AR 9 Attachment B comb — Pasadena City Council, April 11, 2022 (part 5 of 6)

Nina Chomsky
1500 Lancashire St.

Pasadena, CA 91103
[email protected]
May 6, 2021
Mr. Kevin Johnson, Senior Planner
Pasadena Planning Department, Design and Historic Preservation [email protected]
Re: Central Park Apartments Proposed Project
Draft Sustainable Communities Environmental Assessment (SCEA) Mr. Johnson:

I am submitting comments on the above-referenced Draft SCEA in my individual capacity, and not on behalf of any organization. I submit the following comments.

1. The Current Revised Project is Not Eligible for CEQA Review and Assessment Utilizing a SCEA.

The current “proposed” Project is not a newly submitted Project subject to SB 375, and, therefore, eligible for SCEA assessment under the California Environmental Quality Act (CEQA). The current “proposed” Project is a revised original Project.

The original Project was submitted and in the process of review, it appears, prior to the adoption and effective date of SB 375 – in other words, the revised original Project is a “pipeline” project initiated prior to SB 375, and it is not permissible to apply SCEA rules retroactively.

The original Project continues to undergo previously initiated CEQA and entitlement review. To pretend that the original Project never happened and no longer exists, and to jump to a SCEA level of environmental analysis for this highly environmentally sensitive site, appears to be an effort to avoid full public participation and full public review and to rush the revised original Project through to final approval and environmental clearance.

The original Project is an open matter and has never been withdrawn as far as I can determine. The Draft SCEA totally ignores the procedural and legal status of the original Project. It appears that jurisdiction over the original Project continues to rest 1 2
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with the Pasadena City Council and all applicable Commissions, and the original Project was and remains subject to review and analysis pursuant to the original full Environmental Impact Report (EIR) under CEQA. The revised Project does include design, density, and other changes, and it appears that the original EIR is subject to being Supplemented or otherwise updated to reflect original Project revisions and changes.

Therefore, reliance on a SCEA level of CEQA analysis for the revised Project is inadequate under CEQA and violates CEQA. The original EIR should be updated as required and continue to be the operative CEQA review document.

2. All Public Comments Submitted in Connection with Review of the EIR Continue to Be Valid and Must Be Preserved. Since the legal and applicable CEQA review document for the revised original Project is the EIR, all public comments submitted in response to the EIR, whether oral or written, should be deemed as valid comments in response to the revised original Project and preserved. If any such prior EIR public comment is resubmitted, revised, or updated in response to the revised original Project, such public comment should be responded to as required and in the context of the continued validity and applicability of the EIR.

3. The Revised Original Project Must Receive Planning Commission Review. It appears that part of the plan to rush the revised original Project through the Pasadena public process, and to avoid full and adequate public process and review, is to “skip” Planning Commission review and recommendations prior to CEQA and entitlement review by the City Council. Skipping and avoiding Planning Commission review is not acceptable and violates Pasadena rules and customs and is a Land Use and Planning CEQA inadequacy.

Thank you for the opportunity to submit these comments. At your convenience, please acknowledge timely receipt of these comments.

Sincerely,
Nina Chomsky
Nina Chomsky
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1 Johnson, Kevin
From: cindy clark-schnuelle <[email protected]>
Sent: Wednesday, May 05, 2021 11:47 AM
To: Johnson, Kevin
Subject: Central Park Apartments Project
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Dear Kevin,
I write as a citizen of Pasadena that is opposed to the density and massing of the Central Park Apartments Project. I urge that our city council not allow the developer to circumvent our city’s long history of applying thoughtful and appropriate levels of density.

Keep our city commissions review process intact and let all interested and possibility impacted parties have a voice in how this proposed project proceeds.

Best regards,
Cindy Clark-Schnuelle
Northwest Pasadena
cell: 323 791 7721
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1 Johnson, Kevin
From: Carmen Daugherty <[email protected]>
Sent: Wednesday, May 05, 2021 8:06 PM
To: Johnson, Kevin
Subject: Central Park Apartments Project
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Dear Mr. Johnson,
I am writing to you to comment on the above project. I am not a Pasadena resident, but I do visit Central Park regularly with a painting group and by myself to sketch and paint the beautiful Castle Green Building.

I visited this lovely location on this Saturday with my husband. I sketched and painted while he read the paper. It was a lovely and relaxing morning at the park.

While I was there, I learned of the above proposed project. I am against this project, it will change the whole atmosphere of the park. It does not make sense to build a development of this size. It needs to be AFFORDABLE housing. You are building it near the Del Mar Station so people can have access to public transportation, why do you need a parking structure with 195 parking spaces? You should not approve this project.

Thank you for your time.
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1 Takeda, Michi
From: Paul Dorn <[email protected]>
Sent: Wednesday, May 05, 2021 7:53 AM
To: Johnson, Kevin
Subject: Hotel Green
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Please , please do not continue the plan of “rebuilding” the hotel Green! Pasadena is loosing its iconic presence to boring architecture. Don’t be a part of this!
Repair, maintain, but don’t destroy!
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From: Mary Fitzpatrick <[email protected]>
Sent: Wednesday, May 05, 2021 9:22 AM
To: Johnson, Kevin; [email protected]
Subject: Central Park - Castle Green Development
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I would like to express my complete horror and opposition to the development in front of Castle Green and Central Park. The "1903" project is absolutely the wrong place and way to achieve housing density in Pasadena. It would utterly mar the historic character and beauty of that Old Pasadena landmark and area, and "privatizing" a Park area. I oppose.

I am a resident of Pasadena for 48 years.

Sent from the all new AOL app for Android
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1 Johnson, Kevin
From: Erin Fleming <[email protected]>
Sent: Wednesday, May 05, 2021 5:18 PM
To: Johnson, Kevin
Subject: Born at St Luke’s so I’m old school Pasadena
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Mr Johnson,
Feel free to building your building in the park across the street from the Green Street but do not mess with perfection.

Those grounds are awesome and to mess with a Pasadena icon like that is just stupid.

Please. Don’t be stupid.

Erin Fleming
Pasadena area lifer
323/896.8246
[email protected]
Sent from my iPad
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1 Johnson, Kevin
From: Vicki Fletcher <[email protected]>
Sent: Wednesday, May 05, 2021 2:35 PM
To: Johnson, Kevin
Subject: Castle Green
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Please please preserve this wonderful historical landmark. I can’t imagine even thinking about destroying it. Thank You Victoria Fletcher
Sent from my iPhone
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1 Johnson, Kevin
From: Alan Flores <[email protected]>
Sent: Wednesday, May 05, 2021 1:16 PM
To: Johnson, Kevin
Subject: Construction Concerns
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Dear Mr. Johnson,

We are Pasadena residents who use the children’s play area at Central Park. We understand there will be a 6 floor apartment building right at the curb on Dayton, across from the park. The only safe area to load and unload our kids in the car is at Dayton. The play area is only 50 feet from Dayton and less than 100 feet from the building construction. Has the city considered the effect on the health of small children this close to a construction site? Will the parking on Dayton disappear for the duration of construction? Will it disappear forever? This park is the only open space around here. The only thing that makes the play area safe is it is right across the street from the Fire Station, the reset of the park is not safe.

What steps will be taken by the City of Pasadena to keep park users, especially those using the play area, safe from the noise, dust particles and construction debris in the air?

Thank you in advance for answering my questions,
Alan Flores
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1 Johnson, Kevin
From: Shannon Gold <[email protected]>
Sent: Wednesday, May 05, 2021 2:31 PM
To: Johnson, Kevin
Subject: 86 S. Fair Oaks Project
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Kevin Johnson
City of Pasadena
Senior Planner
175 N. Garfield Ave.

Pasadena, CA 91101
Dear Mr. Johnson,
My wife and I have been residents of the Castle Green for 8 years as of this spring. We appreciate the uniqueness of this building and it’s historic significance to Pasadena. For quite some time, this block has been a haven, away from the noise and crowds of busy commercial areas of Colorado Blvd. Not just for the residents in the immediate neighborhood but for families from all over Pasadena to come and relax away from the commerce and noise. The currently proposed project for 86 S. Fair Oaks would surely obliterate that haven for the sake of more commercial space and real estate.

In the past, we’ve come to the city planning meetings regarding the proposed developments on the Green Hotel property and each project was rejected due to various reasons. It hardly seems that this new proposal is an improvement on the previous proposals with regard to the negative impact on the neighborhood, the streets and the historic property that would surround it.

My wife and I strongly oppose this property development proposal, however we would be in favor of a much more modest structure. The proposal at hand does not take into regard the residents of the Hotel Green nor the safety of families that enjoy the playground on the corner of Dayton and Fair Oaks.

In addition, Dayton is a narrow street where cars are often at a stand-still as just with Central Park traffic alone.

It’s unimaginable to consider a structure with parking and commerce of this size on this corner. I strongly urge you to reconsider moving forward with this project for the good of Downtown Pasadena and it’s residents.

Sincerely,
Shannon Gold
99 South Raymond Ave.

Pasadena, Ca 91105
Shannon Gold
212.361.9633
1 Letter I-22
1 Johnson, Kevin
From: Timothi Jane Graham <[email protected]>
Sent: Wednesday, May 05, 2021 3:21 PM
To: Johnson, Kevin
Subject: 86 S. Fair Oaks Project
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Kevin Johnson
City of Pasadena
Senior Planner
175 N. Garfield Ave.

Pasadena, CA 91101
Dear Mr. Johnson,
I and my husband have been living at The Castle Green for about 7 years now. One of the reasons we moved to this building was for its historic value as its one of a handful of buildings in the country on the registry of historic landmark places. Central Park and its environs are a welcome respite from the busy streets of old town Pasadena.

We were shocked, dismayed and disappointed in reviewing the current proposal for the space next door on Dayton. Not only is it larger in scope than the previous project that had been proposed, but it also flagrantly oversteps the objections that had been raised for every single iteration at every single planning meeting we have attended over the years. The number of units, which have always been disputed, have now increased by 25%. The parking structure, which was always problematic, has ballooned to accommodate this. On a very narrow street this would create a huge problem for not only traffic but the park, its visitors and the children that play there. It seems unrealistic. It's already a problem as is with 2 cars not being able to share the street and traffic piling up to turn onto Raymond or Fair Oaks. How can that possibly work with 84 units? It seems untenable.

We understand that something must be agreed upon and commerce is welcomed, but this seems like such a gross overreach and not at all what Colonel Green intended, despite how the developers, Goldrich Kest, are trying to frame and market it. This is much too large and ambitious. This would harm the structure of the original buildings and would take away much needed common areas for the elderly that live next door as well as creating an untenable living situation for the current residents that live here. This also includes all those, including children, that enjoy Central Park ( originally grounds for The Castle Green ). We're hoping we can come to an agreement on something a little more modest in scope that won't be as destructive and which everyone can live with.

The Castle Green is an iconic structure and whatever lives alongside it should be carefully considered. There are so few places that completely exemplify the history of this wonderful old town better than this one of a kind building. She deserves to be protected and treated like the treasure she is. 1 Letter I-23
2 Sincerely,
Timothi Jane Graham
99 South Raymond Avenue
Pasadena, CA 91105
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1 Johnson, Kevin
From: Mo Henry <[email protected]>
Sent: Tuesday, May 04, 2021 9:27 AM
To: Johnson, Kevin; Mo Henry
Subject: The Castle Green Project
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Dear Mr. Johnson,
I am a resident and condo owner at The Castle Green on Raymond Avenue.

I am very concerned about the impact that G&K's construction will have on our historic property. Despite the fact that some new construction approvals have been streamlined because of the SCEA rules, I implore you to consider the historical importance of our building, and the true original vision that Colonel Green had for the property. He never would have foreseen the concept of underground
parking structures, and the possible damages that could occur 120 years into the future, by digging so deeply and close to the Castle's foundation, nor would he have wanted the original building to be
put in permanent shade by a new one.

Please consider us, your current constituents, who have already invested in this wonderful property, who have been paying our taxes
and caring for our places within the constraints of the historical requirements.

Respectfully,
Maureen Henry
99 S Raymond Ave Unit 307
Pasadena, CA 91105
323 543-1000
1 Letter I-26
1 Johnson, Kevin
From: Rich <[email protected]>
Sent: Thursday, May 06, 2021 2:43 AM
To: Johnson, Kevin
Subject: Central Park Apartments / Castle Green
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Dear Mr. Johnson,
My name is Rich Hockens and my parents own unit 203 at the Castle Green . Their unit faces west and will be directly looking at the CPA structure.

Understandable much opposition has been expressed now and over the years regarding the proposed development.

While the Goldrich Kest firm should utilize their property to its fullest potential it must also consider the impact on the Castle Green , other structures, people, and environment.

Could a architectural compromise be made to limit stories , number units and the like as well as addition of trees / other plant materials to soften the view between the Castle Green and the CPA - I’m not apposed to development as long as measures are taken to the sensitivity of the particulars stated above - I’m concerned the impact to the adjacent building with mentally challenged adults in blocking their view as well as on going noise of construction may be most distressing. Perhaps GK could replace those windows with double pane or other options to lessen sounds while simultaneously updating GK own real estate structure.

With some efforts by GK to minimize these effects it would make GK look most environmentally responsible to the greater good and the Pasadena community while still pursuing their endeavors! I’m fervent working together every party can prevail and ultimately provide a positive outcome that enhances life in Pasadena!
Thank you for your time and support!
Best.

Rich Hockens
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1 Takeda, Michi
From: Doug Ingoldsby <[email protected]>
Sent: Wednesday, May 05, 2021 7:58 AM
To: Johnson, Kevin
Subject: Development around the Green Hotel
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I was born in Pasadena in 1949.

I love the Green Hotel.

I am OPPOSED any development that would obscure the view of this Historical building.

Sincerely,
Doug Ingoldsby
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From: Deborah Lingrey <[email protected]>
Sent: Wednesday, May 05, 2021 8:47 AM
To: Johnson, Kevin
Subject: Proposed development around the Hotel Green and Castle Green CAUTION: This email was delivered from the Internet. Do not click links or open attachments unless you know the content is safe. Report phish using the Phish Alert Button. Learn more.... ------------------------
Dear Mr. Johnson,
The Hotel Green/Castle Green and surrounding area bounded by Fair Oaks, Green, Raymond, and Dayton should be restored and preserved without the planned construction of multi-use structures.

I understand that Castle Green would remain largely untouched by this proposed project. However, the disruption to the century old architecture and landscaping, the loss of green space, and the jarring addition of the buildings (and, of course, necessary parking) would be an affront to the history of the area. There are larger questions of the wisdom of continuing to build up-and-out given water/conservation issues, infrastructure considerations, etc. as well.

Although I am currently retired and living in Arizona, I still love Pasadena. I was born at the Huntington Hospital where my dad was a pathologist. I grew up in South Pas, went to nearby Occidental College, worked part time for my dad's lab on Madison, and lived on Craig Ave. before my marriage. Even after moving away, my husband and I made many return visits, first with our children and, in recent years, to attend family and school reunions. During all these stages of my life, I have loved driving through Pasadena. There have been many changes to the city, especially in the business and shopping districts, but I have always felt that Pasadena's history, graciousness, and "vibe" have been prioritized and maintained.

The decisions made about this project should reflect what the city truly values. The entire Hotel Green/Castle Green area is one of Pasadena's treasures. Please protect it.

Sincerely,
Deborah Lingrey
1 Letter I-31
1 Takeda, Michi
From: Kim M <[email protected]>
Sent: Wednesday, May 05, 2021 7:21 AM
To: Johnson, Kevin
Subject: Stop Green Hotel development
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Dear Mr Johnson,
As a 66 year resident I am tired of Pasadena allowing ugly unnecessary buildings to go up. Let's keep our city beautiful. Demand more from greedy developers.

Thank you,
Kim Mischook
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1 Takeda, Michi
From: Krista Moll <[email protected]>
Sent: Thursday, April 15, 2021 11:24 AM
To: Johnson, Kevin
Subject: Central Park Apartments Project
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Hi Kevin -
I am writing today about the Central Parks Apartment Project. I think it's absolutely obnoxious to even be considering a 84 apartment, 6 level, live and commercial space at 86 S. Fair Oaks Avenue.

That area is already over congested and to overwhelm the corner that currently holds about 50 parking spots??!?? The proposed195 parking spaces is not nearly enough for the 84-168+ cars needed for the apartments alone, let alone staff and commercial workers. And the regular traffic that is already congested, especially with Station 31 just kitty corner from this proposed project.

I highly object to the Central Park Apartments Project. I think it will turn into another Pasadena nightmare like Marengo Avenue and other spaces where single family or smaller use turns into monstrosities.

Please stop destroying Pasadena. If you insist and the city council insist on destroying though, many more pedestrian walks and stop lights MUST be installed along Fair Oaks and Raymond in order to save lives and assist Station 31 in doing their job.

Thank you,
Krista Moll
Resident of Pasadena for 20+ years
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City of Pasadena May 6, 2021
175 N. Garfield Avenue
Pasadena, CA 91101
Attention: Kevin Johnson, Senior Planner, City of Pasadena [email protected]
Regarding: The Proposed Central Park Apartments Project, located at 86 S. Fair Oaks Avenue, Pasadena
Dear Mr Johnson,
As a 20 year resident of the Castle Green and current HOA board member I am writing to express concern regarding the Proposed Central Park Apartments Project. I live on the west side of the building and understand from a massing study by our present HOA board chairman, John Cambianica, that the height and width of the proposed apartment building will result in the west side of the Castle Green being in shadow all year long.

Another, more major concern the owners and residents have is that due the size of the carpark and the number of floors, a hole 60-80 feet deep will be dug to lay the foundations of proposed building, which is alarming because of the close proximity to the Castle Green. We are concerned that this will have an effect on the stability of the Castle Green building and its foundations, and will lead to seismic safety issues in the future. I respectfully request that a proper study be carried out to determine the impact of digging such a deep hole in such close proximity to our building, and the potential effect on general and seismic stability of the Castle Green.

Lastly, there is already traffic congestion on Dayton St. A large subterranean car park of over 180 car spaces for this new project will create havoc for drivers along this small street and increase the danger to pedestrians who cross Dayton regularly to use Central Park. I believe the impact of this carpark on traffic flow and pedestrian safety should also be properly documented.

The Castle Green is one of Pasadena’s most well-known landmarks and historic treasures. It appears to be threatened by an ill-conceived, poorly designed building for which the approval is being rushed through. I hope that City Planning will act to protect the Castle Green, and will require Goldrich & Kest to design a more modest block of apartments with a smaller footprint.

Yours sincerely,
Margaret Morgan, Apt 503.

HOA Treasurer.
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Central Park Apartments SCEA
1 Kevin Johnson, Senior Planner April 10, 2021
Planning and Community Development Department
Planning Division Design & Historic Preservation section 175 North Garfield
Pasadena CA 91101
Regarding Central Park Apartments SCEA
86 South Fair Oaks
Hello Mr. Johnson
I am writing to express my concern for the existing Historic Resources Castle Green and the Hotel Green with this new construction project and would like to request attention to the Resource Protection topic in the Daft SCEA under review.

The proposed garage is currently shown at 4 levels and the outline comes quite close to the existing structures. The underground parking is 13’ (15’ on plan 13’ on text) from the Castle Green Dining Room for 4 levels (anticipated grading to 44’ plus footing depth per figure 2.0-28.) My comments and suggestions are to address the Protection of the Historic Resources.

Recommended Castle Green and Green Hotel Protection
Any Contractor’s working on Castle Green of Green Hotel should have:

Contractor’s Qualifications:
 Company literature, resume or other professional documentation that demonstrates compliance with the specified qualifications.
 List of recently completed projects including project name, location, name of owner, reference contact name and phone number, and a description of work performed by the conservator for the project. Minimum of 5 projects of similar size and complexity.

Independent Conservator on site and reporting to City and HP once a week. Secretary of the Interior Standards for acceptance of firm or individual.

Protection Plan for Historic Resources reviewed by the City and Pasadena Heritage (owner of easement) and signed by Independent Conservator. This would layout the plans & details including hard board protection on certain elevation elements in danger.

Existing Condition Documentation of Historic Resources: Clear photos and/or video documentation to assess if damage occurs.

Contractor to provide an Emergency Response Plan, including a phone tree for notification including Pasadena Heritage.

Closeout Submittals to include two copies of Conservation Records prepared for City and Pasadena Heritage:

Final Documentary Photography of protection
Final Existing Condition Documentation of protected items

1 Letter I-37
Central Park Apartments SCEA
2 PROTECTION MATERIALS
Furnish archival materials for protection of historic fabric. Provide necessary and related parts, devices and anchors required for complete protection installation. Rigid protection shall be provided of sufficient
protection shall be provided to prevent surface damage including from materials or products which may stain surfaces. Protection materials will permit moisture evaporation to prevent biological growths.

Protection materials may include but not be limited to:
 Polyethylene Sheet: 4 mil.
 Plywood: 1/2 inch or ¾ inch fire retardant, exterior grade.  Soft Fiberboard: 1/2 inch Homasote, Class A fire-resistant.  Neoprene: 1/4 inch or 1/2 inch stock sizes.
 Bubble Wrap: 1/2 and 1 inch air pockets.
 Polyurethane Foam Sheets: 4 inches thick.
 “Preservation” Tape and Plastic Film Tape.
 Acid free, unbuffered paper.
 Cardboard sheet or roll: Ramboard or equal.
 Foam-core board.
 Coat wood storage crates with non-oxygen permeable film or epoxy resin (minimum of 30 days prior to packing materials).
 Breathable, weather resistant sheet: Dupont Tyvek Commercial Wrap 1162B or equal.

PROTECTION EQUIPMENT
 Furnish temporary equipment as required to maintain temperature and humidity required for protection of historic finishes and materials sensitive to fluctuations in temperature or humidity.  Contractor may provide computer modeling or other predictions/projections of moisture content or thermal characteristics as necessary to confirm the environmental conditions and/or that substrate will be in a stabilized interior environment prior to application of repairs/restorations that may be adversely affected by fluctuations in temperature or humidity.  Requirements for protection adjacent to work: �
 All historic concrete and plaster will be protected from damages from sustained percussive activity, sudden impacts, abrasion, all acid-based materials and materials which may stain the surface.
 Protection materials will be installed in such a way that historic materials and finishes are not damaged. Historic materials will be protected from exposure to elements during repairs.  Infill materials in direct contact with surrounding historic materials will be compositionally compatible.
 Provide interior and exterior shoring, bracing, or support to prevent movement, settlement, or collapse of areas of work.
 Protection materials shall not attach to historic fabric. If no other attachment is possible, indicate in Protection Plan conditions where attachment to historic fabric is unavoidable. Attach to existing joints or to non-exposed portions rather than to finished faces. Installation of protection devices that require attachment to adjacent historic surfaces shall be supervised by Conservator. Attachments to historic fabric shall be made by persons qualified to work on that material. Details of protection material shall be shown in the protection plan.  Maintain protection devices in sound condition until completion of the Work. 2 Letter I-37
Central Park Apartments SCEA
3  Repair or replace protection devices as necessary to maintain effectiveness of protection. Inplace protection devices shall be reviewed periodically by the Conservator and any nonconformance shall be documented in Conservator's weekly field reports.  In event of new damage, use Emergency Response Plan and inform Architect immediately and report in writing a description, nature and extent of damage and proposed method of repair.

Contractor is responsible for repairs and recreation of newly damaged items to Architect’s satisfaction at no additional cost to Owner and in the approved methods of the Secretary of the standards.

MONITORING
 Monitor grade at adjacent footings that are to remain. Monitor by providing spot elevations at corners and every 20 linear feet monthly for the duration of the work. Conservator is to review updated surveys weekly as part of routine field reports. Notify Architect of noted movement.  Monitor environmental conditions of the Castle Green and Green Hotel. Monitor using temperature and humidity equipment. Conservator is to review updated surveys weekly as part of routine field reports and implement environmental modifications such as heaters, fans, or humidifiers as determined necessary by the Conservator.  During periods of rain, make daily observations of the structure and immediately implement procedures to protect the structure and new work where water infiltration is observed. Correct and clean up water intrusion including dehumidifiers, fans, or other instrumentation required to  correct the environmental conditions and prevent the growth of mold and mildew. Emergency Response Plan if historic materials become soaked.

HISTORIC FINISHES PROTECTION MONITORING:

Provide salt analysis of efflorescent materials observed using Merck indicator paper strips. Reporting:
 If chlorides are found, report presence and take precautions to stabilize internal environment.

Deliquescent materials can absorb relatively large amounts of water from the atmosphere to form a temporary liquid saline solution and, as the atmosphere becomes drier, the salts recrystallize and grow with each cycle damaging presenting finishes. Internal atmospheres should not fluctuate between cold-dry and warm-moist.

These protection directives come from my work as an Architect in the Historic Preservation Field.

You never think a disaster will happen until it does.

Best Regards,
Andrea Rawlings
375 Anita Dr.

Pasadena, CA
2 Letter I-37
Adam Relin
317 Carroll Park West
Long Beach, CA, 90814
May 4, 2021
VIA EMAIL AND U.S. MAIL
Kevin Johnson
Senior Planner, Planning & Community Development Department 175 North Garfield Avenue
Pasadena, California, 91101
([email protected])
RE: Central Park Apartments Draft Sustainable Communities Environmental Assessment (“DSCEA”)
Dear Mr. Johnson:

As a frequent visitor to Central Park, and a patron of the various businesses in Old Town Pasadena, I am concerned about the effects of the proposed Central Park Apartments (“Project”) on the park and the community. These concerns include the environmental effects of the Project on traffic, historic resources, and recreation uses. The DSCEA does not adequately describe such potential effects, and fails to include meaningful mitigation measures. The DSCEA should be revised and reissued for comment, and the Project should be reevaluated in light of the environmental effects and public comments.

1. The Project Scale and Design Will Have A Significant Effect on the Old Town Historic District
Before addressing specific comments on the DSCEA, a more general comment on the Project context. Old Town Pasadena is a regional shopping and entertainment destination, bringing both urban life and tax revenue to the City of Pasadena (“City”). Adding residential density near effective public transit is an excellent planning goal, but it is important to make sure that pursuing it does not result in damage to the qualities that make the area desirable to future residents and visitors. The predominance of historic buildings in the area, and their successful 1 2
Letter I-38
restoration and reuse, is a significant, perhaps primary, reason that Old Town is an attraction. No one needs to travel across Southern California to shop at the Container Store or dine at Cheesecake Factory - those amenities can be found near home. People are drawn to Old Town to visit those stores and others because of the unique ambiance of the old buildings, varied storefronts, and modest scale.

But these are delicate qualities that can be diminished or destroyed by incautious planning decisions. The historic value of the district is supported by the high proportion of historic buildings. Diluting that concentration will affect the resource; at some point if the historic district is surrounded by, and infilled with, an excess of larger modern projects it will lose its special quality. That it may be difficult to quantify “ambiance” does not absolve the City from considering the issue.

Adding the large Project immediately adjacent to the City’s signature historic landmarks, in conjunction with other residential developments that have been approved or are under construction in or near the Old Town district, will significantly change the historic district. The City should evaluate these effects, which were not addressed in the Central District Specific Plan, including reducing the value of the district as a regional shopping and entertainment district, and consider reduction in the scale of the Project to keep it, and similar projects, from overwhelming the historic district.

2. Increased Traffic, Particularly on Dayton, Will Significantly Affect Central Park Users
All of the Project traffic will be moved through Dayton Ave., the small access road that borders Central Park. This street is the access point to the park for many visitors, and the safest close parking place for parents who bring their children to the play area located along Fair Oaks just near Dayton. Increasing traffic here will endanger pedestrians, and have significant noise impacts on the park. Reduced air quality, including local CO impacts, will have significant heath effects on children using the play area. The DSCEA fails to address these issues.

Further, the DSCEA does not provide necessary mitigation for the transportation impact of the increased traffic. The Transportation Report concludes, “Dayton Street between Fair Oaks Avenue and Raymond Avenue exceeded the adopted segment impact caps. Conditions to reduce project vehicular trips are required.” No such conditions are evident in the DSCEA. The City should devise such conditions and should consider requiring access to the Project from Fair Oaks rather than Dayton.
3 2
Letter I-38

3. The Project Will Have A Significant Impact on Historic Resources As the DSCEA acknowledges, the Project is smack in the middle of an essential concentration of historic properties. It is not only within the Old Town historic district but actually part of a separately listed historic site included on the national and state lists and designated as a landmark by the City. In spite of this proximity, the DSCEA pretends that a massive new building will not have any effect on the historic qualities of the site.

One of the unusual and valuable things about the Hotel Green/Castle Green site is the fact that it occupies an entire block within the larger historic district. The parking lot at the Project site is modern, of course, but it is essentially open space which does not detract from the impression that the block is much as it was in the past. Unfortunately, the height and mass of the Project make it a co-equal presence on the site with the historic buildings. This changes the listed site from a place that looks very much as it was a century ago into a place that looks about half new. As the impact standards mentioned in the DSCEA explain, an addition to a historic site “needs to be subordinate to the historic building.” (DSCEA,

4.0-68 ) In its current form the Project is not “subordinate” and this results in a significant impact.

Practically the only potentially significant impact acknowledged in the DSCEA is the effect of vibration from construction on the adjacent historic buildings. Even here, the document is careless with historic resources. It’s simply implausible that the Hotel Green, at 20 feet from the construction, will be affected by vibration, while the Castle Green, at 40 feet, will not. Vibration caused by excavating four levels of parking, and constructing a large new building will not suddenly dissipate at 39 feet away. The mitigation measures for vibration should be expanded to include Castle Green.

4. The City Should Require Meaningful Transit Oriented Features The City does not appear to be serious about achieving an actual transit orientation in this “transit oriented development” Project. The Project relies on its proximity to stations on the Gold Line in order to justify limited environmental review under CEQA. While the Project may meet the very basic residential composition and location near transit criteria for Transit Priority Projects (“TPPs”) under SB 375, merely meeting the statutory definition of a TPP is not enough to effectively promote transit use. Yet the City seems willing to simply wave toward the rail 5 4
6 Letter I-38
stations and say “there, see, it promotes transit!” If the Project includes any specific measures to advance transit use, they are not prominent in the DSCEA.

The most obvious source of helpful measures is in the list of mitigation measure from Connect Socal, included in Appendix A of the DSCEA. Mitigation Measure PMM-TRA-1 includes measures that the City might impose to reduce travel demand and increase transit use. The DSCEA explicitly rejects application of these measures, without meaningful explanation. The City should require the Project to include features from this measure, or from the many other available resources, that actually promote the use of transit.

Another significant way the City could promote transit use in its TPPs is to limit onsite parking. If the City expects residents at the Project to use the excellent transit facilities right on their doorstep, then those residents do not need the four levels of underground parking called for by the Project. Reducing this parking, would reduce traffic, noise, and construction impacts of the Project, as well as encouraging transit use.

5. The DSCEA Does Not Adequately Describe The Project
The fundamental purpose of any environmental review document is to inform the public and the decision makers of the potential effects of the project. To do this, the document must clearly describe the project. The DSCEA, however, is not clear about the Project and presents confusing and contradictory information.

Some examples include the following.
a. The DSCEA does not present any context for the public to understand the history of the Project. Apparently the Project is not a new proposal at all, but rather the revision of a prior 64 unit proposal by the same developers. The DSCEA makes no mention of this history. No discussion of the issues with the environmental review for that version of the Project, or the concerns with that plan or its rejection in 2015. No explanation of how a Project for which an EIR was prepared now qualifies for limited review even though the revised Project is substantially larger. Neither the public nor the City decision makers can adequately understand the Project without explanation of these issues. b. The explanation of impacts on trees is badly muddled. The impact analysis says there are 31 trees on site (DSCEA, 4.0-39). But the associated Table

4.4-1 lists only 28 trees. The Project Description says there are 21 trees on the Project site (DSCEA, 2.0-5). And Figure 2.0-4 appears to show 38 existing trees. In presenting the landscape plan, Figure 2.0-32 asserts that 19 existing 7 6
8 Letter I-38
trees will be preserved, but actually lists only 12 preserved trees. How many trees are there? How many will be retained? How many new trees planted? Even though there is an additional review process under the City’s tree ordinance, the DSCEA must be able to present these basic details to the public. Further, because of the relationship of the Project to Central Park, the landscape plan is of particular importance in evaluating the impact of the Project on the visual and recreational resources of the park. c. The description of the Project is inconsistent. Is it six stories and a “mezzanine” (DSCEA, 2.0-16), or six stories and a penthouse (DSCEA,

4.0-70)? Is there both a mezzanine and a penthouse? Which assumption is reflected in the description of the building height and mass? While the City’s plans suggest that infill development is an appropriate use of the Project site, the scale of the Project is too large to fit comfortably into the landmark historic site or the larger historic district, resulting in effects not adequately covered in the DSCEA. The City should consider a reduced project as a way to mitigate Project impacts.

Thank you for the opportunity to review the DSCEA.

Very Truly Yours,
Adam Relin
10 9
8 Letter I-38
City of Pasadena May 6, 2021
175 N. Garfield Avenue
Pasadena, CA 91101
Attention: Kevin Johnson, Senior Planner, City of Pasadena [email protected]
Regarding: The Proposed Central Park Apartments Project, located at 86 S. Fair Oaks Avenue, Pasadena
Dear Mr Johnson,
As a 17 year resident of the Castle Green and current HOA board member I am writing to express concern regarding the Proposed Central Park Apartments Project. I live on the west side of the building and understand from a massing study by our present HOA board chairman, John Cambianica, that the height and width of the proposed apartment building will result in the west side of the Castle Green being in shadow all year long.

Yours sincerely,
Magnus Stark, Apt 504.

Castle Green, Board of Directors
1 Letter I-39
1 Takeda, Michi
From: Patty Swenson <[email protected]>
Sent: Wednesday, May 05, 2021 7:11 AM
To: Johnson, Kevin
Subject: History
CAUTION: This email was delivered from the Internet. Do not click links or open attachments unless you know the content is safe. Report phish using the Phish Alert Button. Learn more...<https://mydoit.cityofpasadena.net/sp?id=kb_article_view&sysparm_article=KB0010263>. ------------------------
Please take care of the history of Pasadena. Take care of the historic Castle Green! Patty Stifel Swenson
Sent from my iPad
1 Letter I-40
1 Johnson, Kevin
From: Edward Temm <[email protected]>
Sent: Thursday, May 06, 2021 5:02 PM
To: Johnson, Kevin
Subject: Central Park Apartments 86 S. Fair Oaks Pasadena Traffic Concerns Attachments: Dayton street 9.JPG; Dayton street 8.JPG; Dayton street 7.JPG; Dayton street 6.JPG; Dayton street 5.JPG; Dayton street 4.JPG; Dayton street 3.JPG; dayton street 2.JPG; Dayton Street 1.JPG
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To whom it may concern:

As a resident of the block where Central Park Apartments is to be built. I have concerns over construction noise.

I am extremely concerned about the increase of traffic and safety in Old Town particularly on Dayton Street between Fair Oaks and Raymond the street which often becomes congested throughout the weekdays and weekends with limited visibility and heavy traffic, sometimes with frustrated drivers, especially at the corners of Fair Oaks also at Raymond. Accidents are not that uncommon here are several pictures of a recent one.
thank you
Edward Temm
1 Letter I-41

1 Johnson, Kevin
From: Amy White <[email protected]>
Sent: Wednesday, May 05, 2021 2:19 PM
To: Johnson, Kevin
Subject: Please Don't Approve the Current Plan for Addition/Expansion of Hotel Green CAUTION: This email was delivered from the Internet. Do not click links or open attachments unless you know the content is safe. Report phish using the Phish Alert Button. Learn more.... ------------------------
Dear Kevin,
I'm reading about the plans for the new addition to the Hotel Green complex and am shocked it is even being considered, especially in its current form. The developer of this plan has shown they can't take proper care of what they already own so why would Pasadena give them additional opportunity to deface one of the city's historical treasures?
They claim they are following the original 1903 vision of Colonel Green. That statement alone shows they can't be trusted with the project as their plans are nothing like the vision of Castle Green. They've thrown that out there with hope that people won't want to question the idea further.

At minimum, thorough public consultation needs to happen including from the historical perspective, seismic safety, traffic impact and environmental impact. And do it in person! Pasadena is opening up and we can soon attend these community discussions in person. The fact it is being pushed through like this shows just how little confidence the developers have in the ability of their plan to withstand such scrutiny.

The City of Pasadena cannot consider themselves a city of "... arts, culture, history, and architecture..." and at the same time approve this plan by the developer.

Please say no to plan.

Best regards,
Amy White
1 Letter I-42
1 Takeda, Michi
From: Julie Wofford <[email protected]>
Sent: Wednesday, May 05, 2021 5:47 AM
To: Johnson, Kevin
Subject: Stop the development obscuring Castle Green
CAUTION: This email was delivered from the Internet. Do not click links or open attachments unless you know the content is safe. Report phish using the Phish Alert Button. Learn more...<https://mydoit.cityofpasadena.net/sp?id=kb_article_view&sysparm_article=KB0010263>. ------------------------
Dear Kevin and to whom it may concern:

I just read about this proposed development that would be 11 stories high and would block the views of our iconic and treasured Pasadena landmark The Castle Green.

What is Pasadena thinking? Do they have no pride or are they just greedy? Do the people making these decisions not live on Pasadena? I beg you all to consider and preserve our beautiful city of Pasadena! I have lived in the Pasadena area for 45 years and have been proud of our Crown City.

Please keep Pasadena Green!!!!
Thanks for your consideration.

Regards,
Julie Wofford
Sent from my iPhone
1 Letter I-43
1 Concerning Proposed Development on the Historically Registered Block of The Castle/Hotel Green - How is it that one of Pasadena’s top three architectural treasures, The Castle Green and The Hotel Green, designated on The National Registry of Historic Places – the whole city block, from Fair Oaks to Raymond Avenues, Dayton to Green Streets – is yet again being threatened by the developer Goldrich & Kest, who plans to build an eleven-level structure, rising seven stories above ground right in front of Pasadena’s iconic Victorian gem, and has the hubris to call their development Colonel Green’s “1903 Vision?”
This view from Fair Oaks of The Castle Green…
This current 123-year-old-view from Fair Oaks of The Castle Green with its iconic turrets will be blocked out 1 Letter I-44
2 …will be replaces with something like this:
…Glass, steal and sprayed-on stucco.

And an iconic “postcard” view of Pasadena for 123 years gone in the blink of an eye, for another towering high-rise mixed-use development.

When the Goldrich & Kest claim to be completing Colonel Green’s 1903 vision, take a closer look at the vision of Colonel Green’s from the building they will be shrouding from view. 1 Letter I-44
3 This kind of detail, shown here on the western turret of Castle Green, was Colonel Green’s Vision! Look at the surface work, the varied window framing, the wrought iron…

The current 123-year-old view of Castle Green and its iconic turrets seen from Fair Oaks and the western half of Old Pasadena will be entirely obscured by this towering new proposed development, and several century old trees cut down.

A 123-year-old “postcard” view soon to be shrouded by a wall of glass and sprayed-on stucco, four floors of subterranean parking, on an eleven-level mixed use development, seven stories above ground level right in front of this Victorian architectural gem, our Pasadena heritage, if G & K have their way.

And what’s to happen to the 100-year-old trees?
And what are the seismic implications – something to be particularly mindful of, given the status of the beloved Pasadena Public Library – of digging a four-story deep hole a few hundred feet from our iconic treasures? The Hotel Green has already had scaffolding up for several years because of a 1 2
3 Letter I-44
4 crumbling façade, which Goldrich & Kest, the current owner (of The Hotel Green, not the Castle Green), has done little more than build a scaffolding to remediate. If they want to carry forward Colonel Green’s 1903 Vision, start by taking care of the actual Colonel Green 1903 building they already own, which has been entirely gutted by them of most original detail, as they have shown little custodial integrity to its interior, or exterior – two of the domes are missing on their roof (replace them!), the detailed façade has crumbled all over their property and they do little or nothing to preserve or restore any of it. And now they want to dig a four-story deep hole and slap up a new tenlevel building a hundred feet from a historically registered building already in their possession that’s literally crumbling.

And why is this project being rushed through City Hall, during Covid, when public comment, if the public even knows to comment, and opposition is being allocated to email and zoom calls? And why the accelerated review process, with the SCEA omitting or minimizing many CEQA areas of review? Why is Goldrich & Kest in such a hurry to jump the line to build this new towering high-rise development, putting their neighbors in permanent shade, when they fail to adequately maintain their current holdings in Colonel Green’s true vision – realized in brick and mortar – in 1903, The (now crumbling, under their watch) Hotel Green.

Do the good people of Pasadena even know this is happening? That an iconic building, used in murals and postcards for well over a century to represent Pasadena – with its towering castle turrets a symbol of our city – is soon to be dominated from view from the western half of Old Pasadena and Fair Oaks – the main artery into and out of Old Pasadena – by an eleven-level, seven story, towering apartment block, to be built on a historically registered site, whose historic designation extends beneath the actual footprint of this development, from Fair Oaks to Raymond, from Green to Dayton. How is that even legal?
I whole-heartly stand in opposition to this development, David Woodbury
Third Generation Pasadena Resident and Local Historian
The Hotel Green, c. 1903
5 3
4 Letter I-44

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APPENDIX I
Green Hotel Apartments Project Final EIR – Not Certified

FINAL ENVIRONMENTAL IMPACTREPORT
City of Pasadena
Planning & Community Development Department
State Clearinghouse Number: 2013031067
Green Hotel
Apartments Project
June2015

i
Green Hotel Apartments Final EIR
Table of Contents
Section 1 Summary.................................................................................................................................................1-1 Section 2 Corrections and Additions................................................................................................................2-1 Section 3 Comments and Responses ................................................................................................................3-1

3.1 Background ......................................................................................................................................................3-1

3.1.1 Draft EIR Published January 24, 2014 .....................................................................................3-1

3.1.2 Recirculated Draft EIR Published January 20, 2015 ..........................................................3-2

3.2 List of Commenters.......................................................................................................................................3-3

3.2.1 List of Public Agencies and Private Parties Commenting on the Draft EIR..............3-3

3.2.2 List of Public Agencies and Private Parties Commenting on the Recirculated Draft EIR...............................................................................................................................................3-3

3.3 Responses to Comments............................................................................................................................. 3-3

3.3.1 Topical Responses to Comments on the Draft EIR ............................................................. 3-3 Topical Response (TR)–CR-1 Potential Impacts to Historic Resources...............3-4 TR-AES-1 Potential View Impacts ........................................................................................3-8 TR-ALT-1 Project Alternatives.............................................................................................3-10

3.3.2 Individual Responses to Comments on the Draft EIR .....................................................3-29 Letter No. 1 County Sanitation Districts of Los Angeles County ...................3-31 Letter No. 2 Pasadena Heritage ...................................................................................3-37 Letter No. 3 Castle Green Homeowner’s Association.........................................3-47 Letter No. 4 Chatten-Brown & Carstens LLP .........................................................3-91 Letter No. 5 Ann Scheid................................................................................................3-103 Letter No. 6 Kelly Sutherlin McLeod, FAIA..........................................................3-111

3.3.3 Comments Received at the Public Hearing on the Draft EIR.....................................3-126

3.3.4 Individual Responses to Comments on the Recirculated Draft EIR.......................3-130 Letter No. 7 Ciy of San Marino ...................................................................................3-131 Letter No. 8 Castle Green Homeowner’s Association.......................................3-135

3.3.5 Comments Received at the Public Hearing on the Recirculated Draft EIR..........3-157 Section 4 Mitigation Monitoring and Reporting Program........................................................................4-1 Attachment 1 – Design Process Memorandum
Table of Contents
ii
Green Hotel Apartments Final EIR
List of Figures
Figure 2-3a Aerial Overview – Oblique Angel ............................................................................................................. 2-7 Figure 2-5 Site Plan and First Floor Layout............................................................................................................... 2-9 Figure 3.1-2 Location of On-Site Trees .......................................................................................................... 2-13 & 3-83 Figure 3-1-15 Vantage Point Locations – Vantage Points 5 through 8 ............................................... 2-15 & 3-11 Figure 3-1.16 Vantage Point 5.............................................................................................................................. 2-17 & 3-13 Figure 3.1-17 Vantage Point 6.............................................................................................................................. 2-19 & 3-15 Figure 3.1-18 Vantage Point 7 ....................................................................................................................2-21 & 3-17 Figure 3.1-19 Vantage Point 8 ....................................................................................................................2-23 & 3-19 Figure 3.1-20 Vantage Point Locations – Vantage Points 9..................................................................... 2-25 & 3-21 Figure 3.1-21 Vantage Point 9 ..................................................................................................................... 2-27& 3-23 List of Tables
Table 1 Summary of Project Impacts, Conditions of Approval, Mitigation Measures, and Residual Impacts ............................................................................................................................................. 1-7 Table 2-1 Summary Disposition of Protected Trees with Project Implementation................2-3 & 3-81 Table 3-1 Summary of On-Site Trees ...........................................................................................................2-5 & 3-79 Table 3-2 Summary Disposition of Protected Trees with Project Implementation............. 2-11 & 3-80 Table 4-6 Reduced Height Alternative – Traffic Generation...........................................................................2-33 Table 4-1 Mitigation Monitoring and Reporting Program ................................................................................ 4-3 1-1
Green Hotel Apartments Final EIR
Section 1
Summary
Introduction
In accordance with the California Environmental Quality Act (CEQA), specifically, CEQA Guidelines Sections 15088, 15089, and 15132, the City of Pasadena (the City) has prepared the Final Environmental Impact Report (EIR) for the proposed Green Hotel Apartments Project (proposed project or project). A Final EIR is defined by Section 15362(b) of the CEQA Guidelines as “containing the information contained in the Draft EIR; comments, either in verbatim or in summary received in the review process; a list of persons commenting; and the responses of the Lead Agency to the comments received.”
The Final EIR is organized in the following sections:
 Section 1 – Summary: This Section is intended to provide a summary of the CEQA requirements, including Project Location, Setting and Description information, Alternatives to the Project, Areas of Controversy, Issues to be Resolved and a Summary of the Project Impacts and Mitigation Measures.
 Section 2 – Corrections and Additions: This Section includes changes to text within the Draft EIR and the Recirculated Draft EIR as a result of either comments received from interested parties during the public review period or as initiated by the Lead Agency (City of Pasadena or City).
 Section 3 – Comments and Responses: This Section includes all comments received on the original Draft EIR during the document’s 45-day public review period, which began on January 24, 2014 and was completed on March 11, 2014, and on the Recirculated Draft EIR during the document’s 45-day public review period, which began on January 20, 2015 and was completed on March 5, 2015. A list of public agencies, organizations, and individuals who submitted comments on the Draft EIR and/or the Recirculated Draft EIR is provided. Responses to comments received on the Draft EIR and Recirculated Draft EIR have been prepared and are included in this Section of this Final EIR.
 Section 4 – Mitigation Monitoring and Reporting Program: This Section includes a list of all mitigation measures for the project and identifies the timing associated with, and entity responsible for, implementing each mitigation measure in a table format. Space is provided within the table for tracking mitigation implementation and effectiveness.

This document, along with the Draft EIR (incorporated by reference), make up the Final EIR as defined in CEQA Guidelines, Section 15132, which states:

The Final EIR shall consist of:
(a) The Draft EIR or a revision of the Draft.
(b) Comments and recommendations received on the Draft EIR either verbatim or in summary.

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(c) A list of persons, organizations, and public agencies commenting on the Draft EIR. (d) The responses of the Lead Agency to significant environmental points raised in the review and consultation process.
(e) Any other information added by the Lead Agency.

Uses of the Final EIR
The Final EIR allows the public and the decision makers the opportunity to review revisions to the Draft EIR and Recirculated Draft EIR, the comments and responses to those comments, and other components of the EIR, such as the Mitigation Monitoring and Reporting Program, prior to approval of the project. The Final EIR serves as the environmental document to support approval of the proposed project, either in whole or in part.

After completing the Final EIR, and before approving the project, the Lead Agency must make the following three certifications as required by Section 15090 of the CEQA Guidelines:
 That the Final EIR has been completed in compliance with CEQA;  That the Final EIR was presented to the decision-making body of the Lead Agency, and that the decision-making body reviewed and considered the information contained in the Final EIR prior to approving the project; and
 That the Final EIR reflects the Lead Agency’s independent judgment and analysis.

Additionally, pursuant to Section 15093(b) of the CEQA Guidelines, when a Lead Agency approves a project that would result in significant unavoidable impacts that are disclosed in the Final EIR, the agency must state its reasons for supporting the approved action in writing. This Statement of Overriding Considerations is supported by substantial information in the record, which includes the Final EIR.

Project Location and Setting
The City of Pasadena (City) is located approximately ten miles northeast of the City of Los Angeles in the County of Los Angeles. Regional access to the City is provided by State Route 134 (SR 134), Interstate 210 (I-210 or Foothill Freeway), State Route 110 (SR110), and Interstate 710 (I-710). The project site is located at 86 South Fair Oaks Avenue, at the northeast corner of Fair Oaks Avenue at Dayton Street. Vehicle access points at the project site currently exist on Dayton Street and South Fair Oaks Avenue. The project site is located within a developed area of Downtown Pasadena on one of the City’s main commercial streets and is surrounded by residential, commercial, retail, and recreational land uses. The project site is bordered by a one-story cafe building and the existing Green Hotel Apartments on the north, Castle Green on the east, Dayton Street and Central Park on the south, and South Fair Oaks Avenue on the west.

The project site is rectangular in shape and approximately 32,362 square feet in size. The site is currently flat and has a surface parking lot with 60 parking spaces (4 handicapped parking spaces and 56 regular parking spaces), a billboard, concrete pathways, benches, an outdoor eating area, and 20 trees (15 of which are protected under the City Trees and Tree Protection Ordinance). The 15 protected trees consist of eight Mexican fan palms, two California fan palms, one Canary Island palm, three Camphor trees, and one Indian laurel fig tree.

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The project site is zoned CD-1 (Central District Specific Plan Sub-district 1, Old Pasadena Subdistrict) and has a General Plan Land Use designation of Specific Plan. The project site also is within the Old Pasadena Historic District which is listed in the National Register of Historic Places (National Register). The Castle Green, located to the east of the project site, and the existing Green Hotel Apartments buildings, located to the north of the project site, were listed together, along with the project site, in the National Register in 1982, and are therefore also listed in the California Register of Historical Resources (California Register). The Castle Green/Green Hotel Apartments listing that includes the project site is an individual listing on the National Register (not as an historic district), and the two buildings were also listed as contributors to the Old Pasadena Historic District (1983; revised, 2007). The boundaries of the Castle Green and existing Green Hotel Apartments are defined in the original National Register registration form as: “The square block bounded by Raymond Avenue on the east, Green Street on the north, Fair Oaks [A]venue on the west and Dayton Street on the south.” Thus, the entire block, which includes the project site, is listed as a historical property in the National Register.

Across Dayton Street to the south is Central Park, a 9.2 acre park which is also a contributing resource to the Old Pasadena Historic District. Across Fair Oaks Avenue to the west are three to four-story mixed-use buildings and parking lots, and across Raymond Avenue to the east are one and two-story commercial uses, all of which are also within the boundaries of the Old Pasadena Historic District. The Los Angeles County Metropolitan Transportation Authority (Metro) Del Mar Gold Line Light Rail Station is located less than a quarter of a mile to the southeast of the project site along Raymond Avenue just north of Del Mar Boulevard.

Project Objectives
The objectives for the proposed project include the following:
 Provide new apartments to assist in satisfying the increasing demand for this product type in the City of Pasadena, and particularly in the Central District and within easy walking distance of jobs and the Metro Gold Line.
 Provide new restaurant, commercial, and retail shops in Old Pasadena, thereby increasing tax revenues throughout the City.
 Provide multi-family housing within a transit-oriented district and within the immediate vicinity of a Metro Gold Line station.
 Provide affordable multi-family housing to the City’s underserved affordable market demand, particularly within the Central District and within walking distance of service oriented jobs.  Provide the residents of the adjacent existing Green Hotel Apartments appropriate parking with direct ingress/egress.
 Build out the third parcel of the Castle Green/existing Green Hotel Apartments in a manner that is based on the original turn of the 20th century vision, which has been underutilized as surface parking since the 1950’s, to thereby create a compatible new gateway framing an entrance to Old Pasadena.
 Broaden the retail connection on Fair Oaks Avenue to Colorado Boulevard by providing retail services along the street frontage.

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 Create a mixed-use development that faces, compliments, and engages with the open space to the south of the site.
 Preserve views of the park from the south-facing units of the existing Green Hotel Apartments by providing an open space corridor between the Castle Green and the proposed project.

Project Characteristics
The proposed project involves construction and operation of a six-story mixed-use building with 64 residential units and 5,000 square feet of commercial space on an existing surface parking lot currently occupied by a billboard, 60 parking spaces and landscaping at 86 South Fair Oaks Avenue in Pasadena. The project site is 32,362 square feet and the proposed multi-story mixed-use building would be 76,980 square feet in size.

The ground floor would consist of 5,000 square feet of commercial space and 20 parking spaces, with 11 of the 20 parking spaces “tucked under” the building. In addition, 15 bicycle parking spaces (4 open rack and 11 enclosed) would be provided on the ground floor. Residential units would be located on the second through sixth floors. The proposed project would provide 9,600 square feet of private open space and recreational uses, which would consist of 2,880 square feet of open space (including a pool), a 1,050 square-foot gym, and 5,670 square feet of open space provided in the courtyard on the ground floor.

Parking for the project would be provided in compliance with City’s Zoning Code and would be accommodated with 20 parking spaces on the ground floor and two levels of underground parking providing 147 parking spaces. The City’s Zoning Code requires the provision of a minimum of 107 spaces for the new building as well as replacement of the 60 existing spaces on-site, which serve the existing Green Hotel Apartments. The proposed building would have a height of 75 feet and would comprise 76,980 square feet of gross floor area (2.38 floor area ratio). The height, floor area ratio, and setbacks meet the development standards for the CD-1 zoning district.

The driveway to the project site would be located along Dayton Street and would provide access to the surface and underground parking. Both ingress and egress would be available from Dayton Street.

Pedestrian access to the residential lobby and commercial uses would be available off of Fair Oaks Avenue.

Construction of the proposed project would require the removal of 10 of the 15 trees protected under the City’s ordinance.1 The City’s Tree Protection Ordinance requires protected trees to be replaced, but allows for several replacement alternatives. If all protected trees to be removed are proposed to be replaced with non-palm trees, they may be replaced with 76 non-palm trees of a minimum 24-inch box size or 48 non-palm trees of a minimum 36-inch box size. Alternatively, if protected palm species are proposed to be replaced with new palm trees, the aggregate height of replacement palm trees must total 167.5 feet, and the remaining removed non-palm trees may be replaced with either 40 24-inch box trees or 24 36-inch box trees.

The Tree Replacement Matrix adopted by the City Council in 2010 also indicates that protected specimen trees must be replaced with specimen or native trees on the list of protected native and

1 In addition to the 15 protected trees located within the project site, there are three protected trees located directly adjacent to the project site, as shown in Figure 3.1-2 of the Final EIR and accounted for in Table 3-2 of the Final EIR (Tree Nos. 7, 22, and 23). Those three protected trees would remain in-place with project implementation.

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specimen trees. The four protected non-palm trees proposed to be removed are on the list of specimen trees; therefore the trees planted to replace them must be on the list of protected native or specimen trees. The City’s Tree Protection Ordinance also states that “the developer may request to pay a fee instead of planting on site up to 50 percent of the required number of replacement trees.” A total of 24 new 36-inch box trees and new palm trees totaling 176 feet in height would be planted on-site, thereby meeting the required replacement trees per the City’s Tree Protection Ordinance.

Three existing palm trees would be transplanted on-site to naturally draining soil and the new trees would be planted in either naturally draining soil or planters above the subterranean parking.

Planters would be raised to provide a portion of the required five-foot planter depth above the grade.

Therefore, the proposed project would meet the requirements of the City’s Tree Protection Ordinance.

Removal of protected trees requires adherence to the ordinance through the review and approval of applications for each removed tree and findings are required to be made to ensure the removals meet the ordinance. The requested tree removals will be reviewed in conjunction with the design review that is required for the proposed project.

Construction activities associated with the proposed project are anticipated to include demolition, site preparation, excavation, grading, construction of the new mixed-use building, application of coatings, paving, painting/striping, installation of lighting/security lighting, and landscaping. Construction would occur in one phase lasting approximately 28 months, beginning in August 2014 and completing in December 2016. Site clearing and grubbing activities would last for approximately five days, demolition of the existing parking lot would occur over a period of approximately one month, grading of the project site is anticipated to take approximately three months, building sub-phase (i.e., construction of the building and underground parking levels) would last for 16 months, application of architectural coatings would last approximately 10 months, and asphalt application would last approximately two months, with some construction phases overlapping. Construction staging would occur on-site and construction of the proposed project would require a maximum of 40 construction workers. Demolition of the existing parking lot would produce approximately 620 cubic yards (cy) of debris. Grading and excavation on the project site would produce approximately 30,000 cy of soil for export.

Alternatives to the Project
CEQA requires that an environmental impact report (EIR) describe a range of reasonable alternatives to a proposed project that could feasibly avoid or lessen any significant environmental impacts, while attaining the basic objectives of the project. Comparative analysis of the impacts of these alternatives is required. In response to the significant impacts associated with the proposed project, the City developed and considered the following alternatives to the project:
 Alternative 1 – No Project
The No Project Alternative is the No Build Alternative and assumes that the proposed building would not be constructed; the site would remain in its current state and continue to be occupied by a billboard and utilized for parking by residents of the existing Green Hotel Apartments building.
 Alternative 2 – Reduced Height
The Reduced Height Alternative assumes the construction of a mixed-use building, much like the proposed building; however, two fewer floors would be constructed thereby reducing the Section 1  Summary
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Green Hotel Apartments Final EIR
number of residential units from 64 to 42 and reducing the required number of parking spaces from 166 to 131. A total of 5,000 square feet of commercial space would remain within the ground floor of the building under the Reduced Height Alternative.

Four other alternatives were considered but rejected as infeasible, as outlined further in Section 4.0, Alternatives.

The CEQA Guidelines require that an environmentally superior alternative be identified from the alternatives considered in an EIR. The No Project Alternative would result in no environmental impacts and therefore would be the Environmentally Superior Alternative to the proposed project.

However, as required by CEQA Guidelines Section 15126.6(e)(2), if the No Project Alternative is identified as the Environmentally Superior Alternative, a second build alternative must be identified as the Environmentally Superior Alternative. As such, Alternative 2, the Reduced Height Alternative, would be the Environmentally Superior Alternative to the proposed project because this alternative would reduce the severity of the significant and unavoidable traffic impact along the Dayton Street segment between Fair Oaks Avenue and Raymond Avenue.

Areas of Known Controversy
The CEQA Guidelines require a Draft EIR to identify areas of controversy known to the lead agency, including issues raised by other agencies and the public. Comments were received from public agencies and interested parties in response to the circulated Notice of Preparation (NOP). In compliance with CEQA Guidelines, the City held two scoping meetings on April 8 and April 15, 2013, to solicit comments and to inform the public of the proposed EIR. Comments were also received in response to the published NOP (provided in Appendix A), which identified environmental topics that local and regional agencies recommended for analysis in the Draft EIR. The following environmental topics of potential controversy were identified during the scoping meetings and/or NOP process:
 Aesthetic and landscaping changes through the removal of trees/canopy trees and survival of new and transplanted trees;
 Ingress/Egress along Dayton Street;
 Fire Safety and emergency access along Dayton Street;  Increased traffic from project implementation;
 Density and height of project relative to surrounding land uses and buildings;  Historical significance of entire block on which the project site is located;  Impact on views from surrounding buildings;
 Alternatives to the proposed design;
 Air quality impacts to sensitive receptors, and specifically the neighboring Castle Green, the existing Green Hotel Apartments, and Central Park;
 Unreinforced masonry walls of Castle Green Apartments could be impacted by excavation, vibration, and other construction activities; and
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Green Hotel Apartments Final EIR
 Loss of soil during construction could cause displacement of Castle Green.

As a result of the comments received during the scoping process, the following environmental topics were evaluated in depth in this Draft EIR:
 Aesthetics;
 Air Quality;
 Cultural Resources;
 Greenhouse Gases;
 Noise and Vibration; and
 Transportation and Circulation.

Issues to be Resolved
The CEQA Guidelines require an EIR to present issues to be resolved by the lead agency. These issues include the choice between alternatives and whether or how to mitigate potentially significant environmental impacts. The major issues to be resolved by the City of Pasadena, as the Lead Agency for the project include the following:
 Whether the recommended mitigation measures should be adopted or modified;  Whether additional mitigation measures need to be applied to the project; and  Whether the project or an alternative should be approved.

Summary of Project Impacts, Conditions of Approval, and Mitigation Measures
A summary of the environmental impacts associated with implementation of the proposed project, conditions of approval (COA) and mitigation measures (MM) included to avoid or lessen the severity of potentially significant environmental impacts, and residual impacts, is provided in Table 1, Summary of Project Impacts, Conditions of Approval, Mitigation Measures, and Residual Impacts, below.

Table 1 Summary of Project Impacts, Conditions of Approval, Mitigation Measures, and Residual Impacts Significance Threshold and Project Impacts Mitigation Measures Residual Impact Aesthetics
The project would introduce a new 6-story
building on a site located within a built-out
environment adjacent to two existing six- and
seven-story buildings. The project would not
have a substantial adverse effect on a scenic
vista (i.e., blocking views of the San Gabriel
Mountains from public vantage points or from
the adjacent uses).

No mitigation is required Less than
significant impact
The project would introduce a new building on
a site covered with mature trees and utilized
only for surface parking. However, the project
No mitigation is required Less than
significant impact
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Green Hotel Apartments Final EIR

2 As part of the Final EIR, an additional condition of approval, COA-CULT-1, was incorporated into the project to address unanticipated archaeological finds during project construction. As described in Section 2 below, it was already concluded in the Initial Study/Notice of Preparation that implementation of the proposed project would not result in significant impacts to archaeological or paleontological resources. The addition of COA-CULT-1 does not change that earlier conclusion; hence, it is not a mitigation measure and is therefore not listed in this table. would not substantially degrade the existing
visual character or quality of the site and its
surroundings.

The project would create a new source of
increased levels of ambient lighting and glare in
the immediate vicinity of the site; however,
light emanating from the new building would
be consistent with the ambient nighttime
illumination levels of existing development and
proposed exterior lighting would be shielded
and oriented in a manner that will prevent
spillage or glare onto surrounding uses.

No mitigation is required Less than
significant impact
The project would result in new shadows being
cast on light-sensitive uses; however, the
project site is in an urban environment,
immediately adjacent to existing buildings of
comparable massing and height.

No mitigation is required Less than
significant impact
Air Quality
The project would create emissions during
construction and operation but would not
conflict with implementation of the applicable
air quality plan.

No mitigation is required No impact
The project would create emissions from
operational/area sources and from increased
vehicle trips , but would not violate any air
quality standard or contribute substantially to
an existing or projected air quality violation.

No mitigation is required Less than
significant impact
The project would generate emissions from
operational/area sources and from increased
vehicle trips but would not result in a
cumulatively considerable net increase of any
nonattainment criteria pollutant.

No mitigation is required Less than
significant impact
The project construction would generate
emissions that would not exceed, but would
nearly approach, the PM2.5 emissions
thresholds; as such, mitigation is included to
ensure that the project would not expose
sensitive receptors to substantial pollutant
concentrations during construction.

MM AQ-1: Construction Equipment Engine
Requirements. The construction contractor shall
ensure that off-road construction equipment be
equipped with engines that meet the model year
2007 or Tier 3 emission standards for off-road
compression-ignition (diesel) engines (13 CCR 2420-
2425.1). Older model year engine may also be used if
they are retrofit with a diesel particulate filter to
reduce PM emissions to the applicable emission
standards.

MM AQ-2: Construction Equipment Limitations. The
construction contractor shall ensure that the
cumulative hours of operation for all off-road diesel
equipment do not exceed 60 hours per day.

Less than
significant impact
The project would generate odors from
construction equipment and potentially from
commercial uses during operations; however,
the project would not create objectionable
odors affecting a substantial number of people.

No mitigation is required Less than
significant impact
Cultural Resources2
The project is adjacent to but would not No mitigation is required Less than Section 1  Summary
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Green Hotel Apartments Final EIR
involve demolition or physical alteration of the
historic Hotel Green or Castle Green
Apartments or any other historic structures.
significant impact
The project involves new construction adjacent
to existing historic resources and would not
involve relocation of a historic resource.

No mitigation is required. Less than
significant impact
The project involves new construction adjacent
to existing historic resources and would not
involve conversion, rehabilitation or alteration
of a significant resource and would comply
with the Standards 9 and 10 of the Secretary of
the Interior’s Standards for Rehabilitation.

No mitigation is required Less than
significant impact
The project would involve the construction of a
new building adjacent to existing historic
resources; however, the new construction
would not reduce the integrity or significance
of important resources on the site or in the
vicinity. The historic character and integrity of
the Castle Green and existing Green Hotel
Apartments would remain intact.

No mitigation is required Less than
significant impact
Greenhouse Gases
The project would generate greenhouse gas
emissions as a result of vehicles traveling to
and from the apartments, natural gas
combustion from space heating, disposal of
solid waste, and electricity used directly by the
building and indirectly to supply water to the
site and to treat wastewater; however, these
emissions would not exceed the SCQAMD’s
proposed screening-level significant threshold
for commercial land uses.

No mitigation is required Less than
significant impact
The project would not conflict with an
applicable plan, policy or regulation adopted
for the purpose of reducing the emissions of
greenhouse gasses.

No mitigation is required No impact
Noise and Vibration
The project could expose persons to or
generate noise levels in excess of standards
established in the local general plan or noise
ordinance, or applicable standards of other
agencies.

Maximum construction noise levels (which
would occur occasionally and intermittently
when equipment would work closest to the
sensitive receptors at the property line at full
power) are estimated at 91 dBA at the existing
Green Hotel Apartments and 81 dBA at Castle
Green at the ground floor. However average
construction noise levels would be 75 dBA and
74 dBA, respectively. Noise levels would be
slightly lower at elevations above the ground
floor because of increased distance between
the source and receptor. Since the maximum
noise levels to be generated during
construction is 80 dBA at 100 feet from the
noise source, construction noise levels would
not exceed the City’s Noise Ordinance limit for
construction noise of 85 dBA at a distance of
100 feet. However, mitigation is included to
minimize noise levels to neighboring properties
to the maximum extent feasible.

COA NOISE-1: Noise Barriers. Before the start of
pavement demolition, the contractor shall erect a 20-
foot-high temporary noise barrier, such as a curtain
of durable flexible composite material with soundabsorptive material on one or both sides and solid wall composed of 5/8-inch plywood or heavier, on the
northern and eastern sides of the project site. The
noise barrier shall be installed without any gaps and
with the sound absorptive side facing the
construction activity area. The barrier shall be
maintained and any damage that may occur be
promptly repaired. The barrier shall remain in place
until the completion of outdoor construction
requiring use of diesel-powered equipment.

COA NOISE-2: Noise Reduction Measures. Prior to
approval of grading plans and/or prior to issuance of
demolition, grading and building permits, the
following noise-reduction measures shall be included
in the construction plans or specifications:
 The construction contractor shall equip all
construction equipment, fixed or mobile, with
properly operating and maintained mufflers,
consistent with manufacturers’ standards.
 The construction contractor shall place all
stationary construction equipment so that the
Less than
significant impact
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equipment is as far as reasonably feasible from
noise-sensitive receptors and so emitted noise is
directed away from noise-sensitive receptors.
 The construction contractor shall locate equipment
staging in areas that will create the greatest
distance between staging area noise sources and
noise-sensitive receptors.

COA Noise-3: Adherence to Noise Restrictions
Ordinance. The project shall adhere to all applicable
requirements of the Noise Restrictions Ordinance
during project construction and operation. A
Construction Related Noise Plan is required as part of
the Construction Staging Plan and must be reviewed
by the Building Division and the Department of
Transportation and approved prior to the issuance of
a grading permit. This plan should show the location
of any construction equipment and how the noise
from this equipment will be mitigated by such
methods as: temporary noise attenuation barriers;
preferential location of equipment; and use of
current technology and noise suppression
equipment.

MM NOISE-1: Construction Time Limits. Prior to
issuance of grading and/or building permits,
contractor specifications shall include a note
indicating that noise-generating construction
activities shall be limited to between the hours of
7:00 AM and 7:00 PM Monday through Friday and
between the hours of 8:00 AM and 5:00 PM
Saturday. On Sundays and Federal holidays, no noisegenerating construction activities shall be permitted.

The proposed project would contribute
operational (post-construction) noise to the
existing environment through (1) the addition
of traffic on local streets, (2) on-site stationary
sources, and (3) on-site outdoor activities.

The primary noise source to the project site
and surrounding buildings is traffic on Fair Oaks
Avenue. The proposed building would block a
substantial portion of the traffic noise to the
project site, the existing Green Hotel
Apartments, and Castle Green. The resultant
traffic noise level at Castle Green and the
existing Green Hotel Apartments residences
would be less than the existing ambient noise
level.

Operational noise sources associated with the
proposed residential uses would include, but
would not be limited to mechanical equipment
(e.g., heating, ventilating, and air conditioning
[HVAC] units and swimming pool pumps);
landscape maintenance equipment; vehicles in
the surface parking area; vehicles entering and
leaving the subterranean parking area; and
outdoor activities at the swimming pool area.

The project would not result in a substantial
permanent increase in ambient noise levels in
the project vicinity above levels existing
without the project.

COA NOISE-3: Adherence to Noise Restrictions
Ordinance. The project shall adhere to all applicable
requirements of the Noise Restrictions Ordinance
during project construction and operation. A
Construction Related Noise Plan is required as part of
the Construction Staging Plan and must be reviewed
by the Building Division and the Department of
Transportation and approved prior to the issuance of
a grading permit. This plan should show the location
of any construction equipment and how the noise
from this equipment will be mitigated by such
methods as: temporary noise attenuation barriers;
preferential location of equipment; and use of
current technology and noise suppression
equipment.

COA NOISE-4: HVAC Noise Levels. Prior to the
issuance of building permits, the Applicant shall
provide data to the Director of Planning and
Community Development demonstrating that the
noise level from heating, ventilation, and air
conditioning (HVAC) units, swimming pool
equipment, and similar mechanical equipment when
measured inside any dwelling unit on the same
property or 20 feet from the outside of the dwelling
unit in which the noise source or sources may be
located would be less than 50 dBA.

COA NOISE-5: Exterior to Interior Noise Reduction.

Prior to the issuance of building permits, the
applicant shall present data to the Director of
Planning and Community Development
demonstrating that the exterior-to-interior noise
reduction for residential units facing Fair Oaks
Less than
significant impact
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Green Hotel Apartments Final EIR
Avenue would be at least 24 A-weighted decibels
(dBA).

COA NOISE-6: Noise Notification. Prior to the
issuance of a Certificate of Occupancy for the project, the applicant shall present information to the
Director of Planning and Community Development
demonstrating that appropriate sale or lease transfer
documents for residential units include an advisory
that the residence is located in the Central District,
an area where there is a potential for noise from
commercial and nighttime activities. The following
language is provided as an example:

All potential buyers and/or renters of residential
property in the Green Hotel Apartments, which is
in Pasadena’s Central District Specific Plan area,
are hereby notified that they may be subject to
audible noise levels attributed to business and
entertainment-related activities common to such
areas, including amplified sound, music, delivery
vehicles, pedestrian and vehicular traffic, and
other urban noise
MM NOISE 2: Noise Restrictions within the Common
Outdoor Area. Prior to the issuance of an occupancy
permit, the Applicant shall provide evidence to the
Director of Planning and Community Development
demonstrating that the building’s Covenants,
Conditions and Restrictions (CC&Rs) or equivalent
regulations include a prohibition on the use of radios, televisions, “boom boxes”, and similar devices in the
pool area and other outdoor common areas unless
the devices are used with headphones, ear buds, or
similar device and that signs with such restrictions
are posted at the pool area.

MM NOISE-3: Pool Hours of Operation. Prior to the
issuance of an occupancy permit, the Applicant shall
provide evidence to the Director of Planning and
Community Development demonstrating that the
building’s CC&Rs or equivalent regulations include a
prohibition on the use of the pool area between
10:00 p.m. and 5:00 a.m. and that signs with pool
hours are posted at the pool area.

The project would generate noise during
construction and during operation. However,
construction and operational noise would not
expose persons or generate noise levels in
excess of standards established in the local
general plan or noise ordinance, or applicable
standards of other agencies.

Less than
significant impact
Construction of the proposed project has the
potential to generate vibration to the adjacent
structures and their occupants. Construction of
the proposed project would not require pile
driving or blasting, which are generally the
sources of the most severe vibration. In
addition, vibratory compactors would not be
MM NOISE-4: Consult with Structural Engineer and
Project Historical Architect. Prior to approval of
grading plans and/or prior to issuance of demolition,
grading and building permits, and to the satisfaction
of the City of Pasadena, the applicant shall retain a
Professional Structural Engineer with experience in
structural vibration analysis and monitoring for
Less than
significant impact
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Green Hotel Apartments Final EIR
used during project construction. However,
conventional heavy construction equipment
would be used for demolition of the existing
parking lot and adjacent sidewalks, for
excavation of the two levels of subterranean
parking, and for export of demolished and
excavated materials.

Because structural damage considerations
require limiting vibration levels to 0.12 ppv
in/sec or a similar level, the perception of
vibration by persons in the existing Green Hotel
Apartments would fall within the barely
perceptible to distinctly perceptible range.

Given the sensitivity of the surrounding uses,
the project has the potential to expose persons
and structures to excessive groundborne
vibration or groundborne noise levels.
historic buildings and a Project Historical Architect as a team to perform the following tasks:
 Review the project plans for demolition and
construction;
 Survey the project site and the existing
Green Hotel Apartment building and the 84
South Fair Oaks Avenue structure, including
geological testing, if required; and
 Prepare and submit a report to the Director of
Planning and Community Development to include,
but not be limited to, the following:
o Description of existing conditions at the
existing Green Hotel Apartment building
and the 84 South Fair Oaks Avenue
structure;
o Vibration level limits based on building
conditions, soil conditions, and planned
demolition and construction methods to
ensure vibration levels would be below

0.12 ppv in/sec, the potential for damage
to the existing Green Hotel Apartment
building and the 84 South Fair Oaks Avenue
structure;
o Specific measures to be taken during
construction to ensure the specified
vibration level limits are not exceeded; and
o A monitoring plan to be implemented
during demolition and construction that
includes post-construction and postdemolition surveys of the existing Green Hotel Apartment building and the 84 South
Fair Oaks Avenue structure.
o Examples of measures that may be
specified for implementation during
demolition or construction include, but are
not limited to
- Prohibition of certain types of impact
equipment;
- Requirement for lighter tracked or
wheeled equipment;
- Specifying demolition by non-impact
methods, such as sawing concrete;
- Phasing operations to avoid
simultaneous vibration sources; and
- Installation of vibration measuring
devices to guide decision making for
subsequent activities.

MM NOISE-5: Post-Construction Survey and
Documentation. To the satisfaction of the City of
Pasadena, at the conclusion of vibration-causing
activities, in the unanticipated event of discovery of
vibration-caused damage, the Structural Engineer
and the Project Historical Architect shall document
any damage to the existing Green Hotel Apartment
building and the 84 South Fair Oaks Avenue structure
caused by construction of the project and shall
recommend necessary repairs. The project applicant
shall be responsible for any repairs associated with
vibration-caused damage as a result of construction
of the project. Any repairs shall be undertaken and
completed as required to conform to the Secretary of
Section 1  Summary
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Green Hotel Apartments Final EIR
the Interior’s Standards for the Treatment of Historic
Properties (36 Code of Federal Regulations 68), and
shall apply the California Historical Building Code
(California Code of Regulations, Title 24, Part 8) and
other applicable codes.

Transportation and Circulation
The project is consistent with the policies in the
Mobility Element of the City’s General Plan.

However, the project would introduce new
vehicle trips onto the Dayton Street segment
between Fair Oaks Avenue and Raymond
Avenue. The increased number of vehicle trips
would result in a significant traffic impact to
this street segment. As such, while no Mobility
Element inconsistencies would occur, the
increased traffic introduced along Dayton
Street between Fair Oaks Avenue and Raymond
Avenue would constitute a significant impact.

No feasible mitigation. Significant and
unavoidable
The project would generate new vehicle trips,
although not to such an extent at designated
congestion management program street
segments and intersections such that impacts
would be significant. As such, the project would
not conflict with an applicable congestion
management program, including, but not
limited to, level of service standards and travel
demand measures, or other standards
established by the county congestion
management agency for designated roads or
highways.

No mitigation is required. No impact
The anticipated maximum queue length for the
westbound left-turn at Fair Oaks Ave/Dayton
Street would not exceed the available storage
length of the westbound traffic lane on Dayton
Street. Additionally, the project would
incorporate regulatory signage so that
westbound traffic along Dayton Street would
not block the project driveway. Therefore, the
project would not result in a safety hazard due
to the project’s design.

COA TRANS-1: Regulatory Signage. Regulatory
signage shall be installed at the project driveway’s
intersection with Dayton Street to prevent motorists
from blocking the driveway. This signage shall
conform to Pasadena Police Department signage
standards for signage installed along driveways with
blocked driveways violations and any violations shall
be subject to citations by PD.

Less than
significant impact
The project would provide emergency access
along Fair Oaks Avenue and Dayton Street, and
as such, would not result in inadequate
emergency access.

No mitigation is required Less than
significant impact
The project would result in an increased
number of vehicle trips and would temporarily
affect Metro bus stops during construction.

However, the project would not conflict with
adopted policies, plans, or programs regarding
public transit, bicycle, or pedestrian facilities,
or otherwise decrease the performance or
safety of such facilities.

MM TRANS-1: Coordination with Metro. The
construction contractor shall contact and notify
Metro Bus Operations Control Special Events
Coordinator at 213-922-4632 a minimum of 10
working days prior to any construction activities that
may impact Metro bus lines. Additionally, the
construction contractor shall contact and include
other bus services, such as ARS and Foothill Transit,
in construction outreach efforts that may be affected
by construction activities. A quarterly compliance
report submitted by the construction contractor
would satisfy Metro’s monitoring requirements.

MM TRANS-2: Maintain Pedestrian Access.

Construction activity shall not be allowed to block or
interfere with pedestrian access to the existing
transit stop located along Fair Oaks Avenue, near the
corner of Fair Oaks Avenue and Dayton Street.

Less than
significant impact
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Green Hotel Apartments Final EIR
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Green Hotel Apartments Final EIR
Section 2
Corrections and Additions
The following corrections and additions are set forth to update the Draft Environmental Impact Report (EIR) and the Recirculated Draft EIR for the proposed Green Hotel Apartments Project (proposed project) in response to the comments received during the public review period for each document. The following corrections and additions have been reviewed in relation to the standards in Section 15088.5(a) and (b) of the California Environmental Quality Act (CEQA) Guidelines regarding when recirculation of a Draft EIR is required prior to certification. Sections 15088.5(a) and (b) of the CEQA Guidelines state:
(a) A lead agency is required to recirculate an EIR when significant new information is added to the EIR after public notice is given of the availability of the draft EIR for public review under Section 15087 but before certification. As used in this section, the term “information” can include changes in the project or environmental setting as well as additional data or other information.

New information added to an EIR is not “significant” unless the EIR is changed in a way that deprives the public of a meaningful opportunity to comment upon a substantial adverse environmental effect of the project or a feasible way to mitigate or avoid such an effect (including a feasible project alternative) that the project’s proponents have declined to implement. “Significant new information” requiring recirculation include, for example, a disclosure showing that:
(1) A new significant environmental impact would result from the project or from a new mitigation measure proposed to be implemented.
(2) A substantial increase in the severity of an environmental impact would result unless mitigation measures are adopted that reduce the impact to a level of insignificance. (3) A feasible project alternative or mitigation measure considerably different from others previously analyzed would clearly lessen the significant environmental impacts of the project, but the project’s proponent declines to adopt it. (4) The draft EIR was so fundamentally and basically inadequate and conclusory in nature that meaningful public review and comment were precluded. (b) Recirculation is not required where the new information added to the EIR merely clarifies or amplifies or makes insignificant modifications in an adequate EIR.

The corrections and additions to the Draft EIR and the Recirculated Draft EIR document included herein do not constitute new significant information requiring recirculation of the Draft EIR beyond what was accomplished through the Recirculated Draft EIR already completed for the project.

Corrections and Additions
Changes to the Draft EIR the Recirculated Draft EIR are identified below by the corresponding Draft EIR the Recirculated Draft EIR section and subsection, if applicable, and the page number. Additions are shown in underline and deletions in double strikeout format.

Section 2  Corrections and Additions
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Green Hotel Apartments Final EIR
Executive Summary
The Executive Summary of the Draft EIR is replaced by Section 1, Summary, as contained in this Final EIR document.

Section 2
Project Description
The first paragraph in Section 2.2 of the Project Description on page 2-1 of the Draft EIR has been revised to acknowledge that access to the project site currently exists on Dayton Street and Fair Oaks Avenue, as presented below and also included in Section 2, Corrections and Additions, of the Final EIR:.

The project site is located within the City of Pasadena (the City), which is located approximately 10 miles northeast of the City of Los Angeles in the County of Los Angeles (Figure 2-1, Regional Location). Regional access to the City is provided by State Route 134 (SR 134), Interstate 210 (I-210 or Foothill Freeway), State Route 110 (SR 110), and Interstate 710 (I-710). The project site is located at 86 South Fair Oaks Avenue, at the northeast corner of Fair Oaks Avenue at Dayton Street. Vehicle access points at the project site currently exist on Dayton Street and South Fair Oaks Avenue. The project site is bordered by a one-story commercial building and the existing Green Hotel Apartments on the north, Castle Green on the east, Dayton Street on the south, and South Fair Oaks Avenue on the west, as shown in Figure 2-2, Local Vicinity and Figure 2-3, Aerial Overview.

Table 2-1 Summary of On-Site Protected Trees, on page 2-2 of the Draft EIR has been replaced as follows:

Genus & Species Common
Name
Estimated
Age (years)
Diameter Height Remain Relocate Remove &
Replace
Cinnamomum
camphora
Camphor 70 36” 45’ X
Cinnamomum
camphora
Camphor 70 23” 45’ X
Cinnamomum
camphora
Camphor 100 50” 45’ X
Washingtonia filifera California
fan palm
80 36” 65’ X
Washingtonia filifera California
fan palm
80 32.5” 60’ X
Ficus microcarpa Indian
laurel fig
65 40” 40’ X
Phoenix canariensis Canary
Island palm
105 30” 65’ X
Washingtonia
robusta1
Mexican fan
palm
75 17” 50’ X
Washingtonia
robusta1
Mexican fan
palm
75 16” 45’ X
Washingtonia
robusta1
Mexican fan
palm
75 16” 50’ X
Washingtonia Mexican fan 75 17” 50’ X
Section 2  Corrections and Additions
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Green Hotel Apartments Final EIR
robusta1palm
Washingtonia
robusta1
Mexican fan
palm
85 21” 75’ X
Washingtonia
robusta1
Mexican fan
palm
45 18” 30’ X
Washingtonia
robusta1
Mexican fan
palm
85 16” 60’ X
Washingtonia
robusta1
Mexican fan
palm
65 16” 75’ X
Table 2-1 Summary Disposition of Protected Trees with Project Implementation Genus & Species Common Name Diameter
(Inches)
Height
(Feet)
Remain
in Place
Relocate
within
Project
Site
Remove/
Mitigate
Through
Replacement
Cinnamomum camphora Camphor 36 45 X
Cinnamomum camphora Camphor 23 45 X
Cinnamomum Camphora Camphor 50 45 X
Washingtonia Filifera California Fan Palm 36 65 X
Cinnamomum camphora Camphor 23 60 X
Washingtonia Filifera California Fan Palm 32.5 60 X
Ficus Microcarpa Indian Laurel Fig 40 40 X
Phoenix Canariensis Canary Island Date
Palm
30 65 X
Syagrus Romanzoffiana Queen Palm ~11 ~12 X
Syagrus Romanzoffiana Queen Palm ~11 ~15 X
Washingtonia Robusta Mexican Fan Palm 17 ~50 X
Washingtonia Robusta Mexican Fan Palm 16 ~45 X
Washingtonia Robusta Mexican Fan Palm 16 ~50 X
Washingtonia Robusta Mexican Fan Palm 17 ~50 X
Washingtonia Robusta X Mexican Fan Palm 21 75 X
Washingtonia Robusta X Mexican Fan Palm 18 ~30 X
Washingtonia Robusta Mexican Fan Palm 16 ~65 X
Washingtonia Robusta Mexican Fan Palm 16 ~75 X
Figure 2-3a, Aerial Overview – Oblique Angle, is added to the Draft EIR after Figure 2-3 on page 2-9, as shown on the following page herein.

The second complete paragraph on page 2-14 of the Draft EIR has been revised to read as follows:

The proposed project would provide 9,600 square feet of private open space and recreational uses, which would consist of 2,880 square feet of open space (including a pool), a 1,050 square-foot gym, and 5,670 square feet of open space provided in the courtyard on the ground floor. Landscaping for the proposed project would include the following trees: marina, crape myrtle, olive tree, and pink trumpet tree along with drought tolerant ground cover and shrubs.

Section 2  Corrections and Additions
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Green Hotel Apartments Final EIR
Figure 2-5, Site Plan and First Floor Layout, on page 2-19 of the Draft EIR is replaced with the figure included on page 2-7 herein.

Section 3.1
Aesthetics
The last sentence of the second paragraph on page 3.1-3 of the Draft EIR is revised to read as follows:

There are no distant views of the San Gabriel Mountains available within the vast majority of the project site, as views to the north are blocked by the existing Green Hotel Apartments building; however, a narrow view window of the mountains is available at the western edge of the site when looking north along Fair Oaks Avenue, with the breadth of that view being constrained by existing multi-story buildings that line both sides of the street.

Table 3-1 Summary of On-Site Trees, on page 3.1-4 of the Draft EIR has been replaced as follows:

Tree # Genus & Species Common Name Diameter Height
50 Cinnamomum camphora (protected) Camphor 36 inches 45 feet 51 Cinnamomum camphora (protected) Camphor 23 inches 45 feet 52 Cinnamomum camphora (protected) Camphor 50 inches 45 feet 53 Washingtonia filifera (protected) California fan palm 36 inches 65 feet 54 Washingtonia filifera (protected) California fan palm 32.5 inches 60 feet 55 Ficus microcarpa (protected) Indian laurel fig 40 inches 40 feet 67 Phoenix canariensis (protected) Canary Island palm 30 inches 65 feet 65 Washingtonia robusta (protected) Mexican fan palm 17 inches 50 feet 71 Washingtonia robusta (non-protected) Mexican fan palm 16 inches 45 feet 72 Washingtonia robusta (non-protected) Mexican fan palm 16 inches 50 feet 77 Washingtonia robusta (non-protected) Mexican fan palm 17 inches 50 feet 78 Washingtonia robusta (non-protected) Mexican fan palm 21 inches 75 feet 79 Washingtonia robusta (non-protected) Mexican fan palm 18 inches 30 feet 80 Washingtonia robusta (non-protected) Mexican fan palm 16 inches 60 feet 81 Washingtonia robusta (non-protected) Mexican fan palm 16 inches 75 feet Section 2  Corrections and Additions
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Green Hotel Apartments Final EIR
Table 3-1 Summary of On-Site Trees
Tree # Genus & Species Common Name Diameter
(Inches)
Height
(Feet)
Protected Status
1 Cinnamomum camphora Camphor 36 45 Protected Specimen Tree 2 Cinnamomum camphora Camphor 23 45 Protected Specimen Tree 3 Pinus Canariensis Canary Island Pine 19 65 Non-Protected Tree 4 Pinus Canariensis Canary Island Pine 18 60 Non-Protected Tree 5 Cinnamomum Camphora Camphor 50 45 Protected Specimen Tree 6 Washingtonia Filifera California Fan Palm 36 65 Protected Specimen Tree 7 Cinnamomum camphora1Camphor 23 60 Protected Specimen Tree 9 Magnolia Grandiglora Southern Magnolia 15 35 Non-Protected Tree 10 Ulmus Parvifolia Chinese Elm 14.5 30 Non-Protected Tree 11 Washingtonia Filifera California Fan Palm 32.5 60 Protected Specimen Tree 12 Ficus Microcarpa Indian Laurel Fig 40 40 Protected Specimen Tree 13 Phoenix Canariensis Canary Island Date
Palm
30 65 Protected Specimen Tree
14 Phoenix Canariensis Canary Island Date
Palm
~36 8 Non-Protected Tree
22 Syagrus Romanzoffiana1Queen Palm ~11 ~12 Protected Street Tree 23 Syagrus Romanzoffiana1Queen Palm ~11 ~15 Protected Street Tree 28 Washingtonia Robusta Mexican Fan Palm 17 ~50 Protected Mature Tree 29 Washingtonia Robusta Mexican Fan Palm 16 ~45 Protected Mature Tree 30 Washingtonia Robusta Mexican Fan Palm 16 ~50 Protected Mature Tree 31 Washingtonia Robusta Mexican Fan Palm 17 ~50 Protected Mature Tree 35 Washingtonia Robusta X Mexican Fan Palm 21 75 Protected Mature Tree 36 Washingtonia Robusta X Mexican Fan Palm 18 ~30 Protected Mature Tree 37 Washingtonia Robusta Mexican Fan Palm 16 ~65 Protected Mature Tree 38 Washingtonia Robusta Mexican Fan Palm 16 ~75 Protected Mature Tree Note: 1. Although the canopy of this tree extends to or into the project site, the trunk of the tree is located outside the site boundary (i.e., off-site).

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Figure 2-3a
Aerial Overview – Oblique Angle
o

Green Hotel Apartments )LQDOEIR
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Figure 2-5
Site Plan and First Floor Layout
Green Hotel Apartments Final EIR
Source: GMPA Architects, Inc., 2013
o
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Green Hotel Apartments Final EIR
Figure 3.1-2, Location of On-Site Trees, on page 3.1-5 of the Draft EIR is replaced with the updated figure included on page 2-11 herein.

Table 3-2 Summary of Relocated/Replaced Protected Trees, on page 3.1-26 of the Draft EIR is replaced as follows:

Tree # Genus & Species Common Name Diameter Height Remain Relocate Replace 50 Cinnamomum camphora Camphor 36” 45’ X
51 Cinnamomum camphora Camphor 23” 45’ X
52 Cinnamomum camphora Camphor 50” 45’ X
53 Washingtonia filifera California fan palm 36” 65’ X
54 Washingtonia filifera California fan palm 32.5” 60’ X 55 Ficus microcarpa Indian laurel palm 40” 40’ X
67 Phoenix canariensis Canary Island palm 30” 65’ X
65 Washingtonia robusta1 Mexican fan palm 17” 50’ X
71 Washingtonia robusta1 Mexican fan palm 16” 45’ X
72 Washingtonia robusta1 Mexican fan palm 16” 50’ X
77 Washingtonia robusta1 Mexican fan palm 17” 50’ X
78 Washingtonia robusta1 Mexican fan palm 21” 75’ X
79 Washingtonia robusta1 Mexican fan palm 18” 30’ X
80 Washingtonia robusta1 Mexican fan palm 16” 60’ X
81 Washingtonia robusta1 Mexican fan palm 16” 75’ X
Notes: 1 Diameter at breast height (dbh)
Table 3-2 Summary Disposition of Relocated/Replaced Protected Trees with Project Implementation Tree # Genus & Species Common Name Diameter
(Inches)
Height
(Feet)
Remain
in Place
Relocate
within
Project
Site
Remove/
Mitigate
Through
Replacement
1 Cinnamomum camphora Camphor 36 45 X
2 Cinnamomum camphora Camphor 23 45 X
5 Cinnamomum Camphora Camphor 50 45 X
6 Washingtonia Filifera California Fan Palm 36 65 X
7 Cinnamomum camphora Camphor 23 60 X
11 Washingtonia Filifera California Fan Palm 32.5 60 X
12 Ficus Microcarpa Indian Laurel Fig 40 40 X
13 Phoenix Canariensis Canary Island Date
Palm
30 65 X
22 Syagrus Romanzoffiana Queen Palm ~11 ~12 X
23 Syagrus Romanzoffiana Queen Palm ~11 ~15 X
28 Washingtonia Robusta Mexican Fan Palm 17 ~50 X
29 Washingtonia Robusta Mexican Fan Palm 16 ~45 X
30 Washingtonia Robusta Mexican Fan Palm 16 ~50 X
31 Washingtonia Robusta Mexican Fan Palm 17 ~50 X
35 Washingtonia Robusta X Mexican Fan Palm 21 75 X
36 Washingtonia Robusta X Mexican Fan Palm 18 ~30 X
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Green Hotel Apartments Final EIR
Table 3-2 Summary Disposition of Relocated/Replaced Protected Trees with Project Implementation Tree # Genus & Species Common Name Diameter
(Inches)
Height
(Feet)
Remain
in Place
Relocate
within
Project
Site
Remove/
Mitigate
Through
Replacement
37 Washingtonia Robusta Mexican Fan Palm 16 ~65 X
38 Washingtonia Robusta Mexican Fan Palm 16 ~75 X
The figures on the pages 2-15 through 2-27, included herein, Figure 3.1-15 through Figure 3.1-21, have been added to Section 3.1, Aesthetics, of the Draft EIR:

Figure 3.1-2
Location of On-Site Trees
Source: GMPA Architects, Inc., 2013
o

PROTECTED TREES TO BE REMOVED

NON-PROTECTED TREE TO BE REMOVED
(SEE A1.15 FOR NON- PROTECTED TREE LEGEND)

PROTECTED TREE TO BE BOXED AND TRANSPLANTED ON THE SITE EXISTING 1305&$5&%TREE TO BE SAVED.

Green Hotel Apartments )LQDOEIR
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Figure 3.1-15
Vantage Point Locations – Vantage Points 5 through 8
Green Hotel Apartments Final EIR
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Figure 3.1-16
Vantage Point 5
Green Hotel Apartments Final EIR
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After
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Figure 3.1-17
Vantage Point 6
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After
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Figure 3.1-18
Vantage Point 7
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After
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Figure 3.1-19
Vantage Point 8
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After
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Figure 3.1-20
Vantage Point Locations – Vantage Point 9
Green Hotel Apartments Final EIR
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Figure 3.1-21
Vantage Point 9
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After
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Green Hotel Apartments Final EIR
Section 3.3
Cultural Resources
The second paragraph on page 3.3-1 of the Draft EIR is updated as follows:

The IS/NOP for the proposed project is included in Appendix A of this EIR. The IS/NOP determined that the proposed project would result in a less than significant impact to archaeological and paleontological resources. Therefore these resource topics are not further evaluated in the Draft EIR. Additionally, the following Condition of Approval (COA) is incorporated into the project to address unanticipated archaeological finds during project construction:

COA-CULT-1: Unanticipated Archaeological Finds
A targeted monitoring program by a qualified professional archaeologist versed in historic archaeology shall be implemented during construction. While the archaeological monitor need not be present throughout construction, the targeted archaeological monitoring program shall minimally include the following:
 Prior to grading, the archeological consultant shall acquire and review a records search from the South Central Coastal Information Center (SCCIC) and review the cultural/historic resource reports prepared for the project to identify any areas of archaeological sensitivity onsite.
 On the first day of the grading phase and/or prior grading activities, the archaeological consultant shall conduct a meeting with the construction crew to assist the crew in identifying potentially significant cultural resources and to identify any potential related concerns. If any potential resources are identified when the monitor is not on site, the monitor shall be called immediately and permitted to examine the area prior to additional disturbances.
 The archaeological consultant shall monitor the first two days of grading activities and initial activities associated with the removal of basements, foundations, and/or concrete slabs.
 The archaeological consultant shall monitor the disturbance (e.g., grading, trenching, etc.) of any archaeologically sensitive areas identified through records review and/or preliminary investigation. To minimize costs, efforts will be made to schedule such disturbance while the archaeological consultant is otherwise present onsite.  The archaeological consultant shall prepare a summary report at the completion of monitoring for submittal to the SCCIC.

The archaeological monitor shall have the authority to halt any activities impacting archaeological resources and the monitor/archaeological consultant must be permitted to adequately evaluate the find. If materials are found to be important, measures must be taken to preserve such materials in place or relocate the materials off site for further study.

Section 3.5
Noise and Vibration
Section 2  Corrections and Additions
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Green Hotel Apartments Final EIR
The first and second paragraphs on page 3.5-21 of the Draft EIR are revised to read as follows:

However, demolition and construction activities could occur closer than 25 feet to the existing Green Hotel Apartment building and attached single-story structure (i.e., 84 South Fair Oaks Avenue). Based on FTA and Caltrans methodologies, if large bulldozers, loaded trucks, or similar equipment were to operate within 20 feet of the existing Green Hotel Apartments building or the 84 South Fair Oaks Avenue structure, the vibration level could exceed the 0.12 ppv in/sec significance threshold (see Table 3.5-6). Data from testing at one particular site (see Table 11 of Appendix G) indicates the 0.12 ppv in/sec threshold could also be exceeded with some construction equipment at distances greater than 20 feet. Because the exact limits of equipment use, types of equipment to be used, and soil conditions are not known, without implementation of mitigation, vibration generated during demolition and construction of the proposed project could result in a potentially significant impact to the existing Green Hotel Apartment building and attached single-story structure (i.e., 84 South Fair Oaks Avenue). The Castle Green building is approximately 75 feet from the project site; at this distance, the potential for structural vibration impacts would be less than significant.

Because structural damage considerations require limiting vibration levels to 0.12 ppv in/sec or a similar level (as may be established through implementation of Mitigation Measures NOISE-4 and NOISE-5), the perception of vibration by persons in the existing Green Hotel Apartments and attached single-story structure (i.e., 84 South Fair Oaks Avenue) would fall within the barely perceptible to distinctly perceptible range. This impact would be less than significant.

Mitigation Measure MM-NOISE-4, included on pages 3.5-21 and 3.5-22 of the Draft EIR, is revised to read as follows:

MM-NOISE-4: Consult with Structural Engineer and Project Historical Architect Prior to approval of grading plans and/or prior to issuance of demolition, grading and building permits, and to the satisfaction of the City of Pasadena, the applicant shall retain a Professional Structural Engineer with experience in structural vibration analysis and monitoring for historic buildings and a Project Historical Architect as a team to perform the following tasks:
 Review the project plans for demolition and construction;  Survey the project site and the existing Green Hotel Apartments building and the 84 South Fair Oaks Avenue structure, including geological testing, if required; and  Prepare and submit a report to the Director of Planning and Community Development to include, but not be limited to, the following:
- Description of existing conditions at the existing Green Hotel Apartments building and the 84 South Fair Oaks Avenue structure;
- Vibration level limits based on building conditions, soil conditions, and planned demolition and construction methods to ensure vibration levels would be below 0.12 ppv in/sec, the potential for damage to the existing Green Hotel Apartments building and the 84 South Fair Oaks Avenue structure;
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Green Hotel Apartments Final EIR
- Specific measures to be taken during construction to ensure the specified vibration level limits are not exceeded; and
- A monitoring plan to be implemented during demolition and construction that includes post-construction and post-demolition surveys of the existing Green Hotel Apartments building and the 84 South Fair Oaks Avenue structure. - Examples of measures that may be specified for implementation during demolition or construction include, but are not limited to
o Prohibition of certain types of impact equipment;
o Requirement for lighter tracked or wheeled equipment; o Specifying demolition by non-impact methods, such as sawing concrete; o Phasing operations to avoid simultaneous vibration sources; and o Installation of vibration measuring devices to guide decision making for subsequent activities.

Mitigation Measure MM-NOISE-5, on page 3.5-22 of the Draft EIR, is revised to read as follows:

MM-NOISE-5: Post-Construction Survey and Documentation
To the satisfaction of the City of Pasadena, at the conclusion of vibration-causing activities, in the unanticipated event of discovery of vibration-caused damage, the Structural Engineer and the Project Historical Architect shall document any damage to the existing Green Hotel Apartments building and the 84 South Fair Oaks Avenue structure caused by construction of the project and shall recommend necessary repairs. The project applicant shall be responsible for any repairs associated with vibration-caused damage as a result of construction of the project. Any such repairs shall be undertaken and completed as required to conform to the Secretary of the Interior’s Standards for the Treatment of Historic Properties (36 Code of Federal Regulations 68), and shall apply the California Historical Building Code (California Code of Regulations, Title 24, Part 8) and other applicable codes.

The Residual Impacts summary paragraph on page 3.5-22 of the Draft EIR is revised to read as follows:

Mitigation Measure NOSIE-4 is a performance standard requirement which would ensure that vibration levels at the existing Green Hotel Apartments building and the 84 South Fair Oaks Avenue structure do not exceed 0.12 ppv in/sec or an alternative threshold as determined by a professional structural engineer. With implementation of mitigation measures identified above, groundborne vibration impacts from construction and operation of the proposed project would be less than significant.

Section 3.6
Transportation and Circulation
The last bullet on page 3.6-21 of the Draft EIR is updated as follows:

Section 2  Corrections and Additions
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Green Hotel Apartments Final EIR
 Dayton Street between Fair Oaks Avenue and Raymond Avenue: 313 626 daily trips The last row on Table 3.6-10. Roadway Segment Average Daily Traffic Analysis – Existing (2013) Conditions, on page 3.6-43 of the Draft EIR is updated as follows:

Dayton St. between Fair Oaks Ave.
and Raymond Ave.
883 313 626 35.4 70.9 Soft measures required; Extensive physical improvements may be
required; Project alternatives may
be considered
The text in the paragraph following Table 3.6-10 on page 3.6-43 of the Draft EIR is updated as follows:

As shown in Table 3.6-10, implementation of the proposed project would result in a 0.8 percent increase in daily traffic on Fair Oaks Avenue between Green Street and Dayton Street, a 2.7 percent increase on Raymond Avenue between Green Street and Dayton Street, a 1.6 percent increase on Raymond Avenue between Dayton Street and Del Mar Boulevard, and a

35.4 70.9 percent increase on Dayton Street between Fair Oaks Avenue and Raymond Avenue.

According to the City’s street segment thresholds (Table 3.6-5), the percent increase associated with the Dayton Street roadway segment between Fair Oaks Avenue and Raymond Avenue would be subject to “soft” measures, extensive physical improvements may be required, and alternatives to the project may be considered. The Raymond Avenue roadway segment between Green Street and Dayton Street would be subject to “soft” measures, which are implemented as conditions of approval and are typically the payment of fees to fund overall general transportation and circulation improvements in the project vicinity. However, as determined by City DOT, there are no feasible mitigation measures available to reduce street segment impacts to below levels of significance along Dayton Street between Fair Oaks Avenue and Raymond Avenue. Therefore, significant and unavoidable segment impacts will remain along this segment. The remaining roadway segments are subject to staff review and conditions and with staff approval impacts would be less than significant.

Section 4
Alternatives
The text in Section 4.4.4, Smaller Scale Alternative, on page 4-5 of the Draft EIR is updated as follows:

The Smaller Scale Alternative would involve the construction of up to 1,080 square feet of retail/commercial with no residential units or up to six residential units with 80 square feet of retail. The Smaller Scale Alternative would involve the construction of a 13 residential unit building with no ground-floor commercial. The intent of this alternative would be to build a project that would result in less than significant traffic impacts to the Dayton Street segment between Fair Oaks Avenue and Raymond Avenue. Implementation of such an alternative, however, is determined to be infeasible because the cost of constructing only 1,080 square feet of retail with no residential units, or the combination of 13 six residential units with 80 square feet of retail/commercial is such that returns on investments made into the project would not be realized; as such, this alternative is financially infeasible.

The text in the last two paragraphs on page 4-13 of the Draft EIR is updated as follows:

As discussed in Section 3.6, Transportation and Traffic, in this EIR, one significant and unavoidable impact would result from implementation of the proposed project. As identified Section 2  Corrections and Additions
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in the Traffic Impact Study prepared for the project, the proposed project had a 35.4 70.9 percent segment impact on Dayton Street between Fair Oaks Avenue and Raymond Avenue.

This 35.4 70.9 percent segment impact would occur because the Dayton Street segment between Fair Oaks Avenue and Raymond Avenue currently receives approximately 883 average daily trips; implementation of the proposed project would result in approximately 313 new trips on this Dayton Street segment, thereby resulting in a 35.4 70.9 percent increase in the number of vehicles traveling along Dayton Street between Fair Oaks Avenue and Raymond Avenue on any given day.

Table 4-6 in Section 4.6 of the Draft EIR is updated beyond the changes showing in Section 4.6 of the Recirculated Draft EIR to clarify that the indication of 239 average daily trips occurring on Dayton Street between Fair Oak Avenue/Raymond Avenue is replaced by the value of 479 (i.e., the 239 should have been shown in stikeout text in the Recirculated DEIR) as follows:

Table 4-6 Reduced Height Alternative – Traffic Generation Street Segment
Existing
Traffic
Daily
Project
Traffic
Percent (%)
Increase
Fair Oaks Avenue between Green Street/Dayton Street 20,690 132 0.6 Raymond Avenue between Green Street/Dayton Street 6,879 144 2.1 Raymond Avenue between Dayton Street/Del Mar Avenue 7,664 96 1.3 Dayton Street between Fair Oaks Avenue/Raymond Avenue 883 239 479 27.1 54.2 Section 5.2
Significant Unavoidable Impacts
The second sentence in Section 5.2 of the Draft EIR is updated beyond the changes showing in Section

5.2 of the Recirculated Draft EIR as follows:

The proposed project would add 313 626 daily trips to this intersection segment, thereby resulting in a significant and unavoidable traffic impact to this street segment to do due to the increased number of vehicles traveling on this segment.

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Section 3
Comments and Responses
According to the California Environmental Quality Act (CEQA) Guidelines, Section 15132, the Final EIR shall consist of the following items: 1) the Draft EIR or a revision of the Draft EIR; 2) comments and recommendations received on the Draft EIR either verbatim or in summary; 3) a list of persons, organizations and public agencies commenting on the Draft EIR; 4) responses of the Lead Agency to significant environmental points raised in the review and consultation process; and 5) any other information added by the Lead Agency.

3.1 Background

3.1.1 Draft EIR Published January 24, 2014
The Draft EIR for the Green Hotel Apartment Project was published on January 24, 2014, and was circulated for a 45‐day public comment period in accordance with CEQA Guidelines Section 15088.5.

Public notice was mailed to property owners within 500 feet of the project site and to all individuals requesting notice for this and all other EIRs within the City of Pasadena, including all speakers at the scoping meetings that were held for this EIR on April 8 and 15, 2013. Public notice was also posted at the office of the Los Angeles County Clerk and was sent to the State Clearinghouse (a division of the Governor’s Office of Planning and Research). The 45-day review period provided interested public agencies, groups, and individuals the opportunity to comment on the contents and accuracy of the document. Copies of the Draft EIR were made available to the public at the City Hall Planning Division counter, the Pasadena Library, and posted online. The public comment period for the Draft EIR ended on March 11, 2014. In addition to written comments received during the 45-day review period, oral comments were taken at the Design Commission public hearing held on March 11, 2014. Public comments on the Draft EIR received by the City are included in this Final EIR, and responses to those comments have been prepared to address the concerns raised.

A total of six comment letters were received on the Draft EIR. A list of commenters is provided below.

The comment letters have been numbered and organized into the following categories:
 Public Agencies;
 Private and Local Organizations; and
 Individuals.

The original bracketed comment letters are provided followed by a numbered response to each bracketed comment. Individual comments within each letter are numbered and the response is given a matching number. Additionally, a summary of comments occurring at the City of Pasadena Design Commission public hearing of March 11, 2014, and responses to those comments, are included herein.

For certain issue areas where a number of similar type comments were received, such as related to historic resources impacts, view impacts, and project alternatives, topical responses are provided at the beginning to the responses to comments section and relevant individual comments are referred to the applicable topical response.

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Where responses to comments on the Draft EIR result in changes to the Draft EIR, these changes are noted and the resulting changes are identified in Section 2, Corrections and Additions, of this Final EIR document.

3.1.2 Recirculated Draft EIR Published January 20, 2015 Subsequent to the publication and circulation for public review of the Draft EIR, City of Pasadena Planning and Community Development staff determined that important new information regarding the Draft EIR analysis of the Green Hotel Apartments Project had become available, which warranted the publication and distribution of a Recirculated Draft EIR for the project. The important new information presented in the Recirculated Draft EIR pertained to the proposed project’s traffic impact on Dayton Street between Fair Oaks Avenue and Raymond Avenue. More specifically, the important new information consisted of a correction to the amount of project-related trips indicated in the Draft EIR as occurring on Dayton Street. That correction resulted in an increase in the severity of the significant traffic impact on Dayton Street that was previously disclosed in the Draft EIR, and also required certain revisions to two of the alternatives in the Draft EIR, as related to traffic impacts on Dayton Street. No other aspects of the original Draft EIR, including the project description, environmental setting, impacts, mitigation measures, and alternatives, have materially changed. As such, consistent with Section 15088.5 of the California Environmental Quality Act (CEQA) Guidelines, the Recirculated Draft EIR only included the traffic-related information that was updated/revised from the Draft EIR.

Similar to the Draft EIR process described above, the Recirculated Draft EIR was circulated for a 45-day review period to provide interested public agencies, groups, and individuals the opportunity to comment on the contents and accuracy of the document. Copies of the Recirculated Draft EIR were made available to the public on January 20, 2015 at the Pasadena Permit Center Design & Historic Preservation Division counter, the Pasadena Central Library, and posted online. The public comment period for the Recirculated Draft EIR ended on March 5, 2015. In addition to written comments received during the 45-day review period, oral comments were taken at a Design Commission public hearing held on February 24, 2015. Public comments on the Recirculated Draft EIR received by the City are included in this Final EIR, along with the aforementioned comments on the Draft EIR, and responses to those comments have been prepared to address the concerns raised.

A total of two comment letters were received on the Recirculated Draft EIR. A list of commenters is provided below. The comment letters have been numbered and organized into the following categories:1
 Public Agencies; and
 Private and Local Organizations.

Similar to above for the Draft EIR, the original bracketed comment letters are provided followed by a numbered response to each bracketed comment. Individual comments within each letter are numbered and the response is given a matching number. Additionally, a summary of comments occurring at the City of Pasadena Design Commission public hearing of February 24, 2015, and responses to those comments, are included herein. Unlike the Draft EIR, there were no groups of

1 Unlike the Draft EIR, no comment letters were received on the Recirculated Draft EIR from individuals; hence, that category is not listed relative to the Recirculated Draft EIR.

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comments on the Recirculated Draft EIR that warranted the preparation of topical responses; hence, only individual written responses to comments on the Recirculated Draft EIR are provided herein.

It should also be noted that only one of the responses to comments on the Recirculated Draft EIR requires changes to the original Draft EIR beyond those changes already reflected in underline or strikeout text in the Recirculated Draft EIR. That single additional change is identified in Section 2, Corrections and Additions, of this Final EIR document, along with the changes to the Draft EIR that are associated with comments received on the Draft EIR.

3.2 List of Commenters

3.2.1 List of Public Agencies and Private Parties
Commenting on the Draft EIR
The following agencies, organizations and individuals provided written comments on the Draft EIR:

Public Agencies
Letter No. 1 County Sanitation Districts of Los Angeles County (March 11, 2014) Private and Local Organizations
Letter No. 2 Pasadena Heritage (March 11, 2014)
Letter No. 3 Castle Green Homeowners Association (March 8 and 9, 2014) Letter No. 4 Chatten-Brown & Carstens on behalf of Castle Green Homeowners Association (March 10, 2014)
Individuals
Letter No. 5 Ann Scheid (March 11, 2014)
Letter No. 6 Kelly Sutherlin McLeod (March 11, 2014)

3.2.2 List of Public Agencies and Private Parties
Commenting on the Recirculated Draft EIR
The following agency and organization provided written comments on the Recirculated Draft EIR:

Public Agencies
Letter No. 7 City of San Marino (January 26, 2015)
Private and Local Organizations
Letter No. 8 Castle Green Homeowners Association (March 2, 2015)

3.3 Responses to Comments

3.3.1 Topical Responses to Comments on the Draft EIR
Several similar type comments on the Draft EIR were received regarding potential impacts to existing historic resources near the project site, viewshed impacts, and project alternatives. The following topical responses provide an overall response for each of those issue areas, to which the relevant comments are referred in the individual responses to comments section that follows.

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TR-CR-1 Potential Impacts to Historic Resources
Comments on the Draft EIR were received relative to the proposed project meeting the “Secretary of the Interior’s Standards for Rehabilitation & Guidelines for Rehabilitating Historic Buildings,” in The Secretary of the Interior’s Standards for the Treatment of Historic Properties, by Kay D. Weeks and Anne E. Grimmer, National Park Service, Washington, D.C., 1995.

The Secretary of the Interior’s Standards for the Treatment of Historic Properties (including Standards for Rehabilitation) are codified in 36 CFR §§ 68.3 and 67.7 and are only directly applicable to “areas under the jurisdiction of the National Park Service.” (See 36 CFR § 1.1) The intent of these standards is to “set forth standards for the treatment of historic properties containing standards for preservation, rehabilitation, restoration and reconstruction. These standards apply to all proposed grant-in-aid development projects assisted through the National Historic Preservation Fund. 36 CFR § 67 focuses on ‘certified historic structures’ as defined by IRS Code 1986. Those regulations are used in the Preservation Tax Incentives Program…” (36 CFR § 68.1) As noted in the Secretary of the Interior’s Guidelines for Preserving, Rehabilitating Restoring & Reconstructing Historic Buildings: “The Secretary of the Interior’s Standards for Treatment of Historic Properties are only regulatory for projects receiving federal grant-in-aid funds otherwise, the Standards and Guidelines are intended only as general guidance for work on any historic building…”(emphasis added.) Further, “[t]he Standards are neither technical nor prescriptive...” These regulations and the associated guidelines make it clear that even when these standards are applicable to a project, they do not require precise conformity with each and every subsection of the standards. As noted in the Guidelines and the regulations themselves, the standards provide various “options” and are “depend[ent] upon the property’s significance, existing physical condition, the extent of documentation” and must “consider “the economic and technical feasibility of each project.” (Secretary of the Interior’s Guidelines, page 19; 36 CFR § 68.3.) As also noted in the associated Guidelines, “latitude is given in the Standards for Rehabilitation and Guidelines for Rehabilitation to replace extensively deteriorated, damaged, or missing features using either traditional or substitute materials.” These Guidelines and Regulations are not part of the CEQA process. CEQA requires analysis of physical impacts to the environment, not a regulatory consistency analysis. As discussed in case law “an inconsistency between a project and other land use controls does not in itself mandate a finding of significance.” (Lighthouse Field Beach Rescue v. City of Santa Cruz (2005) 131 Cal.App.4th 1170.) A significant effect must be correlated to change in the “existing physical conditions.” (CEQA Guidelines Section 15126.2.) “The determination of whether a project may have a significant effect on the environment calls for careful judgment on the part of the public agency involved, based to the extent possible on scientific and factual data. An iron clad definition of significant effect is not always possible because the significance of an activity may vary with the setting.” 14 Cal. Code Regs. § 15064(b).

Therefore, “a lead agency has the discretion to determine whether to classify an impact described in an EIR as ‘significant,’ depending on the nature of the area affected.” Mira Mar Mobile Community v. City of Oceanside (2004) 119 Cal.App.4th 477. The only relationship of the Secretary of the Interior Standards to the CEQA process are discussed under CEQA Guidelines Section 15064.5(b)(3):
“Generally, a project that follows the Secretary of the Interior's Standards for the Treatment of Historic Properties with Guidelines for Preserving, Rehabilitating, Restoring, and Reconstructing Historic Buildings or the Secretary of the Interior's Standards for Rehabilitation and Guidelines for Rehabilitating Historic Buildings (1995), Weeks and Grimmer, shall be considered as mitigated to a level of less than a significant impact on the historical resource.” (See also CEQA Guidelines Section 15126.4.) Even in this instance the CEQA Guidelines do not define compliance with the Secretary of the Interior's Standards as the exclusive method of mitigation. While consistency analysis is not Section 3  Comments and Responses
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required under CEQA, projects such as this undergoing Design Review under Pasadena Municipal Code Section 17.61.030.K(2) must be found to be consistent with the Secretary of the Interiors Standards for the Treatment of Historic Properties prior to approval of Design Review. This finding, however, does not need to be made in the CEQA environmental analysis.

Standard 9 of the Secretary of the Interior’s Standards reads, in part, that “related new construction will not destroy historic materials, features, and spatial relationships that characterize the property and will be compatible with the historic materials, features, size, scale and proportion, and massing to protect the integrity of the property and its environment.” The related new construction associated with the currently proposed project does not destroy historic materials and features because it is apart from, and does not touch or intervene in, any historic buildings on the adjacent properties. As documented in the Draft EIR, specifically in Section 3.3 and Appendices D and E (i.e., cultural resources technical report and tree aging report, respectively), the existing spaces and plants on the project property were found not to be significant character-defining features, and do not contribute to the adjacent historic resources. The documentation, analysis, and conclusions in the cultural resources technical report demonstrate that there are two trees that may date from the period of significance of the historic property, but the open space and its features (i.e., landscaping) do not retain integrity as a contributing part of the site. The open space was similar to the existing condition by 1950, and was a parking lot when the property was listed on the National Register of Historic Places.

The most significant spatial relationships of the adjacent historic resources (i.e., Castle Green and the existing Green Hotel Apartments) are its facades on the public rights of way (Raymond Avenue, Green Street, and Fair Oaks Avenue), and facing south to De Lacey Avenue and Central Park. The addition of the proposed building does not “destroy” these spatial relationships. There is no impact on the street-facing facades on Raymond Avenue, Green Street, or Fair Oaks Avenue. The west end of the south facade of the Green Hotel Apartments building would be partially blocked from some points of view at the south and west, although the extent of such view impacts would be limited by the fact that areas west of the project site are highly developed and predominantly occupied by multi-story buildings that already block views of the site, and the areas south of the site include Central Park, with numerous large trees, and existing development adjacent to the park, all of which limits views of the project site. The footprint of the proposed building is distant from the east side of the Castle Green, and does not touch the west end of the south wall of the Green Hotel (i.e., the existing Green Hotel Apartments building). In circumnavigating the perimeter of the adjacent historic property and the project site, all of the facades of the historic buildings remain open to view from a public right-of-way, and from Central Park. Views of the west bays of the existing Green Hotel Apartments would be obstructed. However, those west bays would still be viewable obliquely from the public right-of-way.

No part of the existing buildings on the block would be obscured by the proposed project except for the west end of the south façade of the Hotel Green (existing Green Hotel Apartments), and that part of the facade would remain visible from the Fair Oaks Avenue sidewalk and from points on the project site. The existing city block, relationships of buildings to the streets, relationships of buildings to the remaining historic open space fronting Raymond Avenue on the adjacent historic property (Castle Green), and relationships to Central Park are not destroyed; the configuration of the proposed project causes little change to character-defining spatial relationships.

Preservation Brief 14, New Exterior Additions to Historic Buildings: Preservation Concerns,” by Anne E. Grimmer and Kay D. Weeks, the National Park Service, Washington, D.C., 2010, addresses Section 3  Comments and Responses
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concerns regarding additions to historic buildings. Although the proposed project is a stand-alone building and not an addition, the principals and guidance provided in Preservation Brief 14 are appropriate for related new construction adjacent to historic buildings and located within historic districts.

Preservation Brief 14 reads, in part, that “most historic districts or neighborhoods are listed in the National Register of Historic Places for their significance within a particular time frame. This period of significance of historic districts as well as individually-listed properties may sometimes lead to a misunderstanding that inclusion in the National Register may prohibit any physical change outside of a certain historical period—particularly in the form of exterior additions. National Register listing does not mean that a building or district is frozen in time and that no change can be made without compromising the historical significance. It does mean, however, that a new addition to a historic building should preserve its historic character.” This guidance is in keeping with the Secretary of the Interior’s Standard 9 which governs the design of additions and related new construction to historic buildings and requires additions to avoid destroying character-defining historic materials, features and spatial relationships. It also requires related new construction to be compatible with, yet differentiated from, the historic resource. It is clear that Standard 9 and the guidance for Standard 9 are for the purpose of assisting in the appropriate design of additions to historic buildings and infill within historic districts, and not in disallowing such additions.

Preservation Brief 14 goes on to state that “a new addition should always be subordinate to the historic building; it should not compete in size, scale or design with the historic building. An addition that bears no relationship to the proportions and massing of the historic building—in other words, one that overpowers the historic form and changes the scale will usually compromise the historic character as well. The appropriate size for a new addition varies from building to building; it could never be stated in a square or cubic footage ratio, but the historic building's existing proportions, site, and setting can help set some general parameters for enlargement.” Preservation Brief 14 also includes photographs and illustrations of numerous examples of compatible new construction that are attached to or touching historic buildings and that are as tall or are taller than the historic building.

There is no universal, objective set of criteria that will define compatibility and subordination.

In accordance with Preservation Brief 14 and Standard 9, the proposed new building recalls the existing historic buildings on the block in general massing, volume and relationship to the street but with a smaller footprint and slightly reduced height. The proposed building is nine feet shorter than the adjacent Hotel Green, and placed as far west as possible, away from the Castle Green’s west façade.

The lower height and smaller footprint ensure that the new building would be subordinate to the adjacent historic buildings and sited so as to leave exterior facades almost as visible on all sides as they are now, with the exception of views from due west and south along Fair Oaks Avenue. See further discussion of views in Topical Response TR-AES-1.

Preservation Brief 14 also encourages new construction on secondary or rear facades, stating that “constructing the new addition on a secondary side or rear elevation—in addition to material preservation—will also preserve the historic character… because a secondary elevation is usually simpler and less distinctive, the addition will have less of a physical and visual impact on the historic building. Such placement will help to preserve the building's historic form and relationship to its site and setting.” While the west facing façade of the Castle Green and south facing façade of the Hotel Green were not intended to be rear facades, the simple detailing of these facades is secondary to the more elaborately articulated and publicly oriented facades facing Green Street and Section 3  Comments and Responses
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Raymond Avenue. Placement of the new building at the southwest corner of the property is, therefore, the most appropriate location to preserve the historic character of the adjacent historic resources.

Preservation Brief 14 states that an addition should not fill a “planned void on a highly-visible elevation (such as a U-shaped plan…).” The existing “void” that the proposed project would fill was not intentionally planned as open space. Instead, the original development scheme included an attached west wing that would have occupied the general location of the proposed project. This unbuilt historic scheme is not a significant condition that can be restored, but it does demonstrate that a compatible infill building in the originally proposed location would not destroy intentionally planned spatial characteristics of the existing block. Rather, the project would reinforce the originally planned spatial characteristics of the Hotel Green complex.

As detailed in the Design Process Memorandum, dated August 1, 2014, and included as Attachment 1 to this Final EIR, the project applicant worked closely with historic architects Architectural Resources Group, Inc. to develop a design for the proposed project that most closely matches the footprint for the originally planned Fair Oaks Avenue frontage of the Hotel Green (i.e., existing Green Hotel Apartments). When it was first proposed in 1902, it was conceived as an L-shaped block that would span the Green Street as well as the Fair Oaks Avenue frontage. However, only the Green Street block was completed. The current proposed project would place a new apartment building in the general configuration of the unrealized Fair Oaks Avenue block that hotel owner Colonel George Gill Green proposed in 1902.

In order to adhere as closely as possible to Col. Green’s intentions, historic illustrations and newspaper articles were referenced to determine the appropriate height, massing, design and placement of the newly proposed building. The height of the proposed Fair Oaks block was six stories, consistent with the other blocks of the hotel and equal to the height of the Castle Green/West Annex so as to balance it visually. The first floor of the building was proposed to meet the sidewalk on Fair Oaks Avenue, with a small setback on Dayton Street to the south. The project applicant also commissioned a professional surveyor to determine the measurements of the existing buildings so that the relative heights of the historic buildings and the proposed building could be accurately compared. Having accurate figures for the size of the historic buildings was necessary so that the discussion of relative heights could have a factual basis. Additionally, the project was designed to preserve as much as feasible of the width of the garden as a buffer between the new building and the Castle Green, as well as to maintain light and views for the south-facing apartments in the Hotel Green.

The proposed Project was modified multiple times, with the unit count reduced from 68 to 64 units, the unit mix adjusted to further reduce the volume, and the total gross square footage reduced from 103,350 square feet (in 2008) to 75,770 square feet (in 2014).

Exterior materials and finishes, fenestration and detailing for the proposed new building were not analyzed relative to design, compatibility, and differentiation with respect to adjacent historic resources. These are building design issues that are required to be reviewed in the project’s Design Review process. Pursuant to Pasadena Zoning Code Section 17.61.030, the Design Commission may require changes to the preliminary design of a building that has received land use entitlements with regard to “density, height, open space, parking or loading, and sign requirements, as long as the conditions are not more restrictive than those prescribed by applicable zoning district regulations or a valid Adjustment Permit, Conditional Use Permit, …or other legislative or zoning entitlements.” (Pasadena Municipal Code (“PMC”), Title 17, § 17.61.030.I(5)(a)). The Design Commission cannot approve the final design of the project unless it can make all of the following findings: (1) the design is Section 3  Comments and Responses
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consistent with the purposes of the City’s design review chapter, and (2) the design is consistent with the Central District Design Guidelines. In addition, for alteration to a designated or qualifying historic resource in the Central District, a finding of consistency with the Secretary’s Standards must also be made. As a result of these finding requirements and the role of the Design Commission as dictated by the PMC, any such changes necessary to enable such findings must already be part of the project design at that later point. The City’s process of analyzing the potential environmental effects of a project to the preliminary level of design review generally known at the time of initial land use approval consideration does not leave to Design Review a duty to mitigate any impacts. Instead, the City’s process requires the Design Commission to ensure the continued integrity of the previously adopted environmental and land use analysis through the required design review findings, which ensure that further design iterations do not create new significant effects, and to require that the project design continue to be revised until those findings can be made.

Secretary of the Interior’s Standard 10 reads: “New additions and adjacent or related new construction will be undertaken in such a manner that, if removed in the future, the essential form and integrity of the historic property and its environment would be unimpaired.” The proposed project easily meets Standard 10 because if the proposed project were constructed, per the project description, and subsequently all of that work were demolished, the existing adjacent historic property will remain intact and untouched.

CEQA Guidelines state that a “substantial adverse change in the significance of an historical resource means that the physical demolition, destruction, relocation, or alteration of the resource or its immediate surroundings such that the significance of an historical resource would be materially impaired.” If the proposed project were constructed, the historic buildings on site, and adjacent, would retain integrity. Even with changes to views of the Hotel Green and Castle Green, those buildings are not physically changed, and their visibility from the streets that surround them as well as from Central Park is not a substantial adverse change; the property continues to convey its significance through its materials and features, and through its visual relationship to the site and setting.

Aside from analyses of whether or not the project meets the Secretary of the Interior’s Standards for Rehabilitation, the National Register property retains its eligibility for the National Register of Historic Places and for the California Register of Historical Resources. This threshold is important in concluding that there is no substantial adverse change to the cultural resource. No impact has been proposed or demonstrated that would reduce the integrity of the Hotel Green and Castle Green such that the property is no longer eligible for designation as a historic landmark. The features that would be removed from the project site – landscaping, paving, fencing and a billboard – are not historic and their removal would therefore not result in substantial adverse change to a historic resource.

TR-AES-1 Potential View Impacts
Comments on the Draft EIR were received relative to the potential view impacts of the proposed project and the analysis conclusion that such impacts would be less than significant. The following expands upon the methodology explained in the Draft EIR and the basis of the analysis conclusions.

As described in Section 3.1.4 of the Draft EIR, the assessment of visual and aesthetic impacts involves qualitative analysis that is inherently subjective in nature. Different viewers react to viewsheds and aesthetic conditions differently. This evaluation measures the existing visual resources and how implementation of the proposed project would alter those resources, thereby analyzing the nature of Section 3  Comments and Responses
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the anticipated changes. The project site was observed and photographically documented, as was the surrounding area, to assist in the analysis.

Photosimulations were prepared in order to provide the Draft EIR reader with a general understanding of how the existing appearance of the project site, as viewed from various locations nearby, would change with project implementation. As shown in Figure 3.1-3 on page 3.1-13 of the Draft EIR, the four vantage points selected for the visual simulations represent locations in close proximity to the site, where the visibility of project development would be very prominent. The associated visual simulations presented in Figures 3.1-4, 3.1-5, 3.1-6, and 3.1-11 in the Draft EIR provide a conservative, arguably worst-case, disclosure of project impacts from those four vantage points close to the project site, but are representative of the overall visual impacts of the project. The analysis in Section 3.1 of the Draft EIR includes consideration of visual/aesthetic impacts from other locations in the general vicinity of the project site, such as those shown in Figures 3.1-7 through 3.1-10 and 3.1-13, that also represent the fact that project implementation would not obstruct or modify views from several other nearby locations.

Several comments received on the Draft EIR indicated that view impacts from other locations not addressed in the Draft EIR should be evaluated, including additional views from within Central Park south of the site and additional views from west of the site, such as from the former Ambassador West campus. In response to such comments, additional vantage points were evaluated in conjunction with preparation of the Final EIR. Figures 3.1-15 through 3.1-21, presented on the following pages, show the visual impacts of the project as viewed from those additional vantage points, which are described below.

Figure 3.1-15 shows the viewpoint locations and direction of views for the additional vantage points considered in the Central Park area south of the project site. Of note is the location and density of mature trees within the park, which substantially screens and limits northward views of the project site and adjacent Castle Green and existing Green Hotel Apartments.

Figure 3.1-16 presents before and after views of the project site from Vantage Point 5, and shows that, based on the north-south axis of the proposed building, much of the existing Green Hotel Apartments building would still be visible from that location.

Figure 3.1-17 presents before and after views of the project site from Vantage Point 6, and, similar to Vantage Point 5, indicates that the orientation of the proposed building and 158-foot separation between the proposed building and Castle Green would maintain a wide view corridor towards the existing Green Hotel Apartments building and views of Castle Green and existing vegetation immediately west of Castle Green outside the project site would be unobstructed by the project.

Figure 3.1-18 presents before and after views of the project site from Vantage Point 7, and indicates that as one moves southward, deeper into Central Park, the visibility of the site and adjacent existing structures becomes much more limited, being obscured and dominated by the trees and landscaping within the park.

Figure 3.1-19 presents before and after views of the project site from Vantage Point 8. Similar to above, the farther south one moves into Central Park, the more limited views toward the project site become, with only a small portion of the upper story building elements being visible from this location.

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Figure 3.1-20 shows the viewpoint location and direction of views for the additional vantage point at the eastern edge of the former Ambassador West campus. Of note is the amount of intervening visual obstructions between this vantage point and the project site, including mature landscaping along the edge of the vantage point site and along the nearby freeway, and the many multi-story structures west of the project site. As shown in Figure 3.1-21, the visibility of the project building from Vantage Point 9 would be minimal (and, in actuality, would likely be less than shown due to the intervening natural haze that occurs over distance, as evidenced by the appearance of the existing buildings in the background).

The additional evaluation of view impacts provided above further supports the Draft EIR conclusion that while certain existing views immediate to the project site would be altered by project development, the existing view characteristics of the overall project vicinity would not substantially change and the view impacts of the project would be less than significant.

Please also see Topical Response TR-CR-1 above regarding how and why impacts of views towards Castle Green and the existing Green Hotel Apartments do not constitute a significant impact on historic resources.

TR-ALT-1 Project Alternatives
Comments on the Draft EIR were received regarding project alternatives, particularly in regards to the range of alternatives considered in the Draft EIR, and whether an additional reduced size alternative should be considered, including as related to the significant traffic impact on Dayton Street.

Range of Alternatives
As indicated in Section 4.1 of the Draft EIR, Section 15126.6 of the California Environmental Quality Act (CEQA) Guidelines requires an environmental impact report (EIR) to describe a range of reasonable alternatives to the project, or to the location of the project, “which would feasibly attain most of the basic objectives of the project but would avoid or substantially lessen any of the significant effects of the project, and evaluate the comparable merits of the alternatives.” The analysis of alternatives shall focus on alternatives “which are capable of avoiding or substantially lessening any significant effects of the project, even if these alternatives would impede to some degree the attainment of project objectives, or would be more costly.” Six alternatives were considered for the proposed project, four of which were determined to be infeasible, as described in Section 4.4 of the Draft EIR, and two that were evaluated in Section 4.6 of the Draft EIR. The four alternatives determined to be infeasible are discussed in the Draft EIR at pp. 4-3 to 4-5, and included:

Figure 3.1-15
Vantage Point Locations – Vantage Points 5 through 8
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Figure 3.1-16
Vantage Point 5
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Figure 3.1-17
Vantage Point 6
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Figure 3.1-18
Vantage Point 7
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Figure 3.1-19
Vantage Point 8
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Figure 3.1-20
Vantage Point Locations – Vantage Point 9
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Figure 3.1-21
Vantage Point 9
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Alternate Access Alternative - An alternative where access to parking would be provided along Fair Oaks Avenue was considered. As described on page 4-4 of the Draft EIR, vehicles traveling southbound on Fair Oaks Avenue would not be permitted to turn left into the parking garage, and vehicles exiting the parking garage would not be able to turn left out of the structure.

Left-turns would not be permitted due to the high volume of traffic on Fair Oaks Avenue. As such, southbound traffic would still need to use Dayton Street to access the site by turning left on Green Street, then turning right on Raymond Avenue, Dayton Street, Fair Oaks Avenue, and finally turning right into underground parking, the number of vehicles traveling on the Dayton Street segment between Fair Oaks Avenue and Raymond Avenue would still remain high and would not alleviate the significant impact otherwise associated with the currently proposed project.

Off-Site Parking Alternative - The Off-Site Parking Alternative would involve construction of the residences and ground-floor commercial only; no underground or at-grade parking would be provided at the site. Instead, parking would be provided at one of two nearby parking structures, and residents, tenants and visitors would access the project site on foot. As described on pages 4-4 and 4-5 of the Draft EIR, the ability to provide the 32 parking spaces located off-site under this alternative would require a perpetual lease for the off-site parking from a site within a travel distance of 1,000 feet. Capacity at the two nearby parking structures has been reached and they are therefore not available, thereby making it infeasible to provide off-site parking within 1,000 feet of the project site.

Alternate Site Alternative - The Alternative Site Alternative would involve the construction of the same project, a 64-unit residential project with 5,000 square feet of ground-floor commercial space, on a different site in the project area. The closest vacant site of similar size to the project is located approximately one and one-half blocks to the east at 100 East Green Street, which is at the intersection of East Green Street and Arroyo Parkway. However, the project applicant does not own or have control over other project sites in the project area, and the one vacant site that is located in the vicinity of the project is not for sale or able to be purchased at this time.

Smaller Scale Alternative - The Smaller Scale Alternative would involve the construction of a 6 residential unit building with no ground-floor commercial. Implementation of such an alternative, however, is determined to be infeasible because the cost of constructing 6 residential units is such that returns on investments made into the project would not be realized.2
The two alternatives that were carried forth in the comparative impacts evaluation in Section 4.6 included the following:

No Project Alternative – As required by Section 15126.6(e) of the CEQA Guidelines, the Draft EIR included evaluation of the No Project Alternative. Under the No Project Alternative the existing billboard would remain on site and residents of the existing Green Hotel

2 Although the Draft EIR identified the Smaller Scale Alternative as having 13 residential dwelling units, that number was reduced to 6 residential dwelling units for reasons explained in the Recirculated Draft EIR.

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Apartments would continue to lease parking spaces from the 60-space parking lot. No development of the site would be anticipated.

Reduced Height Alternative - The Reduced Height Alternative would involve the construction of a residential and commercial building on the same footprint as the proposed building; however, the top two floors of the building would be eliminated thereby reducing the overall height of the building to four stories. The resulting project would include 5,000 square feet of ground-floor commercial and 42 residential units with a total of 131 underground parking spaces. Setbacks along Fair Oaks Avenue and Dayton Street, as well as distances from the existing Green Hotel Apartments and Castle Green would be the same as those of the proposed project, as the building would occupy the same footprint.

As such, a range of six alternatives to the currently proposed project were considered in the Draft EIR, including two reduced-size alternatives proposing less development than that of the project.

Additionally, it is important to note that the current project proposal is, in itself, a reduced-size alternative – twice over – compared to the originally proposed project. As indicated in Section 1.3 of the Draft EIR, the project applicant submitted in 2007 an application to the City of Pasadena for a Preapplication Conference for the construction of a six-story, 103,350-square-foot mixed-use project consisting of 8,000 square feet of ground-floor commercial space and 68 residential units with parking for 179 vehicles. The building was a contemporary design that was U-shaped in plan with the building footprint essentially covering the entire lot. In 2010, an application for Preliminary Consultation (the first phase of the design review process) was submitted, which reduced the building to 97,086 square feet and the number of residential units to 64 (commercial space was proposed to remain at 8,000 square feet). The design remained contemporary, although modified from the previous contemporary design. The plan of the building was also modified but essentially remained covering the entire project site with a slightly increased setback from the easterly property line adjacent to the Castle Green. In response to comments provided by both the Design Commission and the public, the design of the proposed project was modified to be more consistent with a latenineteenth-century design for an addition to the Hotel Green that was planned for this parcel. In 2011, a second application for Preliminary Consultation was submitted which further reduced the size of the building to 84,797 square feet, with the commercial space reduced to 7,450 square feet and the number of units remaining at 64. The design was revised to be more traditional in character and to limit the building footprint to the westerly portion of the project site. The current proposal on which the analysis in this EIR is based further reduces the overall building size to 76,980 square feet and the commercial space to 5,000 square feet, while retaining the residential unit count at 64. The previously proposed more traditional building character has been further refined and the building footprint remains limited to the westerly portion of the project site, set back 158 feet from the Castle Green.

Most importantly, the project is evaluated in this EIR based on the thresholds contained in Appendix G of the CEQA Guidelines, and under the guidance of historical experts, as reflected in the historical resources technical report contained in Appendix D of this EIR. This EIR is required to analyze the effects of the project on the environment as proposed, rather than answering the question of what design is the most harmonious.

It should also be noted that aforementioned refinements to the original project proposal and the associated refinements to the building area footprint brought the basic location and layout of the proposed building into alignment with the original development plan envisioned in for the Hotel Green complex in 1903. As shown in Figures 3.3-4 and 3.3-5 on page 3.3-11 of the Draft EIR, the west wing of the Hotel Green was envisioned to reflect a U-shaped building layout, with the current Section 3  Comments and Responses
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Castle Green building being the east side of the U, the existing Green Hotel Apartments building being the north side of the U, and west side of the U being a north-south oriented building along Fair Oaks Avenue. The orientation and location of the currently proposed project building are generally comparable to those of that west segment of the U. The diagram below shows how the earlier project design concept in 2009 was revised to bring the building footprint into closer alignment with the Hotel Green development concept of the early 20th Century.

Several comments on the Draft EIR were received asking for an alternative to be added that reflects the original 1903 development concept for the Hotel Green site when, in fact, the current project proposal already does that by generally matching the site location, height and mass as depicted in historical renderings (see, in particular, Figures 3.3-4 and 3.3-5 on page 3.3-11 of the Draft EIR, which depict the development concept for the Hotel Green U-shaped complex as envisioned in 1903, as compared to Figure 2-11 and 2-12 on pages 2-31 and 2-33 of the Draft EIR depicting the location, height, and mass of the proposed building, which represents the west leg of the U-shaped complex, in relationship to the previously completed legs of the Hotel Green complex).

Some comments on the Draft EIR were received asking for a reduced-size alternative that proposes some combination of reduced dwelling units and reduced retail development that could possibly avoid the significant traffic impact on Dayton Street anticipated to occur with the proposed project. The following table provides a detailed breakdown of potential residential-retail development combinations and the associated traffic impact on Dayton Street, with scenarios in which street segment impacts to Dayton Street would be less than significant. As shown, very few residential units and very little retail development could occur either alone (i.e., all residential with no retail or all retail with no residential) or in combination without triggering a significant traffic impact on Dayton Street.

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Apartment
(DU)
Spec Retail
per 1000 sf
Daily
Project
Traffic
Existing
Traffic
% Increase
At Dayton
Impacted?
(yes/no) Comments
0 1.080 43 883 4.9 no No du and 1,080 sf retail
0 1.000 40 883 4.5 no
0 0.900 36 883 4.1 no
0 0.800 32 883 3.6 no
0 0.700 28 883 3.2 no
0 0.600 24 883 2.7 no
0 0.500 20 883 2.3 no
0 0.400 16 883 1.8 no
0 0.300 12 883 1.4 no
0 0.200 8 883 0.9 no
0 0.100 4 883 0.5 no
0 0.000 0 883 0.0 no
1 0.200 15 883 1.7 no
2 0.300 25 883 2.9 no
3 0.400 36 883 4.1 no
3 0.450 38 883 4.3 no
3 0.475 39 883 4.4 no
3 0.500 40 883 4.5 no
3 0.550 42 883 4.8 no
3 0.560 42 883 4.8 no
3 0.570 43 883 4.9 no
3 0.580 43 883 4.9 no
Impact at 4.9% or less with 3 du &
580 sf retail
4 0.420 43 883 4.9 no
Impact at 4.9% or less with 4 du &
420 sf retail
5 0.250 43 883 4.9 no
Impact at 4.9% or less with 5 du &
250 sf retail
6 0.080 43 883 4.9 no
Impact at 4.9% or less with 6 du & 80
sf retail
The development mixes from 0-6 residential units listed in the table above were dismissed from consideration for the same reason the Smaller Scale Alternative was dismissed from consideration in the Draft EIR—they are not feasible. Based on the above, it is concluded that the Draft EIR for the proposed project has already considered a reasonable range of project alternatives in compliance with CEQA requirements.

The consideration of alternatives must permit informed agency decision-making and informed public participation, and the information presented in this EIR accomplishes that objective. (State CEQA Guidelines, § 15126.6 (a).) An EIR that discusses a range of alternatives to a proposed project does not need to separately discuss reduced sizes of the alternatives analyzed, since construction of a reduced project is inherent in the analysis of the alternative. (City of Rancho Palos Verdes v. City Council (1976) 59 Cal.App.3d 869, 892-893; Sequoyah Hills Homeowners’ Association v. City of Oakland (1993) 23 Cal.App.4th 704, 713-714 [EIR that analyzed one reduced density alternative with a revised site plan Section 3  Comments and Responses
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to mitigate significant effects, and a second further “decreased density alternative,” was not required to analyze yet another alternative that would be an “exercise in futility” because it would not eliminate a significant impact].)
Identification of an off-site alternative is not required. This is the case because, “(A)lthough CEQA requires that an EIR identify alternatives to a project, it does not expressly require a discussion of alternative project locations. (§§ 21001, subd. (g), 21002.1, subd. (a), 21061.) The CEQA Guidelines require a description of ‘a range of reasonable alternatives to the project, or to the location of the project,’ implying that an agency may evaluate on-site alternatives, off-site alternatives, or both. (CEQA Guidelines, § 15126.6, subd. (a).)” (Mira Mar Mobile Community v. City of Oceanside (2004) 119 Cal.App.4th 477, 491, emphasis added.) Further, identification of suitable locations for particular types of uses is a planning decision that is addressed when land use plans such as the General Plan, Central District Specific Plan, and Zoning Code are adopted. Once those policy decisions set appropriate uses for a site, and an application is consistent therewith, one application should not trigger ad hoc reconsideration of plan policies. (Citizens of Goleta Valley v. Board of Supervisors (1990) 52 Cal.3d 553, 573.)

3.3.2 Individual Responses to Comments on the Draft EIR The following provides individual responses to comments received on the Draft EIR published on January 24, 2014, with a copy of each comment letter bracketed to identify the individual comments for which the attendant written responses are then presented.

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Letter No. 1
1 Section 3  Comments and Responses
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Letter No. 1 County Sanitation Districts of Los Angeles County County Sanitation Districts of Los Angeles County
1955 Workman Mill Road
P.O. Box 4998
Whittier, California 90607
Adriana Raza, Customer Service Specialist, Facilities Planning Department March 11, 2014
Responses
Response 1-1
Potential impacts associated with wastewater generation and treatment were addressed in Section II.20, Utilities and Service Systems, of the Initial Study contained in Appendix A of the Draft EIR. Preparation of the Initial Study took into consideration information provided by the County Sanitation Districts of Los Angeles in the correspondence dated April 23, 2013 sent to Mr. Kevin Johnson of the City of Pasadena (i.e., the attachment to the Draft EIR comment letter from County Sanitation Districts). The conclusion of the Initial Study evaluation was that implementation of the proposed project would result in less than significant impacts related to wastewater. The comments and updated information provided in the County Sanitation Districts' comment letter dated March 11, 2013 do not change that conclusion.

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Letter No. 2
1 1
2 3
4 4
5 6
7 8
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Letter No. 2 Pasadena Heritage
Pasadena Heritage
651 South Saint John Avenue
Pasadena, California 91105
Susan N. Mossmann, Executive Director
Jesse Lattig, Preservation Director
March 11, 2014
Responses
Response 2-1
Please see Topical Response TR-AES-1 regarding the approach to, and conclusions of, the visual impacts analysis in the Draft EIR.

The comment is incorrect in stating that, from Vantage Point 1, the proposed project would obstruct virtually all views of the existing Hotel Green Apartments. The viewshed for Vantage Point 1 on page

3.1-14 of the Draft EIR is looking northwest from within Central Park and this vantage point does not include views of the existing Green Hotel Apartments. The primary view from this vantage point is of the Doty Block at the northwest corner of Fair Oaks Avenue and Dayton Street. There is a 158-foot separation between the west side of Castle Green and the east side of the proposed project building.

As such, substantial portions of the existing Hotel Green Apartments would still be visible in views looking north from within Central Park following completion of the proposed project. That is evidenced in the new additional Vantage Points 5 and 6 in Topical Response TR-AES-1.

Regarding the comment about Vantage Point 3, yes, implementation of the proposed project would block the existing view of Castle Green and its tree canopy from that particular view corridor directly west of the project site; however, that single worst-case view impact does not constitute a significant impact for the project overall. As demonstrated throughout the remainder of the discussion in Section3.1 of the Draft EIR and supplemented by the additional visual simulations and responses to comments in this Final EIR, the majority of existing views of Castle Green from other areas surrounding the block would not be affected by implementation of the project.

Relative to the comment about Vantage Point 4, yes, portions of the landscaping visible in that particular worst-case viewshed looking south along Fair Oaks Avenue at Green Street would no longer appear with project implementation, but that alone does not constitute a significant impact for the project overall. Views of the vast majority of the most notable landscaping in the vicinity of the project site, such as that shown in Figures 3.1-7, 3.1-8, 3.1-10, 3.1-12, 3.1-13, and 3.1-14 would be unaffected by project implementation.

Regarding the last portion of the comment, the trees to be removed from the project site are not historic resources, as documented in Section 3.3 and Appendix E of the Draft EIR. Also, it is not necessary to include a mitigation measure requiring compliance with the Tree Protection Ordinance because compliance with existing Code requirements does not constitute mitigation under CEQA. In addition, the project, as proposed, would meet the requirements of the City Trees and Tree Protection Ordinance, as discussed on pages 3.1-26 and 3.1-27 of the Draft EIR.

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Response 2-2
The figures contained in Appendix B of the Draft EIR indicate Project would have no shade impact on the existing Green Hotel Apartments at summer solstice and very limited shade impacts at winter solstice, with exception of mid- to late-afternoon hours. It should also be noted that the proposed project is located in an urbanized area with several existing multi-story buildings that have shading impacts on adjacent structures during different times of year and time of day. Such is the case at the existing Green Hotel Apartments where, as shown in Figures B-10 through B-12, the building is subject to shading impacts from the Castle Green building during morning hours at winter solstice.

Further, while local governments may protect views and provide for light and air through the adoption of height limits, California case law does not recognize a right to air, light or an unobstructed view (Pacifica Homeowners' Assn. v. Wesley Palms Retirement Community (1986) 178 Cal.App.3d 1147, 1152) and the project does not exceed the City’s height limit.

Response 2-3
Individual development projects within Pasadena are evaluated in light of the City’s General Plan, Urban Design Principles, Design Guidelines, and Zoning Ordinance, as appropriate during the applicable entitlement and approval processes. Compliance with the City’s various planning documents and codes is not a mitigation for aesthetics impacts, but rather if potential impacts are identified during the approval processes, including required CEQA review, then project-specific mitigation measures are formulated. In this case, the proposed project would not result in any significant aesthetics impacts, as documented in Section 3.1 of the Draft EIR. Specifically, implementation of the project would not have a substantial adverse effect on a scenic vista, would not substantially degrade the existing visual character or quality of the site and its surroundings, and would not create a new source of substantial light or glare that would adversely affect day or nighttime views in the area. See also the discussion in Topical Response TR-CR-1 regarding the role of the Design Commission in ensuring the continued integrity of the analysis herein through the required design review finding.

Response 2-4
Please see Topical Response TR-CR-1 regarding the Draft EIR analysis of impacts to historic resources.

Response 2-5
The analysis presented in Section 3.5 of the Draft EIR addresses potential vibration impacts to buildings near project site. As indicated on page 3.5-21 of the Draft EIR, the Castle Green building is approximately 75 feet from the project site, and, at this distance, the potential for structural vibration impacts would be less than significant; however, the potential for construction activities to occur closer than 25 feet to the existing Green Hotel Apartment building poses the potential for significant vibration impacts, in which case Mitigation Measures MM-NOISE-4 and MM-NOISE-4 are presented on that page for reducing the potential vibration impact to a level that is less than significant. Because the existing single-story structure that is connected to the southwest portion of the existing Green Hotel Apartments building (i.e., at 84 South Fair Oaks Avenue) would have the same potential for vibration-related impacts as the existing Green Hotel Apartments building, the discussion on pages 3.5-21 and 3.5-22 of the Draft EIR is hereby revised to clarify that fact, as follows:

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However, demolition and construction activities could occur closer than 25 feet to the existing Green Hotel Apartments building and attached single-story structure (i.e., 84 South Fair Oaks Avenue). Based on FTA and Caltrans methodologies, if large bulldozers, loaded trucks, or similar equipment were to operate within 20 feet of the existing Green Hotel Apartments building or the 84 South Fair Oaks Avenue structure, the vibration level could exceed the

0.12 ppv in/sec significance threshold (see Table 3.5-6). Data from testing at one particular site (see Table 11 of Appendix G) indicates the 0.12 ppv in/sec threshold could also be exceeded with some construction equipment at distances greater than 20 feet. Because the exact limits of equipment use, types of equipment to be used, and soil conditions are not known, without implementation of mitigation, vibration generated during demolition and construction of the proposed project could result in a potentially significant impact to the existing Green Hotel Apartments building and the 84 South Fair Oaks Avenue structure. The Castle Green building is approximately 75 feet from the project site; at this distance, the potential for structural vibration impacts would be less than significant.

Because structural damage considerations require limiting vibration levels to 0.12 ppv in/sec or a similar level (as may be established through implementation of Mitigation Measures NOISE-4 and NOISE-5), the perception of vibration by persons in the existing Green Hotel Apartments and the 84 South Fair Oaks Avenue structure would fall within the barely perceptible to distinctly perceptible range. This impact would be less than significant.

Operation of the proposed project involves residential and retail uses, which would not generate groundborne vibration or noise producing activities and impacts would be less than significant.

Mitigation Measures
The following mitigation measures would reduce potentially significant construction impacts to a less than significant level:

MM-NOISE-4: Consult with Structural Engineer and Project Historical Architect Prior to approval of grading plans and/or prior to issuance of demolition, grading and building permits, and to the satisfaction of the City of Pasadena, the applicant shall retain a Professional Structural Engineer with experience in structural vibration analysis and monitoring for historic buildings and a Project Historical Architect as a team to perform the following tasks:
 Review the project plans for demolition and construction;  Survey the project site and the existing Green Hotel Apartments building and the 84 South Fair Oaks Avenue structure, including geological testing, if required; and  Prepare and submit a report to the Director of Planning and Community Development to include, but not be limited to, the following:
- Description of existing conditions at the existing Green Hotel Apartments building and the 84 South Fair Oaks Avenue structure;
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- Vibration level limits based on building conditions, soil conditions, and planned demolition and construction methods to ensure vibration levels would be below 0.12 ppv in/sec, the potential for damage to the existing Green Hotel Apartments building and the 84 South Fair Oaks Avenue structure;
- Specific measures to be taken during construction to ensure the specified vibration level limits are not exceeded; and
- A monitoring plan to be implemented during demolition and construction that includes post-construction and post-demolition surveys of the existing Green Hotel Apartments building and the 84 South Fair Oaks Avenue structure. - Examples of measures that may be specified for implementation during demolition or construction include, but are not limited to:
o Prohibition of certain types of impact equipment;
o Requirement for lighter tracked or wheeled equipment; o Specifying demolition by non-impact methods, such as sawing concrete; o Phasing operations to avoid simultaneous vibration sources; and o Installation of vibration measuring devices to guide decision making for subsequent activities.

MM-NOISE-5: Post-Construction Survey and Documentation
To the satisfaction of the City of Pasadena, at the conclusion of vibration-causing activities, in the unanticipated event of discovery of vibration-caused damage, the Structural Engineer and the Project Historical Architect shall document any damage to the existing Green Hotel Apartments building and the 84 South Fair Oaks Avenue structure and shall recommend necessary repairs. The project applicant shall be responsible for any repairs associated with vibration-caused damage. Repairs shall be undertaken and completed as required to conform to the Secretary of the Interior’s Standards for the Treatment of Historic Properties (36 Code of Federal Regulations 68), and shall apply the California Historical Building Code (California Code of Regulations, Title 24, Part 8) and other applicable codes.

Residual Impacts
Mitigation Measure NOISE-4 is a performance standard requirement which would ensure that vibration levels at the existing Green Hotel Apartments building and the 84 South Fair Oaks Avenue structure do not exceed 0.12 ppv in/sec or an alternative threshold as determined by a professional structural engineer. With implementation of mitigation measures identified above, groundborne vibration impacts from construction and operation of the proposed project would be less than significant.

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Regarding the commenter’s suggestion that the Final EIR include clear and enforceable measures prior to and during construction to prevent potential structural impacts to the historic resources, Mitigation Measure MM-NOISE-4 is included in the EIR for that very purpose. All mitigation measures in the Final EIR will be included in the Mitigation Monitoring and Reporting Program (MMRP) for the project, which will help ensure that the measures are, in fact, implemented. As specified within MM-NOISE-4, there are several provisions for the monitoring of vibration levels during planned demolition construction to ensure that vibration levels remain below the level where damage could occur. It is anticipated that shoring would be used if and where appropriate as determined by the project structural engineer.

Response 2-6
The Alternate Access Alternative was considered that would substitute the project driveway on Dayton Street with a right-turn in, and right-turn out driveway on Fair Oaks Avenue. Vehicles traveling southbound on Fair Oaks Avenue would not be permitted to turn left into the parking garage.

Vehicles exiting the parking garage would not be able to make a left-turn out of the structure. The southbound traffic would still need to use Dayton Street to access the project site by turning left on Green Street, then turning right on Raymond Avenue, right on Dayton Street, right on Fair Oaks Avenue, and finally turning right into the project driveway. The number of vehicles traveling on Dayton Street between Fair Oaks Avenue and Raymond Avenue would still remain significant (approximately 235) and would not reduce the significant traffic impact identified for the proposed project.

Existing traffic volumes on Dayton Street are so low that even the addition of 44 new trips would trigger the impact threshold and result in a significant and unavoidable traffic impact to this street segment. It is estimated that with access on Fair Oaks Avenue, there would be approximately 235 daily vehicle trips added to Dayton Street, as shown in the table below. For this reason, the Alternate Access Alternative was eliminated from further consideration and evaluation in the Draft EIR.

Average Daily Traffic Volumes (ADT) Analysis for Dayton Street Project Driveway on Dayton Street vs. Fair Oaks Avenue
Street Segment
Existing
Traffic
Daily
Project Trips
Percent
Increase
Dayton Street between Fair Oaks Avenue and Raymond Avenue (Project driveway on Dayton Street as proposed)
883 626 70.9%
Dayton Street between Fair Oaks Avenue and Raymond Avenue (Project driveway on Fair Oaks Avenue as indicated in the Alternative Access Alternative)
883 235 26.6%
As a secondary matter, the City’s Fire Department has recommended that the project access be located on Dayton Street to avoid interference with emergency access.

Fair Oaks Avenue access would also result in adverse impacts to pedestrian safety as Fair Oaks Avenue is a major arterial through pedestrian-oriented Old Pasadena and has high pedestrian traffic volumes.

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Response 2-7
The commenter's concurrence with the Draft EIR's conclusion that Alternative 2 is the Environmentally Superior Alternative is so noted. The Design Commission will take into consideration the conclusions of the Draft EIR in their deliberations on the Project.

Response 2-8
Responses are provided for each comment above; adjustments to the Executive Summary are not warranted.

Castle Green Homeowners Association
Green Hotel Apartments DEIR, Executive Summary Table ES-1 Summary of Project Impacts, Conditions of Approval, Mitigation Measures, and Residual Impacts.

March 9, 2014 - PAGE 1 OF 3
March 9, 2014
It should be noted that upon review of the Draft EIR and Table ES-1, it is clear that all impacts have not been investigated, many are missing and some of those identified are not properly and appropriately addressed and analyzed. Mitigation measures are also missing, incomplete or omitted and must be part of a revised EIR. Some mitigation measures identified are not properly and appropriately addressed and analyzed.

AESTHETICS – (general statement).

All “less than significant impact” conclusions need to be revisited.

AESTHETICS – BOX 1.

This contains an incorrect description of the existing Castle Green - it is not a seven story building, but a six story building per City code, per the Fire Department and per the State Historic Building Code Board. This point has been made since the 2008 review, but again the height of the Castle Green is exaggerated. The project elevations fail to delineate this fact, and need revision (as noted in 2013 & 2010). Similar 6 story height for the project is causing many significant impacts, and some that have not been identified in the DEIR.

AESTHETICS – BOX 2.

The existing site description includes landscaped recreational area, with picnic tables and the occasional wedding ceremony, all under the great and large tree canopy. It is also surface parking and contains mature trees.

The project does substantially degrade the existing condition, but not all existing condition impacts are recognized in this Draft, so “less than significant impact” is premature.

AESTHETICS – BOX 3.

Is it possible the concentration of all 639 additional daily car trips around the ‘open area’ of the Project could result in light and glare impacts The headlights in use from evening until morning will certainly illuminate this area unlike anything that exists, yet no study or analysis of this possibility is made.

AESTHETICS – BOX 4.

There are NO buildings presently or to be built adjacent to this site that would cast such shadows onto the two existing historic structures as does the Project. The “explain it away” excuse that it’s in an urban environment does not properly or adequately address this specific condition. However, the loss of daylight and breeze from this Project will result in higher energy use to the existing structures on the block, yet this is not acknowledged or studied in the DIER. This was also brought up in the IS.

AIR QUALITY (general comment).

There is no mention of the significant loss or reduction of existing airflow to the breeze-dependent Castle Green, with units designed for cross-building ventilation. While this may not be the appropriate category to mention this, it is an impact that needs to be studied.

CULTURAL RESOURCES – (general statement)
All “less than significant impact” conclusions need to be revisited.

CULTURAL RESOURCES – BOX 1.

Demolition of the site results in loss of “protected trees,” and likely historic trees. However, in the 6 years of this project, the City and Applicant have failed to study the historic nature of the trees and existing site features. In theory, this is a loss of the structure of nature – the large tree canopy of mostly “protected trees.” Have the tree canopy and/or remaining landscape features “Acquired Significance” per Standard 4? CULTURAL RESOURCES – BOX 2.

It does involve relocation of 5 protected trees, most of which could actually be historic (see BOX 1 comment above). Do trees count as a historic resource?
Letter No. 3
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Green Hotel Apartments DEIR, Executive Summary Table ES-1 Summary of Project Impacts, Conditions of Approval, Mitigation Measures, and Residual Impacts.

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CULTURAL RESOURCES – BOX 3.

Demolition will destroy the characteristic tree canopy. But most dominant feature of the Project is its height. The Project does NOT comply with Standard #9. In saying new construction “shall be compatible,” Standard 9 does not say, imply or characterize the similar height for the Project is compatible with similar existing heights of the existing buildings. It is not. The height issue is inadequately addressed and analyzed in the DEIR. Protecting the historic integrity of the existing Hotel Green buildings is not achieved by duplicating their height. It should also be noted that Alternative 2 expressly reduces height to be more appropriate. This should be taken to heart.

CULTURAL RESOURCES – BOX 4.

This contains the false statement that the new 6-story building would not reduce the integrity of the existing buildings. In fact, the almost equal height of the Project will dominate the entire Fair Oaks street elevation and most views (studied and omitted) of the historic block contrary to the Secretary of Interior Standard requirements.

This is not consistent with Standard #10
That many impacts from the Project are ignored and/or inadequately studied also raises possibilities of conflict.

GREENHOUSE GASES – BOX 1.

With the concentration of all existing trips and the additional 639 daily trips focused within the 6-story walls of the Project and the existing historic structures, excessive exhaust and vehicle gases could negatively affect the new and existing residents facing the single Dayton driveway area. This is not properly or adequately address and analyzed. While stated to not exceed the AQMD’s threshold for “commercial land uses,” how do emissions stack up to the residential land uses that overwhelmingly are predominant at and surround this site? Should this be studied? How can the “less than significant impact” determination be made with this incomplete review? NOISE AND VIBRATION – (general statement).

All “less than significant impact” conclusions need to be revisited. And all noise and vibration mitigation, known or yet to be addressed and analyzed, must apply to all structures on the block – the existing Green Hotel Apartments, the Castle Green and the small one-story Fair Oaks structure.

NOISE AND VIBRATION – BOX 1.

MM Noise-1 Mitigation measure hours fail to take into account the residential nature of this site. Noise-generating construction should be limited to more constrained time periods: either 7:00 AM – 5:00 PM or 8:00 AM to 6:00 PM on Manday-Friday; Saturday time range should be 9:00 AM to 5:00 PM, or limited to only 28 Saturdays at 8:00 AM – 5:00 Pm with scheduled notice to existing residents.

NOISE AND VIBRATION – BOX 2.

The Table states the primary source of noise to the project site is Fair Oaks Avenue traffic. However, this Project generates and concentrates 5-times the exiting ADT traffic on Dayton Street. It also concentrates all additional 639 daily trips and replacement traffic (not adequately addresses trips for the 60 existing spaces and for the existing Castle Green driveway spaces). This extreme increase in concentrated vehicular trips and impacts could result in a substantial permanent increase in ambient noise, and may not be “less than existing ambient noise level ” as this segment states. This is not adequately analyzed to conclude there will “less than significant impact.” Also in this segment, COA Noise-4 must include the Castle Green in noise notification, as in all mitigation measures. MM Noise-3 must also include noise restrictions on continued pool use after 8:00 PM and before 7:00 AM per hours of operation.

NOISE AND VIBRATION – BOX 4.
“The project has the potential to expose the persons and structures to excessive groundborne vibration and groundborne noise levels,” especially given the sensitivity of the surrounding uses. Yet it is considered a “less than significant impact? Mitigation measures must not just be stated, but be studied and analyzed in the DEIR, as this is a significantly sensitive block. Testing of mitigation methods (not just geological testing) prior to demolition work must be part of mitigation measures.
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Historic structure monitoring for all existing structures on the block during construction must be studied and required as part of this report.

The stated mitigation measures (MM Noise-4 and MM Noise 5) exclude the Castle Green, and only protect the existing Green Hotel Apartments. Again, all mitigation measures must equally address the Castle Green along with the existing Green Hotel Apartments.

TRANSPORTATION AND CIRCULATION – (general statement).

All “less than significant impact” conclusions need to be revisited. Serious deficiencies in the traffic Study exist, of which some are noted below.

TRANSPORTATION AND CIRCULATION – BOX 1.

New vehicle trips would constitute a ADT levels on Dayton segment “five times higher than the City’s threshold of a significant impact,” beyond significant yet with no properly or adequately addressed, analyzed or porposed mitigation measure that must be included in this report. This segment further states these beyond significant trips would create “no Mobility Element inconsistencies. It also appears that existing trips affecting Dayton Street may not have been included in all traffic studies. Clearly “no feasible mitigation” is false, as nothing has been studied.

TRANSPORTATION AND CIRCULATION – BOX 2.

This segment is technically correct that at “designated congestion management program street segments or intersections” the impacts won’t be significant. That’s because they are all too far away from the site, and don’t even receive 50 additional trips. But those are the ONLY intersections this segment addresses.

Missing is any meaningful discussion of the Dayton/Fair Oaks and Dayton/Raymond intersections, as both intersections are not properly or adequately addressed or analyzed, nor are mitigation measures studied or analyzed. Both intersections must be studied, and mitigation measure must be investigated as part of this report.

The only mitigation to increased traffic on Dayton Street that is 5-times the City’s threshold of significant impacts is to add a queuing sign opposite the sole project driveway to keep the intersection unblocked. While beyond inadequate for the total of impacts (stated and unstudied), this is not going to prevent blockage of the driveway.

TRANSPORTATION AND CIRCULATION – BOX 3.

Inadequate study and analysis of emergency egress and access on Dayton Street segment preclude the conclusion of “less than significant impact.” The traffic study must include the existing 60 Apartment trip impacts and the existing Castle Green 12 spaces trip impacts on Dayton Street and beyond.

This segment questionably states there will be no impact on pedestrian and bicycle facilities or decrease the safety or performance of such. What does that say for the significantly worse situation created at both Dayton intersections, likely making it more difficult to cross in an east or west direction for pedestrians and bicyclists.

End.
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March 9, 2014
Noted in these Comments are the 11 stated “Areas of Known Controversy” included in DEIR “Executive Summary,” page ES-5. Comments are in ‘bullet points’ below each DEIR point. The Comments are followed by additional similar aspects or “Controversies” of the project mostly not addressed, or not adequately addressed and analyzed in the DEIR, even though many if not all were brought up in the earlier review phases. These notes may repeat some previously penned Specific Comments, but do include more of an overview of most issues missing or incomplete in the DEIR.

DEIR POINT A - Aesthetic and landscaping changes through the removal of trees/canopy trees and survival of new and transplanted trees.
• This project represents the essential loss of what has always been filtered open space with open airflow, filtered light & noise, amazing views in and out due to the large tree canopy as the existing “built” environment.
• The natural tree canopy is described on page 3.1-3 as “visually prominent,” “distinctive elements of the site and surroundings,” contributors to “both the visual and aesthetic quality of the site,” and are “some of the oldest, and of high visual significance.” It is therefore logical that this loss would be significant, contrary to insignificant findings in the report. • Only 5 of the 15 “protected” trees are saved. At very least, the “protected” trees should be boxed and replanted, if not on-site, then at the adjacent Central Park. • 75% of mature trees will be lost, replaced by small varieties unable to replicating the large tree canopy height and breadth. The requirement should be quality trees, not quantity of trees. • And why no study of the “protected” trees to determine if they are “historic” as called for by the public in the 6-year life of this project?
DEIR POINT B - Ingress/Egress along Dayton Street.
• 639 new daily trips generated just from this Project will be added to an already strained Dayton Street roadway segment. Yet the Traffic Section doesn’t properly study, or propose feasible mitigation of impacts with this lone-driveway location. • The Dayton driveway width is inadequate and should be 24 feet wide. • The DEIR stated a Fair Oaks driveway is “an alternative considered and dismissed.” Which Fair Oaks driveway location is that? Studies are missing from the DEIR. • Why wasn’t a two-driveway alternative studied to avoid or lessen significant impacts? • No analysis of any driveway alternatives in 6 years of review? This driveway further deteriorates the two Dayton intersections, yet no mitigation studied? DEIR POINT C - Fire Safety and emergency access along Dayton Street. • The Fire Department letter addresses the code-required access road width. Are they addressing Dayton Street or the interior site access? Dayton Street doesn’t meet this requirement today, but this is nowhere to be found in the DEIR.
• Let’s remember that the ONLY fire access for the Castle Green is on this street. And Dayton Street is the ONLY existing peak-hour eastward emergency access route for the Fire Station.

This Project (as well as Alternate 2) will likely impact emergency vehicle flow and response time as the total impact of all trips isn’t adequately studied. (AS HAS ALREADY BEEN Letter No. 3
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WITNESSED UNDER CURRENT TRAFFIC LOADS).
• Will this Project require the removal of all on-street parking & loading spaces on north side of Dayton as the illustration suggests, contrary to the City Memo dated June 12, 2013, or is this just another inconsistency uncovered?
DEIR POINT D - Increased traffic from project implementation. • 639 additional daily trips will be generated from this Project. This Project increases average daily trips 5-times above the City’s threshold for significant impacts! • Yet the trip calculation may be faulty by not including all 60 existing and reassignment trip demands on Dayton Street while the Project trips alone raise the average daily trips to 5-times beyond the City’s threshold for significant impact!
• Data for existing Castle Green generated trips on Dayton may be missing as well. • There is no analysis of project Alternatives that avoids or lessens the significant traffic impacts. • From existing conditions to Project & Alternative 2 impacts, the DEIR fails to provide analysis or adequately address the Dayton roadway, and the two Dayton intersections, and omits study Fair Oaks south from Dayton to Del Mar.
• These are issues previously mentioned that are not adequately or at all addressed in this report.

DEIR POINT E - Density and height of project relative to surrounding land uses and buildings. • The project is just too dense, and the impacts go unmitigated. • The Sec. of Interior Standards requires a ‘compatible and subservient’ building, yet the Project is a 6-story building next to two 6-story historic structures. Since the Project’s inception, the height has remained within 10% of existing historic buildings, even after 6 years of dispute. • This Project is taller than most existing historic buildings in the District, and taller than most every new building built in the District.
• Density is driving the height. Why is there no credible alternative presented with both less height and less density – the only solution to avoid or significantly lessen impacts as required by CEQA?
• The height negatively impacts long-establish views, air access, and light access, all unmitigated, and will result in higher energy use for the existing historic residences. Most of these impacts are not studied or adequately addressed.
• “Surrounding” land uses are the 6-story historic Hotel Green structures, the ‘zero-density’ Central Park and parking lot diagonally opposite the site, an adjacent historic one-story structure and a historic 3-story building opposite on Fair Oaks. The newest adjacent buildings are 4 & 3 stories for good reason.
• Looking at the building footprint is also ignored. Relying on a contrived “replication” concept has lead to inflexibility of the footprint, and an artificial constraint on alternatives.

DEIR POINT F - Historical significance of entire block on which the project site is located. • It is still not clearly stated that the parcel is on the National Register. Nor is it clearly stated it is part of the listing on the National Register. Language says it is part of the “nomination.” It's a fine point, but one that’s been brought up and ignored for years. • In fact, on most maps, not only is the entire block outline failed to be noted as on the National Register, the Old Pasadena District is generally not outlined either. 32 33
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• Where is it noted the required application of the Secretary of Interior Standards, as they must trump prescriptive zoning regulations on arguably the MOST significantly historic block in the City. However, the Alternative 2 begins to respect the historical significance of this site. • The report does not objectively address the historical significance of surrounding parcels.

DEIR POINT G - Impact on views from surrounding buildings. • “Would the project have an impact on a scenic vista?” is the basis of Section 3.1.6. However, only 4 relatively close vantage points (Page 3.1-13) are acknowledged and studied. • The report says it provides “a more complete understanding” of views lost, yet studied less than half of the impacted views. It’s no wonder view impacts were deemed less than significant. • No views from the existing historic buildings were considered. No views from a distance to the site were considered – historic view corridors that are impacted. • If all lost views are studied then Project impacts could be at significant levels, with Alternative 2 only slightly increases mitigation since it only addresses height and the 4 inadequate views.

DEIR POINT H - Alternatives to the proposed design.
• Alternative 2 only deals with height, and most impacts remain the same. • Why isn’t there a studied Alternative with way less residential units, a Dayton setback, a different footprint, less or no surface parking, a different driveway location or two driveways? These are all Alternatives asked for over the last 6 years. • Retaining the building footprint and relying on a 101 year old concept has lead to artificial constraints and ineffectual alternatives.
• Why is there no “transfer of development rights” alternative proposed or considered, transferred to the Parson’s lot or other areas that can take higher densities, unlike the Project site? • This report states that Alternative 2 only reduces “the severity of the significant impacts of the Project,” yet alternatives have to avoid or significantly lessen impacts as called for by CEQA.

DEIR POINT I - Air quality impacts to sensitive receptors, and specifically the neighboring Castle Green, the existing Green Hotel Apartments, and Central Park. • The similar height of new Project to existing structures on the block will surely cut-off or significantly reduce air circulation to the breeze-dependent, un-air-conditioned Castle Green and to the south side of the existing Apartments.
• The Castle Green was designed for cross breezes, and still functions that way today, yet no consideration of this exists in the report. This could result in more air conditioning units and higher energy use in the Castle Green.
• Air quality also needs to be considered for the long 28-month construction period, and the need for not just proper measures but for monitoring.

DEIR POINT J - Unreinforced masonry walls of Castle Green Apartments could be impacted by excavation, vibration, and other construction activities. • Almost all of the site will be excavated for the first time ever. Yet all many vibration mitigation measures omit the Castle Green in Table ES-1. Why aren’t these concerns & measures properly and adequately addressed and analyzed in the report?
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DEIR POINT K - Loss of soil during construction could cause displacement of Castle Green. • 30,000 cubic yards of original earth will be displaced for the excavation of the parking structure, almost to the very borders adjacent to the existing historic structures. Vibration of earth-moving vehicles, as well as vibration from 1,500 trucks, about 25 per day or so carting away the earth are of significant concern, and mitigation measures need to be studied. Yet some mitigation measures exclude protecting the Castle Green in Table ES-1.

Comments on important or controversial areas for study in the DEIR:

POINT 1 – No Dayton/ Fair Oaks & Dayton Raymond Intersection studies.

The DEIR says both intersections will be problematic with the Project, yet no alternatives for them were proposed or studied. While POINT B above touches this controversy, specific comments have asked for study of these intersections. Both intersections exist with no signal controls and no marked crosswalks There is no controlled way for vehicles, pedestrians and bicycles to safely make left turns to Fair Oaks and to cross east-west unless the traffic volume allows this.

The Dayton/Fair Oaks intersection is particularly problematic, if not outright dangerous for all users. TO a lesser by significant extend, so is the Dayton Raymond intersection. This means that with the huge Project increases in trips, AM & PM peak hour times will be dangerous. Isn’t this akin to not studying the “crosswalk” in the IDS project, and we all know how that came out.

POINT 2 - Fire Station signalized control light and south Fair Oaks.

When activated this fire signal stops cars into the Dayton/Fair Oaks intersection. This is a problem that is ignored. Not only was the fire station signalized stoplight not studied and not shown on any diagrams, this entire southern Fair Oaks roadway segment from Dayton south to Del Mar Blvd. wasn’t studied, yet the traffic study reports it handles 20-25% of Project traffic.

The DEIR only studied 4 of the 5 roadway segments affected by the Project. This 5th roadway segment has more complications than most that were studied. With added residential traffic from new and future developments to the west of this roadway segment, omitting this roadway study should require a revision to the EIR.

POINT 3 - Fire Department is not being made aware of existing conditions and future impacts.

The FD letter exhibit implies that Dayton Street meets the current safety access width of 20 feet, when in fact it does not. This letter no more conveys an understanding of existing conditions than it conveys an understanding and approval of this Project. This is a concern brought up since 2008. Given the facts, this letter is not applicable to the proposed Project or Alternative 2.

With the Project traffic generating unmitigated traffic impacts, there is no concern mentioned of the deterioration on Dayton and at both Dayton intersections, nor of added traffic on Fair Oaks.

Castle Green folks have long heard concerns from the Fire Department about the existing condition of Dayton Street and the two intersections. With these difficult existing conditions, and the HUGE Project traffic impacts to them, the Fire Department needs involvement as part of a revised EIR.

POINT 4 - Buildings should be Setback on Dayton Street.

The Project (and Alternatives) rely on zoning’s one-size-fits-all solutions, and fail to use the Secretary of Interior’s (and possible CHBC’s) interpretive guidelines to resolve impacts. The Castle Green is entirely setback from Dayton Street, its ground floor setback about 12-feet and all upper floors set back 30 feet, 40 41
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in what results today in a necessary and respectful nod to the significance of the zero-density Central Park. Yet setbacks were ruled out due to “zoning” language. An alternative approach with setbacks should be considered as mitigation to density, massing and resultant traffic impacts, and to meet the required “compatibility and subservience” to the existing historic buildings and to Central Park.

Setting back the Project could also restore portions of lost scenic vistas (Vantage Point No. 1, page 3.1- 13), and could benefit other omitted scenic views and airflow issues not studied but impacted. Setting back the project could also allow for likely necessary structural roadway improvements to Dayton Street and the Dayton/Fair Oaks intersection, all but ignored in this report.

POINT 5 - Most of the impacted scenic vistas are not analyzed.

While the DEIR investigates only 4 scenic views, most of the scenic views lost are not studied. These views have been mentioned since the first review in 2008.

There is no study and analysis of impacts of loss views within the block of the predominant lush green canopy. Or of the lost distant views from the site of the sunset, of the San Rafael Hills, of the Vista del Arroyo. Or of distant views to the site from historical view corridors (from farther south on Fair Oaks and farther west from former Ambassador parcels), and additional scenic views lost or reduced from Central Park not only of the site but of Old Pasadena and mountains to the north & west.

Setbacks (especially when combined with lower heights & densities) would go far to reduce or eliminate impacts that should be studied in additional Alternatives in a revised EIR.

Also of note is that new views for many existing residents will be mostly that of the new Project.

POINT 6 - Noise generated from only ONE driveway/ramp to the parking below ground.

Ambient noise from Fair Oaks is not so much an existing problem, as the on-site large tree canopy acts as a positive filter. In fairness, the new large project could serve a similar function, but it is more likely that it will create a negative effect of an echo chamber for not only the existing fire response, but for the huge increased traffic loads all concentrated between the existing 6-story buildings and the proposed 6 story building – now three similar hard surfaces to trap and bounce sound.

A major new noise source is the unfortunate placement of the sole driveway and parking ramp within this newly created echo canyon, too close to the Castle Green and affecting the existing Apartments.

This will surely generate noise (and some light spillover) for the Castle Green and the existing Apartments. No noise generation or abatement is studied in the DEIR.

A meaningful height reduction and a setback on Dayton would go a long way to alleviate this impact, yet this is not studied in the proposed Alternatives.

An alternate dual-driveway scenario would all lessen these impacts, as would an alternate or dual ramp location.

POINT 7 - Parking for the Project site.

This new total of 24 surface spaces (Fig. 2-5) conflicts with the Project Description (Section 2.7.1 and Table 2-3) of 20 spaces. The Initial Study total is also is 20 surface spaces. Why are there now 4 additional surface spaces to the Project? Who these 24 spaces are dedicated to is not adequately addressed. While 12 spaces have overhead covering, there are still visual with noise impacts, almost as much as the additional open-air 12 surface spaces. 11 spaces are assumed to be surface retail parking, the most active and impactful use. What are the 13 other surface parking spaces dedicated to? Why is there such a large volume of surface parking on this new Project, and not all below ground or hidden, as it is in other new projects in Old Pasadena? 44 45
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While there were 48-60 surface parking spaces on site, this is no validation for new surface parking.

The new Subterranean Parking spaces (Fig. 2-6 & 7), seems to be 148 underground spaces, conflicting with the Project Description (2.7.1, Tables 2-2 & 3) which says 147 underground spaces.

Therefore, the increased parking totals are 172 for the Project, conflicting with the 167 in the report description and Traffic Study.

POINT 8 - Light and glare impacts will increase due to project.

Little if any lighting or glare impacts come from the site today, due to the large tree canopy that partially hides Dayton Street and mostly hides Fair Oaks Avenue from resident’s views. However, with the loss of this canopy, the glare is unstated from the increased 639 additional daily Project traffic trips within view of the existing residents. The new 6-story Project shields the existing buildings from some light and glare, but no more than Alternate 2 and arguably less than the existing tree canopy.

The light from added headlights of the AM & PM peak traffic hours in and out of the paved concrete parking/drive area (like noise) could have some impacts that should be addressed and analyzed.

POINT 9 – Energy Use will increase in existing historic structures on the block.

Sunlight and general daylighting will be reduced for existing historic structures surrounding the Project.

According to Appendix B, beginning at 2:00 PM on the Winter Solstice, shadows begin to be cast onto the existing Apartments, and by 3:00 PM onto the Castle Green, a good 2-3 hours before sunset.

Beginning around 5:00 PM on the Summer Solstice, shadows begin to be cast onto the existing Castle Green, a good 2 hours before sunset (not to mention eliminating sunset views).

Also unstudied is the loss of airflow if a 6-story project is built. This could require the installation of mechanical air conditioning in many residents of the Castle Green, as this building relies on natural breezes for most of its cooling.

These new encroachment of shadows and loss of air flow with the Project will require more energy usage for large portions of the existing historic structures. This should be addressed and analyzed.

The Castle Green Homeowners Association believes it is clear from these Comments, as well as all other Comments submitted for this review along with oral testimony to be presented that the DEIR does not properly or adequately addressed and analyzed many relevant environmental aspects of the Project and Alternatives. The DEIR as submitted represents a failure to fully consider a range of impacts, a failure to study all relevant impacts, and a failure to propose and study appropriate and necessary mitigation. There are also errors, inconsistencies and omissions that compromise this DEIR.

Perhaps the biggest point of frustration, second only to the disappointing actual Project, are that too many of these “controversies” noted in the Executive Summary and in the notes above have been presented before with seemingly indifference or simple rejection without proper study. We hope that this practice will not be repeated in the DEIR review.

Only a revised report and Project would be able to address the many concerns expressed in this review and over the 6-plus years of the life of this Project.

Castle Green Homeowners Association
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Castle Green Homeowners Association
Green Hotel Apartments DEIR, Section 2.0 Project Description Comments March 8, 2014
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Section 2.0 Project Description.

This report fails to note in 2.5, "Land-Uuse and Zoning," that the development site is subject to the Secretary of Interior Standards being applied to all improvements on this parcel, as it is actually listed on the National Register of Historic Places, not just on the “nomination.” The standards are clear about the subservient and compatible nature of any project on such a historic parcel, yet there is scant mention of these Standards and their applicability to this project. This goes to the heart of the concern over the objectivity in this report.

2.6, "Project Objectives," discuss the objectives per the applicant for the proposed project. However there is one flawed objective, as well as one questionable objective.

Four of the project objectives deal appropriately with housing and the desire to provide new apartments to satisfy the increasing demand for residential units in the city. Yet if we look at the percentage of housing provided in this project, compared to the cumulative total of all housing projects, the Project only provides 3% of the cumulative housing total yet it creates significant, unmitigated traffic impacts on at least three reviewed major street conditions: the Dayton Street roadway segment, the Raymond/Dayton intersection and worse impacts on the Dayton/Fair Oaks intersection, all without any proposed or studied mitigation alternatives for these three impacted areas.

Three of the project objectives deal with the desire for new restaurant retail and commercial space in old Pasadena. This is perhaps the most appropriate and supported objective of this project, as it is critical to continue the Old Pasadena character further south along Fair Oaks Avenue.

This component is probably the most important objective, and alone could be the least impactful alternative that should be considered for this project site.

The major flaw in one of the objectives (no. 6) claims the need to build out this parcel "In a manner that is based on the original turn of the 20th century vision." While many in the community have pointed to this historic proposal as a starting point, it has proven that a project of this type creates too many negative impacts, and oddly fails to meet the some key Secretary of Interior Standards for new structures applicable to the site, but not stated in the report.

The questionable project objective, (no. 5), says to provide residents of the adjacent existing Apartments appropriate parking with direct the ingress and egress." This condition already exists, as there is direct driveway access today for the existing surface parking spaces. Yet the report fails to note that this is already a traffic problem. The report also fails to acknowledge is the fact that providing a singular driveway from the new project on Dayton Street creates problems beyond mitigation. So this truly is a questionable objective, one that was desired in response to rejected early schemes.

The same project objectives are listed in Section 4, Alternatives. The same flaws apply to that section, and unfortunately has resulted in an inappropriate Alternative 2, and provided flawed grounds to dismiss some alternatives from ever being studied.

The project site is described as 32,362 ft.². and is generally perceived now as open space from the existing residents on the block. It will be reduced approximately by half with the new projectThe proposed project identifies 9,600 ft.² of private open space on page 2–14, yet the open space square footage is actually 8,450 ft.², when you remove the 1,050 square-foot gym that is inside the building’s ground floor. Why is this given credit for open-space? The actual 8450 ft.² of Private open-space is comparable to the existing landscaped open space.

Letter No. 3
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Therefore, this project, with its supposed benefits, provides similar benefit of the existing space.

In addition to less open space, it eliminates the existing 45 to 75 foot mature tree canopy. This is a loss as it cannot be mitigated, yet its loss is reduced to insignificance in the report. An alternative that provides less-or-no surface parking and a large landscaped area would actually be appropriate to reduce impacts, but other than “no Project” alternative, this concept is not examined.

While the report also notes on page 2–14, that parking for the project is provided in compliance with City code, nowhere else in old Pasadena is there surface parking provided at this scale for new projects. Is the only justification for new surface parking because surface parking already exists on the site? Is it because 55% of the proposed surface parking is "tucked under," yet still exposed to existing residents on the block? How can such a large quantity of new paved-over parking spaces be acceptable for new construction at this sensitive location?

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ratio, and setbacks meet the development standards for the CD – 1 zoning district." However what is missing from this description is that the applicable Secretary of Interior Standards that requires compatibility between new projects and existing historic buildings on the block, nor is it taken into account. Clearly because of this requirement, the 6-story height of 75 feet for the project is not appropriate when the height of the adjacent Castle Green is 78 feet, and approximately 84 feet to the top of the existing Green Hotel Apartments. The new project provides less than a 10% reduction in height when compared to the existing buildings. This clearly does not meet the Secretary of Interior Standards when considering subservient and compatible new construction on the same historic block.

Curiously, the height of the project is a major reasons that this project has many impacts that cannot be mitigated. The inappropriate 75 foot height of this project contributes to the excessive density of the project, which creates huge traffic impacts not addressed on Dayton Street, on the two Dayton intersections, and likely on the unstudied Fair Oaks roadway from Dayton Street to Del Mar Blvd.

The single driveway to the project on Dayton Street is a major problem of this project, as it dumps all of the project traffic on to already-impacted Dayton Street, worsening the two adjacent intersections.

Unfortunately, existing traffic conditions are not correct in the report, and there is insufficient study in the report of these impacted conditions, with no alternatives are provided.

It should be noted that while the removal of 10 of the 15 protected trees allows five protected trees to remain, these five are not trees that create the existing lush canopy that is the predominant view of the existing apartments and of the Castle Green to the south and west.

While it is far superior to be able to maintain or to relocate existing protected trees onto the project site, it appears that this is not a project goal. The replacement trees won't ever come close to the existing mature tree canopy. Questions also remain whether or not the 36 inch box size of the new trees on this property will have the space to grow to their potential or the width to spread out their root canopy.

The report already anticipates construction to last approximately 28 months, beginning in August 2014 and completing in December 2016. A significant amount of time to find artifacts and to investigate historic surface treatments over the long history of this site should be provided by additional time for this phase. What could be uncovered are remnants of historic walkways, historic planting, indicators of layouts of the original park over time, as well as the remnants of the foundation of the original house on the site. Also, there could be remnants of the original sports court parallel to Fair Oaks Avenue. This 54 55
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investigation of historic artifacts should be a condition of any approval prior to any activity on the site.

Of course, the concern remains of air-quality and airborne particulates during the construction phase and a possible heightened effect on some existing residents. Also concern would be noise and especially vibration, as it relates to the integrity of the existing historic buildings on the block.

Comments on plans and elevations submitted.

Figure 2-5, Site plan and first floor layout. There is no text identifying uses on this plan, only the floor plan itself. It is unclear where the common area that is referred to as the open space "gym" is located. It is also unclear what the parking spaces are dedicated to on the surface. Also missing are clear directional arrows on ramps and driveways. The trees that are indicated on this plan show the original canopy as well as the projected mature canopy, blurring the limited coverage of the new trees. In fact, the paved areas seem to cover over 90+% of the open area. Without the surface parking on the ground floor, this actually could have been landscaped open space. Instead it's dominated by auto uses, and pavement. This paved over approach should be completely reconsidered in the alternative section.

Figure 2–6 & 2-7, subterranean parking levels. An amenity that seems to be missing is storage for the private units. Typically there's some amount of storage in the garage area. Because the ground floor plan was not labeled, this unclear if any building storage is provided there or on the ground floor level. It is unfortunate that the subterranean level parking layouts are so tight - another problem with the density of this project. And there are inconsistencies between this plan and Appendix diagrams.

Figures 2-8, 9, & 10, floor layouts. It would be helpful if the actual s.f. area of the apartments were identified to help in reviewing the parking requirements, trips generated and alternatives. It would be helpful to identify accessible exterior spaces as well. These comments have been made before about the presentation, and sadly add to the list of those not addressed.

Figures 2-11 & 2-12, Conceptual elevations. Unfortunately, it appears that some of the same elevation errors noted in the Initial Study and previous scoping sessions remain on these elevations. It is also unfortunate that the predominant height of the existing Castle Green, at 911.4 feet (approx. 78’ high), is not clearly delineated. This was raised during the Initial Study, and the scoping sessions.

By not clearly identifying the legally recognized height of the Castle Green (approx. 78 feet), a false impression is created that the Project building has less impact. Nothing could be further from the truth, as the height directly contributes to many impacts. What these elevations do show is that the height of the proposed building is generally problematic.

This building clearly dominates the west elevation. Because of the length of this elevation and the attempt to relate to the bay window pattern of the existing adjacent facade, this elevation tends to dominate the West side of Fair Oaks, partly due to length, but also to the oversized attempt to ‘compliment’ the historic bay windows. In relationship to the existing historic buildings, this is contrary to the Secretary of the Interior Standards. Yet in other elevations, the proposed six-story height may not always appear to be as dominating as it does in the illustrations provided in other sections of this study.

End.
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Green Hotel Apartments DEIR, Section 3.1 Aesthetics Specific Comments March 9, 2014
PAGE 1 of 2
DEIR Comments on Section 3.1 Aesthetics selected topics

3.1.2.2: In this section the Central District area that is discusses says "most of the buildings are two stories in height, although there are a few taller buildings of either three or four stories…” This should be the basis for reviewing the appropriateness of the Project. Height is a major compatibility factor for new buildings to respect existing historic buildings. Compatibility does not mean equal stature when it comes to new buildings on or adjacent to historic sites, and especially when on the same block.

In fact, there is reason that few existing historic buildings in this District rise above four stories. While mostly historic and significant buildings, they ultimately respect larger historic structures (such as the Castle Green/Green Hotel Apartments) and the scale of the district.

This is evident in most all new construction, that with one exception all new and proposed buildings within the Old Pasadena District are 4, 3 and 2 stories.

3.1.2.3 Surrounding land uses. In the second paragraph Central Park is mentioned only as a contributor to the Old Pasadena District, yet it is individually listed on the National Register.

Also note in the third paragraph, this Section discusses the Castle Green and the "The garden courtyard, located on the eastern side of Castle Green building at Raymond Avenue.” This fails to note is that this was the original 1895 park land of the early Hotel Green, and further fails to discuss the fact that the project site became the “West Park,” shown in Fig. 3.3-6, 7 & 8, Central Park’s predecessor.

It is with amazement that after six years of reviews and comments, this Section fails (in the 4th paragraph) to mention the predominant views from the existing historic residences of the large tree canopy that exists on the project site. This omission continues throughout this report.

Continuing on page 3.1–3, “Viewsheds” on Fair Oaks are mentioned, an is somehow made that existing nighttime lighting levels are considered high to medium. This may only true for existing westernmost edge of the project site, and certainly not for existing block residents. The existing large tree canopy realistically shields most of this nighttime lighting from existing residents, and their impact should be noted as medium to low nighttime lighting levels.

In addition there's discussion of daytime glare from windshields of moving parts vehicles. Do to the fact that Fair Oaks is a heavily traveled street this is somewhat true but only to the westernmost edge of the existing site. Again, as with lighting levels, the large tree canopy dissipates most glare to existing residents. Furthermore the discussion of glass windows and doors producing periodic glare is questionable boilerplate language for this site. To the west and east are the existing historic buildings, and the large tree canopy filters this light in all directions.

3.1.2.4 Project Site
There actually are limited views to the north of San Gabriel Mountains along the western perimeter, and some limited views to the north of the west side of Fair Oaks and north-western Old Pasadena.

The site description of the “significant” existing canopy, “These trees are visually prominent and distinctive elements of the site and surrounding area due to their size and scale, and the trees contribute to both the visual and aesthetic quality of the project site.” Also noted, “These trees are some of the oldest trees in the city… and are of high visual significance.” Letter No. 3
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• Why are views of the trees not studied?
• Why haven’t in the 6-year-life of this project these trees been studied for likely historic significance?
• Why isn’t the loss of this canopy given then acknowledged as a significance unmitigated loss? • Why are other descriptions of this canopy less significantly and incomplete in this report? In table 3–1 on page 3.1–4, summary of on-site trees, they are only 15 “on-site trees” listed in this table, yet Fig. 3.1-2 shows 21 “on-site trees.” In the previous project site description on page 3.1–3, it says there are 20 existing trees on the site, 15 of which are protected. This discrepancy continues and has been noted in previous reviews yet seems to have once again been ignored.

It is unfortunate on page 3.1–5, figure 3.1–2, location of “on-site trees,” that the tree canopy sizes are inaccurately depicted. Every tree appears to be identical in canopy size. This of course greatly diminishes the importance of the trees there and the significance of the trees, and the full impact of the loss of the canopy.

Also in the same figure, there seems to be a discrepancy between protected tree counts and nonprotected tree counts in reference to 3.1.2.4 project site. This figure only indicates that eight trees are protected. This is a discrepancy that is been brought up during the initial study and during two previous reviews yet it has not been corrected.

3.1.5, Thresholds of Significance. There is a discussion of the CEQA guidelines and reference to the Appendix G and four bullet points (top of page 3.1-13). Number one bullet point is "have a substantial adverse effect on a scenic vista." This should apply to not only views into the site but views from in across the site especially from the existing historic green hotel buildings. But the DEIR fails to only study 4 tight viewpoints in concluding a less than significant impact.

Another bullet point, number four, says a significant impact is true if it “Create[s] a new source of substantial light or glare which would adversely affect day or nighttime views in the area." Where is the consideration here of the removal of source of daylight – late-afternoon sun and the sunsets – views from and effect on the existing structures that are now going to be pretty much entirely lost? Shadows beginning in early evening during summer and late afternoon in winter will require more lighting and energy use for existing structures on the block. How much is not analyzed, even though this use is concluded to be insignificant.

3.1.6 Project Impacts
"Substantial adverse effect on scenic vistas." This section states photosimulations were used, "to provide a more complete understanding of the proposed projects effect on scenic vistas." However, this analysis fails to provide a true complete representation of the Project’s effects on relevant scenic vistas.

Only the 4 vantage points described on pages 3.1–13 through 3.1–24 are proposed and analyzed.

Yet the DEIR fails to take into account views impacted from the existing historic structures, and historic vistas to and from the site. This incomplete analysis must be updated to include all relevant view impacts. The historic vistas have long existed from the far west all the way to the sloped land east of Orange Grove Blvd, and from the far south all the way down to the former Raymond Hotel site and more significantly along Fair Oaks north toward the site, considered a gateway into Old Pasadena. 73 74
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Green Hotel Apartments DEIR, Section 4.0 Alternatives Comments March 8, 2014
Review of Section 4.0 – Alternatives
Alternatives are to attempt to obtain most of the Project Objectives, yet avoid or substantially lessen significant impacts of the project, even if those alternatives impede to some degree the attainment of the Project Objectives, or would be more costly.

While the selection of alternatives is to foster public participation and informed decision making, it seems that the exclusion of many alternative ideas mentioned by the public fails to meet this standard. Many alternatives, mentioned over and over, have been ignored, or waved away by a mere statement that they “were considered but dismissed as infeasible.”
Case law clearly comes down on the side of measurably different alternatives that significantly lessen project impacts. Because a selected alternative reduces one or two impacts, or merely reduces the severity of an impact, doesn’t make it appropriate, especially if “dismissed” alternatives do more.

Two questionable Project Objectives are driving not only the project but the dearth of credible alternatives:

1. “Direct ingress/egress for parking” is a questionable goal if it is reason for the Project’s sole access on Dayton Street. Alternative 2 only reduces the severity of traffic impacts, yet other alternatives NOT considered would substantially lessen traffic impacts.

2. Building out the parcel “based on the original turn of the century vision to create a new “gateway” framing Old Pasadena” has proven to be problematic at best when narrowly interpreted as the proposed Project does. Attempting to meet this “objective” has lead to unmitigated traffic problems, to excessive height bringing excessive impacts (studied or not), and to excessive density for this site. Almost all of the negative impacts are due to trying to copy or stick to this “objective.” This Project, while novel and better than previous proposals, has proven to not be appropriate for this project, nor for Alternative 2.

In the discussion of Alternatives, page 4-2 mentions the ill-conceived original 2007 proposal, driven by the same project objectives, and completely rejected by all. While thankfully the current project has less in common visually with the 2007 concept, it is clear that the Project and Alternative 2 have too many unmitigated impacts.

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adequate to reduce significant impacts, yet few if any actual mitigation measures are mentioned, let alone studied and analyzed in the DEIR. The report goes on to say “a number of additional alternatives were considered but dismissed as infeasible.” However, none of these “dismissed” alternatives show evidence of being studied. To merely state that they are infeasible is inadequate and contrary to CEQA requirements.

Alternative 1 is the required “No Project” approach, one that would most please the community. What is omitted from this DEIR, is that Dayton Street as it exists, does not meet the minimum access width required by the fire code. So starting with the existing conditions are problematic, especially if they are omitted.

Alternative 2 in concept actually is just slightly better than the project. It does not change key impacts, and only reduces the severity of unmitigated traffic impacts on Dayton, surrounding intersections and roadway segments.

DISMISSED ALTERNATIVES
First of all, the Alternatives are supposed to be project-based. Statements such as “Much in the same manner” or “the same project” sadly characterize Alternative 2. A major failure here is that real alternative projects are not considered, just alternative portions of projects are considered. No wonder the stated alternatives are rejected, as they consist of “concepts” the City had no intention of supporting from the start. This is a major flaw.

Letter No. 3
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4.4.1 Alternate ACCESS Alternative describes a single driveway on Fair Oaks, yet no location is given. In fact, the existing parcel has a driveway on Fair Oaks. This dismissal goes on to opine that no left turn lanes into the project on Fair Oaks could ever exist, yet no study validates this “statement.” Couldn’t a portion of on-street Fair Oaks parking be removed to allow a left turn lane? Or a lot line adjustment in the parcel in conjunction with onstreet parking changes be studied? Could a reduced size alternative with some or all of the above make a Fair Oaks driveway worth studying? Could a dual-driveway approach combine with the above options for consideration? Yes to all of these possiblities.

Logic says they are worth evaluating, but without study, the DEIR says no way to any other driveway configuration than a single traffic-busting driveway onto Dayton Street. In rejecting any possibilities here, the report creates then ignores the worst series of unmitigated impacts possible.

4.4.2 Off-Site Parking Alternative. While this exploration could have promise, the City takes an “only per Code” approach. Nothing outside the zoning box was looked at, even on this most-significant block that should warrant a “creative” approach. Yet just next door, the Castle Green provides only 10 on-site resident parking places, with the majority of occupants parking across the street. A reduced size project with creative parking solutions could have made this worth of study.

4.4.3 Alternate Site Alternative was dismissed solely because the current owner fails to own or control any other property in the vicinity. Is the grounds for dismissal? Instead of studying a possible alternate site, and following up with the other owners on possibilities that would provide such an alternate to be considered (such as land swap, or transfer of development rights, etc.), the City again dismisses this from further consideration.

4.4.4 Smaller Scale Alternative. Everyone agress that the ground floor commercial is important for continuity with Old Pasadena, yet this “smaller scale” alternative removes this use, instead opting for only 13 residential units with no commercial space. We know the parking needs for the retail space, and this could be accessed from a single Fair Oaks driveway to below ground. 8-14 residential units, per the proposed floor plans could be added and accessed from this same driveway to underground. Less than 69 spaces would be required, limiting underground parking to one floor. Perhaps if less parking, a Dayton ramp could be part of this to allow a second and impact-reducing driveway. The existing Fair Oaks driveway could be the parking entrance. Two driveways could reduce left turn impacts, queuing impacts and overall added traffic impacts. Dismissed.

4.5 Analysis Methodology. The flaw in this section is that only the “alternatives selected for analysis” are sufficiently evaluated, leaving questions about how the “dismissed” alternatives were objectively studied.

Sadly, superior low build options exist, but weren’t considered. Alternatives such as ONLY building the Fair Oaks ground floor retail component with covered parking in a wider footprint, or this and perhaps adding a full or partial second or even a limited third floor of housing above, with smaller underground parking footprint allowing some preservation of historic tree canopies and two driveways is a simple and likely less impactful alternative.

For some reason, alternatives seemed to only follow existing project footprint. In fact, a 2-3 story build, as discussed above with wider lot coverage could have a planted roof, or solar roof, or larger undisturbed ground floor landscaped area with a smaller excavation area.

Section 4.6, Comparative Impact Analysis, Alternative 1 – No Project Alternative Refer to Tom Brohard traffic notes on existing traffic conditions omitted in the DEIR. 87 88
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Green Hotel Apartments DEIR, Section 4.0 Alternatives Comments March 8, 2014
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4.6.2 Alternative 2 – Reduced Height
The only difference in Alternative 2 and the project is the lopping off of the top two floors. However, what results from this reduction in height and density only slightly (in words direct from this section) begin to reduce the severity of the impacts or having similar reductions as the Project.

Artificially lopping off the top two floors may be an obvious start in considering alternatives, this is where it ended.

Why do all other attributes remain the same: views are only ‘slightly improved,’ air access slightly better, fewer daily trips but with traffic still unsupported by roads and intersections. By reducing only ONE attribute, the “Reduced height” Alternative fails when a “Reduced Scope” Alternative should have been studied. Is Alternative 2 more appropriate and desirable than the Project – sort of. But to say this Alternative is good is relative – sorta like the loud relative that lives far away, so he visits less often, which is good, but he’ll always be a relative. This is reason alone to require a revised report.

Aesthetically, to quote the report, “the height would merely be reduced by two stories.” That’s it. And the report says Alt. 2 has similar effects on impacts. Wow, so there’s little difference because it is not a reduction in SCOPE.

And Alternative 2 still isn’t set back on Dayton Street, and still has 20 new surface parking spaces on a large paved “open area” stymieing a more appropriate and less impactful greener landscaped ground floor. Why weren’t the “Known Areas of Controversy” considered when picking alternatives? And there is a false statement by omission on Page 4-8 stating that the Alternative wouldn’t restore turret views from the west. Based on only the 4 close-up Vantage Points, in this case just 200-300 feet west of the site, this is true. Even a 3 or 2 story building from this point could obscure the turret views. Yet the fact is that most of the impacted views aren’t even considered by the Project. Alternative 2 in fact would begin to restore many of the turret views beyond these short-sited Vantage Points, including the historical view corridors of the last 112+ years.

It could also restore many historic western, afternoon and sunset views from the site (also not studied).

Under air quality, while referring to construction, it is deemed for Alternative 2 to be less than significant. What the lower height does is to reduce lost air circulation for the breeze-dependent Castle Green (also not studied) As for Cultural Resources, if the DEIR fails to address all the cultural resources impacts for the Project, then the Alternative is essentially similar in studied impacts. Without an objective Project analysis, of course Alternative 2 looks better. And the report concludes “similar impacts to historic resources would result with implementation of” Alternative 2. Then in other words, lopping off 2 floors in Alt. 2 is really not less impactful, and not really an alternative, and should be deemed inappropriately.

Traffic generation from Alternative 2 is deemed to be on par with the Project, somewhat less but still overwhelming Dayton Street. Alternative 2 continues to create unmitigated circumstances at Dayton & Raymond, at Dayton & Fair Oaks, and at the unstudied Fair Oaks roadway segment from Dayton to Del Mar. So Alt. 2 is essentially similar in traffic impacts as well.

Only a significant reduction of scope for an alternative would meet the CEQA threshold for Alternatives.

The “Conclusion” on page 4-14 pretty much sums up Alternative 2: “The same significant and unavoidable impacts would either be similar to or reduced in comparison to the Project.” It goes on to say Alt. 2 “would not avoid but would reduce the severity of the significant traffic impact of the Project.” Reduce the “severity” is not the standard of which Alternatives are measured, but this fact seems ignored. The standard is to avoid or substantially lessen significant impacts, not to just reduce their severity. …so this really isn’t an appropriate Alternative after all. The above comments are reason enough to require a revised report before any project approvals are granted.

End.
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Letter No. 3 Castle Green Homeowners Association
Castle Green Homeowners Association
March 8 and 9, 2014
Responses
Response 3-1
Detailed responses to the allegations in this comment letter are provided. All impact areas have been appropriately investigated according to CEQA requirements and no mitigation measures are omitted or incomplete.

Response 3-2
The general statement provides no basis or discussion regarding why the “less than significant impact” conclusions need to be revisited. Subsequent comments and conclusions are discussed further below.

Response 3-3
The subject description is a summary of the more detailed discussion of aesthetics provided in Section 3.1 of the Draft EIR. Whether the existing Castle Green is characterized as a six-story building or a seven-story building does not exaggerate nor underestimate the height of the subject structure, nor is that characterization the basis on which the conclusions of the aesthetics impacts analysis were reached. The Draft EIR analysis is based on the actual heights of existing structures in relation to the height of the proposed project building. That is clearly evidenced in the elevations provided in Section 3.1 (i.e., Figure 2-11 and 2-12), which are drawn to scale and have the actual heights, as measured in feet above mean sea level, of numerous existing structural features near the project site.

Castle Green has a height of between 906.1 and 938.2 feet above mean sea level, depending on particular roof features, and the proposed project building has a height of 908.26, which is, for the most part, lower than Castle Green.

Response 3-4
Section 3.1.2.4 of the Draft EIR acknowledges that surface parking and mature trees also currently occupy the project site and are therefore included in the impacts analysis. For the reasons described in Section 3.1 of the Draft EIR, specifically pages 3.1-24 through 3.1-27, implementation of the proposed project will not substantially degrade the existing visual character or quality of the site and its surrounding. The conclusion that there will be no significant impacts pertaining to aesthetics remains valid.

Response 3-5
The issue described in the comment (i.e., headlight illumination impacts) is addressed on page 3.1-27 of the Draft EIR. Furthermore, the project is located in one of the most heavily urbanized and active areas of Pasadena, where lighting from cars in the late evening or early morning hours or glare during daytime hours would not be a material change to the existing condition, and therefore is a less than significant impact.

Response 3-6
The figures presented in Appendix B of the Draft EIR indicate that shading impacts associated with the project would generally be limited to only portions of the adjacent building during certain times of the year and certain hours of the day. The figures in Appendix B also show the substantial separation Section 3  Comments and Responses
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between the project building and existing structures, including a building separation distance of approximately 40 feet to the existing Green Hotel Apartments to the north and approximately 158 to the Castle Green to the east. Figure 2-8 through 2-12 of the Draft EIR also delineate, to scale, the substantial amount of separation between the project building and the aforementioned existing structures. While development of the proposed building may cause existing breezes from the west and south to flow around the new building, there is no indication that there would be a significant loss or reduction of existing airflow to Castle Green. Based on the above, there is no factual basis to conclude that implementation of the project would cause a loss of daylight and breeze resulting in higher energy use.

Response 3-7
Please see Response to Comment 3-6 above. Additionally, relative to the commenter’s statement that the Castle Green units were designed for cross-building ventilation, it should be noted that the currently proposed building is in the same basic location and orientation as originally envisioned in 1903 for the overall Green Hotel complex (see Figures 3.3-4 and 3.3-5 on page 3.3-11 of the Draft EIR), with the notable exception that the current proposal has a 40-foot wide separation between the north end of the proposed building and the south side of the existing Green Hotel Apartments, whereas the original development had continuous building area with no such gap. If anything, the currently proposed project better supports cross-building ventilation at Castle Green than the development concept in mind when Castle Green was designed, by providing a sizeable opening for westerly breezes to flow through.

Response 3-8
The general statement provides no basis or discussion regarding why the “less than significant impact” conclusions need to be revisited. Subsequent comments and conclusions are discussed further below.

Response 3-9
In contrast to the commenter’s allegation, the historic value of the trees and landscaping on site has been evaluated in the EIR. Page 3.3-6 of the Draft EIR includes a discussion of trees at and near the project site. Appendix E of the Draft EIR provides a detailed evaluation of the ages of trees at and adjacent to the project site. As concluded therein, removal of trees onsite would not affect the existing National Register listing and there would be no significant impact related to historic resources.

Further, as discussed under CEQA Guidelines Section 15125(a) the environmental setting [i.e. the basis for determining whether an impact is significant] are the “physical environmental conditions in the vicinity of the project, as they exist at the time the notice of preparation is published…” (See also CEQA Guidelines Section 15126.2(a).) (See also Citizens Committee to Save Our Village v. City of Claremont (1995) 37 Cal.App.4th 1157, 1170 [no historic impacts based upon alleged inconsistency with historic landscape plan when there was no evidence as to the extent, detail, or nature of the plan, no evidence that plan was maintained or continued over time, and no credible evidence that landscaping in accordance with alleged plan was in existence at the present time.] Secretary of the Interior’s Standard 4 states: Changes to a property that have acquired historic significance in their own right will be retained and preserved.

The growth and maturity of the trees on the property is a change; however, this is a change that has not acquired historic significance because historic association has been lost and there is no new context or association. Two trees remain on the parcel from the hotel’s period of significance. The Section 3  Comments and Responses
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historic landscape associated with the hotel is no longer discernible, and the parcel no longer conveys its past use as a designed landscape for the hotel or has a visual association with Central Park. The landscape features currently on the parcel have not acquired historic significance, on the contrary, they have lost historic significance. The project conforms to Standard 4 because there is no change that has acquired significance over time.

Response 3-10
Please see Response to Comment 3-9 above. Relocation of trees will comply with the Tree Protection Ordinance. Trees by themselves could be considered significant, but would have to be designated as such pursuant to the City’s Zoning Code. None of the trees on this site have been, or could be, so designated.

Response 3-11
The height compatibility of the proposed project is addressed on page 3.3-29 of the Draft EIR.

Additionally, please see Topical Response TR-CR-1 regarding the Draft EIR analysis of impacts to historic resources.

Response 3-12
The comment claims that the project is not consistent with Standard 10; however, Standard 10 specifies that if new construction is removed in the future, the integrity of the existing historic resources would be unaffected. The proposed project is a separate building that would not touch the existing historic resources; hence, if it were removed at a future date, the “form and integrity of the historic property and its environment would be unimpaired.” The project is, therefore, consistent with Standard 10. Standard 9 is more related to the commenter’s concern regarding height. Please see Topical Response TR-CR-1 for additional discussion regarding the Draft EIR analysis of impacts to historic resources, including a discussion of height in relation to the adjacent historic buildings.

Response 3-13
The Draft EIR addresses the impacts associated with proposed Project in accordance with CEQA requirements.

Response 3-14
South Coast Air Quality Management District thresholds pertaining to greenhouse gases (GHGs) are based on land use sources of GHGs, not land use receptors. GHG impacts are global in nature, and not specific to local settings. Section 3.2 of the Draft EIR addresses potential air quality impacts associated with construction and operation of the proposed project, including potential impacts to sensitive receptors as discussed on pages 3.2-14 through 3.2-17. That analysis considers potential “hot spots” (i.e., the potential for high concentrations of air pollutants to accumulate in particular areas) and toxic air contaminants. As indicated in Section 3.2, no significant impacts related to air quality are anticipated to occur following implementation of recommended mitigation measures.

Response 3-15
The general statement provides no basis or discussion regarding why the “less than significant impact” conclusions need to be revisited. The analysis of potential noise and vibration impacts to nearby buildings, as presented in Section 3.5 of the Draft EIR and supported by Appendix G, is specific to each building. The nature and applicability of mitigation measures presented in that section, as well as in other sections of the Draft EIR, are specific to the significant impacts identified in the impacts analysis. It is not necessary or appropriate to extend mitigation measures to situations where no Section 3  Comments and Responses
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significant impacts occur. Additionally, it should be noted that the vast majority of mitigation measures presented in Section 3.5 are not limited to specific building, but rather apply in general. The only mitigation measures that are buildings-specific are MM-NOISE-4 and MM-NOISE-5 relative to potential construction-related structure vibration impacts to the existing Green Hotel Apartments and the single-story structure at 84 Fair Oaks Avenue (see Response to Comment 2-5 regarding clarification that the subject mitigation measures apply to 84 Fair Oaks Avenue). Those two building-specific measures do not apply to Castle Green because, as indicated on page 3.5-21 of the Draft EIR, project-related construction activities would be 75 feet or more from Castle Green, which, at that distance, the potential for structural vibration impacts would be less than significant.

Response 3-16
MM-NOISE-1 is consistent with the City’s Noise Ordinance, which is described in Section 3.5.3.3, and provides appropriate time limitations on construction activities, thereby reducing potential noise impacts to a level that is less than significant. The Mitigation Measure extends noise restrictions applicable to residential zones to this site, which is not in a residential zone and would therefore not normally be required to comply with residential noise restrictions. The comment provides no basis for, or analysis in support of, expanding those time limitations beyond those required for residential zones in the City’s Noise Ordinance.

Response 3-17
Noise impacts associated with vehicle traffic on Dayton Street are addressed on page 3.5-14 of the Draft EIR, which states that the project-induced increase in traffic volumes on Dayton Street would increase ambient noise levels by 2 dBA. For comparison, it is widely accepted that the average healthy ear can barely perceive changes of a 3 dBA increase or decrease in noise. The noise generated by 639 new daily project trips is much less significant than the noise generated by 20,690 existing daily vehicle trips on Fair Oaks.

Response 3-18
Condition of Approval COA-NOISE-4 and Mitigation Measure MM- NOISE-3 sufficiently reduce noise impact to a level that is less than significant. No expansion or modifications of those measures are warranted. Moreover, COA-NOISE-4 does not contain any noise notification requirements but rather pertains to providing data to the Director of Planning and Community Development documenting that noise levels from heating, ventilation, and air conditioning (HVAC) and other mechanical equipment will meet specified noise levels. Additionally, MM-Noise-3 in its current form calls for a prohibition on use of the pool area between 10:00 p.m. and 5:00 a.m. To add noise restrictions on continued pool use after 8:00 p.m. and before 7:00 a.m. is unwarranted given that noise intensive use of the pool area during such times seems unlikely and the commenter provides no basis or rationale for why such restrictions during those hours are needed. In the event there is a notable noise disturbance occurring during those hours of interest, enforcement of the city’s noise ordinance, as described in Section

3.5.3.3 of the Draft EIR is available to address the issue.

Response 3-19
Mitigation Measure MM-NOISE-4 on page 3.5-21 of the Draft EIR provides sufficient detail regarding how the measure will work. As described therein, the tasks required in MM-NOISE-4 are to be implemented by a Professional Structural Engineer with experience in structural vibration analysis and monitoring and a Project Historic Architect as a team. As qualified professionals, they will take the steps necessary and appropriate to address potential vibration impacts specific to the site characteristics and specific to the demolition/construction approach proposed. As indicated by the Section 3  Comments and Responses
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examples provided in the latter portion of MM-NOISE-4, the types of measures to be employed are aimed primarily at avoiding or minimizing activities that may result in significant vibration levels. It is not necessary to test such mitigation measures prior to demolition, as suggested by the commenter.

Response 3-20
Please see Response to Comment 2-5, which adds the 84 Fair Oaks Avenue structure to the proposed monitoring program and reiterates the Draft EIR finding that the Castle Green building is approximately 75 feet from the project site, and, at this distance, the potential for structural vibration impacts would be less than significant (i.e., vibration monitoring is not warranted).

Response 3-21
Please see Response to Comment 2-5.

Response 3-22
The general statement provides no basis or discussion regarding why the “less than significant impact” conclusions need to be revisited. The alleged deficiencies in the traffic study are addressed below.

Response 3-23
An Alternative Access Alternative and an Off-Site Parking Alternative have been studied to address the significant impact to Dayton Street. These alternatives are discussed on page 4-4 of the Draft EIR.

Traffic impacts on Dayton Street are identified and discussed on page 3.6-43 of the Draft EIR, as indicated; no feasible mitigation measures are available to reduce significant traffic impacts on Dayton Street because the only way to reduce the impact below a level of significance is to reduce the number of trips along this segment. In order to study the potential to reduce the number of trips along this segment, the Alternate Access Alternative would relocate the project driveway along Fair Oaks Avenue creating right-turn in and right-turn out access for the project site. As discussed in Response 2-6 above, this alternative would not mitigate the significant impact on Dayton Street. The Off-Site Parking Alternative would relocate 32 parking spaces to an off-site parking structure. As described in Section 4.4.2 of the Draft EIR, the capacity of the two nearby parking structures has been reached and they are therefore not available, thereby making it infeasible to provide off-site parking within the required 1,000 feet of the project site. For this reasons, the Off-Site Parking Alternative was eliminated from further consideration and evaluation in the Draft EIR.

Typical local street capacity is between 3,000 to 5,000 Average Daily Traffic (ADT); the current ADT on Dayton Street is 883, and the project would increase the ADT on Dayton Street to approximately 1,509. This increase is substantially below the available capacity on Dayton Street.

The traffic study includes the existing (baseline) trips affecting Dayton Street, which are part of the existing AM and PM vehicle count data, and included in the traffic impact analysis on page 12 and 13 in Appendix H of the Draft EIR, and in the Draft EIR itself on page 3.6-11 and 3.6-13. This includes all trips associated with the existing parking lot, which currently only uses Dayton Street for access (per the applicant, the gated Fair Oaks Avenue driveway is locked and only used for trash pickup).

Response 3-24
The discussion within the Executive Summary box addresses whether project implementation would conflict with the County Congestion Management Program (CMP), and the conclusion therein that it would not conflict with the CMP is correct, which the commenter acknowledges. As described in Section 3  Comments and Responses
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Section 3.6 of the Draft EIR, the traffic study completed for the project addresses six intersections located near the project site, as shown in Figure 3.6-2 of the Draft EIR, and concludes, based on substantial evidence that no significant impacts to any of those intersections would occur.

Response 3-25
Both of the subject intersections (Dayton Street/Fair Oaks Avenue and Dayton Street/Raymond Avenue) are addressed in Section 3.6 of the Draft EIR. As discussed therein, no significant impacts would occur at any of the intersections evaluated; hence, no mitigation measures for intersection impacts are warranted.

Response 3-26
Significant traffic impacts on Dayton Street are identified in Section 3.6 of the Draft EIR and, as indicated on page 3.6-45, no feasible mitigation measures are available to reduce those impacts. The issue of potential blockage of the site driveway on Dayton Street is addressed on page 3.6-49 of the Draft EIR and Condition of Approval COA-TRAN-1 is identified to avoid driveway blockage.

Response 3-27
The emergency access on the Dayton Street segment is discussed on page 3.6-49 of the Draft EIR, with the City’s Fire Department stating that Fair Oaks Avenue has been identified as the preferred and primary emergency access for this project, and that Dayton Street would only be used as a secondary emergency access for this project if circumstances warrant due to the fact that the project is at the corner of Fair Oaks Avenue and Dayton Street. The Fire Department has also recommended that the project driveway to the parking garage be located on Dayton Street to avoid potential conflicts between the project driveway and the primary emergency access location that would be on Fair Oaks Avenue.

The traffic study includes the existing apartment trips and the existing Castle Green trips on Dayton Street, which are part of the existing AM and PM vehicle count data, and included in the traffic analysis on page 12 and 13 in Appendix H of the Draft EIR, and in the Draft EIR itself on page 3.6-11 and 3.6-13.

Response 3-28
The discussion on page 3.6-50 of the Draft EIR indicates that the existing Pedestrian Environmental Quality Index and the Bicycle Environmental Quality Index scores will not be significantly impacted with implementation of the proposed project and in certain cases would be improved.

Response 3-29
As described on page ES-5 of the Draft EIR, the 11 areas of known controversy that are listed were taken into consideration in determining the scope of the EIR analysis, which, in turn, were all addressed in the six topical areas presented as Sections 3.1 through 3.6 of the Draft EIR, along with Section 4 (Alternatives) of the Draft EIR. Many of the specific notes provided by the commenter relative to each area of controversy are repeated elsewhere in the commenter's submittal. Provided below are responses to new/additional comments, as well as cross-references to responses to other comments addressed elsewhere in the submittal.

Response 3-30
The specific points bulleted in this comment are raised elsewhere in the comment letter, and thus addressed in the following Responses to Comments.

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 For Bullet 1, refer to Responses to Comments 3-4, 3-46, 3-48, 3-55, 3-70, and 3-71.  For Bullet 2, refer to Responses to Comments 3-9, 3-55, and 3-75.  For Bullet 3, refer to Responses to Comments 3-10, 3-59, and 3-74.  For Bullet 4, refer to Responses to Comments 3-9, 3-48, 3-59, 3-70, and 3-71.  For Bullet 5, refer to Response to Comment 3-9.

Response 3-31
The specific points bulleted in this comment are raised elsewhere in the comment letter, and thus addressed in the following Responses to Comments.
 For Bullet 1, refer to Responses to Comments 3-23, 3-26, and 3-43.  For Bullet 2, refer to Response to Comment 3-84.
 For Bullet 3, refer to Responses to Comments 3-84 and 3-87.  For Bullet 4, refer to Responses to Comments 3-84 and 3-87.  For Bullet 5, refer to Responses to Comments 3-23, 3-26, and 3-43.

Response 3-32
The specific points bulleted in this comment are raised elsewhere in the comment letter, and thus addressed in the following Responses to Comments.
 For Bullet 1, refer to Responses to Comments 3-43, 3-52, and 3-84.  For Bullet 2, refer to Responses to Comments 3-43 and 3-52.  For Bullet 3, refer to Response to Comment 3-47.

Response 3-33
The specific points bulleted in this comment are raised elsewhere in the comment letter, and thus addressed in the following Responses to Comments.
 For Bullet 1, refer to Responses to Comments 3-41, 3-42, and 3-58.  For Bullet 2, refer to Responses to Comments 3-41, 3-42, and 3-58.  For Bullet 3, refer to Responses to Comments 3-27 and 3-58.  For Bullet 4, refer to Responses to Comments 3-41, 3-58, and Topical Response TR-ALT-1.  For Bullet 5, refer to Responses to Comments 3-25, 3-27, and 3-28.  For Bullet 6, refer to Responses to Comments 3-25, 3-27, 3-28, 3-41, 3-42, 3-58, and 3-85.

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Response 3-34
The specific points bulleted in this comment are raised elsewhere in the comment letter, and thus addressed in the following Responses to Comments.
 For Bullet 1, refer to Responses to Comments 3-44 and 3-57.  For Bullet 2, refer to Responses to Comments 3-3, 3-11, 3-12, 3-44, 3-51, 3-57, and Topical Response TR-CR-1.
 For Bullet 3, refer to Responses to Comments 3-3, 3-11, 3-66, and 3-95.  For Bullet 4, refer to Responses to Comments 3-44, 3-57, 3-95 and Topical Response TR-ALT-1.  For Bullet 5, refer to Responses to Comments 3-3, 3-6, 3-11, 3-49, 3-57, and 3-95.  For Bullet 6, refer to Responses to Comments 3-44 and 3-51.  For Bullet 7, refer to Responses to Comments 3-44, 3-65, and 3-66.

Response 3-35
With one exception, the specific points bulleted in this comment are raised elsewhere in the comment letter. The only item in this comment that is not raised elsewhere in the letter is the second bullet point alleging that the entire block where the project site is located should be shown on maps as being on the National Register, as well as the entirety of the Old Pasadena District. In that regard, the discussion on pages 3.3-16 through 3.3-17 of the Draft EIR, and accompanying Figure 3.3-9, correctly describe how the structures within the subject block contribute to the Old Pasadena District, while, as noted on page 3.3-19, vacant lots, such as the project site, are considered to be non-contributing resources. Regarding the suggestion to outline all of the Old Pasadena District, the discussion on page

3.3-15 describes the boundaries of the District, and the map on page 32 of Draft EIR Appendix E shows the boundaries of the entire District. Please see Responses to Comments 3-51 and 3-67 regarding the other bulleted items in this comment.

Response 3-36
With one exception, the specific points bulleted in this comment are raised elsewhere in the comment letter. The only item in this comment that is not raised elsewhere in the letter is the third bullet point that the Draft EIR does not address impacts to views from existing historic buildings. In that regard, CEQA emphasizes evaluation of visual resources that are visible from public places, like streets, sidewalks, and parks, and is not intended to protect private views, such as those that may be available from existing private property/buildings. For the other bulleted items in this comment, please refer to the following Responses to Comments.
 For Bullet 1, refer to Responses to Comments 3-79 and Topical Response TR-AES-1.  For Bullet 2, refer to Response to Comment 3-79.
 For Bullet 3, refer to Responses to Comments 3-95, 3-96, 3-97, and Topical Response TR-AES-1.  For Bullet 4, refer to Responses to Comments 3-95, 3-96, 3-97, and Topical Response TR-AES-1.

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Response 3-37
The specific points bulleted in this comment are raised elsewhere in the comment letter, and thus addressed in the following Responses to Comments.
 For Bullet 1, refer to Responses to Comments 3-90 and 3-95.  For Bullet 2, refer to Responses to Comments 3-90, 3-91, 3-92, and Topical Response TR-ALT-1.  For Bullet 3, refer to Responses to Comments 3-90 and 3-92.  For Bullet 4, refer to Response to Comment 3-89, and also note that transfer of development rights are not allowed within the Central District Specific Plan area where the project site is located.
 For Bullet 5, refer to Responses to Comments 3-80 and 3-102.

Response 3-38
The specific points bulleted in this comment are raised elsewhere in the comment letter, and thus addressed in the following Responses to Comments.
 For Bullet 1, refer to Responses to Comments 3-7 and 3-98.  For Bullet 2, refer to Responses to Comments 3-7 and 3-49.  For Bullet 3, refer to Response to Comment 3-61.

Response 3-39
The specific points bulleted in this comment are raised elsewhere in the comment letter. Please see Responses to Comments 3-15 and 3-19 which address the bulleted items in this comment.

Response 3-40
Please see Response to Comment 3-15. Also note that, as indicated on page 3.5-11, vibration levels associated with loaded trucks, along with large bulldozers and other such equipment, were accounted for in the impacts analysis. Regarding the excavation of earth near existing structures, it is anticipated that shoring will be used, where appropriate as will be determined by a structural engineer and the Building Official prior to issuance of a building permit for the project.

Response 3-41
The Draft EIR does not say both, or either, of the subject intersections will be problematic. As documented in Section 3.6 of the Draft EIR, no significant impacts would occur at those intersections and the existing Pedestrian Environmental Quality Index and the Bicycle Environmental Quality Index scores in areas around the project site will not be significantly impacted with implementation of the proposed project and in certain cases would be improved.

Response 3-42
The fire station signal on Fair Oaks Avenue is intended to facilitate emergency vehicles exiting the fire station. The flashing beacon near the fire house is not a signalized or an unsignalized intersection. The flashing beacon is used to warm motorists that a fire engine is responding to an emergency and will exit the fire house. During operation, the signal stops traffic for just enough time for the emergency vehicles and equipment to exit the structure. Accordingly, this is not a typical traffic signal since it Section 3  Comments and Responses
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does not operate on a regular basis. Further, the configuration of the intersection of Dayton Street and Fair Oaks Avenue and the emergency signal would not change with implementation of the project, nor would the functionality of the emergency signal and the response pattern of traffic change.

Accordingly, the project would not change the existing scenario. Nor would the introduction of project traffic into the emergency signal area impact the ability of the emergency signal to function appropriately. Finally, it is assumed that traffic from the project would respond as required when the emergency signal is in operation, and there is no evidence to rebut that assumption, nor is there evidence that additional traffic on Fair Oaks Avenue, or Dayton Street, or at their intersection, would impede the operation of the emergency signal.

The street segment of Fair Oaks Avenue between Dayton Street and Del Mar Boulevard is a four-lane roadway with higher capacity than any of the other street segments that have been analyzed. The net increase in traffic on that segment is expected to be less than one percent because the segment of Fair Oaks Avenue north of the segment in question is less than one percent, well under the 4.9 percent threshold that triggers consideration of project alternatives. An additional 1,000 trips would be needed to generate a significant impact on Fair Oaks Avenue. The project generates well below 1,000 average daily trips on Fair Oaks Avenue. Therefore, the street segment of Fair Oaks Avenue between Dayton Street and Del Mar Boulevard was not included as part of the traffic study.

Response 3-43
The Fire Department is aware of the existing and future impacts of the proposed project as well as the Alternative 2 scenario, and the Fire Department has no issues or concerns regarding the safety access on Dayton Street, Fair Oaks Avenue, or the project site itself. The City has numerous locations where streets are not in compliance with the current Fire Code. The City has past practice allowing nonconforming streets to continue to exist and does not burden new projects with requirements to provide fire access when there is alternative fire access provided. In this case, Fair Oaks Avenue has been identified by the Fire Department as the preferred and primary emergency access for this project because it is a larger street and has a larger water main than Dayton Street. Dayton Street would only be used as secondary emergency access for this project if circumstances warrant due to the fact that the project is at the corner of Fair Oaks Avenue and Dayton Street. Because Fair Oaks Avenue would be the primary emergency access for the project, the Fire Department has recommended that access to the project’s parking garage be from Dayton Street to avoid potential conflicts between the project driveway and the primary emergency access location on Fair Oaks Avenue. Any future construction on Dayton Street shall comply with the requirements of California Fire Code (CFC) (Pasadena Fire Chief, August 2014).

Traffic concerns and impacts at both Dayton Street intersections were adequately studied, and the analysis indicated the two intersections (Dayton Street at Fair Oaks Avenue and Dayton Street at Raymond Avenue) would operate at an acceptable level of service (LOS A) with and without the project, as discussed on pages 11 and 34 of the traffic study included in Appendix H of the Draft EIR.

Response 3-44
As indicated on page 2-15 of the Draft EIR, the height, floor area ratio, and setbacks of the proposed project meet the development standards for the CD-1 zoning district. As such, the development plan for the project site complies with the existing zoning requirements, and there are no significant impacts that warrant consideration of building setbacks different than those currently proposed.

Additionally, the project applicant cannot be forced into a Variance situation, notwithstanding that it would be unlikely that the findings necessary to grant such a Variance could be met.

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Response 3-45
As stated on page 3.1-17 of the Draft EIR...” while the proposed project would affect private views from certain residences in the Castle Green and Green Hotel Apartment building, CEQA emphasizes evaluation of visual resources that are visible from public places, like streets, sidewalks, and parks." Impacts to such public views are addressed in the Draft EIR and supplemented with additional discussion and visual simulations provided in this Responses to Comment document.

Notwithstanding, it should be noted that the mature tree canopy visible from Castle Green, the existing Green Hotel Apartments, and offsite areas to the south and southwest is concentrated in the area immediately west of, and on the same property as, Castle Green, which will not be affected by the proposed project, The attached figure, which supplements Figure 2-3 in the Draft EIR provides an oblique aerial view looking northward, which shows the existing vegetation at and near the project site. As shown, the predominant lush green canopy, which the commenter may be referring to, is immediate to Castle Green and outside of the project boundary. The existing vegetative canopy within the project site is characterized by several pockets of trees dispersed within the existing surface parking lot that covers the vast majority of the site. As described in Section 3.1 of the Draft EIR, the loss of onsite trees, being those that cannot be saved in-place or transplanted elsewhere within the site, would be mitigated through replacement trees planted onsite. It should also be noted that the visual impacts discussion on page 3.1-17 of the Draft EIR indicated that, from the perspective of Castle Green residents, the proposed project would obstruct views to the west, which currently include views of the Doty Block building, the former Ambassador College campus, Vista del Arroyo Hotel and Bungalows, Verdugo Mountains, and the San Rafael Hills. See also Topical Response TR-AES-1 Potential View Impacts.

Response 3-46
Notwithstanding that tree foliage such as that currently at the Project site provides minimal sound attenuation, implementation of the project includes replacement and relocation of existing trees.

Based on the low speeds at which vehicles would be operating at the Project driveway, minimal vehicle noise levels would be generated. Moreover, the noise exposure at Castle Green and the Green Hotel Apartments associated with the Project-related 626 trips per day would be more than offset by the shielding of traffic noise from the existing 20,690 average daily trips on Fair Oaks Avenue that would occur with development of the Project building, which would be an intervening noise barrier. A building height reduction, setback on Dayton Street, and/or dual-driveway scenario would not lessen noise impacts. No operations-related noise mitigation is warranted given that there are no significant noise impacts.

Regarding the creation of an “echo chamber” as suggested in the comment, it should be noted that there would be over 150 feet of separation between Castle Green and the proposed building. As shown in the visual simulations presented in Figures 3.1-4 through 3.1-6 and 3.1-11, the exterior of the proposed building has numerous protrusions and other architectural features that “break up” the exterior finish, which will serve to diffract any sound waves extending to the building. Additionally, substantial landscaping, including numerous existing and proposed trees, will occupy the area between the proposed building and Castle Green, especially around the proposed driveway and parking ramp as shown in Figure 2-5b, which has been added in the Final EIR. To the extent that landscaping, such as the tree canopy serves as a “positive filter,” as suggested by the commenter, such would still be the case with project implementation. Based on the above, no significant impacts related to a potential “echo chamber” are anticipated to occur.

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Response 3-47
Figure 2-5 in the Draft EIR was a preliminary site plan that was subsequently updated to include minor refinements to the surface parking layout, landscaping, and other ground level features. The updated site plan, presented herein as Figure 2-5a, delineates the location and intended use of the 20 parking spaces proposed at surface level. The comment provides no indication as to how or why the provision of covered parking, versus uncovered parking, would create visual and/or noise impacts that are not already addressed in Sections 3.1 and 3.5, respectively, of the Draft EIR. The commenter’s question of why isn’t all of the parking underground, instead of having any surface parking, is a design issue and not an environmental issue requiring analysis in the EIR. Regarding underground parking, a total of 147 parking spaces are shown on Figures 2-6 and 2-7 of the Draft EIR, with 78 spaces on Level 1 and 69 spaces on Level 2.

Response 3-48
Light and glare impacts, including impacts associated with vehicle headlights, are addressed in Section 3.1 of the Draft EIR.

Response 3-49
As indicated by the figures contained in Appendix B, shade impacts on adjacent buildings would generally be limited to mid- to late-afternoon, depending on time of year, and, as also reflected in those figures, there is a substantial amount of open area between the proposed Project building and adjacent structures, which would continue to allow for air flow between buildings. The commenter provides no substantial evidence in support of the claim that implementation of the proposed Project would result in increased energy usage at existing buildings in the vicinity of the Project.

Response 3-50
All comments have been carefully reviewed and considered, and written responses have been prepared for all comments. The Draft EIR and the written responses to comments on the Draft EIR, along with other information contained in this Final EIR, meet the requirements of CEQA for the City to consider action on the Project.

Response 3-51
Section 2.5 of the Draft EIR describes the existing General Plan land use and zoning designations applicable to the Project site. Section 3.3 of the Draft EIR addresses historic resource considerations, including issues pertaining to the National Register of Historic Places.

Response 3-52
The comment offers an opinion regarding the appropriateness of the project objectives and does not raise any new environmental issues. That opinion is included as part of the Final EIR, which will be considered by decision makers in taking action on the Project.

Response 3-53
Similar to above, the commenter's opinion regarding the relationship between the project objectives and the alternatives is so noted and is included in the Final EIR.

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Response 3-54
The existing composition of the 32,362 square-foot project site is described in Section 2.2 of the Draft EIR, which includes a surface parking lot with 60 parking spaces, a billboard, concrete pathways, benches, an outdoor eating area, and 20 trees. The first sentence of the second full paragraph on page 2-14 is hereby revised to read:

Response 3-55
Section 3.1 of the Draft EIR provides the analysis and substantial evidence for concluding that the impact associated with the loss, replacement, or relocation of existing trees onsite in compliance with the Tree Protection Ordinance would be less than significant impact. There is no basis for further evaluating alternatives to reduce that impact. Additionally, it should be noted that the comment is incorrect in stating that the proposed project would eliminate the existing 45-75 foot mature tree canopy. As indicated in Table 3-2, as revised in Response to Comment 3-74 below, eight of the 23 existing trees located within or directly adjacent to the project site would remain in place or would be relocated within the project site. Also, the existing trees located directly adjacent to the west side of Castle Green, east of the project site, that are in addition to the 23 trees noted above would be unaffected by the project and would remain in place.

Response 3-56
The questions regarding the amount of surface parking proposed, as opposed to putting all parking underground, is a design issue and not an environmental issue requiring analysis in the EIR. Surface parking is not prohibited in the Zoning Code and the design ensures that surface parking will not be seen from Fair Oaks Avenue, in compliance with design guidelines in the Central District Specific Plan.

Response 3-57

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Pasadena City CouncilApril 11, 2022

Pasadena City Council
April 11, 2022