or a reasonably foreseeable indirect physical change in the environment. An EIR is required when there is substantial evidence that a project may have a significant effect on the environment (CEQA Guidelines Section 15064).
This determination is made by the lead agency.
Once a Program EIR has been certified for a project, subsequent projects within that program will be evaluated to determine whether additional CEQA documentation is required. A change in circumstances, such as the evaluation of water supply, will be considered at that time to determine whether there is the potential for new significant impacts requiring the preparation of an EIR.
With respect to water supply, Senate Bill 610 requires that water supply assessments (WSAs) be furnished to local governments for inclusion in any environmental documentation for certain projects subject to CEQA, as defined in Water Code Section 10912(a). Under SB 610, a WSA would be required for any project if it is a residential development of 500 units or more; a shopping center or business establishment project employing more than 1,000 persons or having more than 500,000 square feet of floor space; a commercial office building employing more than 1,000 persons or having more than 250,000 square feet of floor space; or an industrial, manufacturing, or processing plant or industrial park planned to house more than 1,000 persons, occupying more than 40 acres of land, or having more than 650,000 square feet of floor area. Individual development projects implemented under the proposed Land Use Diagram would be required to prepare a WSA if they meet these requirements.
Under Senate Bill 221, approval by a city or county of certain residential subdivisions requires an affirmative verification of sufficient water supply. SB 221 is intended as a fail-safe to ensure collaboration on finding the needed water supplies to serve a new large subdivision before construction begins. See Subsection 5.14.2 of the DEIR for additional information.
F2-7 Implementation of the proposed project does not require nonconforming uses to be demolished or otherwise eliminated. Legal nonconforming uses and structures may remain. Land use designations identified on the proposed Land Use Diagram only restrict future entitlements on the affected parcels.
F2-8 Please refer to Section 2.3, Air Quality.
F2-9 Project EIRs are the most common type of EIR; they examine the impacts of a specific development or infrastructure project, such as a new building, housing tract, or highway improvement project. Project EIRs focus primarily on the changes in the environment that would result from implementation of that specific, well-defined project.
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
3. Response to Comments
August 2015 Page 3-139
A Program EIR is an EIR that covers a large project or policy document or a series of actions that work as one big project because they’re related geographically, logically, by statute, or by similar impacts (CEQA Guidelines Section 15168). Comprehensive General Plan Updates are almost always processed using a Program EIR, since the details of individual development projects allowed under the proposed plan are not known and the impacts of proposed policies are general in nature. Analysis is generally programmatic and does not focus on localized environmental effects like in a Project EIR. Program EIRs are often used for “tiering,” which is the practice of incorporating by reference the general environmental issues of a program EIR and concentrating on project-specific issues (either in a Project EIR or a more specific Program EIR). A “tiered” document is most often used for a project that implements the program covered by the broader EIR. See also response to Comment F2-6 for what constitutes a project under CEQA.
F2-10 For a list of the proposed project’s significant and unavoidable adverse impacts, see Chapter 6 of the DEIR. Implementation of the proposed project would result in significant unavoidable adverse impacts related to air quality, greenhouse gas emissions, noise, and traffic.
F2-11 The lead agency’s decision-making body, in this case the City of Pasadena City Council, may choose to adopt either the General Plan Update as proposed, something less than the project as proposed, or one of the project alternatives (if it finds that alternative feasible). The findings of fact prepared for the City Council’s discretionary action must reflect 1) which scenario is being adopted, 2) applicable mitigation measures for that scenario, and 3) the status of potentially significant impacts after mitigation. The EIR’s Statement of Overriding Considerations must also reflect the approved project/alternative. If a project alternative is approved, substantial evidence must be included in the administrative record documenting how the conclusions of the EIR remain valid.
F2-12 The commenter refers to a site in the Central District of Pasadena that is currently vacant. The analysis and mitigation outlined in the EIR apply to new development potential under the general plan. Mitigation Measure 2-4 identified in Section 5.2, Air Quality, of the DEIR outlines requirements for the preparation of HRAs. Future entitlements on the site in question, and elsewhere in the City, would be subject to mitigation measures identified in Section 5.2 upon adoption of the General Plan Update.
F2-13 The proposed project establishes new residential and nonresidential development caps for Pasadena’s specific plan areas. See Chapter 3, Project Description, of the DEIR for more information.
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADE N A
3. Response to Comments
F2-14 The commenter endorses the adoption of a specific project alternative. No response is required.
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
3. Response to Comments
August 2015 Page 3-141
LETTER C1 – City Commissions (9 pages)
The following are verbal comments and questions received during the DEIR Comment Period from eleven Commission meetings held in February and March of 2015.
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADE N A
3. Response to Comments
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
3. Response to Comments
August 2015 Page 3-143
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADE N A
3. Response to Comments
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
3. Response to Comments
August 2015 Page 3-145
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADE N A
3. Response to Comments
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
3. Response to Comments
August 2015 Page 3-147
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADE N A
3. Response to Comments
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
3. Response to Comments
August 2015 Page 3-149
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADE N A
3. Response to Comments
This page intentionally left blank.
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
3. Response to Comments
August 2015 Page 3-151
C1 Response to Comments City Commission
C1-1 The General Plan Update and DEIR were presented to the Arts and Culture Commission on March 11, 2015. The commission’s comments related to the proposed Mobility Element and de-emphasized streets map, not the potential environmental impacts of the project. However, the comment is noted and will be provided to the decision-making body (City Council) as part of the consideration of the General Plan Update adoption.
C1-2 The General Plan Update and DEIR were presented to the Design Commission on February 24, 2015. The commission had a number of suggested revisions to the proposed goals and policies in the proposed Land Use Element. These comments do not relate to the potential environmental impacts of the project. However, the comment is noted and will be provided to the decision-making body (City Council) as part of the consideration of the General Plan Update adoption.
C1-3 California Governor Edmund Brown Jr. declared a drought state of emergency on January 17, 2014, asking Californians to reduce water use by 20 percent. The US Department of Agriculture designated 27 California counties, including Los Angeles County, as primary natural disaster areas on January 15, 2014, due to the drought (USDA 2014). The California Department of Water Resources (DWR) reports that State Water Project allocations have been substantially reduced in recent years. There was a 35 percent allocation in 2013 and a 5 percent allocation in 2014, resulting from dry conditions. As of March 2015, the allocation was increased to 20 percent.
In response to the drought, the State Water Resources Control Board adopted Resolution No. 2014-0038 (July 15, 2014) and emergency regulations to ensure that water suppliers, their customers, and state residents increase water conservation and prohibits wasting water in urban settings. Water suppliers are required to activate their Water Shortage Contingency Plan, educate customers and employees, increase local supplies, and report progress.
State Mandates for Water Conservation
On April 1, 2015, Governor Brown signed an executive order directing the State Water Resources Control Board to impose a 25 percent reduction on local water agencies (compared to 2013 water usage). In addition to mandates for cuts in water usage, the executive order includes other conservations requirements and requires water purveyors and large agricultural producers to prepare detailed reports about water use to state regulators.
On April 28, 2015, the State Water Resources Control Board outlined its plan for new mandates on water usage. They consist of conservation targets based on per-capita residential water use. They sort the state’s water districts into nine tiers, each with their
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADE N A
3. Response to Comments
own mandated reductions in water usage based on current consumption rates. The lowest is a 4 percent cut, but most agencies are required to cut usage between 8 and 36 percent. Pasadena Water and Power (PWP) was assigned a 28 percent reduction target.
Water Supply Analysis in the DEIR
The DEIR analyzed water supplies and projected water needs based in part on Pasadena’s 2010 Urban Water Management Plan (UWMP). Water supply is analyzed in Subsection 5.14.2, Water Supply and Distribution Systems, of the DEIR. This subsection explains that Pasadena Water and Power (PWP) obtains water from four sources: groundwater from the Raymond Groundwater Basin; surface water from the Arroyo Seco and Eaton Canyon; purchases from neighboring agencies that combine surface water and groundwater; and imported water from northern California and the Colorado River purchased from the Metropolitan Water District of Southern California (MWD). The subsection also describes water supply projects planned by PWP that would increase the available water supply. Section 5.14, Utilities and Service Systems, of the DEIR acknowledges that Southern California and Pasadena face challenges related to the long-term availability and reliability of water supplies. The Metropolitan Water District (MWD) and PWP both have water supply contingency plans in place, including plans that consider statewide water shortages, catastrophic interruptions to water supplies, and up to a 50 percent reduction in water supplies. See Subsection 5.14.2.1 of the DEIR for detailed information about contingency planning related to Pasadena’s water supply.
Pasadena is in an extreme drought period. In periods of extreme drought, the City relies on its Water Supply Shortage Plans (PMC 13.10) to ensure there is adequate water supply to meet the needs of the growing community. The Water Supply Shortage Plan has four levels of increasingly restrictive measures to address water shortages. Under a Level 4 Water Supply Shortage no new potable water service is permitted.
Despite ongoing drought conditions and threats to the state’s water supplies, the City of Pasadena is not expected to experience a catastrophic shortage of water. As evaluated in Section 5.14 of the DEIR, water demand at buildout of the General Plan Update would represent less than a 1 percent increase over the existing demand. Although buildout of the General Plan Update would increase the City’s population by 27,473 and its number of employees by 40,323, this growth would take place in a City that is largely built out geographically. Adding higher density housing and additional commercial space has not resulted in increased water demand in Pasadena. Despite significant development and population growth over the last fifty years, PWP’s total water use is about the same as it was in 1960. New homes and businesses would largely be introduced in heavily urbanized areas of Pasadena where new uses would generally lessen the amount of land dedicated to turf or is otherwise irrigated. In addition, the City of Pasadena ensures that new development will consume water extremely efficiently by mandating the installation
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
3. Response to Comments
August 2015 Page 3-153
of water efficient fixtures as described in the California Green Building Code.
Furthermore, implementation of existing and planned conservation measures would ensure that per-capita usage of water would decrease over the period covered by the General Plan Update.
Enforcement of existing regulations, conservation programs, and contingency plans are expected to ensure that water demands in Pasadena are met during the planning period of the General Plan Update. Section 5.14 of the DEIR includes a detailed rationale for this conclusion. Furthermore, large development projects in Pasadena allowed under the General Plan Update—such as those with 500 or more dwelling units and those employing more than 1,000 persons—would be required to prepare a water supply assessment (WSA) consistent with Senate Bill 610. These project-level WSAs would evaluate the availability of water to serve the proposed land uses.
City Efforts to Address Water Supply
In response to ongoing drought conditions, the City has taken measures to ensure that residents, businesses, and public facilities use water efficiently. Pasadena’s Municipal Services Committee (MSC) has indicated its intent to expand local conservation efforts, with the goal of exceeding the water usage mandates imposed on PWP by the state.
Level 2 water supply shortage conservation measures were adopted on June 1, 2015, consistent with Pasadena Municipal Code Chapter 13.10. Level 1 measures were in effect as of July 28, 2014 and included the following restrictions:
Outdoor watering three days per week, on Tuesday, Thursday and Saturday, during the spring and summer months, April 1 through October 31. Property owners can water one day per week November 1 through March 31.
No watering outdoors between 9 a.m. and 6 p.m., except with a handheld container or hose with a shutoff nozzle.
No watering during periods of rain.
All water leaks must be fixed within 72 hours.
No excessive water flow or runoff onto pavement, gutters or ditches from watering or irrigating landscapes or vegetation of any kind.
No washing down paved surfaces unless for safety or sanitation, in which case a bucket, a hose with a shutoff nozzle, a cleaning machine that recycles water or a low-volume/high-pressure water broom must be used.
No washing vehicles except by using a handheld bucket or similar container or hose equipped with a water shutoff nozzle.
Level 2 measures restrict water to two days per week, on Tuesday and Saturday from April 1 through October 21, all water leaks must be fixed within 48 hours, and a prohibition on the filling of ornamental lakes and ponds.
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADE N A
3. Response to Comments
Conservation measures are also found in the Pasadena General Plan’s adopted Open Space & Conservation Element and the proposed Land Use Element.
Water Projects
The City of Pasadena has a number of long range planning projects to increase water supply within the City as described on Page 5.14-18 of the DEIR. Additionally, on June 1, 2015, City Council approved the Arroyo Seco Canyon Project. This project is a partnership between PWP and the Arroyo Seco Foundation to expand the spreading area basin allowing additional capture of local water supplies. Implementation of the Arroyo Seco Canyon Project is estimated to increase groundwater recharge in the area by 1,100 acre-feet per year (afy) compared to existing conditions and will be completed at the end of 2016.
Conclusion
Water supply impacts of the proposed project are anticipated to be less than significant.
No new impact to water supplies has been identified and no changes the conclusions of the DEIR are necessary.
C1-4 The General Plan Update and DEIR was presented to the Environmental Advisory Commission on March 17, 2015. The commission’s comments related to the proposed General Plan Update, Land Use Element, and Mobility Element, not the potential environmental impacts of the project. However, the comment is noted and will be provided to the decision-making body (City Council) as part of the consideration of the General Plan Update adoption.
C1-5 The General Plan Update and DEIR was presented to the Historic Preservation Commission on February 17, 2015. The commission’s comments related to the street classification map, not the potential environmental impacts of the project. However, the comment is noted and will be provided to the decision-making body (City Council) as part of the consideration of the General Plan Update adoption.
C1-6 Without mitigation, the General Plan Update would not 1) physically divide an established community, 2) conflict with applicable plans adopted for the purpose of avoiding or mitigating an environmental effect, or 3) conflict with an applicable conservation plan. These thresholds are identified in Appendix G of the state CEQA Guidelines for land use and planning and have been utilized in this EIR. When impacts are not potentially significant pursuant to adopted thresholds, they are considered less than significant and no mitigation is necessary.
C1-7 The commenter refers to Mitigation Measure 4-2, which is identified in Section 5.4, Cultural Resources, of the DEIR. This measure requires project applicants to provide paleontological studies and mitigation plans when applying for permits to grade within
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
3. Response to Comments
August 2015 Page 3-155
the Topanga formation. As the commenter indicates, the applicable area is primarily a single-family residential neighborhood. However, Mitigation Measure 4-2 is necessary to reduce paleontological resource impacts to a less than significant level. Since the area is generally built out and many new single family homes (or home remodels) would not require grading more than six feet deep, there would be no impact and this measure is not expected to apply to a large number of projects during the planning period of the General Plan Update. However, it would be required if a new discretionary project were proposed in that area.
C1-8 The 25-foot buffer was analyzed pursuant to the Federal Transit Administration (FTA) guidelines. Pursuant to the commenter’s request we have revised the vibration sensitivity buffer distance to ensure adequate protection of all historic structures. Using worst case (upper range) vibrations from an impact pile driver, the standard distance attenuation calculation shows that 150 feet would be below the FTA vibration-induced architectural damage criterion. Mitigation Measure 9-4 has been modified, as shown below, to require that vibration studies be prepared for all vibration-intensive construction activities within 50 feet of sensitive receptors and eliminates the use of pile drivers within 150 feet of historic structures.
9-4 Prior to issuance of any construction permits, applicants for individual projects that involve vibration-intensive construction activities, such as pile drivers, jack hammers, bulldozers, and vibratory rollers, within 25 feet of sensitive receptors (e.g., residences and historic structures) or 50 feet of historic structures, shall prepare and submit to the City of Pasadena Planning Division a study to evaluate potential construction-related vibration impacts. The vibration assessment shall be prepared by an acoustical engineer and be based on the FTA vibration-induced architectural damage criterion. If the study determines a potential exceedance of the FTA thresholds, measures shall be identified that ensure vibration levels are reduced to below the thresholds. Measures to reduce vibration levels can include use of less-vibration-intensive equipment (e.g., drilled piles and static rollers) and/or construction techniques (e.g., nonexplosive rock blasting and use of hand tools) and preparation of a preconstruction survey report to assess the condition of the affected sensitive structure. Notwithstanding the above, pile drivers shall not be allowed within 150 feet of any historic structures. Identified measures shall be included on all construction and building documents and submitted for verification to the City of Pasadena Planning Division.
C1-9 As discussed in Section 5.4, Cultural Resources, of the DEIR, the fact that a resource is not listed in or determined to be eligible for listing in the California Register of Historical Resources, or is not included in a local register of historical resources, does not preclude a lead agency from determining that the resource is a historical resource pursuant to CEQA. Section 17.62.090, Alteration, Demolition, or Relocation of a Historic Resource, of the Pasadena Zoning Code states that its provisions apply to a designated
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADE N A
3. Response to Comments
historic resource or “a historic resource eligible for designation.” Furthermore, the same section of the code states that the California State Historical Building Code also applies to an un-designated property if the Director of Planning and Permitting determines that the property qualifies for a historic designation.
C1-10 Refer to response to Comment C1-8. Per the CEQA statute and state CEQA Guidelines, the purpose of mitigation is to avoid or minimize significant adverse impacts. Accordingly, Mitigation Measure 9-4 in Section 5.9 of the DEIR focuses on avoidance of potential vibration-related impacts to historic structures rather than allowing significant impacts to occur and then remedying them afterward. Furthermore, unmitigated construction-related vibration can cause more than cosmetic damage; it could destroy portions of historic structures that may be infeasible to fix by repairs and/or financial disbursements imposed after the damage has occurred.
C1-11 Although most of the land use changes proposed by the General Plan Update are located in its eight Specific Plan areas, development and redevelopment projects could be constructed throughout the City. For this reason, analysis in Section 5.4 of the DEIR and the mitigation measures contained therein address protection of historic resources irrespective of their location. Therefore, a list of the City’s historic resources organized by Specific Plan would not illuminate new or greater impacts related to historic resources as analyzed by the DEIR.
C1-12 Refer to response to Comment C1-5.
C1-13 Section 5.4, Cultural Resources, of the DEIR determined that implementation of proposed General Plan Update policies and continued implementation of existing local, state, and federal regulations would ensure that impacts to historic resources would be less than significant. In particular, General Plan Update Policies LU 8.1 through LU 8.10 and Municipal Code Section 17.62.010 et seq. are specifically crafted to protect Pasadena’s historic resources—including resources that are eligible for historic designation but are not officially registered—from unnecessary demolition or excessive alteration.
C1-14 Refer to response to Comment C1-8. Noise modeling and analysis was conducted for the General Plan Update and included in Appendix G and Section 5.9 of the DEIR.
Mitigation Measures 9-1 through 9-4 identified in the DEIR include explicit references to impacts generated by specific types of vibration activities: “industrial projects” (Mitigation Measure 9-1), “development projects…” within “…screening distances for light rail transit” (Mitigation Measure 9-2), “individual projects that involve…construction activities” (Mitigation Measures 9-3 and 9-4). The measures do not imply that required noise and vibration studies would be required to analyze potential impacts from helicopter overflight.
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
3. Response to Comments
August 2015 Page 3-157
C1-15 Under CEQA, the purpose of mitigation measures is to tangibly reduce or avoid significant adverse impacts. Where no potentially significant impacts are identified, no mitigation is necessary. Impacts 5.7-1 through 5.7-5, as identified in Section 5.7, Hydrology and Water Quality, of the DEIR, were determined to be less than significant upon implementation of regulatory requirements and standard conditions.
C1-16 The distribution, scale, and overall design of development constructed in Pasadena during the planning period of the General Plan Update would be largely driven by market demands. A visual model representing buildout of the General Plan Update would require a large amount of speculation regarding future development.
Furthermore, because neighborhoods in Pasadena—and the City as a whole—are not expected to be built out at maximum allowable building intensities, it would be misleading to create a visual representation of maximum allowable buildout. However, that growth scenario has been utilized and is useful for forecasting other types of environmental analysis (e.g., water supply, student generation), but not appropriate for assessing the future physical appearance of the City as a whole.
C1-17 Comment noted.
C1-18 The paleontological and cultural resources technical report included as Appendix E to the DEIR found five archeological resources in Pasadena: three known prehistoric resources and two historical archeological sites. Locations of these sites and the types of resources in them are kept confidential due to their sensitive nature. Because additional unknown archeological resources could theoretically be found anywhere in Pasadena, a map would not be useful for disclosure of potential impacts to such resources.
C1-19 State laws related to discovery of human remains are listed under Subsection 5.4.5, Existing Regulations and Standard Conditions, of the DEIR and are not restated in the mitigation measures listed under Subsection 5.4.7. No revisions to the DEIR are necessary.
C1-20 The City conducted a Native American Consultation pursuant to California Governmental Code Sections 6540.2, 65092, 65351, and 65352. On April 11, 2014, the City requested a list a tribes from the Native American Heritage Commission (NAHC).
The NAHC sent a list of four tribes to contact for the government to government consultation on April 15, 2014. The City mailed a consultation request to each of the four tribes via certified mail. It was documented that all tribes received the certified mail on and between May 6, 2014 and May 22, 2014. The City received one call from Anthony Morales of the Gabrieleno/Tongva San Gabriel Band of Mission Indians. He requested recognition of inhabited areas along the Arroyo Seco and around Devil’s Gate as areas that have the potential to yield significant archeological resources.
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADE N A
3. Response to Comments
In addition to the Native American Consultation, NAHC performed a Sacred Lands File service. This search failed to indicate the presence of Native American traditional cultural places on the project site or areas of potential effect.
C1-21 The Archaeological Resources Protection Act of 1979 regulates the protection of archaeological resources and sites that are on federal and Indian lands. The commenter is correct in that there are several federally-owned parcels in Pasadena where this law applies.
C1-22 The mitigation monitoring and reporting plan (MMRP) has been prepared as part of the FEIR and will be circulated with other components of the FEIR (such as this Response to Comments chapter). The MMRP contains mitigation measures already previously identified in the DEIR except where modified as part of this FEIR.
C1-23 The General Plan Update and DEIR were presented to the Human Services Commission on March 11, 2015. The commission’s comments related to the proposed General Plan Update, not the potential environmental impacts of the project. However, the comments are noted and will be provided to the decision-making body (and City Council) as part of the consideration of the General Plan Update adoption.
C1-24 The General Plan Update and DEIR were presented to the Northwest Commission on March 12, 2015. The commission’s comments related to the proposed General Plan Update, Land Use Element, and Mobility Element, not the potential environmental impacts of the project. However, the comments are noted and will be provided to the decision-making body (City Council) as part of the consideration of the General Plan Update adoption.
C1-25 In 2013, the legislature passed Senate Bill 743 (SB 743) with the intention to “more appropriately balance the needs of congestion management with statewide goals related to infill development, promotion of public health through active transportation, and reduction of greenhouse gas emissions (SB 743, Section 1(b)(2)). Among the mandates of SB 743 was for the State Office of Planning and Research (OPR) to adopt guidelines that establish an alternative to level of service (LOS), which is currently used to measure traffic congestion/auto delay under CEQA. Draft guidelines were published by OPR in July, 2014. These draft guidelines propose alternative metrics for analyzing traffic impacts, including vehicle miles traveled (VMT), similar to those adopted by the City of Pasadena. However, final guidelines are not expected until summer or fall of 2015. It is expected that the new guidelines would be phased in beginning in 2016.
C1-26 Mitigation for the significant traffic impact at the intersection of Pasadena Avenue and California Boulevard would require conversion of one westbound through lane to a shared through/right-turn lane. Such mitigation would degrade the pedestrian environment by creating two lanes of right-turning traffic that would conflict with pedestrians crossing the north and east legs of the intersection, inconsistent with the
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
3. Response to Comments
August 2015 Page 3-159
General Plan Update’s goals and policies related to improving access to destinations by pedestrians. Therefore, no mitigation is considered feasible and the traffic impact at this intersection would be significant and unavoidable.
C1-27 As shown in Subsection 7.5.13 of the DEIR, the Pasadena Avenue/California Boulevard intersection would operate at LOS F during the AM peak hour under the CD, SFO, and LA Alternative, as under the proposed project. The impact would be significant and unavoidable under both scenarios.
C1-28 Please refer to Section 2.1, Transportation Metrics.
C1-29 This comment relates to the land use planning implications of the General Plan Update and not the potential environmental impacts of the project. The City’s specific plans will be updated in a comprehensive manner, consistent with the General Plan Update, and anticipated to begin in Winter 2015/2016.
C1-30 The commenter’s concerns regarding freeway-generated air quality impacts and air quality monitoring stations are addressed in Section 2.3, Air Quality, of the DEIR and Responses to Comments R6-1, R6-2, R7-2, and R7-4.
C1-31 Pasadena has hundreds of historic homes and uncountable additional scenic resources.
As mentioned in the table’s footnote, Table 5.1-1 is not intended to represent an exhaustive list of visual resources in Pasadena. Instead, it provides examples of wellknown scenic resources in different areas of the City in order to illustrate the great number and broad range of such resources. However pursuant to the commenter’s request Table 5.1-1 has been updated to include historic single-family neighborhoods.
Table 5.1-1 Examples of Visual Resources in Pasadena
Specific Plan/Neighborhood Visual Resource Type of Visual Resource* Specific Plan Areas
Central District • All Saints Episcopal Church
• Castle Green/Green Hotel Apartments
• Central Park
• City Hall
• Civic Auditorium
• Colorado Boulevard
• Memorial Park
• Pasadena City Library
• Pasadena Playhouse
• St. Andrews Catholic Church
• Historic resource
• Historic resource
• Foliage and greenery
• Historic resource
• Historic resource
• Scenic corridor
• Foliage and greenery
• Historic resource
• Historic resource
• Historic resource
East Colorado • Holliston Community Church • Historic resource East Pasadena • Municipal Light and Power Building
• Former Stuart Pharmaceutical Building
• Historic resource
• Historic resource
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADE N A
3. Response to Comments
Table 5.1-1 Examples of Visual Resources in Pasadena
Specific Plan/Neighborhood Visual Resource Type of Visual Resource* Fair Oaks/Orange Grove • La Pintoresca Library and Park • Historic resource Lincoln Avenue • Palm trees along Washington Boulevard • Foliage and greenery South Fair Oaks • Industrial/warehouse buildings
• Glenarm Power Plant fountain
• Unique visual character
• Historic resource
West Gateway • Colorado Street Bridge
• Maranatha High School/Ambassador Auditorium
• Landscaped yards of large estates
• Camphor, magnolia, and palm street trees
• U.S. Court of Appeals Bldg.
• Historic resource
• Landscaped grounds; Historic resource
• Foliage and greenery; unique visual character
• Foliage and greenery
• Historic resource
Outside Specific Plan Areas
Northwest • Arroyo Seco/Brookside Park Corridor
• Arroyo Terrace National Register Historic District
• Banbury Oaks Landmark District
• Devils Gate Dam
• Hahamongna Watershed Park (Upper Arroyo)
• Gamble House
• Pegfair Estates National Register Historic District
• Prospect National Register Historic District
• Rose Bowl
• Wotkyns-Richland Landmark District
• Foliage and greenery
• Historic resource
• Historic resource
• Historic resource
• Foliage, topography, and greenery
• Historic resource
• Historic resource
• Historic resource
• Historic resource
• Historic resource
Northeast • Bristol-Cypress National Register Historic District • Bungalow Heaven Landmark District/National
Register Historic District
• Crawford’s Vista Landmark District
• Craftsman bungalows
• Eaton Canyon
• Garfield Heights Landmark District
• Holliston Avenue Landmark District
• New Fair Oaks National Register Historic District
• Normandie Heights Landmark District
• North Pasadena Heights Landmark District
• Orange Heights National Register Historic
District
• Raymond-Esther Landmark District
• Raymond-Summit National Register Historic
District
• St. Elizabeth of Hungary Catholic Church
• Washington Square Landmark District
• Westminster Presbyterian Church
• Historic resource
• Historic resource
• Historic resource
• Historic resource
• Foliage, topography, and greenery
• Historic resource
• Historic resource
• Historic resource
• Historic resource
• Historic resource
• Historic resource
• Historic resource
• Historic resource
• Historic resource
• Historic resource
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
3. Response to Comments
August 2015 Page 3-161
Table 5.1-1 Examples of Visual Resources in Pasadena
Specific Plan/Neighborhood Visual Resource Type of Visual Resource* • Historic resource
Southeast • California Institute of Technology
• Historic homes (many in Spanish-derived
architectural styles)
• Marengo-Pico Landmark District
• Marguerita Lane National Register Historic
District
• South Hudson Avenue Landmark District
• South Madison Landmark District
• South Marengo National Register Historic District
• South Oakland Landmark District
• Street trees (including camphor and palm trees
on numerous streets)
• Tournament Fields Landmark District
• Landscaped grounds
• Unique visual character
• Historic resource
• Historic resource
• Historic resource
• Historic resource
• Historic resource
• Foliage and Greenery
• Historic resource
Southwest • Bellefontaine Landmark Distirct
• Lower Arroyo Seco
• Lower Arroyo Seco National Register Historic
District
• Markham Place/Governor Markham National
Register Historic District
• Poppy Peak National Register Historic District
• Ross Grove Landmark District
• San Rafael Hills
• South Grand-Covington Place Landmark District
• Weston-Bungalowcraft Landmark District
• Historic resource
• Foliage and greenery/natural habitat
• Historic resource
• Historic resource
• Historic resource
• Historic resource
• Foliage, topography, and greenery
• Historic resource
• Historic resource
Citywide
• Views of San Gabriel Mountains
• Mature street trees
• Public art
• Scenic backdrop
• Foliage and greenery
• Artistic beauty
* For discussion of officially designated historic landmarks, see Section 5.4, Cultural Resources, of this DEIR.
Note: This table is not meant to represent an exhaustive list of visual resources in Pasadena. Instead, it provides examples of well-known scenic resources in different areas of the City.
C1-32 City staff also confirmed that the amount of units studied over the development caps for affordable housing was carried through the DEIR analysis. An example is shown on
C1-33 Commented noted.
C1-34 The Planning Commission had two opportunities to comment on the General Plan Update DEIR on February 11, 2015 and March 11, 2015. As confirmed at the hearing, the Planning Commission will be presented with the General Plan Update and FEIR.
C1-35 Please refer to Section 2.1, Transportation Metrics.
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADE N A
3. Response to Comments
C1-36 Please refer to Section 2.1, Transportation Metrics.
C1-37 Please refer to Section 2.1, Transportation Metrics, and response to Comment C1-26.
C1-38 Please refer to Section 2.1, Transportation Metrics. Projects of community wide significance are required to conduct and mitigate for auto delay at intersections (see Appendix A of this FEIR).
C1-39 The DEIR discloses that air quality impacts of the proposed project, including those related to consistency with SCAQMD thresholds, are significant and unavoidable.
Population and employment growth greater than that analyzed in the DEIR would not change the significance conclusions identified for these impacts. Furthermore, buildout projections for the General Plan Update assume an optimistic growth scenario based on allowable building intensity and other factors. The City does not expect Pasadena to grow beyond those projections during the planning period of the General Plan Update.
C1-40 Vibration studies, as required by Mitigation Measures 9-3 and 9-4, are required to consider the cumulative effects of vibration resulting from the project and adjacent construction projects that would affect the project site.
C1-41 The commenter requested to understand what CEQA process would occur if changes are made to the Land Use Diagram after public review of the DEIR but before adoption of the General Plan Update. The Planning Commission may recommend changes to land uses in the City. Those changes would need to be evaluated within the context of the project as a whole to determine if it would result in any new significant environmental impacts. If new significant impacts are identified, or if a substantial increase in the severity of an environmental impact would result, then recirculation would be required pursuant to CEQA Guidelines Section 15088.5. However, minor changes that would not result in significant new impacts beyond those addressed in the DEIR would be documented in the staff report and findings and considered during General Plan Update adoption.
C1-42 The General Plan Update and DEIR were presented to the Recreation and Parks Commission on March 17, 2015. The commission’s comments related to the proposed General Plan Update, Land Use Element, and Mobility Element, not the potential environmental impacts of the project. However, the comments are noted and will be provided to the decision-making body (and City Council) as part of the consideration of the General Plan Update adoption.
C1-43 The General Plan Update and DEIR were presented to the Senior Commission on March 10, 2015. The commission had no comments.
C1-44 The General Plan Update and DEIR were presented to the Transportation Advisory Commission on February 26, 2015. The commission’s comments are related to the
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
3. Response to Comments
August 2015 Page 3-163
proposed General Plan Update, Land Use Element, and Mobility Element, not the potential environmental impacts of the project. However, the comments are noted and will be provided to the decision-making body (and City Council) as part of the consideration of the General Plan Update adoption.
C1-45 Section 15126.6(e)(2) of the CEQA Guidelines requires a lead agency to identify the “environmentally superior alternative” and, in cases where the “no project” alternative is environmentally superior to the proposed project, “the EIR shall also identify an environmentally superior alternative among the other alternatives.” The City agrees with the commenter that the Efficient Transportation Alternative is also environmentally superior to the proposed project. As shown in Table 7-19 of the DEIR, the Central District, South Fair Oaks, Lincoln Avenue Alternative and the Efficient Transportation Alternative are both environmentally superior to the proposed project. However, the DEIR identifies the most environmentally superior alternative taking into account all environmental issues.
C1-46 Achievement of the proposed project’s objectives, as listed in Subsection 7.1.2 of the DEIR, cannot be feasibly enumerated. For example, enhancement of “quality of life” (Objective 1) and achievement of “economic vitality” (Objective 5) cannot be quantified. Furthermore, the “Conclusion” subsection for each alternative analyzed in Section 7 of the DEIR identifies which objectives would not be met, or would be met to a lesser degree, by each respective alternative. A comparison of the environmental impacts of the alternatives is provided in Table 7-19.
C1-47 The commissioner is correct in noting that the regional jobs-housing balance was not calculated for the project alternatives identified in Chapter 7, Alternatives, of the DEIR.
The table below calculates the effect of the alternatives on regional jobs-housing balance.
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADE N A
3. Response to Comments
Table C1.1 Impact of Project Alternatives on Regional Jobs-Housing Balance Proposed
Project
No Project/
Adopted General
Plan Alternative
Central District, South
Fair Oaks, and Lincoln
Avenue Alternative
Efficient
Transportation
Alternative
Reduced Air Quality
and Noise Impact
Alternative
City of Pasadena
Dwelling Units 71,953 66,113 70,152 71,914 72,078
Employment 151,671 148,532 146,023 149,345 151,444
Jobs-Housing Ratio 2.11 2.25 2.08 2.08 2.10
Difference between Alternative and 2035 SCAG Projections Dwelling Units (2035 SCAG
Projection: 64,631) 7,322 1,482 5,521 7,283 7,447
Employment (2035 SCAG
Projection: 131,300) 20,371 17,232 14,723 18,045 20,144 San Gabriel Valley plus Difference1
Dwelling Units (2035 SCAG
Projection: 552,416) 559,738 553,898 557,937 559,699 559,863 Employment (2035 SCAG
Projection: 728,700) 749,071 745,932 743,423 746,745 748,844 Jobs-Housing Ratio 1.34 1.35 1.33 1.33 1.34
1 Figures for the number of dwelling units and employees in the SGV were calculated by adding 2035 SCAG projections for SGV with the difference in units and employees between 2035 SCAG projections for Pasadena and each respective project alternative.
As shown in the table, all of the alternatives have a similar impact on the San Gabriel Valley’s balance of jobs and housing, with values ranging from 1.33 to 1.35. Under all scenarios, the region would have a healthy jobs-housing balance that is close to that projected for the region in 2035 by the Southern California Association of Governments (SCAG). The impact of each alternative on the overall region is small due to the fact that the region’s jobs-housing ratio is largely a function of units and jobs elsewhere in the region. However, Pasadena is an important hub of jobs in the San Gabriel Valley, most of the region’s jobs (and dwelling units) are outside Pasadena.
Chapter 7 of the DEIR examines the respective traffic impacts of each alternative in regards to freeway mainline segments identified in the Los Angeles County Congestion Management Program (CMP). This analysis demonstrates how each growth scenario would affect the regional transportation network.
C1-48 The commission’s comments relate to the proposed General Plan Update, Land Use Element, and Mobility Element, not the potential environmental impacts of the project.
However, the comments are noted and will be provided to the decision-making body (and City Council) as part of the consideration of the General Plan Update adoption.
August 2015 Page 4-1
4. Revisions to the Draft EIR
4.1 INTRODUCTION
This section contains revisions to the DEIR based upon (1) additional or revised information required to prepare a response to a specific comment; (2) applicable updated information that was not available at the time of DEIR publication; and/or (3) typographical errors. This section also includes revisions to a mitigation measure to fully respond to commenter concerns as well as provide additional clarification to mitigation requirements included in the DEIR. The revision to the mitigation measure does not alter any impact significance conclusions as disclosed in the DEIR. Changes made to the DEIR are identified here in strikeout text to indicate deletions and in underlined text to signify additions.
4.2 DEIR REVISIONS
The following text has been revised in response to comments received on the DEIR.
Dillard.
4.2.1.1 REGIONAL WATER QUALITY CONTROL BOARD
The City of Pasadena and its sphere of influence are in the jurisdictional area of the Los Angeles Regional Water Quality Control Board (LARWQCB). Requirements for avoiding or minimizing stormwater pollution from operation of development projects are in the LARWQCB’s Order No. 01-182 R4-2012-0175, Waste Discharge Requirements for Municipal Separate Storm Sewer System Water and Urban Runoff Discharges in the County of within the Coastal Watersheds of Los Angeles County (“MS4 Permit”) and National Pollution Discharge Elimination System (NPDES) Permit No. CAS004001, most recently amended on April 14, 2011.
MS4 permit requirements meet the National Pollution Discharge Elimination System (NPDES) regulations authorized by Section 402 of the Clean Water Act. The City of Pasadena is a co-permittee on the MS4 Permit and has adopted a Standard Urban Stormwater Mitigation Plan ordinance (Municipal Code Chapter 8.70) to ensure new developments comply with the MS4 Permit.
Pasadena Heritage.
Central District. Pasadena’s Central District is the City’s urban core and includes downtown Pasadena, Old Pasadena, the Civic Center/Midtown area, and the Playhouse District. Colorado Boulevard, which runs east–west through the Central District, is one of the region’s premier retail destinations. The specific plan area features numerous historic and culturally important sites, including City Hall, and the Pasadena
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
4. Revisions to the Draft EIR
Playhouse, Central Park, and Memorial Park. Historic districts include the Old Pasadena, Pasadena Civic Center, Civic Center-Financial, and Pasadena Playhouse historic districts. The Central District is a dense, vibrant, and walkable mix of commercial, residential, and civic land uses. It is divided into seven subdistricts in the Central District Specific Plan.
Pasadena Heritage.
South Fair Oaks. The South Fair Oaks Specific Plan area is south of downtown Pasadena between South Pasadena Avenue to the west and South Arroyo Parkway (SR-110) to the east. The area is dominated by industrial uses and Huntington Hospital. However, it also features the Glenarm Power Plant with the historic Electric Fountain, and Art Center College of Design’s south campus on South Raymond Avenue.
Pasadena Heritage.
Unlike most of the City, which is dominated by urban development, the western portion of Pasadena is characterized by a sequence of open space areas that are oriented to the Arroyo Seco waterway. From north to south, they include Hahamongna Watershed Park, Central Arroyo Park (including Brookside Park), and Lower Arroyo Seco Park. Recreational and cultural amenities include the Brookside Golf Course, Rose Bowl stadium, Kidspace Children’s Museum, and Rose Bowl Aquatics Center. As with the Arroyo Seco on the west side of the City, Eaton Wash in eastern Pasadena is a seasonal waterway that drains runoff from the San Gabriel Mountains to lower elevations in the City. The Central and Lower Arroyo areas are largely part of the Pasadena Arroyo Parks and Recreation District, which is listed on the National Register of Historic Places under the Cultural Landscape category. In addition, the Rose Bowl is a National Historic Landmark.
Pasadena Heritage.
There are three known prehistoric resources in Pasadena, including two sites and a trail. There are also two historic archaeological sites, including an early 20th Century tourist camp and a trash deposit possibly associated with the San Rafael Ranch. Existing designated historic resources in the City include 131 resources listed on the National Register of Historic Places, including 2016 National Historic Districts and 3 National Historic Landmarks (NPS 2013); 1 State Point of Historical Interest; 2 State Historic Landmarks (OHP 2013); numerous City-designated landmarks, memorials, and monuments (Pasadena 2010); and 2017 Citydesignated Landmark Districts (Pasadena 2010). Part of SR-110, the Arroyo Seco Parkway Pasadena Freeway, is designated a National Scenic Byway (FHWA 2013). The City is well known for its large inventory of historic buildings, which include historic estates of early 20th Century business magnates, hundreds of Craftsmen-style bungalows, and numerous private and public buildings of note representing a wide diversity of architecture styles, including Victorian-era buildings, Period Revival style buildings, and Modern buildings.
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
4. Revisions to the Draft EIR
August 2015 Page 4-3
Pasadena Heritage.
4.2.2 Scenic Features and Visual Resources
The City of Pasadena affords a variety of views of scenic landscapes and built environments. The San Gabriel Mountains, near the north City boundary, dominate the skyline from most of the City. The San Rafael Hills are along the western City boundary, and the Verdugo Mountains are further to the west. In addition, the Arroyo Seco corridor and Eaton Canyon traverse the western and eastern portions of the City, respectively. The City also offers scenic views of distinct architecture in the built environment, such as the Old Pasadena Historic District, Pasadena City Hall, Castle Green, St. Andrew Catholic Church bell tower, and Bungalow Heaven.
Section 5.1, Aesthetics, provides a detailed analysis of the City’s scenic vistas, visual resources, and aesthetic character as well as the potential impact to the resources from buildout of the General Plan.
Pasadena Heritage.
The City is served by numerous bus lines operated by Pasadena ARTS (Pasadena Area Rapid Transit System), Foothill Transit, and Metro. Other alternative modes of transportation in the City include services offered by the Los Angeles Department of Transportation (e.g. park-and-ride lots); Dial-A-Ride; the Gold Line (light rail line that links Pasadena to Union Station in Los Angeles); the LAX FlyAway bus service from Pasadena to LAX; and the City of Sierra Madre Gateway Coach. The Gold Line light-rail line (Metro Rail Service Line 804) extends north–south through the southwestern part of the City and continues eastward in the median of I-210, terminating near the eastern City boundary. The City also provides ample opportunities for bicycling via a network of bikeways, bicycle parking, links to transit, and other accommodations, as detailed in the City’s Bicycle Transportation Plan (adopted in 2000 and last updated in 2011).
Pasadena Heritage.
Northwest Pasadena. Outside of the Lincoln Avenue Specific Plan area, this section of Pasadena is characterized by a suburban, residential character. The area is bisected from north to south by the portion of the Arroyo Seco that contains the Rose Bowl, Brookside Golf Course, and other recreational amenities. The Rose Bowl, golf course, and Arroyo Seco corridor as a whole have historic value in addition to their recreational and aesthetic value. East of the Arroyo Seco and west of I-210 are residential neighborhoods that are mostly oriented to an orthogonal street grid. This grid and the regular placement of street trees give the area an orderly and modest small-town aesthetic. West of the Arroyo Seco are residential neighborhoods featuring larger homes on larger lots, many in the San Rafael Hills.
The topography, scenic vistas, and mature tree canopy distinguish these homes and neighborhoods from other areas of the city.
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
4. Revisions to the Draft EIR
Pasadena Heritage.
East Colorado. This area is a three-mile-long corridor extending eastward from Catalina Avenue to the eastern City boundary. It includes Allen Avenue from Colorado Boulevard to the Gold Line station at I210. East Colorado Boulevard features a broad variety of commercial land uses. The visual character of the corridor varies widely, including auto-oriented areas with deficient pedestrian infrastructure and areas with wide sidewalks and businesses that front the sidewalk. Colorado Boulevard offers substantial eastward and westward views through the Specific Plan area and Pasadena. The area also includes multiple distinctive historic buildings, including the Holliston Avenue Methodist Church, H.G. Loud Auto Building, Howard Motor Company Building, Kindel Building, Saga Motor Hotel, and other autooriented uses associated with historic Route 66.
Pasadena Heritage.
South Fair Oaks. The South Fair Oaks Specific Plan area is south of downtown Pasadena between South Pasadena Avenue to the west and South Arroyo Parkway (SR-110) to the east. The area is dominated by industrial uses and Huntington Memorial Hospital. Interspersed between industrial uses are commercial and public uses of varying building types and styles, giving the area an eclectic appearance and character. This varied visual environment includes some of the City’s more adventurous and atypical architecture, as well as several important historic structures.
Table 5.1-1 on Page 5.1-4, Section 5.1, Aesthetics, is hereby modified as follows in response to Comment A7- 14, from Pasadena Heritage.
Table 5.1-1 Examples of Visual Resources in Pasadena
Specific Plan/Neighborhood Visual Resource Type of Visual Resource* Specific Plan Areas
Central District • All Saints Episcopal Church
• Castle Green/Green Hotel Apartments
• Central Park
• City Hall
• Civic Auditorium
• Colorado Boulevard
• Memorial Park
• Pasadena City Library
• Pasadena Playhouse
• St. Andrews Catholic Church
• Historic resource
• Historic resource
• Foliage and greenery
• Historic resource
• Historic resource
• Scenic corridor
• Foliage and greenery
• Historic resource
• Historic resource
• Historic resource
East Colorado • Holliston Community Church • Historic resource
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
4. Revisions to the Draft EIR
August 2015 Page 4-5
Table 5.1-1 Examples of Visual Resources in Pasadena
Specific Plan/Neighborhood Visual Resource Type of Visual Resource* East Pasadena • Municipal Light and Power Building
• Former Stuart Pharmaceutical Building
• Historic resource
• Historic resource
Fair Oaks/Orange Grove • La Pintoresca Library and Park • Historic resource Lincoln Avenue • Palm trees along Washington Boulevard • Foliage and greenery South Fair Oaks • Industrial/warehouse buildings
• Glenarm Power Plant fountain
• Unique visual character
• Historic resource
West Gateway • Colorado Street Bridge
• Maranatha High School/Ambassador Auditorium
• Landscaped yards of large estates
• Camphor, magnolia, and palm street trees
• U.S. Court of Appeals Bldg.
• Historic resource
• Landscaped grounds; Historic resource
• Foliage and greenery; unique visual character
• Foliage and greenery
• Historic resource
Outside Specific Plan Areas
Northwest • Arroyo Seco/Brookside Park Corridor
• Arroyo Terrace National Register Historic District
• Banbury Oaks Landmark District
• Devils Gate Dam
• Hahamongna Watershed Park (Upper Arroyo)
• Gamble House
• Pegfair Estates National Register Historic District
• Prospect National Register Historic District
• Rose Bowl
• Wotkyns-Richland Landmark District
• Foliage and greenery
• Historic resource
• Historic resource
• Historic resource
• Foliage, topography, and greenery
• Historic resource
• Historic resource
• Historic resource
• Historic resource
• Historic resource
Northeast • Bristol-Cypress National Register Historic District • Bungalow Heaven Landmark District/National
Register Historic District
• Crawford’s Vista Landmark District
• Craftsman bungalows
• Eaton Canyon
• Garfield Heights Landmark District
• Holliston Avenue Landmark District
• New Fair Oaks National Register Historic District
• Normandie Heights Landmark District
• North Pasadena Heights Landmark District
• Orange Heights National Register Historic
District
• Raymond-Esther Landmark District
• Raymond-Summit National Register Historic
District
• St. Elizabeth of Hungary Catholic Church
• Washington Square Landmark District
• Historic resource
• Historic resource
• Historic resource
• Historic resource
• Foliage, topography, and greenery
• Historic resource
• Historic resource
• Historic resource
• Historic resource
• Historic resource
• Historic resource
• Historic resource
• Historic resource
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
4. Revisions to the Draft EIR
Table 5.1-1 Examples of Visual Resources in Pasadena
Specific Plan/Neighborhood Visual Resource Type of Visual Resource* • Westminster Presbyterian Church • Historic resource
• Historic resource
• Historic resource
Southeast • California Institute of Technology
• Historic homes (many in Spanish-derived
architectural styles)
• Marengo-Pico Landmark District
• Marguerita Lane National Register Historic
District
• South Hudson Avenue Landmark District
• South Madison Landmark District
• South Marengo National Register Historic District
• South Oakland Landmark District
• Street trees (including camphor and palm trees
on numerous streets)
• Tournament Fields Landmark District
• Landscaped grounds
• Unique visual character
• Historic resource
• Historic resource
• Historic resource
• Historic resource
• Historic resource
• Foliage and Greenery
• Historic resource
Southwest • Bellefontaine Landmark Distirct
• Lower Arroyo Seco
• Lower Arroyo Seco National Register Historic
District
• Markham Place/Governor Markham National
Register Historic District
• Poppy Peak National Register Historic District
• Ross Grove Landmark District
• San Rafael Hills
• South Grand-Covington Place Landmark District
• Weston-Bungalowcraft Landmark District
• Historic resource
• Foliage and greenery/natural habitat
• Historic resource
• Historic resource
• Historic resource
• Historic resource
• Foliage, topography, and greenery
• Historic resource
• Historic resource
Citywide
• Views of San Gabriel Mountains
• Mature street trees
• Public art
• Scenic backdrop
• Foliage and greenery
• Artistic beauty
* For discussion of officially designated historic landmarks, see Section 5.4, Cultural Resources, of this DEIR.
Note: This table is not meant to represent an exhaustive list of visual resources in Pasadena. Instead, it provides examples of well-known scenic resources in different areas of the City.
Pasadena Heritage.
Design Commission (Chapter 2.80). This section of the Municipal Code establishes the City’s Design Commission. The Design Commission is tasked with fulfilling the Pasadena City Council’s declaration that the “achievement of quality in the architecture and urban design of the City is required in the interest of the prosperity, social and cultural enrichment, and general welfare of the people” (Pasadena 2014). The Commission is given the authority to develop City policies and standards related to
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
4. Revisions to the Draft EIR
August 2015 Page 4-7
community design, review development and redevelopment projects regarding aesthetic concerns, and make recommendations regarding environmental review documents.
A subsection of Chapter 2.80 establishes the City’s Urban Forestry Advisory Committee. The code gives authority to the Design Commission to delegate review of matters pertaining to trees to the Urban Forestry Advisory Committee. The Design Commission also serves as the Historic Preservation Commission for properties within the Central District.
from Pasadena Heritage.
Specific examples include the potential for new commercial and mixed uses near the Bungalow Heaven and Historic Highlands Landmark Districts; medium mixed use, high density mixed use, and institutional classifications in the Pasadena Playhouse Districts; medium mixed use, high density mixed use, institutional, and high density residential in the Pasadena Civic Center National Register Historic Landmark District; and medium density residential uses in the Ross Grove Landmark District.
from Pasadena Heritage.
In addition to compliance with Policy LU 8.5, new development would be required to comply with the City’s Design Guidelines for Historic Districts, which are based on the Secretary of the Interior’s Standards for Historic Preservation. For example, areas along North Lake Avenue adjacent to the Bungalow Heaven National Register District and the Historic Highlands Landmark District would allow for Low Mixed Use (1-
1.0 FAR), Low-Medium Mixed Use (0-1.75 FAR), and Low Commercial (0-1.0 FAR). Although the proposed Land Use Diagram would allow new uses with specific FARs adjacent to these landmark and historic districts, new development in this area would still need to comply with the North Lake Specific Plan and development standards (e.g., height, massing, and setback limitations) in Municipal Code Section 17.34.040 and the Urban Design, Sense of Place, and Architectural policies in the land use element. New development in the Pasadena Playhouse, Civic Center-Financial, and Pasadena Civic Center National Register Districts would be required to comply with the Central District Specific Plan and Design Guidelines for Historic Districts. Adherence to these development standards and design guidelines would ensure that infill development would maintain the character and context of the area, incorporate high quality architectural design, and be compatible with adjacent historical structures. Elements of the historic resources and landmarks that are character defining and convey the resources’ significance, including all seven aspects of the resources integrity, would not be altered.
Comment C1-8, from Historic Preservation Commission.
9-4 Prior to issuance of any construction permits, applicants for individual projects that involve vibration-intensive construction activities, such as pile drivers, jack hammers, bulldozers, and
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
4. Revisions to the Draft EIR
vibratory rollers, within 25 feet of sensitive receptors (e.g., residences and historic structures) or 50 feet of historic structures, shall prepare and submit to the City of Pasadena Planning Division a study to evaluate potential construction-related vibration impacts. The vibration assessment shall be prepared by an acoustical engineer and be based on the FTA vibrationinduced architectural damage criterion. If the study determines a potential exceedance of the FTA thresholds, measures shall be identified that ensure vibration levels are reduced to below the thresholds. Measures to reduce vibration levels can include use of less-vibrationintensive equipment (e.g., drilled piles and static rollers) and/or construction techniques (e.g., nonexplosive rock blasting and use of hand tools) and preparation of a preconstruction survey report to assess the condition of the affected sensitive structure. Notwithstanding the above, pile drivers shall not be allowed within 150 feet of any historic structures. Identified measures shall be included on all construction and building documents and submitted for verification to the City of Pasadena Planning Division.
to Comment A1-12, from Bungalow Heaven Neighborhood Association.
See Figure 5.13-4 below.
Bungalow Heaven Neighborhood Association.
The No Project/Adopted General Plan Alternative would have similar impacts for aesthetics, biological resources, cultural resources, and noise. Impacts would be reduced for air quality, public services, recreation, and utilities and service systems. This alternative would result in an increase in impacts to air quality, GHG emissions, hazards and hazardous materials, hydrology and water quality, land use and planning, population and housing, and transportation and traffic. Significant unavoidable adverse impacts identified by the proposed project for air quality, GHG emissions, and noise would not be eliminated. Although this alternative would eliminate the CMP arterial intersection impact at Pasadena Avenue and California Boulevard, it would create a new significant impact at Rosemead Boulevard and Foothill Boulevard. This alternative would also create a new significant impact by increasing VMT per capita over existing.
Edel Mar Blvd
ECalifornia Blvd
N Lake Ave
N Fair Oaks Ave
N Hill Ave
EMountain St
NewYork Dr
N Altadena Dr
E Orange Grove Blvd
San PasqualSt
EWashington Blvd
Linda Vista Ave
EFoothill Blvd
E Green St
L ni co nl Ave
N FigueroaSt
N Los Robles Ave
Meridian St
SLos Robles Ave
Duarte Rd
LidaSt
MadreSt
Foothill Blvd
Colorado Blvd
Virginia Rd
MountWilson Red Box Rd
laLoma Rd
Longden Ave
N Arroyo Blvd
SLake Ave
Highland Dr
Mission St
S Arroyo Blvd
Monterey Rd
Crown Ave
Yosemite Dr
ESierra Madre Blvd
Huntington Dr
EWoodbury Rd
EChevyChase Dr
EMendocinoSt
S Hill Ave
Berksh ire Ave
S Orange Grove Blvd
San Pasqual Ave
Windsor Ave
S Al el n Ave
WAltadena Dr
del Mar Ave
StarlightCrest Dr VenturaSt
N San Gabriel Blvd
S Michill ni da Ave
ELoma Alta Dr
N Rosemead Blvd
N Allen Ave
Wdel Mar Blvd
Arroyo Dr
N Marengo Ave
WGreen St
WGrandview Ave
Fair Oaks Ave
EWalnutSt
Oak Grove Ave
Ave64
N Fair Oaks Ave
Sierra Madre Blvd
S Michillinda Ave
Lake Ave
§¨¦210
§¨¦210
§¨¦210
§¨¦210
·|}þ134
\\fpla1\data\Jobs\Active\2600s\2631 - Pasadena GP EIR\Graphics\GIS\MXD\F5_2035BikeNetwork.mxd 2035 Bicycle Network
Figure 5
Bicycle Facilities Hierarchy
11%
55%
24%
10%
Level 1 - Advanced Facilities Includes BikePaths (P1),MultipurposePaths(PP),CycleTracks/Protected Bike Lanes Level 2 - Dedicated Facilities
Includes Buffered BikeLanes, BikeLanes (2,P2), Bike Boulevards (BB) Level 3 - BasicFacilities
Includes Bike Routes (3,P3),Enhanced Bike Routes (E3,PE3),Emphasized Bikeways (PEB) Source: Fehr & Peers, 2015
5. Environmental Analysis
Figure 5.13-4
Future Bicycle Network
CITY OF PASADENA
GENERAL PLAN UPDATE
DRAFT EIR PRA-06.0L 7/9/2015
NOT TO SCALE
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
4. Revisions to the Draft EIR
This page intentionally left blank.
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
4. Revisions to the Draft EIR
August 2015 Page 4-11
Comment A1-7, from Bungalow Heaven Neighborhood Association.
Table 7-19 Comparison of Alternatives to the Proposed Project Environmental
Resource Area Project
No Project/Adopted
General Plan
Alternative
Central District, South Fair
Oaks, and Lincoln Avenue
Alternative
Efficient
Transportation
Alternative
Reduced Air Quality
and Noise Impact
Alternative
Aesthetics LTS 0 0 0 0
Air Quality S/U +- - - -
Biological Resources LTSM 0 0 0 0
Cultural Resources LTSM 0 - 0 0
GHG S/U + - - +
Hazards and Hazardous
Materials LTS + - 0 +
Hydrology and Water
Quality LTS + 0 0 0
Land Use and Planning LTS + 0 0 -
Noise S/U - - - 0
Population and Housing LTS + 0 0 0
Public Services LTS - - - +
Recreation LTS - - - +
Transportation and
Traffic S/U +1 0 0 -
2 Utilities and Service
Systems LTS - - - +
LTS – Less Than Significant
LTSM – Less Than Significant with Mitigation
S/U – Significant and Unavoidable
(+) = Impact considered greater when compared with the proposed project. (0) = Impact considered neutral when compared with the proposed project. (–) = Impact considered less when compared with the proposed project. 1 The No Project/Adopted General Plan Alternative eliminates one significant unavoidable CMP arterial intersection impact at Pasadena Avenue and California Boulevard. However, it would create a new significant unavoidable CMP impact at Rosemead Boulevard and Foothill Boulevard and a new significant impact by increasing VMT per capita over existing. 2 The Reduced Air Quality and Noise Impact Alternative eliminates one significant unavoidable CMP arterial intersection at Pasadena Avenue and California Boulevard. However, like the proposed project this alternative would result in the following significant CMP impacts: a significant impact on I-210 w/o Rte 134/710 in the PM peak hour for westbound lanes and on I-210 w/o Rosemead Boulevard in the AM peak hour for westbound lanes.
4.3 ADDITIONAL DEIR REVISIONS
The following text has been revised to update information or correct typographical errors.
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
4. Revisions to the Draft EIR
Table 1-3 Pasadena General Plan Update: Net Projections Specific Plan
Residential1 Nonresidential Square Feet2
Acres
Dwelling
Units Population
Retail
Acres
Office
Dwelling
Units Industrial
Institutional
Acres
Total Nonresidential
Dwelling Units Employees
Central District 801 6,147 12,374 1,002,941 2,774,256 -109,770 179,222 3,846,649 13,529 South Fair Oaks 253 1,078 2,220 344,469 1,565,053 -527,474 412,459 1,794,506 7,124 East Colorado 299 361 755 391,200 734,740 -170,953 -31,388 923,600 2,853 East Pasadena 245 1,442 3,099 -318,312 1,854,643 -428,456 0 1,107,875 5,662 North Lake 143 316 649 160,513 172,173 -44,866 -32,453 255,366 771 Fair Oaks/
Orange Grove
210 323 870 503,221 427,856 -211,595 -410,497 308,984 760 Lincoln Ave 73 210 433 352,626 242,557 -259,653 -37,117 298,413 1,027 West Gateway3 0 418 835 163,950 157,325 -14,800 -100,000 206,475 729 No Specific Plan 12,779 2,017 6,237 837,898 1,889,774 -574,890 94,309 2,247,091 7,866 Total 14,803 12,312 27,473 3,438,505 9,818,377 -2,342,457 74,535 10,988,959 40,323 Source: City of Pasadena, August 2013; Fehr & Peers 2014. 1 Dwelling unit projections include development caps, affordable housing estimates, and previously approved but not yet built units. 2 Nonresidential square feet projections include development caps and previously but not yet built nonresidential space. 3 The General Plan Update includes a policy to sunset the West Gateway Specific Plan in the future; however, it is included here to show the location of buildout.
The City of Pasadena determined that an EIR would be required for this project and issued a Notice of Preparation (NOP) and Initial Study on September 5, 20142013 (See Appendix B). Comments received during the public review period, which extended from September 5, 2013, to October 21, 2013, are contained in Appendix C and summarized in Subsection 1.8 of Section 1, Introduction, of this DEIR.
2014–2021 Pasadena Housing Element
The City’s most recent housing element was adopted by City Council on February 3, 2014. For the 2014–2021 planning period, SCAG determined that Pasadena’s RHNA allocation was 1,332 units. Consistent with state housing law, the 2014–2021 Housing Element demonstrates that the City can accommodate its RHNA allocation through the construction of planned residential projects and utilization of its inventory of appropriate housing sites. The Housing Element also identifies goals, policies, and programs designed to address the City’s overall housing needs.
As the City’s population increases, additional fire stations or expansions may be required. Various localized environmental impacts related to new construction or redevelopment of fire stations could occur. In addition to the stations currently identified for replacement (Stations 33 [not funded], 36, 37, and 38 [all funded]) and
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
4. Revisions to the Draft EIR
August 2015 Page 4-13
improvements (Station 31 [not funded]), additional stations or improvements may be required. Any new or expanded fire stations that may be required to serve the City at General Plan buildout will be identified in the forthcoming Standards of Coverage document. Development and operation of new stations in permitted land use designations have been considered in the General Plan Update buildout and analyzed throughout this DEIR, , since it analyzes anticipated effects of citywide growth related to air quality, noise, traffic, utilities, and other environmental impact areas. In addition, if construction impacts of a development project necessitate the closure of roadways that serve a particular project, the applicant would be required to coordinate road closures and emergency access with PFD to ensure an adequate level of fire protection services at the adopted service levels.
The CMP impact at Rosemead Boulevard and Foothill Boulevard is an impact of the No Project/Adopted General Plan Alternative and not an impact of the proposed General Plan Update (see Transportation Analysis Report in Appendix D of this FEIR). This was a typographical error. Page 5.13-33, Chapter 5.13, Transportation and Traffic, is hereby modified as follows:
Arterial Intersections
Pasadena Avenue and California Boulevard (CMP ID #120) – this location is impacted in the AM peak hour. The mitigation measure identified for this location is the conversion of one westbound through lane to a shared through/right-turn lane. This mitigation measure would degrade the pedestrian environment by creating two lanes of right-turning traffic that would conflict with pedestrians crossing the north and east legs of the intersection, inconsistent with the General Plan’s goals and policies related to improving access to destinations by pedestrians.
Rosemead Boulevard and Foothill Boulevard (CMP ID #121) – in Scenarios 2, this location is impacted in the PM peak hour. The mitigation measure identified for this location is the conversion of one northbound through lane to a shared through/right-turn lane. This mitigation measure would degrade the pedestrian environment by creating two lanes of right-turning traffic that would conflict with pedestrians crossing the south and east legs of the intersection, inconsistent with the General Plan’s goals and policies related to improving access to destinations by pedestrians.
4.3.2 Level of Significance After Mitigation
Impact 5.13-1
Implementation of Mitigation Measure 13-1 would ensure that citywide improvements are funded through the City’s transportation impact fee program, thereby reducing impacts to a less than significant level.
Impact 5.13-2
There are no feasible mitigation measures available to reduce impacts to CMP freeway segments and arterial intersections to below a level of significance. For the reasons stated above, improvements to freeway segments require an additional mainline travel lane, which either requires removal of a left hand shoulder resulting in substandard freeway conditions or there is insufficient existing right-of-way. Increasing
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
4. Revisions to the Draft EIR
automobile capacity through roadway widening is also inconsistent with the General Plan’s goals and policies.
Mitigation for Pasadena Avenue and California Boulevard would require conversion of one westbound through lane to a shared through/right-turn lane. Mitigation for Rosemead Boulevard and Foothill Boulevard would require the conversion of a northbound through lane to a shared through/right-turn lane. As discussed above, thisese mitigation measures would degrade the pedestrian environment and are inconsistent with the proposed General Plan’s goals and policies related to improving access to destinations by pedestrians.
Traffic
Impact 5.13-2: There are no feasible mitigation measures available to reduce impacts to CMP freeway segments and arterial intersections to below a level of significance. Improvements to freeway segments require an additional mainline travel lane, which either requires removal of a left hand shoulder resulting in substandard freeway conditions or there is insufficient existing right-of-way. Increasing automobile capacity through roadway widening is also inconsistent with the General Plan’s goals and policies. Mitigation for Pasadena Avenue and California Boulevard would require conversion of one westbound through lane to a shared through/right-turn lane. Mitigation for Rosemead Boulevard and Foothill Boulevard would require the conversion of a northbound through lane to a shared through/right-turn lane. Thisese mitigation measures would degrade the pedestrian environment and are inconsistent with the proposed General Plan’s goals and policies related to improving access to destinations by pedestrians.
Pasadena Office of the City Attorney
Theresa Fuentes, Assistant City Attorney
Pasadena Planning and Community Development Department
Vincent P. Bertoni, AICP, Director
David Reyes, Deputy Director
Arthi Varma, Principal Planner
David Sinclair, Senior Planner
Vicrim Chima, Planner and General Plan Manager
Scott Reimers, Planner
Martin Potter, Associate Planner
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
4. Revisions to the Draft EIR
August 2015 Page 4-15
Pasadena Department of Transportation
Fred Dock, Director
Mark Yamarone, Transportation Administrator
Jenny Cristales, Associate Planner
Environmental Consultant to the City
John Bellas, LEED AP , Michael Baker International
The Final Transportation Analysis Report is provided herein in Appendix D of this FEIR. Minor changes were made to Table labels to correlate the Scenario numbers with the names of alternatives that were analyzed in Section 7.0 of the DEIR for consistency. Additionally Figure 5 “2035 Bicycle Network” was updated as discussed in Section 4.2 above.
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
4. Revisions to the Draft EIR
This page intentionally left blank.
August 2015 Page 5-1
5. Errata to FEIR dated July, 2015
The following constitute revisions to the Final Environmental Impact Report (FEIR) for the Pasadena General Plan Update dated July, 2015. They include response to comment letters that were inadvertently omitted in the FEIR released for public review on July 14, 2015 and edits aimed at updating information and/or correcting typographical errors. This Errata was distributed to commenters and posted on the City’s website on July 22, 2015.
5.1 MISCELLANEOUS ADDITIONAL REVISIONS TO THE FEIR
Pasadena Heritage.
Table 5.10-3 Adopted SCAG Growth Forecasts
Forecast
City of Pasadena1 San Gabriel Valley2
Increase,
2013–2035
Percent Increase,
2013–2035
2020 2035 2020 2035 Pasadena SGV2 Pasadena SGV2
Population 143,400 152,500 1,588,100 1,714,300
12,480
13,885 202,341 10% 13.4%
Households 58,400 61,400 496,200 524,800 5,422 57,495 9.7% 12.3% Employment 124,400 131,300 708,600 728,700
19,952
19,299 44,000 17.2% 6.4%
Source: SCAG 2012. 1 Note that SCAG projections are for the City only and not the entire planning area or the City’s sphere of influence. 2 Population estimates for the SGV were calculated using estimates for the 31 cities that compose the SGVCOG’s definition of the region and do not include for the region’s unincorporated areas.
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
5. Errata to FEIR dated July, 2015
5.2 RESPONSE TO COMMENTS
Comment letters are followed by responses to specific numbered comments. References are made to information provided in the Draft Environmental Impact Report (DEIR) and FEIR.
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
5. Errata to FEIR dated July, 2015
August 2015 Page 5-3
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
5. Errata to FEIR dated July, 2015
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
5. Errata to FEIR dated July, 2015
August 2015 Page 5-5
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
5. Errata to FEIR dated July, 2015
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
5. Errata to FEIR dated July, 2015
August 2015 Page 5-7
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
5. Errata to FEIR dated July, 2015
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
5. Errata to FEIR dated July, 2015
August 2015 Page 5-9
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
5. Errata to FEIR dated July, 2015
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
5. Errata to FEIR dated July, 2015
August 2015 Page 5-11
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
5. Errata to FEIR dated July, 2015
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
5. Errata to FEIR dated July, 2015
August 2015 Page 5-13
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
5. Errata to FEIR dated July, 2015
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
5. Errata to FEIR dated July, 2015
August 2015 Page 5-15
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
5. Errata to FEIR dated July, 2015
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
5. Errata to FEIR dated July, 2015
August 2015 Page 5-17
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
5. Errata to FEIR dated July, 2015
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
5. Errata to FEIR dated July, 2015
August 2015 Page 5-19
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
5. Errata to FEIR dated July, 2015
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
5. Errata to FEIR dated July, 2015
August 2015 Page 5-21
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
5. Errata to FEIR dated July, 2015
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
5. Errata to FEIR dated July, 2015
August 2015 Page 5-23
Response to Comments from Vince Farhat, dated March 15, 2015.
1. The commenter states that the Planning Commission did not endorse DOT’s new transportation performance metrics that were adopted by City Council on November 3, 2014. The DEIR analyzes transportation and traffic impacts based on the City’s adopted thresholds of significance. The transportation analysis in the DEIR does not understate impacts. However, the DEIR analysis does use a different metric than an auto delay based metric to determine transportation impacts. Staff has reviewed the transcripts of the Planning Commission hearings regarding the thresholds. Staff could not find any written or verbal confirmation of DOT or Planning staff committing to analyzing the General Plan EIR using both LOS and the then proposed transportation performance measures and CEQA thresholds.
2. The Pasadena General Plan DEIR considers citywide street segments and circulation in order to evaluate transportation impacts based on to the City’s adopted transportation thresholds of significance. On November 3, 2014, the City Council adopted transportation metrics that contained a requirement for street segment analyses outside of the CEQA process for all projects of “Communitywide Significance.” The street segment metric (outside of the CEQA process) may also apply to smaller projects at the discretion of the Director of Transportation. However, the DEIR does not use a street segment performance measure to analyze transportation impacts. Refer to Responses to Comments 11 through 27 for responses to comments provided on the September 9, 2014 Memorandum.
3. Refer to FEIR Section 2.1, Transportation Metrics for an explanation of why a comparison of the old and new metrics would not provide meaningful information.
Analysis of traffic impacts based on street segment performance criteria would require additional modeling and separate, independent analysis. However, the DEIR did not evaluate traffic impacts based on a street segment performance metric, nor is this analysis required under CEQA.
4. Yes, DEIR Section 5.13.3 explains the methodology for analyzing the transportation and traffic impacts. In addition, FEIR Section 2.1, Transportation Metrics explains why the EIR did not analyze impacts based on the City’s old metrics.
5. The EIR does explain its transportation methodology as stated in Response to Comment 4 above. However, refer to Responses to Comments 28 through 38 for responses to comments provided in the July 18, 2014 Memorandum.
6. Analysis of transportation impacts under the old metrics was not prepared. Refer to FEIR Section 2.1, Transportation Metrics.
7. Refer to FEIR, Section 2.1, Transportation Metrics. If the DEIR used the City’s old metrics to analyze transportation impacts, it would require additional modeling and
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
5. Errata to FEIR dated July, 2015
analysis, independent of what was analyzed. This analysis would be in addition to and cannot be compared with what was provided in the DEIR because it is a measurement of different performance criteria and policies. Impacts based on the new metrics are not “greater” or “less than” impacts based on the old metrics, because they are different methods of measuring impacts altogether.
8. Since there will not be an analysis using the former thresholds, there are no changes to the analysis and the impact conclusions, and therefore no change will have to be made to the Statement of Overriding Considerations.
9. As stated previously, the EIR used the City’s adopted thresholds for measuring transportation impacts. Since an analysis of the old metrics was not included it cannot be stated which alternative would be considered the environmentally superior alternative under that scenario.
10. Comment noted.
11. This September 9, 2014 Memorandum provides the commenter’s opinion on street segment, VMT per capita and VT per capita traffic metrics that were submitted prior to the November 3, 2014 adoption of the new traffic metrics. The commenter states that street segment metrics should be used to measure traffic impacts under CEQA and that VMT and VT per capita do not adequately analyze impacts of auto traffic. These were comments that were provided to the City Council during the consideration and processing of new transportation metrics and do not relate to the sufficiency of the EIR.
As stated in FEIR Section 2.1, Transportation Metrics, the City conducted extensive public review and considered substantial evidence to adopt new traffic thresholds of significance to apply to all CEQA documents pursuant to CEQA Guidelines Section 15064.7(b). As described, 16 public meetings were held on the transportation thresholds of significance prior to City Council adoption in November 2014. Based on the evidence provided to City Council, it determined that the new transportation performance measures and CEQA thresholds are better aligned with the City’s General Plan goals and policies and State regulations to create more sustainable transportation systems. They are also better suited to Pasadena’s existing urban, walkable environment, since traditional performance measures (e.g. LOS) often require mitigation that increases roadway width that often cannot be constructed without adversely affecting existing buildings and the pedestrian environment. The performance measures and CEQA thresholds provide a holistic approach by considering the City’s transportation network, including all modes of travel. The City Council found that this approach provides a more comprehensive systems approach that is independent and distinct from traditional traffic thresholds measuring level of service (see Staff Report and Minutes from the
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
5. Errata to FEIR dated July, 2015
August 2015 Page 5-25
November 3, 2015 City Council Hearing on New Transportation Performance Measures for Transportation Impact Analysis and Thresholds of Significance for CEQA.
12. The commenter provides background regarding the City’s past practices when performing street segment analysis. This comment was provided to the City Council during their consideration of new transportation metrics. On November 3, 2014, the City Council adopted new transportation metrics in accordance with staff ’s recommendations. The adopted transportation metrics include a requirement for street segment analyses outside of the CEQA process for all projects of “Communitywide Significance” (i.e., more than 50 residential units and/or more than 50,000 square feet of non-residential space). The street segment metric (outside of the CEQA process) may also apply to smaller projects (i.e., 11-49 residential units and/or 10,001-49,999 square feet of non-residential space) at the discretion of the Director of Transportation.
Consistent with the commenter’s assertion, the City’s new Transportation Impact Analysis Guidelines limits street segment analysis to projects on “Access” and “Neighborhood Connector” street types within a residential context.
13. Refer to Response to Comment 11. The City adopted new traffic thresholds of significance, eliminating CEQA review of traffic impacts based on street segment metrics.
14. The commenter provides opinions regarding the value of street segment analysis, which are duly noted.
15. The commenter provides opinions regarding the value of street segment analysis, which are duly noted. The commenter correctly characterizes the process by which the City can approve a project with a significant, unavoidable environmental impact vis-à-vis a Statement of Overriding Considerations. The City’s adopted transportation metrics and Transportation Impact Analysis Guidelines provide for transportations metrics to evaluate a project’s potential impacts on auto, transit, bicycle, and pedestrian modes of transportation.
16. The commenter provides opinions regarding the effectiveness of the per capita Vehicle Miles Traveled (VMT) and Vehicle Trips (VT) performance metrics, which are duly noted. The City’s adopted VMT and VT metrics were developed to evaluate projects according to the three main objectives of the Mobility Element—enhance livability; encourage walking, biking, transit and other alternatives to motor vehicles; and create a supportive climate for economic viability.
VMT is a measure of the total distance traveled by automobile, reflecting both the number of auto trips and the length of each auto trip made. Trip length is dependent on a number of factors that are included in the travel demand model, including but not limited to proximity of homes to job generating land uses, proximity to transit centers, socio-economic characteristics, and provision of multimodal transportation
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
5. Errata to FEIR dated July, 2015
infrastructure. The proposed General Plan land use diagram and mobility element were developed to allow growth while reducing trip length and overall VMT.
The travel demand model was used to assess the interaction between land uses and the resulting automobile trips. The results of VMT Per Capita and VT Per Capita analysis, presented in the transportation section of the DEIR, were computed using the City of Pasadena's Citywide Travel Demand Model with different land use inputs for each scenario. This model has been calibrated and validated to Caltrans Travel Forecasting Guidelines and exceeded all of the validation standards, resulting in a locally valid model for Pasadena. Travel demand model documentation for the Pasadena model was included in the DEIR Appendix I.
17. The commenter provides opinions regarding the effectiveness of the per capita Vehicle Miles Traveled (VMT) and Vehicle Trips (VT) performance metrics, which are duly noted.
18. The commenter provides opinions regarding the value of street segment analysis, which are duly noted. See also response to Comment 12, which describes when street segment analysis is required under the City’s new Transportation Impact Analysis Guidelines outside of CEQA.
19. The commenter expresses recommendations and an interpretation of how to apply street segment analysis on a citywide basis. To clarify, the adopted transportation metrics include a requirement for street segment analyses outside of the CEQA process for all projects of “Communitywide Significance” (i.e., more than 50 residential units and/or more than 50,000 square feet of non-residential space). The street segment metric (outside of the CEQA process) may also apply to smaller projects (i.e., 11-49 residential units and/or 10,001-49,999 square feet of non-residential space) at the discretion of the Director of Transportation.
20. The City’s adopted VMT and VT metrics were developed to evaluate projects according to the three main objectives of the Mobility Element—enhance livability; encourage walking, biking, transit and other alternatives to motor vehicles; and create a supportive climate for economic viability.
21. The commenter provides background regarding the City’s past practices and opinions regarding the value of street segment analysis, which are duly noted.
22. The commenter makes recommendations on how to apply street segment analysis on a citywide basis. To clarify, the adopted transportation metrics include a requirement for street segment analyses outside of the CEQA process for all projects of “Communitywide Significance” (i.e., more than 50 residential units and/or more than 50,000 square feet of non-residential space). The street segment metric (outside of the CEQA process) may also apply to smaller projects (i.e., 11-49 residential units and/or
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
5. Errata to FEIR dated July, 2015
August 2015 Page 5-27
10,001-49,999 square feet of non-residential space) at the discretion of the Director of Transportation.
23. The commenter is correct regarding the background of SB 743 and the timing of preliminary guidelines distributed by OPR. No further response is required.
24. Refer to FEIR Section 2.1, Transportation Metrics. The commenter provides an accurate representation of SB 743 as it relates to street segment analysis. On November 3, 2014, the City Council adopted new transportation metrics that included street segment analysis for certain projects outside of the CEQA process. See also response to comment 12.
25. Comment noted.
26. The commenter is recommending altering the thresholds for Street Segment analysis to be included as part of CEQA in order for it to be a more effective tool in achieving neighborhood compatibility.
27. The commenter is recommending maintaining Street Segment analysis as part of CEQA review of individual development projects. On November 3, 2014, the City Council adopted transportation metrics that contained a requirement for street segment analyses outside of the CEQA process for all projects of “Communitywide Significance.” The street segment metric (outside of the CEQA process) may also apply to smaller projects at the discretion of the Director of Transportation.
28. This comment provides the introduction and background of the new transportation performance measures for consideration and relevant on July 18, 2014. No response is necessary.
29. On November 3rd, 2014, City Council adopted three new proposed performance metrics that measure non-auto transportation impacts.
30. On November 3rd, 2014, City Council adopted VMT and VT per capita across the entire City. The commenter states that it should have been limited to smaller geographical areas, which is duly noted.
31. This comment relates to the development of transportation metrics that were adopted by the City Council on November 3rd, 2014. Those adopted metrics maintained VMT and VT metrics on a per capita, citywide basis.
32. On November 3rd, 2014, City Council adopted transportation metrics that did not include Street Segment metrics analysis as part of CEQA.
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
5. Errata to FEIR dated July, 2015
33. DOT developed Transportation Impact Analysis Current Practice and Guidelines that included modified average daily traffic caps to conduct non-CEQA related Street Segment analysis.
34. The adopted non-CEQA thresholds for Level of Service, as set forth within the Transportation Impact Analysis Current Practice and Guidelines, sets LOS caps for Transit Oriented Districts and Citywide at LOS E and D, respectively. Where those LOS caps are exceeded conditions of approval would be recommended.
35. See response to Comment 34. The General Plan Update contains a number of policies and a land use mix designed to foster economic vitality. Economic analysis is not a CEQA related issue.
36. The City adopted new traffic metrics as allowed and encouraged by CEQA. However, this comment is noted and was considered by City Council during review and adoption of the new metrics.
37. This comment is hereby noted.
38. This comment and remainder of the memorandum discusses reasons for maintaining street segment metrics; supporting instead the non-auto mobility performance metrics in combination with more traditional auto metrics. This memorandum was considered by City Council prior to the adoption of the new transportation performance measures on November 3, 2014. This does not relate to the sufficiency of the Pasadena General Plan EIR and no further response is necessary.
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
5. Errata to FEIR dated July, 2015
August 2015 Page 5-29
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
5. Errata to FEIR dated July, 2015
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
5. Errata to FEIR dated July, 2015
August 2015 Page 5-31
Response to Comments from Robert Tait, dated February 25, 2015.
R11-1 The commenter states that the Board of Directors for the El Rio/Lake Neighborhood Association does not believe that certain aspects of the proposed Land Use Element were adequately analyzed in the Pasadena General Plan DEIR. Responses to each of the comments are provided below.
R11-2 The commenter states that mixed use zones adjacent to low density residential would result in environmental impacts (related to aesthetics, air quality, noise, traffic, and parking) due to Chapter 17.43 of the City’s Zoning Code. Refer to FEIR Section 2.2, State Density Bonus Law. Note that the EIR assumed a reasonable level of density bonus development, based on the City’s experience since the implementation of the state density bonus law, and the EIR analyzed the potential environmental effects of this reasonable and fact-based increase in density. As discussed, the EIR addresses impacts related to aesthetics and cultural resources. Impacts related to light, air quality, noise, and traffic are analyzed in the DEIR in Sections 5.1, 5.2, 5.9, and 5.13, respectively. The commenter expresses concern for impacts related to air quality, noise and traffic impacts of the General Plan Update. Both construction and operational impacts related to air quality, noise, and traffic of General Plan Update buildout were analyzed and mitigation measures were included. There are no new impacts anticipated. CEQA does not require the analysis of impacts related to parking.
R11-3 The commenter cites a number of locations in the city where mixed use zoning is allowed or would be proposed adjacent to residential neighborhoods and landmark districts. The commenter is concerned that these areas would utilize density bonus waivers resulting in impacts that were not addressed. However, the commenter does not state specifically what impacts were not addressed in the DEIR. As stated in Response to Comment R11-2 and FEIR Section 2.2, State Density Bonus Law, the DEIR did analyze impacts related to allowing mixed uses adjacent to historic districts and SB 1818.
Furthermore, as discussed in Section 5.1-1 of the DEIR, the City implements a robust set of procedures, regulations, and guidelines related to development review of new projects in Pasadena, most of which require consistency with the General Plan. For example, the City evaluates the design of proposed projects for their consistency with its Citywide Design Principles and Design Guidelines, Design Guidelines for Neighborhood Commercial and Multifamily Districts, and the North Lake Specific Plan.
These guidelines, as well as the City Municipal Code, address context-sensitive design and land use compatibility.
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
5. Errata to FEIR dated July, 2015
This page intentionally left blank.
August 2015 Page 6-1
6. Refined Project Environmental Analysis
This Section documents the environmental analysis of a refined version of the proposed project, the “Refined Project,” and demonstrates that, for all environmental topic areas, impacts of this Refined Project would be similar or lesser than those of the proposed project.
6.1 REFINED PROJECT
Upon review of the DEIR, the Pasadena Planning Commission, in concurrence with staff ’s recommendation, targeted refinements to the proposed project to better reflect multiple interests and community concerns.
This decision was based, in part, on feedback that the proposed project allowed too much development potential and the environmentally preferable CD, SFO, LA Alternative would not permit enough growth in areas where additional development capacity is necessary to meet community needs. After considering these competing interests, the Planning Commission and City staff recommended adoption of a hybrid of the CD, SFO, LA Alternative and the proposed project development capacities. It also recommended minor changes to the policies of the Land Use Element and minor changes to the Land Use Diagram based on comments received during the public process. These changes are described here as the Refined Project.
As part of the General Plan Update process, the Pasadena City Council directed staff to analyze four project alternatives in the Draft Environmental Impact Report (DEIR). The Section 7 of the DEIR analyzed these alternatives, their potential environmental impacts, and their ability to achieve project objectives established for the proposed project. The alternatives included the following:
No Project Alternative (buildout of the adopted General Plan) Central District, South Fair Oaks, Lincoln Avenue Alternative (CD, SFO, LA Alternative) Efficient Transportation Alternative
Reduced Air Quality and Noise Impact Alternative
Since the Refined Project has development caps between the proposed project and the CD, SFO, LA Alternative, the environmental impacts of the Refined Project are generally less than those the DEIR identified for the proposed project and greater than those the DEIR identified for the CD, SFO, LA Alternative. The DEIR determined that the proposed project would result in significant and unavoidable impacts on air quality, GHG emissions, noise, and traffic. The DEIR further determined that the CD, SFO, LA Alternative would reduce the proposed project’s significant impacts, but would not reduce any of those significant impacts to a less than significant level. Likewise, the Refined Project would result in the same significant and unavoidable impacts on air quality, GHG emissions, noise, and traffic, with those impacts being incrementally less than the proposed project but greater than the CD, SFO, LA Alternative. See the “Environmental Analysis of the Refined Project” section of this Memorandum for a detailed analysis of the environmental impacts of the Refined Project.
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
6. Refined Project Environmental Analysis
6.1.1 Description of Refined Project
The Refined Project includes refinements to the Development Caps, Land Use Diagram, and Policies of the proposed project as described in the following subsections.
Development Caps
The Refined Project represents a hybrid of the development caps in the proposed project and CD, SFO, LA Alternative. The Refined Project utilizes the same residential development caps for the North Lake Specific Plan, Fair Oaks/Orange Grove Specific Plan, and Lincoln Avenue Specific Plan areas as compared to the proposed project. It utilizes the same residential development caps for East Pasadena and Lamanda Park as the CD, SFO, LA Lamanda Park Sub-Alternative. Finally, it sets different development caps for residential units in the Central District, South Fair Oaks and East Colorado Specific Plans.
The Refined Project uses the same non-residential development caps for the Lincoln Avenue, Fair OaksOrange Grove, North Lake, and East Pasadena as compared to the proposed project. The Refined Project uses different development caps for non-residential units in the East Colorado and Lamanda Park Specific Plans, with East Colorado being slightly higher than the proposed project, and Lamanda Park being slightly lower than the proposed project. Finally the Refined Project uses the same non-residential development caps for the Central District and South Fair Oaks Specific Plans as the CD, SFO, LA Alternative.
In the Central District and South Fair Oaks Specific Plan areas, the recommendation balances the competing interests regarding residential development levels and sets residential development levels at the mid-point of what was studied between the proposed project and CD, SFO, LA Alternative. These recommendations acknowledge the development potential of the Central District and South Fair Oaks Specific Plan areas consistent with the General Plan’s goal to directing growth towards transit, while tempering that potential in order to limit impacts. For non-residential development caps in the Central District and South Fair Oaks Specific Plan areas, the recommendation utilizes development caps based on an analysis of the amount of non-residential square footage that has historically been realized in those areas.
For the East Pasadena Specific Plan, the recommendation acknowledges the more suburban nature of these communities by reducing the residential development capacity as compared to the proposed project. For the East Colorado Specific Plan area, the Refined Project modifies the residential development cap to more accurately reflect the change in the Specific Plan’s boundaries and the creation of the Lamanda Park Specific Plan.
Table 1 shows a comparison of the development caps between the proposed project, the CD, SFO, LA Alternative, and the Refined Project; and demonstrates that residential and nonresidential caps lie at or between the caps proposed for the proposed project and the caps proposed under the CD, SFO, LA Alternative.
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
6. Refined Project Environmental Analysis
August 2015 Page 6-3
Table 1 Comparison of Proposed Project, CD/SFO/LA Alternative, and Refined Project: Net Increase from Existing Conditions
Specific Plan Area
Residential (dwelling units) Non-residential (square feet) Proposed
Project
CD, SFO, LA
Alternative Refined Project
Proposed
Project
CD, SFO, LA
Alternative Refined Project
Central District 6,147 4,722 5,444 3,846,649 2,561,847 2,561,847 South Fair Oaks 1,078 807 938 1,794,506 1,340,655 1,340,655 East Colorado 334 334 351 209,223 209,223 300,000
Lamanda Park 27 27 117 714,377 714,377 630,000
East Pasadena 1,442 1,442 1,090 1,107,875 1,107,875 1,107,875 North Lake 316 316 316 255,366 255,366 255,366
Fair Oaks / Orange Grove 323 323 323 308,984 308,394 308,984 Lincoln Ave 210 105 210 298,413 153,425 298,413
West Gateway 418 418 418 206,475 206,475 206,475
No Specific Plan 2,017 2,017 2,017 2,247,091 2,247,091 2,247,091 Total 12,312 10,511 11,223 10,988,959 9,104,727 9,256,705 Land Use Diagram
Refinements to the Land Use Diagram were made along with the development caps for the Refined Project to respond to changes requested by property owners, technical corrections, or changes made to align with construction or entitlements received during the preparation of the EIR. The changes affect a small number of parcels, which are listed below:
Fuller Theological Union Master Plan
South Orange Grove Boulevard (west side, Bellefontaine Street to Arlington Drive) 9th Circuit Court of Appeals, Vista Del Arroyo, Desiderio R&D Flex Space (Citywide)
710 Right-of-Way
2810 Eaton Canyon Drive & 3105 East Sierra Madre Boulevard Goals and Policies
Changes to the Goals and Policies that resulted from comments received during the Draft EIR comment period were reviewed and included in the proposed Land Use Element (see Appendix E). The changes were generally limited to changes in phrases, terminology, or the clarification of particular concepts. Three new policies were added to the Goals and Policies in the Land Use Element. The first new policy was added to the Urban Form section supporting the enhancement of the pedestrian experience. This policy would benefit the pedestrian environment and would not result in any environmental impacts.
The second was a new policy addressing transitional heights specifically applicable to the North Lake Specific Plan area. It represents an effort to address concerns related to the contextual design and scale of mixed use
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
6. Refined Project Environmental Analysis
or residential development that occurs on the North Lake Avenue corridor adjacent to established single and multi-family neighborhoods. This policy would further protect the historic neighborhood and enhance the aesthetic character of this area. Therefore, no new environmental impacts would result.
The final policy addition incentivizes high-quality design in new Planned Developments by allowing for a 15 percent increase in the FAR. Although there would be an increase in FAR, this would not affect the development caps, which are being reduced citywide by the Refined Project. The 15 percent increase in FAR would not result in any new environmental impacts.
None of the changes to the Goals and Policies of the General Plan would result in a new significant impact requiring recirculation pursuant to CEQA Guidelines Section 15088.5.
6.1.2 Environmental Analysis of the Refined Project
The following is environmental analysis of the Refined Project recommended for approval by the Planning Commission and City staff.
Aesthetics
The types of impacts associated with degradation of scenic vistas, decreased visual quality, and increased light and glare would be similar to the proposed project under the Refined Project. Development intensities would be reduced along the Central District and South Fair Oaks corridors. However, the overall character of development would be similar to the proposed project. Also similar to the proposed project, the Refined Project does not propose changes in the City’s landform, introduce new areas of tall buildings that would block views, or promote redevelopment of entire neighborhoods.
The Refined Project would still concentrate new development within the downtown, corridors, and specific plan areas, with redevelopment on underutilized parcels occurring, incrementally. The character of the specific plan areas would continue to be defined by the adopted specific plans and design guidelines. For example, development in the Central District would be required to comply with Pasadena’s Citywide Design Principles and Design Guidelines, Pasadena Design Guidelines for Historic Districts, and applicable specific plan design guidelines.
The Refined Project would have the potential to generate new light or glare sources. However, like the proposed project, any new improvements or developments would be subject to the Municipal Code and Design Guidelines, which would ensure that light and glare would be minimized. Overall, the aesthetic impacts associated with the Refined Project would be similar to the proposed project and would remain less than significant.
Air Quality
The Refined Project would reduce air quality pollutants compared to the proposed project due to the reduction in residential uses and nonresidential square footage. This would reduce impacts associated with construction and stationary source emissions. In addition, the project refinement would reduce vehicle trips and VMT compared to the proposed project, reducing long-term operational emissions.
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
6. Refined Project Environmental Analysis
August 2015 Page 6-5
Although the project refinement would result in a reduction in air quality emissions, it would not eliminate significant long- and short-term criteria pollutant contributions of VOCs, NOX, CO, SO2, PM10, and PM2.5; it would not be consistent with the air quality management plan, since criteria pollutants thresholds would be exceeded; and it would cumulatively contribute to the SoCAB nonattainment designations for O3, PM10, and PM2.5. Implementation of the proposed Land Use Diagram was found to have significant and unavoidable impacts to long- and short-term air quality. The Refined Project would reduce some air quality impacts, but not eliminate any significant impacts.
Biological Impacts
Impacts on biological resources would be similar for the proposed project and the Refined Project since the City is largely built out and the overall geographic area available for development would not change.
Threatened and endangered species have been observed or are expected to be present in Pasadena, as indicated in Section 5.3, Biological Resources, of the DEIR. However, prior to and during construction of individual projects, those projects would be required to follow the regulations of the California and federal Endangered Species Acts, including requirements of the USFWS regarding critical habitat. The Refined Project would allow development and redevelopment in areas containing waters of the United States, waters of the state, and wetland habitats. However, similar growth would be allowed under the proposed project and compliance with applicable federal and state regulations—including those related to Section 404 permits, Section 401 water quality certification, USFWS review, and CDFW 1600 Streambed Alteration Agreements— would be required under both scenarios.
Overall, even though development intensity would be reduced under the Refined Project, biological impacts caused by development are expected to be similar to those under the proposed project. This is due to the geographic footprint of growth shared by the two scenarios.
Cultural Resources
Under the Refined Project, overall development intensity would decrease slightly; however, the amount of acreage available for development and redevelopment would remain the same. As a result, impacts to cultural resources would be expected to be substantially similar to those of the proposed project. Similar to the proposed project, future construction activities adjacent to historic buildings have the potential to result in physical impacts or architectural damage due to construction-related vibration. Mitigation is required to ensure that impacts from construction activities would not damage a historical resource. Similar to the project, impacts would be less than significant with mitigation. Ground-disturbing activities associated with buildout of the Refined Project would continue to occur in order to accommodate new development and redevelopment. Consequently, the potential of encountering fossil-bearing soils and rock formations, destroying below-ground paleontological resources, and affecting archaeological sites and sites of cultural significance would still occur, similar to the proposed project. The Refined Project would be required to comply with the same mitigation measures to lessen or negate impacts. Therefore, implementation of the Refined Project would result in impacts similar to buildout of the proposed project, which would be less than significant with mitigation.
PASADENA GENERAL PLA N FINAL EIR
CITY OF PASADENA
6. Refined Project Environmental Analysis