comply with applicable zoning requirements. Historic resource considerations are addressed in Section 3.3 of the Draft EIR and Topical Response TR-CR-1 of this Final EIR, and traffic considerations are addressed in Section 3.6 of the Draft EIR.
Response 3-58
Traffic considerations are addressed in Section 3.6 of the Draft EIR. The comment provides no explanation, facts, or analysis regarding how or why the traffic analysis is not adequate. No significant impact was identified in the traffic study at the intersections of Dayton Street and Fair Oaks Avenue or Dayton Street and Raymond Avenue.
Response 3-59
As indicated in Response to Comment 3-74, five of the 18 protected trees would be saved in-place, three of the protected trees would be boxed and transplanted within the project site, and the remaining ten protected trees would be removed and replaced onsite. As discussed in Response to Comment 3-45, the predominant lush canopy visible from the existing Green Hotel Apartments and Castle Green towards the project site is at the western end of the Castle Green site, which would not be affected by the proposed project. Additionally, as noted above, eight of the existing mature trees Section 3 Comments and Responses
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located within or directly adjacent to the project site would remain in place or be relocated within the project site. 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 (see Figure 2-3a included with Response to Comment 3-45). Between the preservation/on-site transplantation of eight existing protected trees and the mitigation of the removal of ten remaining protected trees with 32 replacement trees that will be planted onsite, it is anticipated that the amount of existing canopy area associated with the existing protected trees will be maintained if not expanded with implementation of the proposed project.
Response 3-60
The potential to encounter significant subsurface historic archaeological resources during excavation activities was addressed in Section II.7 of the Initial Study contained in Appendix A of the Draft EIR and concludes that there would be no potential adverse effect on archaeological resources as a result of the project. However, to address this comment, the following condition of approval will be added to the project to clarify the “standard feature within the construction contract” referenced in the Initial Study:
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.
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Response 3-61
Construction-related air quality impacts and noise/vibration impacts are addressed in Sections 3.2 and 3.5, respectively, of the Draft EIR.
Response 3-62
The updated site plan referenced in Response to Comment 3-47 as a replacement for Figure 2-5 of the Draft EIR identifies the locations of various uses, including the gym and retail uses, proposed on the ground floor and also shows the location of the underground parking access ramp (southeast portion of site) and the nearby driveway connecting with Dayton Street. No significant impacts were identified relative to the proposed surface parking and other associated paved areas; consequently, there is no need to address alternatives for that area.
Response 3-63
The need for, and nature and location of, building storage are not environmental issues; no response is required. The Zoning Code does not require provision of dedicated storage areas.
Response 3-64
In general, the sizes of the proposed apartments are expected to range from approximately 640 sf to approximately 960 sf on most floors, and between approximately 940 sf and approximately 1,645 on the top floor. While the floor area of the individual apartments shown in Figures 2-8 through 2-10 vary by unit type and location, the specific size of each apartment does not pertain to environmental issues. Table 2-2 in the Draft EIR indicates the parking requirements for the proposed apartments, including a breakdown of apartments less than 650 sf and greater than 650 sf. Vehicle trip generation for apartments is by unit count (i.e., 64 units), not unit size, as shown in Table 8 of the traffic study contained in Appendix H of the Draft EIR.
Response 3-65
The elevations presented in Figures 2-11 and 2-12 of the Draft EIR are drawn to scale and include specific call-outs of building heights. The reader is provided clear and accurate information to draw conclusions regarding the relationships between existing and proposed buildings. In regards to the comment regarding the Secretary of the Interior’s Standards, see Topical Response TR-CR-1.
Response 3-66
The comment offers an opinion regarding the height of new and proposed buildings within the Old Pasadena sub-district and does not raise any new environmental issues. That opinion is included as part of the Final EIR, which will be considered by decisionmakers in taking action on the Project.
See also Topical Responses TR-CR-1 and TR-AES-1 regarding historic resources and aesthetics, respectively.
Response 3-67
The commenter’s statement is incorrect. Central Park is not currently listed in the National Register as an individual resource, but rather is a contributor to the Old Pasadena National Register Historic District. This was verified by searching for the property in the National Register’s online database and contacting the South Coast Information Center.
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Response 3-68
Section 3.1 of the Draft EIR pertains to aesthetics considerations while Section 3.3 addresses cultural/historic resources. The information contained in the comment is already reflected in Section
3.3 and is not required to be in Section 3.1.
Response 3-69
As is evident in many of the site photographs presented in Section 3.1 of the Draft EIR, especially the aerial photo in Figure 3.1-3, as well as in Figure 2-3a added as part of the Final EIR, the large tree canopy immediately adjacent to Castle Green and the tree canopy within the project site are clearly within the viewshed looking west from Castle Green. As indicated above in Response to Comment 3-45, however, CEQA emphasizes evaluation of visual resources that are visible from public places, like streets, sidewalks, and parks. The views noted in the comment are private views.
Response 3-70
The subject statement on page 3.1-3 of the Draft EIR is a fair and accurate characterization of the nighttime lighting levels in the areas surrounding the project site as visible to the public, which is the topic at hand in Section 3.1.2.3, whereas the commenter is describing an isolated interior portion of the project site available to private views of existing residents. As indicated above in Response to Comment 3-45, CEQA emphasizes evaluation of visual resources that are visible from public places, like streets, sidewalks, and parks.
Response 3-71
For the same reason described above in Response to Comment 3-70, the description of daytime glare provided on page 3.1-3 of the Draft EIR is considered a fair and accurate characterization of existing conditions in areas surround the project site as visible to the public, as opposed to limited private views of existing residents. As indicated above in Response to Comment 3-45, CEQA emphasizes evaluation of visual resources that are visible from public places, like streets, sidewalks, and parks.
Response 3-72
Comment noted. The last sentence in the second paragraph on page 3.1-3 of the Draft EIR is hereby revised as follows:
There are no distant views of the San Gabriel Mountains available within the vast majority 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.
Response 3-73
The nature, location, and visibility of existing trees located on and near the project site are described in Section 3.1.2 of the Draft EIR and project-related impacts to views of those trees are addressed in Section 3.1.6. In addition to the discussion on pages 3.1-26 and 3.1-27, under the heading Trees and Landscaping, view impacts specific to project-related removal or relocation of trees are discussed on page 3.1-15 relative to Vantage Point 1 and page 3.1-17 relative to Vantage Point 3. Other related discussions also appear on pages 3.1-24 and 3.1-25. Evaluation of the existing trees relative to their age and potential historic significance is provided in Section 3.3 of the Draft EIR and, as indicated on page 3.3-25, and substantiated by Appendix E (Tree Aging Report), the trees that would be impacted by the proposed project are not considered historic resources. Based on the analysis and substantial Section 3 Comments and Responses
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evidence provided in the Draft EIR, the project-related impacts to the onsite trees were determined to be less than significant.
Response 3-74
As indicated in the last paragraph on page 3.1-3 of the Draft EIR, which introduces and references Figure 3.1-1 and Table 3-1, there are 20 trees that occupy the project site (Note: Only the 20 trees shaded in brown and tan on Figure 3.1-2 in the Draft EIR occur within the site boundary of proposed development - the three trees shaded in green occur outside that boundary) and, of those 20 trees 15, of them are protected under the City Trees and Tree Protection Ordinance, which are listed in Table 3-1 of the Draft EIR. Figure 3.1-1 and Table 3-1 have been revised in conjunction with preparation of the Final EIR to further clarify this information, as well provide some corrections to the labeling or protected versus non-protected trees. The revised figure follows on the next page and the revised table is presented below.
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 camphora1 Camphor 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 Filfera 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 Romanzoffiana1 Queen Palm ~11 ~12 Protected Street Tree 23 Syagrus Romanzoffiana1 Queen 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).
Table 3-2 on page 3.1-26 of the Draft EIR has also been revised in order to match the tree numbering and other data in the revised Table 3-1, as well clarify the disposition of protected trees with Section 3 Comments and Responses
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implementation of the proposed project (i.e., identify which protected trees will be saved in-place, which protected trees will be boxed and transplanted elsewhere within the project site, and which protected trees will be removed and mitigated through replacement in accordance with the City Trees and Tree Protection Ordinance). Revised Table 3-2 is as follows:
Table 3-2 Summary Disposition of 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 Filfera 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
37 Washingtonia Robusta Mexican Fan Palm 16 ~65 X
38 Washingtonia Robusta Mexican Fan Palm 16 ~75 X
As related to the above revisions to Table 3-2 of the Draft EIR, Table 2-1 on page 2-2 of the Draft EIR, which provides essentially the same information as Table 3-2, is hereby revised as follows:
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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 Filfera 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
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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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Response 3-75
Figure 3.1-2 in the Draft EIR is intended and designed to depict, using a common symbol, the locations of the existing trees onsite. The analysis of tree impacts took into account the type and size of each tree, as did also the basis of mitigation for loss of trees. The aerial photographs of the project site shown in Figure 3.1-3 of the Draft EIR and Figure 2-3a, added as part of the Final EIR, illustrate the existing tree canopy.
Response 3-76
Please see Response to Comment 3-74 above, which includes a revised Figure 3.1-2 that shows there are 13 protected trees that will be removed or boxed and transplanted on the site, and five protected trees that will be saved in-place.
Response 3-77
As indicated above in Response to Comment 3-45, CEQA emphasizes evaluation of visual resources that are visible from public places, like streets, sidewalks, and parks. The views noted in the comment are private views, wherein CEQA emphasizes public views. Nonetheless, impacts on private views from the existing Green Hotel Apartments and Castle Green buildings are considered on page 3.1-17 of the Draft EIR. In conjunction with preparation of this Final EIR, additional viewpoints were modeled and evaluated - please see Topical Response TR-AES-1. The Draft EIR analysis concluded that aesthetics impacts, including view impacts, associated with project implementation would be less than significant.
Response 3-78
The shade and shadow impacts of the project are discussed on pages 3.1-28 and 3.1-29 of the DraftEIR. This analysis concludes that, “While implementation of the proposed project would result in new shadows being cast on light-sensitive uses, the project is being constructed in an urban environment, immediately adjacent to existing buildings of comparable massing and height, and would be constructed consistently with the zoning and site development standards applicable to the parcel, including those that regulate height and mass. As such, while new shading and shadow patterns would occur, impacts would be less than significant.” Please also see Responses to Comments3-6 and 3-49 regarding shade and shadow impacts and Responses to Comments 3-45 and 3-77 regarding impacts on private views.
Response 3-79
The four vantage points selected for the preparation of visual simulations represent locations where the visibility of project development would be most prominent and the attendant impacts would be greatest, which provided a conservative (i.e., worst-case) disclosure of project impacts. The Draft EIR analysis, specifically Section 3.1, 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, to also represent the fact that project implementation would not obstruct views from several other nearby locations. Beyond the many view locations addressed in the Draft EIR, additional vantage points were evaluated in conjunction with preparation of the Final EIR- please see Topical Response TR-AES-1. That additional evaluation of view impacts further support the Draft EIR conclusion that view impacts would be less than significant with project implementation. It should also be noted that many of the potential impact concerns expressed in the comment pertain to private views, such as from Castle Green. 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. However, despite Section 3 Comments and Responses
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CEQA’s emphasis on public views, impacts on private views from the existing Green Hotel Apartments and Castle Green buildings are considered on page 3.1-17 of the Draft EIR.
Response 3-80
A reasonable range of alternatives was identified and addressed in the Draft EIR - please see Topical Response TR-ALT-1. In all cases, however, none of the feasible alternatives were found to avoid or substantially lessen the one significant impact associated with project implementation - that unavoidable significant impact being the project-related traffic volumes on Dayton Street. All other impacts associated with the proposed project were either less than significant or were reduced to less than significant through specific conditions of approval and mitigation measures identified in the Draft EIR.
Response 3-81
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 decisionmakers in taking action on the Project.
Response 3-82
The commenter’s opinions that the current project proposal is an improvement over the 2007 proposal and that the proposed project and Alternative 2 have too many unmitigated impacts are so noted and are included in the Final EIR for consideration by decisionmakers. It should also be noted, however, there is only one unavoidable significant impact of the proposed project and Alternative 2, which is the traffic segment impact on Dayton Street.
Response 3-83
The mitigation referenced on page 4-3 of the Draft EIR pertains to the mitigation measures and conditions of approval described in detail within Section 3 of the Draft EIR; specifically, Sections 3.2,
3.4, and 3.6. The alternatives considered but dismissed as infeasible are specifically described and addressed in Section 4.4 of the Draft EIR.
Response 3-84
As indicated in the memorandum from the Pasadena Office of the Fire Marshall, provided in Appendix I of the Draft EIR, "Fire apparatus access roads shall have an unobstructed width of not less than 20 feet exclusive of shoulders as defined in the California Fire Code (CFC) Section 503.2.1.
Dayton Street is an established public street and complies with the requirements of CFC." The fact that the existing dimensions of Dayton Street meets the requirements of the CFC applies to both the proposed project and the No Project Alternative.
Response 3-85
The comment generally, but not fully, reflects the conclusions of the Draft EIR analysis of Alternative 2.
As described in Section 4.6.2.7 of the Draft EIR, Alternative 2 has the potential to result in fewer environmental impacts when compared to the proposed project due to the fact that the building would be reduced in size and scale and be occupied by fewer residents. Specifically, this alternative would result in fewer operational air quality, GHG, noise and vibration, and transportation and traffic impacts; however, the reduction of the number of vehicle trips generated by the Reduced Height Alternative is not enough to avoid the significant impact to the Dayton Street segment between Fair Oaks Avenue and Raymond Avenue. In summary, the only unmitigated significant impact Section 3 Comments and Responses
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associated with the proposed project would be traffic on Dayton Street, a significant impact that would be lessened, but not avoided, under Alternative 2.
Response 3-86
The comment offers an opinion regarding the formulation of alternatives and does not raise any new environmental issues. That opinion is included as part of the Final EIR, which will be considered by decisionmakers in taking action on the project.
Response 3-87
The right-of-way along Fair Oaks Avenue and the available on-street parking only allows for two travel lanes in each direction. The on-street metered parking on Fair Oaks Avenue is essential for the nearby businesses, and removal of this parking supply could have secondary impacts, both environmental and economic. Nonetheless, removal is discussed herein in response to this comment.
Removing a portion of on-street parking in this segment would not be sufficient to allow the proper alignment distances to add a southbound left-turn lane. Therefore, all on-street parking along Fair Oaks Avenue between Green Street and Dayton Street would need to be removed to allow the reconfiguration and alignment of the southbound left-turn lane and all through lanes. This would also affect the alignment of lanes at the intersection of Fair Oaks Avenue and Green Street, creating a short distance from the left-turn lane and Green Street, with potential backup of vehicles into the intersection. This would create vehicle congestion and the slowing of traffic by creating a “chokepoint” along Fair Oaks Avenue.
A Fair Oaks Avenue access would not mitigate the significant impact on Dayton Street because at least 44 cars per day would be expected to use Dayton Street to reach the Fair Oaks Avenue access, as discussed in detail in Response to Comment 2-6. Given that significant impacts could not be avoided with the Alternate Access Alternative, a Dayton Street access is preferred over a Fair Oaks Avenue access.
In addition, access from Fair Oaks Avenue, which is a designated multi-modal corridor, would conflict with the City of Pasadena DOT’s adopted Driveway Design Guidelines (March 2011) and the Central District Specific Plan, as follows:
Driveway Design Guidelines (March 2011), Section IV- DOT may require the relocation of proposed driveways in order to minimize conflicts between pedestrians, and vehicular traffic from the parking facility and the abutting street system. The public interest requires optimum capacity of streets to carry all modes of travel including pedestrians, bicycles and transit with minimum potential for traffic accidents. Driveways may not be permitted along multi-modal corridor streets (unless deemed necessary by DOT) where; access is possible using an alley or non-multi-modal corridor street, or the proposed development is industrial or commercial, and at the intersection of the multi-modal corridor streets with a non-multi-modal corridor streets, or access is possible along the non-multi-modal corridor streets frontage. The Central District Specific Plan discusses in Section 5 how multi-modal corridors are meant not just for vehicles but pedestrian, cycling, etc. Multimodal Corridors: A number of Downtown streets are classified by the City-wide Mobility Element as “Multimodal Corridors” with the intent that these routes will support higher traffic volumes while their use will minimize impacts on Pasadena’s residential neighborhoods. In accordance with their multimodal character, these routes need to accommodate other modes of travel, especially transit and pedestrian movement. The Land Use Concept recognizes multimodal corridors as principal Section 3 Comments and Responses
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movers of people and traffic, and therefore, the highest permissible development intensities are generally assigned along these streets. The Specific Plan states that multimodal corridors should accommodate other modes of travel. Adding a driveway introduces an additional conflict point to pedestrians, thereby, going against the CDSP. Reference District-wide Map 20:
Multimodal Corridor Concept.
In addition, the Fire Department has recommended that the project take access from Dayton Street to avoid potential conflicts between the project driveway and the primary emergency vehicle access to the project site along Fair Oaks Avenue.
Response 3-88
As a new development, the proposed project is required to meet applicable code requirements including the provision of on-site parking. The fact that existing uses nearby, such as Castle Green, were developed prior to adoption of current zoning requirements and are "grandfathered" to not meet current requirements, does not relieve the proposed project from meeting current requirements. In addition to not meeting current zoning requirements, this alternative was considered infeasible given the fact that capacity at the two parking structures near the project site has been reached and forcing residents to park over 1,000 feet (several blocks) away does not make sense. The Draft EIR addresses an off-site parking alternative and two reduced size alternatives, as well as several other alternatives, none of which were found to be feasible and avoided or substantially reduced the one unavoidable significant impact of the project.
Response 3-89
Please see Topical Response TR-ALT-1 for a discussion regarding the decision not to analyze an off-site alternative. A reasonable and appropriate level of inquiry was completed relative to identification of a potential alternative site for the proposed project. It is not necessary for the applicant to investigate a myriad of possibilities such as follow-up with other property owners in the local area regarding potential land purchases or land swaps. The transfer of development rights for the project site is not allowed under the City’s Zoning Code.
Response 3-90
Please see Topical Response TR-ALT-1 for a discussion regarding the problems associated with a smaller scale alternative, an alternative access alternative, and various mixes and proportions of residential uses and commercial uses that would still trigger a significant traffic impact on Dayton Street.
Response 3-91
Section 15126.6 of the CEQA Guidelines requires an EIR to identify any alternatives that were considered by the lead agency but were rejected as infeasible during the scoping process and briefly explain the reasons underlying the lead agency’s determination. That is what was done in Section 4.4 of the Draft EIR relative to consideration of alternatives that were considered but rejected as infeasible.
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Response 3-92
In accordance with CEQA requirements, a reasonable range of alternatives were considered in the Draft EIR for the proposed project - please see Topical Response TR-ALT-1 which demonstrates that only a very small commercial or mixed-use project would alleviate the traffic impact on Dayton Street.
Response 3-93
It is unclear as to what the nature is of the comment; no response is possible.
Response 3-94
Please see Responses to Comments 4-7 through 4-18 regarding comments prepared by Tom Brohard.
Response 3-95
As described in Section 4.6.2.7 of the Draft EIR, implementation of the Reduced Height Alternative would result in reduced impacts to air quality, GHG, noise and vibration, and transportation and traffic impacts compared to the proposed project, but would not avoid or substantially lessen the one unavoidable significant impact associated with the project (i.e., traffic on Dayton Street). Evaluation of this alternative, along with the No Project Alternative, responds to the CEQA requirement to consider alternatives to the proposed project. Please see Topical Response TR-ALT-1 for additional discussion regarding the Draft EIR analysis of project alternatives.
Response 3-96
The Draft EIR text quoted by the commenter is specific to the analysis of aesthetics impacts associated with this alternative and is not indicative of the overall characteristics of the alternative. Contrary to the commenter's assertion, the Reduced Height Alternative is a reduction in the scope of development compared to the proposed project in that, in conjunction with the reduction of two stories in building height, the number of proposed apartment units would be reduced from 64 to 42 and the number of underground parking spaces would be reduced from 147 to 131. Please see Topical Response TR-ALT-1 for additional discussion regarding the Draft EIR analysis of project alternatives.
Response 3-97
The subject text on page 4-8 of the Draft EIR is true and accurate as stated, based on substantial evidence provided therein. Although it is possible that partial views of the turrets may be possible as one moves farther and farther to the west, the visual context in which the turrets may appear would be substantially different, and largely diminished, compared to the more representative views described in the Draft EIR (i.e., the visibility and prominence of the turrets viewed against other objects within the viewshed would become smaller and smaller as one moves farther to the west).
Please also see Topical Response TR-CR-1 for additional discussion regarding the Draft EIR analysis of impacts to historic resources, Topical Response TR-AES-1 for additional discussion regarding the Draft EIR analysis of visual impacts, and Topical Response TR-ALT-1 for additional discussion regarding the Draft EIR analysis of project alternatives. See also Responses to Comments 3-45 and 3-77 regarding impacts on private views.
Response 3-98
As discussed in Response to Comment 3-49, implementation of the proposed project is not expected to substantially reduce air flows around the existing Green Hotel Apartments or the Castle Green. Such would also be the case for the Reduced Height Alternative.
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Response 3-99
Section 3.3, along with Appendix A (EIR Initial Study) and Appendix D (Historic Resources Technical Report), of the Draft EIR provide a comprehensive evaluation of potential impacts to cultural resources, and conclude that implementation of the proposed project will not result in significant impacts to cultural resources. The discussion in Section 4.6.2 of the Draft EIR correctly notes and discloses that cultural resource impacts associated with the Reduced Height Alternative would be similar to those of the proposed project, which are less than significant in both cases. That comparative analysis meets the requirements of CEQA.
Response 3-100
The comment generally, but not fully, reflects conclusions of the Draft EIR. The discussion in Section 4.6.2.6 of the Draft EIR indicates that the traffic generation associated with the Reduced Height Alternative and the resultant impacts on Dayton Street would be less than those of the proposed project, but would not reduce the impact to a level that is less than significant. Contrary to the commenter’s statement, the traffic analysis for the project did not identify “unmitigated circumstances at Dayton & Raymond or Dayton & Fair Oaks.” The segment of Fair Oaks Avenue between Dayton Street and Del Mar Boulevard was not studied because Fair Oaks Avenue already has a high volume of traffic. If one already knows that the project’s incremental contribution to traffic on Fair Oaks Avenue is relatively low near the project site, it is not necessary to evaluate segments of Fair Oaks Avenue located farther from the project site.
Response 3-101
The Draft EIR includes consideration of the Smaller Scale Alternative that would avoid the one unavoidable significant impact of the proposed project, that being the traffic impact on Dayton Street; however, as indicated in Section 4.4.4 of the Draft EIR, that alternative is infeasible. The Draft EIR alternatives analysis satisfies the requirements of CEQA. Please see Topical Response TR-ALT-1 for additional discussion regarding the Draft EIR analysis of project alternatives.
Response 3-102
As indicated above in Response to Comment 3-101, the City considered an alternative that would avoid the unavoidable significant impact associated with the proposed project (i.e., traffic impact on Dayton Street); however, that alternative was determined to be infeasible. Please see Topical Response TR-ALT-1 for additional discussion regarding the Draft EIR analysis of project alternatives.
Response 3-103
The City has carefully considered the information contained in the Draft EIR, along with the comments received during the Draft EIR review period and the written responses to those comments, and has determined that preparation and circulation of a revised Draft EIR is not warranted.
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Letter No. 4 Chatten-Brown & Carstens LLP
Chatten-Brown & Carstens LLP
2200 Pacific Coast Highway, Suite 318
Hermosa Beach, California 90254
Douglas P. Carstens
March 10, 2014
Responses
Response 4-1
The Draft EIR impacts analysis takes into consideration the presence of the existing Green Hotel Apartments and Castle Green adjacent to the project site, including, but not limited to, potential view impacts, as addressed in Section 3.1 of the Draft EIR, and potential historic resources impacts, as addressed in Section 3.3 of the Draft EIR. Based on the substantial evidence provided therein, the Draft EIR analysis concluded that project implementation would not result in significant view or historic resource impacts.
Response 4-2
In compliance with CEQA requirements, the Draft EIR addressed a reasonable range of alternatives that could possibly avoid or substantially lessen the single unavoidable significant impact of the project, which was identified as the traffic impact on Dayton Street. Such alternatives are presented and evaluated in Section 4 of the Draft EIR. Alternatives considered but rejected as infeasible include Alternative Access Alternative, Off-Site Parking Alternative, Alternative Site Alternative, and Smaller Scale Alternative (see EIR, pp. 4-3 to 4.5). Alternatives analyzed in the EIR include the No Project Alternative, and Reduced Height Alternative, as these were the only two that could attain most of the basic project objectives at the same time as avoiding or reducing a potentially significant environmental effect. Alternative designs were not considered in the EIR because design in Pasadena is governed by the design review process set forth in PMC Section 17.61.030, and therefore design is not set through the EIR process. Please see Topical Response TR-ALT-1 for additional discussion regarding the Draft EIR analysis of project alternatives and TR-CR-1 for additional discussion regarding design review.
The EIR is intended to identify and disclose the environmental impacts of the project and of the alternatives. It is not intended to, nor does it recommend approval or rejection of the project or any of the alternatives evaluated. Thus, other than environmental impacts, the EIR does not consider the merits of the project or any alternatives, such as the economic, legal, social, technological, or other non-environmental factors that may be considered by decision makers when deciding whether to approve the project or a project alternative. While not included in the EIR itself, such information may be included in the administrative record.
Response 4-3
Implementation of the project, as currently proposed, would not result in significant impacts to biological resources, air quality and human health, and land use plans - see Draft EIR Appendix A-Initial Study Section II-6. Biological Resources; Draft EIR Section 3.2. Air Quality (including Human Health); and, Draft EIR Appendix A-Initial Study Section II-13. Land Use and Planning. As such, evaluation of alternatives to address those impacts is not warranted. The comment provides no critique nor does it pose any comment or question regarding this analysis. As described above in Response to Comment 4-2, the Draft EIR includes and addresses a reasonable range of alternatives to address the unavoidable significant traffic impact on Dayton Street.
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Response 4-4
The existing AM and PM peak hour traffic volumes along Dayton Street are approximately 0.8 vehicles per minute during the AM peak hour and 1.4 vehicles per minute during the PM peak hour.
Dayton Street would not be considered to be burdened with traffic as it currently serves parking for the existing Green Hotel Apartments, Castle Green trips, and on-street parking for Central Park. Not all traffic on Dayton Street is through traffic. Existing vehicle trips along Dayton Street and Fair Oaks Avenue have been accounted for in the existing traffic count data and included in all existing and future analysis scenarios.
Response 4-5
Implementation of the proposed project would not result in a violation of the Fire Code - please see Response to Comment 3-84 above.
Response 4-6
Comment noted. Chatten-Brown & Carstens, LLP will be included in notifications of public hearings or notices related to the proposed project.
Response 4-7
Comments noted. Please see Responses to Comments 4-9 through 4-17 below.
Response 4-8
Comments noted.
Response 4-9
The segment of Raymond Avenue between Green Street and Dayton Street would experience a
2.7 percent increase in ADT, which is not considered a significant impact per DOT guidelines (ADT over 4.9 percent is considered a significant impact). Regarding the possibility of mitigating the street segment impact on Dayton Street, no feasible mitigation measures are available to reduce those impacts; the only way to reduce the impact below a level of significance is to reduce the number of trips along this segment, which would require modification of the project scope as illustrated in topical response TR-ALT-1.
The condition of approval to install a regulatory sign at the project driveway along Dayton Street for the potential queuing along Dayton Street at Fair Oaks Avenue would be adequate to prevent motorists from blocking the driveway. The situation is no different from other apartment driveways on local Pasadena streets and does not require providing any special or preferred treatment from the Police Department. There is no evidence to support the contention that the Police Department would not enforce a regulatory sign at the subject driveway when the City has a history of responding to complaints about non-conformance with regulatory signs. The existing 14-foot-wide through-way traffic lane on a low-volume, low-speed street such as Dayton Street is adequate for two-way operations and the street currently operates adequately as a two-way street. Additionally, widening the roadway would lead to higher speeds on Dayton Street which is not desirable in an urban environment adjacent to a park.
Existing on-street parking conditions along Dayton Street should be maintained to support the Central Park as well as to calm traffic on the street, adjacent to the park. The widening of Dayton Street would be infeasible because it would take property from a historic park on the south or require dedication of six feet of right of way from the project site. This is infeasible because it would Section 3 Comments and Responses
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only address the impact on a portion of the block; the remaining portion on the north side is occupied by the historic Castle Green and could not be widened without significantly impacting the historic building. The widening of Dayton Street would not mitigate the significant impact because the project would still increase the street volumes by 70.9 percent.
Implementation of the proposed project would not result in a violation of the Fire Code; please see Response to Comment 3-43 above.
Response 4-10
All existing vehicle trips along Dayton Street have been accounted for in the existing turning movement traffic count data at both the Fair Oaks Avenue and Dayton Street and Raymond Avenue and Dayton Street intersections and included in all existing and future analysis scenarios. Per the project applicant, the existing driveway on Fair Oaks Avenue is not used for access to the existing parking lot and is always locked except for trash pickup; therefore, all trips associated with the existing parking lot are accounted for in the existing traffic counts. These existing volumes are illustrated on page 12 and 13 of the traffic impact study included in Appendix H of the Draft EIR as well as on pages 3.6-11 and 3.6-13 in the Draft EIR itself.
Response 4-11
Please see Response to Comment 3-42 above.
Response 4-12
Realigning the east leg of Dayton Street at Fair Oaks Avenue with the west leg of Dayton Street would significantly change the project site and significantly limit what can be developed in the remaining portions of the project site. Based on conversations with staff of the Department of Public Works, a minimum of 20 percent of the project site frontage along Dayton Street would be required to provide the curvature required for a safe transition from the east leg to the west leg of Dayton Street. The intersection would experience no significant impact as a result of the proposed project, so there is no nexus to require consideration of a realignment alternative. The comment alleges a past accident history at the intersection of Dayton Street and Fair Oaks Avenue without supporting factual evidence.
The impacts of this project are measured against the baseline as set forth in Section 3.6.2 of the Draft EIR and need not remedy alleged but undescribed accidents or their alleged propensity to occur at the intersection of Dayton Street and Fair Oaks Avenue. Realignment of the street would also potentially add traffic volume on Dayton Street. Further, the remedy of widening Dayton Street to the north and thereby intruding into the project site (and, potentially, the Castle Green site) is not part of the project description, would significantly and adversely impact the historic Castle Green site, and would not mitigate the traffic impact on Dayton Street because the project would still increase the volumes by 70.9 percent.
Response 4-13
The traffic study included in Appendix H of the Draft EIR, on pages 45 through 52, indicates that the existing pedestrian and bicycle environment conditions are at average to high quality for pedestrian walk-ability and bicycle conditions along Fair Oaks Avenue and Dayton Street. The project would not diminish the existing bicycle/pedestrian environment, and therefore, there is no nexus to require any mitigation. The project may activate the bicycle/pedestrian environment by providing additional retail store frontages and additional landscaping.
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Response 4-14
Please see Responses to Comments 3-87 and 4-9 above. The project shall be required to provide a driveway width in compliance with Zoning Code §17.46.150.B, which, for non-residential projects (including mixed-use projects) is 20 feet for a two-way driveway. The plans depict a 20-foot-wide driveway, as required by the Code.
Response 4-15
Comment noted. The four at-grade parking spaces shown on the site plan in Figure 2-5 of the Draft EIR have been relocated to the subterranean garage and a revised site plan, which is consistent with the site plan in the traffic impact study, has been incorporated into the Final EIR. This change has no effect on traffic impacts of the project.
Response 4-16
Project construction, pursuant to Section 9.36.070 of the Pasadena Municipal Code, must occur between the hours of 7:00 AM and 7:00 PM Monday through Friday; and between 8:00 AM and 5:00 PM on Saturday. However, hours for construction traffic (delivery trucks or haul trucks) shall be restricted to the hours between 9:00 AM to 3:00 PM to limit peak hour traffic conflict along the local street network. In addition, the number of construction-related trips would be less than the number of project-related trips analyzed in the traffic study, and, therefore, would be less than significant. Please also see Response to Comment 4-17 below.
Response 4-17
Issues related to project construction traffic access and circulation shall be reviewed and approved by the Department of Public Works and Department of Transportation upon the submittal of a Construction Staging and Traffic Management Plan, which includes the location of site access for construction vehicles; number of trucks and construction worker vehicles for each construction phase and duration of each construction phase; adjacent street and/or on-site staging of construction trucks; and truck routes. This analysis presents information related to all the above elements and provides construction mitigation requirements including development of a construction traffic management plan for the project and locations for construction worker parking in the vicinity of the project site.
Response 4-18
Please see Responses to Comments 4-9 through 4-17 above. 1 Comments on DEIR for Hotel Green Site
11 March 2014
Dear Members of the Design Commission:
Below are my comments on the DEIR. As the author of the original study of the Hotel Green complex and the area surrounding it (Pasadena’s Architectural and Historical Inventory, Survey Area 7), I have followed the development of the preservation of the complex and the City’s efforts with interest. I hope that the City’s commitment to this very special site will continue.
Sincerely,
Ann Scheid
General Comments:
The Hotel Green complex is the most significant of all of Old Pasadena’s historic buildings, second only to City Hall in its importance. As such, this building and its surroundings are part of the public trust implied by the historic designations (which also include City Landmark status, omitted in the report) accorded the property. This complex belongs not only to the owners, but in a greater sense to the citizens of Pasadena, of California and of the nation. There is no doubt that the proposed project will significantly diminish the historic character of the Hotel Green complex. Moreover the garden area, which existed until fairly recently in the building’s history, is being destroyed to accommodate parking that could, with some creative action, be accommodated elsewhere.
If this project is approved in its present form, those in the community and owners of the condominiums in the Castle Green who have invested time and money in ownership, restoration, and maintenance of this iconic historic building, will be rewarded by an action that betrays this public trust, and Pasadena, California, and the nation will be the poorer for it. The Hotel Green complex is unique, exists nowhere else, and unlike the proposed project cannot be found on every street corner. It is a unique component of Pasadena’s urban historic fabric, and a building of national significance.
Discussion of Alternatives
Both the proposed project and the only Alternative offered (aside from No Build) will overwhelm the existing historic complex. The new building, which is clearly incompatible with the old and with the historic buildings across Fair Oaks, will become the dominant building along Fair Oaks. Is this the building that we want to become the “gateway to Old Pasadena?”
Letter No. 5
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2 Additional alternatives need to be studied:
1. Literal Replication: This alternative for additions has been used by architects for centuries and has been used at Dulles Airport (1997), Kennedy-Warren apartments (Washington, DC, 2004), and Chicago’s Carson Pirie Scott store (1960). Since this project is an addition to the complex it should strive for compatibility, especially in proportion, scale and massing; differentiation will be an inevitable outcome. The Hotel Green complex is clearly as significant in its context as any of the above buildings. While this is an unusual solution, it can and is being done. Why hasn’t this alternative been studied?
2. Invention Within a Style: This alternative has also been used by architects for centuries. Recent examples in this country include the repeated additions to the US Capitol building, a new wing on the Frick Collection in New York (1977) and Whitman College at Princeton (2004). Again such an alternative needs to be studied for this significant site.
3. 4.4.2 Off-site Parking Alternative: The study of this alternative has been reduced to a numbers exercise, based on existing code requirements. This analysis ignores the special characteristics of the site, especially its historic development which involved the gradual take-over of the garden by parking and the accommodations made by the City by allowing off-site parking and other creative actions to encourage preservation of the entire complex. Once again, a more creative solution needs to be reached, or the project size needs to be reduced. Pasadena touts its “greenness” and yet it still requires on-site parking for every project? This is a no-win endgame that will result in ever-increasing traffic congestion.
4. 4.4.3. Alternate Site Alternative: Again, this alternative has been dismissed with no real investigation of sites in the area. There is no demonstration of contact/discussions/negotiations with the owners of the Green Street/Arroyo Parkway project or of any investigation or contact with the owners of the Parsons property, both of which might afford opportunities for TDRs. By narrowing Fair Oaks at the Parsons site, significant land area could be recovered for development and the area more closely integrated into Old Pasadena, including facilitating pedestrian street crossing.
5. 4.4.4. Smaller Scale Alternative: Dismissing this alternative as financially infeasible does not include another possible configuration: A two storyproject with retail below and residential above. This would be the most compatible with the existing site and would greatly lessen the impact on the historic buildings. Furthermore it would allow parking below grade that would not interfere with the development of the garden at grade, which should be the goal any project on the site. The number of stories in the dismissed alternative is not indicated in the report. In order to fully evaluate it, this needs to be stated somewhere in the report.
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Aesthetics:
The proposed project does not meet the criteria of Standard 9:
“New additions, exterior alterations or related new construction will not destroy historic materials, features and spatial relationships that characterize the property.” Clearly the spatial relationship and setting of the existing historic complex are severely compromised by the new project, obstructing views for residents from the existing buildings and obstructing public views of the historic buildings. The open space is also severely compromised by the parking structure below, which inhibits garden planting and removes many trees.
Standard 9 continues:
“The new work shall be differentiated from the old and will be compatible with the historic materials, features, size, scale and proportion, and massing to protect the integrity of the historic property and its environment.”
Again, the proposed project does not demonstrate compatibility, especially in the following areas: scale, proportion and massing (see Figures 2-11 and 2-12). As for features and historic materials, these are not clearly defined, although the balconies shown are clearly incompatible with those in the existing buildings.
More information is needed on the following:
The plan for the proposed project (Figure 2-5) does not show the spatial relationships to the existing historic property, which is not included on the plan. To be complete, the EIR should show those relationships clearly, not just in plan but also in elevation (relationships to window openings, balconies, etc.) This information needs to be included to demonstrate the full impact of the project on both the Castle Green and the Hotel Green Apartments.
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Letter No. 5 Ann Scheid
Ann Scheid
March 11, 2014
Responses
Response 5-1
The comment is noted and is included as part of the Final EIR, which will be considered by decisionmakers in taking action on the Project.
Response 5-2
The City of Pasadena’s designation of the existing Green Hotel Apartments building and Castle Green as historic monuments is acknowledged on page 3.3-16, contrary to the comment’s assertion that the information was omitted from the Draft EIR. Section 3.3, along with Appendix D, of the Draft EIR addresses potential impacts to historic resources and, based on substantial evidence presented therein, concludes that implementation of the proposed project will not result in significant impacts to historic resources. The majority of the parking associated with the proposed project will be underground (i.e., 147 of the 167 total spaces). The surface level parking proposed as part of the project will provide 20 spaces within the western portion of the existing 60-space surface parking lot.
Section 4.4.2 of the Draft EIR evaluates an alternative that would provide project-related parking at an off-site location; however, for reasons described therein, that alternative would found to be infeasible.
Additionally, it should be noted that the trees within the project site are not historic resources, as described in Section 3.3.2.2 of the Draft EIR. Please see also Topical Response TR-CR-1, above.
Response 5-3
The comment is noted and is included as part of the Final EIR, which will be considered by decisionmakers in taking action on the Project.
Response 5-4
Section 3.1 of the Draft EIR addresses potential aesthetics impacts, including view and aesthetic character impacts, and, based on substantial evidence presented therein, concludes that implementation of the proposed project will not result in significant impacts to existing views. As indicated in the elevation diagrams presented in Figures 2-11 and 2-12 of the Draft EIR, the mass and scale of the proposed building is generally consistent with those of Castle Green and the existing Green Hotel Apartments. That is also evident in the visual simulations presented in Section 3.1 of the Draft EIR.
Response 5-5
As indicated in Section 1.3 of the Draft EIR and expounded upon in Topical Response TR-ALT-1, several alternatives related to building size, massing, footprint, and design were evaluated in the course of defining the currently proposed building. The current proposal is considered to be generally compatible with the concept originally envisioned for the Green Hotel, with the project building representing the originally designed but unbuilt west wing of the complex. The Draft EIR analysis of the proposed project found no significant impacts related to aesthetics and cultural resources. As such, further evaluation of other design concepts for the project, such as suggested in the comment, is not warranted.
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Response 5-6
Please see Response 5-5 above.
Response 5-7
Section 4.4.2 of the Draft EIR evaluates an alternative that would provide project-related parking at an off-site location; however, for reasons described therein, that alternative would found to be infeasible.
The analysis therein is not a “numbers exercise” but is instead an analysis consistent with the requirements of the Pasadena Zoning Code from which no amount of creativity could deviate.
Response 5-8
Please see Topical Response TR-ALT-1 for a discussion regarding the decision not to analyze an off-site alternative. A reasonable and appropriate level of inquiry was completed relative to identification of a potential alternative site for the proposed project. It is not necessary for the applicant to investigate a myriad of possibilities such as follow-up with other property owners in the local area regarding potential land purchases or land swaps. The transfer of development rights for the project site is not allowed under the City’s Zoning Code. It should also be noted that the comments regarding development at the Parson’s site cannot be considered in relation to this project.
Response 5-9
The alternative suggested in this comment would be generally similar to the Smaller Scale Alternative described in Section 4.4.4 of the Draft EIR, with the notable difference being that the commenter’s alternative includes ground level retail. The limitation of residential apartments to a single level, providing approximately 6 units, as in the case of the Smaller Scale Alternative, would still render this alternative to be financially infeasible.3 Please see Topical Response TR-ALT-1 for additional discussion regarding the Draft EIR analysis of project alternatives including a table of residential/commercial mixes that would alleviate the traffic impact on Dayton Street and would also be financially infeasible.
Response 5-10
Please see Topical Response TR-CR-1 regarding the Draft EIR analysis of impacts to historic resources.
The related new construction will alter spatial relationships that characterize the property. The most significant spatial relationships of the Hotel Green/Castle Green are the relationships between the primary facades and the public right-of-way (Raymond Avenue, Green Street and Fair Oaks Avenue), and the secondary facades that face south to Dayton Street and Central Park. Views of the secondary facades will be partially obscured from Dayton Street and Fair Oaks Avenue; however major portions of those façades will remain visible. The proposed project will alter but not destroy spatial relationships that characterize the Hotel Green/Castle Green.
Response 5-11
Please see Topical Response TR-CR-1 regarding the Draft EIR analysis of impacts to historic resources.
The project is compatible with the adjacent historic resources and the historic character of the District in terms of scale, proportion and massing. The new building is rectangular in plan and has massing similar to the existing adjacent district contributor, Hotel Green/Castle Green. It also recalls traditional historic architectural design details found within the District including arched windows,
3 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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similarly proportioned fenestration, punched windows, cement plaster finishes, and a low-pitched roof with supporting brackets. The new building will also maintain the prevailing setback of the adjacent and nearby District contributors, continuing the street wall that defines and contains the immediate blocks of Fair Oaks Avenue.
Response 5-12
Figures 2-11 and 2-12 in the Draft EIR provide elevation views that show the spatial relationships of the proposed project to adjacent buildings including the existing Green Hotel Apartments and the Castle Green. Additionally, each of the 16 figures contained in Appendix B of the Draft EIR show the spatial relationship between the proposed project building and the existing buildings nearby, including, but not limited to the existing Green Hotel Apartments and Castle Green.
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Letter No. 6
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November 8, 2010, via e-mail
Mr. Abe Chorbajian, Chair
Design Commission
Design & Historic Preservation Section
City of Pasadena
175 North Garfield Avenue
Pasadena, CA 91109
RE: COMMENTS ON PROPOSED PROJECT, 86 SOUTH FAIR OAKS AVENUE, PASADENA Dear Chair Chorabian and Design Commissioners:
As a preservation architect and an architectural historian, we are extremely concerned with the expected impacts that would be caused by the mixed-use project proposed for 86 South Fair Oaks Avenue (proposed project) currently in Preliminary Consultation and subject to your commission review. The comments listed below are related to review for conformance with the California Environmental Quality Act (CEQA), as well as the integrally related issue of conformance with The Secretary of the Interior’s Standards for the Treatment of Historic Properties with Guidelines for Preserving, Rehabilitating, Restoring and Reconstructing Historic Buildings (Standards for Treatment, Kay D. Weeks and Anne E.
Grimmer for the National Park Service, 1995).
National and State Significance
The Castle Green Apartments and Hotel Green buildings were listed together in the National Register of Historic Places (National Register) in 1982, and are therefore listed in the California Register of Historical Resources (California Register). The properties were listed separately (not as an historic district), and each was since listed as a contributor to the Old Pasadena Historic District (1983). CEQA uses California Register of Historical Resources criteria as the threshold for historical resources eligibility under statute 21084.1.
The Castle Green and Hotel Green are therefore considered “historical resources” for the purposes of CEQA.
National Register Boundaries
The boundaries of the Castle and Hotel Green are an important component of this discussion. As described in the National Park Service-prepared “Defining Boundaries for National Register Properties”
Carefully defined [for National Register-listed properties] boundaries are important for several reasons. The boundaries encompass the resources that contribute to the property's significance. Selection of boundaries is… based on the nature of the property's significance, integrity, and physical setting… [B]oundaries … define the limits of the eligible resources. Such resources usually include the immediate surroundings and encompass the appropriate setting. [Areas are excluded] that do not directly contribute to the property's significance as buffer or as open space to separate the property from surrounding areas…. When such areas are small and surrounded by eligible resources, they may not be excluded, but are included as noncontributing resources of the property. That is, do not select boundaries which exclude a small noncontributing island surrounded by contributing resources; simply identify the noncontributing resources and include them within the boundaries of the property.
Letter No. 6
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10 The boundaries of the Castle Green and Green Hotel historic resource are clearly 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 west” Continuation Sheet 11, item 1 page 1. Figure 1 below is excerpted from Continuation Sheet 12 of the same document. It depicts the boundaries of the historic property, annotated in red, from curb to curb (as described), with the very approximate footprint of the proposed project expressed in blue, and clearly shown within the boundaries of the historic property.
Figure 1: National Register property boundaries of Castle Green Apartments and Hotel Green.
Source: National Register nomination form, dated October 29, 1979.
In that the project is proposed within the boundaries of a National Register-listed property, it is imperative that the Commission seriously consider the effects of its design.
Problematic aspects of the current design include its very large size (in height and plan), the block-like massing, ineloquent scale, rough proportions and significant effects on important view sheds. We recommend that the project be redesigned to more convincingly conform to the Standards for Rehabilitation as they relate to new construction, settings, districts and neighborhoods in order to avoid a finding that the proposed project would result in a significant effect on the environment.
The definition of “Environmental Setting” is parallel to the above concepts and is clarified in the Pasadena Zoning Code as:
The entire lot as of the date of landmark or historic monument designation, on which is located a landmark or historic monument, and to which it relates historically, physically, and/or visually. The environmental setting includes, but is not limited to, accessory structures, driveways, fences, gateways, open space, rocks, vegetation (including gardens, lawns, and trees), walkways, and walls (no emphasis needed).
2 Thus, the entire property is a component of the historical resource, not merely the land beneath the buildings. The proposed project would use a large amount of contributing property and is incompatible with the historically significant setting. We strongly urge that 10 11
12 an Environmental Impact Report (EIR) be prepared to objectively analyze the proposed project’s effects of on the adjacent, historically significant buildings, their collective setting and on the historic district as a whole.
Section 106
The entire block where the project is proposed is listed in the National Register as described, and is an “historic property” for the purposes of Section 106 of the National Historic Preservation Act of 1966, as amended. Although there is some US Department of Housing and Urban Development (HUD) nexus in the Hotel Green building ownership by the proposed project owners, it is not known with certainty whether Section 106 is triggered by any components of this project. Of the various plans, some are entitled “Lot Line Adjustment Submission” (see Figure 2). As described in the Code of Federal Regulations (CFR), if such an “undertaking”
(requirement of a federal permit, 36 CFR Section
800.16(y)) were proposed the project would be
subject to federal Section 106 review and may result,
as proposed, in a finding of adverse effect.
Figure 2: Excerpted, annotated, proposed project plan
title block, GMPA, 8/26/2010.
CEQA
CEQA equates “substantial adverse change” in the significance of an historical resource with a significant effect on the environment (Section 21084.1). Substantial adverse change is defined as “demolition, destruction, relocation, or alteration activities which would impair historical significance” (emphasis added, Section 5020.1). The proposed project is expected to cause substantial adverse change in historical resources; therefore environmental clearance for the project must include a complete historical resources technical report, which would include specific mitigation measures to reduce impacts. “Substantial adverse change in the significance of an historical resource means 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” (PRC Section15064.5 (b)(1)).
For the past two years, as clearly communicated to the developer by community stakeholders in meetings and in the press, the existence of serious public controversy has been established concerning the environmental effects of the proposed project.
Examples include recent local newspaper articles: “Proposed Mixed-Use Building in Old Pasadena Frays Nerves” Brenda Gazzar, Pasadena Star-News, 9/25/2010; “Past Present Imperfect” Jake Armstrong, Pasadena Weekly, 9/16/10, thus an additional threshold has been reached requiring preparation of an EIR to examine the effects on historical resources (CEQA Guidelines, Section 15064).
Other CEQA issue areas of concern include the related issue of aesthetics, as well as recreation, geology and soils (the opportunity for ground-borne vibration and differential settlement to affect the historic buildings), traffic and transportation and public services.
Secretary of the Interior’s Standards for Rehabilitation We have reviewed the memorandum prepared by our colleagues at ARG (8/20/10), and while it asserts that the proposed project would meet standards 9 and 10, the other eight 3 12
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standards are not adequately satisfied in the current design. The proposed project plans (GMPA Architects, 8/26/2010) clearly demonstrate that the proposed project design does not conform to the Secretary of the Interior’s Standards for Rehabilitation, particularly as they relate to settings, district and neighborhoods and building sites.
The proposed project does not meet the objectives described in the Secretary of the Interior’s Standards for Rehabilitation, specifically …Additions for the New Use, which include the following as specifically “not recommended:” “Introducing new construction into historic districts that is visually incompatible or that destroys historic relationships within the setting.” The proposed project’s location infilling the L between the Castle Green and Hotel Green buildings destroys the existing parti or geometry between the existing buildings. We note that the City of Pasadena previously approved a project singled-out by the National Park Service (NPS) as a bad example in “Interpreting the Standards Number 41: Incompatible Alterations to the Setting and Environment of a Historic Property” (Attachment 1: U.S. Department of the Interior, Technical Preservation Services, 2006).
“Incompatible Alterations to the Setting and Environment of a Historic Property” declared regarding the other Pasadena project:
the formerly expansive, almost pastoral, landscape that surrounded the… [historic buildings] consisting largely of grass covered areas dotted with small shrubs, olive trees, and clusters of palm trees has been drastically reduced by the new construction. In addition, the height, massing, scale, and proximity of the new construction dwarf the historic… building. The cumulative effect of all these changes negatively impacts the historic character of the… [historic property]. Accordingly, the project does not meet the Standards (emphasis added, Antonio Aguilar, 2006).
The negative review prepared by Park Service staff foretells the expected effects of the proposed 86 South Fair Oaks Avenue project, the impacts of which are significant. The NPS considered the other project improper treatment to the setting of an historic building; the design was modified after construction was completed as a result of the review.
The proposed project would remove 19 trees, of which 6 are protected (ARG, 8/20/10).
The ARG review asserts incorrectly “these [trees] have not been shown to be part of any historic designated landscape…” The National Register registration form clearly described the contributing historic gardens: “It is set back approximately… 30 feet from Dayton Street, affording ample space for a fine garden consisting of lawns, shrubs, pathways, a pool with a fountain, and mature plantings of magnolias, bananas, varieties of palms and other trees.” The landscape open space is plainly a contributing feature to the National Register listing. The registration form concluded: “Thus while located in the urban context of downtown Pasadena, The Castle Green enjoys an oasis of surrounding greenery… Within the L created by this junction of two [Castle and Hotel Green] buildings are located parking lots, garages and other service facilities.”
Recent problems with the panacea of design review in Pasadena have evidenced themselves, as described in the Interpreting the Standards bulletin. Based in part on that fact, we believe that City review and approval would not prove or assure conformance with the Standards for Rehabilitation. The assertion commonly used by the City of Pasadena that design review reduces future project impacts constitutes deferred 15 mitigation. If future design review would be adequate mitigation for historic resources impacts, that premise would not sufficiently commit projects to reduced impacts. The premise lacks CEQA-required specific performance standard details. We bring the Secretary of the Interior’s Rehabilitation Guidelines for Setting to the attention of reviewers, as they apply to new construction in historic districts (underlining indicates emphasis that applies to the proposed project) in Attachment 2.
The proposed project does not meet the objectives described in the Secretary of the Interior’s Standards for Rehabilitation, specifically “Additions for the New Use,” which does recommends against: “Introducing new construction into historic districts that is visually incompatible or that destroys historic relationships within the setting.” This project is both visually incompatible and destroys the relationship between the Hotel Green and Central Park to the south, and the connection between the Hotel Green and Castle Green on its shared corner.
Conclusion
For the past two years several presentations were made by the development team for the 86 South Fair Oaks Avenue project. Community concerns have been clearly and consistently expressed in those meetings, but no benefit has evidenced itself in the overall design approach and treatment. Response has been negligible: weak attempts were made to back-pedal the proposed project into conformance. The development team clearly has no understanding of the unique visual, physical and historic significance of this National Register-listed property in the context of Pasadena and the region. Project proponents would be well-served to engage an experienced historic preservation architect who meets the Secretary of the Interior’s Professional Qualification Standards in historic architecture to collaborate on the project design and to advise on whether project objectives are achievable while meeting CEQA requirements.
In closing, we believe that the proposed project design is not contextual to its setting and that it should be redesigned. An EIR must be prepared to properly analyze environmental impacts under CEQA. The EIR would analyze alternatives to the proposed project. We trust the Design Commission will seriously consider the effects of the proposed project on the historic property, its setting and the surrounding historic district and will take necessary steps to provide the constructive scrutiny deserved for this gateway site. We appreciate the opportunity to comment on the proposed project.
Very truly yours,
Kelly Sutherlin McLeod, AIA Francesca Smith
Architect Architectural Historian
Attachments
5 15
16 17
ATTACHMENT 1
6 18
7 18
8 ATTACHMENT 2
Secretary of the Interior’s Rehabilitation Guidelines
SETTING (District/Neighborhood)
Recommended Not Recommended
Design for the Replacement of
Missing Historic Features
Designing and constructing a new
feature of the building or landscape
when the historic feature is
completely missing, such as row
house steps, a porch, a streetlight, or
terrace. It may be a restoration
based on documentary or physical
evidence; or be a new design that is
compatible with the historic
character of the setting.
Introducing a new building or landscape feature that
is out of scale or otherwise inappropriate to the
setting’s historic character…
Comment: The proposed project is out of scale at six
stories in height; it need not match the existing historic buildings’ heights. It is located an area of lower-rise one- and two-story buildings as well as taller buildings, thus its height should be more transitional to the
neighborhood than fulfill its maximum.
The proposed bland contemporary design is
inappropriate and intrusive to the immediate setting
of the separately significant Castle Green and Green
Hotel buildings and to the Old Pasadena Historic
District.
Alterations/Additions for New Use
Designing and constructing new
additions to historic buildings when
required by the new use. New work
should be compatible with the
historic character of the setting in
terms of size, scale, design, material,
color, and texture.
Introducing new construction into historic districts that is visually incompatible or that destroys historic
relationships within the setting.
Comment: The proposed project is not compatible
with the sizes of contributing buildings in the historic district it faces on the west side, the scale and
proportion is inappropriate and not clearly
articulated, the design is trend-driven, not timeless,
and does not respond to its elements in its setting. The proposed design is neither a respectful neighbor to its historic setting and does it impart any special sense of place that is particular to Pasadena or to the Castle
or Hotel Green property.
Building Site
Minimizing disturbance of terrain
around buildings or elsewhere on the
site, thus reducing the possibility of
destroying or damaging important
landscape features or archeological
resources.
Introducing heavy machinery into areas where it may
disturb or damage [fragile historic buildings] important landscape features or archeological resources.
Comment: Failure to use specialized shoring and pile
driving methods may cause damage to the Castle or
Hotel Green Buildings and potentially to other nearby
and adjacent historical resources. This would
constitute “material impairment” to the historic
resources and therefore “substantial adverse
change,” an impact as defined in CEQA.
Surveying and documenting areas
where the terrain will be altered to
determine the potential impact to
important landscape features or
archeological resources.
Failing to survey the building site prior to the beginning of rehabilitation work which results in damage to, or
destruction of, important landscape features or
archeological resources.
Comment: Unknown.
18 9
Secretary of the Interior’s Rehabilitation Guidelines
SETTING (District/Neighborhood)
Recommended Not Recommended
Protecting, e.g., preserving in place
important archeological resources.
Leaving known archeological material unprotected
so that it is damaged during rehabilitation work.
Comment: Unknown.
Planning and carrying out any
necessary investigation using
professional archeologists and
modern archeological methods
when preservation in place is not
feasible.
Permitting unqualified personnel to perform data
recovery on archeological resources so that improper
methodology results in the loss of important
archeological material.
Comment: Impacts unknown.
Alterations/Additions for the New Use
Designing new onsite parking,
loading docks, or ramps when
required by the new use so that they
are as unobtrusive as possible and
assure the preservation of the historic
relationship between the building or
buildings and the landscape.
Designing… adjacent new
construction which is compatible with
the historic character of the site and
which preserves the historic
relationship between the building or
buildings and the landscape.
Removing non-significant buildings,
additions, or site features which
detract from the historic character of
the site.
Locating any new construction …in a location which
contains important landscape features or open
space, for example removing a lawn and walkway
and installing a parking lot.
Comment: Requires removal of 6 protected trees
(ARG). See discussion of contributing features.
Placing parking facilities directly adjacent to historic buildings where automobiles may cause damage to
the buildings or landscape features, or be intrusive to the building site.
Introducing new construction onto the building site
which is visually incompatible in terms of size, scale, design, materials, color, and texture; which destroys
historic relationships on the site; or which damages or destroys important landscape features.
Removing a historic building in a complex of buildings; or removing a building feature, or a landscape
feature which is important in defining the historic
character of the site.
Source: Weeks and Grimmer. The Secretary of the Interior’s Standards for the Treatment of Historic Properties with Guidelines for Preserving, Rehabilitating Restoring & Reconstructing Historic Buildings: 102-108 and 112-113.
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Letter No. 6 Kelly Sutherlin McLeod, FAIA
Kelly Sutherlin McLeod, FAIA
March 11, 2014
Responses
Response 6-1
Comment noted. A single letter dated November 8, 2010 was included as an attachment. While the 2010 letter is not directed towards the Draft EIR, consideration has been given to the comments therein and written responses are provided below in Responses to Comments 6-8 through 6-15.
Response 6-2
Section 3.3, along with Appendix D, of the Draft EIR provides the analysis of potential impacts to historic resources and sets forth the basis and expert opinion for concluding that the proposed building would be subordinate to the historic resources nearby including the existing Green Hotel Apartments and Castle Green. See also Topical Response TR-CR-1.
Response 6-3
Please see Topical Response TR-CR-1 regarding the Draft EIR analysis of impacts to historic resources.
Response 6-4
The alterations to the surroundings of the Hotel Green/Castle Green, Central Park and the Historic District were analyzed in the Historic Resources Technical Report – See Appendix D of the Draft EIR, specifically pages 42 through 46. The individual National Register nomination boundary for Hotel Green/Castle Green was discussed several times in the Technical Report (p. 12) and described in the Draft EIR, specifically in Section 3.3.2. The subject boundary follows the perimeter of the block bound by Green Street on the north, Raymond Avenue on the east, Dayton Street on the south, and Fair Oaks Avenue on the west. Cumulative impacts to cultural resources, including historic resources, are addressed in Section 3.3.7 on pages 3.3-30 and 3.3-31 of the Draft EIR.
Response 6-5
Section 3.5 of the Draft EIR provides a complete analysis of potential construction-related noise and vibration impacts to structures nearby, including the existing Green Hotel Apartments and Castle Green. The commenter provides no elaboration on, or facts in support of, the allegation that the Draft EIR analysis is inadequate. Section II.7, Cultural Resources, in the Initial Study contained in Appendix A of the Draft EIR addresses the potential for encountering archaeological resources and concludes that, with implementation of the standard condition described therein regarding the potential for encountering historic archaeologic resources during project excavation, there would be no significant impact to such resources. The standard condition calls for a targeted archaeological monitoring program that includes, but will not be limited to, having an archeological consultant complete a records search and review the cultural/historic resource reports to identify any areas of archaeological sensitivity onsite, conduct a meeting with the construction crew to assist the crew in identifying potentially significant cultural resources and to identify any potential related concerns, monitor the first two days of grading activities and initial activities associated with the removal of basements, foundations, and/or concrete slabs, monitor the disturbance (e.g., grading, trenching, etc.) of any archaeologically sensitive areas identified through records review and/or preliminary investigation, and prepare a summary report at the completion of monitoring.
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Response 6-6
Section 4 of the Draft EIR addresses alternatives to the proposed project. Section 3.3 of the Draft EIR concludes that implementation of the proposed project would not result in significant impacts to historic resources, consequently the identification of alternatives to avoid or substantially lessen significant impacts to historic resources is not required under CEQA. Regardless, the analysis in Section 4 includes consideration of historic resources.
Response 6-7
The City has carefully considered the information contained in the Draft EIR, along with the comments received during the Draft EIR review period and the written responses to those comments, and has made appropriate revisions in this Final EIR.
Response 6-8
Based on the date of this comment letter (November 8, 2010), the comments in the letter are not directed towards the Draft EIR or the historical resources technical report prepared for the currently proposed project. Nevertheless, the City has considered the comments therein and provided the following responses.
Response 6-9
The statements in this comment are consistent with the information provided in Section 3.3 of the Draft EIR.
Response 6-10
The statements in this comment are consistent with the information provided in Section 3.3 of the Draft EIR and the Historic Resources Technical Report (Draft EIR Appendix D); that the boundaries of Castle Green and Hotel Green, which includes the project site, are noted in National Register nomination and reiterated in the Historic Resources Technical Report (page 12) completed for the project.
Response 6-11
This comment in this 2010 letter appear to be directed at a project design that has since changed. The 2013 Draft EIR and associated Historic Resources Technical Report address the potential impacts of the currently proposed project design, including building size, massing, scale, proportions. Also, the subject analyses address view sheds towards the existing historic resources, as may be viewed by the general public, but not from those historic resource, as such view shed are private views not public views.
Response 6-12
The analysis in Section 3.3 of the Draft EIR, along with the supporting technical data in Appendix D, objectively and comprehensively analyzes the proposed project’s effects on the adjacent historic resources and the district as a whole. The Zoning Code defines the term “environmental setting” but the National Register nomination for Hotel Green does not state that the environmental setting on the project site is significant. Further, the analysis of the project site in the Draft EIR concludes that there are no historically significant features on the project site.
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Response 6-13
There are no federal actions or approvals associated with the proposed project and no federal funding is being used for the project. As such, the requirements of Section 106 of the National Historic Preservation Act do not apply to the currently proposed project.
Response 6-14
Subsequent to the 2010 comment letter, a comprehensive EIR was prepared for the currently proposed project.
Response 6-15
Notwithstanding that comment letter is from 2010, which precedes the design of the currently proposed project and the preparation of the Draft EIR, the types of issues raised in the comment are addressed in Section 3.3 of the Draft EIR, as supported by the technical analyses contained in Appendix D.
Response 6-16
Subsequent to the 2010 comment letter, a comprehensive EIR was prepared for the currently proposed project and included a complete analysis, prepared by qualified professionals, of potential impacts to historic resources. Additionally, as indicated in Section 1.3 of the Draft EIR and reiterated in Topical Response TR-ALT-1, the currently proposed project reflects and evolution and refinement of the development plan introduced in 2007, with the subsequent modifications to the plan being responsive to comments received. Specifically, 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 late-nineteenth-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 applicant’s refinement of the development concept into the plan that is currently proposed included the involvement of a professional architectural historic resources consulting firm – Archaeological Resources Group, Inc. (ARG).
Response 6-17
Subsequent to the 2010 comment letter, a comprehensive EIR was prepared for the currently proposed project.
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Response 6-18
The subject attachment has been reviewed and taken into consideration, but does not change the findings of the historic resources assessment completed for the project.
3.3.3 Comments Received at the Public Hearing on the Draft EIR The following summarizes comments received from the City of Pasadena Design Commission and the public at the public hearing held on the Draft EIR on Tuesday, March 11, 2014, as specifically related to the Draft EIR. Such comments are paraphrased and not written verbatim. In some cases, public comments expressed during oral testimony were read from, or otherwise reflected by, the written comments submitted by the speakers. Comments expressed at the hearing that were not submitted in writing are responded to below, whereas comments expressed at the hearing that were also submitted in writing are responded to above in the responses to individual comment letters received on the Draft EIR.
City of Pasadena Design Commission Opening Questions and Comments Commissioner Byram: The new building will obscure and block views from Central Park.
Response: See Topical Response TR-AES-1, which describes the additional view analyses completed for the project including view impacts from Central Park.
Commissioner Miller: Why was the segment of Fair Oaks Avenue between Dayton and Del Mar not studied?
Response: See Response to Comment 3-42 for further discussion of this segment of Fair Oaks Avenue.
Commissioner Barar: If you put this new building in its historic context, is the impact on the historic resource considered negligible? The building puts another shade on how view of the historic resources is taken.
Response: See Topical Response TR-CR-1 for further discussion of the cultural resources impacts of the project relative to primary and secondary facades.
Commissioner Moreno: The whole block is historic. Is there a requirement of building material for this certain building development? Is there an impact on historic resources relative to building materials? How does Draft EIR address issues on external materials or construction building type? Response: The compatibility of building materials and construction building types does not typically come up in an EIR analysis. See discussion in TR-CR-1 related to design review.
Commissioner Hansen: The visual simulations in the EIR show substantial changes in appearance.
How did the EIR analysis conclude that there were no significant visual impacts? Response: The issue of assessing visual impacts is subjective in nature. The EIR describes the thresholds used to determine significance. The visual simulations in the Draft EIR focused on most prominent public views and represent the most impact from the project (i.e., worst-case scenario). The analysis also took into account other existing views around the project site that would not be impacted. The conclusions were based on overall impacts. See also Topical Response TR-AES-1.
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Commissioner Hansen: How closely do we need to study the compatibility of building appearances, relative to historic resources?
Response: See TR-CR-1 above.
Public Comments
Doug Carstons (Attorney for Castle Green Homeowner Association):
The comments presented in the oral testimony from Mr. Carstons are included in the written comments that he subsequently submitted to the City. Please see Comment Letter No. 4 above and the associated written responses.
Mike Salazar (Castle Green Homeowners Association):
The comments provided by Mr. Salazar at the public hearing on March 11, 2014 are excerpts from the Draft EIR comment letters submitted by the Castle Green Homeowners Association on March 8 and 9, 2014. Responses to all the comments submitted by the Castle Green Homeowners Association, including, but not limited to, those reiterated by Mr. Salazar, are provided above in Responses to Comments 3-1 through 3-103.
Ann Scheid:
The comments provided by Ms. Scheid at the public hearing on March 11, 2014 are similar to several of the comments contained in her Draft EIR comment letter submitted earlier that day. Responses to all of the comments from Ms. Scheid are provided above in Responses to Comments 5-1 through 5-12.
Jesse Lattig (Pasadena Heritage):
The comments provided by Ms. Lattig at the public hearing on March 11, 2014 are similar to several of the comments contained in the Draft EIR comment letter submitted by Pasadena Heritage earlier that day. Responses to all of the comments from Pasadena Heritage are provided above in Responses to Comments 2-1 through 2-8.
Jack Green (President of Castle Green Homeowners Association): My biggest concern is the massing of the proposed project. This issue cannot be predetermined in this EIR. Because the zoning entitlement goes along with it, and Design Commission’s hands are pretty much tied. I think it has to be looked in totality. I’m afraid that the hands of Design Commission would be tied in order to lower the massing of proposed project. Another issue is that parking is highly dependent on Dayton Street.
The traffic right of way on Dayton Street is only one car wide. The parking is limited. Where is the construction crew going to park? There is a park playground structure at Central Park. The EPA has determined that children are eight times more susceptible to air quality effects. All the people that own unit property at the Castle Green are subject to Secretary of Interior. You have to have a love for history to live there. The building itself may not be impacted; however, the people that live and own property in that building would suffer the consequences and their ability to preserve the Castle Green is compromised. I think the City has to weight these issues.
Response: The discussion on page ES-3 of the Draft EIR acknowledges that the height, floor area ratio, and setbacks (i.e., building massing) of the proposed project meet the existing development standards for the CD-1 zoning district. No changes to the existing zoning for the project site are proposed. As also noted on that same page, the required parking for the Section 3 Comments and Responses
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project would be provided onsite in compliance with the City’s Zoning Ordinance; project-related parking is not dependent on Dayton Street. Construction worker parking would be determined as part of the overall development of the Construction Management and Staging Plan as required by the City’s Department of Public Works and Department of Transportation. Possible locations for construction working parking in the vicinity of the project site include three existing public parking lots (Park and Walk located at Green Street directly across the street from the main entrance of the existing Green Hotel Apartments, Unified Public Parking Lot located at Fair Oaks Avenue between Dayton Street and Green Street, and Unified Public Parking Lot located on the corner of Fair Oaks Avenue and Dayton Street near the Fire Station). The presence and proximity of the existing playground near the project site are specifically acknowledged on page 3.2-11 in the air quality analysis of the Draft EIR and, based on the application of SCAQMD localized significance thresholds (LSTs), no significant impacts would occur. The comment regarding property owners is noted and is included as part of the Final EIR, which will be considered by decisionmakers in taking action on the Project.
Design Commission Summary Closing Comments
Commissioner Rawlings: I would like to see a review of the scenic views (i.e., of the park) and evaluation of more alternatives. The spatial compatibility of size and mass, in general, suggests having more alternatives.
Response: Please see Topical Response TR-AES-1 regarding the Draft EIR analysis of visual impacts, which includes additional evaluation of view impacts from within Central Park.
Commissioner Hansen: The original (1903) development plan for the project site should be evaluated as a project alternative.
Response: Please see Topical Response TR-ALT-1 regarding the Draft EIR analysis of project alternatives
Commissioner Miller: There is potential for real transportation impacts, especially the way the proposed project is designed. There may be potential for queuing. My suggestion is to have Dayton Street be a westbound one-way street.
Response: The conversion of Dayton Street to a westbound one-way street would not mitigate the traffic impact. This street conversion would only restrict traffic to a westbound direction and not reduce the amount of traffic along Dayton Street.
Commissioner Byram: Need to study alternatives with varied footprint.
Response: Please see Topical Response TR-ALT-1 regarding the Draft EIR analysis of project alternatives.
Commissioner Barar: I suggest that all facades of Green Hotel be considered primary views.
Response: As indicated above in Topical Response TR-CR-1, the related new construction will alter spatial relationships that characterize the property. The most significant spatial relationships of the Hotel Green/Castle Green are the relationships between the primary facades and the public right-of-way (Raymond Avenue, Green Street and Fair Oaks Avenue), and the secondary facades that face south to Dayton Street and Central Park. Views of the Section 3 Comments and Responses
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secondary facades will be partially obscured from Dayton Street and Fair Oaks Avenue, however major portions of those façades will remain visible (See Topical Response TR-AES-1).
The proposed project will alter but not destroy spatial relationships that characterize the Hotel Green/Castle Green. Even if all of the views of the Castle Green and existing Green Hotel Apartments were considered equally as primary views, the conclusions of the Draft EIR would not change; that the visual/aesthetic impacts of the proposed project would be less than significant for the reasons detailed in Topical Responses TR-CR-1 and TR-AES-1, which include: the project would have no impact on the street-facing facades on Raymond Avenue, Green Street or Fair Oaks Avenue; 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; while views of the west bays of the Green Hotel would be obstructed, 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, and that part of the facade would remain visible from the Fair Oaks sidewalk and from points on the project site.
Additionally, it should be noted that all of the facades of the Hotel Green/Castle Green are significant, character-defining features of the historic property. Preservation Brief 14, “New Exterior Additions to Historic Buildings: Preservation Concerns,” which is published by the National Park Service as guidance for interpretation of the Standards for Rehabilitation, utilizes the term “primary elevation,” which is equivalent to “primary façade” where used.
Following are relevant statements from Preservation Brief 14:
“A new addition should not be highly visible from the public right of way; a rear or other secondary elevation is usually the best location for a new addition.” “Generally speaking, preservation of historic buildings inherently implies minimal change to primary or ‘public’ elevations and, of course, interior features as well.” “Exterior features that distinguish one historic building or a row of buildings and which can be seen from a public right of way, such as a street or sidewalk, are most likely to be the most significant.”
“Because significant materials and features should be preserved, not damaged or hidden, the first place to consider placing a new addition is in a location where the least amount of historic material and character-defining features will be lost.” It is acknowledged that all of the facades of the historic structures are significant and can be seen from a public right of way. However, the facades that are contiguous with or nearby and facing a public right of way (e.g., a building line at the property line) are the “most significant,” and therefore classified as primary. In this case, the building facades at Fair Oaks Avenue, Green Street, and Raymond Avenue are the most significant, and primary facades. The building facades that face south, mid-block, and the rear side of the east-facing primary façade on Raymond Avenue, are significant and secondary facades. The secondary facades are also differentiated by simpler and less decorative architectural designs.
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3.3.4 Individual Responses to Comments on the Recirculated Draft EIR The following provides individual responses to comments received on the Recirculated Draft EIR published on January 20, 2015, with a copy of each comment letter bracketed to identify the individual comments for which the attendant written responses are then presented.
Letter No.
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Letter No. 7 City of San Marino
City of San Marino
2200 Huntington Drive
San Marino, California 91108
Emy-Rose Hanna, Intern Planner
January 26, 2015
Response
Response 7-1
Comment Noted.
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Green Hotel Apartments Recirculated Draft EIR Comments
February 24, 2015 Presentation to the Design Commission Mike Salazar for the Castle Green Homeowners Association.
March 2, 2015 DRAFT
City of Pasadena
Design Commission
RE: Comments on Recirculated Draft Environmental Impact Report for 86 S. Fair Oaks Avenue and February 24, 2015 Design Commission Hearing.
Dear Design Commissioners:
Pertaining to the Recirculated Draft Environmental Impact Report for the above-noted project, and in regards to the recent Feb. 24, 2015 Hearing at the Design Commission, there are areas of the Staff Report that should be clarified or corrected. Of note are:
1. While the DEIR has found less than significant impacts except for Transportation and Circulation, it should be noted that the community at large has, continually since before the Initial Study up to this RDEIR, raised significant objection to this limited conclusion. Speakers and written comments have cited possible impacts continually ignored or under-evaluated, such as but not limited to Aesthetics, Air Quality, Cultural Resources, Greenhouse Gas Emissions and Noise & Vibration, as well as in regards to Transportation and Circulation.
2. The Staff Report anticipates this Commission will eventually adopt a Statement of Overriding Considerations. However, that is only if the Design Commission accepts the Final EIR as adequate. Staff Report fails to note out that there are other alternative routes that the Commission may consider. The Design Commission has not been briefed as to the full range of its review options, as is required under CEQA guidelines. In addition to the Statement of Overriding Considerations, to certify/adopt the Final EIR the Design Commission would have to also have to create a Mitigation Monitoring and Reporting Program and EIR Findings addressing the EIR conditions and those continually raised by the comments but potentially not addressed in the Final EIR.
3. The Staff Report states the “remaining four levels” above the ground floor retail contain 64 residential units. In fact, it is “five remaining floors” above ground floor retail. PLEASE NOTE that this same error was contained in the March 11, 2014 Staff Report. It was then pointed out, but was forgotten or overlooked.
4. The Staff Report erroneously states ground floor parking at grade is tucked under the eastern side of the building. In fact, fully 50% of ground floor surface parking is exposed and dominates the open space on the ground floor. And not all “replacement” parking is below ground. In fact, four (4) of the ground floor surface parking spots are replacement parking for the existing Green Hotel Apartments. PLEASE NOTE that this same error was contained in the March 11, 2014 Staff Report. It was then pointed out, but was effectively forgotten or overlooked. It was also contained in the 2013 Initial Study, pointed out in public comment and not addressed.
5. The Staff Report states 167 Project parking spaces, yet plans and other areas of the DEIR state both 167 and 169 parking spaces. I believe it is Table 2-3 (Floor by Floor Details) that states 20 parking spaces on ground floor, and Figure 2-5 (Site Plan First Floor Layout) that shows 24 spaces on the ground floor.
PLEASE NOTE that this same error was contained in the March 11, 2014 Staff Report. It was then pointed out, but was effectively forgotten or ignored.
6. The Staff Report should clarify the “entitlements” stated that will be brought to the Design Commission are merely the Concept and Final Design Review.
The basis for the "Recirculated Draft Environmental Impact Report” (R-DEIR) seems to be that the public is being asked to consider the R-DEIR's "important correction" (“correction”) and its impacts that doubles the daily trips generated by the Project and Alternative 2 onto the Dayton Street Segment above levels previously reported in Letter No. 8
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Green Hotel Apartments Recirculated Draft EIR Comments
February 24, 2015 Presentation to the Design Commission Mike Salazar for the Castle Green Homeowners Association.
the Draft EIR and Traffic Study Appendix H. This “correction” is being characterized as essentially a numerical error in the DEIR than a substantive one – a ‘correction’ that only impacts the traffic trips from the Project & two Alternatives on the Dayton Street Roadway Segment. This ‘correction’ is reinforced as such because no other corresponding traffic & circulation data - like intersection loads or other Roadway Segment loads - no other traffic 'numbers' in Section 3 and throughout the R-DEIR have been adjusted in the least.
Yet this “correction” has impacted other areas of the DEIR, most notably the Alternatives (Section 4), albeit selectively. The ‘correction’ has had a major impact on the Smaller Scale Alternative that is “considered but rejected as [financially] infeasible,” apparently requiring this Alternative to be cut down to less than half its size.
We still have no data or proof that financial infeasibility exists, (or at what level of project size that financial feasibility exists), the reason this Smaller Scale Alternative was rejected.
But while the “correction” doubles the “significant traffic and circulation impacts” for the big Alternative 2, it has failed to generate the slightest of change to Alternative 2; just the numerical corrections, and again without any explanation of the scope of change as noted above. What this “correction” should have done is generated a more appropriate and less-impactful Alternative 3 around the 50% or less size range (below the last year’s acceptable 313 daily trip range), utilizing mitigation measures ignored in every single Alternative proposed or rejected.
We also need to know if any other full Project and the Reduced Height Alternative 2 impacts dealing with vehicles in the remaining DEIR, such as but not limited to Air Quality (operational emissions) and Greenhouse Gasses (operational GHG emissions) have been examined due to this “correction,” and if in fact they are reflective of the “corrected” 626 and 479 daily trips (respectively). These two Sections mentioned (Air Quality & Greenhouse Gasses) have not been adjusted in the R-DEIR. This must be confirmed as well, as Staff was unable to confirm this at the Feb. 24, 2015 hearing. Which begs the question, “Are there other areas that may have vehicular impacts due to the doubling of trips on the Dayton Street Segment that require further adjustment/review/comments prior to issuing the Final EIR?” In addition, essentially none of the impacts outlined in the Castle Green HOA Comments (March 10, 2014 letter from Chatten-Brown & Carstens LLP, including Tom Brohard Comments) in last year’s (2014) DEIR hearing seem to be addressed, let alone resolved. These comments by and large stand, and should be considered resubmitted for question under this R-DEIR. This letter is attached to this submission.
Ultimately Staff must clarify these and other points, but more importantly the Final EIR must address and resolve them or risk being declared inadequate. The Design Commission, under their CEQA responsibilities, must also insist the above points are clearly addressed and resolved in order to make legal Findings, one way or another.
The following are comments on the R-DEIR Sections that are specifically noted as affected by the “correction” and those that elaborate on comments so far presented. I will apologize in advance, as there is some repetitive discussion of issue that cross the Section divides. But I have chosen to err on the side of being more inclusive so as not to risk the varied and often related impacts from the R-DEIR “correction” and items still seen as omissions or incompletely addressed.
SECTION 1.0
In the first Section of the R-DEIR, “Introduction to the Recirculated Draft EIR,” the first paragraph says, “Specifically, important new information is presented in this Recirculated Draft EIR relative to the proposed project’s impact on Dayton Street between Fair oaks Avenue and Raymond Avenue. That important new information consists of a correction to the amount of project-related trips indicated in the Draft EIR as occurring on Dayton Street. No other aspects of the original Draft EIR, including environmental setting, impacts, mitigation measures, and alternatives, have materially changed. As such, consistent with …. (CEQA) Guidelines, this Recirculated Draft EIR only includes the traffic-related information that was updated/revised from the Draft EIR.” 8 11
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Green Hotel Apartments Recirculated Draft EIR Comments
February 24, 2015 Presentation to the Design Commission Mike Salazar for the Castle Green Homeowners Association.
This is false, and should require a re-notification effort in order to factually portray the scope of material changes related to Alternatives that are identified in Section 4 of this R-DEIR. This statement says that, No other aspects of the original Draft EIR, including the… alternatives, have materially changed.” In fact, the “Smaller Scale Alternative significantly changed solely because of this “new information.” The change to this alternative went well beyond traffic-related information. It went to the very make-up of the alternative.
While Section 1.3 additionally mentions “related corrections within Section 4,” this again is a false characterization of the complete change required of the Smaller Scale Alternative.
SECTION 3.6
In the Recirculated Draft EIR (R-DEIR), what is described as "an important correction" to the Section 3.6 Transportation and Circulation is that last year’s DEIR's Average Daily Trips impacting Dayton Street Segment is not the stated 313 trips (a 35.4% increase), but a doubling of that number to a whopping 626 daily trips.
Yet despite this, there is still:
- NO specified Project-related “hard measures” studied or required for needed mitigation for the Dayton Street Segment that is now impacted twice the rate of the DEIR. In fact, not even any “soft” measures for traffic/circulation mitigation are proposed, identified and studied, which seems necessary for this project to move forward.
- NO specified Project-related “soft measures” studied or required for mitigation for the Dayton/Fair Oaks & Dayton/Raymond unsignalized intersections that are impacted by Dayton Segment trips, yet not addressed. In fact, no “hard” measures for traffic/circulation mitigation are proposed for these two intersections, which seem necessary for this project to move forward.
- NO revised study of the impacts on Pedestrian or Biking quality ratings for the Dayton Street Segment. In fact, it has not be clarified which traffic numbers both the PEQI & BEQI studies used to come up with their DEIR conclusions, unchanged in the R-DEIR.
Pg. 3.6-45. Why, if the Dayton Street Segment trips have doubled, is there no change or additions in the ADT impact in Table 3.6-10 in the form of specific soft and hard measures? This table sets a 7.5% increase threshold for daily trips, yet instead of the DEIR’s 35.4% Project increase and 27.9% Alternative 2 increase in trips on the Dayton Street Segment, we have a whopping 70.9% & 54% increase, respectively. In doubling the significant and unavoidable traffic/circulation impacts (and the severity), why is the Project and Alternative 2 still only subject to some future “soft” measures for future mitigation after project is approved? This Project is now almost 10x the City-accepted threshold of 7.5% increase in daily trips.
With this “correction,” still only a “Payment of fees to fund overall general transportation and circulation improvements in the project vicinity” per P. 3.6-45 with a “Do Not Block Driveway” sign at a singular Project driveway remains all that is called for – absolutely NO CHANGE from the DEIR. This is not only inadequate, but the doubling of the impact from DEIR to R-DEIR should require the proposal of specific soft and alternative hard mitigation measures as a condition of Project approval.
Which further begs the question, given the “correction,” what additional studies/evaluations were made beyond last year’s DEIR to continue to conclude that no feasible measures are available to mitigate this new impact? Pg. 3.6-46. Why isn’t Table 3.6-11 (Mobility Elements Policies), Policy 4.4 further reviewed given the doubling of Dayton Segment trips? It states, “Design intersections… to achieve safe interactions for all modes of travel…” This must happen as part of Project review, and not after the fact. Ignoring the Dayton Segment and the connected intersections is not consistent with CEQA guidelines, and grounds for declaring the Final EIR inadequate.
Pg. 3.6-48.
Why is there no clarification of the RED text, and no strikeout of the erroneous DEIR numbers in Figure 3-6.13? 15 16
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13 Green Hotel Apartments Recirculated Draft EIR Comments February 24, 2015 Presentation to the Design Commission Mike Salazar for the Castle Green Homeowners Association.
Why is there no corresponding “Raymond Ave. & Dayton Street” intersection diagram included in figure 3.6-13, as it has an almost equal impact as the included Fair Oaks & Dayton intersection? Why is there no queuing analysis of Dayton Street at the Raymond intersection? Pg. 3.6-49. Figure 3.6-14.
Why is the Fair Oaks & Dayton St. intersection falsely indicated as a simple cross-traffic intersection, and not as the hazardous, full offset intersection it is?
Why does Figure 3.6-14 omit queuing at Raymond Ave.?
Why does Figure 3.6-14 omit driveway indications for Castle Green rear parking? Why is there no indication here (nor mention anywhere in this report) of the Fire Access route for the Castle Green at the south edge of the frontage on Dayton Street? Now that traffic numbers have doubled on the Dayton Segment, connected intersections should require mitigation measures to be identified and evaluated as part of this Project as called for in the DEIR review comments. It is the proposed Project, as well as Proposed Alternative 2 that both make this Segment and connecting intersections go from bad to worse in the severity of significant and unavoidable impacts. This should be likened to the omission of the pedestrian crosswalk/access at the controversial IDS project, only worse. That omission was a much simpler fault, compared to this issue, and that resulted in a successful action requiring the mitigating of impact and the restudy of Alternatives that significantly reduced the IDS Project overall size and impacts.
Pg. 3.6-51. Doubling the daily trip volume on the Dayton Segment will surely impact emergency access, yet no change has been analyzed, no additional review of the Fire Department has been indicated in the R-DEIR.
Current analysis is based on 50% less impact/traffic, and must be updated in the Final EIR to include all relevant Fire Access issues, such as (but not limited to): a) Dayton & Fair Oaks intersection in relation to trips and Fire Signal crowding of intersection, b) Fire Access roadway standards for all roadway segments (including the unstudied Fair Oaks segment south of Dayton to Del Mar Blvd., c) Fire Access to the existing Green Hotel Apartments, d) Fire Access to the existing Castle Green.
Pg. 3.6-52. Doubling the daily trips volume on this Segment will surely lower the PEQI & BEQI scores, yet no additional review has been made despite doubling vehicular traffic on this Segment and connected intersections.
Also, no mention of this “correction” affecting the relatively new increase in vehicular and pedestrian traffic for the larger new Central Park Playground directly opposite the project.
SECTION 4 - Alternatives
It should be noted that in the introduction paragraph (Pg. 4-1) to this Section, the “correction” is only partially represented, specified as impacting 4.6.2.6, yet omits its major impact on 4.4.4. This has the effect of not only diminishing the actual impact of the “correction” changes, but could lead to the public possibly skipping over the important revision to Section 4.4 “Smaller Scale Alternative,” and this error must be corrected.
How this “correction” impacts 4.6.2.6 is inadequately specified in the intro paragraph, with the R-DEIR using a generically vague phrase, “updated to present new information” in describing the impacts one part of Section 4.
What's important to note is that the "correction" of doubling the daily trips on the Dayton Street Segment as described in Section 3.6 actually impacts Section 4 Alternatives, albeit for some reason applied selectively, in the R-DEIR.
From our perspective, all comments on Alternative 2, a still-missing Alternative 3 and the unrealistic Smaller Scale 6-unit Rejected Alternative, as well as all Alternatives considered are valid topics for comment in this RDEIR review.
The R-DEIR applied the "correction" to the "4.4 Alternatives Considered but Rejected as Infeasible," requiring a significant modification to downsize the still-rejected "Smaller Scale Alternative" (4.4.4) as noted below. Yet when applied to Alternative 2 in "4.3 Selection of Alternatives for Analysis," it only changed traffic counts for Dayton Street Segment, and nothing else, despite the doubling of significant and unavoidable traffic/circulation impacts. 17 18
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21 Green Hotel Apartments Recirculated Draft EIR Comments February 24, 2015 Presentation to the Design Commission Mike Salazar for the Castle Green Homeowners Association.
That is cherry picking and biased, in not applying it further to Alternative 2 and more importantly in not creating Alternative 3 with significant mitigation measures required. Here’s how it breaks down:
Alternative 2: The proposed Alternative 2 (4.3) in the R-DEIR is recalculated to add 479 daily total trips to the Dayton Street Segment, a 54% project increase that is 7-times the City-accepted 7.5% ADT increase – a doubling of the DEIR’s erroneous total of 239 daily trips. Yet there are absolutely NO OTHER CHANGES to Alternative 2, and we are now to accept that it actually makes traffic much worse than last year’s DEIR full Project’s reported 313 trips. Alternative 2 should have been reexamined for reconsideration, with mitigation measures identified and applied to meet CEQA requirements. Yet nothing of the sort happened.
In the DEIR Section 4.6.2.6 on Alternative 2, there are four specific references to the erroneous 313 daily trips for the Project and 239 trips (and 27.1% reduction) in Alternative 2, corrected in the R-DEIR. Yet in the DEIR, (in the 3rd, 4th and 5th paragraphs and in Table 4-6) the erroneous trip numbers are referenced as the justification for Alternative 2. (Only one table - 4-5 - does have the 'corrected' figures in the DEIR). Yet the R-DEIR only corrects these numerical entries to reflect the 626 & 479 respective Dayton Segment trips, and provides no further explanation, unlike the completely revised 13-unit Smaller Scale Alternative (4.4 below) that is completely revised.
Alternative 3: Due to Alternative 2’s increased severity of significant and unavoidable impacts on the Dayton Street Segment, to better represent CEQA’s purpose, a valid Alternative 3 should have then been created and analyzed in this R-DEIR. This should be around the 50% density figure (or less if necessary), and include actual mitigation ‘soft’ and ‘hard’ measures. This was likely a judgment call that seems to fail CEQA intent if not requirements.
An Alternative 3 in this case should be required to not exceed the 313 daily trips erroneously reported for the Project in the DEIR. The 313 trips seemed to be a level of impact that both the City and Developer supported. It should be noted that Table 4-5 from the DEIR already had the correct Trip Generation numbers (626 for the Project on Dayton Segment), and 479 for Alternative 2.
However, if there was an Alternative 3 with 313 maximum trips or there about, that would represent a 50% reduction of the severity of impacts from the Project, a common threshold for CEQA Alternatives that is missing. This possible Alternative 3 would also represent a 35% reduction from Alternative 2, and would clearly be the superior Alternative. This is a missed opportunity, which is why this EIR remains inadequate. There is also no doubt that an Alternative 3 would be considered ‘financially feasible’ as well.
With ‘soft’ and ‘hard’ mitigation measures a possibility, we see this option as necessary per CEQA rules. "Alternatives Considered but Rejected as Infeasible" (4.4): Because last year’s DEIR Alternatives were apparently based on the erroneous 313 daily trips on the Dayton Segment, the DEIR’s proposed a 13-unit residential-only project (with no retail) as the "Smaller Scale Alternative" (4.4.4), because 13 units was then the artificially induced threshold to keep traffic and circulation impacts “less than significant” without any mitigation whatsoever. The DEIR rejected this Alternative only because it was determined to be "financially infeasible" without providing one bit of evidence or guidelines to make this determination. (Public comments at the time asked for the back-up data to prove this, yet the R-DEIR provides none). Nor was there any explanation of why the Smaller Scale Alternative had no mitigation to allow a more financially feasible and realistic option.
Now, in the R-DEIR as a result of the “correction,” the "Smaller Scale Alternative" is reexamined and significantly reduced to only 6 residential units, less than 50% of last year’s 13 units, to reduce traffic/circulation to less than significant levels. Again, this Alternative is rejected for the same stated reason (Section 4.6.2.6) in the R-DEIR. And again, there is no explanation (or guidelines) of why the 21 22
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Green Hotel Apartments Recirculated Draft EIR Comments
February 24, 2015 Presentation to the Design Commission Mike Salazar for the Castle Green Homeowners Association.
Smaller Scale Alternative had no mitigation measures to allow a more financially feasible and realistic option. Clearly the “correction” significantly affected this Smaller Scale Alternative, triggering a complete revision. So why did it NOT require the same for other “considered but rejected Alternatives? Why, for a Smaller Scale Alternative, wasn’t the existing Fair Oaks driveway retained to allow a more realistic and financially feasible project for consideration by taking direct trips off of Dayton Street Segment? (See the following 4.4.1 for more on this existing Fair Oaks driveway). To use the excuse that only a 6-unit project would result in less than significant traffic impacts on Dayton Segment, when the existing 60-space lot has a second driveway on Fair Oaks, seems disingenuous, given the massive impact the Project and Alternative 2 have. How does this meet the spirit, if not the letter of CEQA? Providing such a lowly Alternative of 6 units only is laughable, and so close to “no project” that it is viewed as a waste to consider seriously by the community or the developer. It is hard to see how this meets CEQA, as its only justification is the artificial application of “less than significant impacts” without any mitigation whatsoever.
Section 4.4 "Alternatives Considered but Rejected as Infeasible.” In addition to the “Smaller Scale Alternative” changes noted above, this Section says that the R-DEIR again considered three other rejected alternatives: "Alternate Access Alternative," "Off-Site Parking Alternative," and “Alternate Site Alternative” yet made no changes whatsoever despite the doubling of Dayton Street Segment traffic impacts. What new review has taken place since last year’s DEIR on these Alternatives, in light of the increased severity of significant and unavoidable impacts in the R-DEIR on the Project, Alternative 2, and the Smaller Scale Alternative (rejected)? This lack of revision is subject to question, since these Alternatives – individually, partially or in some combination - could help mitigate some of the 50% increase in daily trips from the R-DEIR’s Project & Alternative 2 on the Dayton Segment. This was a choice by the R-DEIR not to partially or fully reconsider these Alternatives, and that's reason enough to declare the inadequacy of this Report.
4.4.1 Alternate Access Alternative: Perhaps what remains missing in all of the evaluations of this EIR process to date is the overlooked fact that today their exists a second driveway from the existing 60- space surface parking area that actually is on Fair Oaks Avenue. This Alternate Access driveway is virtually omitted from identification and discussion in the body of this R-DEIR and the DEIR. I can only find one indication of it, albeit without any identifying text, on the unrelated Figure 3.1-2 (in the DEIR), “Location of On-Site Trees.”
Was this existing Fair Oaks Avenue driveway studied for retention? Is it buried in the Appendix H, making it hard for the public to find? Why has a project (and alternatives) been selected that actually removes this existing mitigation access from use, effectively choosing to creating a high level of significant and unavoidable impacts and unnecessarily increasing the severity of them on tiny Dayton Street when faced with the true level of impact of the R-DEIR’s “correction.” Again any consideration of a Fair Oaks Avenue access – for all or some of the Project or Alternative 2 daily trips – was again explained away without any modification from the DEIR. Was the severity of Dayton Street Segment traffic “correction” not enough to reconsider this opportunity? Was the fact that the Dayton & Fair Oaks intersection remains unchanged and unstudied in the R-DEIR why a Fair Oaks Avenue Project or Alternative 2 access still is not considered? And why has the R-DEIR failed (as did the DEIR) to present any quantifiable data confirming exactly what study of this (and other rejected Alternatives) has been made and when?
It’s easy math to say that if the current 60 replacement parking spots for the existing Green Hotel building use Dayton Street both presently and in the R-DEIR scenarios, why not consider the separate Fair Oaks 24 25
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28 Green Hotel Apartments Recirculated Draft EIR Comments February 24, 2015 Presentation to the Design Commission Mike Salazar for the Castle Green Homeowners Association.
Avenue access for these vehicles? Has this existing driveway been studied for limited use? We’re talking about providing a driveway, not necessarily a second ramp. Already, the vast majority of the ground floor “open space” is paved/access/parking use. If this takes a proportionate number of daily trips off Dayton Street, then that proportional number of new units, in addition to the 6 units, would lead to “less than significant” impacts. This should be the basis of Alternative 3, triggered by the doubling of daily trips on Dayton.
And if there is even any hope of this project providing on-block parking for the adjacent Castle Green Condominiums, this Alternative Access MUST be studied.
The R-DEIR can’t on one hand say that a Fair Oaks Ave. access is infeasible due to the high volume on Fair Oaks without providing any proof (or aspects studied), then say that the Fair Oaks & Dayton intersection needs no improvements. It is most likely that retaining the existing Fair Oaks access is a challenge due to the existing roadway configurations at the West Dayton & East Dayton intersections and lesser due to solely the “volume.” Yet there is a failure to analyze this issue – one that is left ONLY to create significant & unavoidable impacts.
Another aspect that remains incomplete in this R-DEIR is that this Alternative only considers southbound [INBOUND] project traffic as reason to eliminate Alternate Access on Fair Oaks, by reasoning that because southbound [inbound] traffic would turn left on Green ST., the make successive right turns on Raymond, Dayton and Fair Oaks to get into a FO driveway, so the number of vehicles using Dayton Street would still be high.
Yet this ‘analysis’ again fails to objectively balance its review in examining Fair Oaks Ave. access ‘outflow’ or northbound traffic benefits as well. The correlating outflow traffic from a Fair Oaks access would benefit Dayton Street. That outflow traffic leaving the Project (and Alternatives) would significantly reduce the additional trips on Dayton, as traffic would primarily head north (in using the ‘southbound’ reasoning). Then outbound traffic to south could turn right on Green Street (low impact), then turn right on Raymond (low impact) and head south to Del Mar (very low impact). Seems like a win-win. This is easily achieved by restricting left turns on Fair Oaks from project, thereby eliminating most Dayton traffic outbound. Was this considered?
Unfortunately 4.4.1 only appears to consider one particular type of trip to make a snap judgment against any benefits of Fair Oaks Ave. access, yet provides NO evidence or studies to validate the omission of any Fair Oaks Ave. access for the Project or Alternatives. This one-sided consideration of the inbound traffic points out yet another BIG inadequacy of this R-DEIR process.
4.4.2 Off-Site Parking Alternative: Staff has again cited that Off-Site parking is not permitted by code, yet this is NOT adequate reason for it not to be restudied (or studied in the first place as the case may be). This section fails to acknowledge that the current Castle Green’s 51 units predominantly rely on OffSite parking, with City approve, to this day. This is a prime example of why Off-Site parking has been inadequately studied, and why it deserves to be studied.
For such a significantly historic block, and because of the proposed Project and Alternative 2 significant and unavoidable impacts on Dayton Street, this should be reason enough to have brought forth as a possible required mitigation measure. Yet Staff says it is not allowed, and nothing more, raising the question, why this adequately studied giving the R-DEIR “correction.”
4.4.3 Alternative Site Alternative: Was this option again restudied for the R-DEIR process? If not studied since last year’s DEIR, this is another inadequacy. And what is the point of this section if it can be explained away simply because an owner has no other adjacent property or no “control” of other area properties. What efforts has this owner made to investigate this for the R-DEIR process since last year’s DEIR review? Has the City required the owner to make new efforts for this R-DEIR? This needs to be answered.
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30 Green Hotel Apartments Recirculated Draft EIR Comments February 24, 2015 Presentation to the Design Commission Mike Salazar for the Castle Green Homeowners Association.
The R-DEIR, along with all previous iterations, avoids the necessary/required work of an adequate EIR to actually consider appropriate Alternatives with mitigation measures that would reduce the severity of and the level of significant and unavoidable project impacts. Alternative 2 begins to do that, but clearly a “feasible” Alternative 3 should have been created by now. In fact, Staff stated that it was not the City’s responsibility to create every single alternative. Yet this appears to be an excuse to avoid more appropriate Alternatives scenarios with soft and hard measures that actually mitigate some impacts.
This R-DEIR continues to hide behind the statement that “the addition of 43 new daily trips would exceed the threshold and result in a significant and unavoidable traffic impact to this street segment,” as if no mitigation measures or alternative measures should or can be considered for study and application to the Project and Alternatives. This R-DEIR fails to objectively state the actual situation: “WITHOUT ANY MITIGATION, the addition of 43 new daily trips would exceed the threshold and result in a significant and unavoidable traffic impact to this street segment.” With mitigation measures such as, but not limited to the rejected Alternatives, a new Alternative 3 project could actually be the most appropriate project. Without any mitigation measure for Alternative 2 and no Alternative 3, the inadequacy of this R-DEIR is glaring.
Section 5.0 Other CEQA Considerations
The R-DEIR also has reference to the "correction" in Section 5.2 Significant and Unavoidable Impacts. It states that Section 3 used the erroneous trip numbers, then corrects those numbers, and eliminates the phrase "to this intersection" without a replacement phrase. What they failed to correct is to change this phrase (“to this intersection”) to "in this segment," referring to the Dayton Street Roadway Segment where impacts have doubled.
Here is where the R-DEIR should have provided more clarification of what type of error the "correction" represented and its full scope of impact.
Appendix H
This is the last identified area of change in the R-DEIR, the Traffic Impact Study. What's most inadequate about how the R-DEIR ‘correction’ is handled is that the Traffic Impact Study makes absolutely no mention, nor explanation anywhere in its body of the “correction” until you actually come across the first numerical-only correction (identified only by RED text) on the 40th page. Appendix H retains the same June 2013 general date, and the same June 11, 2013 internal letter with absolutely no mention of corrections or being part of or as a result of the “correction” in the R-DEIR. This puts the public at a disadvantage.
These three numerical changes are only reflected in RED text, on pages 40, 41 & 57. These appear to be minimal numerical corrections only, without so much as a single explanation and raise the question if they have impacts on other data, and if not, why is it?
It also seems that this Study omits any mention of the existing site driveway on Fair Oaks Avenue, and why it was removed and not considered. No plan document indicates the two driveway access points (on Dayton Street and on Fair Oaks Street).
No explanation why Green Street at Fair Oaks and Green Street at Raymond intersections were not studied.
There is no mention of the Fire Station signalized stop in Fair Oaks Avenue description (Pg. 9), nor of the Valley signalized intersection and Orange Pl., compounding the question why this Fair Oaks Roadway Segment is omitted from study. While it appears that the Project increase trips on this Segment may not meet the City’s numerical threshold for study, clearly its challenges should have required its study.
Apparently Table-8 had the correct 626 daily trip numbers in the DEIR, as no correction is noted. 30 31
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Green Hotel Apartments Recirculated Draft EIR Comments
February 24, 2015 Presentation to the Design Commission Mike Salazar for the Castle Green Homeowners Association.
Did the PEQI & BEQI results utilize Figure 23 of the Traffic Study? There is no description of Green Street in description (Pg. 8-9).
ADDITIONAL AREAS of Concern raised by “Correction”
Economic Feasibility as a measure to restrict, disqualify or reject Alternatives.
To date, it should be clear that the City has provided absolutely no quantifiable material to the Design Commission or to the public of the financial infeasibility of project Alternatives, nor has the City provided any information on how this determination was made, nor of the information used to make such a determination, such as thresholds or standards.
It is not easy to initially comprehend how a property purchased in the early 1970s for about $106,000 must have such an impactful level of construction to be financially feasible, given that it is the smaller portion of this property purchased decades ago. The fact that this remained ‘open space’ as unimproved land essentially since its 1895 inception as park of West park, and since its 1970s purchase seems to indicate some financial viability as a lowor-no-build parcel.
We are now at the Recirculated Draft EIR phase and once again call upon this and other relevant information determining financial infeasibility be made public, and an appropriate Public Comment period and hearing be provided for public review, analysis and comments to be made. To wait until the Final EIR is released for disclosure of feasibility standards seems to be a detrimental and unnecessary delay. Given that Staff has been able to make a financial infeasibility judgments in last year’s DEIR, and then again due to this R-DEIR’s “correction,” why is there a delay in making this information available right away? Until such time, it is with the utmost level of concern that this R-DEIR is inadequate as presented. It is essential to understand the CEQA rules allowing disqualifications based on financial infeasibility, and to not appear or to show bias in consideration of Alternatives.
DESIGN REVIEW
The instructions to the Design Commission on Feb. 24, 2015 for the anticipated Concept Design Review are of concern. Staff’s instructions at this hearing may have given the casual observer the impression that only numerical proscriptive building codes are what dictate Concept Design approval of the Project. Furthermore, Staff mentioned that no height, size, etc. could be changed due to concerns about the Final EIR. However, what Staff failed to objectively acknowledge is the ability of the Design Commission to consider and apply the Secretary of Interior Standards, and to not approve the project.
Here are some reasons for being able to reduce the height or size due at Design Review (and not inadequacy of the EIR issues):
Reason 1: The EIR fails to adequately address impacts to historic and cultural resources, as myriad public comment has pointed out over the multiple hearings. Citing Old Pasadena Guidelines and Standards with findings could actually make a case for less height and size. Because a numerical threshold may not have achieved an “impact” in an EIR doesn’t mean that there is no impact to address.
Reason 2: The building envelope of the original proposed project was reduced after great outcry in 2008 & then again in 2010 or 2011. The code allows a ridiculous 97,069 square feet of buildable area, based on lot size and an FAR of 3.00. This zoning capacity was protested in the 1990s before becoming law as part of the General Plan overhaul. Giving this most historic site TOD density was a mistake then and is proven by the very modifications we have witnessed by the Applicant over this project’s long life. 38 39
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42 Green Hotel Apartments Recirculated Draft EIR Comments February 24, 2015 Presentation to the Design Commission Mike Salazar for the Castle Green Homeowners Association.
The City approved an overbearing FAR on this parcel, essentially ignoring the highest historic significance for this block, and all of the surrounding parcels of this block that have significantly lower buildings. In fact, the average height allowed in the four adjacent blocks is 38.75’ of building height (Central District Height Map). And most buildings (except the Schoolhouse Parking Structure) surrounding this site, many from the turn of the 20th century-era, are at or around the 40-foot threshold.
And Central Park is a zero-build site.
Reason 3: The lot coverage of this project has significantly reduced after great outcry, and is far less than the prescriptive code allowances. Far more lot coverage is actually allowed, and if only codes were used, the project would cover far more than it does today. In fact, why wasn’t a bit more lot coverage considered in Project Alternatives to reduce impacts, such as height, view, air, light, etc.? Even though these were not identified in the EIR as being significantly impacted, the public comment sees it otherwise, and the application of codes and guidelines would provide the ability to identify this impact and mitigate it (as possible with the Secretary of Interior Standards).
Reason 4: Just because zoning in place allows for 6 stories doesn’t mean that it is allowable under guidelines in place. There are many zoning components in Old Pasadena that govern this site. The zoning numbers state that a particular FAR and a maximum height is permitted, or “allowed” on this site.
They are not the only requirements – just the most easily quantifiable requirements. The negative impacts of a 6 story building, similar if not almost equal in height to the most historically significant existing building complex in Old Pasadena, “allowed” by current zoning numbers is hard to mitigated, but arguably would not be allowable in objectively applying the Secretary of Interior Standards & other Guidelines applicable in Old Pasadena – guidelines with more ‘subjective,’ non-numerical application.
Bullet points on the DEIR’s general project issues (Areas of Controversy) that need to be addressed with this the “correction” to the Traffic/Alternatives in the R-DEIR:
1. Height inappropriate for this most-significant historic site, with the Project being similar height to landmark structures on the very same block. Further reduction of height could have significantly lessened the severity of significant and unavoidable impacts beyond Alternative 2.
2. Setbacks on Dayton Street could go a long way to provide the physical area to attempt to realign Dayton Street to reduce traffic impacts driven by the R-DEIR corrections. As it is, this Project and Alternative 2 with a Dayton Street zero-setback eliminates any ability to address this significant and unavoidable impact. This is a glaring inadequacy, as the one physical location to make needed mitigation is not studied or even discussed.
3. Additionally, a setback on Dayton Street is necessary for Project (and Alternative 2) not to dominate this historic site, to appropriately respect/acknowledge the adjacent Castle Green that is setback 18 feet at the ground, and about 30 feet 2nd-6 floors from the Dayton frontage, and the zero-density historic Central Park. This Project completely crowds the Dayton/Fair Oaks corner, blocking historic views and unnecessarily eliminating the only logical area to physically address traffic mitigation measures. A Zero setback dominates and disrespects this historic settings and historic surroundings (and is detrimental to historic views and traffic access/safety).
4. Fair Oaks Avenue access now must be reviewed and made feasible, especially in light of the doubling of the actual traffic loads on narrow Dayton Street (and the City policy declaration that NO parking should be removed from Dayton Street).
5. The 626 added daily trips on Dayton Street Segment represent a 70.9% increase in Average Daily Traffic (ADT) volumes. The City maximum increase is 7.5% (Page 3.6-23) to create significant impacts. This Project represents a 9.4x increase, and 8.4x above the acceptable 7.5% increase. Dayton Street is an important eastbound fire access roadway, and provides the ONLY fire apparatus access to the City Treasure Castle Green.
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48 Green Hotel Apartments Recirculated Draft EIR Comments February 24, 2015 Presentation to the Design Commission Mike Salazar for the Castle Green Homeowners Association.
6. Study of Dayton Street Segment and of hard measures to be explored. This should have been required by now. Among the topics requiring study: traffic loads, parking, general accessibility and fire access.
Hard improvements must be required in this Report.
7. Study of the Dayton & Fair Oaks intersection – it remains unsignalized and again ignored, still wrongly represented in Figure 3.6-14 & Appendix H traffic study Figure 23, and fails any real-world navigation tests except in the lightest of traffic conditions. This now must not only be studied, but hard improvements must be required as part of this Report, not put off or ignored further. The Fire Signal that requires traffic to block this intersection must be studied as well.
8. The Raymond & Dayton intersection remains unsignalized, and hard improvements should be identified and required, as the traffic impact is similar to that on Dayton & Fair Oaks intersection.
9. The Green Street & Fair Oaks and Green Street & Raymond intersections should be included in traffic studies, as they are on the same project block and will handle over 50% of project traffic.
10. The Roadway Segment of Fair Oaks from Dayton south to Del Mar is still omitted and should be studied.
This contains the failed Dayton/Fair oaks intersection with the signalized Fire Station stop at its south edge, and two intersections (at Valley and Orange Place) that may be impacted and carry much more traffic from the additional residential units of the East Ambassador campus.
11. A restudy to further analyze impacts of the doubling of daily trips as required in PEQI & BEQI studies on the Dayton Street Segment. It seems hard to believe that in doubling the load on this street that there is NO impact to these two analyses. At minimum, if the impact is purely numerical in nature, at least provide this explanation. But by not addressing it, it is unknown if the R-DEIR impacts these analyses.
12. Real and historic View corridors are in fact eliminated but still not studied: corridors that would be less impacted by a lower project alternative, or by a setback project alternative. These views are from historic Green Hotel and Castle Green, and from historic vantage points, like new residential areas of East Gateway, or from south end of historic Central park. Alternatives could study this oft-stated community concern.
13. Accurate and realistic analyses of air circulation (it was a consideration for the historic Castle Green’s design) and daylight impacts of a 6-story project that could have been studied or further addressed in Alternatives.
I look forward to these and all other comments being considered for necessary revisions to be made before a Final EIR is prepared, for a less impactful project if this is to move forward.
Mike Salazar
for the Castle Green Homeowners Association
99 S. Raymond Avenue
Pasadena, CA 91105
Encl.: March 10, 2014 DEIR Comment Letter from Castle Green HOA/Chatten-Brown & Carstens. 49 50
51 52
53 54
55 56
57
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Letter No. 8 Castle Green Homeowners Association
Castle Green Homeowners Association Michael Salazar
March 2, 2015
Responses
Response 8-1
Section 21091(d)(2)(A) of CEQA and Section 15088 of the state CEQA Guidelines require the lead agency to prepare written responses to comments submitted on a draft EIR during the public review period. While there is no requirement to address comments on a project staff report, such as those submitted by the commenter, the City has prepared the following responses to address the expressed concerns regarding the staff report.
Response 8-2
All comments submitted to the City during the public review period for the original Draft EIR, as well as comments submitted on the Recirculated Draft EIR, are addressed in the written responses contained in the Final EIR. The conclusions of the Draft EIR and Recirculated Draft EIR, as supported by substantial evidence provided therein and augmented by information in the Final EIR (i.e., responses to comments), have not changed – the only unavoidable significant impact that would occur with implementation of the proposed Project is the traffic impact on the segment of Dayton Street between Fair Oaks Avenue and Raymond Avenue. No substantial evidence has been submitted to the City that would change the conclusions provided in the Final EIR.
Response 8-3
The Final EIR for the proposed Project provides a complete and accurate environmental review of the Project, including evaluation of a reasonable range of alternatives, in full accordance with the requirements of CEQA. The Design Commission has received the Final EIR, which includes written responses to all comments received on the Draft EIR and the Recirculated Draft EIR, for review and consideration prior to taking action on the project. At the time the agenda packets are finalized for the hearing at which the Final EIR is presented for certification and the project is presented for approval, the Design Commission will be provided with the Mitigation Monitoring and Reporting Program (MMRP) for the Project, the appropriate CEQA Findings for the Project, pursuant to Section 21081 of CEQA, and a Statement of Overriding Considerations, all of which will be taken into account in conjunction with the Design Commission taking action on the Project. These additional documents will become public at the same time they are provided to the Design Commission.
Response 8-4
The error in the staff report is noted. The project description in the Draft EIR Section 2.7.1 correctly describes the project as“…a six-story mixed-use building with 64 residential units and 5,000 square feet of commercial space…” and this project description was the basis for the environmental analysis.
Response 8-5
The error in the staff report is noted. The project description in the Draft EIR Section 2.7.1 correctly describes the ground floor of the project as having “…20 parking spaces, with 11 of the 20 parking spaces ‘tucked under’ the building.” This project description was the basis for the environmental analysis.
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Response 8-6
The staff report and Draft EIR Section 2.7.1 (Tables 2-2 and 2-3 in particular) all state that the project provides 167 parking spaces. Figure 2-5 in the Draft EIR has been replaced with Figure 2-5a in the Final EIR to reflect the removal of four parking spaces that were erroneously included at the southeast corner of the site. With this revised exhibit incorporated, the Final EIR accurately reflects the total number of parking spaces provided as 167.
Response 8-7
The commenter is correct that the only entitlements required for this project are Concept and Final Design Review. The Draft EIR specifies this in section 2.8.
Response 8-8
The commenter’s characterization of the correction made to the traffic data in the Draft EIR is inaccurate and not consistent with the facts presented in the Recirculated Draft EIR. Contrary to the commenter’s assertion, the correction presented in the Recirculated Draft EIR does not result in, or reflect, a doubling of the daily trips generated by the Project and Alternative 2. As described on page
3.6-1 of the Recirculated Draft EIR, the original Draft EIR inadvertently indicated only the number of daily vehicle trips travelling between the Project site driveway on Dayton Street and either of the intersections located at end of the street. In other words, the 313 daily trips indicated in the Draft EIR as occurring on Dayton Street would either be on the segment extending between the Project site driveway and Fair Oaks Avenue to the west or be on the segment extending between the Project site driveway and Raymond Avenue to the east. When the 313 daily trips occurring on each of those two “half-segments” of Dayton Street are added together, the total would be 626 daily trips. As indicated throughout the Transportation and Circulation section of the Draft EIR (Section 3.6), the daily trip generation associated with the proposed Project was always indicated as 626 (see, in particular, Table 3.6-7 and the associated narrative discussion in the section), and that trip generation number did not change in the Recirculated Draft EIR. The correction made in the Recirculated Draft EIR to indicate a total of 626 average daily trips travelling on Dayton Street comports with that trip generation number, since all project-related trips would occur via the Project site driveway on DaytonStreet. Similarly, the corrections reflected in Section 4.6.2.6 of the Recirculated Draft EIR regarding the transportation and traffic impacts associated with Alternative 2 are simply a matter of adding the daily traffic travelling on the two half-segments of Dayton Street between Fair Oaks Avenue and Raymond Avenue (i.e., 239 daily trips on the segment between Fair Oaks Avenue and the Project site driveway plus 239 daily trips on the segment between the Project site driveway and Raymond Avenue), as reflected by the 479 average daily trips shown for that segment of Dayton Street in Table 4-6 of the Recirculated DEIR (Note: The 239 daily trips indicated in that table was inadvertently not shown in strikeout, but is now included in Section 2, Corrections and Additions, of the Final EIR). As indicated by comparing Table 4-5 in the Draft EIR to Table 4-5 in the Recirculated Draft EIR, there was no change in the trip generation for the proposed Project or Alternative 2 (the Reduced Height Alternative). The subject correction to the characterization of total daily trips on Dayton Street does not affect the remainder of the traffic impacts analysis, including the intersection analyses for Dayton Street/Fair Oaks Avenue and Dayton Street/Raymond Avenue, or any other environmental impacts addressed in the Draft EIR because the assignment/distribution of vehicle trips outside the Project site was correct to begin with and did not change.
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Response 8-9
The revisions made to the Draft EIR’s discussion of the Smaller Scale Alternative that resulted from the correction made to daily traffic volumes on Dayton Street reflect the fact, as stated in the second sentence in Section 4.4.4 of both the Draft EIR and the Recirculated Draft EIR, “The intent of this alternative would be to build a project that would result in less than significant impacts to the Dayton Street segment between Fair Oaks Avenue and Raymond Avenue.” The underlined text that follows that statement in the Recirculated Draft EIR explains the nature of, and basis for, reducing the Smaller Scale Alternative by half. Information regarding the financial feasibility or infeasibility of a reduced scale alternative is not part of the EIR, and is expected to be provided to the Design Commission and the public within the discussion to come in the staff report and/or CEQA findings.
Regarding the commenter’s suggestion to generate an “Alternative 3 around the 50 percent or less size range (below the last year’s acceptable 313 daily trip range),” the Draft EIR already considered and addressed a reasonable range of alternatives. This includes, as specifically related to traffic impacts on Dayton Street, the Reduced Height Alternative with 42 units, which lessened, but did not avoid, the significant traffic impact, and the Smaller Scale Alternative with six units, which would avoid the subject significant impact, but is not a feasible alternative. As discussed in Topical Response TR-ALT-1, Project Alternatives, it is not necessary to further refine and evaluate an additional hypothetical reduced development alternative that does not reduce impacts appreciably, such as the one suggested by the commenter, because the Draft EIR has already addressed a range of alternatives with specific development scenarios that would reduce or avoid the subject significant impact.
Furthermore, the suggested alternative of “around the 50 percent or less size range (below the last year’s acceptable 313 daily trip range)” would not reduce the significant Dayton Street segment impact to a less than significant level. Rather, as noted in Section 4.4.4 of the Recirculated DEIR, the maximum number of residential units that could occur without resulting in a significant traffic impact on Dayton Street would be six.
Response 8-10
As indicated in the responses immediately above, the correction reflected in the Recirculated Draft EIR pertains to only the characterization of total daily trips on Dayton Street, and all other aspects of the environmental analysis of the proposed Project presented in the Draft EIR are unaffected and unchanged. In particular, the data used to calculate air quality and greenhouse gas emissions was not faulty and did not have to be changed or updated, and daily trip generation associated with the proposed Project and the Alternative 2 (the Reduced Height Alternative) did not change, as evidenced by comparing Table 4-5 in the Draft EIR to Table 4-5 in the Recirculated Draft EIR, nor did the assignment/distribution of trips associated with the project. As such, there is no change to the Draft EIR analyses of Air Quality (operational emissions), Greenhouse Gasses (operational GHG emissions), or any other topic area studied in the Draft EIR.
Response 8-11
Written responses to all of the comments and allegations presented in the letter submitted by Chatten-Brown & Carstens LLP on March 10, 2014, on behalf of Castle Green Homeowners Association, are included in the Final EIR. See, specifically, Responses to Comments 4-1 through 4-18.
Written responses to other comments submitted by Castle Green Homeowners Association on the Draft EIR are also contained in the Draft EIR (See Responses to Comments 3-1 through 3-103), along with written responses to all other comments received in the Draft EIR and Recirculated Draft EIR.
The intent of the Recirculated Draft EIR was to present important new information and not to respond to previously provided comments, which is required to be part of the Final EIR per CEQA Guidelines Section 3 Comments and Responses
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§15088.5, Recirculation of an EIR Prior to Certification and §15132, Contents of Final Environmental Impact Report.
Response 8-12
Written responses have been prepared for all comments received on the Draft EIR and Recirculated Draft EIR, and the Final EIR has been completed in accordance with the requirements of CEQA and the state CEQA Guidelines. Additionally, the appropriate CEQA Findings, Statement of Overriding Considerations, and MMRP have been provided to the Design Commission for their review and consideration prior to taking action on the proposed Project.
Response 8-13
The statements quoted from the Recirculated Draft EIR are true and correct. As indicated in the Recirculated Draft EIR and further supported by substantial evidence presented in the above and below responses to comments, the only aspects of the Draft EIR that were materially affected by the correction to the characterization of total daily trips on Dayton Street were limited to only that - the characterization of total daily trips on Dayton Street. The changes in Section 4 related to alternatives were driven solely by the correction to traffic volumes on Dayton Street, both directly for Alternative 2 (i.e., correction to the daily traffic volume indicated for Dayton Street under a Reduced Height Alternative scenario) and indirectly for the Smaller Scale Alternative (i.e., the point of that alternative was to identify a development scenario that would avoid the significant traffic impact on Dayton Street, which, based on the corrected doubling of traffic on Dayton Street, meant that the amount of allowable development generating trips on Dayton Street would need to be reduced by half in order to avoid a significant traffic impact on that street). As these changes were provided in the Recirculated Draft EIR, the public was provided adequate opportunity to understand and comment on them.
Response 8-14
As indicated above in Responses to Comments 3-26 and 4-9, there are no feasible mitigation measures available for the traffic impacts on Dayton Street, either at the numbers stated in the Draft EIR or the numbers stated in the Recirculated Draft EIR.
Some theoretical mitigation measure examples include the installation of curb extensions, traffic signal upgrades/enhancements, and installation of center medians to name a few. These measures will not mitigate or appreciably reduce significant impacts to Dayton Street. As Dayton Street is such a low volume street, the project would have to radically alter its scope in order to reduce its daily trips to a point where impacts would be appreciably reduced or reduced to below a level of significance. The Draft EIR and Recirculated Draft EIR evaluated such a scenario, in terms of the Smaller Scale Alternative, and found it to be infeasible.
Examples of “soft” measures which help to reduce vehicular trips is to provide bicycle parking and the development of a Travel Demand Management Plan (TDM), which the project is subject to by Code. A TDM plan may include but not limited to a bikesharing program, a carsharing program, shuttle service to major transit stops, an on-site transit kiosk, and provide transit passes just to name a few. Such soft mitigation measures would not appreciably reduce impacts or reduce the impacts of the project to below a level of significance.
The PEQI and BEQI scores are a function of existing daily traffic volume collected in March 2013.
Therefore, the correction to the total daily trips on Dayton Street does not affect PEQI, BEQI.
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Response 8-15
The right-hand column in Table 3.6-10 indicates the types of traffic improvement measures appropriate for specific levels of traffic growth on a street segment, as specified by the City’s Transportation Impact Review Current Practices and Guidelines in effect at the time of the analysis.
Table 3.6-5 presented earlier in Section 3.6 of the Draft EIR and the Recirculated Draft EIR delineates the types of multi-modal measures that are associated with various increments of traffic grown on street segments. As indicated in Table 3.6-5, any increase in traffic growth of 7.5 percent or more is subject to the same set of multi-modal measures. Given that the Draft EIR indicated the daily traffic growth on Dayton Street to be 35.4 percent, which was already well above the 7.5 percent threshold, the fact that the corrected traffic volume on Dayton Street increased that number to 70.9 percent does not change the types of multi-modal measures previously specified in the Draft EIR (i.e., the measures are the same for any increase of 7.5 percent or more). As indicated on page 3.6-45 and reiterated on page 3.6-47 of the Recirculated DEIR, no feasible mitigation measures are available to reduce impacts along the Dayton Street segment between Fair Oaks Avenue and Raymond Avenue. That infeasibility finding is unaffected by the correction to the traffic volumes on Dayton Street, and remains the same whether the traffic increase on the subject street segment is 35.4 percent or 70.9 percent. Please also see Response to Comment 8-14 above.
Response 8-16
As indicated above in Response to Comment 8-8, the correction to the characterization of total daily trips on Dayton Street does not affect the analysis of intersection impacts presented in the Draft EIR, including the intersections of Dayton Street/Fair Oaks Avenue and Dayton Street/Raymond Avenue.
Response 8-17
As discussed above in Response to Comment 8-8, the correction to the characterization of total daily trips on Dayton Street has to do with the fact that the Draft EIR inadvertently indicated the traffic volume of 313 trips on each half-segment of Dayton Street between Fair Oaks Avenue and Raymond Avenue (i.e., the half-segment extending between the Project site driveway and Fair Oaks Avenue to the west and the half-segment extending between the Project site driveway and Raymond Avenue to the east), which when added together would be 626 daily trips. Figure 3.6-13 in the Draft EIR presents the PM peak hour turning movement on Dayton Street, as related to potential queuing impacts on Dayton Street. The correction to the daily traffic volumes on Dayton Street does not affect or relate to that peak hour queuing analysis. Regarding the commenter’s question regarding why the information in Figure 3.6-13 does not include the intersection of Dayton Street and Raymond Avenue, it is because there is not a potential queuing issue at that intersection due to its distance from the Project site driveway, as shown on Figure 3.6-14 of the Draft EIR and the Recirculated Draft EIR.
Response 8-18
None of the four questions at the beginning of this comment pertain to the new information presented in the Recirculated Draft EIR, and, as indicated above in Response to Comment 8-8, the correction to the characterization of total daily trips on Dayton Street does not affect or change the intersection impacts analyses presented in the Draft EIR. Also, the subject correction does not affect the analysis of potential traffic hazards, which are addressed on pages 3.6-45 through3.6-49 of the Draft EIR.
Response 8-19
As discussed in Response to Comment 3-27, the City Fire Department has identified Fair Oaks Avenue as the preferred and primary emergency access for the Project, and Dayton Street would only be used as a secondary emergency access for the Project, if circumstances warrant. The City Fire Department Section 3 Comments and Responses
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has stated that Dayton Street meets the Code-required 20 feet of clear roadway width to provide emergency services to the Project site (see page 3.6-49 of the Draft EIR). The intersections at both ends of Dayton Street currently operate at Level of Service A and would continue to operate at Level of Service A with the addition of Project-related traffic on Dayton Street. As indicated above, the intersection impacts analyses in the Draft EIR, including the intersection of Fair Oaks Avenue and Dayton Street, are not affected by the correction to the characterization of total daily trips on Dayton Street.
Response 8-20
Please see Response to Comment 8-14 above.
Response 8-21
Please see Responses to Comments 8-8, 8-9, 8-10, and 8-13 above.
Response 8-22
Please see Response to Comment 8-8 above.
Response 8-23
Please see Response to Comment 8-9 above regarding why the formulation and analysis of an “Alternative 3” is unwarranted, and Response to Comment 8-15 regarding the infeasibility of mitigation measures for the traffic impact on Dayton Street.
Response 8-24
As indicated in Response to Comment 3-23, there are no feasible mitigation measures to address the significant traffic impact on Dayton Street, and the only way to reduce the impact below a level of significance is to reduce the number of trips along this segment. The Smaller Scale Alternative was formulated for that very reason and while the Draft EIR indicated that a reduced scale alternative with no more than 13 units would avoid the significant impact, the correction to the characterization of total daily trips on Dayton Street provided the basis for having to reduce the Smaller Scale Alternative to only six units in order to avoid the significant impact. See Response to comment 8-9 regarding financial infeasibility information
Response 8-25
Section 4.4.1 of the Draft EIR addresses the Alternative Access Alternative, which proposes access to and from the Project’s parking garage would be via Fair Oaks Avenue, and explains the basis for why that alternative access is infeasible. Response to Comment 3-87 provides additional discussion regarding the infeasibility of that alternative.
Response 8-26
As indicated in the introduction of Section 4.4.4 of the Draft EIR and Recirculated Draft EIR, the intent of the Smaller Scale 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. The intent of formulating such an alternative is completely consistent with the CEQA requirement to consider alternatives that could avoid significant impacts. The Draft EIR also includes Alternative 2, the Reduced Height Alternative, which would reduce, but not avoid, that same significant impact, which is also consistent with CEQA requirements relative to considering a reasonable range of alternatives that could reduce or avoid significant impacts. The fact that the Smaller Scale Alternative could only include six units in order to avoid the significant traffic impact and such an alternative is Section 3 Comments and Responses
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infeasible is not, in any way, “a waste to consider” but rather meets the very purpose of CEQA to disclose to the public and decision makers what it would take to avoid the significant traffic impact on Dayton Street. As indicated in Response to Comment 3-23, there are no feasible mitigation measures to address the significant traffic impact on Dayton Street.
Response 8-27
Contrary to the commenter’s claim, Section 4.4 of the Recirculated Draft EIR does not say “that the R-DEIR again considered three other rejected alternatives: ‘Alternative Access Alternative,’ ‘Off-Site Parking Alternative,’ and ‘Alternative Site Alternative’.” Section 1.3 of the Recirculated Draft EIR describes the format of the document, noting that it “focuses on updates to the transportation and traffic analysis (Section 3.6) that was presented in the Draft EIR as well as related corrections within Section 4, Alternatives…” and then goes on to explain how changes to the Draft EIR are indicated (i.e., underlining for new text and strike-out for deleted text). The three subject alternatives were carried into the Recirculated Draft EIR because they are part and parcel of Section 4 of the Draft EIR, and the fact that the Recirculated Draft EIR shows no changes to the discussion of those alternative reflects the fact that the correction to the characterization of total daily trips on Dayton Street does not affect those alternatives in any way.
Response 8-28
Response to Comment 8-25 above notes the fact that the Alternate Access Alternative was addressed in the Draft EIR and further discussed in Response to Comment 3-87, and Response to Comment 8-27 immediately above notes that the correction to the characterization of total daily trips on Dayton Street does not affect the analysis of that alternative in any way. Notwithstanding, the first paragraph in Section 2.2 of the Project Description in 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.
Response 8-29
Response to Comment 8-27 immediately above notes that the correction to the characterization of total daily trips on Dayton Street does not affect the analysis of that Off-Site Parking Alternative in any way. It should also be noted that Castle Green’s reliance on off-site parking stems from the fact that it was built before parking requirements were established. No further response is required.
Response 8-30
Response to Comment 8-27 immediately above notes that the correction to the characterization of total daily trips on Dayton Street does not affect the analysis of that Alternative Site Alternative in any way. No further response is required.
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Response 8-31
The deletion of the words “to this intersection” simply corrects an inadvertent reference to the word “intersection” when it is clear from the entirety of the paragraph, and the remainder of the specific sentence itself, that the only subject at hand is the segment of Dayton Street between Fair Oaks Avenue and Raymond Avenue. Notwithstanding, replacement of the words “to this intersection” with the words “to this segment” is hereby incorporated into the Final EIR, as reflected in Section 2, Corrections and Additions, of the Final EIR.
Response 8-32
The last sentence of the first paragraph on page 3.6-1 of the Recirculated Draft EIR clearly indicates that: The complete Traffic Impact Study for the Proposed Green Hotel Apartments Mixed-Use Development (2013), with the aforementioned correction made in a manner similar to the format of this section of the Recirculated Draft EIR (i.e., deletions indicated in strikethrough text and additions shown as underlined text) can be found in Appendix H of this Recirculated EIR.” The fact that there are very few changes shown in the Traffic Impact Study contained in Appendix H of the Recirculated Draft EIR reflects the fact that the correction to the characterization of total daily trips on Dayton Street has absolutely no material effect on the overall traffic analysis and conclusions, other than the change in the way the volume of project trips on Dayton Street is portrayed. Similarly, the numerical correction does not affect the content of the Traffic Impact Study report cover letter of June 11, 2013.
Response 8-33
The nature of, and basis for, the correction to the characterization of total daily trips on Dayton Street are clearly explained in Section 1, Introduction to the Recirculated Draft EIR, and in the Summary of Revisions as the introduction to Section 3.6, Recirculated Transportation and Circulation, of the Recirculated Draft EIR. The revised Traffic Impact Study, with the changes noted by the commenter, was included as an integral part of the Recirculated Draft EIR, and, as noted in Response to Comment 8-32 above, the nature of the changes made to the Traffic Impact Study is clearly explained on page 3.6-1 of the Recirculated Draft EIR. As explained above in Response to Comment 8-8, and reiterated in several responses thereafter, the subject correction affects only the characterization of total daily trips on Dayton Street as related to the proposed Project, Alternative 2, and the Smaller Scale Alternative; it does not affect other any data or analyses in the Draft EIR.
Response 8-34
Please see Response to Comment 8-28 above.
Response 8-35
Please see Response to Comment 8-8 and 3-25 above.
Response 8-36
Please see Response to Comment 8-19 and 3-42 above.
Response 8-37
Please see Response to Comment 8-8 above, which notes the fact that the daily trip generation associated with the proposed Project was always indicated as 626 (see, in particular, Table 3.6-7 and the associated narrative discussion in the section), and that trip generation number did not change in the Recirculated Draft EIR. The commenter’s observance that Table 8 in the Traffic Impact Analysis had the correct number and did not change as part of the Recirculated Draft EIR comports with that fact.
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Response 8-38
The PEQI analysis and the BEQI analysis are addressed in Sections 9 and 10, respectively, of the Traffic Impact Analysis. Figure 23 of the Traffic Impact Analysis pertains to vehicle queuing conditions, as indicated by the figure title, which does not pertain to the PEQI and BEQI. The correction to the characterization of total daily trips on Dayton Street does not affect PEQI, BEQI, and vehicle queuing.
Response 8-39
Green Street is described in Section 3.6.2.1, Existing Street System, of the Draft EIR, and is unaffected by the correction to the characterization of total daily trips on Dayton Street, as evidenced by the absence of any revisions to that description in Section 3.6.2.1 of the Recirculated Draft EIR.
Response 8-40
The City may consider economic, social, environmental, legal and technological factors when determining the feasibility of alternatives and mitigation measures. There is no requirement that any economic consideration take place in the EIR, and it may take place elsewhere in the administrative record.
Response 8-41
This comment does not pertain to the Recirculated Draft EIR; consequently, no response is required.
Response 8-42
This comment does not pertain to the Recirculated Draft EIR, and in the case of Reasons 2, 3 and 4 in the comment, does not pertain to environmental issues (i.e., pertains to design and code compliance); consequently, no response is required. Notwithstanding, the types of environmental concerns raised in Reason 1 of the comment are generally similar to those previously submitted by the commenter on the Draft EIR, which have been responded to elsewhere in the Final EIR. In particular, please see Topical Response TR-CR-1 regarding potential impacts to historic and cultural resources.
Response 8-43
As explained above in Response to Comment 8-8, and reiterated in several responses thereafter, the subject correction affects only the characterization of total daily trips on Dayton Street as related to the proposed Project, Alternative 2, and the Smaller Scale Alternative; it does not affect other any data or analyses in the Draft EIR. As such, it does not warrant any additional analysis of the Areas of Known Controversy presented in page ES-5 of the Draft EIR.
Response 8-44
This comment does not pertain to the Recirculated Draft EIR; consequently, no response is required.
Notwithstanding, the nature and content of the comment are similar to those of other comments previously submitted by the commenter on the Draft EIR, which have been responded to elsewhere in the Final EIR, including but not limited to Responses to Comments TR-CR-1 and 3-11.
Response 8-45
This comment does not pertain to the Recirculated Draft EIR; consequently, no response is required.
Notwithstanding, the nature and content of the comment are similar to those of other comments previously submitted by the commenter on the Draft EIR, which have been responded to elsewhere in the Final EIR, including but not limited to Responses to Comments TR-CR-1, 3-44, and 5-11.
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Response 8-46
Please see Response to Comment 8-45 above.
Response 8-47
Please see Responses to Comment 3-87, 8-25, and 8-28 above.
Response 8-48
The increase in vehicle trips on Dayton Street was disclosed in several locations in the Recirculated Draft EIR. Please see Response to Comment 8-19 above regarding Fire Department emergency access.
Response 8-49
Please see Response to Comment 8-14 above.
Response 8-50
Please see Response to Comment 8-8 above regarding the fact that the correction to the characterization of total daily trips on Dayton Street does not affect the intersection analysis presented in the Draft EIR. No significant impacts would occur to the intersection of Dayton Street and Fair Oaks Avenue; hence, no improvements to, or mitigation for, that intersection are warranted.
Please also see Response to Comment 3-42 regarding the Fire Signal.
Response 8-51
Please see Response to Comment 8-8 above regarding the fact that the correction to the characterization of total daily trips on Dayton Street does not affect the intersection analysis presented in the Draft EIR. No significant impacts would occur to the intersection of Dayton Street and Raymond Avenue; hence, no improvements to, or mitigation for, that intersection are warranted.
Response 8-52
Please see Response to Comment 8-8 above regarding the fact that the correction to the characterization of total daily trips on Dayton Street does not affect the intersection analysis presented in the Draft EIR. No significant impacts would occur to the intersections of Green Street and Fair Oaks Avenue and Green Street and Raymond Avenue; hence, no improvements to, or mitigation for, those intersections are warranted. Please also see Response to Comment 3-25 for discussion of the specific intersections cited in this comment.
Response 8-53
The correction to the characterization of total daily trips on Dayton Street does not affect the Draft EIR analysis of traffic on Fair Oaks Avenue; consequently no further analysis of traffic on Fair Oaks Avenue is warranted. Please also see Response to Comment 3-42 for discussion of the segment of Fair Oaks Avenue south of Dayton Street.
Response 8-54
As indicated above in Responses to Comments 8-8 and 8-38, the correction to the characterization of total daily trips on Dayton Street is, indeed, numerical only and does not affect the PEQI and BEQI analyses completed for the Draft EIR.
Response 8-55
Please see Response to Comment 8-44 and TR-AES-1 above.
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Response 8-56
Please see Response to Comment 8-44, 3-6 and 3-7 above.
Response 8-57
Comment noted.
Response 8-58
The presence of the existing driveway on Fair Oaks Avenue is the focus of the Alternative Access Alternative addressed in Section 4.4.1 of the Draft EIR. Please also see Response to Comment 8-28 above.
3.3.5 Comments Received at the Public Hearing on the Recirculated Draft EIR The following summarizes comments on environmental topics that were received from the public and the City of Pasadena Design Commission at the public hearing held on the Recirculated Draft EIR on Tuesday, February 24, 2015 and provides responses to these comments. Comments are paraphrased and not written verbatim. In one case, public comments expressed during oral testimony were read from, or otherwise reflected by, the written comments submitted by the speaker. Comments expressed at the hearing that were not submitted in writing are responded to immediately below, whereas comments expressed at the hearing that were also submitted in writing are responded to above in the responses to individual comment letters received on the Recirculated Draft EIR.
Public Comments
Mike Salazar on behalf of Castle Green Homeowners Association The comments presented in the oral testimony from Mr. Salazar are included in the written comments that he subsequently submitted to the City. Please see Comment Letter No. 8 above and the associated written responses.
Dianne Patrizzi
Comment No. 1: Ms. Patrizzi expressed concern that development of the proposed project would block the view of Castle Green from Dayton Street.
Response: View impacts associated with the proposed Project are addressed in Section 3.1, Aesthetics, of the Draft EIR, and further discussed in Topical Response TR-AES-1. The analysis concluded that existing views will be impacted by development of the Project; however, the impacts would be less than significant.
Comment No. 3: Ms. Patrizzi expressed concern about constructing two levels of subterranean parking beneath “a crumbling building.”
Response: As shown in Figures 2-6 and 2-7 of the Draft EIR, the proposed subterranean parking garage for the Project would not extend beneath any existing structures, such as the existing Hotel Green Apartments or Castle Green, and would be well removed/distant from those buildings. In addition, MM-NOISE-4 and MM-NOISE-5 provide measures to ensure that vibration associated with construction of the project would not affect the adjacent historic buildings and that any damage that may occur be repaired by the project applicant.
Section 3 Comments and Responses
3-158
Green Hotel Apartments Final EIR
Comment No. 3: Habitat loss from the removal or relocation of existing trees was not addressed in the Draft EIR.
Response: As indicated in Section II.6 of the Initial Study completed for the EIR, contained in Appendix A of the Draft EIR, the project is currently used as a surface parking lot and located in a highly developed urbanized area of the City. The project site is surrounded by commercial, retail, and high-density residential land uses, along with Central Park to the south. Although trees are present on the project site, no known candidate, sensitive, or special status species exist on or in the immediate vicinity of the site, per the CDDB database. In addition, the project site and surrounding area do not provide suitable habitat for sensitive species and the project would not directly affect or modify the habitat of any identified sensitive species. As such, the issue of habitat impacts associated with the loss/relocation of on-site trees did not require further evaluation in the Draft EIR.
City of Pasadena Design Commission Comments on the Recirculated DEIR Commissioner Maitless: Was off-site parking considered for the project? Response: Explanation of the Off-Site Parking Alternative is provided in Section 4.4.2 of the Draft EIR.
Commissioner Rawlings: Are there measures that could reduce the traffic impacts on Dayton Street, even if they don’t completely eliminate the significant impact? Response: Appendix H to the Draft EIR includes a Traffic Impact Study – Acceptance Letter dated June 12, 2013 and includes recommended conditions of approval to incorporate into the project that would assist in reducing but not eliminating the identified significant traffic impact on Dayton Street. Also see Response to Comment 8-14 above.
Commissioner Rawlings: Relative to the infeasibility of the alternatives, was a “pro forma” done on all the alternatives?
Response: See Response to Comment 8-9 for information about provision of financial feasibility information.
4-1
Green Hotel Apartments Final EIR
Section 4
Mitigation Monitoring and Reporting Program
A Mitigation Monitoring and Reporting Program (MMRP) describes the procedures that will be followed to implement the mitigation measures adopted in connection with the approval of the proposed project and the methods for monitoring such actions. The MMRP has been prepared in conformance with Section 21081.6 of the California Environmental Quality Act (CEQA). The intent of the program is to (1) verify satisfaction of the required mitigation measures of the EIR; (2) provide a methodology to document implementation of the required mitigation; (3) provide a record of the monitoring program; (4) identify monitoring responsibility; (5) establish administrative procedures for the clearance of mitigation measures; (6) establish the frequency and duration of monitoring; and (7) utilize existing review processes wherever feasible. A MMRP is necessary only for impacts which would be significant if not mitigated. The following table consists of the mitigation measures associated with the proposed project, as well as specific conditions of approval identified for the purpose of addressing significant impacts, and provides and entry for each measure that notes the timing of the measure, the responsible entity for mitigation monitoring, an entry to record when the mitigation measure was completed, and the measures effectiveness.
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Section 4 Mitigation Monitoring and Reporting Program 4-3
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Table 4-1 Mitigation Monitoring and Reporting Program
Mitigation Measure
Responsible
Implementation
Party
Monitoring
Period
Monitor/
Reporter/
Monitoring Agency
Documentation of Compliance
Action/Reports Effectiveness Sign-off/Date
Air Quality
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.
Construction
Contractor
During
construction
Department of
Planning and
Development,
Building & Safety
Division
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.
Construction
Contractor
During
construction
Department of
Planning and
Development,
Building & Safety
Division
Noise and Vibration
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.
Construction
Contractor
Prior to start of
construction
Department of
Planning and
Development,
Building & Safety
Division
Section 4 Mitigation Monitoring and Reporting Program 4-4
Green Hotel Apartments Final EIR
Mitigation Measure
Responsible
Implementation
Party
Monitoring
Period
Monitor/
Reporter/
Monitoring Agency
Documentation of Compliance
Action/Reports Effectiveness Sign-off/Date
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 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 noisesensitive receptors.
City of Pasadena
Building
Department
Prior to
approval of
grading plans
and/or prior to
issuance of
demolition,
grading and
building
permits
Department of
Planning and
Development,
Building & Safety
Division
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.
Construction
Contractor
During
construction
and operation
Department of
Planning and
Development,
Building & Safety
Division
Section 4 Mitigation Monitoring and Reporting Program 4-5
Green Hotel Apartments Final EIR
Mitigation Measure
Responsible
Implementation
Party
Monitoring
Period
Monitor/
Reporter/
Monitoring Agency
Documentation of Compliance
Action/Reports Effectiveness Sign-off/Date
MM NOISE-1: Construction Time Limits. Prior to
issuance of grading and/or building permits, contractor specifications shall include a note indicating that noisegenerating 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
noise-generating construction activities shall be
permitted.
City of Pasadena
Building
Department
Prior to
issuance of
grading and/or
building
permits
Department of
Planning and
Development,
Building & Safety
Division
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.
City of Pasadena
Building
Department
Prior to
issuance of
building
permits
Department of
Planning and
Development,
Building & Safety
Division
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 Avenue would be at least 24 Aweighted decibels (dBA).
City of Pasadena
Building
Department
Prior to
issuance of
building
permits
Department of
Planning and
Development,
Building & Safety
Division
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
City of Pasadena
Building
Department
Prior to
issuance of an
occupancy
permit
Department of
Planning and
Development,
Building & Safety
Division
Section 4 Mitigation Monitoring and Reporting Program 4-6
Green Hotel Apartments Final EIR
Mitigation Measure
Responsible
Implementation
Party
Monitoring
Period
Monitor/
Reporter/
Monitoring Agency
Documentation of Compliance
Action/Reports Effectiveness Sign-off/Date
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.
City of Pasadena
Building
Department
Prior to
issuance of an
occupancy
permit
Department of
Planning and
Development,
Building & Safety
Division
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.
City of Pasadena
Building
Department
Prior to
issuance of an
occupancy
permit
Department of
Planning and
Development,
Building & Safety
Division
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.
Construction
Contractor
During
construction
and operation
Department of
Planning and
Development,
Building & Safety
Division
Section 4 Mitigation Monitoring and Reporting Program 4-7
Green Hotel Apartments Final EIR
Mitigation Measure
Responsible
Implementation
Party
Monitoring
Period
Monitor/
Reporter/
Monitoring Agency
Documentation of Compliance
Action/Reports Effectiveness Sign-off/Date
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 Apartment building and the 84 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 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 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 post-demolition
surveys of the existing Green Hotel Apartment
building and the 84 Fair Oaks Avenue
structure.
o Examples of measures that may be specified
for implementation during demolition or
City of Pasadena
Building
Department
Prior to
approval of
grading plans
and/or prior to
issuance of
demolition,
grading and
building
permits.
Department of
Planning and
Development,
Building & Safety
Division
Section 4 Mitigation Monitoring and Reporting Program 4-8
Green Hotel Apartments Final EIR
Mitigation Measure
Responsible
Implementation
Party
Monitoring
Period
Monitor/
Reporter/
Monitoring Agency
Documentation of Compliance
Action/Reports Effectiveness Sign-off/Date
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 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 vibrationcaused damage as a result of construction of the project. Any 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.
City of Pasadena
Building
Department
At construction
completion and
prior to
issuance of
occupancy
permit
Department of
Planning and
Development,
Building & Safety
Division
Section 4 Mitigation Monitoring and Reporting Program 4-9
Green Hotel Apartments Final EIR
Mitigation Measure
Responsible
Implementation
Party
Monitoring
Period
Monitor/
Reporter/
Monitoring Agency
Documentation of Compliance
Action/Reports Effectiveness Sign-off/Date
Transportation and Circulation
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.
City of Pasadena
Department of
Transportation
At completion
of construction
and prior to
issuance of
occupancy
permit
Department of
Planning and
Development,
Building & Safety
Division;
Department of
Transportation
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.
Construction
Contractor
During
construction
Department of
Planning and
Development,
Building & Safety
Division;
Department of
Transportation
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.
Construction
Contractor
During
construction
Department of
Planning and
Development,
Building & Safety
Division;
Department of
Transportation
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i
Green Hotel Apartments Final EIR
Attachment 1
Design Process Memorandum
Table of Contents
ii
Green Hotel Apartments Final EIR
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ARCHITECTURAL RESOURCES GROUP, INC.
Architects, Planners & Conservators
Design Process Memorandum
Green Hotel Apartments
86 South Fair Oaks Ave., Pasadena
Prestige Homes, Inc.
August 1, 2014
The proposed Hotel Green Apartments (the “Project”) has been designed to provide an attractive project that is compatible with the adjacent Hotel Green and Castle Green and to meet the Secretary of the Interior’s Standards. In fact, ARG undertook an extensive effort to research, design, and improve the Project to adhere as closely as possible to Colonel Green’s original vision for the Project Site. Thus, the Project that respects and complies with the general parameters of the historic vision, including the size, scale, and function of the buildings and landscape. Further, the Historic Resources Technical Report for the EIR, prepared by Historic Resources Group, thoroughly analyzed the Project and determined that it meets the Secretary of the Interior’s Standards. Provided below is a discussion of ARG’s design process for the project with respect to size, footprint, and massing.
Background
Renderings of an addition to the hotel appeared after the turn of the 20th century, at which time the hotel consisted of 1) the original hotel building on the east side of S. Raymond Ave. (completed in 1889) and 2) the West Annex (1899), later known as the Castle Green, on the west side of S. Raymond Ave. along with the connecting bridge built over the street to serve both buildings.
A third unit, now known as the Hotel Green, lies perpendicular to the Castle Green/West Annex along E.
Green St. When it was first proposed in 1902, it was conceived as an L-shaped block that would span the Green St. as well as the Fair Oaks Ave. frontage. However, only the Green St. block was completed. The current proposed Project would place a new apartment building in the general configuration of the unrealized Fair Oaks block that hotel owner Colonel George Gill Green proposed in 1902. After the opening of the Green St. block, he still intended to pursue construction of the Fair Oaks block, which would have added more hotel rooms, a theater, and ground-floor retail, as well as the opportunity to redefine the garden in the center of the property.
In order to adhere as closely as possible to Col. Green’s intentions, ARG had two tasks in the design process:
the first was to determine, lacking any available plans, the volume and the footprint of the wing as it was proposed and illustrated in 1902-1903. Second was to evaluate the program for the Project and determine how to make it complement the parameters of the 1902 building with respect to size, scale, and function of the buildings and landscape. To determine the height, massing, design, and placement of the building, we had three historic illustrations at our disposal as well as descriptions from newspaper articles.
Design Process Memorandum
August 1, 2014
p. 2 of 6
ARCHITECTURAL RESOURCES GROUP, INC.
Architects, Planners & Conservators
1) Birdseye View, Annual Report of the Auditor of the City of Pasadena, 1902‐1903. 2) Collection of Pasadena Museum of History.
3) Board of Trade publication/illustrated souvenir pamphlet: Pasadena, California. Directors of Board of Trade. 1903.
Design Process Memorandum
August 1, 2014
p. 3 of 6
ARCHITECTURAL RESOURCES GROUP, INC.
Architects, Planners & Conservators
Size and Massing: 1902
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.1 There also appears (in Figs.
2, 3) to be an attic story in the north and south ends below the hipped roofs. The massing of the building, which we noted mainly from Figure 1, was two larger hipped-roof pavilions at the north and south ends with a narrower connecting segment in between. The footprint of the north pavilion is, for the most part, defined by its hipped roof, but much of that roof over north pavilion, then, is incorporated within the Wooster Block (see overlap of north hipped roof and mass of Wooster Block in Fig. 1).
From Fig. 3 we determined that the first floor of the building was proposed to meet the sidewalk on S. Fair Oaks, with a small setback on Dayton St. to the south. The building is connected to the Green St. block on the north end. Above the first floor, portions of the building are set back on the west, south, and east to create a kind of gallery or promenade overlooking the streets and parks. An open arcade with a pavilion in the center (recalling the bridge over S. Raymond Ave.) spans the garden, enclosing the north portion of it from Dayton St.
We referred to Fig. 1 to determine the east-to-west width of the building. The west side is shown to be aligned at the sidewalk but stepped back on the upper floors by a width of one bay. A newspaper article from February, 1902 noted that the balcony was to be up to 16 feet deep in places, giving an indication of the depth of the setback. The width of the building would have accommodated a double-loaded corridor and rooms along each side. A south-end unit, or perhaps the end of each corridor, terminated in a recessed balcony at the south end as seen in Fig. 3.
An article nearly a year later, on Jan. 1, 1903, noted that there would be 165 rooms in the Fair Oaks wing (and a similar number in the Green St. wing). This translates to approximately 33 rooms per floor, but the number of window bays in the renderings does not allow for nearly that many units (there are only nine full-size windows facing out on each flank of the wing per floor). The rooms are noted to be 14-16 feet by 18-20 feet, or in the range of 250 to 320 square feet, but it is unclear from the description whether this includes the bathrooms and closets which are mentioned separately. With these discrepancies, the room count does not align with the renderings. In addition, the volume of the theater may have occupied some portion of the upper floors. These discrepancies seem to indicate that the design for the building may have still been in development and not yet fully resolved.
1 Note that the massing of the Castle Green is significantly distorted in the birds eye view in Fig. 1. This is easily seen by comparing the actual footprint of the building in Fig. 4 with its appearance in Fig. 1. It is likely that the two north-south wings (Fair Oaks and Castle Green/West Annex) were to be similar in massing, as seen in Fig. 3.
Design Process Memorandum
August 1, 2014
p. 4 of 6
ARCHITECTURAL RESOURCES GROUP, INC.
Architects, Planners & Conservators
4) Aerial view of the existing Castle/Hotel Green with proposed (1902) footprint indicated in orange. 5) ARG sketch showing approximation of the volume of the Fair Oaks block as proposed by Col. Green.
Design Process Memorandum
August 1, 2014
p. 5 of 6
ARCHITECTURAL RESOURCES GROUP, INC.
Architects, Planners & Conservators
The orange dotted line in Fig. 4 above shows the approximate footprint of Col. Green’s proposed Fair Oaks block. This outline is based mainly on Fig. 1 above. The east line is based on the alignment with the cupola near the inside corner (i.e., the northwest corner of the garden). The west boundary is indicated at the sidewalk, as seen in Fig. 3, and the south boundary was set back from the sidewalk, as seen in Fig. 1. Note, however, that the articulation of the bays, fenestration patterns, and the roofline of the Green Street block were not built as proposed in these illustrations, and the south elevation was greatly simplified. Fig. 5 is a diagrammatical view by ARG intended to complement and clarify what is seen in the historic renderings.
ARG’s Design Response
The dimensions of the addition proposed in 1902 described above are based on the renderings circulated in the press and some specific information from newspaper sources, as noted. 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.
The footprint of the existing, historic buildings are based on a professional surveyor’s measurements. We have used these surveyor’s measurements and our CAD drawings to determine the relative distances between the proposed and historic buildings on the property. From the historic renderings shown above, we determined that the width of the garden (i.e., the space between the West Annex and the Fair Oaks Block) proposed in 1902 was approximately 155’-160’ based on the known dimensions of the existing buildings on the property and the renderings of architect Frederick Roehrig’s design for the Fair Oaks Block. Leaving room for error due to the imprecise nature of the historic renderings, ARG’s design has moved as close as possible to adhering to the width of garden as it was proposed in 1902 by remaining comparable to the width of the footprint that was proposed at that time.
The Project’s proposed design also had to take into account modern day constraints and protecting the historic features of the Hotel Green itself which Col. Green’s 1902 plan would have modified. Thus, the proposed Project does not touch or extend from the south face of the former Wooster Block and so does not form a continuous L-shape. The proposed building is free-standing. Col. Green’s early proposal was for an L-shaped wing to be built all at once, with the Fair Oaks and Green St. wings to be connected. Later, a small commercial building, now a contributor to the Old Pasadena National Register District, was constructed just south of the former Wooster Block (northwest corner of the property) on Fair Oaks.
The connection of the two buildings (historic Hotel Green and new apartment building) has not been proposed in this Project for several reasons. First, the connection would cause physical changes to the historic features of the Hotel Green itself, including the removal of a south-facing hanging balcony at the fifth floor. Second, it avoids the need to demolish a contributing building to the Old Pasadena Historic District. The retention of the space between the buildings also allowed all of the existing apartment units in the Hotel Green to remain intact.
The provision of this buffer space between the two buildings, however, also added to the necessary volume of the proposed building when compared to a longer, narrower (1902) building that would have reached an additional 38 feet (approximately) to the north (see Fig. 4) to connect with the Green St. block. The north-tosouth dimension proposed today is shorter than that proposed in 1902 due to the space retained between the Green St. and Fair Oaks blocks. The east-to-west dimension, however, is comparable to that of the 1902 proposal. This means that the currently proposed footprint is actually smaller in area than that of the 1902 Design Process Memorandum
August 1, 2014
p. 6 of 6
ARCHITECTURAL RESOURCES GROUP, INC.
Architects, Planners & Conservators
proposal. The overall volume, however, is wider above the first floor since there is no significant setback at the 2nd floor level as Col. Green’s scheme proposed.
ARG designed the project 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).
Meeting the Standards for Rehabilitation
Adhering as closely as possible to the historically proposed volume of the Fair Oaks block was a strategy for achieving compatible new construction on the property and meeting the Secretary of the Interior’s Standards.
Although the current project is not a treatment of a historic building, the new construction is proposed within the historic property of the Hotel Green and, due to the historic association, the subject parcel was included within the National Register listing for the property (though by that time it had been subdivided into three parcels).
Through the process of analyzing the existing historic buildings as well as the information we have about the early, unbuilt designs for the property, ARG has designed a project that successfully meets the Standards.
The Historic Resources Technical Report for the EIR made the same finding as well. The critical measurement of the width of the building, and therefore the distance between the new building and the historic Castle Green, appears to be consistent with what was intended with the proposed 1902 addition.
Based on historic illustrations and current measurements, the proposed Project is compatible with the adjacent historic buildings and consistent with the historic plans for an addition to the property.
APPENDIX J
Supplemental Noise Analysis for Section 7.10
Federal Transit Administration Yes
Noise Impact Assessment Spreadsheet No
version: 1/29/2019 Project Noise Exposure/Ldn (dBA)
Project Noise Exposure/Leqh (dBA)
Project: 86 Fair Oaks Avenue Project Noise Exposure/Ldn (dBA) Project Results Summary
Existing Ldn: 56 dBA
Total Project Ldn: 35 dBA 1. Outdoor Quiet
Receiver Parameters Total Noise Exposure: 56 dBA 2. Residential Receiver: Green Hotel Apartments Increase: 0 dB 3. Institutional Land Use Category: 2. Residential Impact?: None
Existing Noise (Measured or Generic Value): 56 dBA
Distance to Impact Contours
Dist to Mod. Impact Contour
(Source 1): 23 ft Fixed Guideway
Dist to Sev. Impact Contour
(Source 1): 13 ft Highway/Transit
Noise Source Parameters Stationary Source
Number of Noise Sources: 1 --
1 Bus Operating Facility
Noise Source Parameters Source 1 Bus Storage Yard
Source Type: Stationary Source Bus Transit Center
Specific Source: Parking Garage Source 1 Results Crossing Signals Daytime hrs Avg. Number of Autos/hr 53 Leq(day): 31.7 dBA Ferry Terminal (no fog horn) \ Leq(night): 27.5 dBA Ferry Terminal (w/ fog horn)
55 Ldn: 34.8 dBA Layover Tracks (commuter rail)
Parking Garage
Nighttime hrs Avg. Number of Autos/hr 20 Park & Ride Lot 40 Rail Yard & Shops
65 --
--
Distance Distance from Source to Receiver (ft) 150
Number of Intervening Rows of Buildings 0 2 Automated Guideway Transit /Rubber Tire Adjustments Noise Barrier? No Automated Guideway Transit /Steel Wheel Diesel Electric Locomotive
Diesel Multiple Unit (DMU)
Electric Locomotive
Locomotive Warning Horn
Monorail
Fixed Guideway Maglev
Rail Car Rail Car
3 Rail Transit Vehicle/Streetcar <= 25 mph
40 Rail Transit Vehicle/Streetcar > 25 mph
2.8 Transit warning device
3 3 Bus Operating Facility
40 Bus Storage Yard
0.7 Bus Transit Center
Crossing Signals
Distance 50 Ferry Terminal (no fog horn)
1 Ferry Terminal (w/ fog horn)
Adjustments Noise Barrier? No Layover Tracks (commuter rail) Joint Track/Crossover? No Parking Garage
Embedded Track? No Park & Ride Lot
Aerial Structure? No Rail Yard & Shops
--
--
Stationary Source
Transit warning device 4 Automobiles and Vans
Buses (diesel-powered)
50 Buses (electric)
0.465 Buses (hybrid)
--
--
50 --
0.11 --
--
Distance 50 --
0 --
Adjustments Noise Barrier? --
5 Bus Operating Facility
Bus Storage Yard
Bus Transit Center
Crossing Signals
Highway/Transit Ferry Terminal (no fog horn)
Buses (hybrid) Ferry Terminal (w/ fog horn)
Layover Tracks (commuter rail)
50 Parking Garage
1 Park & Ride Lot
Rail Yard & Shops
--
50 --
0.44 6 Automobiles and Vans
Distance 70 Buses (diesel-powered)
0 Buses (electric)
Adjustments Noise Barrier? Buses (hybrid)
--
--
--
--
--
Stationary Source --
Parking Garage --
--
Distance
Adjustments Noise Barrier?
Highway/Transit
Buses (diesel-powered)
0.0 dBA
0.0 dBA
Distance
Adjustments Noise Barrier?
40 45
50 55
60 65
70 75
80 85
40 45 50 55 60 65 70 75 80
Project Noise Exposure/Ldn (dBA)
Existing Noise Exposure (dBA)
Noise Impact Criteria
(FTA Manual, Fig 4-2)
Moderate Impact
Severe Impact
Green Hotel
Apartments
0 0 dB
5 10
15 20
40 45 50 55 60 65 70 75 80
Noise Exposure Increase (dB)
Existing Noise Exposure (dBA)
Increase in Cumulative Noise Levels Allowed
(FTA Manual, Figs 4-3 and 4-4)
Moderate Impact Severe Impact Green Hotel Apartments
Land Use Code
Setting
Time Period
Trip Type
# Data Sites
Time Entering Exiting Entering Exiting Entering Exiting 12-1 AM 0.7 0.3 0.8 0.2 2.6 0
1-2 AM 0.3 0.2 1.3 0.1 0.4 0
2-3 AM 0.2 0.2 0.8 0.3 0.9 0.9
3-4 AM 0.4 0.3 0.6 0.3 0.4 0
4-5 AM 0.3 0.8 0.6 0.0 0.4 1.8
5-6 AM 0.6 2.7 2.3 1.6 0.4 3.1
6-7 AM 1.5 6.5 4.1 4.1 1.8 8.0
7-8 AM 2.8 12.1 4.2 17.7 5.3 12.0
8-9 AM 3.5 8.8 5.1 9.2 4.8 10.2
9-10 AM 2.9 5.7 2.5 5.6 5.7 4.9
10-11 AM 2.7 4.7 4.4 3.8 2.2 4.9
11-12 PM 4.5 4.5 3.1 5.7 3.9 2.7
12-1 PM 4.8 4.6 4.7 5.2 4.4 2.7
1-2 PM 4.1 4.8 5.3 3.7 3.9 6.7
2-3 PM 5.8 5.0 5.9 3.3 3.9 4.9
3-4 PM 6.7 4.9 6.2 4.4 6.1 4.0
4-5 PM 10.6 6.2 10.0 4.7 4.8 5.8
5-6 PM 12.6 7.7 8.7 4.1 8.3 7.6
6-7 PM 9.3 6.6 6.7 8.6 8.8 4.0
7-8 PM 7.8 4.8 6.7 4.4 7.9 4.4
8-9 PM 7.0 3.3 5.1 4.3 7.0 2.2
9-10 PM 5.5 2.2 4.6 3.1 5.3 4.9
10-11 PM 3.6 1.9 4.4 2.8 7.0 3.1
11-12 AM 2.0 1.1 1.9 2.8 3.5 1.3
Hourly Trips Average Daytime Average Nighttime
12-1 AM 1.0 0.5 4 4
1-2 AM 0.5 0.25 2 2
2-3 AM 0.4 0.2 2 2
3-4 AM 0.7 0.35 3 3
4-5 AM 1.1 0.55 5 5
5-6 AM 3.3 1.65 14 14
6-7 AM 8.0 4 35 35
7-8 AM 14.9 7.45 65 65
8-9 AM 12.3 6.15 53 53
9-10 AM 8.6 4.3 37 37
10-11 AM 7.4 3.7 32 32
11-12 PM 9.0 4.5 39 39
12-1 PM 9.4 4.7 41 41
1-2 PM 8.9 4.45 39 39
2-3 PM 10.8 5.4 47 47
3-4 PM 11.6 5.8 50 50
4-5 PM 16.8 8.4 73 73
5-6 PM 20.3 10.15 88 88
6-7 PM 15.9 7.95 69 69
7-8 PM 12.6 6.3 55 55
8-9 PM 10.3 5.15 45 45
9-10 PM 7.7 3.85 33 33
10-11 PM 5.5 2.75 24 24
11-12 AM 3.1 1.55 13 13
ADT 866
53 20
Weekday Weekday Weekday
Vehicle Vehicle Vehicle
8 4 3
% of 24-Hour Traffic % of 24-Hour Traffic % of 24-Hour Traffic Hourly Distribution of Entering and Exiting Vehicle Trips by Land Use Source: ITE Trip Generation Manual , 10th Edition
221
General Urban/Suburban Dense Multi-Use Urban Center City Core Multifamily Housing (Mid-Rise)