Cities Index.
AR 16 ATTACHMENT H

Pasadena City Council
October 24, 2022

Document
AR 16 ATTACHMENT H
Meeting
October 24, 2022
Body
Pasadena City Council
Pages
8
Original file
159.3 MB
Text extracted from the city's file for reading and search. Open the original on ww2.cityofpasadena.net. That file is the official record.

Planned Development #39 (Affinity Project)
City Council

ATTACHMENT H

DRAFT EIR
Draft Environmental Impact Report
SCH No. 2021080103
Affinity Project
Prepared for City of Pasadena
Planning and Community Development Department
175 North Garfield
Pasadena, California 91101
Prepared by Psomas
225 South Lake Avenue, Suite 1000
Pasadena, California 91101
January 2022

Affinity Project Draft EIR
i Table of Contents

TABLE OF CONTENTS
Section Page
Executive Summary .............................................................................................................. ES-1 Introduction ...................................................................................................... ES-1 Project Location and Setting ........................................................................... ES-1 Project Description .......................................................................................... ES-2 Project Alternatives ......................................................................................... ES-3 Issues to be Resolved ..................................................................................... ES-4 Areas of Controversy ....................................................................................... ES-4 Summary of Significant Environmental Impacts .............................................. ES-5 Section 1.0 Introduction ...................................................................................................... 1-1

1.1 Purpose of the EIR ................................................................................. 1-1

1.1.1 Regulatory Framework ................................................................ 1-1

1.1.2 Lead Agency ............................................................................... 1-1

1.1.3 Incorporation by Reference ......................................................... 1-1

1.2 EIR Focus ............................................................................................... 1-2

1.2.1 Scoping Process ......................................................................... 1-2

1.3 Project Applicant and Contact Person .................................................... 1-7

1.4 Public Review of the Draft EIR ............................................................... 1-7

1.5 Decision-Making process ........................................................................ 1-8 Section 2.0 Environmental Setting and Project Description ............................................ 2-1

2.1 Project Location ...................................................................................... 2-1

2.2 Project Setting and Characteristics ......................................................... 2-1

2.2.1 On-site and Surrounding Land Uses ........................................... 2-1

2.2.2 Physical Characteristics .............................................................. 2-2

2.2.3 Relevant Planning Considerations .............................................. 2-4

2.3 Project Objectives ................................................................................... 2-5

2.4 Project Description.................................................................................. 2-6

2.4.1 Proposed Land Uses .................................................................. 2-7

2.4.2 Construction Scenario ............................................................... 2-12

2.4.3 Project Operation ...................................................................... 2-13

2.5 Planned Development Plan and Exchange Program ........................... 2-14

2.6 Approach to Cumulative Impact Analysis ............................................. 2-15

2.7 Intended Uses of the EIR ...................................................................... 2-18

2.7.1 City of Pasadena ....................................................................... 2-18

2.7.2 Responsible and Trustee Agencies .......................................... 2-18

2.8 References ........................................................................................... 2-19 Affinity Project Draft EIR
ii Table of Contents
Section 3.0 Environmental Analysis ................................................................................... 3-1

3.1 Air Quality ............................................................................................ 3.1-1

3.1.1 Existing Conditions .................................................................. 3.1-1

3.1.2 Relevant Programs and Regulations ....................................... 3.1-7

3.1.3 Thresholds of Significance ..................................................... 3.1-12

3.1.4 Methodology .......................................................................... 3.1-12

3.1.5 Environmental Impacts .......................................................... 3.1-14

3.1.6 Cumulative Impacts ............................................................... 3.1-27

3.1.7 Mitigation Measures ............................................................... 3.1-27

3.1.8 Level of Significance After Mitigation ..................................... 3.1-28

3.1.9 Summary of Analysis ............................................................. 3.1-28

3.1.10 References ............................................................................. 3.1-28

3.2 Cultural and Paleontological Resources .............................................. 3.2-1

3.2.1 Existing Conditions .................................................................. 3.2-1

3.2.2 Relevant Cultural Resource Regulations ................................. 3.2-4

3.2.3 Thresholds of Significance ..................................................... 3.2-11

3.2.4 Methodology .......................................................................... 3.2-12

3.2.5 Environmental Impacts .......................................................... 3.2-12

3.2.6 Cumulative Impacts ............................................................... 3.2-15

3.2.7 Mitigation Measures ............................................................... 3.2-16

3.2.8 Level of Significance After Mitigation ..................................... 3.2-17

3.2.9 Summary of Analysis ............................................................. 3.2-17

3.2.10 References ............................................................................. 3.2-18

3.3 Energy ................................................................................................. 3.3-1

3.3.1 Existing Conditions .................................................................. 3.3-1

3.3.2 Relevant Programs and Regulations ....................................... 3.3-1

3.3.3 Thresholds of Significance ....................................................... 3.3-3

3.3.4 Methodology ............................................................................ 3.3-3

3.3.5 Environmental Impacts ............................................................ 3.3-4

3.3.6 Cumulative Impacts ................................................................. 3.3-8

3.3.7 Mitigation Measures ................................................................. 3.3-8

3.3.8 Level of Significance After Mitigation ....................................... 3.3-8

3.3.9 Summary of Analysis ............................................................... 3.3-9

3.3.10 References ............................................................................... 3.3-9

3.4 Greenhouse Gas Emissions ................................................................ 3.4-1

3.4.1 Existing Conditions .................................................................. 3.4-1

3.4.2 Relevant Programs and Regulations ....................................... 3.4-5

3.4.3 Thresholds of Significance ..................................................... 3.4-13

3.4.4 Methodology .......................................................................... 3.4-14

3.4.5 Environmental Impacts .......................................................... 3.4-14

3.4.6 Cumulative Impacts ............................................................... 3.4-22

3.4.7 Mitigation Measures ............................................................... 3.4-22

3.4.8 Level of Significance After Mitigation ..................................... 3.4-22

3.4.9 Summary of Analysis ............................................................. 3.4-22

3.4.10 References ............................................................................. 3.4-23

3.5 Hazards and Hazardous Materials ...................................................... 3.5-1

3.5.1 Existing Conditions .................................................................. 3.5-1

3.5.2 Relevant Programs and Regulations ....................................... 3.5-5

3.5.3 Thresholds of Significance ....................................................... 3.5-9 Affinity Project Draft EIR
iii Table of Contents

3.5.4 Methodology .......................................................................... 3.5-10

3.5.5 Environmental Impacts .......................................................... 3.5-10

3.5.6 Cumulative Impacts ............................................................... 3.5-13

3.5.7 Mitigation Measures ............................................................... 3.5-14

3.5.8 Level of Significance After Mitigation ..................................... 3.5-14

3.5.9 Summary of Analysis ............................................................. 3.5-14

3.5.10 References ............................................................................. 3.5-14

3.6 Land Use and Planning ....................................................................... 3.6-1

3.6.1 Existing Conditions .................................................................. 3.6-1

3.6.2 Relevant Programs and Regulations ....................................... 3.6-2

3.6.3 Thresholds of Significance ....................................................... 3.6-6

3.6.4 Methodology ............................................................................ 3.6-6

3.6.5 Environmental Impacts ............................................................ 3.6-6

3.6.6 Cumulative Impacts ............................................................... 3.6-25

3.6.7 Mitigation Measures ............................................................... 3.6-25

3.6.8 Level of Significance After Mitigation ..................................... 3.6-25

3.6.9 Summary of Analysis ............................................................. 3.6-25

3.6.10 References ............................................................................. 3.6-26

3.7 Noise ................................................................................................... 3.7-1

3.7.1 Existing Conditions .................................................................. 3.7-1

3.7.2 Relevant Programs and Regulations ....................................... 3.7-5

3.7.3 Thresholds of Significance ..................................................... 3.7-10

3.7.4 Methodology .......................................................................... 3.7-10

3.7.5 Environmental Impacts .......................................................... 3.7-11

3.7.6 Cumulative Impacts ............................................................... 3.7-19

3.7.7 Mitigation Measures ............................................................... 3.7-20

3.7.8 Level of Significance After Mitigation ..................................... 3.7-21

3.7.9 Summary of Analysis ............................................................. 3.7-21

3.7.10 References ............................................................................. 3.7-22

3.8 Public Services and Recreation ........................................................... 3.8-1

3.8.1 Existing Conditions .................................................................. 3.8-1

3.8.2 Relevant Programs and Regulations ....................................... 3.8-6

3.8.3 Thresholds of Significance ....................................................... 3.8-9

3.8.4 Methodology .......................................................................... 3.8-10

3.8.5 Environmental Impacts .......................................................... 3.8-10

3.8.6 Cumulative Impacts ............................................................... 3.8-14

3.8.7 Mitigation Measures ............................................................... 3.8-16

3.8.8 Level of Significance After Mitigation ..................................... 3.8-16

3.8.9 Summary of Analysis ............................................................. 3.8-16

3.8.10 References ............................................................................. 3.8-17

3.9 Transportation...................................................................................... 3.9-1

3.9.1 Existing Conditions .................................................................. 3.9-1

3.9.2 Relevant Programs and Regulations ....................................... 3.9-4

3.9.3 Thresholds of Significance ....................................................... 3.9-6

3.9.4 Methodology ............................................................................ 3.9-7

3.9.5 Environmental Impacts ............................................................ 3.9-9

3.9.6 Cumulative Impacts ............................................................... 3.9-13

3.9.7 Mitigation Measures ............................................................... 3.9-13

3.9.8 Level of Significance After Mitigation ..................................... 3.9-13 Affinity Project Draft EIR
iv Table of Contents

3.9.9 Summary of Analysis ............................................................. 3.9-13

3.9.10 References ............................................................................. 3.9-14

3.10 Tribal Cultural Resources .................................................................. 3.10-1

3.10.1 Existing Conditions ................................................................ 3.10-1

3.10.2 Relevant Programs and Regulations ..................................... 3.10-1

3.10.3 Thresholds of Significance ..................................................... 3.10-3

3.10.4 Methodology .......................................................................... 3.10-3

3.10.5 Environmental Impacts .......................................................... 3.10-3

3.10.6 Cumulative Impacts ............................................................... 3.10-5

3.10.7 Mitigation Measures ............................................................... 3.10-6

3.10.8 Level of Significance After Mitigation ..................................... 3.10-7

3.10.9 Summary of Analysis ............................................................. 3.10-7

3.11 Utilities and Service Systems ............................................................ 3.11-1

3.11.1 Existing Conditions ................................................................ 3.11-1

3.11.2 Relevant Programs and Regulations ..................................... 3.11-7

3.11.3 Thresholds of Significance ................................................... 3.11-12

3.11.4 Methodology ........................................................................ 3.11-13

3.11.5 Environmental Impacts ........................................................ 3.11-13

3.11.6 Cumulative Impacts ............................................................. 3.11-27

3.11.7 Mitigation Measures ............................................................. 3.11-29

3.11.8 Level of Significance After Mitigation ................................... 3.11-29

3.11.9 Summary of Analysis ........................................................... 3.11-29

3.11.10 References ....................................................................... 3.11-29 Section 4.0 Alternatives ....................................................................................................... 4-1

4.1 Introduction ............................................................................................. 4-1

4.1.1 Criteria for Selecting Alternatives ................................................ 4-1

4.1.2 Alternatives to the Proposed Project ........................................... 4-3

4.2 Alternatives Eliminated From Detailed Consideration ............................ 4-4

4.2.1 Alternative Site ............................................................................ 4-4

4.2.2 Project with No Variance for Historic Resources ........................ 4-5

4.3 Alternatives Carried Forward for Detailed Consideration ....................... 4-6

4.3.1 Alternative 1: No Project/No Development ................................. 4-6

4.3.2 Alternative 2: Project Development with Existing Zoning ............ 4-9

4.3.3 Alternative 3: All Residential Project with Variance for Historic Resources .................................................................... 4-15

4.3.4 Alternative 4: All Medical Office Project with Variance for Historic Resources .................................................................... 4-21

4.4 Environmentally Superior Alternative .................................................... 4-26

4.5 References ........................................................................................... 4-30 Section 5.0 Other Required CEQA Considerations ........................................................... 5-1

5.1 Significant Irreversible Environmental Changes ..................................... 5-1

5.2 Growth-Inducing Impacts ........................................................................ 5-2

5.3 References ............................................................................................. 5-6 Affinity Project Draft EIR
v Table of Contents
Section 6.0 Document Preparers and Contributors .......................................................... 6-1

6.1 City of Pasadena Planning and Community Development Department . 6-1

6.2 City of Pasadena Department of Transportation .................................... 6-1

6.3 Consultants ............................................................................................. 6-1 TABLES
Table Page
ES-1 Summary of Project Impacts, Mitigation, and Level of Significance After Mitigation ........................................................................................................................... 7 1-1 Summary of Comments Received During Scoping Period............................................. 1-2 2-1 Summary of Existing Land Uses .................................................................................... 2-1 2-2 Tree Inventory Summary ................................................................................................ 2-3 2-3 Summary of Proposed Land Uses ................................................................................. 2-8 2-4 City of Pasadena General Plan Development Caps .................................................... 2-17 2-5 City of Pasadena Remaining Development Capacity .................................................. 2-17 2-6 Other Agency Approvals and Requirements ................................................................ 2-18

3.1-1 Air Quality Monitoring Data From the Pasadena-South Wilson Avenue Monitoring Station ......................................................................................................................... 3.1-5

3.1-2 Attainment Status of Criteria Pollutants in the South Coast Air Basin......................... 3.1-6

3.1-3 Peak Daily Existing Emissions .................................................................................... 3.1-7

3.1-4 California and Federal Ambient Air Quality Standards ................................................ 3.1-8

3.1-5 SCAQMD Air Quality Significance Thresholds .......................................................... 3.1-13

3.1-6 Estimated Maximum Daily Construction Emissions for the Project ........................... 3.1-17

3.1-7 Localized Construction Emissions for the Project ..................................................... 3.1-18

3.1-8 Net Operational Emissions for the Project ................................................................ 3.1-19

3.1-9 Localized Operational Emissions for the PRoject ..................................................... 3.1-20

3.1-10 Estimated Maximum Daily Construction Emissions for the Project with Building A Residential/Commercial ............................................................................................ 3.1-21

3.1-11 Localized Construction Emissions for the Project with Building A Residential/Commercial ............................................................................................ 3.1-22

3.1-12 Net Operational Emissions for the Project with Building A Residential/Commercial ............................................................................................ 3.1-23

3.1-13 Localized Operational Emissions for the Project with Building A Residential/Commercial ............................................................................................ 3.1-24

3.2-1 Previously Recorded Historical Resources on the Project Site ................................... 3.2-2

3.2-2 Previously Recorded Historical Resources in the Project Vicinity ............................... 3.2-3

3.3-1 Construction-Related Energy Use for the Project ....................................................... 3.3-4

3.3-2 Energy Use During Operation of the Project ............................................................... 3.3-5

3.3-3 Construction-Related Energy Use for the Project With Building A Residential/Commercial .............................................................................................. 3.3-6

3.3-4 Energy Use During Operation of the Project with Building A Residential/Commercial .............................................................................................. 3.3-7

3.4-1 Comparison of Worldwide GHG Emissions ................................................................ 3.4-3

3.4-2 Estimated Annual GHG Emissions for Uses to be Removed ...................................... 3.4-4

3.4-3 City of Pasadena Climate Action Plan Efficiency Thresholds ................................... 3.4-14

3.4-4 Estimated GHG Emissions from Construction of the Project .................................... 3.4-15

3.4-5 Estimated Annual Net GHG Emissions from Operation of the Project ...................... 3.4-16

3.4-6 GHG Efficiency Metric for the Project ....................................................................... 3.4-16 Affinity Project Draft EIR
vi Table of Contents

3.4-7 Estimated GHG Emissions from Construction of the Project with Building A Residential/Commercial ............................................................................................ 3.4-17

3.4-8 Estimated Annual Net GHG Emissions from Operation of the Project with Building A Residential/Commercial ........................................................................... 3.4-18

3.4-9 GHG Efficiency Metric for the Project with Building A Residential/Commercial ........ 3.4-19

3.5-1 Summary of Existing Land Uses ................................................................................. 3.5-1

3.5-2 Land Use History ......................................................................................................... 3.5-2

3.6-1 Summary of Existing Land Uses ................................................................................. 3.6-1

3.7-1 Short-Term Ambient Noise Measurements ................................................................. 3.7-4

3.7-2 City of Pasadena Guidelines for Noise Compatible Land Use .................................... 3.7-7

3.7-3 Construction Vibration Damage Criteria .................................................................... 3.7-10

3.7-4 Construction Noise Levels at Surrounding Receptors............................................... 3.7-12

3.7-5 Net Trip Generation for the Project ........................................................................... 3.7-13

3.7-6 Net Street Segment Volumes with the Project (Year 2026) ...................................... 3.7-14

3.7-7 Net Trip Generation for the Project with Building A Residential/Commercial ............ 3.7-16

3.7-8 Vibration Levels for Construction Equipment ............................................................ 3.7-17

3.7-9 Vibration Levels and Building Damage at Surrounding Uses.................................... 3.7-18

3.8-1 Pasadena Fire Department Facilities Serving the Project Site.................................... 3.8-2

3.8-2 Pasadena Unified School District Facilities Serving the Project Site .......................... 3.8-4

3.8-3 City of Pasadena Parks and Recreation Facilities Serving the Project Site ................ 3.8-5

3.9-1 Transit Facilities Hierarchy .......................................................................................... 3.9-2

3.9-2 Existing Transit Service in the Project Area ................................................................ 3.9-3

3.9-3 Bicycle Facilities Hierarchy ......................................................................................... 3.9-4

3.9-4 City of Pasadena CEQA Transportation Thresholds ................................................... 3.9-7

3.9-5 Transportation Impact Analysis Summary for the Project ......................................... 3.9-10

3.9-6 Transportation Impact Analysis Summary for the Project with Building A Residential/Commercial ............................................................................................ 3.9-10

3.11-1 Pasadena Water Supply Sources and Quantities (AFY) ........................................... 3.11-2

3.11-2 PWP Imported Water Supplies (AFY) ....................................................................... 3.11-2

3.11-3 Groundwater Volume Pumped (AFY) ....................................................................... 3.11-4

3.11-4 Historic Project Site Water Demand .......................................................................... 3.11-5

3.11-5 Existing Wastewater Generation ............................................................................... 3.11-6

3.11-6 PWP’s 2020 Water Demands ................................................................................. 3.11-16

3.11-7 PWP Projected Water Demand (AF) ....................................................................... 3.11-17

3.11-8 Project Water Demand ............................................................................................ 3.11-18

3.11-9 PWP Normal-Year Potable Water Supply and Demand Comparison (AFY) ........... 3.11-19

3.11-10 PWP Single-Dry-Year Potable Water Supply and Demand Comparison (AFY) .. 3.11-21

3.11-11 PWP Multiple-Dry-Year Potable Water Supply and Demand Comparison (AFY) 3.11-22

3.11-12 Five-Year Drought Risk Assessment ................................................................... 3.11-22

3.11-13 Project with Building A with Residential/Commercial Water Demand .................. 3.11-24 4-1 Summary of Alternatives ................................................................................................ 4-4 4-2 Alternative 2 Transportation Analysis Comparison ...................................................... 4-14 4-3 Alternative 3 Transportation Analysis Comparison ...................................................... 4-19 4-4 Alternative 3 Utility Comparison ................................................................................... 4-20 4-5 Alternative 4 Transportation Analysis Comparison ...................................................... 4-24 4-6 Alternative 4 Utility Comparison ................................................................................... 4-25 4-7 Comparison of Impacts for Project Alternatives ........................................................... 4-28 4-8 Ability of Project Alternatives to Meet Objectives ......................................................... 4-29

Affinity Project Draft EIR
vii Table of Contents

EXHIBITS
Exhibit Follows Page
2-1 Regional Location and Local Vicinity ........................................................................... 2-1 2-2 Existing Project Site .................................................................................................... 2-1 2-3 Aerial Photograph ....................................................................................................... 2-1 2-4 Project Site Plan .......................................................................................................... 2-7 2-5 First (Ground) Level Plan ............................................................................................ 2-7 2-6 Level 2 Plan ................................................................................................................ 2-7 2-7 Level 3 Plan ................................................................................................................ 2-7 2-8 Level 4 Plan ................................................................................................................ 2-7 2-9 Level 5 Plan ................................................................................................................ 2-7 2-10 Level 6 Plan ................................................................................................................ 2-7 2-11 Level 7 Plan ................................................................................................................ 2-7 2-12 East and North Elevations ........................................................................................... 2-9 2-13 West and South Elevations ......................................................................................... 2-9 2-14 Cross Section (North-South) ....................................................................................... 2-9 2-15 Affinity Project Shadow Study ..................................................................................... 2-9 2-16a–e Conceptual Landscape Plan ..................................................................................... 2-11 2-17a–b Conceptual Utility Plans ............................................................................................ 2-12

APPENDICES
Appendix
A-1 Initial Study/Notice of Preparation
A-2 Scoping Period Comments
B Air Quality and Greenhouse Gas Emissions Modeling Data C-1 Historic Resources Assessment
C-2 Cultural Resources Records Search
C-3 Paleontological Resources Records Search
D Energy Modeling Data
E Phase I Environmental Site Assessment
F Noise Modeling Data
G-1 Transportation Impact Analysis/CEQA Evaluation for Project G-2 Transportation Impact Analysis/CEQA Evaluation for Project with Building A Residential/Commercial
H Assembly Bill 52 Outreach Records
I Water Supply Assessment

Affinity Project Draft EIR
viii Table of Contents
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Affinity Project Draft EIR
ES-1 Executive Summary

EXECUTIVE SUMMARY

INTRODUCTION
The California Environmental Quality Act (CEQA) (Section 21000 et. seq. of the California Public Resources Code) requires that lead agencies consider the potential environmental consequences of projects over which they have discretionary approval authority prior to taking approval action on such projects. An Environmental Impact Report (EIR) is a public document designed to provide the City, trustee and responsible agencies, the general public, and other interested parties with an analysis of potential environmental consequences of a project and to support informed decision making by the Lead Agency. The City of Pasadena (City) is the Lead Agency under CEQA and is responsible for preparing the EIR. This determination is made in accordance with Sections 15051 and 15367 of the State CEQA Guidelines, which define the Lead Agency as the public agency that has the principal responsibility for carrying out or approving a project.

This EIR has been prepared to identify, analyze, and mitigate, to the extent feasible, the potential environmental effects associated with implementation of The Affinity Project (Project or Project with Building A Residential/Commercial). This EIR has been prepared pursuant to the requirements of CEQA and the Guidelines for the Implementation of CEQA (State CEQA Guidelines) (Title 14, California Code of Regulations, Chapter 3, Sections 15000 et. seq.).

This Executive Summary has been prepared in accordance with Section 15123(a)(b) of the State CEQA Guidelines, which states that an EIR should contain a brief summary of the proposed actions and its consequences and should identify (1) each significant effect with proposed mitigation measures and alternatives that would reduce or avoid that effect; (2) areas of controversy known to the Lead Agency; and (3) issues to be resolved, including the choice among alternatives and whether or how to mitigate significant effects.

PROJECT LOCATION AND SETTING
The City of Pasadena (City) is situated along the western edge of the San Gabriel Valley and at the foothills of the San Gabriel Mountains. The Project site is in the southwestern quadrant of the City and to the southeast of the State Route (SR)-110 and Interstate-210 (I-210) intersection.

The Project site encompasses approximately 3.3 acres (144,853 square feet [sf]) located between 465 and 577 South Arroyo Parkway, City of Pasadena, Los Angeles County. The site is bound by East Bellevue Drive on the north, South Arroyo Parkway on the east, East California Boulevard on the south, and the Metro Gold (L) Line on the west.

The Project site consists of five parcels developed with a total of nine commercial buildings with seven businesses. All existing buildings on the site are one or two stories with heights ranging between 17 feet and 63 feet. All existing land uses have surface parking except for the Whole Foods Market, which has a 275-space subterranean parking structure for its sole use. Table 2-1, Summary of Existing Land Uses, summarizing the existing on-site land uses; and Exhibit 2-2, Existing Project Site, illustrating the addresses and locations of the nine existing buildings and other on-site land uses, is provided in Section 2.0, Project Description, of this EIR.

The Project area is an urban environment, and the site and surrounding area are fully built out with a broad mix of land uses. These land uses also represent a variety of ages, architectural styles, heights, and conditions. Exhibit 2-3, Aerial Photograph, depicting the site and existing land use types in the surrounding area is provided in Section 2.0, Project Description, of this EIR.

Affinity Project Draft EIR
ES-2 Executive Summary
Commercial land uses are primarily located to the north, including retail, services, and restaurants. Other land uses to the north include medical offices; Pasadena Humane Society, located approximately 0.1-mile to the northwest; Central Park, located approximately 0.2-mile northwest of the site; and single- and multi-family residential land uses located, at the nearest, approximately 0.2-mile to the north on Del Mar Boulevard and approximately 0.1-mile to the northnortheast on Bellevue Drive. Commercial land uses are located opposite the Project site on Arroyo Parkway. Single- and multi-family residential land uses are situated less than 0.1-mile to the east along Marengo Avenue and Arroyo Parkway. Land uses to the south include a mix of commercial, medical office, and single- and multi-family residential land uses; the latter is located along Marengo Avenue and California Boulevard to the southeast. To the west, there is a mix of commercial and non-profit (i.e., npr/KPCC and Union Station Homeless Services) uses. Further from the site, land uses include a mix of commercial, medical, light industrial, single- and multifamily residential, and public (e.g., schools, churches, parks).

Regional access to the site is provided by SR-110 located approximately 0.6-mile due south on Arroyo Parkway. Local access is provided by adjacent surface streets and Metro’s Del Mar Station located approximately 0.2-mile to the north. Exhibit 2-1, Regional Location and Local Vicinity, illustrates the Project site location and is provided in Section 2.0, Project Description, of this EIR.

PROJECT DESCRIPTION
The Applicant requests approval to rezone the Project site from CD-6 to a Planned Development (PD) zone, and approval of a PD Plan. The Project involves demolition of 6 (of the 9) existing buildings totaling 45,912 sf, located at 491, 495, 499, 503, 541, and 577 South Arroyo Parkway, and construction of 2 new buildings, as identified below:
 Building A: a 154,000-sf, 7-story (aboveground) medical office building with ground-floor commercial uses;
 Building B: a 184,376-sf, 7-story (aboveground) assisted living building with 85,800 sf of assisted living uses and 98,576 sf of independent living uses including up to 95 studio, one-, and two-bedroom senior housing units; and
 Up to 850 parking spaces in 5 subterranean levels.

Alternatively, the proposed PD Plan would provide the flexibility to exchange the uses in Building A from medical office and ground floor commercial for the following:
 3,000 sf of commercial and a sales/leasing management office on the ground floor;  Up to 197 residential dwelling units; and
 Up to 650 parking spaces in 4 subterranean levels (1 less parking level than the Project as proposed).

Although the Project described is anticipated to reflect the Project to be constructed, the flexibility to exchange the uses in Building A would enable the Project to respond to the economic needs and demands of the City at the time of Project implementation. The proposed site layout and the aboveground height, mass, and other parameters of the Building A design would remain the same. The PD Plan would define all aspects of site design and provide caps on the types and amounts of allowable land uses, regardless of whether Building A is developed with medical office or residential dwelling units. It is noted that based on the development cap of 87 dwelling units per acre (du/acre), a total of 289 units could be constructed. Therefore, if a total of 197 units were constructed in Building A, only 92 senior housing units (i.e., 3 fewer units than the Project as proposed) could be constructed in Building B. Conversely, if 95 senior housing (i.e., independent living) units were constructed in Building B, only 194 units could be constructed in Building A.

Affinity Project Draft EIR
ES-3 Executive Summary
Throughout the CEQA documentation, these two development scenarios will be referred to as:
 Project (development of Building A with medical office/commercial), and  Project with Building A Residential/Commercial (development of Building A with residential/commercial).

A total of 5 levels of subterranean parking spanning both proposed buildings with up to 850 parking spaces would be constructed to serve the new development as well as the existing structures at 501 and 523 South Arroyo Parkway under the Project scenario. When including the new subterranean parking, the Project would consist of approximately 753,439 sf of new construction. For the Project with Building A Residential/Commercial, a total of 4 levels of subterranean parking spanning both proposed buildings with up to 650 parking spaces would be constructed to serve the new development as well as the existing structures at 501 and 523 South Arroyo Parkway.

Approximately 79,553 sf of the existing development would be retained and integrated into the Project, including the Whole Foods Market and associated 275-space subterranean parking structure at 465 South Arroyo Parkway, and the 2 historic structures at 501 and 523 South Arroyo Parkway. The Applicant anticipates that restaurant uses would occupy the approximately 5,882 sf of space in the existing buildings to be retained at 501 and 523 South Arroyo Parkway. In retaining these structures, the Applicant is also requesting a zoning variance for historic resources related to building height. Specifically, the Applicant is requesting an increase in allowable building height of the two new buildings to offset the reduction in developable area due to preserving the two historic structures (i.e., 501 and 523 South Arroyo Parkway) on the Project site. Exhibit 2-4, Project Site Plan, provided in Section 2.0, Project Description, of this EIR, depicts a schematic overview of the Project design.

PROJECT ALTERNATIVES
Section 15126.6 of the State CEQA Guidelines requires an evaluation of the comparative effects of a reasonable range of alternatives to the proposed Project that would feasibly attain most of the proposed Project objectives and would avoid or substantially lessen any of the significant impacts of the proposed Project. A feasible alternative is one that can be accomplished successfully in a reasonable period of time, taking economic, legal, social, and technological factors into consideration. The range of alternatives is governed by the “rule of reason” that requires the EIR to set forth only those alternatives necessary to permit a reasonable choice.

In accordance with Section 15126.6 of the State CEQA Guidelines, Section 4.0, Alternatives, of this EIR addresses alternatives to the proposed Project. Section 4.0 provides a description of each alternative; a comparative analysis of the potential environmental effects of each alternative to those associated with the proposed Project; a discussion of each alternative’s ability to meet the Project objectives; and a discussion of the environmentally superior alternative. For complete description of all Project alternatives analyzed in this EIR, refer to Section 4.0. The following is a summary description of the alternatives evaluated in this EIR:
 Alternative 1 – No Project/No Development. This alternative addresses one of the two types of “No Project” alternatives identified by CEQA. Under the No Project/No Development Alternative, the existing environmental setting would remain unchanged.

The City would not rezone the Project site from CD-6 (Central District Specific Plan [CDSP], Arroyo Corridor/Fair Oaks subdistrict), to a Planned Development (PD) zone, approve the PD Plan, nor would the City approve the Project or Project with Building A Residential/Commercial. This Alternative assumes the Project site would continue to remain in its existing state without demolition of any existing structures and site Affinity Project Draft EIR
ES-4 Executive Summary
improvements, and the continued use and operation of the existing land uses present at the time the NOP was distributed in August 2021.
 Alternative 2 – Project Development with Existing Zoning. Alternative 2 assumes the site is developed with the same land uses as the Project or Project with Building A Residential/Commercial but with application of existing zoning (i.e., no PD Plan).

Alternative 2 would result in demolition of 6 (of the 9) existing buildings totaling 45,912 sf, same as the Project, and a total of 217,280 sf of aboveground development–including the 79,553 sf of existing development to be retained. As such, this alternative would result in construction of 2 new buildings with 137,727 sf of new development, a total of 387 parking spaces in 3 subterranean levels, and a maximum height of 50 feet or 65 feet with height averaging. Alternative 2 with Building A Residential/Commercial could result in up to 108 residential dwelling units and 3,000 sf of commercial, with up to 282 parking spaces in 2 subterranean levels.
 Alternative 3 – All Residential Project with Variance for Historic Resources.

Alternative 3 assumes the demolition of 6 (of the 9) existing buildings totaling 45,912 sf, and a total of 417,929 sf of aboveground development – including the 79,553 sf of existing development to be retained, same as the Project. However, Alternative 3 assumes the new buildings would include up to 289 market-rate residential units (i.e., apartments and/or condominiums), except for ground-floor commercial in Building A, and a total of 607 parking spaces in 4 subterranean levels.
 Alternative 4 – All Medical Office Project with Variance for Historic Resources.

Alternative 4 assumes the demolition of 6 (of the 9) existing buildings totaling 45,912 sf, and a total of 417,929 sf of aboveground development – including the 79,553 sf of existing development to be retained, same as the Project. However, Alternative 4 assumes the new buildings would include solely medical office uses except for ground-floor commercial in Building A, and a total of 1,218 parking spaces in 7 subterranean levels.

ISSUES TO BE RESOLVED
Section 15123(b)(3) of the State CEQA Guidelines requires that an EIR contain a discussion of issues to be resolved, including the choice among alternatives and whether or how to mitigate significant impacts. With respect to the proposed Project or Project with Building A Residential/Commercial, the key issues to be resolved include decisions by the City of Pasadena, as Lead Agency, pertaining to:
 Whether this environmental document adequately describes the potential environmental impacts of the proposed Project;
 Whether the recommended mitigation measures and the design of the Project should be modified and/or adopted as proposed;
 Whether the Project benefits override those environmental impacts that cannot be feasibly avoided or mitigated to a less than significant level;
 Whether there are other mitigation measures that should be applied to the Project besides those identified in the EIR; and
 Whether there are any alternatives to the proposed Project that would substantially lessen any of its significant impacts while achieving most of the basic Project objectives.

AREAS OF CONTROVERSY
Section 15123(b)(2) of the State CEQA Guidelines indicates that an EIR summary should identify areas of controversy known to the Lead Agency, including issues raised by the public agencies Affinity Project Draft EIR
ES-5 Executive Summary
and the public. This EIR has taken into consideration the written comments received from the public and various agencies in response to the IS and Notice of Preparation (NOP) distributed on August 3, 2021 (for a 30-day public review period from August 5, 2021 through September 3, 2021), and comments received during the two public virtual scoping meetings held on August 11, 2021, and August 26, 2021 via Zoom. A copy of the NOP comments received are provided in Appendix A-2 of this EIR. A summary of issues raised in response to the NOP, and where in the EIR they are discussed, is presented in Table 1-1 in Section 1.0, Introduction, of this EIR.

The primary environmental areas of controversy known to the City of Pasadena that have been raised to date related to implementation of the proposed Project include biological (tree removal), land use (context and scale of development), transportation (traffic generation and traffic safety), and water supply.

SUMMARY OF SIGNIFICANT ENVIRONMENTAL IMPACTS
Pursuant to Sections 15126.2 and 15126.4 of the State CEQA Guidelines, a Draft EIR is required to identify any potentially significant adverse impacts and recommend mitigation measures that would eliminate or reduce these impacts to levels of less than significant.

At the onset of the CEQA process, the City determined that an EIR is required for the proposed Project and prepared an IS in accordance with State CEQA Guidelines Sections 15063. The City determined there would be no impacts or less than significant impacts to the following environmental topics and/or thresholds (refer to the IS/NOP in Appendix A-1). Therefore, in accordance with Section 15128 of the State CEQA Guidelines, these are identified as topical areas that would not receive further evaluation in this EIR:
 Aesthetics
 Agricultural and Forestry Resources
 Biological Resources
 Geology and Soils
 Hydrology and Water Quality
 Mineral Resources
 Population and Housing
 Wildfire
Based on the results of the IS and comments received in response to the NOP, the City determined implementation of the proposed Project and/or Project with Building A Residential/Commercial has the potential to impact the following environmental topics, which are further addressed in this Draft EIR:
 Air Quality
 Cultural and Paleontological
Resources
 Energy
 Greenhouse Gas Emissions
 Hazards and Hazardous Materials
 Land Use and Planning
 Noise
 Public Services and Recreation
 Transportation
 Tribal Cultural Resources
 Utilities and Service Systems
If the City of Pasadena, as Lead Agency, determines that unavoidable significant adverse impacts would result from the proposed Project, a Statement of Overriding Considerations must be prepared and adopted before it can approve the proposed Project. A Statement of Overriding Considerations states that the decision-making body has weighed the physical, social, and economic benefits of the Project against its unavoidable significant environmental effects and has determined that the benefits of the Project outweigh its adverse effects; therefore, the adverse effects are considered acceptable.

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ES-2 Executive Summary
Although the level of significance after mitigation (if any) may be the same for each threshold and/or environmental topic, the degree or severity of impact may be slightly different under each alternative. The potentially significant adverse environmental impacts of the Project and Project with Building A Residential/Commercial, which require mitigation, include:
 Cultural Resources (historic resources [501 and 523 South Arroyo Parkway] and unknown archaeological resources),
 Noise (potential for vibration-related cosmetic building damage to Whole Foods Market and 501 and 523 South Arroyo Parkway), and
 Tribal Cultural Resources (unknown tribal cultural resources).

Table ES-1, Summary of Project Impacts, Mitigation, and Level of Significance after Mitigation, beginning on the following page, presents a summary of significant environmental impacts identified in Sections 3.1 through 3.11 of this EIR; Mitigation Measures (MMs) that reduce identified significant impacts; and the level of significance of each impact after mitigation.

Significant irreversible environmental changes and growth-inducing impacts are addressed in Section 5.0, Other CEQA Considerations.

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TABLE ES-1

SUMMARY OF PROJECT IMPACTS, MITIGATION,

AND LEVEL OF SIGNIFICANCE AFTER MITIGATION
Summary of Project Impacts Mitigation Measures
Level of
Significance
After Mitigation
Section 3.2 – Cultural Resources Tenant improvement plans for 501 and 523 South Arroyo Parkway do not anticipate demolishing, moving, or making major alterations to these historic resources, which would both be preserved in place. However, as tenant improvement plans remain conceptual and have not yet been finalized, there may be a potential for impact.

MM CUL-1. To the satisfaction of the City, the Project Applicant shall engage with a licensed architect and/or engineer that meets the Secretary of the Interior’s Professional Qualifications Standards for historic architect to develop a series of protection interventions and protocols that will preserve the two historical resources on the Project site – 501 and 523 South Arroyo Parkway – during all construction activities in, on, and near these two buildings. These measures shall take into consideration the protection of and security of both resources, particularly the preservation of the character-defining features through the installation of physical protective barriers around each resource and the creation of site protocols that will eliminate the potential for physical damage resulting from impacts with construction and transport equipment. To ensure the protection of these resources and their character-defining features, all protective barriers (which shall be installed prior to the initiation of any construction activity) and protocols shall be compliant with the Secretary of the Interior’s Standards for Rehabilitation and Guidelines for Rehabilitating Historic Buildings (Weeks and Grimmer 1995) (Standards) and be subject to review and approval by the City planning staff. Site protocols for protecting the historical resources shall outline issues related to site access and navigation by contractors and construction personnel to reduce the potential for any inadvertent accidents between equipment and the two on-site historical resources. Additionally, a series of emergency measures shall be developed that outlined specific step-by-step processes in the event that an accident involves one of the historical resources. This will likely include the following:

Stop-work protocols after an accident involving a historical resource occurs, (1) Notification procedures and identification key contacts, (2) Identification of qualified historic preservation professionals to investigate the historical resources following the determination that the area is safe, (3) Thorough conditions assessment of the resource by the qualified consultant to ascertain the level and extent of the damage, and
Less than significant
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TABLE ES-1

SUMMARY OF PROJECT IMPACTS, MITIGATION,

AND LEVEL OF SIGNIFICANCE AFTER MITIGATION
Summary of Project Impacts Mitigation Measures
Level of
Significance
After Mitigation
(4) Preparation of a historical resource treatment plan to stabilize the historical resource and address the damage, which will be submitted to City staff for review and approval prior to completing the work and resumption of construction activities.

Additionally, protocols shall include regular on-site monitoring during construction activities by historic preservation consultant, either a SOI Qualified historic architect or architectural historian. The historic preservation consultant shall document the existing conditions of each resource prior to the initiation of any construction activity and prior to installation of the protective barriers and implementation of the protection protocols. This documentation phase will include high resolution digital photographs of each facade, as well as details of character-defining features for each resource. During construction, the historic preservation consultant shall prepare field report memoranda to the City confirming that the Standards compliant protection barriers are installed in accordance with the Standards, and that agreed upon protocols are being followed throughout the course of the Project. These memoranda will be submitted to City staff for their records and review. A final report outlining the conditions of the historical resources prior, during, and following the Project’s construction shall be issued to the City for approval following construction activities and prior to the issuance of a Certificate of Occupancy.

There are no known archaeological resources on the Project site. However, based on the results on the cultural resources records searches conducted for the Project site and vicinity (Appendices C-2), unknown archaeological resources have potential to be present in native sediments beneath the Project site.

MM CUL-2. If cultural resources are discovered during construction of land development projects in Pasadena that may be eligible for listing in the California Register for Historic Resources, all ground disturbing activities in the immediate vicinity of the find shall be halted until the find is evaluated by a Registered Professional Archaeologist. If testing determines that significance criteria are met, then the project shall be required to perform data recovery, professional identification, radiocarbon dates as applicable, and other special studies; and provide a comprehensive final report including site record to the City and the South-Central Coastal Information Center at California State University Fullerton. No further grading shall occur in the area of the discovery until Planning Department approves the report..

Less than significant
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TABLE ES-1

SUMMARY OF PROJECT IMPACTS, MITIGATION,

AND LEVEL OF SIGNIFICANCE AFTER MITIGATION
Summary of Project Impacts Mitigation Measures
Level of
Significance
After Mitigation
Section 3.7 – Noise The Whole Foods Market building and the structures at 501 and 523 South Arroyo Parkway may experience vibration levels during operation of a certain equipment that could cause cosmetic damage.

MM NOI-1. The potential for vibration-induced cosmetic (i.e., not structural) damage to the structures at 465, 501, and 523 South Arroyo Parkway shall be reduced by implementing the following three steps: (1) setbacks, (2) monitoring, and (3) restoration (if applicable). (1) The Project Applicant shall be responsible for ensuring the construction specifications include the following language: “Construction equipment shall observe setback distances of 30 feet from any of the three on-site buildings being retained (Whole Foods Market and 501 and 523 South Arroyo Parkway) for equipment equivalent to a large bulldozer (29,000 pounds or more) and 20 feet for jackhammers and loaded trucks. Small dozers and other equipment with vehicle weights of less (29,000 pounds) are not anticipated to result in substantial levels of vibration that could cause building damage”. (2) The Project Applicant shall be responsible for placing a vibration monitor in each of the three on-site buildings to remain on the site. The contractor would need to have vibration measurements taken on the site when heavy equipment or vibration intensive activities occurs near (i.e., less than 30 feet horizontal distance) to these three buildings. Vibration measurements will be recorded and compared to the vibration thresholds appropriate for the building that may be impacted.

Vibration records shall be submitted to the City once a week. The appropriate vibration thresholds are as follows: 0.12 peak particle velocity (PPV) for 501 and 523 South Arroyo Parkway and 0.30 PPV for Whole Foods Market. The Applicant shall be responsible for preparing a Monitoring Plan, describing the proposed location of vibration monitors, the timing of monitoring, collecting vibration records (including date, time, activity that precipitated the monitoring, and who recorded the vibration level), to whom and when the monitoring records will be submitted, and any remedial actions needed because of vibration readings. The Monitoring Plan is subject to review and approval by City staff and will be submitted prior to initiation of any construction activity on the site. If vibration levels are below these thresholds, it is permissible to have construction activity with large (over 29,000 pounds) equipment, jackhammers, and/or loaded trucks within the setback distances included in item 1 above. Additionally, vibration monitoring shall guide construction activity near the perimeter of these buildings during subterranean excavation and construction activity. If vibration levels are found to exceed the applicable threshold, then the associated construction activity Less than significant
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TABLE ES-1

SUMMARY OF PROJECT IMPACTS, MITIGATION,

AND LEVEL OF SIGNIFICANCE AFTER MITIGATION
Summary of Project Impacts Mitigation Measures
Level of
Significance
After Mitigation
shall immediately halt, and alternative methods for achieving the construction activity shall be determined and employed to reduce the construction-generated vibration exposure to the building(s) to less than the thresholds. While the specific alternative methods to be employed cannot be foreseen, as it would be depending on situation-specific factors, the performance objective of maintaining activity that results in vibration below the applicable thresholds shall guide all decisions. (3) If cosmetic damage does occur to one or more of these three buildings because of vibration from Project-related construction activities despite setbacks and monitoring, the Project Applicant shall be responsible for restoring the damage. Cosmetic damage includes things like, for example, cracks in paint/plaster, fallen plaster/stucco from a facade, and cracked glass. Specifically, any restorations to Whole Foods Market shall be implemented to return the damaged area to the same condition (e.g., materials, colors, style) as present at the start of construction. Any restorations to the buildings at 501 and 523 South Arroyo Parkway shall conform to the Secretary of the Interior’s Standards for the Rehabilitation and Guidelines for Rehabilitating Historic Buildings (Weeks and Grimmer 1995) (Standards), and the determination of whether the planned restorations is consistent with the Standards shall be made by a qualified historic preservation professional meeting the Secretary of the Interior’s Professional Qualifications Standards for architectural history or historic architecture (Professional) and to the satisfaction of the City. The restorations to the historic buildings, if necessary, may be either to the conditions present before construction was initiated or, if the planned updates to these buildings are underway may be conducted to meet proposal conditions.

The City of Pasadena Planning & Community Development Department shall be responsible for ensuring these requirements are included in the construction specifications prior to any demolition activity on the site. The Project Applicant and the City’s inspector assigned to the Project shall also be responsible for ensuring these measures are consistently implemented throughout the construction period.

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TABLE ES-1

SUMMARY OF PROJECT IMPACTS, MITIGATION,

AND LEVEL OF SIGNIFICANCE AFTER MITIGATION
Summary of Project Impacts Mitigation Measures
Level of
Significance
After Mitigation
Section 3.10 – Tribal Cultural ResourcesBased on consultation with the Gabrieliño Tongva Tribe and Gabrieliño Band of Mission Indians – Kizh Nation pursuant with AB 52, there are no known tribal cultural resources on the Project site. However, there is always the possibility that undiscovered intact cultural resources, including tribal cultural resources, may be present below the surface in native (i.e., undisturbed) sediments.

MM TCR-1. Prior to the commencement of any ground disturbing activity at the Project site, the Project Applicant shall accommodate a Native American Monitor (Monitor) culturally affiliated with the site as recognized by the Native American Heritage Commission (NAHC). The Monitor contracted and retained shall be at the expense of the tribe(s) that consulted on this Project. The Tribal Monitor will only be present onsite during the construction phases that involve ground-disturbing activities. Ground disturbing activities are defined by the Tribe as activities that may include, but are not limited to pavement removal, potholing or auguring, grubbing, tree removals, boring, grading, excavation, drilling, and trenching within the Project area. The Tribal Monitor will complete daily monitoring logs that will provide descriptions of the day’s activities, including construction activities, locations, soil, and any cultural materials identified. The on-site monitoring shall end when all ground-disturbing activities on the Project site are completed, or when the Tribal Representatives and Tribal Monitor have indicated that all upcoming ground-disturbing activities at the Project Site have little to no potential for impacting Tribal Cultural Resources. Upon discovery of any Tribal Cultural Resources, construction activities shall cease in the immediate vicinity of the find (not less than the surrounding 50 feet) until the find can be assessed. All Tribal Cultural Resources unearthed by Project construction activities shall be evaluated by the Tribal Monitor approved by the Consulting Tribe and a qualified Archaeologist (if one is present). If the resources are Native American in origin, the Consulting Tribe will retain it/them in the form and/or manner the Tribe deems appropriate, for educational, cultural and/or historic purposes. If human remains and/or grave goods are discovered or recognized at the Project Site, all ground disturbance in the immediate vicinity of the find shall be halted, and the County Coroner shall be notified per Section 5097.98 of the Public Resources Code and Section 7050.5 of the Health & Safety Code. Human remains and grave/burial goods shall be treated alike per Section 5097.98(d)(1) and (2) of the Public Resources Code. Work may continue in other parts of the Project site while evaluation and, if necessary, mitigation takes place (Section 15064.5[f] of the State CEQA Guidelines). Preservation in place (i.e., avoidance) is the preferred manner of treatment. If preservation in place is not feasible, treatment may include implementation of archaeological data recovery excavations to remove the resource along with Less than significant
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TABLE ES-1

SUMMARY OF PROJECT IMPACTS, MITIGATION,

AND LEVEL OF SIGNIFICANCE AFTER MITIGATION
Summary of Project Impacts Mitigation Measures
Level of
Significance
After Mitigation
subsequent laboratory processing and analysis. Any historic archaeological material that is not Native American in origin (non-Tribal Cultural Resource) shall be curated at a public, non-profit institution with a research interest in the materials, such as the Natural History Museum of Los Angeles County or the Fowler Museum, if such an institution agrees to accept the material. If no institution accepts the archaeological material, it shall be donated to a local school or historical society in the area for educational purposes.

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1-1 Introduction
SECTION 1.0 INTRODUCTION

1.1 PURPOSE OF THE EIR

1.1.1 REGULATORY FRAMEWORK
The California Environmental Quality Act (CEQA) (Section 21002.1 of the California Public Resources Code [PRC]) states that “the purpose of an environmental impact report (EIR) is to identify the significant effects on the environment of a project, to identify alternatives to the project, and to indicate the manner in which those significant effects can be mitigated or avoided”. This EIR has been prepared in accordance with CEQA (Section 21000 et. seq. of the PRC) and the State CEQA Guidelines (Section 15000 et. seq. of Title 14, California Code of Regulations [CCR]).

An EIR is the most comprehensive form of environmental documentation identified in CEQA and the State CEQA Guidelines. EIRs are intended to provide an objective, factually supported analysis of the environmental consequences associated with a project that has the potential to result in significant, adverse environmental impacts, including after implementation of mitigation measures (MMs). In accordance with Section 15121(a) of the State CEQA Guidelines, this Draft EIR is an informational document that will inform public agency, decision makers, and the general public of (1) the significant environmental effects of the proposed Affinity Project (Project or Project with Building A Residential/Commercial); (2) possible ways to minimize the significant effects; and (3) reasonable alternatives to the Project and the Project with Building A Residential/Commercial.

1.1.2 LEAD AGENCY
Section 15051 of the State CEQA Guidelines identifies the Lead Agency as the public entity with the greatest responsibility for carrying out or approving the Project as a whole. The City has the primary authority to approve and adopt and subsequently implement the Affinity Project or the Project with Building A Residential/Commercial. As such, the City of Pasadena (City) is serving as the Lead Agency under CEQA and is responsible for preparing this EIR.

While this EIR has been prepared with consultant support, City staff have reviewed all submitted drafts, technical studies, and consistency with City regulations and policies and has commissioned the preparation of this EIR to reflect its own independent judgment, consistent with Section 15084 of the State CEQA Guidelines.

1.1.3 INCORPORATION BY REFERENCE
As permitted by Section 15150 of the State CEQA Guidelines, this Draft EIR has referenced several technical studies, analyses, and reports. Information from the documents, which have been incorporated by reference into this Draft EIR, has been briefly summarized in the appropriate sections and the relationship between the incorporated part of the referenced document and the EIR has been described. In addition, documents and other sources that have been used in the preparation of this EIR are identified at the end of each section of this Draft EIR. In accordance with Section 15150(b) of the State CEQA Guidelines, the locations where the public may obtain and review these referenced documents and other sources used in the preparation of the Draft EIR are also identified.

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1-2 Introduction

1.2 EIR FOCUS

1.2.1 SCOPING PROCESS
An Initial Study/Notice of Preparation (IS/NOP) was distributed on August 3, 2021, to applicable federal, State, regional, and local government agencies and interested parties for a 30-day public review period (August 5, 2021 through September 3, 2021) to solicit comments and to inform agencies and the public of the Project and the upcoming preparation of an EIR. The IS/NOP included a description of the proposed Project; potential environmental effects associated with Project implementation; and an invitation to agencies and the public to review and comment on the IS/NOP. A copy of the IS/NOP is provided in Appendix A-1 of this EIR. The City held two virtual scoping meetings for the Project:

Scoping Meeting No. 1
(Planning Commission)
August 11, 2021
6:30 PM
Scoping Meeting No. 2
August 26, 2021
6:30 PM
The purpose of the scoping meetings was to receive input on the environmental issues that should be addressed in the EIR. Comments received during the scoping period were received from 5 agencies, 10 organizations, and 21 individuals. Written comments are provided in Appendix A-2 of this EIR. Verbal comments received during the two scoping meetings are summarized below.

The issues raised by the comment letters and scoping meeting comments are summarized in Table 1-1, Summary of Comments on the IS/NOP, along with the primary EIR section(s) where each issue is addressed. It should be noted that the Draft EIR addresses all topical issues carried forward from the Initial Study consistent with the current environmental checklist questions in Appendix G of the State CEQA Guidelines, and current CEQA and State CEQA Guidelines requirements. NOP comments related to Project design preferences or other issues that are not environmentally related are not addressed in CEQA documentation; however, they are part of the Project record and will be seen by the decision-making body as part of their consideration of the Project and Project with Building A Residential/Commercial.

TABLE 1-1

SUMMARY OF COMMENTS RECEIVED DURING SCOPING PERIOD
Commentor Comments/Issues Raised Where Discussed
Agencies
California Department of
Transportation
Information on transportation impacts
on the State highway system; heavy
and oversized vehicles on State
highways
Section 3.9, Transportation, summarizes the SB 743-
compliant transportation analysis conducted for the
Project and Project with Building A
Residential/Commercial
Los Angeles County
Metropolitan Transportation
Authority (Metro)
Adjacency of Metro L (Gold) Line and
measures to reduce potential impacts,
transit-supportive planning, Metro
Adjacent Development Handbook
Comments related to development adjacent to
Metro’s right-of-way along the L Line, and
opportunities to facilitate use of nearby transit
facilities are acknowledged. Section 3.9,
Transportation, summarizes the SB 743-compliant
transportation analysis conducted for the Project and
Project with Building A Residential/ Commercial.

Metro is identified as a Responsible Agency in
Section 2.0 because of adjacency of light rail line
Los Angeles County Sanitation
Districts
Wastewater generation and
conveyance, wastewater generation
estimate (Project only), connection
fees, Air Quality Management Plan
(AQMP) conformance
AQMP conformance is addressed in Section 3.1, Air
Quality; wastewater generation, conveyance, and
treatment is addressed in Section 3.11, Utilities and
Service Systems
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1-3 Introduction
TABLE 1-1

SUMMARY OF COMMENTS RECEIVED DURING SCOPING PERIOD
Commentor Comments/Issues Raised Where Discussed
Native American Heritage
Commission
Native American tribal consultation
under AB 52 and SB 18; cultural
resource assessment
recommendations
AB 52 consultation was completed by the City.

Because the Project would not involve the adoption
of a Specific Plan or amendment of the General Plan,
consultation under Senate Bill 18 is not required.

Section 3.10, Tribal Cultural Resources, addresses
potential impacts on tribal cultural resources and
human remains based on the conduct of a Phase I
Cultural Resource Assessment and Native American
consultation
South Coast Air Quality
Management District (SCAQMD)
Guidelines for air quality analysis,
permits, mitigation measures, and data
sources
Section 3.1, Air Quality, summarizes the air quality
analysis conducted for the Project and Project with
Building A Residential/ Commercial. SCAQMD is
identified as a Responsible Agency in Section 2.0
because of proposed diesel backup generators
Organizations
Advocacy No. 1 (Done,
Feldmann, Marchioni, Old
Pasadena Management District
/Mulheim, Chamber of
Commerce and Civic Association
of Pasadena/Little, Schillaci,
Smith, Worrell)
Support for the Project Comment acknowledged
Advocacy No. 2 (Ficarra) Support for the Project Comment acknowledged Livable Pasadena (Letter No. 1) Land use pattern, proposed medical corridor, water supply, setbacks/project
design, noise, lighting, traffic
congestion, traffic safety, Prism traffic
study, existing traffic level of service
(LOS), Magnolia Landmark District
comment support, proposed Planned
Development moratorium support,
General Plan/Mobility Element
inconsistency
Land use issues are addressed in Section 3.6, Land
Use and Planning; noise issues are addressed in
Section 3.7, Noise; and transportation issues are
addressed in Section 3.9, Transportation
Livable Pasadena (Letter No. 2) Project description
instability/inadequacy and EIR
inappropriateness, water supply,
proposed density, heat index and
related health impacts, energy usage
CEQA project description standards and heat
island/heat index are addressed in Section 2.0,
Environmental Setting and Project Description; water
supply issues are addressed in Section 3.11, Utilities
and Service Systems; land use issues are addressed
in Section 3.6, Land Use and Planning; energy usage
is addressed in Section 3.3, Energy
Livable Pasadena (Prism) Mobility Element inconsistency, traffic congestion/LOS affects, traffic safety,
vehicle miles traveled (VMT) impact
Land use issues are addressed in Section 3.6, Land
Use and Planning; and transportation issues are
addressed in Section 3.9, Transportation
Madison Heights Neighborhood
Association
Tree removal, number of parking
spaces, traffic, loss of mountain views,
limited walkability, minimal green
space, community outreach deficiency,
cumulative impacts, historic
neighborhood and single-family
neighborhood impacts, water supply
Tree removals were addressed under Threshold

2.4(e) in Section 2.4, Biological Resources, of the
Initial Study (Appendix A-1); aesthetic issues were
addressed in Section 2.1, Aesthetics, of the Initial
Study; transportation issues are addressed in Section

3.9, Transportation; proposed landscaping (i.e.,
green space) is detailed in Section 2.4.1 in Section

2.0, Environmental Setting and Project Description;
details of the City’s noticing process consistent with
CEQA requirements is addressed in this section
(Section 1.0); the approach to the cumulative impact
analysis is presented in Section 2.5 and the
cumulative impact analysis is presented in Section

3.X.6 of each topical section in the EIR; historic
resources issues are addressed in Section 3.2,
Cultural and Paleontological Resources; off-site
impacts, where relevant, are addressed in Sections

3.1 through 3.11; and water supply issues are
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1-4 Introduction
TABLE 1-1

SUMMARY OF COMMENTS RECEIVED DURING SCOPING PERIOD
Commentor Comments/Issues Raised Where Discussed
addressed in Section 3.11, Utilities and Service
Systems
Magnolia Avenue Landmark
District
General Plan/Mobility Element
inconsistency, location near
historic/single-family neighborhood,
proposed near Huntington Hospital,
Marengo/California intersection safety
issues, overabundance of
nursing/assisted living facilities in City,
proposed Planned Development
moratorium support, public outreach,
building heights, inadequate green
space, inadequate infrastructure
Land use issues are addressed in Section 3.6, Land
Use and Planning; transportation issues are
addressed in Section 3.9, Transportation; historic
resources issues are addressed in Section 3.2,
Cultural and Paleontological Resources; off-site
impacts, where relevant, are addressed in Sections

3.1 through 3.11; details of the City’s noticing
process consistent with CEQA requirements is
addressed in this section (Section 1.0); proposed
landscaping (i.e., green space) is detailed in Section

2.4.1 in Section 2.0, Environmental Setting and
Project Description; infrastructure issues are
addressed in Section 3.11, Utilities and Service
Systems
Pasadena Beautiful Foundation
(Chuck Livingstone)
Historic resources nearby; traffic; water
supply; design compatibility with trees
and gardens
Historic resources issues are addressed in Section

3.2, Cultural and Paleontological Resources;
transportation issues are addressed in Section 3.9,
Transportation; water supply issues are addressed in
Section 3.11, Utilities and Service Systems; aesthetic
issues were addressed in Section 2.1, Aesthetics, of
the Initial Study; land use issues are addressed in
Section 3.6, Land Use and Planning
Protect Pasadena Trees New specific plan policies on tree planting and protection on public and
private property, stronger tree
protection/urban forestry views,
setbacks, heat islands
Land use issues are addressed in Section 3.6, Land
Use and Planning; tree removals were addressed
under Threshold 2.4(e) in Section 2.4, Biological
Resources, of the Initial Study (Appendix A-1); heat
island/heat index are addressed in Section 2.0,
Environmental Setting and Project Description
West Pasadena Residents’
Association
Project description instability, water
supply, traffic circulation, EIR
premature
CEQA project description standards are addressed in
Section 2.0, Environmental Setting and Project
Description; water supply issues are addressed in
Section 3.11, Utilities and Service Systems;
transportation issues are addressed in Section 3.9,
Transportation
Individuals
Natalie Bazarevitsch Support for the Project Comment acknowledged Nina Chomsky Project description instability, historic
resources analysis, historic buildings
not historic enough to allow variance,
Project design (height/massing), EIR
should include aesthetics section or
historic resources analysis and land
use and planning section that
addresses issues covered under
aesthetics topic
CEQA project description standards are addressed in
Section 2.0, Environmental Setting and Project
Description; aesthetic issues were addressed in
Section 2.1, Aesthetics, of the Initial Study (Appendix A-1); historic resources issues are addressed in
Section 3.2, Cultural and Paleontological Resources
Maggie Crawford Support for the Project Comment acknowledged Erika Foy Traffic infrastructure; small-town feel;
scale near historic neighborhoods;
cumulative traffic impact; project
height, density, setbacks; risks with
high-density living–poor air quality,
heat index; keep Pasadena special
Transportation issues, including cumulative impacts,
are addressed in Section 3.9, Transportation; historic
resources issues are addressed in Section 3.2,
Cultural and Paleontological Resources; land use
issues are addressed in Section 3.6, Land Use and
Planning; air quality issues are addressed in Section

3.1, Air Quality; heat island/heat index are addressed
in Section 2.0, Environmental Setting and Project
Description
Jim Gamb Support for the Project Comment acknowledged
Akila Gibbs Support for the Project Comment acknowledged Affinity Project Draft EIR
1-5 Introduction
TABLE 1-1

SUMMARY OF COMMENTS RECEIVED DURING SCOPING PERIOD
Commentor Comments/Issues Raised Where Discussed
Kristin Techentin Harrison Traffic congestion/intersection geometry; proposed ingress/egress;
traffic noise; Project design; heat
index; parkway sidewalk and tree
planting; pedestrian safety
Transportation issues, including cumulative impacts,
are addressed in Section 3.9, Transportation; noise
issues are addressed in Section 3.7, Noise
Tricia Keane Support for the Project Comment acknowledged Dean Kitchens Support for the Project Comment acknowledged Stan Kong Support for the Project Comment acknowledged
Erik Landswick Support for the Project Comment acknowledged Nikki Maciejowski Support for the Project Comment acknowledged Penny Plotkin Support for the Project Comment acknowledged Julie Rosenberg Support for the Project Comment acknowledged Michelle Round Support for the Project Comment acknowledged Tammy Silver Setbacks; in-ground trees; heat index;
transportation/traffic
Aesthetic issues were addressed in Section 2.1,
Aesthetics, of the Initial Study; land use issues are
addressed in Section 3.6, Land Use and Planning;
heat island/heat index are addressed in Section 2.0,
Environmental Setting and Project Description;
transportation issues are addressed in Section 3.9,
Transportation
Susan Stevens Traffic; traffic safety; noise; building
massing, setbacks, green space;
historic context; water supply
Transportation issues, including traffic safety, are
addressed in Section 3.9, Transportation; historic
resources issues are addressed in Section 3.2,
Cultural and Paleontological Resources; aesthetic
issues were addressed in Section 2.1, Aesthetics, of
the Initial Study; land use issues are addressed in
Section 3.6, Land Use and Planning; noise issues
are addressed in Section 3.7, Noise; water supply
issues are addressed in Section 3.11, Utilities and
Service Systems
Victoria Stratman Support for the Project Comment acknowledged Steven Trytten Support for the Project Comment acknowledged Carole Walker Support for the Project Comment acknowledged Xiaoyan Zhou Traffic; noise; air quality; water supply; electric consumption
Transportation issues are addressed in Section 3.9,
Transportation; noise issues are addressed in
Section 3.7, Noise; air quality issues are addressed
in Section 3.1, Air Quality; water supply and electric
consumption issues are addressed in Section 3.11,
Utilities and Service Systems
Scoping Meeting No. 1
Commissioner Lambert
Giessinger
Variance for historic resources Staff explained the reason for the historic resources variance; description of PD Plan process, including
variance for historic resources, is discussed in
Section 2.0, Environmental Setting and Project
Description, and Section 3.6, Land Use and Planning
Commissioner Andrea Rawlings Historic resources and variance for historic resources; aesthetics
Staff explained the process for the historic resources
variance for the Project and discussed that the
findings of the aesthetics analysis in the Initial Study was in compliance with Senate Bill (SB) 743;
nonetheless, aesthetics considerations solely as they
relate to historic resources will be addressed (in
Section 3.2, Cultural and Paleontological Resources)
through preparation of a Historic Resources
Assessment
Affinity Project Draft EIR
1-6 Introduction
TABLE 1-1

SUMMARY OF COMMENTS RECEIVED DURING SCOPING PERIOD
Commentor Comments/Issues Raised Where Discussed
Commissioner D. Jason Lyon Hydrology; water runoff and
groundwater
Staff explained the hydrologic analysis presented in
the Initial Study; the impact finding is based on
implementation of standard State and City
regulations during both construction and operation
that would fully manage runoff for this Project
Commissioner Mic Hansen Water supply; construction phase impacts; transportation; utilities; EIR
format; cumulative impacts approach
and specific plans
Water supply is evaluated as part of Section 3.11,
Utilities and Service Systems, consistent with
Appendix G of the State CEQA Guidelines;
construction-phase impacts are evaluated for every
checklist question presented in Sections 3.1 through

3.11; Transportation is addressed in Section 3.9,
Transportation; the narrative format of the EIR is
consistent with the state of the practice and the
requirements of CEQA and the State CEQA
Guidelines; the Executive Summary and Section 4.0,
Alternatives, provide an overall summary of the Draft
EIR’s findings; Section 2.5 of Section 2.0,
Environmental Setting and Project Description,
describes the approach to the cumulative impact
analysis, which is provided for each topic addressed
in Sections 3.1 through 3.11; the cumulative impacts
are based on buildout of the adopted General Plan
and related adopted Specific Plans.

Madison Heights Neighborhood
Association (Rob Manske)
Project design (e.g., density, setbacks,
aesthetics, building scale relative to
residential, change in site use); water;
traffic congestion and safety; noise;
infrastructure; General Plan
consistency
Aesthetic issues were addressed in Section 2.1,
Aesthetics, of the Initial Study; and was evaluated
consistent with SB 743; transportation and traffic
safety are addressed in Section 3.9, Transportation;
water supply and infrastructure requirements are
addressed in Section 3.11, Utilities and Service
Systems; noise issues are address ed in Section 3.7,
Noise; land use issues, including consistency with
the General Plan and the Central District Specific
Plan, are addressed in Section 3.6, Land Use and
Planning
Livable Pasadena
(Megan Foker)
Water supply and use; cumulative
impacts
Water supply, including cumulative impacts, is
addressed in Section 3.11, Utilities and Service
Systems
Magnolia Landmark District
(Erika Foy)
Traffic; intersection safety; cumulative
impacts
Transportation and traffic safety, including cumulative impacts, are addressed in Section 3.9,
Transportation
Pasadena Heritage
(Andrew Salimian)
Cultural resources; traffic; water supply
and retention
Historic resources are addressed in Section 3.2,
Cultural and Paleontological Resources; water supply
is address in Section 3.11, Utilities and Service
Systems;
Scoping Meeting No. 2
Coalition for Responsible
Equitable Economic
Development (CREED) LA
(representing coalition of labor
unions)
Air quality; noise; GHG, on-site soil
contamination
Air quality issues are addressed in Section 3.1, Air
Quality; noise issues are addressed in Section 3.7,
Noise; greenhouse gas issues are addressed in
Section 3.4, GHG Emissions; on-site soil
contamination issues are addressed in Section 3.5,
Hazards and Hazardous Materials
LiUNA Southern California
District Council of Laborers (Bill
Quisenberry)
Stated no environmental-related
comments to make; looking for
opportunity to put membership to work
on the project.

Comment acknowledged
Ross Selvidge Support for the Project Comment acknowledged Affinity Project Draft EIR
1-7 Introduction
Based on the results of the IS and comments received on the NOP, the City determined that implementation of the proposed Project and/or Project with Building A Residential/Commercial has the potential to impact the following environmental topics, which are further addressed in this Draft EIR:
 Air Quality,
 Cultural and Paleontological Resources,
 Energy,
 Greenhouse Gas Emissions,
 Hazards and Hazardous Materials,
 Land Use and Planning,
 Noise,
 Public Services and Recreation,
 Transportation,
 Tribal Cultural Resources, and
 Utilities and Service Systems.

The City determined there would be no impacts or less than significant impacts to the following environmental topics and/or thresholds (refer to the IS/NOP in Appendix A-1). Therefore, in accordance with Section 15128 of the State CEQA Guidelines, these are identified as topical areas that would not receive further evaluation in this EIR:
 Aesthetics,
 Agricultural and Forestry Resources,
 Biological Resources,
 Geology and Soils,
 Hydrology and Water Quality,
 Mineral Resources,
 Population and Housing, and
 Wildfire.

1.3 PROJECT APPLICANT AND CONTACT PERSON
The Project Applicant is:

The Arroyo Parkway, LLC
716 Mission Street
South Pasadena, CA 91030
All inquiries regarding the Project and the EIR should be directed to:

Mr. Jason Van Patten
Senior Planner
City of Pasadena Planning and Community Development Department 175 North Garfield Avenue
Pasadena, CA 91101
[email protected]
Phone: (626) 744-6760

1.4 PUBLIC REVIEW OF THE DRAFT EIR
The Draft EIR for the Project is being distributed to responsible and trustee agencies, other affected agencies, surrounding cities, interested parties, and all parties who requested a copy of the EIR in accordance with CEQA. During the 45-day public review period, this Draft EIR, including the technical appendices, is available for review online at Affinity Project Draft EIR
1-8 Introduction
https://www.cityofpasadena.net/planning/planned-development-39-affinity-project/ and hard copies are available at the following four locations during regular business hours:

City of Pasadena Permit Center (Window 3)
175 North Garfield Avenue
Pasadena, California 91101
Allendale Library
1130 S. Marengo Avenue
Pasadena, CA 91106
Office of the City Clerk
100 N. Garfield Avenue, Room S228
Pasadena, CA 91101
Comments on the Draft EIR from public agencies and interested individuals will be accepted during the 45-day public review period from Tuesday, January 18, 2022 to Thursday, March 3, 2022. Written comments on the Draft EIR should be sent to the Lead Agency contact identified above, via mail or email. Upon completion of the 45-day public review period, written responses will be prepared for all environmental issues raised in the comment letters, and the comments and responses will be included into the Final EIR. All responses to comments submitted on this Draft EIR by public agencies will also be provided to those agencies at least ten days prior to certification of the EIR, consistent with Section 15088(b) of the State CEQA Guidelines.

1.5 DECISION-MAKING PROCESS
An EIR is one of the various decision-making tools used by a Lead Agency to consider the merits and disadvantages of a project that is subject to its discretionary authority. For an EIR, in accordance with Section 21081 of CEQA and Section 15091 of the State CEQA Guidelines, public agencies are required to make written findings for each significant environmental impact identified in the EIR. If the Lead Agency and responsible agencies decide that the benefits of proposed Project outweigh any identified unmitigated significant environmental effects, the Lead Agency is required to adopt a Statement of Overriding Considerations supporting their actions.

Prior to approving a proposed Project, the Lead Agency must consider the information contained in the EIR; determine whether the EIR was properly prepared in accordance with CEQA and the State CEQA Guidelines; determine that the EIR reflects the independent judgment of the Lead Agency; adopt findings concerning the Project’s significant environmental impacts and alternatives; and adopt a Statement of Overriding Considerations if the Project would result in significant impacts that cannot be reduced to a less than significant level.

The City Council is the decision-making body for the Project. Public hearings before both the City of Pasadena Planning Commission and then the City Council will be held. Prior to the Planning Commission and City Council hearings, the Project will go to the Design Commission. The role for Planned Developments is limited to recommendations to the Commission and Council on aesthetic and urban design issues related to elements such as architecture, landscaping, and site plan as well as historic preservation. Comments on the aesthetic/cultural resources of a draft environmental study are appropriate. Public hearings before the Commission and Council are to consider the Project and the adequacy of the Final EIR (which includes the Draft EIR, Responses to Comments on the Draft EIR, and revisions and clarifications to the Draft EIR), at which time public testimony will be received. The City Council will consider whether to certify the Final EIR and adopt a Mitigation Monitoring and Reporting Program, EIR Findings relative to the Project’s environmental effects, and a Statement of Overriding Considerations, if applicable. The City Council, as the decision-making body of the Lead Agency, will then consider whether to approve, approve in modified form, or disapprove the proposed Project.

Affinity Project Draft EIR
2-1 Environmental Setting and Project Description
SECTION 2.0 ENVIRONMENTAL SETTING AND PROJECT DESCRIPTION

2.1 PROJECT LOCATION
The Affinity Project (Project or Project with Building A Residential/Commercial) site encompasses approximately 3.3 acres (144,853 square feet [sf]) located between 465 and 577 South Arroyo Parkway, City of Pasadena, Los Angeles County. The site is bound by East Bellevue Drive on the north, South Arroyo Parkway on the east, East California Boulevard on the south, and the Metro Gold (L) Line on the west. Regional access to the site is provided by State Route (SR) 110 located approximately 0.6-mile due south on Arroyo Parkway. Local access is provided by adjacent surface streets and Metro’s Del Mar and Fillmore Stations located approximately 0.2-miles to the north and south, respectively. Exhibit 2-1, Regional Location and Local Vicinity, illustrates the Project site location.

2.2 PROJECT SETTING AND CHARACTERISTICS

2.2.1 ON-SITE AND SURROUNDING LAND USES
The City of Pasadena (City) is situated along the western edge of the San Gabriel Valley and at the foothills of the San Gabriel Mountains. The Project site is in the southwestern quadrant of the City and to the southeast of the SR-110 and Interstate-210 (I-210) intersection.

The Project site consists of five parcels developed with a total of nine commercial buildings with seven businesses. All existing buildings on the site are one or two stories with heights ranging between 17 feet and 63 feet. All existing land uses have surface parking except for the Whole Foods Market, which has a 275-space, subterranean parking structure for its sole use. Table 2-1, Summary of Existing Land Uses, summarizes the existing on-site land uses; and Exhibit 2-2, Existing Project Site, illustrates the addresses and locations of the nine existing buildings and other on-site land uses.

TABLE 2-1

SUMMARY OF EXISTING LAND USES
Address Existing Use Building Size Disposition
465 S. Arroyo Parkway Whole Foods Market 73,671 sf To Be Retained 491/495 S. Arroyo Parkway K9 Loft 12,676 sf To Be Demolished 499/503 S. Arroyo Parkway Corporate Furniture Resource 21,437 sf To Be Demolished 501 S. Arroyo Parkway Gold Line Pilates 2,880 sf Historic Resource; To Be Retained 523 S. Arroyo Parkway Town & Country Event Rentals 3,002 sf Historic Resource; To Be Retained 541 S. Arroyo Parkway Little Lily’s Kitchen 7,493 sf To Be Demolished 577 S. Arroyo Parkway Guisado’s Restaurant 4,306 sf To Be Demolished Total Existing Building Area 125,465 sf
S.: South; sf: square feet
The Project area is an urban environment, and the site and surrounding area are fully built out with a broad mix of land uses. These land uses also represent a variety of ages, architectural styles, heights, and conditions. Exhibit 2-3, Aerial Photograph, shows the site and existing land use types in the surrounding area.

Commercial land uses are primarily located to the north, including retail, services, and restaurants. Other land uses to the north include medical offices; Pasadena Humane Society, UV134
UV710
UV110
Fair Oaks Ave
Los Robles Ave
Arroyo Pkwy
California Blvd
Orange Grove Blvd
Pasadena Ave
Colorado Blvd
Saint John Ave
Glenarm St
Del Mar Blvd
Corson St Pasadena Ave
Los Robles Ave
Saint John Ave
At and SF Railroad
Central Park
Pasadena Mem Park
Allendale Park
Singer Park
Blair High School
Westridge Elementary School
Fuller Theological Seminary
Rose City High School
Art Center College of Design
Allendale Elementary School
Mayfield Jr SCH of Holy Child
D:\Projects\3PAS\012100\MXD\ex_LV_RL_20210202.mxd
²
San Gabriel
Reservoir
Project Location
§¨405
§¨210
§¨105
§¨10
§ §¨710 ¨110
§¨605
ST19
ST170
ST107
ST72
ST134
ST110
ST60
ST213
ST57
ST710
ST91
Los Angeles
Orange
Glendale
West
Hollywood West Covina
Carson
Buena Park
Hawthorne
Lakewood
Downey
Whittier
Anaheim
Regional Location and Local Vicinity
Affinity Project
Exhibit 2-1
(Rev: 02/05/2021 RMB) R:\Projects\PAS_Pasaden\3PAS012100\Graphics\ex_LV_RL.pdf 1,000 500 0 1,000
Feet
Project Boundary
Map not to scale
Source: Adept 2021
(02/04/2021 RMB) R:\Projects\PAS_Pasaden\3PAS012100\Graphics\ex_exisiting_project_site.pdf D:\Projects\3PAS\012100\GRAPHICS\project_description\ex2-2_existing_project_site_20210204.ai Affinity Project
Existing Project Site Exhibit 2-2

EXISTING TREES TO BE REMOVED

EXISTING BUILDING STRUCTURES TO BE DEMOLISHED
UV110
S
Arroyo Pkwy
E Del Mar Blvd
E California Blvd
S Fair Oaks Ave
D:\Projects\3PAS\012100\MXD\ex_Aerial_20210316.mxd
²
Aerial Photograph
Affinity Project
Exhibit 2-3
(Rev: 03/16/2021 RMB) R:\Projects\PAS_Pasaden\3PAS012100\Graphics\ex_AerialPhotograph.pdf 500 250 0 500
Feet
Aerial Source: ESRI, Maxar 2019
Project Boundary
Land Use
High Density Residential
High Mixed Use
Institutional
Low Commercial
Low Density Residential
Medium Commercial
Medium Density Residential
Medium Mixed Use
Medium-High Density Residential
Open Space
R&D Flex Space
Urban Housing
Affinity Project Draft EIR
2-2 Environmental Setting and Project Description
located approximately 0.1-mile to the northwest; Central Park, located approximately 0.2-mile northwest of the site; and single- and multi-family residential land uses located, at the nearest, approximately 0.2-mile to the north on Del Mar Boulevard and approximately 0.1-mile to the northnortheast on Bellevue Drive. Commercial land uses are located opposite the Project site on Arroyo Parkway. Single- and multi-family residential land uses are situated less than 0.1-mile to the east along Marengo Avenue and Arroyo Parkway. Land uses to the south include a mix of commercial, medical office, and single- and multi-family residential land uses; the latter is located along Marengo Avenue and California Boulevard to the southeast. To the west, there is a mix of commercial and non-profit (i.e., npr/KPCC and Union Station Homeless Services) uses. Further from the site, land uses include a mix of commercial, medical, light industrial, single- and multifamily residential, and public (e.g., schools, churches, parks).

2.2.2 PHYSICAL CHARACTERISTICS
The Project site is relatively flat with a gentle slope of approximately two percent to the south and southeast. Elevations on the site range from approximately 800 feet above mean sea level (msl) along the northern site boundary to approximately 782 feet above msl in the southeast corner.

The site is entirely developed, with the portion of the site south of the Whole Foods Market having a 97 percent impervious surface area. The existing buildings primarily drain runoff via roof drains that either connect to an underground curb drain or release just above the pavement or sidewalk.

The storm water runoff then outfalls through sheet flow along driveways and street-adjacent curb drains onto the Arroyo Parkway sidewalk or directly connects to the municipal storm drain system (Fuscoe Engineering 2021).

There is limited ornamental vegetation present on the Project site. As shown in Table 2-2, Tree Inventory Summary, on the following page, a total of 40 trees were inventoried on the Project site and the adjacent public right-of-way (ROW). Of these, 17 trees located in the ROW are protected under the City Trees and Tree Protection Ordinance. The remaining 23 trees are located on private property within the Project site and are not protected. These include 19 queen palms, 2 Canary Island pines, 1 pecan, and 1 African fern pine (Carlberg Associates 2021).

The site currently has seven points of access, including two on California Boulevard, one on Bellevue Drive, and five on Arroyo Parkway when including the Whole Foods Market exit. All of these access points, except the access from Bellevue Drive and the Whole Foods Market exit, are driveways leading to surface parking; the access point on Bellevue Drive leads into the subterranean parking structure serving Whole Foods Market.

Metro’s Gold (L) Line runs adjacent to the western site boundary. The nearest light rail platforms are Del Mar Station and Fillmore Station, located approximately ¼-mile due north and due south of the Project site, respectively. Additional public transit service present near the site includes the California Boulevard/Arroyo Parkway Metro bus stop located in the ROW on the southern site boundary, and the Bellevue Drive/Arroyo Parkway Metro bus stop located in the ROW at the northeast corner of the site.

Affinity Project Draft EIR
2-3 Environmental Setting and Project Description
TABLE 2-2

TREE INVENTORY SUMMARY
Tree ID
Tree Species Protected
Common Name Scientific Name Tree? Disposition
Trees on Private Property
1 queen palm Syagrus romanzoffiana No Remove
2 queen palm Syagrus romanzoffiana No Remove
3 queen palm Syagrus romanzoffiana No Remove
4 queen palm Syagrus romanzoffiana No Remove
5 queen palm Syagrus romanzoffiana No Remove
6 queen palm Syagrus romanzoffiana No Remove
7 queen palm Syagrus romanzoffiana No Remove
8 queen palm Syagrus romanzoffiana No Remove
9 queen palm Syagrus romanzoffiana No Remove
10 queen palm Syagrus romanzoffiana No Remove
11 queen palm Syagrus romanzoffiana No Remove
12 queen palm Syagrus romanzoffiana No Remove
13 queen palm Syagrus romanzoffiana No Remove
14 queen palm Syagrus romanzoffiana No Remove
15 queen palm Syagrus romanzoffiana No Remove
16 queen palm Syagrus romanzoffiana No Remove
17 African fern pine Afrocarpus falcatus No Remove
18 queen palm Syagrus romanzoffiana No Remove
19 queen palm Syagrus romanzoffiana No Remove
20 queen palm Syagrus romanzoffiana No Remove
21 Canary island pine Pinus canariensis No Remove
22 Canary island pine Pinus canariensis No Remove
23 pecan Carya illinoinensus No Remove
Trees in Public Right-of-Way
ST24 camphor Cinnamomum camphora Yes Preserve and Protect ST25 weeping fig Ficus benjamina Yes Preserve and Protect ST26 date palm Phoenix dactylifera Yes Preserve and Protect ST27 African fern pine Afrocarpus falcatus Yes Preserve and Protect ST28 African fern pine Afrocarpus falcatus Yes Preserve and Protect ST29 date palm Phoenix dactylifera Yes Preserve and Protect ST30 date palm Phoenix dactylifera Yes Preserve and Protect ST31 date palm Phoenix dactylifera Yes Preserve and Protect ST32 African fern pine Afrocarpus falcatus Yes Remove
ST33 date palm Phoenix dactylifera Yes Preserve and Protect ST34 African fern pine Afrocarpus falcatus Yes Preserve and Protect ST35 African fern pine Afrocarpus falcatus Yes Preserve and Protect ST36 African fern pine Afrocarpus falcatus Yes Preserve and Protect ST37 African fern pine Afrocarpus falcatus Yes Preserve and Protect ST38 date palm Phoenix dactylifera Yes Remove
ST39 African fern pine Afrocarpus falcatus Yes Preserve and Protect ST40 date palm Phoenix dactylifera Yes Preserve and Protect Source: Carlberg Associates. 2021 (February 3). City of Pasadena Tree Inventory, 555 South Arroyo Parkway, Pasadena, California 91105. Sierra Madre, CA: Carlberg Associates.

Affinity Project Draft EIR
2-4 Environmental Setting and Project Description

2.2.3 RELEVANT PLANNING CONSIDERATIONS
City of Pasadena
The City’s General Plan land use designation for the Project site is High Mixed-Use, which is intended to support multi-story mixed-use buildings with a variety of compatible commercial and residential uses. Development within this designation is characterized by shared open spaces, extensive landscaping, minimal building separations, and shared driveways with parking located underground or to the rear of the street. The High Mixed-Use General Plan land use category allows maximum densities of 3.0 floor area ratio (FAR) and 87 dwelling units per acre (du/acre).

Based on the lot size, the site would allow up to 434,559 sf of floor area and up to 289 dwelling units.

The Land Use Element of the City’s General Plan establishes an overall pattern of development that directs growth “into specific areas in order to protect residential neighborhoods and create mixed-use urban environments.” These areas are based on a concept of higher density, mixeduse environments that support transit- and pedestrian-oriented mobility strategies. The Central District is one of eight areas throughout the City requiring preparation of a specific plan to implement this goal. The site is zoned CD-6 (Central District, Arroyo Corridor/Fair Oaks subdistrict). The City considers the Central District to be Pasadena’s urban core, and this Specific Plan (Central District Specific Plan [CDSP]) includes a “diverse mix of land uses designed to create the primary business, financial, retailing, and government center of the City” (Pasadena 2004).

The CDSP includes both Public Realm and Private Realm Design Guidelines, which apply to all development in this district, including the Project. The CDSP also provides District-wide land use, mobility, and urban design concepts. The CDSP identifies sub-districts, and within the subdistricts, precincts that include more specific goals, policies, and standards targeted toward the vision for each neighborhood. The site is in the Arroyo Corridor Transition precinct within the Arroyo Corridor/Fair Oaks sub-district, which is an important gateway to downtown that also supports a broad, but rather undefined, mixture of uses at the periphery of the urban core. The objective of the Arroyo Corridor/Fair Oaks sub-district is to establish Arroyo Parkway as a visually appealing entrance corridor. Additionally, the intent of sub-district is to provide an attractive opportunity for employment-generating uses adaptable to changing economic conditions–such as arts, technology, and knowledge-based enterprise–within a revitalized low-scale, mixed-use setting at the periphery of Downtown Pasadena. The emphasis of the Arroyo Corridor Transition precinct is the transitional character of the area towards more pedestrian and transit-oriented development with a mix of land uses including residential, commercial, and employment (Pasadena 2004). Within this Corridor, building height is limited to 50 feet, or 65 feet using height averaging.

As discussed further below and in Section 3.6, Land Use and Planning, of this Draft EIR, the Applicant seeks approval to rezone the site as a Planned Development (PD) district and approval of a PD Plan. The City’s PD zone is a special purpose zoning district defined pursuant to Section

17.26.020(C) of the Pasadena Municipal Code. The PD zoning district is “intended for sites where an applicant proposes and the City desires to achieve a particular mix of uses, appearance, land use compatibility, or special sensitivity to neighborhood character.” The Applicant is also requesting a zoning variance for historic resources related to building height. Specifically, the Applicant is requesting an increase in allowable building height to offset the reduction in developable area due to preserving the two historic structures (i.e., 501 and 523 South Arroyo Parkway) on the Project site.

Affinity Project Draft EIR
2-5 Environmental Setting and Project Description
Southern California Association of Governments
The Southern California Association of Governments (SCAG) is the Metropolitan Planning Organization (MPO) for six counties: Los Angeles, Orange, San Bernardino, Riverside, Ventura, and Imperial Counties, an area that encompasses more than 38,000 square miles. As the designated MPO, the federal government mandates that SCAG research and draw up plans for transportation, growth management, hazardous waste management, and air quality.

SCAG is responsible for maintaining a continuous, comprehensive, and coordinated planning process resulting in a Regional Transportation Plan (RTP) and a Federal Transportation Improvement Program (FTIP) and developing a Sustainable Communities Strategy (SCS) to reduce greenhouse gas emissions, as required by applicable State law (Senate Bill [SB] 375) as an element of the RTP. On September 3, 2020, the SCAG Regional Council adopted the 2020– 2045 RTP/SCS. The 2020 RTP/SCS combines the need for mobility with a “sustainable future” through a reduction in the amount of emissions produced from transportation sources.

High-Quality Transit Areas (HQTAs) are areas within one-half mile of a fixed guideway transit stop or a bus transit corridor where buses pick up passengers at a frequency of every 15 minutes or less during peak commuting hours. Transit Priority Areas (TPAs) are areas within one-half mile of a major transit stop that is existing or planned (SCAG 2020). The Project site is within both a HQTA and TPA.

2.3 PROJECT OBJECTIVES
Section 15124(b) of the State CEQA Guidelines requires an EIR to include a statement of the proposed project’s objectives. This disclosure will assist in developing the range of Project alternatives to be investigated in the EIR and will provide a rationale for the adoption of a Statement of Overriding Considerations if one is needed. The Affinity Project seeks to achieve the following key objectives:

1. Reinforce and strengthen Arroyo Parkway as a major commercial corridor and the Central District’s economic vitality through the development of multi-story buildings with a variety of complementary commercial and/or residential uses in underutilized areas with higher development capacity.

2. Provide jobs, services, revenues, and opportunities that will support Pasadena as an economically vital city and allow for continued fiscal health.

3. Develop assisted living facilities that have access to local commercial services, health care facilities, community facilities, and public transit.

4. Satisfy local and regional demand for varying levels of care (independent living, residential care, continuing care) to individuals, depending on need, that are transit-accessible and pedestrian-friendly.

5. Improve Pasadena’s infrastructure and urban form through modernized buildings that are energy- and water-efficient.

6. Preserve and integrate Pasadena’s historic resources as part of a complementary development that reduces the risk of resource demolition, deterioration by neglect, and/or impacts from natural circumstances.

7. Invest sustainably by providing for the needs of existing and future residents and businesses while in proximity to transportation opportunities.

Affinity Project Draft EIR
2-6 Environmental Setting and Project Description

2.4 PROJECT DESCRIPTION
The Applicant requests approval to rezone the Project site from CD-6 to a Planned Development (PD) zone, and approval of a PD Plan. The Project involves demolition of 6 (of the 9) existing buildings totaling 45,912 sf, located at 491, 495, 499, 503, 541, and 577 South Arroyo Parkway, and construction of 2 new buildings, as identified below:
 Building A: a 154,000-sf, 7-story (aboveground) medical office building with ground-floor commercial uses;
 Building B: a 184,376-sf, 7-story (aboveground) assisted living building with 85,800 sf of assisted living uses and 98,576 sf of independent living uses including up to 95 studio, one-, and two-bedroom senior housing units; and
 Up to 850 parking spaces in 5 subterranean levels.

Alternatively, the proposed PD Plan would provide the flexibility to exchange the uses in Building A from medical office and ground floor commercial for the following:
 3,000 sf of commercial and a sales/leasing management office on the ground floor;  Up to 197 residential dwelling units; and
 Up to 650 parking spaces in 4 subterranean levels (1 less parking level than the Project as proposed).

Although the Project described is anticipated to reflect the Project to be constructed, the flexibility to exchange the uses in Building A would enable the Project to respond to the economic needs and demands of the City at the time of Project implementation. The proposed site layout and the aboveground height, mass, and other parameters of the Building A design would remain the same. The PD Plan would define all aspects of site design and provide caps on the types and amounts of allowable land uses, regardless of whether Building A is developed with medical office or residential dwelling units. It is noted that based on the development cap of 87 dwelling units per acre (du/acre), a total of 289 units could be constructed. Therefore, if a total of 197 units were constructed in Building A, only 92 senior housing units (i.e., 3 fewer units than the Project as proposed) could be constructed in Building B. Conversely, if 95 senior housing (i.e., independent living) units were constructed in Building B, only 194 units could be constructed in Building A.

Throughout the CEQA documentation, these two development scenarios will be referred to as:
 Project (development of Building A with medical office/commercial), and  Project with Building A Residential/Commercial (development of Building A with residential/commercial).

A total of five levels of subterranean parking spanning both proposed buildings with up to 850 parking spaces would be constructed to serve the new development as well as the existing structures at 501 and 523 South Arroyo Parkway under the Project scenario. When including the new subterranean parking, the Project would consist of approximately 753,439 sf of new construction. For the Project with Building A Residential/Commercial, a total of 4 levels of subterranean parking spanning both proposed buildings with up to 650 parking spaces would be constructed to serve the new development as well as the existing structures at 501 and 523 South Arroyo Parkway.

Approximately 79,553 sf of the existing development would be retained and integrated into the Project, including the Whole Foods Market and associated 275-space subterranean parking Affinity Project Draft EIR
2-7 Environmental Setting and Project Description
structure at 465 South Arroyo Parkway, and the 2 historic structures at 501 and 523 South Arroyo Parkway. The Applicant anticipates that restaurant uses would occupy the approximately 5,882 sf of space in the existing buildings to be retained at 501 and 523 South Arroyo Parkway. In retaining these structures, the Applicant is also requesting a zoning variance for historic resources related to building height. Specifically, the Applicant is requesting an increase in allowable building height of the two new buildings to offset the reduction in developable area due to preserving the two historic structures (i.e., 501 and 523 South Arroyo Parkway) on the Project site. Exhibit 2-4, Project Site Plan, provides a schematic overview of the Project design.

Section 15124 of the State CEQA Guidelines defines what information shall be contained in a project description for purposes of analysis in an EIR. The concept of a stable and finite project description is shaped by selected published CEQA court decisions. The project description provided in this Draft EIR meets the requirements of Section 15124 and is also stable and finite.

A stable and finite project description, as interpreted in the relevant legal cases, is not synonymous with allowing only a single development scenario. The siting, mass, and outward appearance of the Project, regardless of scenario, is clearly defined both in this EIR and in the Initial Study. The upper limits of development of both buildings for both scenarios is clearly defined, and the Initial Study and this EIR address both scenarios in distinct, separate analyses.

Therefore, the project description provided in this Draft EIR is legally adequate and allows for a full and robust analysis of all potential impacts of implementing either the Project or Project with Building A Residential/Commercial, if approved.

2.4.1 PROPOSED LAND USES
Table 2-3, Summary of Proposed Land Uses, on the following page summarizes the existing and proposed uses for the Project and the Project with Building A Residential/Commercial. Exhibit 2-5, First (Ground) Level Plan; Exhibit 2-6, Level 2 Plan; Exhibit 2-7, Level 3 Plan; Exhibit 2-8, Level 4 Plan; Exhibit 2-9, Level 5 Plan; Exhibit 2-10, Level 6 Plan; and Exhibit 2-11, Level 7 Plan present the floor plans from the ground floor through Level 7 for the Project.

Under the Project scenario, the medical office building would have commercial uses as well as a lobby, loading bay, and circulation areas on the Ground (first) level and medical office uses on Levels 2 through 7.

On the Ground (first) Level of the assisted living building, there would be a foyer, parlor, bistro, and dining room for open use; a private dining room for assisted living use; a casual dining/lounge, dining area, and private dining room for independent living use; and “back of house” facilities for the assisted living uses, such as a day spa, kitchen, laundry, staff lounge, and business offices; and a loading bay. There would be separate entrances and sets of elevator bays for use by assisted and independent living residents and guests. Levels 2 and 3 would be exclusively assisted living and include communal spaces; Level 4 would be a mix of assisted and independent living; and levels 5 through 7 would be exclusively independent living. Level 7 would also have a gym, billiard room, club room, and bistro lounge for independent living residents. As noted above, a total of 95 studio, one-, and two-bedroom senior housing units would be constructed as part of the assisted living building.

Under the Project with Building A Residential/Commercial scenario, the floor levels, building envelope, site layout, and open space would be the same as presented for the medical office building. Detailed floor plans for development of residential uses and ground floor commercial and management office, if the land uses in Building A are exchanged, have not been developed at the time of preparation of this Draft EIR. However, the dwelling units are anticipated to be market-rate apartments and/or condominiums of various sizes.

Map not to scale
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(02/04/2021 RMB) R:\Projects\PAS_Pasaden\3PAS012100\Graphics\ex_project_site_plan.pdf D:\Projects\3PAS\012100\GRAPHICS\project_description\ex2-4_project_site_plan_20210204.ai Affinity Project
Project Site Plan Exhibit 2-4

HEIGHT MEASUREMENT POINT - MEDICAL HEIGHT MEASUREMENT POINT - ASSISTED HEIGHT MEASUREMENT POINT - ASSISTED 10’-0”
Sidewalk
5’-2”
Setback
19’-0”
Driveway
2’-0”
Setback
842’-9” SITE LENGTH
169’-8” SITE DEPTH
No Setback No Setback
10’-0”
Sidewalk24’-0” Driveway
P.L.
28’-2”
Driveway
41’-8”
R=30’-4”
20’-9”
Driveway
10’ Setback
P.L. P.L.

P.L.

P.L. P.L. P.L.

S ARROYO PKWY

MEDICAL BUILDING
7 LEVELS / 90 FT HT.

TYPE I CONSTRUCTION
154,000 FAR SF

BUILDING A

HISTORIC

COMMERCIAL

BLDG TO BE

RETAINED
3,00 FAR SF

HISTORIC

COMMERCIAL

BLDG TO BE

RETAINED
2,88 FAR SF

S RAYMOND AVE

E CALIFORNIA BLVD
E BELLEVUE DR Loading Loading
Parking Access
167’-0”
307’-0”
158 0” 0 158’-” 0 5
158’-0”
Parking Access Parkin Pg Access

ASSISTED BUILDING
7 LEVELS / 87 FT HT.

TYPE I CONSTRUCTION
184,376 FAR SF

ASSISTED BUILDING
GARDEN

ASSISTED BUILDING
GARDEN

BUILDING B

METRO GOLD LINE
2 LEVELS / ~60 FT HT.

TYPE II CONSTRUCTION
73,671 FAR SF

WHOLE FOODS
MARKET
Commercial Commercial Residential
Commercial Commercial Commercial
Commercial
CommercialCommercial
Commercial
Commercial
Commercial
Commercial Commercial
Commercial
Commercial
Commercial Commercial
Commercial Commercial
Commercial
Commercial
Commercial
Commercial

SITE PLAN AND VICINITY MAP

SCALE FOR SITEPLAN
Commercial
California Blvd
E Del Mar Blvd
E Bellevue Dr
S. Arroyo Parkway
Marengo Ave
S Euclid Ave
Los Robles Ave
Fair Oaks Ave
S Raymond Ave
South Pasadena Ave
9 1.8.2021
THE AFFINITY 555 S ARROYO PKWY PASADENA CA 91101
|
D. SITE PLAN
Map not to scale
Source: Adept 2021
(02/04/2021 RMB) R:\Projects\PAS_Pasaden\3PAS012100\Graphics\ex_ground_level_plan.pdf D:\Projects\3PAS\012100\GRAPHICS\project_description\ex2-5_ground_level_plan_20210204.ai Affinity Project
First (Ground) Level Plan Exhibit 2-5
1,550 SF
6,737 SF 5,160 SF
1,659 SF
1,809 SF
1,948 SF
3,307 S 3,307 SF
1716 SF

BACK OF
HOUSE
2,625 SF
6,850 SF
1,550 SF 2,013 SF
1720 SF

MOB COMMERCIAL

MOB CIRCULATION/LOBBY

MOB LOADING

ASSISTED BLDG LOADING

ASSITED BLDG CORRIDOR

ASSITED BLDG BACK OF HOUSE

ASSISTED BLDG AL ENTRY

ASSISTED BLDG IL ENTRY
Map not to scale
Source: Adept 2021
(02/04/2021 RMB) R:\Projects\PAS_Pasaden\3PAS012100\Graphics\ex_level2_plan.pdf D:\Projects\3PAS\012100\GRAPHICS\project_description\ex2-6_level2_plan_20210204.ai Affinity Project
Level 2 Plan Exhibit 2-6
pj _ p __p _ HICS\project description\ex2-6 level2 plan 20210204.ai OFFICE
20,5 23,028 93 SSFF

MOB OFFICE

MOB CIRCULATION

ASSITED BLDG AL COMMON SPACE

ASSITED BLDG AL CIRCULATION

ASSISTED BLDG AL LIVING UNITS
Map not to scale
Source: Adept 2021
(02/04/2021 RMB) R:\Projects\PAS_Pasaden\3PAS012100\Graphics\ex_level3_plan.pdf D:\Projects\3PAS\012100\GRAPHICS\project_description\ex2-7_level3_plan_20210204.ai Affinity Project
Level 3 Plan Exhibit 2-7
OFFICE
2224,
,671 SF
236 SF

MOB OFFICE

MOB CIRCULATION

ASSITED BLDG AL COMMON SPACE

ASSITED BLDG AL CIRCULATION

ASSISTED BLDG AL LIVING UNITS
Map not to scale
Source: Adept 2021
(02/04/2021 RMB) R:\Projects\PAS_Pasaden\3PAS012100\Graphics\ex_level4_plan.pdf D:\Projects\3PAS\012100\GRAPHICS\project_description\ex2-8_level4_plan_20210204.ai OFFICE
242,671 SF 236

MOB OFFICE

MOB CIRCULATION

ASSITED BLDG AL CIRCULATION

ASSISTED BLDG AL LIVING UNITS

ASSISTED BLDG IL CIRCULATION

ASSISTED BLDG IL LIVING UNITS
Affinity Project
Level 4 Plan Exhibit 2-8
Map not to scale
Source: Adept 2021
(02/04/2021 RMB) R:\Projects\PAS_Pasaden\3PAS012100\Graphics\ex_level5_plan.pdf D:\Projects\3PAS\012100\GRAPHICS\project_description\ex2-9_level5_plan_20210204.ai OFFICE 22,236 SF

MOB OFFICE

MOB CIRCULATION

ASSISTED BLDG IL CIRCULATION

ASSISTED BLDG IL LIVING UNITS
Affinity Project
Level 5 Plan Exhibit 2-9
Map not to scale
Source: Adept 2021
(02/04/2021 RMB) R:\Projects\PAS_Pasaden\3PAS012100\Graphics\ex_level6_plan.pdf D:\Projects\3PAS\012100\GRAPHICS\project_description\ex2-10_level6_plan_20210205.ai OFFICE
2118,
,
162 727 SSFF

MOB OFFICE

MOB CIRCULATION

ASSISTED BLDG IL CIRCULATION

ASSISTED BLDG IL COMMON SPACE

ASSISTED BLDG IL LIVING UNITS
Affinity Project
Level 6 Plan Exhibit 2-10
Map not to scale
Source: Adept 2021
(02/04/2021 RMB) R:\Projects\PAS_Pasaden\3PAS012100\Graphics\ex_level7_plan.pdf D:\Projects\3PAS\012100\GRAPHICS\project_description\ex2-11_level7_plan_20210205.ai OFFICE
18,727 SF

MOB OFFICE

MOB CIRCULATION

ASSISTED BLDG IL CIRCULATION

ASSISTED BLDG IL LIVING UNITS
Affinity Project
Level 7 Plan Exhibit 2-11
Affinity Project Draft EIR
2-8 Environmental Setting and Project Description
TABLE 2-3

SUMMARY OF PROPOSED LAND USES
Existing Buildings to Remain
Address Use Floor Area (Gross sf)
465 South Arroyo Parkway Whole Foods Market 73,671 sf
501 South Arroyo Parkway (historic) Gold Line Pilates 2,880 sf 523 South Arroyo Parkway (historic) Town & Country Event Rentals 3,002 sf Total Square Footage 79,553 sf
Parking (Whole Foods Structure) 275 spaces / 2 loading spaces Project Development
Floor Area (Gross sf)
Medical Office Building (A) Assisted Living Building (B) Basement/Subterranean Levels 415,063
Ground 14,635 25,377
2nd 23,028 31,269
3rd 26,671 29,107
4th 26,671 29,107
5th 26,671 29,107
6th 21,162 21,299
7th 21,162 19,110
Total Gross Square Footage 154,000 (Aboveground) 184,376 (Aboveground) 753,439 (Including five subterranean levels spanning both buildings) Parking Up to 850 spaces
Total Aboveground Built Area
(Existing + Proposed) 417,929
Building Outline/Site Coverage 99,224 sf / 68 percent
Proposed FAR 2.89
Open Space 8,676 22,929
Project with Building A Residential/Commercial Development Floor Area (Gross sf)
Residential/Commercial Building (A) Assisted Living Building (B) Differences from Project Scenario Up to 197 dwelling units & 3,000 sf of ground-floor commercial Same as Project
Total Square Footages 154,000 (Aboveground) 184,376 (Aboveground) 670,427 (Including four subterranean levels spanning both buildings)a Parking Up to 650 spaces
Total Aboveground Built Area
(Existing + Proposed) 417,929
Building Outline/Site Coverage 99,224 sf / 68 percent
Proposed FAR 2.89
Open Space 8,676 22,929
a Reflects one less subterranean parking level, all other floor area sizes are the same sf: square feet; N/A: not applicable; FAR: floor area ratio

Affinity Project Draft EIR
2-9 Environmental Setting and Project Description
Design and Architecture
Exhibit 2-12, East and North Elevations, shows elevations of the Project from the east (Arroyo Parkway) and the north (Bellevue Drive); and Exhibit 2-13, West and South Elevations, shows elevations of the Project from the west (Gold Line tracks) and the south (California Boulevard).

These elevations illustrate the massing and relative height of the proposed buildings among the existing buildings on the site to be retained and the adjacent streets and light rail line. The building configuration is further illustrated in the north-south cross-section presented on Exhibit 2-14, Cross Section (North-South). This shows a section of the Project as though viewing from South Arroyo Parkway, with the medical office building on the far left and the Whole Foods Market on the far right. The maximum building heights for the Project to the top of parapet, not including appurtenances, would range from 90 feet 6 inches to 93 feet 6 inches above ground level, as shown on Exhibits 2-12 through 2-14. As shown, portions of the Project step down in height, ranging approximately between 29 feet and 77 feet 6 inches in height, not including appurtenances.

Consistent with the site zoning, roof mounted appurtenances covering not more than 25 percent of the roof area may exceed the established height limit by a maximum of 15 feet. As defined by the City, roof mounted appurtenances may include a tower, spire, cupola, chimney, penthouse, water tank, or other similar structures that are attached to a structure and not intended for human occupancy.

A shadow study was prepared by the Applicant to determine whether the proposed buildings would adversely affect the solar access of surrounding land uses. Specifically, Section

17.40.090(D) of the Pasadena Municipal Code (PMC) states:

Solar access. No structure shall be established or enlarged unless it has been reviewed by the Zoning Administrator for its effect on solar access to existing and future solar applications on adjacent properties subject to the following findings:

1. There are no conditions, covenants, and restrictions existing or proposed that are adverse to solar energy systems;

2. Solar access has been addressed within the context of any required Environmental Impact Report; and

3. The proposed structure will not prohibit or unreasonably restrict the use of solar energy systems on adjacent properties.

Exhibit 2-15, Affinity Project Shadow Study, illustrates the anticipated shade generated by the proposed buildings at 10:00 AM and 2:00 PM on both the Summer solstice (longest day of the year) and Winter equinox (shortest day of the year). As shown, at the Summer solstice the shade generated is limited to overlapping the public right-of-way (ROW) to the east and west. As expected, at the Winter equinox, the shade generated extends a greater distance to the north, east, and west. To the north and east, it extends only onto public ROW. To the west, in the morning hours the shade would extend to slightly overlap the rear of some of the existing structures facing South Raymond Avenue. These include the KPCC/Southern California Public Radio buildings at 474 South Raymond Avenue and the Self-Storage and U-Haul business at 552 South Raymond Avenue. Neither of these businesses depend on sun/solar access for their operations nor are there open areas for employee or visitor use near the rear of these buildings.

Most importantly, there is abundant flat roof area remaining beyond the limited shade generated during a portion of the year for both businesses to implement solar energy systems, should it be desired in the future. Therefore, the Project would not prohibit or unreasonably restrict the use of solar energy systems on adjacent structures.

Map not to scale
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EAST ELEVATIONEAST ELEVATION CONTINUE NORTH ELEVATION
90’-0” 3’-6”
65’-0”
T.O.ROOFT.O.PARAPET
3’-6” T.O.ROOF
T.O.PARAPET
87’-0”
29’-0”
20’-0”
36’-6”
78’-0”
78’-0”
36’-6”
59’-0”
Height Measurement Point For MEDICAL
Height Measurement Point For ASSISTED
Height Measurement Point For WHOLE FOODS
Height Measurement Point For WHOLE FOODS Height Measurement Point For WHOLE FOODS

METRO GOLDLINE
Affinity Project
East and North Elevations Exhibit 2-12
East Elevation
East Elevation Continue North Elevation
Map not to scale
Source: Adept 2021

WEST ELEVATIONWEST ELEVATION CONTINUE SOUTH ELEVATION
90’-0”
90’-0”
Height Measurement Point For WHOLE FOODS
59’-0”
43’-6”
Height Measurement Point For ASSISTED
87’-0”
Height Measurement Point For MEDICAL
Height Measurement Point For MEDICAL

METRO GOLDLINE
3’-6” T.O.ROOF
T.O.PARAPET
3’-6” T.O.ROOF
T.O.PARAPET
3’-6” T.O.ROOF
T.O.PARAPET
(02/04/2021 RMB) R:\Projects\PAS_Pasaden\3PAS012100\Graphics\ex_west_and_south_elevations.pdf D:\Projects\3PAS\012100\GRAPHICS\project_description\ex2-13_west_and_south_elevations_20210205.ai Affinity Project
West and South Elevations Exhibit 2-13
West Elevation
West Elevation Continue South Elevation
Map not to scale
Source: Adept 2021
(02/04/2021 RMB) R:\Projects\PAS_Pasaden\3PAS012100\Graphics\ex_cross_section.pdf D:\Projects\3PAS\012100\GRAPHICS\project_description\ex2-14_cross_section_20210205.ai Affinity Project
Cross Section (North-South) Exhibit 2-14

EXISTING WHOLE FOODS

WHOLE FOODS PARKING

OFFICEOFFICEOFFICEOFFICEOFFICEOFFICE

COMMERCIAL / OFFICE AL LOBBY
GRAND

FOYER BISTRO DINING

PARKINGPARKINGPARKING

PARKING

PARKINGPARKINGPARKINGPARKING

PARKINGPARKING

DINING LOUNGE AND LOBBY AN

ASSISTED LIVING UNITS LIVASSISTED LIVING UNITS LIV

INDEPENDENT LIVING UNITS T INDEPENDENT LIVING UNITS T
LEVEL 215’-0”LEVEL -1-10’-8”LEVEL -2-21’-4”LEVEL -3-32’-0”LEVEL -4-42’-8” LEVEL -1-10’-8”LEVEL -2-21’-4”LEVEL -3-32’-0”LEVEL -4-42’-8” LEVEL -5
LEVEL -5 -53’-4”-53’-4”LEVEL 1 - GROUND0’-0”LEVEL 327’-6”LEVEL 440’-0”LEVEL 552’-6”LEVEL 665’-0”LEVEL777’-6”TOP OF ROOF90’-0”TOP OF PARAPET93’-6” T.O. PARAPET 90’-6”
LEVEL 223’-0”LEVEL 1 - GROUND0’-0”LEVEL 333’-8”LEVEL 444’-4”LEVEL 555’-0”LEVEL 665’-8”LEVEL776’-4”T.O. ROOF87’-0” MOB Parking Count
LEVEL -1LEVEL -2LEVEL -3LEVEL -4LEVEL -5
TOTAL
6492
76 GROUND 8 6
88170
180180
42566
Parking Count
ASSISTED Parking Count
Source: Adept 2021
(07/20/2021 MMD) R:\Projects\PAS_Pasaden\3PAS012100\Graphics\ex_shadow_study.pdf D:\Projects\3PAS\012100\GRAPHICS\project_description\ex_shadow_study_20210720.ai Affinity Project
Affinity Project Shadow Study Exhibit 2-15
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S Arroyo Pkwy
S Arroyo Pkwy
E California Blvd
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Shadow Study - December 23, 10am - 2pm
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Shadow Study - June 23 @ 2pm
Shadow Study - December 23 @ 2pm
Affinity Project Draft EIR
2-10 Environmental Setting and Project Description
The proposed building facades incorporate numerous window openings to provide views and to avoid blank, massive-looking building faces. The facades would also be articulated with patios, window shades, and varying surface treatments to provide variation and break up the surface of the buildings. Portions of both the proposed buildings would be set back from the widest part of the building envelope and some portions of the buildings would extend only to Level 4 and Level

6. Additionally, the ground floor would be slightly taller than the remaining levels, at 15 feet high.

This would act to differentiate the ground floor and, combined with some unique architectural features for this level, create a human-scale and pedestrian-friendly environment. The assisted living building would have a steel stud exterior wall clad with a combination of textured face brick and smooth plaster or precast concrete accents. Trellises and balcony railings would be painted steel with a cement fiber composite soffit and sealed concrete decking. Glazing would be factory finished aluminum or steel operable frames with bronze-, gray-, or green-tinted thermal glass and spandrel glass at floors and vision glass heads. Exterior decks would be a double slab construction with paver tiles. The medical office building would have a combination of aluminum frame glass curtain wall and steel stud exterior wall clad with a mixture of textured face brick and smooth plaster or glass fiber reinforced concrete precast accents on the lower floors of the building. Glazing would be a factory finished aluminum structural silicone glazing system with bronze-, gray-, or green-tinted thermal glass and spandrel glass at floors and vision glass heads.

Exterior decks would be a double slab construction with paver tiles. The Project proposes to maintain visual continuity through the consistent application of high-quality building, landscape, and hardscape design and materials. Only non-reflective building materials would be used.

Under the Project with Building A Residential/Commercial, the setbacks, scale, massing, and other aspects of the architectural design would be the same as discussed for the Project with the medical office building.

The existing historic structures at 501 and 523 South Arroyo Parkway would be preserved in place. Specific future tenant improvement plans for these historical resources on the Project site are still in the conceptual phase as of the preparation of this Draft EIR. However, the plans do not anticipate demolishing, moving, or making major alterations to these structures. Proposed tenant improvements to the exterior of these two structures would be reviewed by an architectural historian meeting the Secretary of the Interior’s Professional Qualifications Standards for architectural history or historic architecture. Specifically, these plans shall be reviewed by the qualified architectural historian for consistency with the Secretary of the Interior’s Standards for the Treatment of Historic Properties.

As noted in Section 2.5 further below, the Project, or Project with Building A Residential/Commercial, would be required to undergo the Design Review process. The Design Review considers factors such as compatibility with surroundings, massing, proportion, siting, void-to-void relationships, and compliance with applicable design guidelines.

Landscape, Hardscape, and Lighting
Approximately 31,605 sf of open space, including public and private (for solely resident and staff use space), would be provided across the site for both the Project and Project with Building A Residential/Commercial scenarios. As discussed previously, the Project would result in the removal of 23 non-protected non-native trees on the Project site and 2 protected, non-native street trees. As shown on Exhibit 2-16a, Conceptual Landscape Plan, the Project would include a total of 25 trees in above-grade planters within the site. The 15 remaining protected street trees would be protected in place during construction and remain after the Project is implemented. As discussed in Section 2.4, Biological Resources, of the Initial Study, the Urban Forestry section of the City’s Public Works Department typically requires a fee, dependent on the size of the tree(s) being removed, to be remitted into the City’s street tree fund. For the Project, a planned condition of approval calls for planting of one new street tree along both Arroyo Parkway and California Affinity Project Draft EIR
2-11 Environmental Setting and Project Description
Boulevard. The Project would also include a total of 25 trees in above-grade planters within the site.

Exhibits 2-16b through 2-16e present the conceptual landscape plan for Levels 1 through 6. As shown, each level of the Project would include placement of drought-tolerant species of ornamental trees, shrubs, and groundcovers near outdoor seating areas and passages on the ground level and on above-ground building levels. Regarding the creation of a heat island and/or increase of the local heat index, the Project would result in at worst a neutral contribution to the heat index in the area. Heat islands are created by a combination of heat-absorbing surfaces (such as dark pavement and roofing), heat-generating activities (such as engines and generators), and the absence of vegetation (which provides evaporative cooling).

It is noted that of the 23 on-site trees to be removed, 19 are queen palms (Syagrus romanzoffiana), which provide little shade. They do provide some measure of evaporative cooling, which can help offset the heat index, but not at ground level. Additionally, the site currently contributes to the urban heat island effect by consisting almost entirely of asphalt or concrete surface and buildings. The hydrology study prepared for the Project (and provided as Appendix C of the Initial Study) assessed that the site is currently 97 percent impervious surface area. With implementation of the Project, the site would be 98 percent ground-level impervious surface area.

However, with the Project there is a net increase in vegetation on the site compared to the existing condition, with landscaping at the ground level and on levels 2, 3, and 6. All vegetation, whether in ground or planters, provides evaporative cooling. Under the Project with Building A Residential/Commercial, the landscape (including tree removal and planting), hardscape, and lighting would be the same as that discussed for the Project.

Project Circulation, Access, and Parking
As shown on Exhibit 2-5, the Project uses south of Whole Foods Market would have three ingress/egress points, one on California Boulevard and two on South Arroyo Parkway. Two circular drop-off areas would be constructed, with one situated on the north side of each proposed building.

Under the Project, a total of 5 levels of subterranean parking with up to 850 parking spaces would be constructed to serve the proposed land uses and the existing structures at 501 and 523 South Arroyo Parkway. The ingress/egress on East Bellevue Drive to the 275-space Whole Foods Market parking structure would remain and continue serving the grocery store; this parking structure would be entirely separated from the proposed parking structure.

Under the Project with Building A Residential/Commercial, the circulation and access would be the same as that discussed for the Project. As noted above, this scenario would provide 200 fewer parking spaces with one less level of subterranean parking when compared to the Project.

Utilities
Wet and dry utilities are currently provided to the Project site and surrounding area by various providers, as listed below. The agencies responsible for these services are in parentheses:
 Water facilities (Pasadena Water and Power [PWP]);
 Wastewater facilities (Los Angeles County Sanitation Districts and City of Pasadena Department of Public Works);
 Storm drain facilities (Los Angeles County Flood Control District and City of Pasadena Department of Public Works);
 Electricity (Southern California Edison); and
 Natural Gas (Southern California Gas Company).

Map not to scale
Source: Adept 2021
(02/04/2021 RMB) R:\Projects\PAS_Pasaden\3PAS012100\Graphics\ex_ConceptualLandscapePlan.pdf D:\Projects\3PAS\012100\GRAPHICS\project_description\ex2-16_ConceptualLandscapePlan_20210318.ai Affinity Project
Conceptual Landscape Plan Exhibit 2-16a
ED.

MKT.

FAM. PARLOR.

LOADING
M.C. M.D.F. M.E.P.

AL
ELEC
AL
H2O
STAFF
LOUNGE

BOC LAUNDRY DAY SPA
WK RM

KITCHEN

AL PRIV
DINING
MEPMOB
GRAND
FOYER

BISTRO ALL DINING
ROOM
IL PRIV.

DINER
DAY
SPA
MKT.

SALES.

IL DINING
CASUAL
DINING +
LOUNGE

EXISTING

BUILDING

EXISTING

BUILDING
UP DN
10' @ 7.5% 47' @ 15% 8'-2" CLR

HEAD ROOM
RAMP @ 15% RAMP @ 7.5% M

DROP OFF

ELECTRICAL
VAULT

ELECTRICAL
VAULT

LOADING

RAMP DN

RAMP DN
DN
UP

RAMP DN
UP DN
UP DN
DN UP

DROP OFF
UP DN
DN
TRASH
UP

TRASH TRASH

COMMERCIAL LOBBY
IL ELEC.

IL H2O

SOUTH ARROYO PARKWAY

LACTC RAILWAY

EAST CALIFORNIA STREET
T 3 T 4 T 5 T 6 T 7 T 8 T 9 T 10 T 11 T 12 T 13 T 14 T 15 T 23 T 2T 1
T 17
T 18 T 19
T 20
ST 40 ST 39 ST 38 ST 37 ST 36 ST 35 ST 34 ST 33 ST 32
T 21 T 22
T 16

CONCEPTUAL LANDSCAPE
A. TREE PLAN - LEVEL 1 - GROUND

CINNAMOMUM CAMPHORA CAMPHOR TREE

EXISTING STREET TREES

TAG BOTANICAL NAME COMMON NAME DISPOSITION

PROTECT IN PLACE
- NUMBERS CORRESPOND TO ARBORISTS REPORT & TREE PLAN- PLEASE SEE ARBORIST REPORT & PLAN FOR ADDITIONAL INFORMATION

4.6 SIZE DBH "
ST 24ST 25 FICUS BENJAMINA WEEPING FIG 3, 3.5 PROTECT IN PLACEST 26 PHOENIX DACTYLIFERA DATE PALM BT 20' PROTECT IN PLACEST 27 AFROCARPUS FALCATUS AFRICAN FERN PINE 18.9 PROTECT IN PLACEST 28 AFROCARPUS FALCATUS AFRICAN FERN PINE 1 PROTECT IN PLACEST 29 PHOENIX DACTYLIFERA DATE PALM BT 25' PROTECT IN PLACEST 30 PHOENIX DACTYLIFERA DATE PALM BT 25' PROTECT IN PLACEST 31 PHOENIX DACTYLIFERA DATE PALM BT 25' PROTECT IN PLACE ST 33 PHOENIX DACTYLIFERA DATE PALM BT 25' PROTECT IN PLACEST 32 AFROCARPUS FALCATUS AFRICAN FERN PINE 21.5 ST 34 AFROCARPUS FALCATUS AFRICAN FERN PINE 3.7 PROTECT IN PLACEST 35 AFROCARPUS FALCATUS AFRICAN FERN PINE 1 PROTECT IN PLACEST 36 AFROCARPUS FALCATUS AFRICAN FERN PINE 20.2 PROTECT IN PLACEST 37 AFROCARPUS FALCATUS AFRICAN FERN PINE 15.2 PROTECT IN PLACE ST 38 PHOENIX DACTYLIFERA DATE PALM BT 20' REMOVE
ST 39 AFROCARPUS FALCATUS AFRICAN FERN PINE 20 PROTECT IN PLACE ST 40 PHOENIX DACTYLIFERA DATE PALM BT 25' PROTECT IN PLACE

REPLACEMENT RATIO
--------------

SPECIES PER CITY OF PASADENA
--
1 STREET TREE

SYAGRUS ROMANZOFFIANA QUEEN PALM

TAG BOTANICAL NAME COMMON NAME DISPOSITION
BT 20' REMOVE
SIZE DBH "
T 1T 2
T 3 BT 15' REMOVET 4T 5T 7T 8
T 10T 9T 11T 12T 13T 14T 15T 16T 17

SYAGRUS ROMANZOFFIANA QUEEN PALM
SYAGRUS ROMANZOFFIANA QUEEN PALM BT 15' REMOVESYAGRUS ROMANZOFFIANA QUEEN PALM REMOVE BT 20' AFROCARPUS FALCATUS AFRICAN FERN PINE REMOVE & 7.4 4.3, 7.3 SYAGRUS ROMANZOFFIANA QUEEN PALM REMOVE BT 15'
T 6 SYAGRUS ROMANZOFFIANA QUEEN PALM REMOVE BT 20'
SYAGRUS ROMANZOFFIANA QUEEN PALM REMOVE BT 15'
SYAGRUS ROMANZOFFIANA QUEEN PALM REMOVE BT 15'
SYAGRUS ROMANZOFFIANA QUEEN PALM REMOVE BT 15'
SYAGRUS ROMANZOFFIANA QUEEN PALM REMOVE BT 15'
SYAGRUS ROMANZOFFIANA QUEEN PALM REMOVE BT 15'
SYAGRUS ROMANZOFFIANA QUEEN PALM REMOVE BT 20'
SYAGRUS ROMANZOFFIANA QUEEN PALM REMOVE BT 15'
SYAGRUS ROMANZOFFIANA QUEEN PALM REMOVE BT 15'
SYAGRUS ROMANZOFFIANA QUEEN PALM REMOVE BT 15'
SYAGRUS ROMANZOFFIANA QUEEN PALM REMOVE BT 20'

EXISTING SITE TREES - NUMBERS CORRESPOND TO ARBORISTS REPORT & TREE PLAN - PLEASE SEE ARBORIST REPORT & PLAN FOR ADDITIONAL INFORMATION

REPLACEMENT RATIO
2 EA - 36" BOX2 EA - 36" BOX1 EA - 36" BOX1 EA - 36" BOX1 EA - 36" BOX2 EA - 36" BOX1 EA - 36" BOX1 EA - 36" BOX1 EA - 36" BOX1 EA - 36" BOX1 EA - 36" BOX2 EA - 36" BOX1 EA - 36" BOX1 EA - 36" BOX1 EA - 36" BOX2 EA - 36" BOX0

SYAGRUS ROMANZOFFIANA QUEEN PALM

TAG BOTANICAL NAME COMMON NAME DISPOSITION
BT 17' REMOVE
SIZE DBH "
T 18T 19T 20 BT 17' REMOVET 21T 22

SYAGRUS ROMANZOFFIANA QUEEN PALM
SYAGRUS ROMANZOFFIANA QUEEN PALM BT 17' REMOVEPINUS CANARIENSIS CANARY ISLAND PINE REMOVE 20.8 PINUS CANARIENSIS CANARY ISLAND PINE REMOVE 17.4
T 23 CARYA ILLINOINENSIS PECAN REMOVE 5.5

EXISTING SITE TREES CONTINUED - NUMBERS CORRESPOND TO ARBORISTS REPORT & TREE PLAN - PLEASE SEE ARBORIST REPORT & PLAN FOR ADDITIONAL INFORMATION

REPLACEMENT RATIO
1 EA - 36" BOX2 EA - 36" BOX1 EA - 36" BOX1 EA - 36" BOX00 TOTAL NUMBER OF REPLACEMENT TREES REQUIRED 26 EA - 36" BOX TOTAL NUMBER OF REPLACEMENT STREET TREES REQUIRED 1 EA - 36" BOX REMOVE
Tree Plan - Level 1 - Ground
Map not to scale
Source: Adept 2021
(02/04/2021 RMB) R:\Projects\PAS_Pasaden\3PAS012100\Graphics\ex_ConceptualLandscapePlan.pdf D:\Projects\3PAS\012100\GRAPHICS\project_description\ex2-16b_ConceptualLandscapePlan_20210318.ai Affinity Project
Conceptual Landscape Plan Exhibit 2-16b
ED.

MKT.

FAM. PARLOR.

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AL
ELEC
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H2O
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BOC LAUNDRY DAY SPA
WK RM

KITCHEN

AL PRIV
DINING
MEPMOB
GRAND
FOYER

BISTRO ALL DINING
ROOM
IL PRIV.

DINER
DAY
SPA
MKT.

SALES.

IL DINING
CASUAL
DINING +
LOUNGE

EXISTING

BUILDING

EXISTING

BUILDING
UP DN
10' @ 7.5% 47' @ 15% 8'-2" CLR

HEAD ROOM
RAMP @ 15% RAMP @ 7.5% M

DROP OFF

ELECTRICAL
VAULT

ELECTRICAL
VAULT

LOADING

RAMP DN

RAMP DN
DN
UP
DN UP

RAMP DN
UP DN
UP DN
DN UP

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UP DN
DN
TRASH
UP

TRASH TRASH

COMMERCIAL LOBBY
IL ELEC.

IL H2O

SOUTH ARROYO PARKWAY

LACTC RAILWAY
 ž ž ž

CONCEPTUAL LANDSCA
G. FLOORPLANS - LEVEL 1 - G

EAST CALIFORNIA STREET

SYMBOL BOTANICAL NAME COMMON NAME SIZE QUANTITY
OLEA EUROPAEA 'SWAN HILL' SWAN HILL FRUITLESS OLIVE 60" BOX 1CERCIS OCCIDENTALIS WESTERN REDBUD 36" BOX 4TIPUANA TIPU TIPU TREE 36" BOX 6 LEUCADENDRON SAFARI 'GOLD STRIKE' YELLOW CONEBUSH 5 GAL -LANTANA MONTIVIDENSIS TRAILING LANTANA 1 GAL - ANIGOZANTHOS 'ORANGE CROSS' ORANGE KANGAROO PAW 1 GAL -CUPRESSUS ARIZONICA 'GLAUCA' ARIZONA BLUE CYPRESS 15 GAL -LOROPETALUM CHINENSE 'CHINA PINK' CHINA PINK FRINGE FLOWER 5 GAL -

PLANT MATERIAL LEGEND
WUCOLS REG 4

LOWLOWMODERATELOWLOWLOWVERY LOWMODERATE
CERCIS OCCIDENTALIS | WESTERN REDBUD OLEA EUROPAEA 'SWAN HILL' | SWAN HILL FRUITLESS OLIVE TIPUANA TIPU | TIPU TREE ANIGOZANTHOS 'ORANGE CROSS' ORANGE KANGAROO PAW CUPRESSUS ARIZONICA 'GLAUCA' | BLUE ARIZONA CYPRESS LANTANA MONTIVIDENSIS | TRAILING LANTANA LEUCADENDRON SAFARI 'GOLD STRIKE' | YELLOW CONEBUSH LOROPETALUM CHINENSE 'CHINA PINK' | CHINA PINK FRINGE FLOWER Floorplan - Level 1 - Ground
Map not to scale
Source: Adept 2021
(02/04/2021 RMB) R:\Projects\PAS_Pasaden\3PAS012100\Graphics\ex_ConceptualLandscapePlan.pdf D:\Projects\3PAS\012100\GRAPHICS\project_description\ex2-16c_ConceptualLandscapePlan_20210318.ai Affinity Project
Conceptual Landscape Plan Exhibit 2-16c
2 S S S S S HAIR CARE
SPA
WELL
NESS
SUITE
DD 22 S 2
S
22 S

ENTERTAIN
2 SPA
SS
2 2
SSS
2 2
2 S 2

DD D D DD D D
WET
ACTIV

EXISTING

BUILDING

EXISTING

BUILDING
M
DN UP
DN

OPEN TO
BELOW
TT
UP DN
UP DN
DN UP
DN

SKYLIGHT
TO
LOBBY
OPEN
TO
DROP
OFF

SYMBOL BOTANICAL NAME COMMON NAME SIZE QUANTITY
CHILOPSIS LINEARIS 'BURGUNDY' BURGUNDY DESERT WILLOW 36" BOX 3GINKGO BILOBA 'AUTUMN GOLD' AUTUMN GOLD GINKGO TREE 3 36" BOX LEUCOPHYLLUM FRUTESCENS TEXAS SAGE - 5 GAL
BULBINE FRUTESCENS 'HALLMARK' ORANGE STALKED BULBINE - 1 GAL LEUCADENDRON 'SAFARI SUNSET' SAFARI SUNSET CONEBUSH - 15 GAL CALLISTEMON 'LITTLE JOHN' LITTLE JOHN BOTTLEBRUSH - 5 GAL LIRIOPE 'PURPLE EXPLOSION' PURPLE EXPLOSION LILYTURF - 5 GAL

PLANT MATERIAL LEGEND
WUCOLS REG 4

LOWMODERATELOWLOWMODERATELOWMODERATE
NASSELLA TENUISSIMA MEXICAN FEATHER GRASS 1 GAL - LOW
CHILOPSIS LINEARIS 'BURGUNDY' | BURGUNDY DESERT WILLOW GINKGO BILOBA 'AUTUMN GOLD' | AUTUMN GOLD GINKGO BULBINE FRUTESCENS 'HALLMARK' | ORANGE STALKED BULBINE CALLISTEMON 'LITTLE JOHN' | LITTLE JOHN BOTTLEBRUSH LEUCOPHYLLUM FRUTESCENS | TEXAS SAGE LEUCADENDRON 'SAFARI SUNSET' | SAFARI CONEBUSH LIRIOPE 'PURPLE EXPLOSION' | PURPLE EXPLOSION LILYTURF NASELLA TENUISSIMA | MEXICAN FEATHER GRASS Floorplan - Level 2 - Podium
Map not to scale
Source: Adept 2021
(02/04/2021 RMB) R:\Projects\PAS_Pasaden\3PAS012100\Graphics\ex_ConceptualLandscapePlan.pdf D:\Projects\3PAS\012100\GRAPHICS\project_description\ex2-16d_ConceptualLandscapePlan_20210318.ai Affinity Project
Conceptual Landscape Plan Exhibit 2-16d
2 S DD 22 S 2
S
22 2 SPA
SS
2 2
SSS
2 S

D D DD D D

ROOF BELOW

ROOF BELOW
DD
M
M
S S
M
V

DININGROOM
LIVING
ROOM
RES
LAUN REFL.

SERV.

STAFF
OFFICE
SS
ACTIV.

S
TINY
OFFICE
VESTI.

SERV.

DINING

ROOM LIVING ROOM

ACTIVITY RC
OFF
REFL.

DN UP

OPEN TO
BELOW
TT
UP DN
UP DN
DN UP

SYMBOL BOTANICAL NAME COMMON NAME SIZE QUANTITY
BRAHEA ARMATA BLUE HESPER PALM 36" BOX 5EREMOPHILA GLABRA BLUE HORIZON 1 GAL - ALOE ARBORESCENS TORCH ALOE 15 GAL -
HESPERALOE PARVIFLORA RED YUCCA 5 GAL -
LEPTOSPERMUM SCOPARIUM NEW ZEALAND TEA TREE 15 GAL -

PLANT MATERIAL LEGEND
WUCOLS REG 4

LOWLOWLOWLOWLOW
SENECIO SERPENS BLUE CHALK STICKS 1 GAL - LOWTRADESCANTIA PALLIDA PURPLE HEART 1 GAL - LOW FURCRAEA FOETIDA 'MEDIOPICTA' - 15 GAL - LOW
BRAHEA ARMATA | BLUE HESPER PALM ALOE ARBORESCENS | TORCH ALOE TIPUANA TIPU | TIPU TREE FURCRAEA FOETIDA 'MEDIOPICTA' HESPERALOE PARVIFLORA | RED YUCCA LEPTOSPERMUM SCOPARIUM | NEW ZEALAND TEA TREE SENECIO SERPENS | BLUE CHALK STCKS TRADESCANTIA PALLIDA | PURPLE HEART Floorplan - Level 3
Map not to scale
Source: Adept 2021
(02/04/2021 RMB) R:\Projects\PAS_Pasaden\3PAS012100\Graphics\ex_ConceptualLandscapePlan.pdf D:\Projects\3PAS\012100\GRAPHICS\project_description\ex2-16e_ConceptualLandscapePlan_20210318.ai

BISTROLOUNGE
CLUB
ROOM

BILLARD

AEROBICS

EXERCISEEQUIPMENT

LOCKERS
DN UP

OPEN TO
BELOW
TT
UP DN
UP DN
DN UP
1 2 SS SS
1 1 1 1 1 11 2
1 1
SS

SYMBOL BOTANICAL NAME COMMON NAME SIZE QUANTITY
BAUHINIA VARIEGATA 'PUPUREA' PURPLE ORCHID TREE 36" BOX 4CERCIDIUM X 'DESERT MUSEUM' DESERT MUSEUM PALO VERDE 12 36" BOXLEUCOSPERMUM 'SCARLET RIBBON' NODDING PINCUSHION - 5 GALASPARAGUS DENSIFLORUS 'MEYERS' MEYERS ASPARAGUS - 5 GALOLEA EUROPAEA 'LITTLE OLLIE' DWARF OLIVE - 15 GALEUPHORBIA TURCALLI STICKS ON FIRE - 15 GALMUHLENBERGIA CAPILLARIS PINK CLOUD MUHLY GRASS - 1 GAL

PLANT MATERIAL LEGEND
WUCOLS REG 4

MODERATELOWLOWMODERATELOWVERY LOWMODERATE
LEYMUS ARENARIUS 'BLUE DUNE' BLUE DUNE LYME GRASS 1 GAL - LOW BAUHINIA VARIEGATA 'PURPUREA' | PURPLE ORCHID TREE CERCIDIUM X 'DESERT MUSEUM' | DESERT MUSEUM PALO VERDE ASPARAGUS DENSIFLORUS 'MEYERS' | MEYERS ASPARAGUS LEUCOSERMUM 'SCARLET RIBBON' | NODDING PINCUSHION LEYMUS ARENARIUS 'BLUE DUNE' | BLUE DUNE LYME GRASS MUHLENBERGIA CAPILLARIS | PINK CLOUD MUHLY GRASS OLEA EUROPAEA 'LITTLE OLLIE' | DWARF OLIVE EUPHORBIA TURCALLI | STICKS ON FIRE
Affinity Project
Conceptual Landscape Plan Exhibit 2-16e
Floorplan - Level 6
Affinity Project Draft EIR
2-12 Environmental Setting and Project Description
Existing utility infrastructure is located on site and in the surrounding roadways. Exhibits 2-17a and 2-17b, Conceptual Utility Plans, show the locations of existing wet and dry utilities and the locations of proposed connections to utilities. As shown, all connections to water and sewer utilities and all dry utilities would occur on Arroyo Parkway.

There are 2 existing, PWP, 8-inch diameter domestic water lines in Arroyo Parkway; a 6-inch diameter domestic water line in Bellevue Drive; and a 12-inch diameter domestic water line in California Boulevard. There are two existing City of Pasadena 8-inch diameter sewer lines in Arroyo Parkway and one 8-inch diameter sewer line in California Boulevard. The northern sewer line in Arroyo Parkway turns west at and connects to the line in California Boulevard; the southern line turns east.

As shown on Exhibit 2-17a, there is an existing City of Pasadena 10-foot diameter, reinforced concrete pipe (RCP) storm drain that parallels the site’s eastern boundary in Arroyo Parkway. The 10-foot storm drain begins at an upstream network of storm drains beginning south of the I-210 and continues south to the City of South Pasadena. Here the pipe connects to a Los Angeles County Flood Control District (LACFCD) 10-foot diameter storm drain that outfalls into the Alhambra Wash Channel. There is an existing 45-inch diameter City-owned RCP storm drain in California Boulevard that connects to the 10-foot diameter storm drain in Arroyo Parkway. South of the 45-inch diameter storm drain is a 54-inch diameter LACFCD-owned RCP storm drain that also connects to the 10-foot diameter storm drain at Arroyo Parkway. With Project implementation, all on-site drainage would be collected in a proposed private storm drain system and treated before discharging to the soil below or Arroyo Parkway. Water quality treatment would be provided by either an infiltration system, a stormwater biofiltration system, or a combination of both. Storm water runoff would generally follow the same overall drainage pattern towards the south. Runoff would flow towards the proposed catch basins and trench drains throughout the outdoor areas. Storm water that falls onto building roofs would be collected with roof drains and routed either directly to the Project’s subterranean levels for treatment or onto pavement surrounding the proposed uses.

Under the Project with Building A Residential/Commercial, the wet and dry utility infrastructure, including storm water management, would be the same as discussed for the Project.

2.4.2 CONSTRUCTION SCENARIO
The Project, or Project with Building A Residential/Commercial, would be constructed beginning in 2023 over a period of approximately 34 months and would be completed in a single phase.

Project construction would occur from Monday through Saturday, without activity on Sundays or holidays, between the hours defined in Section 9.36.070 (Construction Projects) of the PMC (7:00 AM to 7:00 PM Monday through Friday and 8:00 AM to 5:00 PM on Saturday).

Demolition of six of the existing buildings and other on-site improvements, such as paving, light fixtures, and signage, would generate an estimated 4,200 cubic yards (cy) of debris, generating an estimated 300 one-way haul truck trips, over the course of 2.5 months (68 workdays). This would result in an average of 4 and 5 one-way truck trips per workday. Site preparation would then generate an estimated 30 one-way truck trips over the course of 1 month (26 workdays).

This would result in an average of just less than 1 truck trip per workday.

Implementation of the Project would involve the excavation and export of an estimated 184,013 cy of soil, generating an estimated 13,200 one-way truck trips, over the course of 4 months (103 workdays). The excavation is needed to accommodate the subterranean parking structure for the Project, which has maximum excavation depths between 54 and 58 feet below ground surface (bgs). This would equate to an average of 128 one-way trips per workday. These figures assume the use of 14-cy trucks.

Map not to scale
Source: Adept 2021
(02/04/2021 RMB) R:\Projects\PAS_Pasaden\3PAS012100\Graphics\ex_conceptual_utility_plans.pdf D:\Projects\3PAS\012100\GRAPHICS\project_description\ex2-17_conceptual_wet_utility_plan_20210205.ai Affinity Project
Conceptual Utility Plans Exhibit 2-1
7 a
Map not to scale
Source: Adept 2021
(02/04/2021 RMB) R:\Projects\PAS_Pasaden\3PAS012100\Graphics\ex_conceptual_utility_plans.pdf D:\Projects\3PAS\012100\GRAPHICS\project_description\ex2-17b_conceptual_utility_plan_20210318.ai Affinity Project
Conceptual Utility Plans Exhibit 2-17b

AMP INTAKE

MEDICAL OFFICE BUILDING MOB COMMON AREA (INCLUSIVE OF ELEVATOR)RETAIL/RESTAURANTASSISTED LIVING BUILDINGAL COMMON AREA (INSIVE OF ELEVATORS)SUBTERRANEAN PARKING 150,000 SF5,160 SF6737 SF180,000 SF5,000 SF400,000 SF
6,000 AMPS1,000 AMPS1,200 AMPS4,000 AMPS1,000 AMPS2,000 AMP Affinity Project Draft EIR
2-13 Environmental Setting and Project Description
Excavation associated with the Project with Building A Residential/Commercial would generate 36,802 cy less soil than that required for the Project, commensurate with the 1 less subterranean level. Therefore, this scenario would involve the excavation and export of an estimated 147,211 cy of soil, generating an estimated 10,515 one-way truck trips, over the course of 4 months (103 workdays). This would equate to an average of 102 one-way trips per workday. All other aspects of construction would be essentially the same for both the Project and Project with Building A Residential/Commercial scenarios.

Building construction, including architectural coatings, would generate a waste stream requiring an estimated 795 one-way truck trips over the course of 26.5 months (691 workdays). This would result in an average of just over 1 truck trip per workday. Chapter 8.62 (Waste Management Plan for Certain Construction and Demolition Projects within the City of Pasadena) et. seq. of the PMC is the City’s construction and demolition waste management ordinance (C&D ordinance), which requires at least 75 percent of the construction waste stream to be diverted from landfill disposal.

Construction and demolition debris, after diversion, would be disposed at Scholl Canyon Landfill, located approximately 2.5 miles northwest of the site, at 3001 Scholl Canyon Road in Glendale.

Construction and demolition debris being diverted from landfill disposal may be directed to many different facilities in the region that reuse or recycle this type of material.

2.4.3 PROJECT OPERATION
The Project is anticipated to be opened to the public in 2026. The medical office building would operate with hours typical of the land use–generally between 8:00 AM and 6:00 PM on weekdays and between 9:00 AM and 1:00 PM on Saturdays. However, operational hours of individual tenants of the medical office building would vary and may be longer or shorter than the typical hours. The non-commercial portion of the medical office building is expected to result in approximately 523 visitors per day and 646 employees. The commercial uses on the ground floor of the medical office building are expected to result in approximately 43 visitors per day and 9 employees. In total, Building A would generate an estimated 655 employees and 566 visitors per day. The assisted living building would also operate with hours typical of the land use. Assisted living facilities are generally operational 24 hours per day with visitation hours anticipated to be daily (Monday through Sunday) between 8:00 AM and 6:00 PM. The assisted living building is expected to result in approximately 20 to 45 visitors per day, approximately 66 employees, up to 113 assisted living residents being cared for, and up to 109 independent living residents (if the maximum of 95 independent living units are constructed). In total, Building B would generate an estimated 66 employees, 222 residents, and up to 45 visitors per day.

The two historic buildings to be retained, total 5,882 sf, are assumed to operate as fast-casual restaurants as part of the Project or Project with Building A Residential/Commercial for purposes of this Draft EIR. These two buildings are expected to result in approximately 16 employees and 83 visitors per day. Therefore, the Project as a whole would generate an estimated 222 residents, 737 employees, and up to 694 visitors per day. For purposes of this Draft EIR, all employees are assumed to be full-time as a conservative approach.

If the Project with Building A Residential/Commercial is constructed, Building A would generate approximately 493 residents associated with up to 197 units1. Under this development scenario, Building A would include a leasing/sales management office that would employ a small number of individuals–assumed to be 4 persons for purposes of this Draft EIR–and potentially employ maintenance personnel as well. As with the Project, the commercial uses on the ground floor of Building A are expected to result in approximately 43 visitors per day and 9 employees. In total, Building A with Residential Commercial would generate an estimated 493 residential and 20 1 Based on a rate of 2.5 persons per household derived from the Southern California Association of Governments (SCAG) 2019 Profile for the City of Pasadena (SCAG 2019).

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employees. The number of visitors to residential uses is not estimated as it is for business uses (e.g., medical, office, assisted living). Therefore, the Project with Building A Residential/Commercial as a whole would generate an estimated 715 residents, 95 employees, and up to 128 visitors per day.

2.5 PLANNED DEVELOPMENT PLAN AND EXCHANGE PROGRAM
Implementation of the Project or Project with Building A Residential/Commercial could occur subsequent to the adoption of the PD zone and accompanying PD Plan. According to the City of Pasadena Zoning Code, the specific purposes of the PD zoning district are to:
 Establish a procedure for the development of large parcels of land in order to reduce or eliminate the rigidity, delays, and inequities that otherwise would result from application of land use regulations and administrative procedures designed primarily for small parcels;  Ensure orderly and thorough planning and review procedures that will result in quality urban design.
 Encourage variety and avoid monotony in large developments by allowing greater freedom in selecting the means to provide access, light, open space, and amenity;  Allow certain types of development consistent with the general plan that can be acceptable at a specific location only under standards significantly more restrictive than those of a base district in which the use is permitted;
 Provide a mechanism whereby the city may authorize desirable developments in conformity with the general plan without inviting speculative rezoning applications that if granted, often could deprive subsequent owners of development opportunities that do not necessarily result in construction of the proposed facilities;  Encourage allocation and improvement of common open space in residential areas, and provide for maintenance of the open space at the expense of those who will directly benefit from it;
 Encourage the preservation of serviceable existing structures of historic value or artistic merit by providing the opportunity to use them imaginatively for purposes other than that for which they were originally intended; and
 Encourage the assembly of properties that might otherwise be developed in unrelated increments to the detriment of surrounding neighborhoods.

Adoption of a PD zoning district would reclassify the Project site from CD-6 to PD-39, while simultaneously establishing applicable land use regulations and development standards that are specific to the newly established zoning district. The regulations and standards that dictate allowed and conditionally allowed land uses and development would be prescribed in the accompanying PD Plan. This ensures the Project or Project with Building A Residential/Commercial is developed as intended. PD Plans are developed in consideration of existing zoning requirements that are applicable to a project site while also providing flexibility in site usage and building design.

The City’s process allows a property owner to initiate an amendment to reclassify a property two acres or larger to a PD zoning district. A proposed PD zoning district and the allowed or conditionally allowed land uses are required to be consistent with the City’s General Plan.

However, development cannot exceed maximums for floor area ratio or density on the Land Use Diagram unless approved by the City Council (but only as high as 3.0 FAR and 87 du/acre).

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2-15 Environmental Setting and Project Description
The review process of a new PD Application requires input from the City’s Design Commission, Planning Commission, and City Council. The review process for a proposed Planned Development is outlined in Sections 17.26.020(C)(3)(d) (Commission and Council Action),

17.61.030(I)(5)(b) (Design Conditions), and 17.74 (Amendments) of the PMC. The role of the Design Commission is limited to recommendations to the Planning Commission and City Council on aesthetic and urban design issues related to architecture, landscaping, site plan, and related aesthetic issues, as well as historic preservation. Additionally, comments on the aesthetic/cultural resources of a draft environmental study are appropriate. Therefore, review and advisement by the Design Commission regarding the proposed PD zone and PD Plan would occur first at a public meeting.

A subsequent review of a proposed PD zone and PD Plan would occur at a public hearing by the Planning Commission. The Planning Commission’s role is to make a written recommendation to the City Council to approve, approve with modifications, or disapprove the proposed reclassification and PD Plan. The City Council’s role is to hold a public hearing to consider the recommendation of the Planning Commission and to hear evidence regarding the proposal. Upon receipt of the Planning Commission's recommendation, the City Council would move to approve, approve in modified form, or disapprove the proposed PD zoning district and PD Plan. Prior to any approval, the City Council is required to certify the Final EIR. Planned Developments and the accompanying PD Plan are made a part of the Zoning Code when approved to ensure implementation occurs as approved.

The basic design of a project, including compatibility with surroundings, massing, proportion, siting, solid-to-void relationships, and compliance with applicable design guidelines is evaluated through the City’s Design Review process and is a role for the City’s Design Commission. This phase of review generally occurs after approval of the PD application, if received. An approved PD zoning district and accompanying PD Plan cannot be later revised without requiring a formal application from the applicant, noticed public hearings before the Planning Commission and City Council, and the appropriate environmental review pursuant to CEQA.

2.6 APPROACH TO CUMULATIVE IMPACT ANALYSIS
Discussions of the cumulative impacts of the Project is provided in Sections 3.1 through 3.11, relative to each CEQA topical issue evaluated herein. The following is an overview and introduction to the cumulative analysis per the State CEQA Guidelines. This avoids the undue repetition of CEQA requirements relative to cumulative analysis within individual sections.

Section 15355 of the State CEQA Guidelines defines cumulative impacts as “two or more individual effects which, when considered together, are considerable or which compound or increase other environmental impacts”. Section 15355 also specifies:
a) The individual effects may be changes resulting from a single project or a number of separate projects.
b) The cumulative impact from several projects is the change in the environment which results from the incremental impact of the project when added to other closely related past, present, and reasonably foreseeable probable future projects. Cumulative impacts can result from individually minor but collectively significant projects taking place over a period of time.

Pursuant to Section 15130(b) of the State CEQA Guidelines:

The discussion of cumulative impacts shall reflect the severity of the impacts and their likelihood of occurrence, but the discussion need not provide as great detail Affinity Project Draft EIR
2-16 Environmental Setting and Project Description
as is provided for the effects attributable to the project alone. The discussion should be guided by standards of practicality and reasonableness, and should focus on the cumulative impact to which the identified other projects contribute rather than the attributes of other projects which do not contribute to the cumulative impact.

Section 15130(b)(1) of the State CEQA Guidelines describes two allowable methods to determine the scope of projects considered in the cumulative impact analysis, as follows:
(A) A list of past, present, and probable future projects producing related or cumulative impacts, including, if necessary, those projects outside the control of the agency; or (B) A summary of projections contained in an adopted local, regional or statewide plan, or related planning document, that describes or evaluates conditions contributing to the cumulative effect. Such plans may include: a general plan, regional transportation plan, or plans for the reduction of greenhouse gas emissions. A summary of projections may also be contained in an adopted or certified prior environmental document for such a plan.

Such projections may be supplemented with additional information such as a regional modeling program. Any such document shall be referenced and made available to the public at a location specified by the lead agency.

The cumulative impact analysis contained in this EIR uses method B, the projections method. The buildout of the City’s General Plan will be used as the basis of growth projections to assess cumulative impacts. The Land Use Element of the City of Pasadena General Plan designates the intensity of development and the mix of allowed uses within each specific plan area. Specifically, Policy 1.3 states: “Regulate building intensity and population density consistently with the designations established by the Land Use Diagram. Within these, cumulative new development within the specific plan areas shall not exceed the number of housing units and commercial square feet specified in the following table”. The referenced table is presented in Table 2-4, City of Pasadena General Plan Development Caps, on the following page.

These development caps are applicable as of the date of adoption of the Land Use Element, which was August 18, 2015. The City’s development caps do not apply to affordable housing units, except for the Fair Oaks/Orange Grove specific plan area. Also, a shift of development cap from one specific plan to a different specific plan area is not permitted. It is noted that affordable housing units are not counted towards residential caps in any Specific Plan, except for the Fair Oaks/Orange Grove Specific Plan; and parking structures and structures tied to educational institutions also do not count towards non-residential development capacity limits.

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TABLE 2-4

CITY OF PASADENA GENERAL PLAN DEVELOPMENT CAPS
Specific Plan Area Residential Units Commercial Square Feet Central District 4,272 2,112,000
South Fair Oaks 802 988,000
East Pasadena 750 1,095,000
Lamanda Park 100 630,000
East Colorado 300 300,000
North Lake 250 250,000
Fair Oaks / Orange Grove 325 300,000
Lincoln Avenue 180 300,000
Totals 6,979 5,975,000
Source: Pasadena, City of. 2015b (August 18, adopted). Land Use Element of Pasadena General Plan. Pasadena, City of. Land-Use-Element-2016-01-25.pdf (cityofpasadena.net).

Table 2-5 summarizes the remaining development capacity throughout the City as of December 6, 2021 (the most recent available data). The remaining development capacity summarized above reflects all projects, including those currently in progress without entitlements. It is expected that some proportion of these projects will not come to fruition. However, to provide a conservative analysis, they have been reflected in the projections for purposes of cumulative impact analysis in this EIR. The cumulative impact analysis assumes buildout of all remaining development capacity in the City.

TABLE 2-5

CITY OF PASADENA REMAINING DEVELOPMENT CAPACITY
Specific Plan Area Residential Units Commercial Square Feet Central District 1,018 778,357a
South Fair Oaks 785 621,193
East Pasadena 57 1,284,029
Lamanda Park 101 562,867
East Colorado 199 6,534
North Lake 250 250,245
Fair Oaks / Orange Grove (43) 253,721
Lincoln Avenue 116 363,422
Totals 2,483 3,342,011
a Not including 105,020 net square feet of commercial land use associated with the Project in Building A (as proposed) (i.e., 154,000 sf – 48,980 sf).

Sources:

Pasadena, City of. 2021a (December 6, last updated). Development Cap Tracking Worksheet-Summary. Pasadena, City of. GP DEV CAP WORKSHEET Nov2021.xlsx (cityofpasadena.net).

Pasadena, City of. 2021b (November 30, last updated). Development Cap Tracking Worksheet-Details. Pasadena, City of. GP DEV CAP WORKSHEET Nov2021.xlsx (cityofpasadena.net).

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2.7 INTENDED USES OF THE EIR

2.7.1 CITY OF PASADENA
The City of Pasadena is expected to use the information contained in the EIR for consideration of approvals related to and involved in Project implementation. Actions to be considered by the City, after implementation of the CEQA process, include, but not be limited to:
 Approval of the Planned Development (PD) Zoning District and PD Plan (this includes approval of the Affinity Project, zoning map amendment to rezone the property from CD6 to PD-39, and variance for historic resources for building height);  Certification of the Affinity Project Environmental Impact Report;  Public Street Tree Removal Approval;
 Design Review;
 Vesting Tentative Tract Map or Tentative Tract Map Approval (only if residential units for sale); and
 Other discretionary and ministerial permits and approvals that may be deemed necessary, including but not limited to: master sign plan, temporary street closure permits, encroachment permits, grading permits, excavation permits, foundation permits, and building permits (including lot tie agreement).

2.7.2 RESPONSIBLE AND TRUSTEE AGENCIES
State law requires that all EIRs be reviewed by trustee and responsible agencies. A “Trustee Agency” is defined in Section 15386 of the State CEQA Guidelines as “a State agency having jurisdiction by law over natural resources affected by a project, which are held in trust for the people of the State of California”. Per Section 15381 of the State CEQA Guidelines, “the term ‘Responsible Agency’ includes all public agencies other than the Lead Agency which have discretionary approval power over the project”.

The EIR also provides environmental information to responsible agencies, trustee agencies, and other public agencies that may be required to grant approvals and permits or coordinate with the City as part of Project implementation. These agencies include, but are not limited to, those listed in Table 2-6, Other Agency Approvals and Requirements.

TABLE 2-6

OTHER AGENCY APPROVALS AND REQUIREMENTS
Agency Approval Required
Los Angeles County Metropolitan Transportation Authority (Metro) Construction within 100 feet of Metro light rail Los Angeles Regional Water Quality Control Board Construction General Permit South Coast Air Quality Management District Permit for Operation of Diesel Backup Generator Affinity Project Draft EIR
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2.8 REFERENCES
Pasadena, City of. 2021a (December 6, last updated). Development Cap Tracking WorksheetSummary. Pasadena, City of. GP DEV CAP WORKSHEET Nov2021.xlsx (cityofpasadena.net).https://www.cityofpasadena.net/wp-content/uploads/sites/30/LandUse-Element-2016-01-25.pdf?v=1626398951978 Pasadena, City of. 2021b (November 30, last updated). Development Cap Tracking WorksheetDetails. Pasadena, City of. GP DEV CAP WORKSHEET Nov2021.xlsx (cityofpasadena.net).
———. 2015 (August). Pasadena General Plan. Pasadena, CA: the City. General Plan - Planning & Community Development Department (cityofpasadena.net). ———. 2004 (November 8, adopted). Central District Specific Plan. Pasadena, CA: the City.

Central District - Planning & Community Development Department (cityofpasadena.net).

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3-1 Environmental Analysis
SECTION 3.0 ENVIRONMENTAL ANALYSIS
In accordance with Sections 15125 and 15126(a) to (c) of the California Environmental Quality Act (CEQA) Guidelines, this section of the Draft EIR analyzes those environmental topics where the Project could result in “potentially significant impacts”, as identified in the IS/NOP included in Appendix A-1 and based on comments received during the scoping period. The City identified the following topics as requiring detailed EIR analysis:
• Air Quality (Section 3.1),
• Cultural and Paleontological Resources (Section 3.2), • Energy (Section 3.3),
• Greenhouse Gas Emissions (Section 3.4),
• Hazards and Hazardous Materials (Section 3.5),
• Land Use and Planning (Section 3.6),
• Noise (Section 3.7),
• Public Services and Recreation (Section 3.8),
• Transportation (Section 3.9),
• Tribal Cultural Resources (Section 3.10), and
• Utilities and Service Systems (Section 3.11).

Each topical section includes the information presented in the format described below.

As discussed in Section 1.0, Introduction, the City determined there would be no impacts or less than significant impacts to the following environmental topics:
• Aesthetics,
• Agricultural and Forestry Resources,
• Biological Resources,
• Geology and Soils,
• Hydrology and Water Quality,
• Mineral Resources,
• Population and Housing, and
• Wildfire.

Therefore, these topics do not require, and this Draft EIR will not set forth, any further analysis of these topics.

Where a potentially significant environmental effect has been identified and is not reduced to a level considered less than significant, including after incorporation of applicable regulations that are necessary independent of the CEQA process, Project-specific mitigation measures have been identified, consistent with Section 15126.4 of the State CEQA Guidelines. Any mitigation measure, and timing thereof, is subject to the approval of the City. Section 15126.4(a) of the State CEQA Guidelines requires lead agencies to consider feasible mitigation measures to avoid or substantially reduce a project’s significant environmental impacts. If determined necessary in the future, the City may substitute, at its discretion, any mitigation measure (and timing thereof) that has (1) the same or superior result as the original mitigation measure and (2) the same or superior effect on the environment (Section 21080(f) of CEQA).

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Environmental Analysis Format
To facilitate the analysis of each topic presented in Section 3.0, a standard format was developed.

This format is presented below, with a brief discussion of the information included within each heading.

Existing Conditions
This section describes the existing environmental conditions related to each topic analyzed. In accordance with Section 15125 of the State CEQA Guidelines, the existing local and regional setting is discussed as they existed when the IS/NOP was circulated from August 5, 2021, through September 3, 2021, unless otherwise noted. This section provides the baseline conditions with which environmental changes associated with the Project and Project with Building A Residential/Commercial would be compared and analyzed.

Relevant Programs and Regulations
This section includes a summary of the existing federal, State, regional, County, and/or local laws, regulations, and ordinances that directly relate to the environmental topic being analyzed. These are summarized to provide background information and to establish the regulatory setting under which the construction and operation of the Project or Project with Building A Residential/Commercial would occur.

Thresholds of Significance
Section 15126.2 of the State CEQA Guidelines requires an EIR to “identify and focus on the significant environmental effects of the proposed project”. “Effects” and “impacts” mean the same under CEQA and are used interchangeably in this EIR. A “significant effect” or “significant impact” on the environment is “a substantial, or potentially substantial, adverse change in any of the physical conditions within the area affected by the project” (Section 15382 of the State CEQA Guidelines).

In determining whether an impact is “significant”, Section 15064.7 of the State CEQA Guidelines encourages each public agency to develop and publish thresholds of significance to use in determining the significance of an environmental impact. These thresholds may consist of identifiable quantitative, qualitative, or performance-level criteria used to determine non-compliance or compliance. Non-compliance means the effect would be significant, and compliance with the thresholds means the effect normally would be less than significant.

Like most municipalities, the City of Pasadena has not adopted thresholds of significance for every resource area but has adopted local thresholds for areas such as traffic. Nonetheless, a majority of the significance criteria used in the analysis in Section 3.0 of this EIR are derived from Appendix G of the State CEQA Guidelines. In addition, City policies and standards (such as the City’s noise ordinance), as well as thresholds adopted by other public agencies with jurisdiction over select issues, are used as thresholds of significance, where applicable. For example, the South Coast Air Quality Management District publishes numerical thresholds for criteria pollutant emissions. Also, accepted technical and scientific data are used in some instances to determine if an impact would be considered significant. These thresholds are identified under each environmental topic and have been used in analyzing the potential impacts of the Project and Project with Building A Residential/Commercial.

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Methodology
This section describes the methods that were used in the process of analyzing impacts related to the implementation of the Project and Project with Building A Residential/Commercial in relation to the thresholds of significance for that environmental topic.

Environmental Impacts
The analysis of environmental impacts presented in this Draft EIR identifies direct and indirect, as well as short-term and long-term, environmental impacts of the Project and the comparative impacts of the Project with Building A Residential/Commercial. The thresholds of significance (discussed above) provide the basis for distinguishing between impacts that are determined to be significant (i.e., impact exceeds the threshold of significance) and those that are considered less than significant. The analysis is structured to address each threshold, while considering any residual impact after compliance with any applicable regulations pertinent to that topic. If there would be a significant environmental impact after regulatory compliance, feasible mitigation measure(s) are developed to reduce or avoid the identified impact.

Where the impact analysis demonstrates that a potential environmental effect is too speculative or subjective for evaluation, or that the effect is beneficial, that conclusion is noted. Where the impact analysis demonstrates that a potential environmental effect could have a substantial or potentially substantial and adverse impact on existing physical conditions within the City, that conclusion is noted and followed by a discussion of how the proposed mitigation would address the potential impact.

Cumulative Impacts
While the extent of environmental changes that would occur with individual projects that are proposed, planned, or under construction in the City or region may not be significant, the sum of the impacts of these cumulative projects and the Project or Project with Building A Residential/Commercial may be cumulatively considerable, as defined in Section 15065(c) of the State CEQA Guidelines. Section 2.6, Approach to Cumulative Impact Analysis, of this EIR contains a discussion of the overall methodology to determine the scope of projects and/or regional growth considered in the cumulative impact analysis. A discussion of the anticipated environmental changes resulting from the cumulative projects and the proposed development on a cumulative level, are addressed in each topical analysis presented in Section 3.0 of this Draft EIR, which contains a more detailed discussion of the cumulative impact analysis methodology for each environmental topic.

Mitigation Measures
The mitigation measures (MMs) for each topic have been developed, when necessary, to reduce or avoid significant adverse environmental impacts after incorporation of relevant regulations.

Level of Significance After Mitigation
This section identifies the level of significance of the identified impacts after implementation of the required mitigation measures, where applicable. Significant and unavoidable impacts are those adverse effects that either cannot be mitigated or that remain significant even after mitigation.

References
Documents and other sources that have been used in the preparation of each topical analysis are identified in this section.

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Summary of Analysis
This section presents an overview of the topical analysis for the Project and Project with Building A Residential/Commercial, including identification of any MMs and level of significance after mitigation.

Affinity Project Draft EIR

3.1-1 Air Quality

3.1 AIR QUALITY

3.1.1 EXISTING CONDITIONS
Climate and Meteorology
The Project site is located in the Los Angeles County portion of the South Coast Air Basin (SoCAB). The SoCAB is a 6,600-square-mile area bound by the Pacific Ocean to the west, the San Gabriel, San Bernardino, and San Jacinto Mountains to the north and east, and the San Diego County line to the south. The SoCAB includes all of Orange County and the non-desert portions of Los Angeles, Riverside, and San Bernardino Counties, in addition to the San Gorgonio Pass area of Riverside County.

The SoCAB’s terrain and geographical location (i.e., a coastal plain with connecting broad valleys and low hills) determine its distinctive semi-arid climate, which is characterized by moderate temperatures, oceanic influences, and precipitation during winter (November through April).

According to the 2016 South Coast Air Quality Management District’s (SCAQMD’s) Air Quality Management Plan (AQMP), the SoCAB’s air pollution problems are a consequence of the combination of emissions from the nation’s second largest urban area, meteorological conditions adverse to the dispersion of those emissions, and mountainous terrain surrounding the Basin that traps pollutants as they are pushed inland with the sea breeze. The average wind speed for Los Angeles is the lowest of the nation’s 10 largest urban areas. In addition, the summertime daily maximum mixing heights1 in Southern California are the lowest, on average, due to strong temperature inversions in the lower atmosphere that effectively trap pollutants near the surface.

Southern California also has abundant sunshine, which drives the photochemical reactions that form pollutants such as ozone (O3) and a significant portion of fine particulate mass, equal to or smaller than 2.5 microns in size (PM2.5).

With very light average wind speeds, the basin atmosphere has a limited capability to disperse air contaminants horizontally. The dominant daily wind pattern is a daytime sea breeze (onshore breeze) and a nighttime land breeze (offshore breeze), broken only occasionally by winter storms and infrequent strong Santa Ana winds from the Great Basin, Mojave, and deserts to the north.

The vertical dispersion of air pollutants in the SoCAB is hampered by the presence of a temperature inversion in the layers of the atmosphere near the surface of the Earth. In a normal situation, as temperatures decrease with altitude, air continues to rise as it remains warmer than the surrounding air. With an inversion layer, air cannot continue to expand upwards, as it is trapped by the warmer air above.

Criteria Air Pollutants
Air quality is defined by ambient air concentrations of seven criteria air pollutants, which are a group of common air pollutants identified by the U.S. Environmental Protection Agency (USEPA) to be of concern with respect to the health and welfare of the general public. Federal and State governments regulate criteria pollutants by using ambient standards based on criteria regarding the health and/or environmental effects of each pollutant. These pollutants include nitrogen dioxide (NO2); ozone (O3); particulate matter, including both particles equal to or smaller than 10 microns in size (PM10) and particles equal to or smaller than 2.5 microns in size (PM2.5); carbon monoxide (CO); sulfur dioxide (SO2); and lead. Particulate matter size refers to the aerodynamic 1 The maximum mixing height is an index of how well pollutants can be dispersed vertically in the atmosphere.

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diameter of the particle. A description of each criteria pollutant, including source types and health effects, is provided below.

Nitrogen Dioxide
Nitrogen gas, normally relatively inert (i.e., nonreactive), comprises about 80 percent of the air.

At high temperatures (e.g., in combustion processes) and under certain other conditions, nitrogen can combine with oxygen to form several different gaseous compounds collectively called nitrogen oxides (NOx). Nitric oxide (NO), NO2, and nitrous oxide (N2O) are important constituents of NOx. NO is converted to NO2 in the atmosphere. Motor vehicle emissions are the main source of NOx in urban areas.

NO2 is a red-brown pungent gas and is toxic to various animals and to humans because of its ability to form nitric acid with water in the eyes, lungs, mucus membranes, and skin. In animals, long-term exposure to NOx increases susceptibility to respiratory infections, lowering resistance to such diseases as pneumonia and influenza. Laboratory studies show that susceptible humans, such as asthmatics, who are exposed to high concentrations of NO2 can suffer lung irritation and, potentially, lung damage. Epidemiological studies have also shown associations between NO2 concentrations and daily mortality from respiratory and cardiovascular causes, and with hospital admissions for respiratory conditions.

While the National Ambient Air Quality Standards (NAAQS) only address NO2, NO and NO2 are both precursors in the formation of O3 and PM2.5, as discussed below. Because of this and the fact that NO emissions largely convert to NO2, NOx emissions are typically examined when assessing potential air quality impacts.

Ozone
Ozone is a secondary pollutant, meaning that it is not directly emitted. It is a gas that is formed when volatile organic compounds (VOCs) (also referred to as reactive organic gases) and NOx undergo photochemical reactions that occur only in the presence of sunlight. The primary source of VOC emissions is unburned hydrocarbons in motor vehicle and other internal combustion engine exhaust. NOx also form as a result of the combustion process, most notably due to the operation of motor vehicles. Sunlight and hot weather cause ground-level O3 to form; as a result, ozone is known as a summertime air pollutant. Ground-level O3 is not to be confused with atmospheric O3 or the “ozone layer”, which occurs very high in the atmosphere and shields the planet from some ultraviolet rays. Ground-level O3 is the primary constituent of smog. Because O3 formation occurs over extended periods of time, both O3 and its precursors are transported by wind, and high O3 concentrations can occur in areas well away from sources of its constituent pollutants.

People with lung disease, children, older adults, and people who are active can be affected when ozone levels exceed ambient air quality standards. Numerous scientific studies have linked ground-level ozone exposure to a variety of problems, including the following:
• lung irritation that can cause inflammation much like a sunburn; • wheezing, coughing, pain when taking a deep breath, and breathing difficulties during exercise or outdoor activities;
• permanent lung damage to those with repeated exposure to ozone pollution; and • aggravated asthma, reduced lung capacity, and increased susceptibility to respiratory illnesses like pneumonia and bronchitis.

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Particulate Matter
Particulate matter includes both aerosols and solid particles of a wide range of size and composition. Of particular concern are PM10 and PM2.5. Particulate matter tends to occur primarily in the form of fugitive dust. This dust appears to be generated by both local sources and by region-wide dust during moderate to high wind episodes. These regional episodes tend to be multi-district and sometimes interstate in scope. The principal sources of dust in urban areas are from grading, construction, disturbed areas of soil, and dust entrained by vehicles on roadways.

PM10 is generally emitted directly as a result of mechanical processes that crush or grind larger particles or from the re-suspension of dusts, most typically through construction activities and vehicular travels. PM10 generally settles out of the atmosphere rapidly and is not readily transported over large distances.

PM2.5 is directly emitted in combustion exhaust and is formed in atmospheric reactions between various gaseous pollutants including NOx, sulfur oxides (SOx), and VOCs. PM2.5 can remain suspended in the atmosphere for days and/or weeks and can be transported long distances, as many as several hundred miles.

The principal health effects of airborne particulate matter are on the respiratory system.

Short-term exposure, lasting several days or weeks, to high PM2.5 and PM10 levels is associated with premature mortality and increased hospital admissions and emergency room visits; increased respiratory symptoms are also associated with short-term exposure to high PM10 levels. Long-term exposure, lasting years to decades, to high PM2.5 levels is associated with premature mortality and development of chronic respiratory disease. According to the USEPA, some people are much more sensitive than others to breathing PM10 and PM2.5. People with influenza, chronic respiratory and cardiovascular diseases, and the elderly may suffer worse illnesses; people with bronchitis can expect aggravated symptoms; and children may experience decline in lung function due to breathing in PM10 and PM2.5. Other groups considered sensitive include smokers and people who cannot breathe well through their noses. Exercising athletes are also considered sensitive because many breathe through their mouths.

Carbon Monoxide
Carbon monoxide is a colorless and odorless gas which, in the urban environment, is associated primarily with the incomplete combustion of fossil fuels in motor vehicles. CO combines with hemoglobin in the bloodstream and reduces the amount of oxygen that can be circulated through the body. High CO concentrations can cause headaches; aggravate cardiovascular disease; and impair central nervous system functions.

CO concentrations can vary greatly over comparatively short distances. Relatively high concentrations are typically found near crowded intersections; along heavily used roadways carrying slow-moving traffic; and at or near ground level. Even under the most severe meteorological and traffic conditions, high concentrations of CO are limited to locations within a relatively short distance (i.e., up to 600 feet or 185 meters) of heavily traveled roadways.

Sulfur Dioxide
Sulfur oxides (SOx) constitute a class of compounds of which SO2 and sulfur trioxide (SO3) are of greatest importance. Ninety-five percent of pollution-related SOx emissions are in the form of SO2.

SOx emissions are typically examined when assessing potential air quality impacts of SO2. The primary contributor of SOx emissions is fossil fuel combustion for generating electric power.

Industrial processes, such as nonferrous metal smelting, also contribute to SOx emissions. SOx Affinity Project Draft EIR

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is also formed during combustion of motor fuels; however, most of the sulfur has been removed from fuels, greatly reducing SOx emissions from vehicles.

SO2 combines easily with water vapor, forming aerosols of sulfurous acid (H2SO3), a colorless, mildly corrosive liquid. This liquid may then combine with oxygen in the air, forming the even more irritating and corrosive sulfuric acid (H2SO4). Peak levels of SO2 in the air can cause temporary breathing difficulty for people with asthma who are active outdoors. Longer-term exposures, lasting years to decades, to high levels of SO2 gas and particles cause respiratory illness and aggravate existing heart disease. SO2 reacts with other chemicals in the air to form tiny sulfate particles which are measured as PM2.5.

Lead
Lead is a stable compound, which persists and accumulates both in the environment and in animals. In humans, it affects the body’s blood-forming (or hematopoietic), nervous, and renal systems. In addition, lead has been shown to affect the normal functions of the reproductive, endocrine, hepatic, cardiovascular, immunological and gastrointestinal systems, although there is significant individual variability in response to lead exposure. In general, an analysis of lead is limited to projects that emit significant quantities of the pollutant (i.e., lead smelters) and are not applied to residential projects.

Toxic Air Contaminants
Toxic air contaminants (TACs) are a diverse group of air pollutants that may cause or contribute to an increase in deaths or in serious illness, or that may pose a present or potential hazard to human health. TACs may be emitted from a variety of common sources, including motor vehicles, gasoline stations, dry cleaners, industrial operations, painting operations, and research and teaching facilities. The USEPA uses the term “hazardous air pollutants” for TACs.

TACs are different than the criteria pollutants previously discussed in that ambient air quality standards have not been established for them. TACs occurring at extremely low concentrations may still cause health effects, and it is typically difficult to identify levels of exposure that do not produce adverse health effects. TAC impacts are described by carcinogenic (i.e., cancer) risk, chronic (i.e., of long duration) and acute (i.e., severe but of short duration) adverse effects on human health. Diesel particulate matter (DPM) is a TAC and is responsible for the majority of California’s known cancer risk from outdoor air pollutants.

Existing Regional Air Quality
The nearest air quality monitoring to the Project site is the Pasadena-South Wilson Avenue monitoring station located approximately 1.2 miles southeast of the Project site. Pollutants measured at this monitoring station include O3, PM2.5, and NO2. Monitoring data from the years 2017-2019 are shown in Table 3.1-1, Air Quality Monitoring Data from the Pasadena-South Wilson Avenue Monitoring Station. Federal and State air quality standards are presented with the number of times those each of those standards were exceeded.

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TABLE 3.1-1

AIR QUALITY MONITORING DATA FROM

THE PASADENA-SOUTH WILSON AVENUE MONITORING STATION
Pollutant
California
Standard
National
Standard Year Max. Levela
State
Standard
Days Exceededb
National
Standard
Days Exceededb, c
O3
(1 hour) 0.09 ppm None
2018 0.112 8 NA
2019 0.120 11 NA
2020 0.163 41 NA
O3
(8 hour) 0.070 ppm 0.070 ppm
2018 0.091 20 19
2019 0.098 29 24
2020 0.116 61 60
NO2
(1 Hour) 0.18 ppm 0.100 ppm
2018 0.068 0 0
2019 0.059 0 0
2020 0.061 0 0
NO2
(AAM) 0.030 ppb 0.053 ppb
2018 0.014 No No
2019 0.013 No No
2020 0.013 No No
PM2.5
(24 Hour) None 35 µg/m3
2018 32.5 N/A 0/0
2019 41.8 N/A 1/3.1
2020 67.7 N/A 2/6.1
PM2.5
(AAM) 12 µg/m3 15 µg/m3
2018 10.3 No No
2019 8.7 No No
2020 11.9 No No
O3: ozone; ppm: parts per million; µg/m3: micrograms per cubic meter; AAM: annual arithmetic mean; NO2: nitrogen dioxide. “–” indicates that the data are not reported or there is insufficient data available to determine the value. N/A indicates that there is no applicable standard.

State and national data may differ because of differing methods for selecting hours for averaging. a California maximum levels were used. b
For annual averaging times, a “Yes” or “No” response is given if the annual average concentration exceeded the applicable standard. c
PM is measured once every 6 days. Where 2 values are shown for PM2.5, the first is for the measured value, and the second is the estimated number of days.

Source: CARB 2021
When a region has air quality that fails to meet the standards, the USEPA and the California Air Resources Board (CARB) designate the region as “nonattainment” and the regional air quality agency must develop plans to attain the standards. These attainment designations are shown in Table 3.1-2, Attainment Status of Criteria Pollutants in the South Coast Air Basin. As identified in Table 3.1-2, all of Los Angeles County is designated as a nonattainment area for O3, PM10, and PM2.5; portions of Los Angeles County, not including the Project site are designated nonattainment for NO2 and lead.

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TABLE 3.1-2

ATTAINMENT STATUS OF CRITERIA POLLUTANTS

IN THE SOUTH COAST AIR BASIN
Pollutant State Federal
O3 (1 hour) Nonattainment No standards
O3 (8 hour) Nonattainment Nonattainment
PM10 Nonattainment Attainment/Maintenance
PM2.5 Nonattainment Serious Nonattainment
CO Attainment Attainment/Maintenance
NO2 Attainment/Nonattainmentb Attainment/Maintenance
SO2 Attainment Attainment
Lead Attainment Nonattainment/Attainmenta
All others Attainment/Unclassifiedc No standards
O3: ozone; PM10: respirable particulate matter 10 microns or less in diameter; PM2.5: fine particulate matter 2.5 microns or less in diameter; CO: carbon monoxide; NO2: nitrogen dioxide; SO2: sulfur dioxide; SoCAB: South Coast Air Basin.
a
Los Angeles County is classified nonattainment for lead; the remainder of the SoCAB is in attainment of the State and federal standards.
b
The near-road portion of CA-60 in San Bernardino, Riverside, and Los Angeles Counties is classified as nonattainment for NO2; the remainder of the SoCAB is in attainment of State standards. c
“Unclassified” designation indicates that the air quality data for the area are incomplete and do not support a designation of attainment or nonattainment.

Source: CARB 2021b, USEPA 2021a
Existing Project Site Emissions
Pollutants are emitted from current operations at the Project site. Existing emissions were calculated for the businesses that would be removed from the site (i.e., 491/495, 499/503, 541, and 577 South Arroyo Parkway) and replaced by new uses associated with the Project or Project with Building A Residential/Commercial. In other words, the existing emissions in Table 3.1-3 do not include emissions from the buildings to be retained with implementation of the Project (i.e., 465, 501, and 523 South Arroyo Parkway). Existing vehicle trip data, an estimated 2,454 daily trips, are derived from the Transportation Impact Analysis – Outside of CEQA Analysis prepared for the Project (Pasadena DOT 2021a). The results of the analysis are shown in Table 3.1-3, Peak Daily Existing Emissions, on the following page.

Sensitive Air Quality Receptors
Sensitive receptors include, but are not limited to children, the elderly, persons with preexisting respiratory or cardiovascular illness, and athletes and others who engage in frequent exercise.

Therefore, sensitive receptors land uses include, but are not limited to schools, parks, hospitals, residences, and convalescent homes. The nearest sensitive air quality receptors to the Project site are residences in a mixed-use, multi-story building at 482 South Arroyo Parkway, on the opposite side of the street approximately 100 feet from the Project site.

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TABLE 3.1-3

PEAK DAILY EXISTING EMISSIONS
Source
Emissions (lbs/day)*
VOC NOx CO SOx PM10 PM2.5
Area sources 1 <1 <1 <1 <1 <1
Energy sources <1 1 1 <1 <1 <1
Mobile sources 5 2 33 <1 6 2
Total Existing Operational Emissions** 6 3 34 <1 6 2
lbs/day: pounds per day; VOC: volatile organic compound; NOx: nitrogen oxides; CO: carbon monoxide; SOx: sulfur oxides; PM10: respirable particulate matter 10 microns or less in diameter; PM2.5: fine particulate matter 2.5 microns or less in diameter; SCAQMD: South Coast Air Quality Management District.

Totals may not add due to rounding.
* Existing emissions were quantified for uses to be demolished, and not for uses to be retained with implementation of the Project or Project with Building A Residential/Commercial. This provides a more conservative analysis of air quality and greenhouse gas emissions, as less emissions would be deducted from the proposed Project’s emissions, as shown further below in Table 3.1-8, Net Operational Emissions for the Project and Table 3.1-12, Net Operational Emissions for the Project with Building A Residential/Commercial.
** Values are the higher of summer or winter.

See Appendix B, Air Quality and Greenhouse Gas Emissions Modeling Data, for CalEEMod model outputs.

3.1.2 RELEVANT PROGRAMS AND REGULATIONS
Federal
The USEPA defines seven “criteria” air pollutants, as described below. These pollutants are called criteria pollutants because the USEPA has established National Ambient Air Quality Standards (NAAQS) for the concentrations of these pollutants (USEPA 2021b). The CARB has also established standards for the criteria pollutants, known as California Ambient Air Quality Standards (CAAQS), and the State standards are generally more restrictive than the NAAQS.

The NAAQS and CAAQS are shown in Table 3.1-4, California and Federal Ambient Air Quality Standards, on the following page.

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TABLE 3.1-4

CALIFORNIA AND FEDERAL AMBIENT AIR QUALITY STANDARDS
Pollutant Averaging Time
California
Standards
Federal Standards
Primarya Secondaryb
O3
1 Hour 0.09 ppm (180 µg/m3) – –
8 Hour 0.070 ppm (137
µg/m3) 0.070 ppm (137 µg/m3) Same as Primary
PM10 24 Hour 50 µg/m3 150 µg/m3 Same as Primary
AAM 20 µg/m3 – Same as Primary
PM2.5 24 Hour – 35 µg/m3 Same as Primary
AAM 12 µg/m3 12.0 µg/m3 15.0 µg/m3
CO
1 Hour 20 ppm (23 mg/m3) 35 ppm (40 mg/m3) –
8 Hour 9.0 ppm (10 mg/m3) 9 ppm (10 mg/m3) –
8 Hour
(Lake Tahoe) 6 ppm (7 mg/m3) – –
NO2
AAM 0.030 ppm (57 µg/m3) 0.053 ppm (100 µg/m3) Same as Primary 1 Hour 0.18 ppm (339 µg/m3) 0.100 ppm (188 µg/m3) –
SO2
24 Hour 0.04 ppm (105 µg/m3) – –
3 Hour – – 0.5 ppm
(1,300 µg/m3)
1 Hour 0.25 ppm (655 µg/m3) 0.075 ppm (196 µg/m3) –
Lead
30-day Avg. 1.5 µg/m3 – –
Calendar Quarter – 1.5 µg/m3
Same as Primary Rolling 3-month Avg. – 0.15 µg/m3
Visibility
Reducing
Particles
8 Hour
Extinction coefficient
of 0.23 per km –
visibility ≥ 10 miles
(0.07 per km – ≥30
miles for Lake Tahoe) No
Federal
Standards Sulfates 24 Hour 25 µg/m3
Hydrogen
Sulfide 1 Hour 0.03 ppm (42 µg/m3)
Vinyl
Chloride 24 Hour 0.01 ppm (26 µg/m3)
O3: ozone; ppm: parts per million; µg/m3: micrograms per cubic meter; PM10: respirable particulate matter 10 microns or less in diameter; AAM: Annual Arithmetic Mean; –: No Standard; PM2.5: fine particulate matter 2.5 microns or less in diameter; CO: carbon monoxide; mg/m3
: milligrams per cubic meter; NO2: nitrogen dioxide; SO2: sulfur dioxide; km: kilometer. a
National Primary Standards: The levels of air quality necessary, within an adequate margin of safety, to protect the public health. b National Secondary Standards: The levels of air quality necessary to protect the public welfare from any known or anticipated adverse effects of a pollutant.

Note: More detailed information in the data presented in this table can be found at the CARB website (www.arb.ca.gov).

Source: USEPA 2021b, CARB 2016
State
CARB, a part of the California Environmental Protection Agency (CalEPA), is responsible for coordinating and administering both the federal and State air pollution control programs in California. In this capacity, CARB conducts research, sets the CAAQS (as shown above in Table 3.1-4), compiles emission inventories, develops suggested control measures, oversees local programs, and prepares the State Implementation Plan (SIP) for California. For regions that Affinity Project Draft EIR

3.1-9 Air Quality
do not attain the CAAQS, CARB requires the air districts to prepare plans for attaining the standards. These plans are then integrated into the SIP. CARB establishes emissions standards for (1) motor vehicles sold in California, (2) consumer products (e.g., hair spray, aerosol paints, barbecue lighter fluid), and (3) various types of commercial equipment. It also sets fuel specifications to further reduce vehicular emissions.

Advanced Clean Cars
In January 2012, CARB approved the Advanced Clean Cars program, an emissions-control program for model years 2017 through 2025. The program combines the control of smog, soot, and GHG emissions with requirements for greater numbers of zero-emission vehicles. By 2025, when the rules will be fully implemented, 2025 model year automobiles will emit 75 percent fewer smog-forming emissions and 34 percent fewer global warming gases than the average 2012 model year automobile.

Title 24 Energy Efficiency Standards
The Energy Efficiency Standards for Residential and Nonresidential Buildings (Title 24, Part 6 of the California Code of Regulations) were established in 1978 in response to a legislative mandate to reduce California’s energy consumption. The current applicable standards are the 2019 Standards, effective January 1, 2020. The requirements of the energy efficiency standards result in the reduction of natural gas and electricity consumption. Since using natural gas produces criteria pollutant emissions, a reduction in natural gas consumption results in a related reduction in air quality emissions.2 Additional discussion of the Title 24 energy efficiency standards is included in Section 3.4, Greenhouse Gas Emissions. The 2019 standards require that there is sufficient onsite electricity generation to meet the annual electricity usage for low rise residential buildings. The 2022 Energy Efficiency Standards are being developed and would improve upon the 2019 Energy Code for new construction of, and additions and alterations to, residential and nonresidential buildings. Proposed standards would have an effective date of January 1, 2023.

The California Energy Commission (CEC) updates the standards every three years.

Title 24 Green Building Standards
The 2019 California Green Building Standards Code (Title 24, Part 6 of the California Code of Regulations), also known as the “CALGreen Code,” contains mandatory requirements and voluntary measures for new residential and nonresidential buildings (including buildings for retail uses, office uses, public schools, and hospitals) throughout California. Development of the CALGreen Code is intended to (1) cause a reduction in GHG emissions from buildings; (2) promote environmentally responsible, cost-effective, healthier places to live and work; (3) reduce energy and water consumption; and (4) respond to the directives by the Governor. In short, the CALGreen Code is established to reduce construction waste; make buildings more efficient in the use of materials and energy; and reduce environmental impact during and after construction.

The CALGreen Code provides standards for bicycle parking, carpool/vanpool/electric vehicle spaces, light and glare reduction, grading and paving, energy-efficient appliances, renewable energy, graywater systems, water efficient plumbing fixtures, recycling and recycled materials, pollutant controls (including moisture control and indoor air quality), acoustical controls, storm water management, building design, insulation, flooring, and framing, among others.

Implementation of the CALGreen Code measures reduces energy consumption and vehicle trips and encourages the use of alternative-fuel vehicles which, in turn, reduces pollutant emissions. 2 Because electricity is not generated on site, the emissions associated with electricity generation are not included in the emissions calculations.

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Regional
South Coast Air Quality Management District and Southern California Association of Governments
In the SoCAB, the South Coast Air Quality Management District (SCAQMD) is the agency responsible for protecting public health and welfare through the administration of federal and State air quality laws, regulations, and policies. Included in the SCAQMD’s tasks are the monitoring of air pollution; the preparation of the Air Quality Management Plan (AQMP) for the SoCAB; and the promulgation of rules and regulations.

In the Project area, SCAG is the federally designated Metropolitan Planning Organization and the State-designated transportation planning agency for six counties: Riverside, San Bernardino, Los Angeles, Ventura, Imperial, and Orange.

The SCAQMD and SCAG are jointly responsible for formulating and implementing the AQMP for the SoCAB. SCAG’s Regional Mobility Plan and Growth Management Plan form the basis for the land use and transportation control portion of the AQMP.

Air Quality Management Plans
The SCAQMD’s current air quality planning document is the 2016 Air Quality Management Plan (2016 AQMP). The SCAQMD adopted the 2016 AQMP on March 3, 2017 (SCAQMD 2021). The 2016 AQMP is a regional and multi-agency effort among the SCAQMD, CARB, SCAG, and USEPA. The SCAQMD is responsible for ensuring that the SoCAB meets the NAAQS and CAAQS by reducing emissions from stationary (area and point), mobile, and indirect sources. To accomplish this goal, the SCAQMD prepares AQMPs in conjunction with the SCAG, County transportation commissions, and local governments; develops rules and regulations; establishes permitting requirements for stationary sources; inspects emissions sources; and enforces such measures through educational programs or fines, when necessary.

The 2016 AQMP evaluates integrated strategies and measures to meet the following NAAQS (SCAQMD 2021):
• 8-hour O3 (75 parts per billion [ppb]) by 20323
• Annual PM2.5 (12 micrograms per cubic meter [µg/m3]) from 2021 to 2025 • 8-hour O3 (80 ppb) by 2024
• 1-hour O3 (120 ppb) by 2023
• 24-hour PM2.5 (35 µg/m3) by 2019
South Coast Air Quality Management District Rules
The proposed Project would be required to comply with existing SCAQMD rules for the reduction of fugitive dust and criteria pollutant emissions. The following rules are most relevant to the proposed Project:

SCAQMD Rule 201 requires a “Permit to Construct” prior to the installation of any equipment “the use of which may cause the issuance of air contaminants . . .” and Regulation II provides the 3 On October 1, 2015, the USEPA lowered the 8-hour O3 standard to 0.070 ppm (70 ppb). The SIP (or AQMP) for the 70 ppb standard will be due 4 years after the attainment/nonattainment designations are issued by the USEPA, which is expected in 2017. Thus, meeting the 70 ppb standard will be addressed in a 2021 AQMP.

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requirements for the application for a Permit to Construct. Rule 203 similarly requires a Permit to Operate. Rule 219, Equipment not Requiring a Written Permit Pursuant to Regulation II, identifies “equipment, processes, or operations that emit small amounts of contaminants that shall not require written permits . . .” This would apply to the diesel backup generators that are proposed for each new building.

SCAQMD Rule 402, Nuisance, states that a project shall not “discharge from any source whatsoever such quantities of air contaminants or other material which cause injury, detriment, nuisance, or annoyance to any considerable number of persons or to the public, or which endanger the comfort, repose, health or safety of any such persons or the public, or which cause, or have a natural tendency to cause, injury or damage to business or property.” SCAQMD Rule 403, Fugitive Dust, requires actions to prevent, reduce, or mitigate fugitive particulate matter emissions. These actions include applying water or chemical stabilizers to disturbed soils; managing haul road dust by applying water; covering all haul vehicles before transporting materials; restricting vehicle speeds on unpaved roads to 15 miles per hour (mph); and sweeping loose dirt from paved site access roadways used by construction vehicles. In addition, Rule 403 requires that vegetative ground cover be established on disturbance areas that are inactive within 30 days after active operations have ceased. Alternatively, an application of dust suppressants can be applied in sufficient quantity and frequency to maintain a stable surface.

Rule 403 also requires grading and excavation activities to cease when winds exceed 25 mph.

SCAQMD Rule 445 has been adopted to reduce the emissions of particulate matter from woodburning devices and prohibits the installation of such devices in any new development.

SCAQMD Rule 1113 governs the sale of architectural coatings and limits the VOC content in paints and paint solvents. Although this rule does not directly apply to the Project, it does dictate the VOC content of paints available for use during building construction.

SCAQMD Rule 1403, Asbestos Emissions from Demolition/Renovation Activities, specifies work practice requirements to limit asbestos emissions from building demolition and renovation activities, including the removal and associated disturbance of asbestos-containing materials (ACMs). All operators are required to maintain records, including waste shipment records, and are required to use appropriate warning labels, signs, and markings. Handling of ACMs is discussed in the Initial Study and Section 3.5, Hazards and Hazardous Materials, of this Draft EIR.

City
The Open Space and Conservation Element of the City of Pasadena’s General Plan states, “. . . while air quality is not a state-mandated element, air quality is included in the Open Space and Conservation Element to address reducing pollutant levels through stationary source, mobile source, transportation and land use control, and energy conservation measures” (Pasadena 2012). There are no policies in the Open Space and Conservation Element that are directly applicable to the Project air quality emissions or issues. The goals and policies, where referenced to air quality, are directed towards reduction of greenhouse gas (GHG) emissions and the sequestration of CO2. GHG emissions are discussed in Section 3.4, Greenhouse Gas Emissions, of this Draft EIR.

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3.1.3 THRESHOLDS OF SIGNIFICANCE
The following significance criteria are derived from Appendix G of the State CEQA Guidelines. A project would result in a significant adverse air quality impact if it would:

Threshold 3.1a: Conflict with or obstruct implementation of the applicable air quality plan; Threshold 3.1b: Result in a cumulatively considerable net increase of any criteria pollutant for which the Project region is in non-attainment under an applicable federal or state ambient air quality standard; and/or
Threshold 3.1c: Expose sensitive receptors to substantial pollutant concentrations.

Appendix G of the State CEQA Guidelines also states that the significance criteria established by the applicable air quality management district may be relied upon to make significance determinations. The SCAQMD has established significance thresholds to assess the regional and localized impacts of Project-related air pollutant emissions. Table 3.1-5, SCAQMD Air Quality Significance Thresholds, on the following page presents the significance thresholds applied to the Project.

The Initial Study (provided in Appendix A-1) concluded the following threshold related to air quality was determined to result in less than significant impacts and was not carried forward into the Draft EIR for further analysis:
• Would the project result in other emissions (such as those leading to odors) adversely affecting a substantial number of people?

3.1.4 METHODOLOGY
In June 2021, the SCAQMD in conjunction with the California Air Pollution Control Officers Association (CAPCOA) and other California air districts, released the latest version of the California Emissions Estimator Model™ (CalEEMod™), version 2020.4.0 (CAPCOA 2021). The purpose of this model is to calculate construction-source and operational-source pollutants (NOx, VOC, PM10, PM2.5, SOx, and CO) and GHG emissions from direct and indirect sources; and quantify applicable air quality and GHG reductions achieved from mitigation measures.

CalEEMod version 2020.4.0 was used to estimate the criteria air pollutant emissions associated with the existing land uses to be removed and the proposed land uses for the Project and Project with Building A Residential/Commercial. The inputs and data for the modeling are described above for existing uses; below for proposed uses; and in Appendix B, Air Quality and Greenhouse Gas Emissions Modeling Data.

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TABLE 3.1-5

SCAQMD AIR QUALITY SIGNIFICANCE THRESHOLDS
Mass Daily Thresholdsa
Pollutant Construction Operation
NOx 100 lbs/day 55 lbs/day
VOC 75 lbs/day 55 lbs/day
PM10 150 lbs/day 150 lbs/day
PM2.5 55 lbs/day 55 lbs/day
SOx 150 lbs/day 150 lbs/day
CO 550 lbs/day 550 lbs/day
Lead 3 lbs/day 3 lbs/day
TACs, Odor, and GHG Thresholds
TACs
(including carcinogens and noncarcinogens)
Maximum Incremental Cancer Risk ≥ 10 in 1 million
Cancer Burden > 0.5 excess cancer cases (in areas ≥ 1 in 1 million) Chronic & Acute Hazard Index ≥ 1.0 (project increment)
Odor Project creates an odor nuisance pursuant to SCAQMD Rule 402 GHG 10,000 MT/yr CO2e for industrial facilities
Ambient Air Quality Standards for Criteria Pollutantsb, c NO2
1-hour average
annual arithmetic mean
The SCAQMD is in attainment; the Project is significant if it causes or contributes to an exceedance of the following attainment standards:

0.18 ppm (State)

0.03 ppm (State) and 0.0534 ppm (federal)
PM10
24-hour average
annual average

10.4 µg/m3 (construction)c & 2.5 µg/m3 (operation)

1.0 µg/m3
PM2.5
24-hour average 10.4 µg/m3 (construction)c & 2.5 µg/m3 (operation) SO2
1-hour average
24-hour average

0.25 ppm (State) & 0.075 ppm (federal – 99th percentile)

0.04 ppm (State)
Sulfate
24-hour average 25 µg/m3 (State)
CO
1-hour average
8-hour average
SCAQMD is in attainment; project is significant if it causes or contributes to an exceedance of the following attainment standards:

20.0 ppm (State) and 35 ppm (federal)

9.0 ppm (State/federal)
Lead
30-day average
Rolling 3-month average

1.5 µg/m3 (State)

0.15 µg/m3 (federal)
NOx: nitrogen oxides, lbs/day: pounds per day, VOC: volatile organic compound, PM10: respirable particulate matter with a diameter of 10 microns or less, PM2.5: fine particulate matter with a diameter of 2.5 microns or less, SOx: sulfur oxides, CO:
carbon monoxide, TACs: toxic air contaminants, GHG: greenhouse gases, MT/yr CO2e: metric tons per year of carbon dioxide equivalents, NO2: nitrogen dioxide, ppm: parts per million, µg/m3 : micrograms per cubic meter; SCAQMD: South Coast Air Quality Management District
a Source: SCAQMD CEQA Handbook (SCAQMD 1993) b Ambient air quality thresholds for criteria pollutants based on SCAQMD Rule 1303, Table A-2 unless otherwise stated c Ambient air quality threshold is based on SCAQMD Rule 403 Source: SCAQMD 2019
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3.1-14 Air Quality

3.1.5 ENVIRONMENTAL IMPACTS
Threshold 3.1a: Would the Project conflict with or obstruct implementation of the applicable air quality plan?
CEQA requires a discussion of any inconsistencies between a project and applicable General Plans (GPs) and regional plans (Section 15125 of the State CEQA Guidelines). The regional plan that applies to the Project and Project with Building A Residential/Commercial is the SCAQMD’s AQMP, discussed above in Section 3.1.2.

The SCAQMD CEQA Handbook states that “New or amended GP Elements (including land use zoning and density amendments), Specific Plans, and significant projects must be analyzed for consistency with the AQMP”. The SCAQMD CEQA Handbook identifies two key indicators of consistency:
(1) Whether the project will result in an increase in the frequency or severity of existing air quality violations or cause or contribute to new violations or delay timely attainment of air quality standards or the interim emission reductions specified in the AQMP. (2) Whether the project will exceed the assumptions in the AQMP or increments based on the year of project buildout and phase.

Both of these criteria are evaluated below for the Project and Project with Building A Residential/Commercial.

Project
First Criterion of AQMP Consistency
With respect to the first criterion, based on the air quality modeling conducted for the Project (see the discussion provided below under Thresholds 3.1b and 3.1c), construction and operation of the Project would not exceed the SCAQMD’s CEQA thresholds of significance and consequently would not result in an increase in the frequency or severity of existing air quality violations nor cause or contribute to new violations, or delay timely attainment of air quality standards or the interim emissions reductions in the AQMP. This is demonstrated in Tables 3.1-6 and 3.1-7, below.

Therefore, the Project is consistent with the first criterion.

Second Criterion of AQMP Consistency
With respect to the second criterion, the Project was assessed as to whether it would exceed the assumptions in the AQMP. The 2016 AQMP includes an analysis of emissions, meteorology, atmospheric chemistry, regional growth projections, and the impact of existing control measures.

The purpose of the 2016 AQMP is to set forth a comprehensive program that would promote reductions in criteria pollutants, greenhouse gases, and toxic risk and efficiencies in energy use, transportation, and goods movement. The 2016 AQMP incorporates the latest scientific and technical information and planning assumptions, including SCAG’s 2016-2040 Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS); updated emission inventory methods for various source categories; and SCAG’s latest growth forecasts.4 The 2016 AQMP includes strategies and measures necessary to meet the NAAQS. The AQMP is based on projections of energy usage and vehicle trips from land uses within the SoCAB. 4 It is noted that SCAG adopted the 2020-2045 RTP/SCS in September 2020 and that SCAQMD in the process of developing a 2022 AQMP.

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3.1-15 Air Quality
The Project site is within the CD-6 (Central District Specific Plan, Arroyo Corridor/Fair Oaks subdistrict) zoning district. This is discussed further in Section 2.0, Environmental Setting and Project Description, of this Draft EIR. As discussed in Section 2.0, High-Quality Transit Areas (HQTAs) are areas within one-half mile of a fixed guideway transit stop or a bus transit corridor where buses pick up passengers at a frequency of every 15 minutes or less during peak commuting hours. Transit Priority Areas (TPAs) are areas within one-half mile of a major transit stop that is existing or planned (SCAG 2020). The Project site is within both a HQTA and TPA.

Metro’s Gold Line runs adjacent to the western site boundary. The nearest light rail platforms are Del Mar Station located approximately ¼-mile due north and Fillmore Station located approximately ¼-mile due south. Additional public transit service present near the site includes the California Boulevard/Arroyo Parkway Metro bus stop located in the ROW on the southern site boundary, and the Bellevue Drive/Arroyo Parkway Metro bus stop located in the ROW at the northeast corner of the site. The proximity of the Project site to the station would encourage the use of mass transit which is consistent with the AQMP’s goal of using non-single occupancy vehicles. The Project would be a mixed-use development, providing a mix of medical, commercial, restaurant, and residential uses. The Project site is suitably located to encourage the use of public transit and active transportation modes for the residences, employees, and visitors to the Project site.

As discussed in Section 3.6, Land Use and Planning, of this Draft EIR, the Applicant seeks approval to rezone the site as a Planned Development (PD) district and approval of a PD Plan.

The City’s PD zone is a special purpose zoning district defined pursuant to Section 17.26.020(C) of the Pasadena Municipal Code. However, the Project uses would not exceed the development cap of 87 dwelling units per acre and 3.0 floor area ratio (FAR), and as such, would be consistent with the existing High Mixed-Use General Plan land use designation of the Project site. Because the General Plans of cities within the SoCAB are used to determine the regional emissions of the Basin, emissions related to the development of the Project site are therefore consistent with the growth expectations for the region. As such, the Project would not exceed the anticipated growth accounted for within the Land Use Element of the General Plan which helped formed the basis of the AQMP. In addition, the emissions generated by the Project are below the SCAQMD’s significance thresholds, as demonstrated below. As such, no conflict with the 2016 AQMP would occur with the Project. There would be a less than significant impact, and no mitigation is required.

Project with Building A Residential/Commercial
First Criterion of AQMP Consistency
The impact findings for the Project with Building A Residential/Commercial would not differ from the impact findings for the Project, regarding conflict with or obstruction of the applicable air quality management plan. As demonstrated for the Project, the Project with Building A Residential/Commercial would be consistent with the first criterion for consistency with the 2016 AQMP. The Project would also not result in an increase in the frequency or severity of existing air quality violations or cause or contribute to new violations or delay timely attainment of air quality standards or the interim emission reductions specified in the AQMP. This is demonstrated in Tables 3.1-10 and 3.1-12 presented further below in response to Threshold 3.1b, which show that the Project with Building A Residential/Commercial would result in criteria pollutant emissions that are less than the SCAQMD’s thresholds.

Second Criterion of AQMP Consistency
For the second criterion, the Project with Building A Residential/Commercial would also be located within a HQTA and TPA, and as such, encourages the use of mass transit, which is consistent with the AQMP’s goal of using non-single occupancy vehicles. In fact, the Project with Building A Residential/Commercial would locate more residential uses proximate to uses that would Affinity Project Draft EIR

3.1-16 Air Quality
encourage the use of mass transit which is consistent with the AQMP’s goal of using non-single occupancy vehicles. Additionally, the Project with Building A Residential/Commercial would not exceed the development cap of 87 dwelling units per acre or 3.0 FAR, and as such, would be also consistent with the High Mixed-Use General Plan land use designation of the Project.

Consequently, the Project with Building A Residential/Commercial would be consistent with the second criterion for consistent with an applicable AQMP. There would be a less than significant impact and no mitigation is required.

Threshold 3.1b: Would the Project result in a cumulatively considerable net increase of any criteria pollutant for which the Project region is in non-attainment under an applicable federal or state ambient air quality standard?
As shown above in Table 3.1-2, the Project site is in a nonattainment area for O3, PM10, and PM2.5. The Project and Project with Building A Residential/Commercial would generate PM10, PM2.5, and O3 precursors (NOx and VOC) during short-term construction and long-term operations, as discussed below.

Project
Construction Impacts
Construction-Related Regional Emissions
A project may have a significant impact where project-related emissions would exceed federal, State, or regional standards or thresholds, or where project-related emissions would substantially contribute to an existing or projected air quality violation. Conversely, a project with daily emission rates below the SCAQMD’s established air quality significance thresholds (shown in Table 3.1-5) would have a less than significant effect on regional air quality. Project emissions were estimated using CalEEMod version 2020.4.0 program, as described above.

Project construction is planned to occur from March 2023 to January 2026 with a six-day work week. The CalEEMod input for construction emissions was based on the Project’s construction assumptions and default assumptions derived from CalEEMod. Demolition would include an estimated 45,912 square feet (sf) of buildings and the export of approximately 300 14-cubic yard (cy) truckloads of debris. Grading for the subterranean garage and other areas for improvement would require the export of an estimated 184,013 cy of soil, requiring approximately 13,200 truckloads for export.

Table 3.1-6, Estimated Maximum Daily Construction Emissions, presents the estimated maximum daily emissions occurring both onsite and offsite during construction of the Project and compares the estimated emissions with the SCAQMD’s daily regional emission thresholds. As shown in Table 3.1-6, all pollutant emissions would be below the SCAQMD’s respective thresholds.

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3.1-17 Air Quality
TABLE 3.1-6

ESTIMATED MAXIMUM DAILY CONSTRUCTION EMISSIONS

FOR THE PROJECT
Year
Emissions (lbs/day)
VOC NOx CO SOx PM10 PM2.5
2023 6 42 57 <1 4 2
2024 5 39 57 <1 3 2
2025 52 37 56 <1 3 2
2026 52 5 8 <1 1 <1
Maximum Emissions 52 42 57 <1 4 2
SCAQMD Thresholds (Table 3.1-5) 75 100 550 150 150 55
Exceeds SCAQMD Thresholds? No No No No No No
lbs/day: pounds per day; VOC: volatile organic compound; NOx: nitrogen oxides; CO: carbon monoxide; SOx: sulfur oxides; PM10:
respirable particulate matter 10 microns or less in diameter; PM2.5: fine particulate matter 2.5 microns or less in diameter; SCAQMD: South Coast Air Quality Management District.

Values are higher of summer or winter.

Source: SCAQMD 2019 (thresholds); see Appendix B, Air Quality and Greenhouse Gas Emissions Modeling Data, for CalEEMod model outputs.

Construction-Related Localized Emissions
In addition to the mass daily emissions thresholds established by the SCAQMD, short-term local impacts to nearby sensitive receptors from on-site emissions of NO2, CO, PM10, and PM2.5 are examined based on SCAQMD’s localized significance threshold (LST) methodology. To assess local air quality impacts for development projects without complex dispersion modeling, the SCAQMD developed screening (lookup) tables to assist lead agencies in evaluating impacts.

The LST method is limited to projects that are five acres or less. For the purposes of an LST analysis, the SCAQMD considers receptors where it is possible that an individual could remain for 1 hour for NO2 and CO exposure and 24 hours for PM10 and PM2.5 exposure. The emissions screening thresholds in the lookup tables are based on the SCAQMD’s Air Quality Significance Thresholds and CARB’s 1-hour NO2 AAQS (SCAQMD 2008). The nearest off-site receptors that could be exposed for 1 hour to NO2 and CO during construction would be the commercial uses west of the site beyond the light rail tracks, approximately 40 feet from the Project’s western boundary. The nearest sensitive air quality receptors that could be exposed to PM10 and PM2.5 for 24 hours are residences in a multi-story building at 482 South Arroyo Parkway, approximately 100 feet from the Project site.

The screening thresholds are for receptors within 25 meters (82 feet) of the Project site to account for non-sensitive receptors located closer than the nearest sensitive receptor. The screening thresholds for receptors farther away would be higher and the Project emissions would be a smaller fraction of the screening thresholds. Table 3.1-7, Localized Construction Emissions for the Project, shows the maximum daily on-site emissions for construction activities compared with the SCAQMD LST screening thresholds. It is noted that this LST analysis is conservative because the nearest sensitive receptor for PM10 and PM2.5 is approximately 30 meters (100 feet) away.

The Project’s maximum daily on-site emissions would occur during the building construction phase in 2023. As shown in Table 3.1-7, Localized Construction Emissions for the Project, the local emissions from the Project would be below the LST screening thresholds. There would be a less than significant impact, and no mitigation is required.

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3.1-18 Air Quality
TABLE 3.1-7

LOCALIZED CONSTRUCTION EMISSIONS FOR THE PROJECT
Emissions and Thresholds
Emissions (lbs/day)
NOx CO PM10 PM2.5
Project maximum daily on-site emissions 41 52 2 2
SCAQMD LST Screening Thresholda 69 535 4 3
Exceed threshold? No No No No
lbs/day: pounds per day; NOx: nitrogen oxides; CO: carbon monoxide; PM10: respirable particulate matter 10 microns or less in diameter; PM2.5: fine particulate matter 2.5 microns or less in diameter; LST: localized significance threshold. a
Data is for SCAQMD Source Receptor Area 8, West San Gabriel Valley.

Source: SCAQMD 2009 (thresholds); see Appendix B, Air Quality and Greenhouse Gas Emissions Modeling Data, for CalEEMod outputs.

Cumulative Construction Emissions
Construction activities associated with the Project would result in less than significant construction-related regional and localized air quality impacts, as quantified above in Tables 3.1-6 and 3.1-7, respectively. Short-term cumulative impacts related to air quality could occur if construction of the Project and other projects in the surrounding area were to occur simultaneously. In particular, with respect to local impacts, the consideration of cumulative construction particulate matter (i.e., PM10 and PM2.5) impacts is limited to cases when projects constructed simultaneously are within a few hundred yards of each other because of: (1) the combination of the short range (distance) of particulate dispersion (especially when compared to gaseous pollutants), and (2) the SCAQMD’s required dust-control measures, which further limit particulate dispersion from the Project site. As of the preparation of this Draft EIR, there are no known nearby projects that would be concurrently under construction.

SCAQMD’s policy with respect to cumulative impacts associated with the above-referenced pollutants and their precursors is that impacts that would be directly less than significant on a project level would also be cumulatively less than significant (SCAQMD 2003a). Because the Project’s construction emissions are below the SCAQMD’s regional and local significance thresholds, local construction emissions would not be cumulatively considerable. There would be a less than significant impact, and no mitigation is required.

Operational Impacts
The following section provides an analysis of potential long-term air quality impacts to regional air quality with the long-term operation of the Project. The potential operations-related air emissions have been assessed for both regional and local criteria pollutant emissions and cumulative impacts.

Operations-Related Regional Emissions
Operational emissions are comprised of area, energy, mobile, and stationary source emissions.

The principal source of all long-term criteria pollutant emissions would be vehicle trips. Area source emissions are based on CalEEMod assumptions for the specific land uses and size.

Energy emissions are based on the Applicant’s estimate of natural gas use. Mobile source emissions are based on the estimated Project-related trip generation forecast of 6,366 daily trips, as provided in the Project TIA (Pasadena DOT 2021a) and the vehicle miles traveled (VMT) assumptions for the Project’s trips (Pasadena DOT 2020). The emissions analyses for the Project also includes the anticipated electrical demand, natural gas demand, and mobile trips for the two historic buildings to be retained, which are assumed to operate as restaurants for the purposes of this Draft EIR. The peak daily Project long-term gross and net operational emissions are Affinity Project Draft EIR

3.1-19 Air Quality
summarized below in Table 3.1-8, Net Operational Emissions for the Project. The net operational emissions account for the emissions from the land uses to be demolished and/or replaced with the proposed Project uses on the site plus the land uses to be retained. As shown, all criteria pollutant emissions would be less than the SCAQMD mass regional daily emissions thresholds.

It should be noted that operational emissions, without reductions from existing uses, would also be less than the SCAQMD mass regional daily emissions thresholds. There would be a less than significant operational regional impact, and no mitigation is required.

TABLE 3.1-8

NET OPERATIONAL EMISSIONS FOR THE PROJECT
Source
Emissions (lbs/day)
VOC NOx CO SOx PM10 PM2.5
Area sources 8 <1 15 <1 <1 <1
Energy sources <1 1 1 <1 <1 <1
Mobile sources 12 6 88 <1 18 5
Stationary – Generators 1 2 2 <1 <1 <1
Total Gross Operational Emissions* 21 10 106 <1 18 5
Less Existing Emissions (Table 3.1-3) 6 3 34 <1 6 2
Net Operational Emissions 15 6 71 <1 12 3
SCAQMD Significance Thresholds (Table 3.1-5) 55 55 550 150 150 55 Exceeds Threshold? No No No No No No
lbs/day: pounds per day; VOC: volatile organic compound; NOx: nitrogen oxides; CO: carbon monoxide; SOx: sulfur oxides; PM10:
respirable particulate matter 10 microns or less in diameter; PM2.5: fine particulate matter 2.5 microns or less in diameter; SCAQMD: South Coast Air Quality Management District.
* Some totals do not add due to rounding. Highest of Winter or Summer model runs shown.

Source: SCAQMD 2019 (thresholds); see Appendix B, Air Quality and Greenhouse Gas Emissions Modeling Data, for CalEEMod model outputs.

Operations-Related Localized Emissions
Project-related air emissions from on-site sources such as emergency generators, vehicle usage (cars and trucks), landscaping equipment, and on-site usage of natural gas appliances may have the potential to generate emissions that exceed the State and federal air quality standards in the vicinity of the Project even though these pollutant emissions may not be significant enough to create a regional impact to the SoCAB.

The local air quality emissions from on-site operations were analyzed using the SCAQMD’s Mass Rate LST Look-up Tables and the LST Methodology, as discussed further above. Table 3.1-9, Localized Operational Emissions for the Project, shows the on-site operational emissions from area sources, energy usage, vehicles operating on-site, and the calculated emissions screening thresholds.

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3.1-20 Air Quality
TABLE 3.1-9

LOCALIZED OPERATIONAL EMISSIONS FOR THE PROJECT
On-Site Emission Source
Pollutant Emissions (pounds/day)
NOx CO PM10 PM2.5
Area Sources 0.2 15.0 0.1 0.1
Energy Sources 1.5 1.0 0.1 0.1
Mobile Sourcesa 0.2 2.2 0.4 0.1
Stationary Sources 2.0 1.8 0.1 0.1
Project’s Total Maximum Daily On-Site Emissions 3.8 20.0 0.7 0.4 SCAQMD LST Screening Thresholdb 98.0 812.0 2.0 1.0
Exceeds Threshold? No No No No
lbs/day: pounds per day; NOx: nitrogen oxides; CO: carbon monoxide; PM10: respirable particulate matter 10 microns or less in diameter; PM2.5: fine particulate matter 2.5 microns or less in diameter; LST: localized significance threshold. a
On-site vehicle emissions based on 2.5% of the gross vehicular emissions, which is the estimated portion of vehicle emissions occurring within a quarter mile of the Project site. b Data is for SCAQMD Source Receptor Area 8, West San Gabriel Valley, with a source receptor distance of 25-meters, 2 acres.

Source: SCAQMD 2009 (thresholds); see Appendix B, Air Quality and Greenhouse Gas Emissions Modeling Data, for CalEEMod outputs.

As shown in Table 3.1-9, operation of the Project would not exceed the local NOx, CO, PM10, or PM2.5 LST screening thresholds. Operation of the Project would have a less than significant local operational impact to sensitive receptors, and no mitigation is required.

Cumulative Operational Emissions
As shown in Tables 3.1-8 and 3.1-9 above, operational regional emissions of VOC, NOx, PM10, and PM2.5 would be below the SCAQMD CEQA significance thresholds. Consistent with the approach described above (under the header “Cumulative Construction Impacts”), because the Project’s operational emissions are less than the respective SCAQMD daily operational thresholds, the Project’s operations phase activities would not contribute to a cumulatively considerable net increase of a pollutant for which the SoCAB is in nonattainment. Emissions of nonattainment pollutants or their precursors would not be cumulatively considerable. There would be a less than significant impact, and no mitigation is required.

Project with Building A Residential/Commercial
Construction Impacts
Construction-Related Regional Emissions
The Project with Building A Residential/Commercial construction is also planned to occur from March 2023 to January 2026 with a six-day work week. All Project with Building A Residential/Commercial construction assumptions would be consistent with those of the Project, except that grading for the subterranean garage and other areas for improvement would require 36,802 cy less of soil export than the Project (for a total of 147,211 cy of soil export) and 2,685 less truckloads than the Project (for a total of 10,515 truckloads for export). Table 3.1-10, Estimated Maximum Daily Construction Emissions for the Project with Building A Residential/Commercial, presents the estimated maximum daily emissions occurring both onsite and offsite during construction of the Project with Building A Residential/Commercial compared to the SCAQMD’s daily regional emission thresholds. As shown in Table 3.1-10, all pollutant emissions would be below the SCAQMD’s respective thresholds, consistent with the Project. The Affinity Project Draft EIR

3.1-21 Air Quality
emissions for the Project with Building A Residential/Commercial are comparable to those of the Project (refer to Table 3.1-6).

TABLE 3.1-10

ESTIMATED MAXIMUM DAILY CONSTRUCTION EMISSIONS FOR THE

PROJECT WITH BUILDING A RESIDENTIAL/COMMERCIAL
Year
Emissions (lbs/day)
VOC NOx CO SOx PM10 PM2.5
2023 6 42 58 <1 4 2
2024 5 39 57 <1 3 2
2025 48 37 57 <1 3 2
2026 48 5 8 <1 1 <1
Maximum Emissions 48 42 58 <1 4 2
SCAQMD Thresholds (Table 3.1-5) 75 100 550 150 150 55
Exceeds SCAQMD Thresholds? No No No No No No
lbs/day: pounds per day; VOC: volatile organic compound; NOx: nitrogen oxides; CO: carbon monoxide; SOx: sulfur oxides; PM10: respirable particulate matter 10 microns or less in diameter; PM2.5: fine particulate matter 2.5 microns or less in diameter; SCAQMD: South Coast Air Quality Management District.

Values are higher of summer or winter.

Source: SCAQMD 2019 (thresholds); see Appendix B, Air Quality and Greenhouse Gas Emissions Modeling Data, for CalEEMod model outputs.

Construction-Related Localized Emissions
Localized emissions for the Project with Building A Residential/Commercial were calculated to assess local air quality based on its construction assumptions. These were the same as the localized emissions for the Project. Consistent with the Project, the nearest off-site receptors that could be exposed for 1 hour to NO2 and CO during construction would be the commercial uses west of the site, approximately 40 feet from the Project’s western boundary. The nearest sensitive air quality receptors that could be exposed to PM10 and PM2.5 for 24 hours are residences in a multi-story building at 482 South Arroyo Parkway, approximately 100 feet from the Project site.

The emissions screening thresholds are for receptors within 25 meters (82 feet) of the Project site to account for non-sensitive receptors located closer than the nearest sensitive receptor. The screening thresholds for receptors farther away would be higher and the Project emissions would be a smaller fraction of the thresholds. Table 3.1-11, Localized Significance Threshold Construction Emissions for the Project with Building A Residential/Commercial, shows the maximum daily on-site emissions for construction activities compared with the SCAQMD LST screening thresholds. As with the Project, the LST analysis is conservative because the nearest sensitive receptor for PM10 and PM2.5 is approximately 30 meters (100 feet) away. The Project with Building A Residential/Commercial’s maximum daily on-site emissions would also occur during the building construction phase in 2023, as for the Project. As shown in Table 3.1-11, the local emissions from the Project with Building A Residential/Commercial would be below the screening thresholds, and no significant impacts would result. No mitigation is required. The magnitude of emissions for the Project with Building A Residential/Commercial are comparable to the Project.

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3.1-22 Air Quality
TABLE 3.1-11

LOCALIZED CONSTRUCTION EMISSIONS FOR THE PROJECT WITH

BUILDING A RESIDENTIAL/COMMERCIAL
Emissions and Thresholds
Emissions (lbs/day)
NOx CO PM10 PM2.5
Project maximum daily on-site emissions 41 52 2 2
SCAQMD LST Screening Thresholda 69 535 4 3
Exceed threshold? No No No No
lbs/day: pounds per day; NOx: nitrogen oxides; CO: carbon monoxide; PM10: respirable particulate matter 10 microns or less in diameter; PM2.5: fine particulate matter 2.5 microns or less in diameter; LST: localized significance threshold. a
Data is for SCAQMD Source Receptor Area 8, West San Gabriel Valley.

Source: SCAQMD 2009 (thresholds); see Appendix B, Air Quality and Greenhouse Gas Emissions Modeling Data, for CalEEMod outputs.

Cumulative Construction Emissions
Construction activities associated with the Project with Building A Residential/Commercial would result in less than significant construction-related regional and localized air quality impacts, as quantified above in Tables 3.1-10 and 3.1-11, respectively. Consistent with the Project analysis above, because the construction emissions estimated for the Project with Building A Residential/Commercial are below the SCAQMD’s regional and local significance thresholds, construction emissions would not be cumulatively considerable. There would be a less than significant impact, and no mitigation is required.

Operational Impacts
Operations-Related Regional Impacts
Implementation of the Project with Building A Residential/Commercial would result in increased residential dwelling units and no medical office building uses. As such, the emissions are quantified in Tables 3.1-12, Net Operational Emissions for the Project with Building A Residential/Commercial, and 3.1-13, Localized Operational Emissions for the Project with Building A Residential/Commercial, to provide a comparison.

Operational emissions are comprised of area, energy, mobile, and stationary source emissions, consistent with the Project. The principal source of all long-term criteria pollutant emissions would be vehicle trips, consistent with the Project. However, as there would be less trips with the Project with Building A Residential/Commercial, there would be lower mobile emissions. Area source emissions are based on CalEEMod assumptions for the specific land uses and size. Energy emissions are based on the Applicant’s estimate of natural gas use. Mobile source emissions are based on the estimated Project with Building A Residential/Commercial-related trip generation forecast of 2,494 daily trips (with transit reductions), as provided in the TIA prepared for the Project with Building A Residential/Commercial uses (Pasadena DOT 2021b), and the vehicle miles traveled (VMT) assumptions for the Project with Building A Residential/Commercial’s trips (Pasadena DOT 2021c). It should be noted that the emissions analyses also include the anticipated electrical demand, natural gas demand, and mobile trips for the conversion of the two historic buildings to commercial uses. The peak daily long-term gross and net operational emissions are summarized below in Table 3.1-12. The net operational emissions account for the emissions from the land uses to be removed from the Project site. The operational emissions are comparable to those of the Project. The net operational emissions would be less than the SCAQMD mass regional daily emissions thresholds. It should be noted that the total gross Affinity Project Draft EIR

3.1-23 Air Quality
operational emissions, without reductions from existing uses, would also be less than the SCAQMD mass regional daily emissions thresholds. There would be a less than significant impact, and no mitigation is required.

TABLE 3.1-12

NET OPERATIONAL EMISSIONS FOR THE PROJECT

WITH BUILDING A RESIDENTIAL/COMMERCIAL
Source
Emissions (lbs/day)*
VOC NOx CO SOx PM10 PM2.5
Area sources 9 <1 31 <1 <1 <1
Energy sources <1 1 1 <1 <1 <1
Mobile sources 5 2 34 <1 6 2
Stationary – Generators 1 2 2 <1 <1 <1
Total Gross Operational
Emissions*
15 6 67 <1 7 2
Less Existing Emissions (Table 3.1-
3)
6 3 34 <1 6 2
Net Operational Emissions* 9 2 33 <1 <1 <1
SCAQMD Significance Thresholds
(Table 3.1-5) 55 55 550 150 150 55
Significant Impact? No No No No No No
lbs/day: pounds per day; VOC: volatile organic compound; NOx: nitrogen oxides; CO: carbon monoxide; SOx: sulfur oxides; PM10: respirable particulate matter 10 microns or less in diameter; PM2.5: fine particulate matter 2.5 microns or less in diameter; SCAQMD: South Coast Air Quality Management District. * Some totals do not add due to rounding.

Source: SCAQMD 2019 (thresholds); see Appendix B, Air Quality and Greenhouse Gas Emissions Modeling Data, for CalEEMod model outputs.

Operations-Related Localized Emissions
Same as the Project, Project with Building A Residential/Commercial-related air emissions from on-site sources such as emergency generators, vehicle usage (cars and trucks), landscaping equipment, and on-site usage of natural gas appliances may have the potential to generate emissions that exceed the State and federal air quality standards in the vicinity of the Project even though these pollutant emissions may not be significant enough to create a regional impact to the SoCAB.

The local air quality emissions from on-site operations were analyzed using the SCAQMD’s Mass Rate LST Look-up Tables and the LST Methodology. Table 3.1-13 shows the on-site operational emissions from area sources, energy usage, vehicles operating on-site, and the calculated emissions screening thresholds.

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TABLE 3.1-13

LOCALIZED OPERATIONAL EMISSIONS FOR THE PROJECT

WITH BUILDING A RESIDENTIAL/COMMERCIAL
On-Site Emission Source*
Pollutant Emissions (pounds/day)
NOx CO PM10 PM2.5
Area Sources 0.4 31.0 0.2 0.2
Energy Sources 1.1 0.5 0.1 0.1
Mobile Sourcesa 0.1 0.8 0.2 0.04
Stationary Sources 2.0 1.8 0.1 0.1
Project’s Total Maximum Daily On-Site
Emissions 3.5 34.2 0.5 0.4
SCAQMD LST Screening Thresholdb 98.0 812.0 2.0 1.0
Exceeds Threshold? No No No No
lbs/day: pounds per day; NOx: nitrogen oxides; CO: carbon monoxide; PM10: respirable particulate matter 10 microns or less in diameter; PM2.5: fine particulate matter 2.5 microns or less in diameter; LST: localized significance threshold. a
On-site vehicle emissions based on 2.5% of the gross vehicular emissions, which is the estimated portion of vehicle emissions occurring within a quarter mile of the Project site. b Data is for SCAQMD Source Receptor Area 8, West San Gabriel Valley, with a source receptor distance of 25- meters, 2 acres.

Source: SCAQMD 2009 (thresholds); see Appendix B, Air Quality and Greenhouse Gas Emissions Modeling Data, for CalEEMod outputs.

The data provided in Table 3.1-13 shows that the operations of the Project with Building A Residential/Commercial would not exceed the local NOx, CO, PM10, or PM2.5 screening thresholds, consistent with the Project. The operational emissions are comparable to those of the Project. The emissions would be less than the SCAQMD LST screening thresholds. There would be a less than significant impact, and no mitigation is required.

Cumulative Operational Impacts
Same as the Project, as shown in Tables 3.1-12 and 3.1-13, operational emissions of VOC, NOx, PM10, and PM2.5 would be below the SCAQMD CEQA significance thresholds for the Project with Building A Residential/Commercial. Therefore, because the Project with Building A Residential/Commercial’s operational emissions are less than the respective SCAQMD daily operational thresholds, the Project with Building A Residential/Commercial’s operational activities would not contribute to a cumulatively considerable net increase of a pollutant for which the SoCAB is in nonattainment. Emissions of nonattainment pollutants or their precursors would not be cumulatively considerable. There would be a less than significant impact, and no mitigation is required. This is comparable to the findings for the Project.

Threshold 3.1c: Would the Project expose sensitive receptors to substantial pollutant concentrations?
A significant impact may occur when a project would generate pollutant concentrations to a degree that would significantly affect sensitive receptors, which include populations that are more susceptible to the effects of air pollution than the population at large. Exposure of sensitive receptors is addressed for emissions from construction and operation of the Project. To address construction activities, the analysis below includes the following issues: localized air quality impacts from construction; and toxic air contaminants (TACs), specifically diesel particulate matter (DPM) from on-site construction. To address operational emissions, the analysis evaluates potential exposure to sensitive receptors, the analysis below discusses local air quality impacts from on-site operations, and CO hotspots. Operational, long-term TACs may be generated by Affinity Project Draft EIR

3.1-25 Air Quality
some industrial land uses; commercial land uses (e.g., gas stations and dry cleaners); and diesel vehicles at bus stations or warehouses. The proposed residential and commercial uses do not generate substantial quantities of TACs and are therefore not addressed in this analysis.

Project
Construction
Localized Impacts from Construction
Localized impacts from construction were analyzed above in response to Threshold 3.1b; specifically, Table 3.1-7 and associated analysis. Emissions were found to be less than the applicable SCAQMD LST screening thresholds; therefore, there would be a less than significant impact related to localized impacts from construction of the Project, and no mitigation is required.

Toxic Air Contaminant Emissions from On-Site Construction Construction activities would result in short-term, project-generated emissions of DPM from the exhaust of off-road, heavy-duty diesel equipment used for site preparation; paving; building construction; and other miscellaneous activities. CARB identified DPM as a TAC in 1998. The dose to which receptors are exposed is the primary factor used to determine health risk. Dose is a function of the concentration of a substance or substances in the environment and the duration of exposure to the substance. Thus, the risks estimated for a maximally exposed individual (MEI) are higher if a fixed exposure occurs over a longer time period. According to the Office of Environmental Health Hazard Assessment (OEHHA), health risk assessments—which determine the exposure of sensitive receptors to TAC emissions—should be based on a 40-year exposure period; however, such assessments should be limited to the period/duration of activities associated with the Project.

There would be relatively few pieces of off-road, heavy-duty diesel equipment in operation, and the total construction period of approximately 34 months would be relatively short when compared to a 40-year exposure period. Combined with the highly dispersive properties of DPM and additional reductions in particulate emissions from newer construction equipment, as required by USEPA and CARB regulations, construction emissions of TACs would not expose sensitive receptors to substantial emissions of TACs. The impact would be less than significant, and no mitigation is required.

Operational
Localized Criteria Pollutants from On-site Operations
Localized impacts from construction were analyzed in response to Threshold 3.1b; specifically, Table 3.1-9 and associated analysis. Emissions were found to be less than the applicable SCAQMD LST screening thresholds. Therefore, there would be a less than significant impact related to localized impacts from operation of the Project, and no mitigation is required.

Carbon Monoxide Hotspot
In an urban setting, vehicle exhaust is the primary source of CO. Consequently, the highest CO concentrations generally are found close to congested intersections. Under typical meteorological conditions, CO concentrations tend to decrease as the distance from the emissions source (e.g., congested intersection) increases. Localized areas where ambient concentrations exceed federal and/or State standards for CO are termed CO “hotspots”. According to the Transportation ProjectLevel Carbon Monoxide Protocol (the Protocol), projects may worsen air quality if they worsen Affinity Project Draft EIR

3.1-26 Air Quality
traffic flow, defined for signalized intersections as increasing average delay at intersections operating at Level of Service (LOS) E or F or causing an intersection that would operate at LOS D or better without the Project, to operate at LOS E or F with the Project (UCD ITS 1997). If impacts are less than significant close to congested intersections, impacts also would be less than significant at more distant sensitive-receptor and other locations. The Project’s Transportation Impact Analysis – Outside of CEQA Analysis identified one signalized intersection, Arroyo Parkway at California Boulevard, that would operate at LOS E in the AM and PM peak hours with increased delay under Existing Plus Project conditions when compared to existing conditions (Pasadena DOT 2021a).

The 2003 AQMP and the 1992 Federal Attainment Plan for Carbon Monoxide (SCAQMD 2003b) evaluated numerous intersections for the potential to result in CO hotspots and found that the 1-hour CO standard (20.0 ppm) would likely not be exceeded until the daily traffic at the intersection exceeded more than 400,000 vehicles per day. Based on data in the Project’s Transportation Impact Analysis – Outside of CEQA Analysis, average daily traffic at the Arroyo Parkway/California Street intersection under Existing Plus Project conditions is conservatively estimated at 48,000 vehicles based on PM peak hour traffic volumes being approximately 10 percent of average daily trips. The 48,000 daily trips at this intersection is substantially less than the 400,000 vehicles per day needed to exceed the CO standards. Therefore, CO concentrations at the intersection would be substantially less than the CO ambient air quality standards.

Moreover, vehicle emission standards have become increasingly more stringent since 1992 and background CO concentrations are less than in 1992. As such, the small contribution of Projectrelated traffic would not result in CO concentrations that would exceed either the State or federal ambient air quality standards. The Project would result in less than significant impacts related to CO hotspots, and no mitigation is required.

Project with Building A Residential/Commercial
Construction
Localized Impacts from Construction
Localized impacts from construction were analyzed in response to Threshold 3.1b; specifically, Table 3.1-11 and associated analysis. Emissions were found to be less than the applicable SCAQMD LST screening thresholds. Therefore, there would be a less than significant impact related to localized impacts from construction of the Project with Building A Residential/Commercial, and no mitigation is required. This is comparable to the findings of the Project.

Toxic Air Contaminant Emissions from On-Site Construction As with the Project, for the Project with Building A Residential/Commercial there would be relatively few pieces of off-road, heavy-duty diesel equipment in operation, and the total construction period of approximately 34 months would be relatively short when compared to a 40- year exposure period. Combined with the highly dispersive properties of DPM and additional reductions in particulate emissions from newer construction equipment, as required by USEPA and CARB regulations, construction emissions of TACs would not expose sensitive receptors to substantial emissions of TACs. The impact would be less than significant, and no mitigation is required. This is comparable to the findings of the Project.

Affinity Project Draft EIR

3.1-27 Air Quality
Operational
Localized Criteria Pollutants from On-site Operations
Localized impacts from construction were analyzed in response to Threshold 3.1b; specifically, Table 3.1-9 and associated analysis. Emissions were found to be less than the applicable SCAQMD LST screening thresholds. Therefore, there would be a less than significant impact related to localized impacts from operation of the Project with Building A Residential/Commercial, and no mitigation would be required. This is comparable to the finding for the Project.

Carbon Monoxide Hotspot
Consistent with the Project, the Project with Building A Residential/Commercial’s Transportation Impact Analysis – Outside of CEQA Analysis identified one signalized intersection, Arroyo Parkway at California Boulevard, that would operate at LOS E in the AM and PM peak hours with increased delay under Existing Plus Project conditions when compared to existing conditions for the PM peak hour, and slightly reduced delay for the AM peak hour (Pasadena DOT 2021b).

Based on data in the Project with Building A Residential/Commercial TIA (Pasadena DOT 2021c), average daily traffic at the Arroyo Parkway/California Street intersection under Existing Plus Project conditions is conservatively estimated at 45,000 vehicles. Therefore, CO concentrations at the intersection would be substantially less than the CO ambient air quality standards.

Moreover, vehicle emission standards have become increasingly more stringent since 1992 and background CO concentrations are less than in 1992. As such, the small contribution of Projectrelated traffic would not result in CO concentrations that would exceed either the State or federal ambient air quality standards. The Project with Building A Residential/Commercial would result in less than significant impacts related to CO hotspots, and no mitigation is required. This is comparable to the findings for the Project.

3.1.6 CUMULATIVE IMPACTS
Project
Consistency with the AQMP, as analyzed in Threshold 3.1a, is not subject to cumulative impact analysis. Threshold 3.1b analyzed cumulative construction and operational impacts and found both to be less than significant. SCAQMD’s policy with respect to cumulative impacts–impacts that would be directly less than significant on a project level would also be cumulatively less than significant– is applicable to the TAC analysis analyzed in response to Threshold 3.1c. Direct TAC impacts would be less than significant; therefore, cumulative TAC impacts would be less than significant for the Project. With respect to CO hotspot impacts, although cumulative traffic is not addressed in the TIA, the Existing Plus Project traffic volume at the Arroyo Parkway/California Street intersection is substantially below the level of concern such that cumulative traffic could not approach the level of significance. There would be no cumulatively considerable impacts with Project implementation, and no mitigation is required.

Project with Building A Residential/Commercial
The cumulative impact findings for the Project, as stated above, would be applicable to the Project with Building A Residential/Commercial. Therefore, there would be no cumulatively considerable impact for the Project with Building A Residential/Commercial, and no mitigation is required.

3.1.7 MITIGATION MEASURES
No significant impacts related to air quality would occur, and no mitigation is required.

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3.1-28 Air Quality

3.1.8 LEVEL OF SIGNIFICANCE AFTER MITIGATION
Less than significant.

3.1.9 SUMMARY OF ANALYSIS
Project
The Project would not result in a conflict with or obstruct implementation of the applicable air quality plan (the SCAQMD’s 2016 AQMP); therefore, there would be less than significant impacts.

The Project would not result in a cumulatively considerable net increase of any criteria pollutant for which the Project region is in non-attainment under an applicable federal or State AAQS, and impacts would be less than significant. The Project would not expose sensitive receptors to substantial pollutant concentrations, and as such, this impact would be less than significant.

Project with Building A Residential/Commercial
The summary of findings for the Project with Building A Residential/Commercial would be comparable to the findings for the Project. Specifically, the Project with Building A Residential/Commercial would not result in a conflict with or obstruct implementation of the applicable air quality plan (the SCAQMD’s 2016 AQMP); therefore, there would be less than significant impacts. The Project with Building A Residential/Commercial would not result in a cumulatively considerable net increase of any criteria pollutant for which the Project region is in non-attainment under an applicable federal or State AAQS, and impacts would be less than significant. The Project with Building A Residential/Commercial would not expose sensitive receptors to substantial pollutant concentrations, and as such, this impact would be less than significant.

3.1.10 REFERENCES
California Air Pollution Control Officers Association (CAPCOA). 2021. California Emission Estimator Model (CalEEMod)TM Version 2020.4.0, Developed by Breeze Software, a division of Trinity Consultants in Collaboration with SCAQMD and other California Air Districts. Sacramento, CA: CAPCOA.

California Air Resources Board (CARB). 2021 (September 23, last accessed). Top 4 Summary:

Pasadena-S Wilson Avenue Monitoring Station. Sacramento, CA: CARB. https://www.arb.ca.gov/adam/topfour/topfourdisplay.php. ———. 2021b. (accessed May 10), Maps of Current State and Federal Area Designations. https://ww2.arb.ca.gov/resources/documents/maps-state-and-federal-area-designations. ———. 2016 (May 4). Ambient Air Quality Standards. Sacramento, CA: CARB. http://www.arb.ca.gov/research/aaqs/aaqs2.pdf.

Pasadena, City of (Pasadena). 2012 (January). General Plan Update. Draft Open Space and Conservation Element. Pasadena, CA: City of. https://www.cityofpasadena.net/wpcontent/uploads/sites/30/General-Plan-Open-Space-and-Conservation-Element2012.pdf?v=1620843342485 Pasadena Department of Transportation (Pasadena DOT). 2021a (March 22). Transportation Impact Analysis, Outside of CEQA Analysis. Project Address: 491-577 South Arroyo Parkway. Demolition of approximately 46,000 sf commercial. Construction of 151,000 sf medical office, 3,000 sf commercial, 184,376 sf senior living facility consisting of 95 Affinity Project Draft EIR

3.1-29 Air Quality
independent living units and 85,800 sf assisted living. 5,882 sf restaurant to remain.

Pasadena, CA: Pasadena DOT.
———.2021b (June 17). Transportation Impact Analysis, Outside of CEQA Analysis. Project Address: 491-577 South Arroyo Parkway. Project Summary: Demolition of approximately 46,000 sf commercial. Construction of 151,000 sf residential building with up to 197 units, 3,000 sf commercial, 184,376 sf senior living facility consisting of up to 95 independent living units and 85,800 sf assisted living. 5,882 sf restaurant to remain. Pasadena, CA:

Pasadena DOT.
———. 2021c (June 17). Transportation Impact Analysis, CEQA Evaluation, Project Address 491- 577 South Arroyo Parkway. Project Summary: Demolition of approximately 46,000 sf commercial. Construction of 151,000 sf residential building with up to 197 units, 3,000 sf commercial, 184,376 sf senior living facility consisting of up to 95 independent living units and 85,800 sf assisted living. 5,882 sf restaurant to remain. Pasadena, CA: Pasadena DOT. Appendix G-2.
———. 2020 (November 30). Transportation Impact Analysis, CEQA Evaluation, Category 2, Project Address 491-577 South Arroyo Parkway. Project Summary: Demolition of approximately 46,000 sf commercial. Construction of 151,000 sf residential building with up to 197 units, 3,000 sf commercial, 184,376 sf senior living facility consisting of up to 95 independent living units and 85,800 sf assisted living. 5,882 sf restaurant to remain.

Pasadena, CA: Pasadena DOT. Appendix G-1.

South Coast Air Quality Management District (SCAQMD).2021 (April 9, last accessed). Final 2016 AQMP and Related SIP Submittals. http://www.aqmd.gov/home/air-quality/clean-airplans/air-quality-mgt-plan/final-2016-aqmp ———. 2019 (April, Revision). SCAQMD Air Quality Significance Thresholds. Diamond Bar, CA:

SCAQMD. http://www.aqmd.gov/docs/default-source/ceqa/handbook/scaqmd-air-qualitysignificance-thresholds.pdf?sfvrsn=2. ———. 2009. Localized Significance Thresholds. Diamond Bar, CA: SCAQMD. http://www.aqmd.gov/home/rules-compliance/ceqa/air-quality-analysishandbook/localized-significance-thresholds ———. 2008 (July, as revised). Final Localized Significance Threshold Methodology. Diamond Bar, CA: SCAQMD. http://www.aqmd.gov/ceqa/handbook/LST/ Method_final.pdf. ———. 2003a (August). White Paper on Potential Control Strategies to Address Cumulative Impacts from Air Pollution. Diamond Bar, CA: SCAQMD.
http://www.aqmd.gov/docs/default-source/Agendas/Environmental-Justice/cumulativeimpacts-working-group/cumulative-impacts-white-paper.pdf. ———. 2003b. 2003 Air Quality Management Plan. https://www.aqmd.gov/home/airquality/clean-air-plans/air-quality-mgt-plan/2003-aqmp ———. 1993. CEQA Air Quality Handbook. Diamond Bar, CA: SCAQMD.

Southern California Association of Governments (SCAG). 2020 (Adopted September 3). Connect SoCal, The 2020-2045 Regional Transportation Plan/ Sustainable Communities Strategy of The Southern California Association Of Governments. Los Angeles, CA. SCAG. https://scag.ca.gov/read-plan-adopted-final-plan
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3.1-30 Air Quality
U.S. Environmental Protection Agency (USEPA). 2021a (April 30, current as of). Nonattainment Areas for Criteria Pollutants (Green Book). Research Triangle Park, NC: USEPA. https://www.epa.gov/green-book
———. 2021b (accessed May 10). NAAQS Table. Research Triangle Park, NC: USEPA. https://www.epa.gov/criteria-air-pollutants/naaqs-table.

Affinity Project Draft EIR

3.2-1 Cultural and Paleontological Resources

3.2 CULTURAL AND PALEONTOLOGICAL RESOURCES
This section addresses potential impacts to cultural and paleontological resources that could result from the implementation of the Project or Project with Building A Residential/Commercial.

Information in this section is derived from a Historical Resource Assessment Report (Historical Resource Assessment) prepared for the Project site by PaleoWest, LLC and dated January 14, 2022 (PaleoWest 2022, Appendix C-1); an archaeological records search conducted by the South Central Coastal Information Center (SCCIC) on July 24, 2020 (Appendix C-2); the Sacred Lands File search conducted by the Native American Heritage Commission (NAHC) received on July 15, 2020 and the Native American consultation initiated by the City on May 28, 2020 (Appendix C-2); and a paleontological resource record search conducted by the Natural History Museum of Los Angeles County (NHM) received on December 25, 2020 (Appendix C-3). Section 3.10, Tribal Cultural Resources, provides further information regarding the Native American consultation conducted pursuant to Assembly Bill (AB) 52.

3.2.1 EXISTING CONDITIONS
Archaeological and Historical Resources
Historical Resource Assessment Report
A pedestrian survey of the Project site was conducted as part of the Historical Resource Assessment by PaleoWest on May 4, 2020. During the field survey, the exteriors of the buildings within the Project site were analyzed, photographed, and recorded. Any building or structure determined to have been built prior to 1975 or to be potentially eligible for the CRHR were formally evaluated on Department of Parks and Recreations (DPR) 523 series forms. The Historical Resource Assessment from PaleoWest is presented in Appendix C-1.

In addition to the Project site, the general conditions and character of the surrounding area were observed during the field survey on May 4, 2020. Attention to building types, uses, spatial organization, periods of construction, architectural styles, and other characteristics were noted at this time. A subsequent desktop analysis of the previously documented historical resources identified within the Project vicinity was also conducted. This entailed using readily available digital tools, such as street views from February 2021, to confirm current conditions of these resources and to cross-reference this with existing documentation related to the historic status of each resource, including California Historical Resources Inventory Database (CHRID) entries, DPR 523 forms, and National Register of Historic Preservation (NRHP) nominations.

South Central Coastal Information Center Record Search
A literature review and records search were conducted by Psomas at the SCCIC at California State University, Fullerton on July 30, 2020. The SCCIC records were used by Psomas and provided to PaleoWest. This inventory effort included the Project site and a 0.5-mile radius around the Project site, collectively termed the “Project study area.” The objective of this records search was to identify prehistoric or historical cultural resources that have been recorded within the broader context surrounding the Project site during prior cultural resource investigations.

The SCCIC search included a review of all recorded sites and cultural resources reports on file for the Project study area. The results from the information center indicated that 17 cultural resources investigations were previously conducted within the 0.5-mile radius. However, of the 17 previous investigations, the SCCIC indicated that none of the studies overlapped with the current Project site.

Affinity Project Draft EIR

3.2-2 Cultural and Paleontological Resources
While no previous investigations included any portion of the Project site, there are individual resources documented outside the preparation of a cultural resources investigation that are present on site. The SCCIC search identified 63 historic built environment resources previously identified within the 0.5-mile radius. A copy of the records search results in is included in Appendix C-2.

Project Site
The SCCIC search did not identify any archaeological sites within the Project site but did identify three historic built environmental resources in the Project site, as shown in Table 3.2-1, below.

TABLE 3.2-1

PREVIOUSLY RECORDED HISTORICAL RESOURCES ON THE PROJECT SITE Primary No Resource Name/Address Resource Type
Year
Built
Year
Recorded
Historic Status
(NRHP, CRHR,
Local)
P-19-183400 Pacific Electric Railroad
Garage/465 S. Arroyo Parkway
Building 1923,
2007
1986 Potentially Local
eligible
P-19-183401 Market Basket Warehouse/
501-503 S. Arroyo Parkway
Building 1940 1989 Local eligible
P-19-183402 Lewis Iron Building/
523 S. Arroyo Parkway
Building 1922 1989 Local eligible
Source: SCCIC 2020 and PaleoWest 2022.

Preliminary desktop review of the resources identified within the Project site confirmed that both 501 South Arroyo Parkway and 523 South Arroyo Parkway appear to be extant (e.g., remain present on the site). These properties were previously recommended as eligible for the local register and are, therefore, considered historical resources for the purposes of CEQA. The former Pacific Electric Railroad Garage, which was also previously recommended eligible for the Local Register, appears to be partially extant. The building was integrated into the existing commercial building occupied by Whole Foods Market. Currently, the east and north facades of this building remain, while the remainder of the building was removed and replaced with new construction in 2007.

Project Vicinity
In addition to the resources located within the Project site, multiple historical resources were identified in the records in the surrounding vicinity. For the purposes of the Historical Resources Assessment, and the potential analysis of the Project and its indirect impact to the setting and adjacent and nearby historical resources, a separate overlay was outlined to identify those resources that have the potential to be impacted. Referred to herein as the “Project vicinity,” this area was delineated to account for potential indirect impacts, such as visual or atmospheric alterations, resulting from the Project.

The Project vicinity is centered around the Project site, which corresponds with the entire subject block fronting South Arroyo Parkway to the east and is bounded by East Bellevue Drive to the north, East California Boulevard to the south, and the Los Angeles Metropolitan Transportation Authority (Metro) light rail alignment to the rear (i.e., west). The boundaries of the Project vicinity extend approximately one city block in each direction to align with East Del Mar Boulevard to the north, Edmondson Alley to the west, Pico Street to the south, and South Marengo Avenue to the east. Within the Project vicinity, nine historic resources were identified, including seven buildings and two historic districts; one historic district is fully within the Project vicinity whereas the other is only partially within the delineated area.

Affinity Project Draft EIR

3.2-3 Cultural and Paleontological Resources
Table 3.2-2 below outlines those previously recorded historical resources located within the Project vicinity.

TABLE 3.2-2

PREVIOUSLY RECORDED HISTORICAL RESOURCES

IN THE PROJECT VICINITY
Primary
Number Resource Name/Address
Resource
Type Year Built
Year
Recorded
Historic Status
(NRHP, CRHR,
Local)
P-19-180051 The Home Laundry Building 1922 1987
NRHP-listed,
CRHR-listed,
Local-listed
P-19-180068 S. Marengo Historic District Historic District 1901-1916 1981 NRHP-listed,
CRHR-listed,
Local-listed
P-19-180069 Don Carlos Court/
374-386 S. Marengo Ave Building 1927 1983
NRHP-listed,
CRHR-listed,
Local-listed
P-19-180070 Evanston Inn/
385-395 S. Marengo Ave Building 1897 1981
NRHP-listed,
CRHR-listed,
Local-listed
P-19-180680 Bryan Court, Adams Court/
427 S. Marengo Historic District 1916 1981
NRHP-listed,
CRHR-listed,
Local-listed
P-19-183343
George S. Hunt Studio &
Shop Building/ 161 E.

California Blvd.

Building 1927 1991, 2000 Local eligible
P-19-183344 Wallace Neff Office/
180 E. California Blvd. Building 1927 1991, 2011 NRHP eligible, Local-listed P-19-183346 Raymond Flowers/
62 E. California Blvd. Building 1933 1991, 2004 NRHP eligible, Local eligible
P-19-183399 Cornet Building/
411 S. Arroyo Parkway Building 1945 1989, 2012
Potentially eligible
for NRHP, CRHR,
Local (needs reevaluation)
P-19-183403 Bryan’s Cleaners/
544 S. Arroyo Parkway Building 1938 1986 Local eligible P-19-183407 Pasadena Humane Society/
361 S. Raymond Ave Building 1929 1989 NRHP-listed,
CRHR-listed,
Local-listed
P-19-183408
Royal Laundry,
Milus Textile Service/
443 S. Raymond Ave
Building 1927 1991, 2000,
2007
NRHP-listed,
CRHR-listed,
Local-listed
LD17 (City #) Marengo-Pico
Landmark District Historic District 1912-1927 2008, 2011 Local-listed Source: SCCIC 2020 and PaleoWest 2022
Additional Sources
In addition to the records search, general contextual and site-specific research was conducted for the Project site and the surrounding area. Additional sources consulted include the NRHP, the Office of Historic Preservation Directory of Properties in the Historic Property Data File, Los Angeles County Assessor files, historical newspapers databases, historic Sanborn Fire Insurance Maps, Los Angeles Public Library databases, newspaper.com, ancestry.com, Pasadena city directories, and the City’s CHRID system.

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3.2-4 Cultural and Paleontological Resources
Historical maps consulted include the Los Angeles (USGS 1894, 1900), Altadena (USGS 1928), and Pasadena (USGS 1953, 1966, 1972, 1988, 1955) 7.5-minute USGS quadrangles. The 1894 and 1900 maps depicted the Project site as thoroughly built out, but no extant buildings within the Project site were depicted. The 1928 map showed two buildings within the Project site that roughly correspond with 495 South Arroyo Parkway and 501 South Arroyo Parkway. A review of available Sanborn Fire Insurance Maps from 1931 through 1951 was also conducted.

Native American Heritage Commission
Psomas submitted a request to the Native American Heritage Commission (NAHC) for a Sacred Lands File search on July 10, 2020. Results were received on July 15, 2020. The result of the Sacred Lands File (SLF) check conducted by the NAHC was positive for sacred places or objects with cultural value to a California Native American tribe. The NAHC recommended contacting the Gabrieleno Band of Mission Indians – Kizh Nation for more information. The Sacred Lands File results summary from the NAHC is presented in Appendix C-2. The results of Native American consultation pursuant to Assembly Bill 52 is presented in Section 3.10, Tribal Cultural Resources.

Paleontological Resources
Natural History Museum Los Angeles County
Psomas submitted a request to the NHM for a paleontological resource record search on December 16, 2020. Results were received on December 25, 2020. The results of the paleontological resources record search were negative for fossil localities within the Project site; however, the museum did identify several localities nearby from the same sedimentary deposits that occur in the Project site, either at the surface or at depth. These include mastodon (Mammut), Horse (Equus), Birds (Aves) from the Pleistocene Epoch, and several unidentifiable invertebrate specimens from the Pliocene Epoch. The records search results summary from the NHM is presented in Appendix C-3.

3.2.2 RELEVANT CULTURAL RESOURCE REGULATIONS
Federal
National Historic Preservation Act
The National Historic Preservation Act (NHPA) of 1966, as amended, promotes the preservation, enhancement, and productive use of historic resources. The NHPA established the Advisory Council on Historic Preservation (ACHP) and provided procedures for the ACHP and federal agencies in promoting historic preservation. Properties of traditional religious and cultural importance to Native Americans are protected under Section 101(d)(6)(A) of the NHPA.

Section 106 of the NHPA requires that federal actions and the use of federal funds take into account their potential effects on historic properties or those listed in or eligible for listing in the National Register of Historic Places (NRHP, National Register). Under Section 106, the significance of any adversely affected cultural resource is assessed and mitigation measures are proposed to reduce the impacts to an acceptable level.

National Register of Historic Places
Authorized by the NHPA, the U.S. Department of the Interior National Park Service’s NRHP is part of a national program to coordinate and support public and private efforts to identify, evaluate, and protect America’s historic and archaeological resources. The NRHP is the official list of the nation’s historic places worthy of preservation. Listing on the National Register places no Affinity Project Draft EIR

3.2-5 Cultural and Paleontological Resources
obligations on private property owners. It places no restrictions on the use, treatment, transfer, or disposition of private property. Listing on the NRHP does, however, incentivize preservation.

Property owners can become eligible to receive federal preservation grants and federal tax credits; they may utilize alternative methods of preservation in compliance with building code provisions. For a resource to qualify for listing on the NRHP, the quality of significance in American history, architecture, archaeology, engineering, and culture must be present in districts, sites, buildings, structures, and objects that possess integrity and:

A. are associated with events that have made a significant contribution to the broad patterns of our history; or
B. are associated with the lives of persons significant in our past; or C. embody distinctive characteristics of a type, period, or method of construction, or that represent the work of a master, or that possess high artistic values, or that represent a significant and distinguishable entity whose components may lack individual distinction; or
D. have yielded or may be likely to yield information important in prehistory or history.

Integrity
To be eligible for listing in the NRHP, a property must retain sufficient integrity to convey its significance. The NRHP publication How to Apply the National Register Criteria for Evaluation (National Register Bulletin 15) establishes how to evaluate the integrity of a property: “Integrity is the ability of a property to convey its significance”. The evaluation of integrity must be grounded in an understanding of a property’s physical features and how they relate to the concept of integrity. Determining which of these aspects are most important to a property requires knowing why, where, and when a property is significant. To retain historic integrity, a property must possess several, and usually most, aspects of integrity:

1. Location is the place where the historic property was constructed or the place where the historic event occurred.

2. Design is the combination of elements that create the form, plan, space, structure, and style of a property.

3. Setting is the physical environment of a historic property and refers to the character of the site and the relationship to surrounding features and open space. Setting often refers to the basic physical conditions under which a property was built and the functions it was intended to serve. These features can be either natural or man-made, including vegetation, paths, fences, and relationships between other features or open space.

4. Materials are the physical elements that were combined or deposited during a particular period or time and in a particular pattern or configuration to form a historic property.

5. Workmanship is the physical evidence of crafts of a particular culture or people during any given period of history or prehistory and can be applied to the property as a whole or to individual components.

6. Feeling is a property’s expression of the aesthetic or historic sense of a particular period of time. It results from the presence of physical features that, when taken together, convey the property’s historic character.

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3.2-6 Cultural and Paleontological Resources

7. Association is the direct link between the important historic event or person and a historic property.

Secretary of the Interior’s Standards and Guidelines for Archaeology and Historic Preservation
The Secretary of the Interior’s Standards for the Treatment of Historic Properties with Guidelines for Preserving, Rehabilitating, and Reconstructing Historic Buildings or the Secretary of the Interior’s Standards for Rehabilitation and Guidelines for Rehabilitating Historic Buildings (Weeks and Grimmer 1995) (both referred to as the SOI Standards were codified in 1995 (36 Code of Federal Regulations [CFR] Part 68) to establish professional standards that apply to all proposed development grant-in-aid projects assisted through the National Historic Preservation Fund and to serve as general guidance for work on any other historic building. The SOI Standards apply to historic properties of all periods, styles, types, materials, and sizes. The ten Standards for Rehabilitation are:

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

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

3. Each property will be recognized as a physical record of its time, place, and use. Changes that create a false sense of historical development, such as adding conjectural features or elements from other historic properties, will not be undertaken.

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

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

6. Deteriorated historic features will be repaired rather than replaced. Where the severity of deterioration requires replacement of a distinctive feature, the new feature will match the old in design, color, texture, and, where possible, materials. Replacement of missing features will be substantiated by documentary and physical evidence.

7. Chemical or physical treatments, if appropriate, will be undertaken using the gentlest means possible. Treatments that cause damage to historic materials will not be used.

8. Archaeological resources will be protected and preserved in place. If such resources must be disturbed, mitigation measures will be undertaken.

9. New additions, exterior alterations, or related new construction will not destroy historic materials, features, and spatial relationships that characterize the property. The new work will be differentiated from the old and will be compatible with the historic materials, features, size, scale and proportion, and massing to protect the integrity of the property and its environment.

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

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3.2-7 Cultural and Paleontological Resources
State
California Environmental Quality Act
The Project is subject to compliance with CEQA, as amended. Specifically, under Public Resources Code Section 201084.1, a “project that may cause a substantial adverse change in the significance of an historical resources is a project that may have a significant effect on the environment.” The first step in the CEQA compliance process in terms of historical resources is to identify any that may be impacted by the project.
“Historical resource” is a term with a defined statutory meaning (Public Resources Code Section 21084.1). The determination of significant impacts on historical and archaeological resources is described in Sections 15064.5(a) and 15064.5(b) of the State CEQA Guidelines. Section 15064.5(a) states that historical resources include the following:

1. A resource listed in, or determined to be eligible by the State Historical Resources Commission, for listing in the [CRHR] (Public Resources Code Section 5024.1).

2. A resource included in a local register of historical resources, as defined in Section 5020.1(k) of the Public Resources Code or identified as significant in a historical resource survey meeting the requirements of Section 5024.1(g) of the Public Resources Code, will be presumed to be historically or culturally significant. Public agencies must treat any such resource as significant unless the preponderance of evidence demonstrates that it is not historically or culturally significant.

3. Any object, building, structure, site, area, place, record, or manuscript which a lead agency determines to be historically significant or significant in the architectural, engineering, scientific, economic, agricultural, educational, social, political, military, or cultural annals of California may be considered to be a historical resource, provided the lead agency’s determination is supported by substantial evidence in light of the whole record. Generally, a resource will be considered by the lead agency to be historically significant if the resource meets the criteria for listing in the [CRHR] (Public Resources Code Section 5024.1).

4. The fact that a resource is not listed in or determined to be eligible for listing in the CRHR, not included in a local register of historical resources (pursuant to Section 5020.1[k] of the Public Resources Code), or identified in a historical resources survey (meeting the criteria in Section 5024.1[g] of the Public Resources Code) does not preclude a lead agency from determining that the resource may be an historical resource as defined in Public Resources Code Section 5020.1(j) or 5024.1.

Cultural resources are buildings, sites, humanly modified landscapes, traditional cultural properties, structures, or objects that may have historical, architectural, cultural, or scientific importance based on established criteria. CEQA states that if a project will have a significant impact on important cultural resources, deemed “historically significant,” then project alternatives and mitigation measures must be considered.

California Register of Historical Resources
The CRHR established a list of properties that are to be protected from substantial adverse change (Public Resources Code Section 5024.1). A historical resource may be listed in the CRHR if it exhibits significance under one or more of the following criteria:

1. It is associated with events that have made a significant contribution to the broad patterns of California’s history and cultural heritage.

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3.2-8 Cultural and Paleontological Resources

2. It is associated with the lives of persons important in California’s past.

3. It embodies the distinctive characteristics of a type, period, region, or method of construction, or represents the work of an important creative individual, or possesses high artistic value.

4. It has yielded or is likely to yield information important in prehistory or history.

In addition to exhibiting significance under one or more of the above criteria, a resource must also retain sufficient historical integrity to convey its significance. Historical integrity is the physical aspects of a resource related to its historic character. Integrity is evaluated through seven aspects: location, design, setting, materials, workmanship, feeling, and association.

The CRHR includes properties that are listed or have been formally determined to be eligible for listing in the NRHP, State Historical Landmarks, and eligible Points of Historical Interest. Other resources require nomination for inclusion in the CRHR. These may include:
 resources contributing to the significance of a local historic district,  individual historical resources,
 historical resources identified in historic resource surveys conducted in accordance with State Historic Preservation Office procedures,
 historic resources or districts designated under a local ordinance consistent with Commission procedures, and
 local landmarks or historic properties designated under local ordinance.

California Historical Building Code
The California State Historical Building Code (CHBC) (California Code of Regulations, Title 24, Part 8) is intended to save California’s architectural heritage by recognizing the unique construction issues inherent in maintaining and adaptively reusing historic buildings. The CHBC’s standards and regulations facilitate the rehabilitation or change of occupancy so as to preserve their original or restored elements and features; to encourage energy conservation and a costeffective approach to preservation; and to provide for reasonable safety from fire, seismic forces, or other hazards for occupants and users of such buildings, structures, and properties and to provide reasonable availability and usability by the physically disabled. The 2019 triennial edition of the CHBC, effective January 1, 2020, is the currently adopted code. The City has adopted the CHBC by reference (Section 14.04.010 of the Pasadena Municipal Code [PMC]) and amended in Section 14.04.258 by adding the following: “4. The use of wood on the exterior side of exterior walls shall be prohibited in the Extreme, high and moderate fire hazard severity zones as identified by the Pasadena Fire Department”.

California Health and Safety Code (Sections 7050.5, 7051, and 7054) Sections 7050.5, 7051, and 7054 of the California Health and Safety Code collectively address the illegality of interference with human burial remains (except as allowed under applicable sections of the California Public Resources Code [PRC]). These sections also address the disposition of Native American burials in archaeological sites and protect such remains from disturbance, vandalism, or inadvertent destruction. Procedures to be implemented are established for (1) the discovery of Native American skeletal remains during construction of a project; (2) the treatment of the remains prior to, during, and after evaluation; and (3) reburial.

Section 7050.5 of the California Health and Safety Code specifically provides for the disposition of accidentally discovered human remains. Section 7050.5 states that if human remains are Affinity Project Draft EIR

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found, no further excavation or disturbance of the site or any nearby area reasonably suspected to overlie adjacent remains shall occur until the County Coroner has determined the appropriate treatment and disposition of the human remains.

California Public Resources Code (Section 5097.98)
Section 5097.98 of the PRC states that, if remains are determined by the Coroner to be of Native American origin, the Coroner must notify the NAHC within 24 hours. When the NAHC receives this notification from a County Coroner, it shall immediately notify those persons it believes to be most likely descended from the deceased Native American. The descendants may, with the permission of the owner of the land or his or her authorized representative, inspect the site of the remains and may recommend to the owner or the person responsible for the excavation work means for treatment or disposition, with appropriate dignity, of the human remains and any associated grave goods. The descendants shall complete their inspection and make recommendations or preferences for treatment within 48 hours of being granted access to the site. This regulation also requires that, upon the discovery of Native American remains, the landowner shall ensure that the immediate vicinity, according to generally accepted cultural or archaeological standards or practices, where the Native American human remains are located, is not damaged or disturbed by further development activity until the landowner has discussed and conferred with the most likely descendants regarding their recommendations and all reasonable options regarding their preferences for treatment. This section of the PRC has been incorporated into Section 15064.5(e) of the State CEQA Guidelines.

City
Mills Act
The Mills Act (Sections 50280 et. seq. of the California Government Code) grants participating local agencies (cities and counties) the authority to contract with the owners of qualified historical properties, pursuant to the CHBC (discussed above), who actively participate in the rehabilitation, restoration, and/or maintenance their historic property while receiving property tax relief. While State law enacted the Mills Act, the program is administered by local governments, which establish their own criteria and determine how many contracts to allow in their jurisdiction.

The City of Pasadena adopted the “Historic Property Contract Program” to establish the procedures and guidelines to receive financial incentives for designating, rehabilitating, or protecting historic buildings.

City of Pasadena Historic Preservation Ordinance
The City of Pasadena has established an historic preservation program to promote “the identification, evaluation, rehabilitation, adaptive use, and restoration of historic structures.” The criteria for the designation of historic monuments, landmarks, historic signs, landmark trees, or landmark districts are applied “according to applicable National Register of Historic Places Bulletins for evaluating historic properties”. These criteria are excerpted, below, from Section

17.62.040 of the PMC.

Historic Monuments
A historic monument shall include all historic resources previously designated as historic treasures before adoption of [Zoning Code Chapter 17.62] in 2002, historic resources that are listed in the National Register at the State-wide or federal level of significance (including National Historic Landmarks) and any historic resource that is significant at a regional, State, or federal Affinity Project Draft EIR

3.2-10 Cultural and Paleontological Resources
level, and is an exemplary representation of a particular type of historic resource and meets one or more of the following criteria:
a) It is associated with events that have made a significant contribution to the broad patterns of the history of the region, State, or nation.
b) It is associated with the lives of persons who are significant in the history of the region, State, or nation.
c) It is exceptional in the embodiment of the distinctive characteristics of a historic resource property type, period, architectural style, or method of construction, or that is an exceptional representation of the work of an architect, designer, engineer, or builder whose work is significant to the region, State, or nation, or that possesses high artistic values that are of regional, State-wide, or national significance. d) It has yielded, or may be likely to yield, information important in prehistory or history of the region, State, or nation.

A historic monument designation may include significant public or semi-public interior spaces and features.

Landmarks
A landmark shall include all properties previously designated a landmark before adoption of [Zoning code Chapter 17.62] in 2002 and any historic resource that is of a local level of significance and meets one or more of the criteria listed below.

A landmark may be the best representation in the City of a type of historic resource or it may be one of several historic resources in the City that have common architectural attributes that represent a particular type of historic resource. A landmark shall meet one or more of the following criteria:
a) It is associated with events that have made a significant contribution to the broad patterns of the history of the City.
b) It is associated with the lives of persons who are significant in the history of the City. c) It embodies the distinctive characteristics of a type, architectural style, period, or method of construction, or represents the work of an architect, designer, engineer, or builder whose work is of significance to the City or possesses artistic values of significance to the City.
d) It has yielded, or may be likely to yield, information important locally in prehistory or history.

Historic Signs
A historic sign shall include all signs in the sign inventory as of the date of adoption of the Zoning Code and any sign subsequently designated historically significant by the Historic Preservation Commission that possesses high artistic values. A historic sign shall meet one or more or the following criteria:
a) The sign is exemplary of technology, craftsmanship or design of the period when it was constructed, uses historic sign materials and means of illumination, and is not significantly altered from its historic period. Historic sign materials shall include metal or wood facings, or paint directly on the façade of a building. Historic means of illumination shall include incandescent light fixtures or neon tubing on the exterior of the sign. If the sign has been altered, it must be restorable to its historic function and appearance.

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b) The sign is integrated with the architecture of the building. c) A sign not meeting criteria a or b above may be considered for inclusion in the inventory if it demonstrates extraordinary aesthetic quality, creativity, or innovation.

All other regulations relating to signs shall comply with Chapter 17.48 (Signs).

Landmark Trees
A tree shall qualify to be of historic or cultural significance and of importance to the community if it meets any one of the following criteria:

1. It is one of the largest or oldest trees of the species located in the City;

2. It has historical significance due to an association with a historic event, person, site, street, or structure; or

3. It is a defining landmark or significant outstanding feature of a neighborhood.

Landmark Districts
A landmark district shall include all landmark districts previously designated before adoption of this Chapter and any grouping of contiguous properties that also meet the following criteria:
a) Within its boundaries, a minimum of 60 percent of the properties qualify as contributing; and
b) The grouping represents a significant and distinguishable entity of Citywide importance and one or more of a defined historic, cultural, development and/or architectural context(s) (e.g., 1991 Citywide historic context, as amended, historic context prepared in an intensive level survey or historic context prepared specifically for the nominated landmark district).

When considering applications to designate a landmark district, the Historic Preservation Commission shall use the National Register of Historic Places Bulletin #21: “Defining Boundaries for National Register Properties.”

3.2.3 THRESHOLDS OF SIGNIFICANCE
The following significance criteria are derived from Appendix G of the State CEQA Guidelines. A project would result in a significant adverse cultural and paleontological resources impact if it would:

Threshold 3.2a: Cause a substantial adverse change in the significance of a historical resource pursuant to Section 15064.5;
Threshold 3.2b: Cause a substantial adverse change in the significance of an archaeological resource pursuant to Section 15064.5;
Threshold 3.2c: Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature.

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The Initial Study (provided in Appendix A-1) concluded the following threshold related to cultural resources was determined to result in less than significant impacts and was not carried forward into the Draft EIR for further analysis:
 Would the project result disturb any human remains, including those interred outside of formal cemeteries?

3.2.4 METHODOLOGY
An Historical Resource Assessment for the Project site was prepared by PaleoWest and dated January 14, 2022 (Appendix C-1). As discussed previously, Psomas conducted an archaeological records search on July 24, 2020 at the SCCIC at California State University, Fullerton; submitted a request to the NAHC for a Sacred Lands File search on July 10, 2020, the results were received on July 15, 2020 (Appendix C-2); submitted a request to the NHM for a paleontological resource record search on December 16, 2020, the results were received on December 25, 2020 (Appendix C-3); and initiated Native American consultation consistent with AB 52 on May 28, 2020. The records search results were reviewed by a Registered Professional Archaeologist and combined with the findings of the Historical Resource Assessment, considered in the analysis of potential impacts to historic, archaeological, and paleontological resources.

3.2.5 ENVIRONMENTAL IMPACTS
Threshold 3.2a: Would the Project cause a substantial adverse change in the significance of a historical resource pursuant to Section 15064.5? Project
The buildings at 491, 495, 499, 503, and 541 South Arroyo Parkway were evaluated for historical significance by applying the criteria of the CRHR and the Local Register using data gathered during the pedestrian survey and information acquired through historical research. PaleoWest recommends that the buildings at 491, 495, 499, 503, and 541 South Arroyo Parkway are not eligible for inclusion in the CRHR or the Local Register. PaleoWest concurs with the previous recommendation that the buildings at 501 and 523 South Arroyo Parkway are eligible for the Local Register and observed no changes that would compromise that assessment. Further, PaleoWest recommends that the buildings at 501 and 523 South Arroyo Parkway are locally eligible for the CRHR under Criterion C. Therefore, both buildings at 501 South Arroyo Parkway and 523 South Arroyo Parkway are historical resources for the purposes of CEQA (PaleoWest 2022, Appendix C-1).

Collectively, the buildings located at 491, 495, 499, 501, 503, 523, and 541 South Arroyo Parkway (referred to herein as the South Arroyo Parkway Industrial District) were evaluated to determine if they represent a potential historic district due to the timing of their construction and original development of industrial uses along a railroad and near downtown Pasadena. PaleoWest’s analysis of the South Arroyo Parkway Industrial District included determining if it is locally eligible for the CRHR under Criterion A and as a City Landmark District. The analysis found that the district does not retain sufficient integrity to convey its historical significance. The buildings have been modified over time to accommodate their current use as commercial buildings. These modifications have led to a loss of historic material and have fundamentally changed the use and design of the buildings. Buildings that were constructed during the period of significance of the potential district, have been substantially altered over time, fragmenting the association of the extant buildings with their interrelated historical use, and compromising the integrity of setting, feeling, and association. Therefore, the South Arroyo Parkway Industrial District is not a historical resource for the purposes of CEQA (PaleoWest 2022, Appendix C-1).

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3.2-13 Cultural and Paleontological Resources
As determined in the Historic Resources Assessment, the Project site contains two historic resources: the buildings at 501 and 523 South Arroyo Parkway. Based on available plans, the Project would not involve the physical destruction of the buildings at 501 and 523 South Arroyo Parkway, nor would it result in any significant internal or external physical modifications that would compromise the historic integrity of the buildings. The Project would change the setting, but those changes would not physically alter the buildings and are not substantial enough to compromise the overall historic integrity or obstruct the view of the buildings from the public right-of-way. The surrounding area has been modified over time by new construction and modifications to existing buildings, including the construction of multi-story buildings, which has resulted in the disruption of the historical setting. Therefore, the Project would not result in a substantive adverse change to the historic integrity of the buildings at 501 and 523 South Arroyo Parkway.

While the current Project description would not result in a substantive adverse change to the historic integrity of the buildings at 501 and 523 South Arroyo Parkway, the potential for future internal and external modifications to them does exist in the form of tenant improvements.

However, the City’s existing design review process, established in Zoning Code Section

17.61.030, requires a finding of consistency with the SOI’s Standards to approve any proposed exterior changes to historical buildings within the Central District. Therefore, mitigation measure (MM) CUL-1 requires that the Project Applicant engage with a licensed architect and/or engineer that meets the SOI’s Professional Qualifications Standards to develop a series of protection interventions and protocols that would preserve the two historical resources on the Project site – 501 and 523 South Arroyo Parkway – during construction activities. These protocols shall take into consideration the protection of and security of both resources, particularly the preservation of the character-defining features through the installation of physical protective barriers around each resource and the creation of site protocols that will eliminate the potential for physical damage resulting from impacts associated with construction and transport of equipment.

The potential for vibration to cause damage to the buildings at 501 and 523 South Arroyo Parkway is addressed in Section 3.7, Noise, of this Draft EIR. The most damaging sources of vibrations include blasting and pile driving. The Project’s construction would not include blasting or pile driving; therefore, vibrations from these particularly damaging activities would not impact the buildings at 501 and 523 South Arroyo Parkway. However, there is potential for some construction equipment that would be used on the site to cause cosmetic damage to these buildings because of vibration. Implementation of MM NOI-1, which outlines setbacks for operation of vibrationcausing construction equipment, would reduce the potential for cosmetic damage to these two buildings to a less than significant level.

Implementation of MM CUL-1 would ensure that potential tenant improvements associated with this Project do not result in a significant impact on the identified historical buildings. The Project is not expected to cause a substantial adverse change in the significance of a historical resource as defined in Section 15064.5.

Project with Building A Residential/Commercial
The analysis of historical resources for the Project with Building A Residential/Commercial would be the same as that of the Project, as both buildings at 501 South Arroyo Parkway and 523 South Arroyo Parkway are planned to be preserved and integrated into the site development in the same way as the Project. Therefore, the Project with Building A Residential/Commercial would not involve the physical destruction of 501 South Arroyo Parkway and 523 South Arroyo Parkway, nor would it result any significant physical modifications that would comprise the historic integrity of the buildings. Through implementation of MM CUL-1, tenant improvements to 501 and 523 South Arroyo Parkway would result in less than significant impacts to a documented historical resource. As with the Project, the Project with Building A Residential/Commercial would not compromise the overall historic integrity of, nor obstruct the public view of, the historic buildings.

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3.2-14 Cultural and Paleontological Resources
As discussed for the Project, the potential for vibration to cause damage to the buildings at 501 and 523 South Arroyo Parkway is addressed in Section 3.7, Noise, of this Draft EIR.

Implementation of MM NOI-1, which outlines setbacks for operation of vibration-causing construction equipment, would reduce the potential for cosmetic damage to these two buildings to a less than significant level. Therefore, with implementation of MMs CUL-1 and NOI-1, the Project with Building A Residential/Commercial is not expected to cause a substantial adverse change in the significance of a historical resource as defined in Section 15064.5.

Threshold 3.2b: Would the Project cause a substantial adverse change in the significance of an archaeological resource pursuant to Section 15064.5?
Project
There are no known archaeological resources within the Project site; additionally, no known archaeological resources are within ½-mile of the Project site (Appendix C-2). However, the Project site is located within a region of California that has evidence for human occupation dating back several thousand years as noted by the positive SLF results for sacred sites located near the Project site. Thus, archaeological resources have the potential to be present in native sediments beneath the Project site. Therefore, the potential to encounter previously unidentified archaeological resources is a potentially significant impact. This impact would be reduced to a less than significant level with implementation of MM CUL-2, which requires attendance by a qualified archaeologist at the pre-grade conference and identifies actions to take in the event that cultural resources (i.e., prehistoric sites, historic sites, and/or isolated artifacts) are discovered.

Project with Building A Residential/Commercial
The Project with Building A Residential/Commercial would have one less level of subterranean parking spanning both proposed buildings. However, the possibility of unknown, intact archaeological resources being present in native sediments beneath the Project site remains the same as the Project. Therefore, with implementation of MM CUL-2, there would be a less than significant impact related to encountering unknown archaeological resources.

Threshold 3.2c: Would the Project directly or indirectly destroy a unique paleontological resource or site or unique geologic feature? Project
No unique geologic features are known to exist, and no fossils have been documented on the Project site. The City’s General Plan EIR states that “Although Quaternary Old Alluvial Deposits [such as those beneath the site] in general have the potential to yield fossils, the paleontological sensitivity in these areas of the City is considered low due to its proximity to the mountains to the north. Since the older Quaternary alluvial sediments are close to the sediment source, the uppermost layers of these deposits are likely too coarse-grained to preserve fossils. However, abundant fossils occur in the Topanga Formation. The Topanga Formation is in the southwesternmost portions of the City and near the South Fair Oaks specific plan area. Grading and excavations deeper than six feet into the Topanga Formation have the potential to impact significant fossils” (Pasadena 2015). Accordingly, the City requires monitoring for projects that could excavate within the Topanga Formation; however, the Project would not involve excavation in the Topanga Formation. There would be less than significant impacts related to paleontological resources, and no mitigation is required.

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3.2-15 Cultural and Paleontological Resources
Project with Building A Residential/Commercial
The Project with Building A Residential/Commercial would have one less level of subterranean parking spanning both proposed buildings. As discussed for the Project, the Project with Building A Residential/Commercial would not involve excavation in the Topanga Formation, which has potential to yield significant paleontological resources. There would be a less than significant impacts related to encountering unknown archaeological resources, and no mitigation is required.

3.2.6 CUMULATIVE IMPACTS
Project
Although cultural resources are site-specific regarding any given resource (e.g., resources of important cultural value to Native Americans and the history of California), impacts may be considered cumulative simply because they relate to the loss of cultural resources in general over time throughout the region. Historic structures that may be altered or demolished in and near the City could affect the cultural significance of an individual site or the structure, as well as incrementally diminish the City’s historical context. As noted above, the buildings at 501 and 523 South Arroyo Parkway are eligible for the Local Register and eligible for the CRHR under Criterion C; however, the Project is not expected to cause a substantial adverse change in the significance of either resource as defined in Section 15064.5 with implementation of MM CUL-1.

Compliance with CEQA and the City’s Historic Preservation Ordinance would prevent significant adverse impacts on historical resources in the City and avoid a cumulative contribution to the loss of historical resources during development throughout the City pursuant to the General Plan.

Implementation of MM NOI-1, which outlines setbacks for operation of vibration-causing construction equipment, would reduce the potential for cosmetic damage to these two buildings to a less than significant level. Therefore, the Project would not result in a cumulatively considerable impact to historical resources.

Regarding archaeological resources, there are no known resources listed or determined eligible for listing on the Project site. Implementation of MM CUL-2, consistent with the City’s General Plan, would reduce potential impacts to archaeological resources to a less than significant level.

The City requires implementation of this mitigation where there is potential to encounter unknown cultural resources, as appropriate, thereby avoiding a cumulative contribution to the loss of archaeological resources during development throughout the City pursuant to the General Plan.

The Project site is not located in the portions of the City considered to be paleontologically sensitive. Therefore, the Project would not result in a cumulatively considerable impact to archaeological and paleontological resources.

Project with Building A Residential/Commercial
The cumulative analysis of the Project with Building A Residential/Commercial would be the same as that of the Project. The Project with Building A Residential/Commercial is not expected to cause a substantial adverse change in the significance of either resource as defined in Section 15064.5 with implementation of MM CUL-1. Compliance with CEQA and the City’s Historic Preservation Ordinance would prevent significant adverse impacts on historical resources in the City and avoid a cumulative contribution to the loss of historical resources during development throughout the City pursuant to the General Plan EIR. Implementation of MM NOI-1, which outlines setbacks for operation of vibration-causing construction equipment, would reduce the potential for cosmetic damage to the two buildings to a less than significant level. Therefore, the Project with Building A Residential/Commercial would not result in a cumulatively considerable impact to historical resources.

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3.2-16 Cultural and Paleontological Resources
The more limited excavation associated with one less level of subterranean parking would not reduce the possibility of unknown, intact archaeological resources being present in native sediments beneath the site. The City requires implementation of this mitigation (herein MM CUL-2) where there is potential to encounter unknown cultural resources, as appropriate, thereby avoiding a cumulative contribution to the loss of archaeological resources during development throughout the City pursuant to the General Plan. The site is not located in the portions of the City considered to be paleontologically sensitive. Therefore, the Project with Building A Residential/Commercial would not result in a cumulatively considerable impact to archaeological and paleontological resources.

3.2.7 MITIGATION MEASURES
MM CUL-1 To the satisfaction of the City, the Project Applicant shall engage with a licensed architect and/or engineer that meets the Secretary of the Interior’s Professional Qualifications Standards for historic architect to develop a series of protection interventions and protocols that will preserve the two historical resources on the Project site – 501 and 523 South Arroyo Parkway – during all construction activities in, on, and near these two buildings. These measures shall take into consideration the protection of and security of both resources, particularly the preservation of the character-defining features through the installation of physical protective barriers around each resource and the creation of site protocols that will eliminate the potential for physical damage resulting from impacts with construction and transport equipment.

To ensure the protection of these resources and their character-defining features, all protective barriers (which shall be installed prior to the initiation of any construction activity) and protocols shall be compliant with the Secretary of the Interior’s Standards for Rehabilitation and Guidelines for Rehabilitating Historic Buildings (Weeks and Grimmer 1995) (Standards) and be subject to review and approval by the City planning staff.

Site protocols for protecting the historical resources shall outline issues related to site access and navigation by contractors and construction personnel to reduce the potential for any inadvertent accidents between equipment and the two on-site historical resources. Additionally, a series of emergency measures shall be developed that outlined specific step-by-step processes in the event that an accident involves one of the historical resources. This will likely include the following:
1) Stop-work protocols after an accident involving a historical resource occurs,
2) Notification procedures and identification key contacts, 3) Identification of qualified historic preservation professionals to investigate the historical resources following the determination that the area is safe, 4) Thorough conditions assessment of the resource by the qualified consultant to ascertain the level and extent of the damage, and 5) Preparation of a historical resource treatment plan to stabilize the historical resource and address the damage, which will be submitted to City staff for review and approval prior to completing the work and resumption of construction activities.

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Additionally, protocols shall include regular on-site monitoring during construction activities by historic preservation consultant, either a SOI Qualified historic architect or architectural historian. The historic preservation consultant shall document the existing conditions of each resource prior to the initiation of any construction activity and prior to installation of the protective barriers and implementation of the protection protocols. This documentation phase will include high resolution digital photographs of each facade, as well as details of characterdefining features for each resource. During construction, the historic preservation consultant shall prepare field report memoranda to the City confirming that the Standards compliant protection barriers are installed in accordance with the Standards, and that agreed upon protocols are being followed throughout the course of the Project. These memoranda will be submitted to City staff for their records and review. A final report outlining the conditions of the historical resources prior, during, and following the Project’s construction shall be issued to the City for approval following construction activities and prior to the issuance of a Certificate of Occupancy.

MM CUL-2 If cultural resources are discovered during construction of land development projects in Pasadena that may be eligible for listing in the California Register for Historic Resources, all ground disturbing activities in the immediate vicinity of the find shall be halted until the find is evaluated by a Registered Professional Archaeologist. If testing determines that significance criteria are met, then the project shall be required to perform data recovery, professional identification, radiocarbon dates as applicable, and other special studies; and provide a comprehensive final report including site record to the City and the South-Central Coastal Information Center at California State University Fullerton. No further grading shall occur in the area of the discovery until Planning Department approves the report.

3.2.8 LEVEL OF SIGNIFICANCE AFTER MITIGATION
The mitigation measures identified above would reduce potential impacts associated with historic and archaeological resources to a less than significant level. There would be less than significant impacts related to paleontological resources, and no mitigation is required. Therefore, no significant and unavoidable impacts relating to cultural resources have been identified.

3.2.9 SUMMARY OF ANALYSIS
Project
Based on the Historical Resource Assessment prepared for the Project site, the buildings at 501 and 523 South Arroyo Parkway are historical resources for the purposes of CEQA (PaleoWest 2022, Appendix C-1). While the Project’s tenant improvements do not anticipate demolishing, moving, or making major alterations to these historic resources, these plans remain conceptual and have not yet been finalized. Therefore, there may be a potential for impact and MM CUL-1 would be required to ensure that any alterations to these two structures meet the SOI’s Standards.

The potential for vibration to cause damage to the buildings at 501 and 523 South Arroyo Parkway is addressed in Section 3.7, Noise, of this Draft EIR. Implementation of MM NOI-1, which outlines setbacks for operation of vibration-causing construction equipment, would reduce the potential for cosmetic damage to these two buildings to a less than significant level. With implementation of MMs CUL-1 and NOI-1, there would be a less than significant impact to historical resources.

There are no known archaeological or paleontological resources on the Project site. However, based on the results on the cultural resources records searches conducted for the Project site Affinity Project Draft EIR

3.2-18 Cultural and Paleontological Resources
and vicinity (Appendices C-2), unknown archaeological resources have potential to be present in native sediments beneath the Project site. Therefore, MM CUL-2, which is consistent with the City’s General Plan EIR, would be required. With implementation of MM CUL-2, the Project would result in less than significant impacts related to archaeological resources. The Project site is not located in the portions of the City considered to be paleontologically sensitive. Therefore, there would be less than significant impacts related to paleontological resources, and no mitigation is required.

Project with Building A Residential/Commercial
The analysis of cultural resources for the Project with Building A Residential/Commercial would be the same as that of the Project regarding the documented historic resources (501 and 523 South Arroyo Parkway). The more limited excavation associated with one less level of subterranean parking would not reduce the possibility of unknown, intact archaeological resources being present in native sediments beneath the site. With implementation of MMs CUL1, CUL-2, and NOI-1, the Project with Building A Residential/Commercial would result in less than significant impacts related to historic and archaeological resources. The site is not located in the portions of the City considered to be paleontologically sensitive. Therefore, there would be less than significant impacts related to paleontological resources, and no mitigation is required.

3.2.10 REFERENCES
PaleoWest, LLC. (PaleoWest). 2022 (January 14). Historical Resource Assessment Report of the Affinity Project, Pasadena, Los Angeles County, California. San Diego, CA: PaleoWest.

Appendix C-1.

Pasadena, City of. 2015 (January). Pasadena General Plan Draft Environmental Impact Report Volume I. Pasadena, CA: the City. General-Plan_Draft-EIR_2015-01.pdf (cityofpasadena.net).

Weeks (K.D.) and Grimmer (A.E.). 2017. The Secretary of the Interior’s Standards for the Treatment of Historic Properties with Guidelines for Preserving, Rehabilitating, Restoring and Reconstructing Historic Buildings. Washington, D.C.: 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 (nps.gov).

Affinity Project Draft EIR

3.3-1 Energy

3.3 ENERGY

3.3.1 EXISTING CONDITIONS
The Project site consists of five parcels developed with a total of nine commercial buildings with seven businesses with an existing building area of 125,465 square feet (sf). These existing uses consume electricity as well as natural gas for space heating and cooking needs. Depending on when these buildings were built or renovated, they would have complied with the energy efficiency standards that were adopted at that time.

3.3.2 RELEVANT PROGRAMS AND REGULATIONS
Federal
The Office of Energy Efficiency and Renewable Energy’s (EERE) mission is to accelerate the research, development, demonstration, and deployment of technologies and solutions to equitably transition America to net-zero greenhouse gas emissions economy-wide by no later than 2050, and ensure the clean energy economy benefits all Americans, creating good paying jobs for the American people—especially workers and communities impacted by the energy transition and those historically underserved by the energy system and overburdened by pollution (EERE 2021).

EERE’s work will involves the four principles:
 Building the clean energy economy in a way that benefits all Americans. We must address environmental injustices that disproportionately affect communities of color, low-income communities, and indigenous communities.
 Fostering a diverse science, technology, engineering, and math (STEM) workforce. We need to increase awareness of clean energy job opportunities at minority-serving institutions and ensure that organizations receiving EERE funding are thinking through diversity and equity in their own work.
 Developing more robust workforce training opportunities to build a pipeline for permanent, good-paying jobs for the clean energy workforce.
 Working closely and learning from state and local governments.

State
Title 24 Energy Efficiency Standards
The Energy Efficiency Standards for Residential and Nonresidential Buildings (Title 24, Part 6 of the California Code of Regulations [CCR]) were established in 1978 in response to a legislative mandate to reduce California’s energy consumption. The currently applicable standards are the 2019 Standards, effective January 1, 2020. The 2019 standards focus on four key areas: smart residential photovoltaic systems, updated thermal envelope standards (preventing heat transfer from the interior to exterior and vice versa), residential and nonresidential ventilation requirements, and nonresidential lighting requirements. The ventilation measures improve indoor air quality, protecting homeowners from air pollution originating from outdoor and indoor sources (California Energy Commission [CEC] 2021). The requirements of the energy efficiency standards result in the reduction of natural gas and electricity consumption. Both natural gas and electricity use produce GHG emissions. The goal of the standards is to reduce energy use in new homes by more than 50 percent.The 2019 standards require that there is sufficient on-site electricity generation to meet the annual electricity usage for low rise residential buildings. A 30 percent Affinity Project Draft EIR

3.3-2 Energy
reduction in energy uses is anticipated for nonresidential uses. The requirement for low-rise residential buildings to develop onsite electricity generation is consistent with the goal to develop renewable sources of energy.

The CEC adopted the 2008 changes to the Building Energy Efficiency Standards in order to (1) “Provide California with an adequate, reasonably-priced, and environmentally-sound supply of energy” and (2) “Respond to Assembly Bill 32, the Global Warming Solutions Act of 2006, which mandates that California must reduce its greenhouse gas emissions to 1990 levels by 2020”.

Additionally, it has been California policy that all new residential buildings will be zero net energy (ZNE) by 2020 and new commercial buildings will be ZNE by 2030, as described in the 2008 California Public Utilities Commission (CPUC) long-term energy efficiency strategic plan. In 2013, the CEC, in coordination with the CPUC, commenced a process to update the Title 24 energy efficiency standards and, the 2016 Title 24 Energy Efficiency Standards establish building design and construction requirements that move closer to achieving California’s ZNE goals. The requirements of the energy efficiency standards result in the reduction of natural gas and electricity consumption. Both natural gas use and electricity generation result in GHG emissions.

California Green Building Standards Code
The 2019 California Green Building Standards Code (24 CCR, Part 11), also known as the CALGreen code, contains mandatory requirements and voluntary measures for new residential and nonresidential buildings (including buildings for retail, office, public schools and hospitals) throughout California). The development of the CALGreen Code is intended to improve public health, safety, and general welfare by enhancing the design and construction of buildings through the following construction practices: (1) planning and design; (2) energy efficiency; (3) water efficiency and conservation; (4) material conservation and resource efficiency; and (5) environmental quality. In short, the code is established to reduce construction waste; make buildings more efficient in the use of materials and energy; and reduce environmental impact during and after construction.

Senate Bills 1078, 107, and SBX1-2 (Renewable Portfolio Standards) Established in 2002 under SB 1078, accelerated in 2006 under SB 107, and again in 2011 under SBX1-2, California’s Renewable Portfolio Standard (RPS) requires retail sellers of electric services to increase procurement from eligible renewable energy resources to 33 percent of total retail sales by 2020. Initially, the RPS provisions applied to investor-owned utilities, community choice aggregators, and electric service providers. SBX1-2 added, for the first time, publicly owned utilities to the entities subject to RPS.

Senate Bill 100
On September 10, 2018, Governor Brown signed SB 100, the 100 Percent Clean Energy Act of 2018. SB 100 requires renewable energy and zero-carbon resources to supply 100 percent of electric retail sales to end-use customers and 100 percent of electricity procured to serve state agencies by December 31, 2045. This policy requires the transition to zero-carbon electric systems that do not cause contributions to increase of GHG emissions elsewhere in the western electricity grid (CEC 2021b). SB 100 also creates new standards for the RPS goals established by SB 350 in 2015. Specifically, the bill increases required energy from renewable sources for both investor-owned utilities and publicly owned utilities from 50 percent to 60 percent by 2030.

City Green Building Ordinance
The City green building ordinance is Municipal Code Sections 14.04.500 through 14.04-511 (as amended). The ordinance incorporates the 2019 CALGreen and 2019 Building and Energy Affinity Project Draft EIR

3.3-3 Energy
Efficiency Standards. Under the ordinance, nonresidential development that is over 25,000 square feet would be subject to the mandatory Tier 1 CALGreen standards, and nonresidential development over 50,000 square feet would be subject to the mandatory Tier 2 CALGreen standards (Section 14.04.504).

City of Pasadena Green City Action Plan
The City of Pasadena developed and adopted the Green City Action Plan on September 18, 2006 (Pasadena 2006). The plan, which contains various actions and goals applicable on a local level, was prepared to create a more sustainable City capable of meeting growing demand and reducing impacts to natural resources. There are seven focus areas within the plan: (1) Energy, (2) Waste Reduction, (3) Urban Design, (4) Urban Nature, (5) Transportation, (6) Environmental Health, and (7) Water. Each of these focus areas contains actions and goals.

A partial list of these actions and goals related to energy that are applicable to the Project and Project with Building A Residential/Commercial is shown below:
 Action 2: Reduce the city’s peak electric load by 10 percent within seven years through energy efficiency, shifting the timing of energy demands and conservation measures.  Action 8: Advance higher density, mixed use, walkable, bikeable, and disabled accessible neighborhoods which coordinate land use and transportation with open space systems for recreation and ecological restoration.
 Action 13: Expand affordable public transportation coverage to within ½ kilometer of all city residents in ten years.
 Action 15: Implement a policy to reduce the percentage of commute trips by single occupancy vehicles by 10 percent in seven years.

3.3.3 THRESHOLDS OF SIGNIFICANCE
The following significance criteria are derived from Appendix G of the State CEQA Guidelines. A project would result in a significant adverse energy impact if it would:

Threshold 3.3a: Result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation; and/or
Threshold 3.3b: Conflict with or obstruct a State or local plan for renewable energy or energy efficiency.

3.3.4 METHODOLOGY
Energy consumption was calculated for the construction and operations phases of the Project and the Project with Building A Residential/Commercial. Fuel consumption from construction worker, vendor, and delivery/haul trucks as well as operations phase vehicle trips were calculated using the trip rates and distances provided in the CalEEMod construction output files, as provided in Appendix B, Air Quality and Greenhouse Gas Emissions Modeling Data, of this Draft EIR.

Operations phase trip generation and trip lengths were provided within the City’s traffic analysis, provided in Appendix G-1, Transportation Impact Analysis/CEQA Evaluation for Project, and Appendix G-2, Transportation Impact Analysis/CEQA Evaluation for Project with Building A Residential/Commercial. Total vehicle miles traveled (VMT) were then calculated for each type of construction and operations-related trips and divided by the corresponding miles per gallon factor using CARB’s EMissions FACtor (EMFAC) 2017 model. EMFAC provides the total annual VMT Affinity Project Draft EIR

3.3-4 Energy
and fuel consumed for each vehicle type. Utility-related energy consumption was estimated and provided by the Applicant. The inputs and data for the modeling are provided in Appendix D, Energy Modeling Data.

3.3.5 ENVIRONMENTAL IMPACTS
Threshold 3.3a: Would the Project result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation? Project
Construction
Construction of the Project would require the use of construction equipment for grading and building activities; all off-road construction equipment is assumed to use diesel fuel.

Transportation energy use depends on the type and number of trips, VMT, fuel efficiency of vehicles, and travel mode. During construction, transportation energy would be used for the transport and use of construction equipment, from delivery vehicles and haul trucks, and from construction employee vehicles that would use gasoline and/or diesel fuel. The use of these energy resources fluctuates according to the phase of construction and would be temporary.

Table 3.3-1, Construction-Related Energy Use for the Project, quantifies anticipated energy use during construction activities of the Project. The use of these energy resources fluctuates according to the phase of construction and would be temporary.

TABLE 3.3-1

CONSTRUCTION-RELATED ENERGY USE FOR THE PROJECT
Source
Gasoline Fuel
(gallons)
Diesel Fuel
(gallons)
Off-road Construction Equipment 59,671 71,430
Worker commute 57,735 274
Vendors 1,253 21
On-road haul 22 18,937
Total 118,682 90,662
Source: Energy data can be found in Appendix D, Energy Modeling Data.

Construction energy use could be considered wasteful, inefficient, or unnecessary if construction equipment is not well-maintained such that its energy efficiency is substantially lower than newer equipment; if equipment idles even when not in use; if construction trips utilize longer routes than necessary; or if excess electricity and water1 are used during construction activities. Pursuant to the Title 13, Section 2485 of California Code of Regulations, all diesel-fueled commercial motor vehicles must not idle for more than five consecutive minutes at any location. Mandatory compliance would reduce fuel use by construction vehicles. Fuel energy consumed during construction would also be temporary in nature, and there are no unusual Project characteristics that would necessitate the use of construction equipment that would be less energy-efficient than at comparable construction sites in other parts of the region or State. Short-term energy usage for construction of the Project would result in long-term energy savings from newly constructed buildings that are compliant with the current Title 24 CALGreen code. As such, energy use associated with construction of the Project would not result in significant impacts related to 1 Indirect energy use for the extraction, treatment, and conveyance of water.

Affinity Project Draft EIR

3.3-5 Energy
wasteful, inefficient, or unnecessary consumption of energy resources. There would be a less than significant impact, and no mitigation is required.

Operation
The Project would promote building energy efficiency through compliance with energy efficiency standards (Title 24 Energy Efficiency Standards and CALGreen). Development of the Project is required to comply with the latest building energy efficiency standards adopted by the State and the City at the time of Project implementation. Mobile source energy consumption is based on estimated Project-related trip generation forecast of 6,366 daily trips, as provided in the Project Transportation Impact Analysis – Outside of CEQA Analysis (Pasadena DOT 2021a) and the VMT assumptions for the Project’s trips (Pasadena DOT 2020; Appendix G-1). The energy use for the Project also includes the anticipated electrical demand, natural gas demand, and mobile trips for the conversion of the two historic buildings to commercial uses, which are assumed to be restaurant for the purposes of this Draft EIR. The estimated energy consumption attributable to the Project as calculated by CalEEMod is shown in Table 3.3-2, Energy Use During Operation of the Project, below.

TABLE 3.3-2

ENERGY USE DURING OPERATION OF THE PROJECT
Land Use
Gasoline
(gallons/yr)
Diesel
(gallons/yr)
Natural Gas
(kBTU/yr)
Electricity
(kWh/yr)
Project Land Uses 211,629 4,226 5,543,466 5,678,570
kBTU: kilo-British thermal units; kWh: kilowatt hour; yr: year Source: Energy data can be found in Appendix D, Energy Modeling Data.

Adherence to the 2019 Building Energy Efficiency Standards would result in a reduction of energy use as compared to previous energy standards (CEC 2021). The reduction in energy use intensity typically consisted of upgrades to higher efficiency equipment and improved building automation, lighting controls, and sequences of operations. The CEC states that the 2019 energy efficiency standards are projected to result in a 30 percent improvement in energy efficiency over the 2016 standards for nonresidential buildings. Therefore, the new buildings would be more energy efficient than existing buildings that are proposed to be demolished and buildings proximate to the Project site and would be among the most energy-efficient buildings in the City.

Transportation energy use would be associated with daily trips associated with the proposed project. The Project site is within both a High-Quality Transit Area (HQTA) and Transit Priority Area (TPA). HQTAs are areas within one-half mile of a fixed guideway transit stop or a bus transit corridor where buses pick up passengers at a frequency of every 15 minutes or less during peak commuting hours. TPAs are areas within one-half mile of a major transit stop that is existing or planned. Project employees, visitors and residents of the Project site would be able to use these energy-efficient mass transit options. In addition, consistent with Title 24 requirements, the Project would be required to develop electric vehicle charging infrastructure (6 percent of nonresidential parking spaces) as well as storage and parking for bicycles (5 percent of vehicle parking spaces).

This would encourage and support the use of transportation that does not rely on gasoline and diesel fuels.

Because the Project would involve the most energy-efficient buildings required under the 2019 Title 24 Energy Efficiency Standards and would promote energy efficient transportation options by developing within a HQTA and TPA and promoting alternative-fueled vehicles, the Project Affinity Project Draft EIR

3.3-6 Energy
would not result in the inefficient, wasteful, or unnecessary consumption of energy. There would be a less than significant impact, no mitigation is required.

Project with Building A Residential/Commercial
Construction
The analysis of construction energy use and efficiency for the Project with Building A Residential/Commercial would be essentially the same as the Project. All construction assumptions for the Project with Building A Residential/Commercial would be consistent with the Project, except that grading for the subterranean garage and other areas for improvement would require 36,802 cy less soil export than the Project (for a total of 147,211 cy of soil export) and 2,685 less truckloads than the Project (for a total of 10,515 truckloads for export). Table 3.3-3, Construction-Related Energy Use for the Project with Building A Residential/Commercial, provides the anticipated energy use during construction activities.

TABLE 3.3-3

CONSTRUCTION-RELATED ENERGY USE FOR THE PROJECT WITH

BUILDING A RESIDENTIAL/COMMERCIAL
Source
Gasoline Fuel
(gallons)
Diesel Fuel
(gallons)
Off-road Construction Equipment 59,671 71,430
Worker commute 57,016 271
Vendors 1,253 21
On-road haul 17 14,969
Totals 117,958 86,691
Source: Energy data can be found in Appendix D, Energy Modeling Data.

The Project with Building A Residential/Commercial is anticipated to result in slightly less energy demand during construction than the Project. As with the Project, fuel energy consumed during construction for the Project with Building A Residential/Commercial would also be temporary in nature, and there are no unusual Project characteristics that would necessitate the use of construction equipment that would be less energy-efficient than at comparable construction sites in other parts of the region or State. Short-term energy usage for construction of the Project with Building A Residential/Commercial would result in long-term energy savings from newly constructed buildings that are compliant with the current Title 24 California Building Code. As such, energy use associated with construction of the Project with Building A Residential/Commercial would not result in significant impacts related wasteful, inefficient, or unnecessary consumption of energy resources. There would be a less than significant impact, and no mitigation is required.

Operations
The Project with Building A Residential/Commercial would promote building energy efficiency through compliance with energy efficiency standards (Title 24 and CALGreen). The development of the Project with Building A Residential/Commercial is required to comply with the latest building energy efficiency standards adopted by the State and the City at the time of Project implementation. Mobile source energy demand is based on estimated Project with Building A Residential/Commercial-related trip generation forecast of 2,494 daily trips, as contained in the Transportation Impact Analysis – Outside of CEQA Analysis prepared for the Project with Building A Residential/Commercial (Pasadena DOT 2021b) and incorporates the vehicle VMT Affinity Project Draft EIR

3.3-7 Energy
assumptions for the Project with Building A Residential/Commercial’s trips (Pasadena DOT 2021c). It should be noted that the energy use also includes the anticipated electrical demand, natural gas demand, and mobile trips for the conversion of the two historic buildings to commercial uses, as with the Project. The estimated energy consumption attributable to the Project with Building A Residential/Commercial as calculated by CalEEMod and provided by the Applicant is shown in Table 3.3-4, Energy Use During Operation of the Project with Building A Residential/Commercial, below.

TABLE 3.3-4

ENERGY USE DURING OPERATION OF THE PROJECT WITH BUILDING

A RESIDENTIAL/COMMERCIAL
Land Use
Gasoline
(gallons/yr)
Diesel
(gallons/yr)
Natural Gas
(kBTU/yr)
Electricity
(kWh/yr)
Project with Building A Residential/Commercial
Land Uses
77,747 1,606 4,497,483 5,517,728
kBTU: kilo-British thermal units; kWh: kilowatt hour; yr: year Sources: Energy data can be found in Appendix D, Energy Modeling Data.

The Project with Building A Residential/Commercial would also be required to adhere to the 2019 Building Energy Efficiency Standards which result in an improvement in energy efficiency.

Therefore, the new buildings would be more energy efficient than existing proposed to be demolished as well as buildings proximate to the Project Site and would be among the most energy efficient buildings in the City.

The Project with Building A Residential/Commercial would also be located within both a HQTA and TPA. Employees, visitors, and residents of the Project with Building A Residential/Commercial site would be able to use these energy efficient mass transit options. In addition, the Project would be required to develop electric vehicle charging infrastructure (6 percent of nonresidential parking spaces) as well as storage and parking for bicycles (5 percent of vehicle parking spaces). This would encourage and support the use of transportation that does not rely on gasoline and diesel fuels.

Because the Project with Building A Residential/Commercial would involve the most energy efficient buildings required under the 2019 Title 24 Energy Efficiency Standards and would promote energy efficient transportation options by developing within a HQTA and TPA as well as promote alternative fueled vehicles, the Project would not result in the inefficient, wasteful, or unnecessary consumption of energy. There would be a less than significant impact, and no mitigation is required.

Threshold 3.3b: Would the Project conflict with or obstruct a State or local plan for renewable energy or energy efficiency?
Project
As discussed above, strategies and measures have been implemented at the State level with the California’s Title 24 Energy Efficiency Standards for Residential and Nonresidential Buildings and the CALGreen Code. The Project would be more energy-efficient than the existing buildings in the vicinity of the site, including the buildings to be demolished. The CALGreen Code requires the development of electric vehicle charging infrastructure to promote and support alternatively fueled vehicles and bicycling. The Project would also be consistent with the City’s Green City Action Plan, by increasing energy efficiency for buildings, developing higher density, mixed-use, walkable, bikeable, and disabled-accessible neighborhoods which coordinate land use and Affinity Project Draft EIR

3.3-8 Energy
transportation. As such, the Project would not conflict with or obstruct the State or the City’s goals for energy efficiency and energy efficiency. There would be a less than significant impact, and no mitigation is required.

Project with Building A Residential/Commercial
The analysis of conflict of the Project with Building A Residential/Commercial with plans for renewable energy and energy efficiency would be the same as that of the Project. The Project with Building A Residential/Commercial would result in a lower VMT than the Project; however, both scenarios would be consistent with applicable energy-related plans and regulations. The proposed buildings would be more energy-efficient than the existing buildings in the vicinity of the site and the buildings to be demolished on site. The Project with Building A Residential/Commercial would provide electric vehicle charging infrastructure and provide bicycle parking on-site for its residents, visitors, and employees. The Project with Building A Residential/Commercial would be consistent with the City’s Green City Action Plan by increasing energy efficiency for buildings, developing higher density, mixed-use, walkable, bikeable, and disabled-accessible neighborhoods which coordinate land use and transportation. As such, the Project with Building A Residential/Commercial would not conflict with or obstruct the State or the City’s goals for energy efficiency. There would be a less than significant impact, and no mitigation is required.

3.3.6 CUMULATIVE IMPACTS
Project
The geographic area for consideration of cumulative impacts is the City. Future development throughout the City would generate additional energy demand and construction and operational fuel energy demand. Future development projects in the City would also need to comply with all applicable local and State energy efficiency and renewable energy regulations. The electrification of the transportation sector is anticipated throughout California and would contribute to reduced fuel energy use related to future development throughout the City. Also, regional (i.e., Southern California Association of Governments) planning documents support a denser land use pattern with a focus on proximity to transit. Therefore, the Project would not result in a cumulatively considerable impact related to energy.

Project with Building A Residential/Commercial
The cumulative impact analysis of energy for the Project with Building A Residential/Commercial would be the same as the cumulative impact analysis for the Project.

3.3.7 MITIGATION MEASURES
No significant impacts related to energy would occur, and no mitigation measures are necessary.

3.3.8 LEVEL OF SIGNIFICANCE AFTER MITIGATION
The Project and Project with Building A Residential/Commercial would not result in significant energy related impacts.

Affinity Project Draft EIR

3.3-9 Energy

3.3.9 SUMMARY OF ANALYSIS
Project
Construction and operation of the Project would not result in wasteful, inefficient, or unnecessary construction of energy resources, nor conflict with or obstruct the applicable State or local plans for renewable energy and energy efficiency. There would be a less than significant impacts, and no mitigation is required.

Project with Building A Residential/Commercial
The summary of findings for the Project with Building A Residential/Commercial would be comparable to the findings for the Project. This scenario would have slightly reduced excavation commensurate with one fewer subterranean level and reduced operational VMT. However, for all the same reasons as discussed for the Project, construction and operation of the Project with Building A Residential/Commercial would not result in wasteful, inefficient, or unnecessary construction of energy resources, nor conflict with or obstruct the applicable State or local plans for renewable energy and energy efficiency. There would be less than significant impacts, and no mitigation is required.

3.3.10 REFERENCES
California Energy Commission. 2021. 2019 Energy Efficiency Building Standards. Sacramento, CA: CEC. https://www.energy.ca.gov/rules-and-regulations/building-energy-efficiency Pasadena, City of. Green City Action Plan. 2006. Pasadena, CA: City of Pasadena:
https://ww5.cityofpasadena.net/planning/wp-content/uploads/sites/56/2017/07/GreenCity-Action-Plan.pdf Pasadena Department of Transportation (Pasadena DOT). 2021a (March 22). Transportation Impact Analysis, Outside of CEQA Analysis. Project Address: 491-577 South Arroyo Parkway. Demolition of approximately 46,000 sf commercial. Construction of 151,000 sf medical office, 3,000 sf commercial, 184,376 sf senior living facility consisting of 95 independent living units and 85,800 sf assisted living. 5,882 sf restaurant to remain.

Pasadena, CA: Pasadena DOT.
———.2021b (June 17). Transportation Impact Analysis, Outside of CEQA Analysis. Project Address: 491-577 South Arroyo Parkway. Project Summary: Demolition of approximately 46,000 sf commercial. Construction of 151,000 sf residential building with up to 197 units, 3,000 sf commercial, 184,376 sf senior living facility consisting of up to 95 independent living units and 85,800 sf assisted living. 5,882 sf restaurant to remain. Pasadena, CA:

Pasadena DOT.
———. 2021c (June 17). Transportation Impact Analysis, CEQA Evaluation, Project Address 491- 577 South Arroyo Parkway. Project Summary: Demolition of approximately 46,000 sf commercial. Construction of 151,000 sf residential building with up to 197 units, 3,000 sf commercial, 184,376 sf senior living facility consisting of up to 95 independent living units and 85,800 sf assisted living. 5,882 sf restaurant to remain. Pasadena, CA: Pasadena DOT. Appendix G-2.
———. 2020 (November 30). Transportation Impact Analysis, CEQA Evaluation, Category 2, Project Address 491-577 South Arroyo Parkway. Project Summary: Demolition of approximately 46,000 sf commercial. Construction of 151,000 sf residential building with up to 197 units, 3,000 sf commercial, 184,376 sf senior living facility consisting of up to 95 Affinity Project Draft EIR

3.3-10 Energy
independent living units and 85,800 sf assisted living. 5,882 sf restaurant to remain.

Pasadena, CA: Pasadena DOT.

US Department of Energy. Office of Energy Efficiency & Renewable Energy (EERE). Washington, D.C.: EERE. https://www.energy.gov/eere/office-energy-efficiency-renewable-energy.

Affinity Project Draft EIR

3.4-1 Greenhouse Gas Emissions

3.4 GREENHOUSE GAS EMISSIONS

3.4.1 EXISTING CONDITIONS
Global Climate Change and Greenhouse Gases
Climate change is a recorded change in the Earth’s average weather measured by variables such as wind patterns, storms, precipitation, and temperature. Historical records show that global temperature changes have occurred naturally in the past, such as during previous ice ages. The year 2020 ranks as Earth’s hottest year on record, tying 2016.1 Overall, Earth’s average temperature has risen more than two degrees Fahrenheit since the 1880s. Continuing the planet’s long-term warming trend, the year’s globally averaged temperature was 1.84 degrees Fahrenheit (1.02 degrees Celsius) warmer than the baseline 1951-1980 mean. The last seven years have been the warmest seven years on record, typifying the ongoing and dramatic warming trend (NASA 2021).

The global atmospheric concentration of carbon dioxide (CO2), the most abundant greenhouse gas (GHG), has increased from a pre-industrial (roughly 1750) value of about 280 parts per million (ppm) to a seasonally-adjusted 413.73 ppm in July 2021. The National Oceanic and Atmospheric Administration (NOAA) Annual Greenhouse Gas Index (AGGI) in 2020 was 1.47, which means the warming influence of GHGs has increased 47 percent since 1990. It took about 240 years for the AGGI to go from zero to one, and 30 years to increase by another 47 percent (NOAA Earth System Research Laboratory [ESRL] 2021).

Greenhouse Gases
GHGs are global pollutants and are therefore unlike criteria air pollutants such as ozone (O3), particulate matter (PM10 and PM2.5), and toxic air contaminants (TACs), which are pollutants of regional and local concern (see Section 3.1, Air Quality, of this Draft EIR). While pollutants with localized air quality effects have relatively short atmospheric lifetimes (generally on the order of a few days), GHGs have relatively long atmospheric lifetimes, ranging from one year to several thousand years. Long atmospheric lifetimes allow for GHGs to disperse around the globe.

Therefore, GHG effects are global, as opposed to the local and/or regional air quality effects of criteria air pollutant and TAC emissions.

GHGs, as defined under California’s Assembly Bill (AB) 32, include CO2, methane (CH4), nitrous oxide (N2O), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and sulfur hexafluoride (SF6).

GHGs vary widely in the power of their climatic effects; therefore, climate scientists have established a unit called global warming potential (GWP). The GWP of a gas is a measure of both potency and lifespan in the atmosphere as compared to CO2. For example, as CH4 and N2O are approximately 25 and 298 times (respectively) more powerful than CO2 in their ability to trap heat in the atmosphere, they have GWPs of 25 and 298, respectively (CO2 has a GWP of 1). Carbon dioxide equivalent (CO2e) is a quantity that enables all GHG emissions to be considered as a group despite their varying GWP. The GWP of each GHG is multiplied by the prevalence of that gas to produce CO2e.

General Environmental Effects of Global Climate Change
Executive Order (EO) S-3-05 mandates the preparation of biennial science assessment reports on climate change impacts and adaptation options for California. EO S-13-08 directs the California Natural Resources Agency (CNRA) to develop a State Climate Adaptation Strategy and to provide 1 A separate, independent analysis by the National Oceanic and Atmospheric Administration (NOAA) concluded that 2020 was the second-warmest year in their record, behind 2016.

Affinity Project Draft EIR

3.4-2 Greenhouse Gas Emissions
State land use planning guidance related to sea level rise and other climate change impacts.

Current reports resulting from these directed actions are the Climate Action Team Report to the Governor and Legislature and the California Climate Adaptation Strategy (CalEPA 2010; CNRA 2009a). These studies report that global warming in California is anticipated to impact resources including, but not limited to, those discussed below.
 Public Health. Many Californians currently experience the worst air quality in the nation, and climate change is expected to make matters worse. Higher temperatures would increase the frequency, duration, and intensity of conditions conducive to air pollution formation. If global background O3 levels increase as predicted under some scenarios, it may become impossible to meet local air quality standards. Air quality could be further compromised by more frequent wildfires, which emit fine particulate matter that can travel long distances. Rising temperatures and more frequent heat waves would increase the risk of death from dehydration, heat stroke/exhaustion, heart attack, stroke, and respiratory distress. Climate change may also increase asthma rates and the spread of infectious diseases and their vectors, as well as challenge food and water supplies.

Children, the elderly, people with chronic heart or lung disease, outdoor workers, people who exercise outdoors and the economically-disadvantaged would be particularly vulnerable to these changes. In addition, more frequent extreme weather events could also result in increased injuries and deaths from these phenomena.  Energy. Increasing mean temperature and more frequent heat waves will drive up demand for cooling in summer; this new energy demand will only be partially offset by decreased demand for heating in winter. Hydropower, which currently provides 15 percent of in-state generation, would be threatened by declining snowpack, which serves as a natural reservoir for hydropower generation in the spring and summer. Winter storms, earlier snowmelt, and greater runoff may combine to cause flooding, which could, in turn, damage transmission lines and cause power outages.
 Water Resources. Rising temperatures, less precipitation, and more precipitation falling as rain instead of snow could severely diminish snowpack. Because the Sierra Nevada snowpack provides most of California’s available water, this potential loss would increase the risk of summer water shortages and would hamper water distribution and hydropower generation. The diminished snowpack would also nearly eliminate all skiing and other snow-related recreation. Rising sea levels would push saltwater into California’s estuaries, wetlands, and groundwater aquifers, threatening the water quality and reliability in the Sacramento/San Joaquin River Delta—a major California freshwater supply. Extreme precipitation and flooding could also damage water quality by creating sudden increases in runoff. Moreover, warming would increase evapotranspiration rates from plants, soil, and open water surfaces, which would result in greater demand for irrigation. Overall, climate change would reduce California’s water supplies even as its growing population requires additional resources.
 Sea Level and Flooding. Sea level at California’s coasts is expected to rise by 11 to 18 inches above 2000 levels by 2050 and by 23 to 55 inches by 2100. If realized, these increases would create more frequent and higher storm surges; would erode some coastal areas; and would increase pressure on existing levees. These increases would create a greater risk of flooding in previously untouched inland areas. Consequently, continued development in vulnerable coastal areas would put more people and infrastructure at risk.  Agriculture. Although higher CO2 levels can stimulate plant production and increase plant water-use efficiency, in the long-term, climate change would reduce the quantity and quality of agricultural products statewide. As temperatures rise, farmers will face greater water demand for crops and a less reliable water supply, as well as increased competition from urban water users. Sea level rise may cause saltwater intrusion in the Delta region, Affinity Project Draft EIR

3.4-3 Greenhouse Gas Emissions
making it difficult to raise certain crops. Rising temperatures will likely aggravate O3 pollution, interfering with plant growth and making plants more susceptible to disease and pests. In addition, warming would reduce the number of colder hours needed for fruit and nut production; would shift pest and weed ranges; would alter crop-pollinator timing; and would increase the frequency of droughts, heat waves, and floods. Higher average temperatures would also increase mortality and decrease productivity in livestock.  Forestry. California timber production has declined over the past few decades due, in part, to warming and increased wildfires. While further warming may increase production for some species in some locations, climate change is expected to reduce overall forest growth. Increasing average temperatures and drought frequency would result in more wildfires and greater burned areas, while less frequent and more intense rainfall would increase soil erosion and landslides. Higher temperatures and less water would force many tree species to shift their ranges; those that run out of livable habitat may die out.

Pests, diseases, and invasive species may also colonize new areas, further challenging forest health and biodiversity.
 Ecosystems. Rising average temperatures would subject plants and animals to greater thermal stress, causing some species to adapt or shift their ranges, while others may face extinction. Invasive species may also shift their ranges, threatening native species.

Changing temperatures would also alter the timing of plant flowering and insect emergence, damaging species’ ability to reproduce. Changing precipitation patterns would impact aquatic and riparian ecosystems by reducing snowpack, stream flow, and groundwater, while increasing the frequency of droughts, floods, and wildfires. As sea levels rise, some coastal habitats may be permanently flooded or eroded, and saltwater intrusion into freshwater resources may threaten terrestrial species. Changes in ocean circulation and temperature, ocean acidification, and increased runoff and sedimentation would threaten pelagic species. In sum, continued global warming would alter natural ecosystems and threaten California’s biological diversity.

Global, National, and State Contributions to Greenhouse Gas Emissions Table 3.4-1, Comparison of Worldwide Greenhouse Gas Emissions, compares the magnitude of GHG emissions on the global, national and State scales. It shows the relative estimated quantities of GHG emissions from worldwide to California. CO2e emissions are commonly expressed as metric tons of carbon dioxide equivalent (MTCO2e). Larger quantities of emissions, such as on the State or world scale, are expressed in million MTCO2e (MMTCO2e). Metric tons may also be stated as “tonnes”.

TABLE 3.4-1

COMPARISON OF WORLDWIDE GHG EMISSIONS
Area and Data Year
Annual GHG Emissions
(MMTCO2e)
World (2018) 47,552
United States (2018) 6,024
California (2018) 425
SCAG region (2020) 216
Pasadena (2009) 2.04
GHG: greenhouse gas; MMTCO2e: million metric tons of carbon dioxide equivalent Source: Climate Watch 2021; CARB 2021a; SCAG 2020a; Pasadena 2018.

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3.4-4 Greenhouse Gas Emissions
As shown, the U.S. contributes approximately 12.7 percent of worldwide GHG emissions per year and California contributes approximately 0.9 percent. The SCAG region contributes approximately 51 percent of California’s GHG emissions. Based on the data in Table 3.4-1, the City of Pasadena’s GHG emissions are approximately 0.9 percent of the SCAG region’s emissions; however, it is noted that there is an 11-year difference in the dates of the data.

The most common GHG is CO2, which constitutes approximately 80 and 83 percent of all GHG emissions in the U.S. and California, respectively. The primary contributors to California GHG emissions are (1) transportation; (2) industrial uses; and (3) electric power production from both in-State and out-of-State sources. In the City’s 2009 GHG emissions inventory, the transportation sector accounted for the largest portion of emissions, contributing approximately 52 percent of the community-wide total. Energy use was the second largest producer of emissions, contributing approximately 47 percent of the community-wide total (Pasadena 2018).

Project Site Emissions
GHGs are emitted from current operations at the Project site. Existing Project site GHG emissions were estimated using the California Emissions Estimator Model (CalEEMod) version 2020.4.0 computer program (CAPCOA 2021), as discussed further under Section 3.4.4, Methodology.

Existing emissions were calculated for the four businesses that would be removed from the site (i.e., 491/495, 499/503, 541, and 577 South Arroyo Parkway) and replaced by new uses associated with the Project or Project with Building A Residential/Commercial. In other words, the existing emissions do not include emissions from the buildings to be retained with implementation of the Project (i.e., 465, 501, and 523 South Arroyo Parkway). Existing vehicle trip data, an estimated 2,454 daily trips, are derived from the Transportation Impact Analysis (TIA) – Outside of CEQA Analysis prepared for the Project (Pasadena DOT 2021a). The results of the analysis are shown in Table 3.4-2, Estimated Annual GHG Emissions for Uses to be Removed. As shown in this table, the majority of existing emissions are from vehicle trips (mobile source emissions), followed by energy emissions.

TABLE 3.4-2

ESTIMATED ANNUAL GHG EMISSIONS FOR USES TO BE REMOVED
Source
Emissions
(MTCO2e/yr)
Area <1
Energy 629
Mobile 796
Waste 130
Water 61
Total Operational Emissions 1,616
MTCO2e/yr: metric tons of carbon dioxide equivalent per year Notes:
 Totals may not add due to rounding variances.
 Detailed calculations in Appendix B, Air Quality and Greenhouse Gas Emissions Modeling Data.

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3.4-5 Greenhouse Gas Emissions

3.4.2 RELEVANT PROGRAMS AND REGULATIONS
Federal
U.S. Environmental Protection Agency Findings
On December 7, 2009, the U.S. Environmental Protection Agency (USEPA) Administrator signed two distinct findings regarding GHGs under Section 202(a) of the Clean Air Act (CAA).  Endangerment Finding: The Administrator finds that the current and projected concentrations of the six key well-mixed GHGs—carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and sulfur hexafluoride (SF6)—in the atmosphere threaten the public health and welfare of current and future generations.
 Cause or Contribute Finding: The Administrator finds that the combined emissions of these well-mixed GHGs from new motor vehicles and new motor vehicle engines contribute to the GHG pollution which threatens public health and welfare.

The findings do not themselves impose any requirements on industry or other entities. However, this action was a prerequisite implementing GHG emissions standards for vehicles (USEPA 2021a). A light-duty vehicle is defined any motor vehicle with a gross vehicle weight of 6,000 pounds or less (CARB 2021b).

Light-Duty Vehicle Greenhouse Gas Emissions Standards and Corporate Average Fuel Economy Standards
The USEPA and the Department of Transportation’s National Highway Traffic Safety Administration (NHTSA) have been working together on developing a National Program of regulations to reduce GHG emissions and to improve the fuel economy of light-duty vehicles. On April 1, 2010, the USEPA and NHTSA announced a joint Final Rulemaking establishing standards for 2012 through 2016 model year vehicles. On October 15, 2012, the agencies issued a Final Rulemaking with standards for model years 2017 through 2025. The rules require these vehicles to meet an estimated combined average emissions level of 295 grams of CO2 per mile by 2012, decreasing to 250 grams per mile by 2016, and finally to an average industry fleet-wide level of 163 grams per mile in model year 2025. The 2016 standard is equivalent to 35.5 miles per gallon (mpg) and the 2025 standard is equivalent to 54.5 mpg if the levels were achieved solely through improvements in fuel efficiency. The agencies expect, however, that a portion of these improvements will occur due to air conditioning technology improvements (i.e., they will leak less) and due to the use of alternative refrigerants, which would not contribute to fuel economy. These standards would cut GHG emissions by an estimated 2 billion metric tons and 4 billion barrels of oil over the lifetime of the vehicles sold under the program (model years 2017–2025). The combined USEPA GHG standards and NHTSA Corporate Average Fuel Economy (CAFE) standards resolve previously conflicting requirements under both federal programs and the standards of the State of California and other States that have adopted the California standards (USEPA and NHTSA 2012).

On September 19, 2019, NHTSA and the USEPA issued a final action entitled the “One National Program Rule” to enable the federal government to provide nationwide uniform fuel economy and GHG emission standards for automobile and light duty trucks. This action finalizes critical parts of the Safer, Affordable, Fuel-Efficient (SAFE) Vehicles Rule that was first proposed in August 2018. In this proposal, the agencies proposed new and amended GHG and Corporate Average Fuel Economy (CAFE) standards for model year 2021 to 2026 light duty vehicles (USEPA and NHTSA 2019).

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3.4-6 Greenhouse Gas Emissions
In this action, USEPA withdrew the Clean Air Act waiver that had been granted to the State of California in January 2013 for the State’s Advanced Clean Car program with respect to GHG and Zero Emission Vehicle (ZEV) elements. In November 2019, California, 21 other states, the District of Columbia, and four California cities filed a petition for EPA to reconsider SAFE-1. A petition for reconsideration was also files by several environmental groups.

On April 28, 2021, USEPA published a Notice of Reconsideration: California State Motor Vehicle Pollution Control Standards; Advanced Clean Car Program; Reconsideration of a Previous Withdrawal of a Waiver of Preemption; Opportunity for Public Hearing and Public Comment. The public comment period closed on July 6, 2021 (USEPA 2021b).

State
Assembly Bill 1493 (Mobile Source Reductions)
Assembly Bill (AB) 1493, adopted September 2002, also known as Pavley I, requires the development and adoption of regulations to achieve the maximum feasible reduction of GHGs emitted by noncommercial passenger vehicles, light-duty trucks, and other vehicles used primarily for personal transportation in the State. The emission standards have become increasingly more stringent through the 2016 model year. California is also committed to further strengthening these standards beginning in 2017 to obtain a 45 percent GHG reduction from 2020 model year vehicles (CARB 2021c). Regulations to make California emissions standards for model year 2017 and beyond consistent with federal standards were adopted in 2012 and are discussed further below.

CARB’s Advanced Clean Cars Program
In January 2012, CARB approved the Advanced Clean Cars Program, an emissions-control program for model year 2017 through 2025. The program combines the control of smog, soot and GHGs with requirements for greater numbers of zero-emission vehicles. By 2025, when the rules will be fully implemented, the new automobiles will emit 34 percent fewer global warming gases and 75 percent fewer smog-forming emissions. The program also requires car manufacturers to offer for sale an increasing number of zero-emission vehicles (ZEVs) each year, including battery electric, fuel cell, and plug-in hybrid electric vehicles. In March 2017, CARB adopted GHG standards for 2022 through 2025 model years and directed staff to begin rule development for 2026 and subsequent model years (CARB 2021d).

Executive Order S-3-05 (Statewide GHG Targets)
On June 1, 2005, Governor Arnold Schwarzenegger signed EO S-3-05, which proclaims that California is vulnerable to the impacts of climate change. It declares that increased temperatures could reduce snowpack in the Sierra Nevada Mountains; could further exacerbate California’s air quality problems; and could potentially cause a rise in sea levels. In an effort to avoid or reduce the impacts of climate change, EO S-3-05 calls for a reduction in GHG emissions to the year 2000 level by 2010, to year 1990 levels by 2020, and to 80 percent below 1990 levels by 2050.

However, executive orders do not have the same status as a law, because in California’s constitutional system, it is the Legislature, not the Governor, who is entrusted with the role of making statewide laws. The Legislature declined to include the EO's 2050 goal in AB 32 (discussed below), and again declined to use the EO's 2050 goal in adopting Senate Bill (SB) 375 (discussed below), nor has it incorporated it in any implementing legislation or applicable plans.

Additionally, although CARB has the requisite authority to adopt whatever regulations are necessary beyond the AB 32 horizon year 2020 to meet the target set forth in S-3-05, the agency has not done so. Since the Legislature has never enacted EO S-3-05’s 2050 target, and no expert agency has interpreted CEQA to require it, the 2050 target has only the force and effect of an Affinity Project Draft EIR

3.4-7 Greenhouse Gas Emissions
executive order issued by a former Governor. If the Legislature has delegated any of its authority to define CEQA’s requirements, it delegated that authority to the Governor’s Office of Planning and Research (OPR).

Senate Bill 97 and the State CEQA Guidelines
Pursuant to Senate Bill (SB 97), OPR developed and CNRA adopted proposed amendments to the State CEQA Guidelines (CEQA Amendments) for the feasible mitigation of GHG emissions and their effects. The CEQA Amendments became effective on March 18, 2010.

The CEQA Amendments for Greenhouse Gas Emissions state in Section 15064.4(a) that lead agencies should “make a good faith effort, to the extent possible on scientific and factual data, to describe, calculate or estimate” GHG emissions. The CEQA Amendments note that an agency may identify emissions by either selecting a “model or methodology” to quantify the emissions or by relying on “qualitative analysis or other performance based standards” (CNRA 2009b). Section 15064.4(b) of the State CEQA Guidelines provides that the lead agency should consider the following when assessing the significance of impacts from GHG emissions on the environment (CNRA 2009b):
 The extent a project may increase or reduce GHG emissions as compared to the environmental setting.
 Whether the project emissions exceed a threshold of significance that the lead agency determines applies to the project.
 The extent to which the project complies with regulations or requirements adopted to implement a statewide, regional, or local plan for the reduction or mitigation of GHG emissions.

All of these are considered in the impact analysis presented in this section. The revisions to Appendix G, Environmental Checklist Form, of the State CEQA Guidelines, which is often used as a basis for lead agencies’ selection of significance thresholds, do not prescribe specific thresholds. Rather, Appendix G asks whether the project would conflict with a plan, policy or regulation adopted to reduce GHG emissions or would generate GHG emissions that would significantly affect the environment, indicating that the determination of what is a significant effect on the environment should be left to the lead agency. Accordingly, the CEQA Amendments do not prescribe specific methodologies for performing an assessment; they do not establish specific thresholds of significance; and they do not mandate specific mitigation measures. Rather, the CEQA Amendments emphasize the lead agency’s discretion to determine the appropriate methodologies and thresholds of significance consistent with the manner in which other impact areas are handled in CEQA (CNRA 2009b).

The CEQA Amendments indicate that lead agencies should consider all feasible means, supported by substantial evidence and subject to monitoring and reporting, of mitigating the significant effects of GHG emissions. As pertinent to the Project, these potential mitigation measures, set forth in Section 15126.4(c) of the State CEQA Guidelines, may include (1) measures in an existing plan or mitigation program for the reduction of GHG emissions that are required as part of the lead agency’s decision; (2) reductions in GHG emissions resulting from a project through implementation of project design features; (3) off-site measures, including offsets, to mitigate a project’s emissions; and (4) carbon sequestration measures (CNRA 2009b).

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3.4-8 Greenhouse Gas Emissions
Among other things, the CNRA noted in its Public Notice for these changes that impacts of GHG emissions should focus on the cumulative impact on climate change. The Public Notice states (CNRA 2009a):

While the Proposed Amendments do not foreclose the possibility that a single project may result in greenhouse gas emissions with a direct impact on the environment, the evidence before [CNRA] indicates that in most cases, the impact will be cumulative.

Therefore, the Proposed Amendments emphasize that the analysis of greenhouse gas emissions should center on whether a project’s incremental contribution of greenhouse gas emissions is cumulatively considerable.

Thus, the CEQA Amendments continue to make clear that the significance of GHG emissions is most appropriately considered on a cumulative level.

Assembly Bill 32 (Statewide GHG Reductions)
In furtherance of the goals established in EO S-3-05, the California Legislature adopted the public policy position that global warming is “a serious threat to the economic well-being, public health, natural resources, and the environment of California” (California Health and Safety Code, Section 38501). The public policy statements became law with the enactment of the California Global Warming Solutions Act of 2006 (AB 32) in September 2006, after considerable study and expert testimony before the Legislature. The law instructs CARB to develop and enforce regulations for the reporting and verifying of statewide GHG emissions. AB 32 directed CARB to set a GHG emission limit based on 1990 levels, to be achieved by 2020. The bill set a timeline for adopting a scoping plan for achieving GHG reductions in a technologically and economically feasible manner. The scoping plan is described further below.

Executive Order B-30-15 (Statewide Interim GHG Targets) California EO B-30-15 (2015) set an “interim” statewide emission target to reduce GHG emissions to 40 percent below 1990 levels by 2030 and directed State agencies with jurisdiction over GHG emissions to implement measures pursuant to statutory authority to achieve this 2030 target and the 2050 target of 80 percent below 1990 levels. Specifically, the Executive Order directed CARB to update the Scoping Plan to express this 2030 target in metric tons.

Senate Bill 32/Assembly Bill 197
SB 32, signed September 8, 2016, implements a goal of EO B-30-15. Under SB 32, in "adopting rules and regulations to achieve the maximum technologically feasible and cost-effective GHG emissions reductions," CARB must ensure that statewide GHG emissions are reduced to 40 percent below the 1990 level by 2030. SB 32's findings state that CARB will “achieve the state’s more stringent GHG emission reductions in a manner that benefits the state’s most disadvantaged communities and is transparent and accountable to the public and the Legislature.” AB 197, a companion to SB 32, adds two members to the CARB and requires measures to increase transparency about GHG emissions, climate policies, and GHG reduction actions.

California Air Resources Board Scoping Plan
On December 11, 2008, CARB adopted the Scoping Plan to achieve the goals of AB 32. The Scoping Plan establishes an overall framework for the measures that will be adopted to reduce California’s GHG emissions. CARB determined that achieving the 1990 emission level would require a reduction of GHG emissions of approximately 28.5 percent below what would otherwise occur in 2020 in the absence of new laws and regulations (referred to as “business as usual”).

The Scoping Plan evaluates opportunities for sector-specific reductions; integrates all CARB and Affinity Project Draft EIR

3.4-9 Greenhouse Gas Emissions
Climate Action Team early actions and additional GHG reduction measures by both entities; identifies additional measures to be pursued as regulations; and outlines the role of a cap-andtrade program.

First Update to the Climate Change Scoping Plan
CARB approved the final “First Update to the Climate Change Scoping Plan” on May 22, 2014.

The first update describes California’s progress towards AB 32 goals, stating that “California is on track to meet the near-term 2020 GHG limit and is well positioned to maintain and continue reductions beyond 2020 as required by AB 32”. Specifically, “if California realizes the expected benefits of existing policy goals (such as 12,000 megawatts [MW] of renewable distributed generation by 2020, net zero energy homes after 2020, existing building retrofits under AB 758, and others) it could reduce emissions by 2030 to levels squarely in line with those needed in the developed world and to stay on track to reduce emissions to 80 percent below 1990 levels by 2050” (CARB 2014). Reducing the "business as usual" or NAT condition of 509 MMTCO2e to the 1990 emissions level of 431 MMTCO2e will require a reduction of 78 MMTCO2e, or approximately a 15.3 percent reduction (compared to a 28.5 percent reduction as set forth in the original Scoping Plan but not directly comparable because of the change in methodology).

Second Update to the Climate Change Scoping Plan
CARB prepared a second update to the Scoping Plan to reflect the 2030 target established in EO B-30-15 and in SB 32 (discussed above). The Final Proposed 2017 Scoping Plan was published in November 2017, and the third public Board Meeting for the Proposed Scoping Plan was held on December 14, 2017, where the Final Proposed 2017 Climate Change Scoping Plan (Second Update to the Climate Change Scoping Plan, or 2017 Scoping Plan Update) was adopted.

The 2017 Scoping Plan Update includes new statutory GHG reduction requirements that were not included in the current Scoping Plan, including SB 32 (discussed below) which sets a 40 percent GHG reduction target below 1990 GHG levels to be achieved by 2030, SB 350 (which sets a 50 percent reduction in GHG emissions from electricity generation and other energy uses in existing structures, and a 50 percent renewable energy portfolio requirement), and SB 650 (which establishes priority GHG reduction targets for designated types of GHGs such as methane). The key elements of the 2017 Scoping Plan Update proposal call for further GHG reductions from the refinery sector specifically, further reductions from other stationary sources through either a renewed and expanded cap and trade or carbon tax program, further reductions from other sectors such as transportation technologies and services, water and solid waste conservation and management, and land uses in both open space and urban areas (CARB 2017). 2022 Scoping Plan Update
The 2022 Scoping Plan Update will assess progress towards achieving the SB 32 2030 target and lay out a path to achieve carbon neutrality by mid-century. The first public workshops for the 2022 Scoping Plan Update were held in June 2021 (CARB 2021e).

Senate Bill 375 (Land Use Planning)
Signed September 30, 2008, SB 375 provides for a new planning process to coordinate land use planning and regional transportation plans (RTPs) and funding priorities in order to help California meet the GHG reduction goals established in AB 32. SB 375 requires Metropolitan Planning Organizations, including the Southern California Association of Governments (SCAG), to incorporate a Sustainable Communities Strategy (SCS) in their regional transportation plans that will achieve GHG emission reduction targets set by CARB. There are two mutually important facets to SB 375: reducing vehicle miles traveled (VMT) and encouraging more compact, Affinity Project Draft EIR

3.4-10 Greenhouse Gas Emissions
complete, and efficient communities for the future. SB 375 also includes provisions for exemptions from or streamlined CEQA review for projects classified as transit priority projects (SCAG 2016).

See additional discussion of the SCAG plan under “Regional” regulations below.

Senate Bills 1078, 107, and SBX1-2 (Renewable Portfolio Standards) Established in 2002 under SB 1078, accelerated in 2006 under SB 107, and again in 2011 under SBX1-2, California’s Renewable Portfolio Standard (RPS) requires retail sellers of electric services to increase procurement from eligible renewable energy resources to 33 percent of total retail sales by 2020. Initially, the RPS provisions applied to investor-owned utilities, community choice aggregators, and electric service providers. SBX1-2 added, for the first time, publicly owned utilities to the entities subject to RPS.

Senate Bill 350
SB 350, signed October 7, 2015, is the Clean Energy and Pollution Reduction Act of 2015. SB 350 is the implementation of some of the goals of EO B-30-15. The objectives of SB 350 are:
(1) To increase from 33 percent to 50 percent, the procurement of our electricity from renewable sources.
(2) To double the energy efficiency savings in electricity and natural gas final end uses of retail customers through energy efficiency and conservation (California Energy Commission [CEC] 2021a).

Senate Bill 100
On September 10, 2018, Governor Brown signed SB 100, the 100 Percent Clean Energy Act of 2018. SB 100 requires renewable energy and zero-carbon resources to supply 100 percent of electric retail sales to end-use customers and 100 percent of electricity procured to serve state agencies by December 31, 2045. This policy requires the transition to zero-carbon electric systems that do not cause contributions to increase of GHG emissions elsewhere in the western electricity grid (CEC 2021b). SB 100 also creates new standards for the RPS goals established by SB 350 in 2015. Specifically, the bill increases required energy from renewable sources for both investor-owned utilities and publicly owned utilities from 50 percent to 60 percent by 2030.

Executive Order B-55-18
On September 10, 2018, Governor Brown also signed California EO B-55-18, which sets a new statewide goal of carbon neutrality as soon as possible, and no later than 2045, and achieve net negative emissions thereafter. EO B-55-18 was added to the existing Statewide targets of reducing GHG emissions, including the targets previously established by Governor Brown of reducing emissions to 40 percent below 1990 levels by 2030 (EO B-30-15 and SB 32), and by Governor Schwarzenegger of reducing emissions to 80 percent below 1990 levels by 2040 (EO S-3-05).

Title 24 Energy Efficiency Standards
The Energy Efficiency Standards for Residential and Nonresidential Buildings (Title 24, Part 6 of the California Code of Regulations [CCR]) were established in 1978 in response to a legislative mandate to reduce California’s energy consumption. The currently applicable standards are the 2019 Standards, effective January 1, 2020. The 2019 standards focus on four key areas: smart residential photovoltaic systems, updated thermal envelope standards (preventing heat transfer from the interior to exterior and vice versa), residential and nonresidential ventilation Affinity Project Draft EIR

3.4-11 Greenhouse Gas Emissions
requirements, and nonresidential lighting requirements. The ventilation measures improve indoor air quality, protecting homeowners from air pollution originating from outdoor and indoor sources (CEC 2021c). The requirements of the energy efficiency standards result in the reduction of natural gas and electricity consumption. Both natural gas and electricity use produce GHG emissions. The goal of the standards is to reduce energy use in new homes by more than 50 percent. The 2019 standards require that there is sufficient on-site electricity generation to meet the annual electricity usage for low rise residential buildings. A 30 percent reduction in energy uses is anticipated for nonresidential uses. The requirement for low-rise residential buildings to develop onsite electricity generation is consistent with the goal to develop renewable sources of energy.

The CEC adopted the 2008 changes to the Building Energy Efficiency Standards in order to (1) “Provide California with an adequate, reasonably-priced, and environmentally-sound supply of energy” and (2) “Respond to Assembly Bill 32, the Global Warming Solutions Act of 2006, which mandates that California must reduce its GHG emissions to 1990 levels by 2020”. In 2013, the CEC, in coordination with the CPUC, commenced a process to update the Title 24 energy efficiency standards and, the 2016 Title 24 Energy Efficiency Standards establish building design and construction requirements that move closer to achieving California’s zero net energy (ZNE) goals. The requirements of the energy efficiency standards result in the reduction of natural gas and electricity consumption. Both natural gas use and electricity generation result in GHG emissions.

California Green Building Standards Code
The 2019 California Green Building Standards Code (24 CCR, Part 11), also known as the CALGreen code, contains mandatory requirements and voluntary measures for new residential and nonresidential buildings (including buildings for retail, office, public schools and hospitals) throughout California). The development of the CALGreen Code is intended to improve public health, safety, and general welfare by enhancing the design and construction of buildings through the following construction practices: (1) planning and design; (2) energy efficiency; (3) water efficiency and conservation; (4) material conservation and resource efficiency; and (5) environmental quality. In short, the code is established to reduce construction waste; make buildings more efficient in the use of materials and energy; and reduce environmental impact during and after construction.

California Air Pollution Control Officers Association
The California Air Pollution Control Officers Association (CAPCOA) is the association of Air Pollution Control Officers representing all 35 local air quality agencies throughout California.

CAPCOA is not a regulatory body but has been an active organization in providing guidance in addressing the CEQA significance of GHG emissions and climate change as well as other air quality issues. The August 2010 CAPCOA publication entitled Quantifying Greenhouse Gas Mitigation Measures, A Resource for Local Government to Assess Emission Reductions from Greenhouse Gas Mitigation Measures provides guidance on the quantification of project-level mitigation of GHGs associated with land use, transportation, energy use, and other related project areas. The guidance includes detailed procedures about the approaches to assessing and calculating the GHG emissions reductions associated with project design features and mitigation measures (CAPCOA 2010). This publication’s methods are used in the CalEEMod computer model that is used to calculate GHG emissions.

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3.4-12 Greenhouse Gas Emissions
Regional
South Coast Air Quality Management District
The City lies within the boundaries of the South Coast Air Quality Management District (SCAQMD). SCAQMD is the regulatory agency responsible for improving air quality for large areas of Los Angeles, Orange County, Riverside and San Bernardino counties, including the Coachella Valley. The region is home to more than 17 million people–about half the population of the entire state of California. The mission of the SCAQMD is “To clean the air and protect the health of all residents in the South Coast Air District through practical and innovative strategies” (SCAQMD 2021).

Southern California Association of Governments
As previously discussed, SB 375 specifically required Metropolitan Planning Organizations (MPOs), including SCAG, to incorporate an SCS in their RTPs that will achieve GHG emission reduction targets set by CARB. SCAG’s current SCS is included in its 2020–2045 RTP/SCS Connect SoCal (SCAG 2020b).2 The 2020–2045 RTP/SCS combines the need for mobility with a “sustainable future” through a reduction in the number of emissions produced from transportation sources. The document was adopted by SCAG on September 3, 2020. The 2020–2045 RTP/SCS is expected to reduce per capita transportation emissions by 19 percent by 2035 relative to 2005.

City
The City of Pasadena Climate Action Plan (CAP) was adopted on March 5, 2018 (Pasadena 2018). The CAP states, “Climate change presents Pasadena with both complex challenges and tremendous opportunities. The City of Pasadena is committed to creating a vision for a more sustainable community. By making choices to reduce its GHG emissions and preparing for the changes that are underway, Pasadena can reduce the risks from climate change.” With respect to CEQA evaluation of new development projects, the CAP states, The CAP establishes a framework for evaluating and mitigating GHG emissions by providing an emissions inventory, emissions reduction goals, and strategies for reducing emissions. Part of these emissions reductions will need to be achieved through better environmental and sustainable performance by new development projects.

To determine whether new development projects comply with the CAP, and to ensure that projects are contributing to GHG reductions, City staff will use the CAP Consistency Checklist (Checklist) for discretionary projects subject to CEQA.

New development projects that meet the requirements of the Checklist, including completion of one of the three options (Options A, B, or C) listed below, will be deemed to be consistent with the CAP and will be found to have a less than significant contribution to cumulative GHG emissions. Projects that do not meet the requirements in the Checklist will be deemed to be inconsistent with the CAP and must prepare a project specific analysis of GHG emissions (Pasadena 2018).
2 The 2020-2045 RTP/SCS succeeds the 2016-2040 RTP/SCS.

Affinity Project Draft EIR

3.4-13 Greenhouse Gas Emissions
The following Options are provided by the City for new development projects to establish consistency with the CAP, as included in Appendix D, Climate Action Plan Consistency Checklist, of the City’s CAP (Pasadena 2017).
 Option A, Sustainable Development Actions, requires that the Project incorporate sustainable development actions, which would become conditions of the entitlement for approval of the project, intended to ensure that the project contributes its fair share to the City’s cumulative GHG reduction goals.
 Option B, GHG Efficiency, requires that the Project demonstrate consistency with the applicable Pasadena’s per service population GHG efficiency threshold.  Option C, Net Zero GHG Emissions, requires that the Project achieve Net Zero GHG Emissions, which requires quantifying the project’s GHG emission levels and demonstrate that the project would not result in a net increase in GHG emissions.

The Checklist and Option B are discussed further below, under Section 3.4.3, Thresholds of Significance, and in the impact findings, under Section 3.4.5, Environmental Impacts.

3.4.3 THRESHOLDS OF SIGNIFICANCE
The following significance criteria are derived from Appendix G of the State CEQA Guidelines. A project would result in a significant adverse greenhouse gas emissions impact if it would:

Threshold 3.4a: Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment; and/or
Threshold 3.4b: Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases.

The CAP Checklist, as described above, is a tool for new development projects to demonstrate consistency with the CAP, a qualified GHG reduction plan in accordance with CEQA Guidelines Section 15183.5. The City’s CAP Option B GHG efficiency metric is used for this analysis. Per the City’s CAP, this method recognizes that highly efficient projects (e.g., compact and mixed-use development) with relatively high mass emissions may nevertheless meet the local and State GHG reduction goals/targets. Using the demographic projections developed for the CAP, the City has developed service person efficiency thresholds for the years of 2020, 2025, 2030 and 2035 which are consistent with Pasadena’s GHG emission goals included in the CAP and the State targets it is designed to achieve (AB 32, SB 32, and substantial progress towards EO S-3-05).

Table 3.4-3, City of Pasadena Climate Action Plan Efficiency Thresholds, provides the thresholds for GHG efficiency for the first year that the Project would be in operation.

Affinity Project Draft EIR

3.4-14 Greenhouse Gas Emissions
TABLE 3.4-3

CITY OF PASADENA CLIMATE ACTION PLAN

EFFICIENCY THRESHOLDS
Project’s First Operational Year Threshold
2017 – 2020 5.63 MTCO2e/SP
2021 – 2025 4.56 MTCO2e/SP
2026 – 2030 3.57 MTCO2e/SP
2031 – 2035 2.73 MTCO2e/SP
MTCO2e: metric tons of carbon dioxide equivalent; SP: service person.

Source: Pasadena 2018.

Under Option B, based on the Project’s and Project with Building A Residential/Commercial’s first operational year of 2026, the City’s GHG efficiency metric of 3.57 MTCO2e per service person (MTCO2e/SP) would be used as the GHG efficiency threshold. Per the CAP, with Option B, projects must be able to demonstrate a GHG efficiency which is less than or equal to the threshold listed below for the projects’ first operational year to be considered consistent with the Pasadena CAP and State targets it is designed to achieve.

3.4.4 METHODOLOGY
In June 2021, the SCAQMD in conjunction with the CAPCOA and other California air districts, released the latest version of the California Emissions Estimator Model™ (CalEEMod™), version 2020.4.0 (CAPCOA 2021). The purpose of this model is to calculate construction-source and operational-source air pollutants, including GHG emissions, from direct and indirect sources; and quantify applicable GHG reductions achieved from mitigation measures. CalEEMod version 2020.4.0 was used to estimate the GHG emissions associated with the existing land uses to be removed and the proposed land uses for the Project and Project with Building A Residential/Commercial. The inputs and data for the modeling are described above for existing uses; below for proposed uses; and in Appendix B of this Draft EIR.

3.4.5 ENVIRONMENTAL IMPACTS
Threshold 3.4a: Would the Project generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment? As described above, under Section 3.4.3, Thresholds of Significance, Option B would be applied to this analysis to assess Project and Project with Building A Residential/Commercial consistency with the CAP to determine whether either project would generate GHG emissions that may have a significant impact on the environment.

Project
Construction of the Project would begin in 2023, occur over a period of approximately 34 months, and would be completed in a single phase. Construction emissions for the Project were calculated using CalEEMod 2020.4.0, as described above. Project construction is planned to occur from March 2023 to January 2026 with a six-day work week. The CalEEMod input for construction emissions was based on the Project’s construction assumptions and default assumptions derived from CalEEMod. Demolition would include an estimated 45,912 square feet (sf) of buildings and the export of approximately 300 14-cubic yard (cy) truckloads of debris. Grading for the subterranean garage and other areas for improvement would require the export of an estimated 184,013 cy of soil, requiring approximately 13,200 truckloads for export. The principal source of construction-related GHG emissions would be from internal combustion engines of construction Affinity Project Draft EIR

3.4-15 Greenhouse Gas Emissions
equipment, on-road construction vehicles, and workers’ commuting vehicles. The estimated construction GHG emissions for the proposed Project would be 3,691 MTCO2e, as shown in Table 3.4-4, Estimated GHG Emissions from Construction of the Project.

TABLE 3.4-4

ESTIMATED GHG EMISSIONS FROM

CONSTRUCTION OF THE PROJECT
Year
Emissions
(MTCO2e)
2023 986
2024 1,429
2025 1,267
2026 9
Total 3,691
MTCO2e: metric tons of carbon dioxide equivalent
Notes:
 Totals may not add due to rounding variances.
 Detailed calculations in Appendix B, Air Quality and Greenhouse Gas Emissions Modeling Data.

Operational emissions are comprised of area, energy, mobile, stationary source, waste, and water emissions. Operational GHG emissions would come primarily from energy; other sources include mobile trips; water consumption; natural gas for space and water heating; and gasoline-powered landscaping and maintenance equipment. Area source emissions are based on CalEEMod assumptions for the specific land uses and size. Energy emissions are based on the Applicant’s estimate of electrical and natural gas use and default CalEEMod values. Mobile source emissions are based on the estimated Project-related trip generation forecast of 6,366 daily trips, as contained in the Project TIA – Outside of CEQA Analysis (Pasadena DOT 2021a) and incorporate the vehicle miles traveled (VMT) assumptions for the Project’s trips (Pasadena DOT 2020). The emissions analyses for the Project also includes the anticipated electrical demand, natural gas demand, and mobile trips for the conversion of the two historic buildings to commercial uses, which are assumed to be restaurant for the purposes of this Draft EIR. The Project’s long-term gross and net operational emissions are summarized below in Table 3.4-5, Estimated Annual Net GHG Emissions from Operation of the Project. The net operational emissions account for the emissions from the land uses to be demolished and/or replaced with the proposed Project uses on the site plus the land uses to be retained. As shown in Table 3.4-5, the Project’s estimated net operational emissions would be 3,257 MTCO2e/yr.

Affinity Project Draft EIR

3.4-16 Greenhouse Gas Emissions
TABLE 3.4-5

ESTIMATED ANNUAL NET GHG

EMISSIONS FROM OPERATION OF THE PROJECT
Source
Emissions
(MTCO2e/yr)
Area 3
Energy 2,363
Mobile 1,938
Stationary - Generators 9
Waste 450
Water 110
Gross Operational Emissions 4,873
Existing Operational Emissions (Table 3.4-2) 1,616
Net Operational Emissions 3,257
MTCO2e/yr: metric tons of carbon dioxide equivalent per year Notes:
 Totals may not add due to rounding variances.
 Detailed calculations in Appendix B, Air Quality and Greenhouse Gas Emissions Modeling Data.

Table 3.4-6, GHG Efficiency Metric for the Project, shows the Project’s GHG efficiency using Option B from the City’s CAP. According to Section 2.0, Project Description, the Project would add 959 service persons to the Project site (222 residents and 737 full-time employees). Based on the service population of 959 SP for the Project, described above, the GHG efficiency metric would be 3.52 MTCO2e/SP, which does not exceed the City’s CAP GHG efficiency threshold of

3.57 MTCO2e/SP for 2026. As such, the Project has demonstrated consistency with the City’s CAP, and the Project would not generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment. There would be a less than significant impact, and no mitigation is required.

TABLE 3.4-6

GHG EFFICIENCY METRIC FOR THE PROJECT
Source Emissions
Construction Emissions (Amortized) (MTCO2e/yr) 123a
Net Operational Emissions (MTCO2e/yr) 3,257b
Annual GHG Emissions 3,380
Service Population 959
Project-level GHG efficiency
(MTCO2e/SP/yr) 3.52
GHG Efficiency Threshold for 2026
(MTCO2e/SP/yr)
c 3.57
Exceed Threshold? No
MTCO2e/yr.: metric tons of carbon dioxide equivalent per year; SP: service person; yr: year a Total derived by dividing construction emissions (see Table 3.4-4) by 30. b Total operational emissions are the gross operational emissions with a net reduction of existing emissions (see Table 3.4-5). c
See Table 3.4-3 for threshold for 2026.

Affinity Project Draft EIR

3.4-17 Greenhouse Gas Emissions
Project with Building A Residential/Commercial
The Project with Building A Residential/Commercial construction is also planned to occur from March 2023 to January 2026 with a six-day work week. All construction assumptions for the Project with Building A Residential/Commercial would be consistent with the Project, except that grading for the subterranean garage and other areas for improvement would require 36,802 cy less of soil export than the Project (for a total of 147,211 cy of soil export) and 2,685 less truckloads than the Project (for a total of 10,515 truckloads for export). The principal source of construction-related GHG emissions would be from internal combustion engines of construction equipment, on-road construction vehicles, and workers’ commuting vehicles. The estimated construction GHG emissions for the Project with Building A Residential/Commercial would be 3,637 MTCO2e, as shown in Table 3.4-7, Estimated GHG Emissions from Construction of the Project with Building A Residential/Commercial.

TABLE 3.4-7

ESTIMATED GHG EMISSIONS FROM

CONSTRUCTION OF THE PROJECT WITH

BUILDING A RESIDENTIAL/COMMERCIAL
Year
Emissions
(MTCO2e)
2023 931
2024 1,429
2025 1,267
2026 9
Total 3,637
MTCO2e: metric tons of carbon dioxide equivalent
Notes:
 Totals may not add due to rounding variances.
 Detailed calculations in Appendix B.

As discussed above, operational emissions are comprised of area, energy, mobile, stationary source, waste, and water emissions. Operational GHG emissions for the Project with Building A Residential/Commercial would come primarily from energy, like the Project. Other sources include mobile trips; water consumption; natural gas for space and water heating; and gasoline-powered landscaping and maintenance equipment. Energy emissions are based on the Applicant’s estimate of electrical and natural gas use and default CalEEMod values. Mobile source emissions are based on estimated Project with Building A Residential/Commercial-related trip generation forecast of 2,494 daily trips, as contained in the TIA – Outside of CEQA Analysis prepared for the Project with Building A Residential/Commercial (Pasadena DOT 2021b) and incorporate the VMT assumptions for the Project with Building A Residential/Commercial’s trips (Pasadena DOT 2021c). The emissions analyses also include the anticipated electrical demand, natural gas demand, and mobile trips for the conversion of the two historic buildings to commercial uses, which are assumed to be restaurant for the purposes of this Draft EIR. The Project with Building A Residential/Commercial’s long-term gross and net operational emissions are summarized below in Table 3.4-8, Estimated Annual Net GHG Emissions from Operation of the Project with Building A Residential/Commercial. The net operational emissions account for the emissions from the land uses to be demolished and replaced with the proposed Project uses on the site. As shown in Table 3.4-8, the Project’s estimated net operational emissions would be 1,618 MTCO2e/yr.

Affinity Project Draft EIR

3.4-18 Greenhouse Gas Emissions
TABLE 3.4-8

ESTIMATED ANNUAL NET GHG EMISSIONS FROM

OPERATION OF THE PROJECT WITH

BUILDING A RESIDENTIAL/COMMERCIAL
Source
Emissions
(MTCO2e/yr)
Area 6
Energy 2,249
Mobile 798
Stationary - Generators 9
Waste 62
Water 110
Gross Operational Emissions 3,233
Existing Operational Emissions (Table 3.4-2) 1,616
Net Operational Emissions 1,618
MTCO2e/yr: metric tons of carbon dioxide equivalent per year Notes:
 Totals may not add due to rounding variances.
 Detailed calculations in Appendix B, Air Quality and Greenhouse Gas Emissions Modeling Data.

Table 3.4-9, GHG Efficiency Metric for the Project with Building A Residential/Commercial, shows the Project with Building A Residential/Commercial’s GHG efficiency using Option B from the City’s CAP. According to Section 2.0, Project Description, the Project with Building A Residential/Commercial would add 810 service persons to the Project site (715 residents and 95 full-time employees). Based on the service population of 810 SP, the GHG efficiency metric would be 2.15 MTCO2e/SP, which does not exceed the City’s CAP GHG efficiency threshold of 3.57 MTCO2e/SP for 2026. As such, the Project with Building A Residential/Commercial has demonstrated consistency with the City’s CAP, and would not generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment. There would be a less than significant impact, and no mitigation is required.

Affinity Project Draft EIR

3.4-19 Greenhouse Gas Emissions
TABLE 3.4-9

GHG EFFICIENCY METRIC FOR THE PROJECT WITH

BUILDING A RESIDENTIAL/COMMERCIAL
Source Emissions
Construction Emissions (Amortized) (MTCO2e/yr) 121a
Net Operational Emissions (MTCO2e/yr) 1,618b
Annual GHG Emissions (MTCO2e/yr) 1,739c
Service Population 810
Project with Building A Residential/Commerciallevel GHG efficiency (MTCO2e/SP/yr) 2.15 GHG Efficiency Threshold for 2026 (MTCO2e/SP/yr)d 3.57
Exceed Threshold? No
MTCO2e/yr.: metric tons of carbon dioxide equivalent per year; SP: service person a Total derived by dividing construction emissions (see Table 3.4-7) by 30. b Total operational emissions are the gross operational emissions with a net reduction of existing emissions (see Table 3.4-5). c
Annual emissions include the amortized construction emissions and the net operational emissions. d
City of Pasadena CAP Option B Threshold for the year 2026 (see Table 3.4-3).

Threshold 3.4b: Would the Project conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases?
Project
A lead agency may assess the significance of GHG emissions by determining a project’s consistency with a local GHG reduction plan or CAP that qualifies under Section 15183.5 of the State CEQA Guidelines. A CAP is designed to ensure that development within a jurisdiction occurs in a manner that supports the goals of AB 32. The City adopted its CAP on March 5, 2018.

As described above, the CAP is a long-range planning document that guides the City towards long-term emissions reductions in accordance with State of California goals. The CAP analyzes emission sources within the City, forecasts future emissions, and establishes emission reduction targets. This CAP is the City’s roadmap to achieving the City’s 2030 target and State-mandated goal of 40 percent below 1990 levels by 2030, with the ultimate goal of achieving carbon neutrality by 2045. Thus, the CAP is consistent with State plans, policies, and regulations, AB 32, the AB 32 Scoping Plan and updates, EO B-30-15, SB 32, and EO B-55-18. However, to provide further substantiation that the Project would be consistent with State plans, policies, and regulations, Project consistency with the SCAG 2020–2045 RTP/SCS Connect SoCal, CARB’s California’s Climate Change Scoping Plan (Scoping Plan), and Statewide GHG reduction goals for 2030 or 2050 identified in EO S-3-05 and SB 32, is discussed below.

SCAG’s Connect SoCal plan is centered on maintaining and better managing the transportation network for moving people and goods, while expanding mobility choices by locating housing, jobs, and transit closer together, and increasing investment in transit and complete streets. Connect SoCal’s “Core Vision” includes the following categories: Sustainable Development, System Preservation and Resilience, Demand and System Management, Transit Backbone, Complete Streets, and Goods Movement. The Core Visions detail strategies to implement the goals of Connect SoCal. These strategies include, but are not limited to, the following: focus growth near destinations and mobility options; promote diverse housing choices; leverage technology innovations; support implementation of sustainability policies; and promote a green region (SCAG Affinity Project Draft EIR

3.4-20 Greenhouse Gas Emissions
2020b). The Project would not conflict with these strategies, as it would provide employment opportunities and residential uses on-site and proximate to other related uses. Furthermore, as described in Section 2.0, Project Description, of this Draft EIR, the Project is an infill and mixeduse development project, and is within a Transit Priority Area (TPA) and High-Quality Transit Area HQTA, as defined by the SCAG. Therefore, the Project would provide access for visitors, employees, and residents at the Project site to utilize mass-transit options to travel to and from the site. The Project would promote diverse housing choices by providing assisted living and independent living units on-site, along with medical uses. This would reduce reliance on singleoccupancy vehicles. The infill redevelopment component of the Project would accommodate new growth, which would increase connectivity in the existing City neighborhood, especially considering that the Project site is currently underutilized with surface parking and no housing onsite. Additionally, the Project would comply with all pertinent regulations to reduce GHG emissions, including Title 24 Energy Efficiency Standards for Residential and Nonresidential Buildings and the California Green Building Standards Code, which would involve the development of electric vehicle charging infrastructure and bicycle storage and parking. This would assist the City in the transition from fossil fuel-based transportation. Therefore, the Project would not conflict with the Connect SoCal plan.

The CARB adopted the Scoping Plan to implement AB 32. The Scoping Plan was adopted in 2008 and updated in 2014 and 2017 and provides a framework for actions to reduce the State’s GHG emissions. Statewide plans and regulations, including, but not limited to, light duty vehicle GHG emissions standards, Advanced Clean Car standards, Low Carbon Fuel Standard, Renewable Portfolio Standards, Energy Efficiency Standards for Residential and Nonresidential Buildings, and California Green Building Standards, are being implemented. The Scoping Plan requires CARB and other State agencies to adopt regulations and other initiatives to reduce GHGs in the State. The Scoping Plan is not directly applicable to specific projects, nor is it intended to be used for project-level evaluations. The policies and regulations adopted for the purposes of supporting the Scoping Plan documents (i.e., AB 32, SB 32, EO S-3-05) specify reduction targets for the State. For example, EO S-3-05 establishes the following goals: GHG emissions should be reduced to 2000 levels by 2010, to 1990 levels by 2020, and to 80 percent below 1990 levels by 2050. The 2017 Scoping Plan focuses on GHG reduction targets for 2030, as specified in EO B-30-15 and now SB 32, and the path to meet 2050 GHG emissions goals. At the time of preparation of this EIR, no plans, policies, or regulations that are specific to SB 32 and applicable to the Project have been adopted. The Project would not conflict with the goals of the Scoping Plan and its updates, as the Project would be consistent with the City’s CAP and would not exceed the City’s CAP Option B GHG threshold of 3.57 MT CO2e per service persons for the operational year of 2026. Additionally, per the reasons described above, including the Project’s mixed-use nature within a TPA and HQTA, and because the Project would not exceed the threshold in the City’s CAP, this analysis supports the conclusion that the Project would not impede the State’s trajectory toward the previously described Statewide GHG reduction goals for 2030 or 2050.

Although VMT would be higher for the Project than existing conditions, as detailed further in Section 3.9, Transportation, of this Draft EIR, the Pasadena DOT determined that the Project would not exceed any of the CEQA transportation thresholds defined in the City’s TIA guidelines.

With implementation of the Project, there would be a higher efficiency of trips, as mixed uses would be located proximate to each other and public transit options. For example, the Los Angeles County Metropolitan Transportation Authority (Metro) Gold (L) Line runs adjacent to the western site boundary. The nearest light rail platforms are Del Mar Station and Fillmore Station, located approximately ¼-mile due north and due south, respectively. Additional public transit service present near the site includes the California Boulevard/Arroyo Parkway Metro bus stop located in the right-of-way (ROW) on the southern site boundary, and the Bellevue Drive/Arroyo Parkway Metro bus stop located in the ROW at the northeast corner of the site. Multimodal transportation Affinity Project Draft EIR

3.4-21 Greenhouse Gas Emissions
is encouraged with the availability of bicycle racks on Metro, Pasadena Transit, and City of Los Angeles Department of Transportation (LADOT) buses and at each Metro Gold (L) Line Station.

In addition, bicycles are allowed onto Metro Gold (L) Line trains. Transit facilities provided by these agencies within ¼-mile of the Project site include the following: Pasadena Transit bus routes 20, 51, 52; Metro bus routes 177, 256, 501, 686, and 687; and Metro Gold (L) Line (light rail).

Public transit availability would reduce vehicle trips and associated GHG emissions when compared with locations without similar transit attributes. Additionally, the Project would provide bicycle parking to encourage reduction of fossil-fueled vehicle use by employees and the associated GHG emissions, and it would provide new facilities for charging of electric vehicles, and parking for low-emission vehicles.

As discussed above under Threshold 3.4a, the Project’s GHG efficiency metric would be below the City’s CAP GHG efficiency threshold of 3.57 MTCO2e/SP. The provision of infill development at a higher density than the existing land uses near high-quality transit service supports the goals and policies of the CAP, thereby supporting AB 32, the AB 32 scoping plan and updates, EO B30-15, SB 32, and EO B-55-18. Therefore, the Project would not conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing GHG emissions. The impact would be less than significant, and no mitigation is required.

Project with Building A Residential/Commercial
Consistent with the Project, the Project with Building A Residential/Commercial’s GHG efficiency metric would be below the City’s CAP GHG efficiency threshold of 3.57 MTCO2e/SP, per Option B. As such, the Project with Building A Residential/Commercial has also demonstrated consistency with an applicable plan, policy, or regulation adopted for the purposes of reducing GHG emissions. However, to provide further substantiation that the Project with Building A Residential/Commercial would be consistent with State plans, policies, and regulations, Project with Building A Residential/Commercial consistency with the SCAG 2020–2045 RTP/SCS Connect SoCal, CARB’s California’s Scoping Plan, and Statewide GHG reduction goals for 2030 or 2050 identified in EO S-3-05 and SB 32, is discussed below.

Consistent with the Project, the Project with Building A Residential/Commercial would not conflict with SCAG’s Connect SoCal plan. The Project with Building A Residential/Commercial would provide employment opportunities and residential uses on-site and proximate to other related uses. Additionally, the Project with Building A Residential/Commercial is an infill and mixed-use development project and is within a TPA and HQTA, and would therefore provide access for visitors, employees, and residents at the Project site to utilize mass-transit options to travel to and from the site. The infill redevelopment component of the Project with Building A Residential/Commercial would accommodate new growth, which would increase connectivity in the existing City neighborhood, especially considering that the Project site is currently underutilized with surface parking and no housing onsite. Additionally, the Project with Building A Residential/Commercial would comply with all pertinent regulations to reduce GHG emissions, including Title 24 Energy Efficiency Standards for Residential and Nonresidential Buildings and the California Green Building Standards Code. Therefore, the Project would not conflict with the Connect SoCal plan. Regarding consistency with the CARB Scoping Plan, the Project with Building A Residential/Commercial would also not conflict with the goals of the Scoping Plan and its updates, as the Project with Building A Residential/Commercial would be consistent with the City’s CAP and would not exceed the City’s CAP Option B GHG threshold of 3.57 MTCO2e per service persons for the operational year of 2026. Because the Project with Building A Residential/Commercial would not exceed the threshold in the City’s CAP, and all of the reasons stated above, this analysis supports the conclusion that the Project with Building A Residential/Commercial would not impede the State’s trajectory toward the previously described Statewide GHG reduction goals for 2030 or 2050.

Affinity Project Draft EIR

3.4-22 Greenhouse Gas Emissions
Although VMT would be higher for the Project with Building A Residential/Commercial than existing conditions, the Pasadena DOT determined that the Project with Building A Residential/Commercial would not exceed any of the CEQA transportation thresholds defined in the City’s TIA guidelines. Compared to the Project, the Project with Building A Residential/Commercial would have substantively lower VMT per Capita and lower VT per Capita.

With implementation of the Project with Building A Residential/Commercial, there would be a higher efficiency of trips, as mixed uses would be located proximate to each other and public transit options. Additionally, the Project with Building A Residential/Commercial would also provide bicycle parking to encourage reduction of fossil-fueled vehicle use by employees and the associated GHG emissions and would provide new facilities for charging of electric vehicles and parking for low-emission vehicles. Therefore, the Project with Building A Residential/Commercial would not conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing GHG emissions. This is consistent with the findings for the Project. The impact would be less than significant, and no mitigation is required.

3.4.6 CUMULATIVE IMPACTS
Project
Because the magnitude of global GHG emissions is extremely large when compared with the emissions of typical development projects, it is accepted as very unlikely that any individual development project would have GHG emissions of a magnitude to directly impact global climate change. CAPCOA’s CEQA and Climate Change Report states, “GHG impacts are exclusively cumulative impacts; there are no non-cumulative GHG emission impacts from a climate change perspective” (CAPCOA 2008). As noted by the CNRA, “Due to the global nature of GHG emissions and their potential effects, GHG emissions will typically be addressed in a cumulative impacts analysis” (CNRA 2009b). Therefore, the analysis presented above represents the cumulative impact analysis of GHG emissions for the Project. As discussed, the Project would be below the GHG efficiency threshold and result in measures that are consistent with goals of the CAP. As such, the Project would have a less than significant impact and no mitigation is required.

Project with Building A Residential/Commercial
As stated above, the analysis presented above represents the cumulative impact analysis for the Project with Building A Residential/Commercial related to GHG emissions, and therefore, the Project with Building A Residential/Commercial would have a less than significant impact and no mitigation is required.

3.4.7 MITIGATION MEASURES
No significant impacts related to GHG emissions would occur, and no mitigation is required.

3.4.8 LEVEL OF SIGNIFICANCE AFTER MITIGATION
Less than significant.

3.4.9 SUMMARY OF ANALYSIS
Project
Option B of the CAP was utilized to establish consistency with the City’s CAP for the Project.

Based on the service population of 959 SP for the Project, the Project’s GHG efficiency metric would be 3.52 MTCO2e/SP, which does not exceed the City’s CAP GHG efficiency threshold of

3.57 MTCO2e/SP for 2026. As such, the Project has demonstrated consistency with the City’s Affinity Project Draft EIR

3.4-23 Greenhouse Gas Emissions
CAP, and the Project would not generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment. There would be a less than significant impact. As the Project would be consistent with the CAP, it would not conflict with an applicable plan, policy, or regulation adopted for the purposes of reducing GHG emissions. There would be a less than significant impact, and no mitigation is required.

Project with Building A Residential/Commercial
Option B of the CAP was utilized to establish consistency with the City’s CAP for the Project with Building A Residential/Commercial. Based on the service population of 810 SP for the Project with Building A Residential/Commercial, the GHG efficiency metric would be 2.15 MTCO2e/SP, which does not exceed the City’s CAP GHG efficiency threshold of 3.57 MTCO2e/SP for 2026. As such, the Project with Building A Residential/Commercial has demonstrated consistency with the City’s CAP, and would not generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment. There would be a less than significant impact and no mitigation is required. As the Project with Building A Residential/Commercial would be consistent with the CAP, it would not conflict with an applicable plan, policy, or regulation adopted for the purposes of reducing GHG emissions. There would be a less than significant impact, and no mitigation is required.

3.4.10 REFERENCES
California Air Pollution Control Officers Association (CAPCOA). 2021. California Emission Estimator Model (CalEEMod)TM Version 2020.4.0, Developed by Breeze Software, a division of Trinity Consultants in Collaboration with SCAQMD and other California Air Districts. Sacramento, CA: CAPCOA.
———. 2010 (August). Quantifying Greenhouse Gas Mitigation Measures: A Resource for Local Government to Assess Emission Reductions from Greenhouse Gas Mitigation Measures.

Sacramento, CA: CAPCOA. http://www.capcoa.org/wpcontent/uploads/2010/11/CAPCOA-Quantification-Report-9-14-Final.pdf. ———. 2008 (January). CEQA and Climate Change. http://www.capcoa.org/wpcontent/uploads/2012/03/CAPCOA-White-Paper.pdf California Air Resources Board (CARB). 2021a (accessed June 8). California Greenhouse Gas Emission Inventory - 2020 Edition. Sacramento, CA: CARB. https://www.arb.ca.gov/cc/inventory/data/data.htm.
———. 2021b (June 8, access date). Glossary of Air Pollution Terms. Sacramento, CA: CARB. http://www.arb.ca.gov/html/gloss.htm.
———. 2021c (June 8, access date). California's Greenhouse Gas Vehicle Emission Standards under Assembly Bill 1493 of 2002 (Pavley). https://ww2.arb.ca.gov/californiasgreenhouse-gas-vehicle-emission-standards-under-assembly-bill-1493-2002-pavley. ———. 2021d (June 8, access date). Advanced Clean Cars Program. https://ww2.arb.ca.gov/ourwork/programs/advanced-clean-cars-program/about. ———. 2021e (Accessed June 10). AB 32 Climate Change Scoping Plan, https://ww2.arb.ca.gov/our-work/programs/ab-32-climate-change-scoping-plan. ———. 2017 (November). California’s 2017 Climate Change Scoping Plan. Sacramento, CA:

CARB. https://ww2.arb.ca.gov/our-work/programs/ab-32-climate-change-scoping-plan.

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3.4-24 Greenhouse Gas Emissions
———. 2014. First Update to the Climate Change Scoping Plan: Building on the Framework Sacramento, CA: CARB. https://ww2.arb.ca.gov/our-work/programs/ab-32-climatechange-scoping-plan.

California Energy Commission (CEC). 2021a (April 11, last accessed). Clean Energy and Pollution Reduction Act—SB 350. Sacramento, CA: CEC.
https://www.energy.ca.gov/rules-and-regulations/energy-suppliers-reporting/cleanenergy-and-pollution-reduction-act-sb-350. ———. 2021b (April 11, last accessed). SB 100 Joint Agency Report. Sacramento, CA: CEC. https://www.energy.ca.gov/sb100.
———. 2021c (accessed February 19). 2019 Energy Efficiency Building Standards. https://www.energy.ca.gov/programs-and-topics/programs/building-energy-efficiencystandards/2019-building-energy-efficiency.

California Environmental Protection Agency (CalEPA). 2010 (December). Climate Action Team Report to Governor Schwarzenegger and the California Legislature. Sacramento, CA:

CalEPA. http://www.energy.ca.gov/2010publications/CAT-1000-2010-005/CAT-1000- 2010-005.PDF.

California Natural Resources Agency (CNRA). 2009a. 2009 California Climate Adaptation Strategy. Sacramento, CA: CNRA.
https://resources.ca.gov/CNRALegacyFiles/docs/climate/Statewide_Adaptation_ Strategy.pdf.
———. 2009b (December). Final Statement of Reasons for Regulatory Action. Sacramento, CA:

CNRA.https://resources.ca.gov/CNRALegacyFiles/ceqa/docs/Final_ Statement_of_Reasons.pdf.

Climate Watch. 2021 (accessed October 21). Data Explorer. Washington, D.C.: Climate Watch. https://www.climatewatchdata.org/data-explorer/historical-emissions?historicalemissions-data-sources=cait&historical-emissions-gases=all-ghg&historical-emissionsregions=All%20Selected&historical-emissions-sectors=total-including-lucf&page=1.

National Aeronautics and Space Administration (NASA). 2021 (January 14, Posted). 2020 Tied for Warmest Year on Record NASA Analysis Shows: NASA, NOAA. New York, NY: NASA, the Goddard Institute for Space Studies.
https://www.giss.nasa.gov/research/news/20210114//.

Pasadena, City of (Pasadena). 2018 (March 5). Climate Action Plan. Pasadena, CA: City of. https://www.cityofpasadena.net/planning/wp-content/uploads/sites/30/Final-PasadenaClimate-Action-Plan_3.5.2018.pdf?v=1634847783378. ———. 2017 (December 28). Appendix D – Climate Action Plan Consistency Checklist.

Pasadena, CA: City of. https://ww5.cityofpasadena.net/planning/wpcontent/uploads/sites/56/2017/12/D-CAP-Consistency-Checklist.pdf.

Pasadena Department of Transportation (Pasadena DOT). 2021a (March 22). Transportation Impact Analysis, Outside of CEQA Analysis. Project Address: 491-577 South Arroyo Parkway. Demolition of approximately 46,000 sf commercial. Construction of 151,000 sf medical office, 3,000 sf commercial, 184,376 sf senior living facility consisting of 95 independent living units and 85,800 sf assisted living. 5,882 sf restaurant to remain.

Pasadena, CA: Pasadena DOT.

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3.4-25 Greenhouse Gas Emissions
———.2021b (June 17). Transportation Impact Analysis, Outside of CEQA Analysis. Project Address: 491-577 South Arroyo Parkway. Project Summary: Demolition of approximately 46,000 sf commercial. Construction of 151,000 sf residential building with up to 197 units, 3,000 sf commercial, 184,376 sf senior living facility consisting of up to 95 independent living units and 85,800 sf assisted living. 5,882 sf restaurant to remain. Pasadena, CA:

Pasadena DOT.
———. 2021c (June 17). Transportation Impact Analysis, CEQA Evaluation, Project Address 491- 577 South Arroyo Parkway. Project Summary: Demolition of approximately 46,000 sf commercial. Construction of 151,000 sf residential building with up to 197 units, 3,000 sf commercial, 184,376 sf senior living facility consisting of up to 95 independent living units and 85,800 sf assisted living. 5,882 sf restaurant to remain. Pasadena, CA: Pasadena DOT. Appendix G-2.
———. 2020 (November 30). Transportation Impact Analysis, CEQA Evaluation, Category 2, Project Address 491-577 South Arroyo Parkway. Project Summary: Demolition of approximately 46,000 sf commercial. Construction of 151,000 sf residential building with up to 197 units, 3,000 sf commercial, 184,376 sf senior living facility consisting of up to 95 independent living units and 85,800 sf assisted living. 5,882 sf restaurant to remain.

Pasadena, CA: Pasadena DOT. Appendix G-1.

South Coast Air Quality Management District (SCAQMD). 2021 (June 10, access date). About South Coast AQMD: Diamond Bar, CA: SCAQMD. https://www.aqmd.gov/nav/about. ———. 2010 (September 28). Greenhouse Gas CEQA Significance Threshold Stakeholder Working Group Meeting #15 (slide presentation). Diamond Bar, CA: SCAQMD. http://www.aqmd.gov/docs/default-source/ceqa/handbook/greenhouse-gases-(ghg)- ceqa-significance-thresholds/year-2008-2009/ghg-meeting-15/ghg-meeting-15-mainpresentation.pdf?sfvrsn=2. ———. 2008 (October). Draft Guidance Document – Interim CEQA Greenhouse Gas (GHG) Significance Thresholds. Diamond Bar, CA: SCAQMD.
http://www.aqmd.gov/docs/default-source/ceqa/handbook/greenhouse-gases-(ghg)- ceqa-significance-thresholds/year-2008-2009/ghg-meeting-6/ghg-meeting-6-guidancedocument-discussion.pdf?sfvrsn=2.

Southern California Association of Governments (SCAG). 2020a (May). Certified Program Environmental Impact Report. Connect SoCal, The 2020-2045 Regional Transportation Plan/ Sustainable Communities Strategy of The Southern California Association Of Governments. Los Angeles, CA. SCAG. https://scag.ca.gov/read-plan-adopted-final-plan. ———. 2020b (Adopted September 3). Connect SoCal, The 2020-2045 Regional Transportation Plan/ Sustainable Communities Strategy of The Southern California Association Of Governments. Los Angeles, CA. SCAG. https://scag.ca.gov/read-plan-adopted-final-plan. ———. 2016 (April). The 2016–2040 Regional Transportation Plan/Sustainable Communities Strategy. A Plan for Mobility, Accessibility, Sustainability and a High Quality of Life. Los Angeles, CA: SCAG. http://scagrtpscs.net/Documents/2016/final/f2016RTPSCS.pdf.

U.S. Department of Commerce, National Oceanic and Atmospheric Administration, Earth System Research Laboratory, Global Monitoring Laboratory (ESRL) 2021 (last updated October 5). Trends in Atmospheric Carbon Dioxide. Boulder, CO: ESRL. https://gml.noaa.gov/ccgg/trends/global.html.

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3.4-26 Greenhouse Gas Emissions
U.S. Environmental Protection Agency (USEPA). 2021a (accessed July 15). Endangerment and Cause or Contribute Findings for Greenhouse Gases under Section 202(a) of the Clean Air Act. Washington, D.C.: USEPA. epa.gov/ghgemissions/endangerment-and-cause-orcontribute-findings-greenhouse-gases-under-section-202a-clean. ———. 2021b (Accessed October 21). Notice of Reconsideration of a Previous Withdrawal of a Waiver for California’s Advanced Clean Car Program (Light-Duty Vehicle Greenhouse Gas Emission Standards and Zero Emission Vehicle Requirements). Washington, D.C.:

USEPA. https://www.epa.gov/regulations-emissions-vehicles-and-engines/noticereconsideration-previous-withdrawal-waiver.

U.S. Environmental Protection Agency and U.S. Department of Transportation, National Highway Traffic Safety Administration (USEPA and NHTSA). 2019 (September 19). One National Program Rule on Federal Preemption of State Fuel Economy Standards. ———. 2012 (October 15). 2017 and Later Model Year Light-Duty Vehicle Greenhouse Gas Emissions and Corporate Average Fuel Economy Standards. Federal Register (Volume 77, No. 199, pp. 62623–63200). Washington, D.C.: USEPA and NHTSA.

Affinity Project Draft EIR

3.5-1 Hazards and Hazardous Materials

3.5 HAZARDS AND HAZARDOUS MATERIALS
This section analyzes potential hazards from current and/or past uses on and near the Project site and use and transport of hazardous materials during construction and operation of the Project and Project with Building A Residential/Commercial. Information in this section is derived in part from the Phase I Environmental Site Assessment; 465, 491, 503, 525 and 577 South Arroyo Parkway, Pasadena, California 91105 (Phase I ESA), prepared by EMG and dated April 2020 (EMG 2020). The Phase I ESA is provided in Appendix E of the Draft EIR.

3.5.1 EXISTING CONDITIONS
Historic and Current Uses of the Project Site
As discussed in Section 2.0, Environmental Setting and Project Description, the Project site consists of five parcels developed with a total of nine commercial buildings with seven businesses.

Table 2-1 summarizes the existing on-site land uses.

TABLE 3.5-1

SUMMARY OF EXISTING LAND USES
Address Existing Use Building Size Disposition
465 S. Arroyo Parkway Whole Foods Grocery 73,671 sf To Be Retained 491/495 S. Arroyo Parkway K9 Loft 12,676 sf To Be Demolished 499/503 S. Arroyo Parkway Corporate Furniture Resource 21,437 sf To Be Demolished 501 S. Arroyo Parkway Gold Line Pilates 2,880 sf Historic Resource; To Be Retained 523 S. Arroyo Parkway Town & Country Event Rentals 3,002 sf Historic Resource; To Be Retained 541 S. Arroyo Parkway Little Lily’s Kitchen 7,493 sf To Be Demolished 577 S. Arroyo Parkway Guisado’s Restaurant 4,306 sf To Be Demolished S.: South; sf: square feet
The Phase I ESA included a chronological history of the Project site uses. Based on review of historical documentation, on-site development was identified beginning in the 1890s (EMG 2020).

Table 3.5-2 summarizes the land use history of the Project site roughly by decade. These land uses had a wide variety of tenants, which are listed in the Phase I ESA provided in Appendix E.

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3.5-2 Hazards and Hazardous Materials
TABLE 3.5-2

LAND USE HISTORY
Years Land Use(s)
1890s Residences and vacant lots
1900s A factory and vacant lots
1910s Vacant building and vacant lots
1920 to Mid-1930s Various commercial buildings (including current 485-497, 499/511 and 501 Arroyo Parkway buildings) and vacant lots
Late 1930s to 1940s Various commercial buildings (including current 485-497, 499/511 and 501 Arroyo Parkway buildings) and a service station on the southeast portion of the site 1950s to Early 1960s
Various commercial buildings (including current 485-497, 499/511, 501, 523 and 541 Arroyo Parkway buildings) and a service station on the southeast portion of the Project.

Of note, a “gasol pump” was noted on the 1950 Sanborn map located on the southeast corner of the 499/511 Arroyo Parkway buildings building Mid-1960s to Late 1960s Various commercial buildings (including current 485-497, 499/511, 501, 523 and 541 Arroyo Parkway buildings) and a service station on the southeast portion of the site 1970s
Various commercial buildings (including current 485-497, 499/511, 501, 523 and 541 Arroyo Parkway buildings) and a service station on the southeast portion of the site. Of note, a “gasol” pump was noted on the southeast corner of the 499/511 Arroyo Parkway buildings in the 1970 Sanborn map.
1980s to Early 1990s Various commercial buildings (including current 485-497, 499/511, 501, 523 and 541 Arroyo Parkway buildings) and a service station on the southeast portion of the site Mid-1990s to Late 1990s Various commercial buildings (including current 485-497, 499/511, 501, 523 and 541 Arroyo Parkway buildings)
Early 2000s to Mid-2000s
Various commercial buildings (including current 485-497, 499/511, 501, 523 and 541 Arroyo Parkway buildings) and a service station on the southeast portion of the site. Of note, the service station was demolished in approximately 2002 and replaced by the current 577 Arroyo Parkway building
2008 to Current Various commercial buildings (including current 441-483, 485-497, 499/511, 501, 523, 541 and 577 Arroyo Parkway buildings)
EMG. 2020 (April 30). Phase I Environmental Site Assessment; 465, 491, 503, 525 and 577 South Arroyo Parkway, Pasadena, California 91105. Owings Bills, MD: EMG. Appendix E.

Phase I Environmental Site Assessment
The purpose of a Phase I ESA is to identify “recognized environmental conditions” or RECs, which are defined as “the presence or likely presence of any hazardous substances or petroleum products on a property under conditions that indicate an existing release, a past release, or a material threat of a release of any hazardous substance or petroleum products into structures on the property or into the ground, groundwater, or surface water of the property”. Therefore, a Phase I ESA addresses the potential for site contamination due to past or present land uses and the potential for future site contamination based on current conditions on and surrounding a site.

The Phase I ESA did not identify any current RECs that warranted further site investigation (e.g., soil and/or water testing) based on current or historic uses of the site. The Phase I ESA also reviewed off-site facilities that have suspected or documented environmental concerns or RECs that could negatively impact the Project site. It was determined that no off-site facilities have the potential to impact the Project site, and there are no applicable RECs (EMG 2020).

Historical Recognized Environmental Condition
The Phase I ESA concluded that there was one Historical REC. An Historical REC is defined under American Society for Testing and Materials (ASTM) E1527–13 as a past release of any Affinity Project Draft EIR

3.5-3 Hazards and Hazardous Materials
hazardous substances or petroleum products that has occurred in connection with the property and has been addressed to the satisfaction of the applicable regulatory authority or meeting unrestricted residential use criteria established by a regulatory authority, without subjecting the property to any required controls (e.g., property use restriction, AULS, institutional controls, or engineering controls), at the time the Phase I ESA is conducted. Essentially, this means a property was, or would have been, categorized as an REC at some point in the past, but has been remediated (i.e., cleaned up) to a point that it is not considered an REC at the time the Phase I ESA is prepared (in this case 2020).

As part of the Phase I ESA, it was determined that a former ARCO station at 125 East California Boulevard was located on the Project site from approximately the 1930s to 2002 and utilized at least three underground storage tanks (USTs). This facility was on the southern portion of the site, the location of the current restaurant at 577 South Arroyo Parkway (EMG 2020).

An unauthorized gasoline release impacting groundwater was first reported in 1988 and soil vapor extraction operations were initiated. In 1998, three USTs were removed from the site and various soil and groundwater investigations were subsequently conducted. The station received a “no further action” letter from the Pasadena Fire Department (PFD) dated May 24, 2000. However, the former ARCO site also received an additional clarification letter regarding this “no further action” letter stating that while the site has complied with the regulatory requirements for the site investigation/remediation, contamination remained at the site below regulatory action levels. A Declaration of Environmental Restriction allowing access for remediation was recorded on August 21, 2002, that was to terminate 90 days after No Further Action was received. Quarterly monitoring was conducted, and 761 cubic yards of soil was removed. The Los Angeles Regional Water Quality Control Board (LARWQCB) granted case closure on December 3, 2004, with no property use restrictions, activity and use limitations, institutional controls, or engineering controls.

The monitoring wells were abandoned in 2005. The Phase I ESA concluded that based on the “no further action” status, the historical use of the Project as a service station represents a Historical REC (EMG 2020). As noted above, there are no controls on this portion of the site related to this past gasoline release and remediation.

Other Notable Findings
The Phase I ESA also identified other findings related to current and past land uses that were determined to be “de minimis conditions” or otherwise did not rise to the level of an REC; these are described below.

Gasoline Pump
A “gasol” pump was identified in the southeastern corner of what was then 511 South Arroyo Parkway based on Sanborn maps dated 1950 and 1970. This is no longer a street address in use; this would be in the central portion of the Project site in the area now occupied by the structure at 501 South Arroyo Parkway. “Gasol” is an abbreviated term for gasoline, which is used on Sanborn maps during this time period. A “gasol” pump generally consists of a fuel dispenser and most commonly a mechanical pump and nozzle. Based on the lack of information related to the historical presence of a “gasol” pump on-site, Ramboll US Corporation (Ramboll) conducted a Phase II Environmental Site Assessment to evaluate the subsurface conditions in the vicinity of the pump. On February 13, 2018, Spectrum Geophysics of Chatsworth conducted a geophysical survey to mark subsurface utility lines, subsurface structures, and underground obstructions in the area of concern. During the geophysical survey, two approximately two-inch-diameter metal conduits were observed extending above ground surface in the general vicinity of the former “gasol” pump (EMG 2020).

Affinity Project Draft EIR

3.5-4 Hazards and Hazardous Materials
One conduit was located within an elevated concrete pad, extended approximately three inches above the ground surface and was backfilled with concrete. The second conduit extended approximately two inches above the ground surface and was open to an approximate depth of five feet below ground surface (bgs). A petroleum-like odor was noted on the measuring tape used to measure the total depth of the open conduit. Finally, a subsurface metallic anomaly, suggestive of piping, was detected approximately one-half foot bgs and extended laterally between the two aforementioned conduits. Two soil borings were also advanced to 20 feet bgs in the vicinity of the former pump. Soil samples were collected from borings at approximate depths of 5, 10, 15, and 20 feet bgs and were field screened for organic vapors with a photoionization detector (EMG 2020).

The soil samples were also submitted to a laboratory for the analysis of volatile organic compounds (VOCs), oxygenates and methyl tert butyl ether (MTBE), total petroleum hydrocarbons (TPH)-gasoline range organics (GRO), TPH-diesel range organics (DRO), TPH-oil range organics (ORO), and lead. Groundwater samples were not collected due to the typical depth to groundwater in the area (more than 140 feet bgs). No VOC, MTBE or TPH were detected in soil samples. Lead was detected at concentrations ranging from 3.8 mg/kg to 10 mg/kg; however, all concentrations were below the U.S. Environmental Protection Agency (USEPA) regional screening levels for residential and commercial/industrial use, and within typical background levels for California. Based on this information, the Phase I ESA stated the former “gasol” pump represents a de minimis condition associated with the site and no further action or investigation is recommended (EMG 2020).

Bus Facility and Fueling Station
The review of the historical data available for the site identified that a bus facility (and later a distributing company, auto repair facility, tire center and auto detailing shop) with an associated fueling station was located on the northern portion of the site, in the area of the current Whole Foods store, from approximately the 1930s through 2007. Sanborn Maps from 1950 through 1970 depicted “gas and oil tanks” in the southern portion of the Whole Foods site. Furthermore, a UST was formerly associated with 455 South Arroyo Parkway, in the area of the current Whole Foods store. No details regarding the size or contents of the UST were provided. Additionally, Absolute Automotive at 451 South Arroyo Parkway was listed on the historical auto station database which may have also been associated with this address/business. No records regarding the installation or removal of USTs were found during this assessment (EMG 2020).

As a three-story underground parking garage was constructed at the Whole Foods building, the Phase I ESA stated that it appears likely that any onsite USTs or potentially contaminated soils associated with USTs would have been excavated and removed during the construction of the parking garage. Based on the excavation of onsite soils during the redevelopment in 2008 and anticipated depth to groundwater (approximately 150 feet bgs), the former bus fueling facility and historical USTs do not appear to represent a REC. The Phase I ESA concluded that no further action or investigation is recommended (EMG 2020).

Hazardous Building Materials
Based on the date of construction (1921, 1925, 1951, 2003 and 2008), there is a potential that asbestos containing materials (ACMs) exist at the Project. The suspect asbestos containing roofing materials, ceiling tile, wallboard/joint compound, vinyl floor tile, vinyl sheet flooring and various mastics were observed in generally good condition except for some limited areas of damage noted in the 499/511 Arroyo Parkway building and the 577 Arroyo Parkway building (EMG 2020).

Affinity Project Draft EIR

3.5-5 Hazards and Hazardous Materials
Considering the dates of construction (1921, 1925, 1951, 2003 and 2008), there is a potential that there is lead-based paint existing at the site. The painted surfaces were observed to be in generally good condition, with no chipping, peeling, or cracking paint observed. All paint applied prior to 1978 is considered suspect (EMG 2020).

Waste Generation
One cooking grease bin and an in-ground grease trap, which were not currently in use, were identified at the vacant former Margarita Jones restaurant (541 South Arroyo Parkway) and an additional in-ground grease trap, which is not currently in use was identified at the 577 South Arroyo Parkway building located on the southwest portion of the site, which was vacant at the time the Phase I ESA was prepared and is now operating as Guisado’s Restaurant. In addition, a 55-gallon drum was observed on the southwest portion of the site. According to labeling on the drum, the contents are “Non-hazardous” and consist of soil cuttings that were generated during the completion of a subsurface investigation at the Project in 2018. No evidence of releases from the grease bin, traps or drum, such as staining or dead vegetation, was observed. The cooking grease in the bin and any remaining cooking grease located in the grease traps, as well as the contents of the soil cutting drum, were recommended for disposal by a licensed contractor in accordance with applicable regulations in the Phase I ESA (EMG 2020). The Applicant reports the soil cuttings and cooking grease have been disposed of appropriately and restaurants now occupy the locations of the grease traps; these properties were unoccupied at the time of the Phase I ESA site reconnaissance.

3.5.2 RELEVANT PROGRAMS AND REGULATIONS
Federal
Resource Conservation and Recovery Act
The Resource Conservation and Recovery Act (RCRA) was authorized by Congress on October 21, 1976, through the amendment of the Solid Waste Disposal Act. This law creates the framework for the proper management of hazardous and non-hazardous solid waste. The California Environmental Protection Agency (CalEPA) and the Department of Toxic Substances Control (DTSC) regulate the generation, transportation, treatment, storage, and disposal of hazardous waste under both the RCRA and the California Hazardous Waste Control Act, discussed further below. Both laws impose “cradle-to-grave” regulatory systems for handling hazardous waste in a manner that protects human health and the environment.

Emergency Planning & Community Right to Know Act
The Emergency Planning & Community Right to Know Act (EPCRA) was enacted by Congress as the national legislation on community safety. This law was designated to help local communities protect public health, safety, and the environment from chemical hazards. The primary purpose of EPCRA is to inform communities and citizens of chemical hazards in their areas by requiring businesses to report the locations and quantities of chemicals stored on-site to State and local agencies. These reports help communities prepare to respond to chemical spills and similar emergencies.

Section 3131 of EPCRA requires manufacturers to report releases to the environment (i.e., air, soil, and water) of more than 600 designated toxic chemicals; report off-site transfers of waste for treatment or disposal at separate facilities; pollution prevention measures and activities; and participate in chemical recycling. These annual reports are submitted to the USEPA and state agencies. The USEPA maintains and publishes a database that contains information on toxic chemical releases and other waste management activities by certain industry groups and federal Affinity Project Draft EIR

3.5-6 Hazards and Hazardous Materials
facilities. This online, publicly available, national digital database is called the Toxics Release Inventory and was expanded by the Pollution Prevention Act of 1990.

To implement EPCRA, Congress required each state to appoint a State Emergency Response Commission (SERC) to coordinate planning and implementation activities associated with hazardous materials. The SERCs were required to divide their states into Emergency Planning Districts and to name a Local Emergency Planning Committee (LEPC) for each district. The federal EPCRA program is implemented and administered in California by the California Emergency Management Agency (Cal EMA), a SERC, six LEPCs, and 83 Certified Unified Program Agencies (CUPAs). Cal EMA provides staff support to the SERC and the LEPCs. The Governor's Office of Emergency Services (OES) coordinates and provides staff support for the SERC and LEPCs. Broad representation by firefighters, health officials, government and media representatives, community groups, industrial facilities, and emergency managers ensures that all necessary elements of the planning process are represented.

Hazardous Materials Transportation Act
The Hazardous Materials Transportation Act, promulgated under Title 49 of the CFR and administered by the U.S. Department of Transportation (DOT), governs the handling and transport of hazardous materials, including medical waste. In 1999, the DOT defined regulated medical waste as a hazardous material under Class 6.2 of the DOT regulations, thereby subjecting it to the provisions of the Hazardous Materials Transportation Act. The California Department of Transportation (Caltrans) implements these federal regulations for hazardous materials transported within California.

State
Medical Waste Management Act
The Medical Waste Management Act (MWMA) (California Health and Safety Code Sections 117600-118360) governs the management of medical waste in California. The Medical Waste Management Program (MWMP), administered by the California Department of Public Health (DPH), Environmental Management Branch, regulates the generation, handling, storage, treatment, and disposal of medical waste by providing oversight for the implementation of the MWMA. The MWMA regulates the storage, disposal, and transport of medical waste through a registration and permit process, including requirements for an on-site medical waste management plan. The regulations require special containers for medical, biohazardous, and sharps wastes; storage of medical waste in the common storage facility; segregation of the biohazard and medical wastes from other hazardous wastes; medical waste transportation requirements; the use of steam sterilization, incineration, microwave, or other approved technology to treat medical waste on site; protective clothing for handlers; treatment and tracking records; and annual inspection and enforcement provisions.

California Occupational Safety and Health Administration The Division of Occupational Safety and Health, better known as Cal/OSHA, protects and improves the health and safety of working men and women in California through setting and enforcing standards; providing outreach, education, and assistance; and issuing permits, licenses, certifications, registrations, and approvals. Employers are required to monitor worker exposure to listed hazardous substances and notify workers of exposure (8 California Code of Regulations [CCR] Sections 337‐340). Cal/OSHA regulations specify employer requirements including employee training, provision of safety equipment, accident‐prevention programs, and hazardous substance exposure warnings.

Affinity Project Draft EIR

3.5-7 Hazards and Hazardous Materials
Asbestos Abatement
Asbestos is a known human carcinogen, and the USEPA and CalEPA have identified asbestos as a hazardous air pollutant pursuant to Section 12 of the Federal Clean Air Act. Further, the California Air Resources Board (CARB) has identified asbestos as a Toxic Air Contaminant (TAC), pursuant to the California Health and Safety Code (Section 39650 et. seq.). Asbestos is also regulated as a potential worker safety hazard under the authority of the CalOSHA, discussed above. These rules and regulations prohibit emissions of asbestos from asbestos-related demolition or construction activities; require medical examinations and monitoring of employees engaged in activities that could disturb asbestos; specify precautions and safe work practices that must be followed to minimize the potential for release of asbestos fibers; and require notice to federal and local government agencies prior to beginning renovation or demolition that could disturb asbestos.

In California, asbestos abatement must be performed and monitored by contractors with appropriate certifications from the California Department of Health Services (DHS). In addition, CalOSHA has regulations to protect worker safety during potential exposure to asbestos under Title 8 of the California Code of Regulations (Section 1529 Asbestos). All demolition that could result in the release of asbestos must be conducted according to CalOSHA standards. These standards were developed to protect the general population and construction workers from respiratory and other hazards associated with exposure to these materials.

The South Coast Air Quality Management District’s (SCAQMD’s) Rule 1403 provides guidelines for the proper removal and disposal of asbestos-containing materials. In accordance with Rule 1403, structures that may contain asbestos are required to be subject to an asbestos survey by a Certified Asbestos Consultant (certified by CalOSHA) to identify building materials that contain asbestos. Under this rule, removal of asbestos must include prior SCAQMD notification; compliance with removal procedures and time schedules; asbestos-handling and clean-up procedures; and storage, disposal, and landfilling requirements.

Lead Abatement
Because of its toxic properties, lead is regulated as a hazardous material. Inorganic lead is also regulated as a TAC. In California, lead abatement must be performed and monitored by contractors with appropriate certifications from the California DHS. In addition, CalOSHA has adopted regulations to protect worker safety during potential exposure to lead under Title 8 of the California Code of Regulations (Section 1532.1 Lead). All demolition that could result in the release of lead must be conducted according to these standards, which were developed to protect the general population and construction workers from respiratory and other hazards associated with lead exposure.

Business Plan Act
In recognition of the dangers associated with keeping hazardous substances, the state legislature has enacted several laws regulating the use and transport of identified hazardous materials.

California’s Hazardous Materials Release Response Plans and Inventory Law, sometimes called the “Business Plan Act,” aims to minimize the potential for accidents involving hazardous materials and to facilitate an appropriate response to possible hazardous materials emergencies.

The law requires businesses that use hazardous materials to provide inventories of those materials to designated emergency response agencies, to illustrate on a diagram where the materials are stored onsite, to prepare an emergency response plan, and to train employees to use the materials safely.

Affinity Project Draft EIR

3.5-8 Hazards and Hazardous Materials
Chapter 6.95 of the California Health and Safety Code and Title 19 of the California Code of Regulations describe the requirements for chemical disclosure, business emergency plans, and community right-to-know programs. In particular, Chapter 6.95 requires all businesses using hazardous materials to inform local government agencies of the types and quantities of materials stored on site. This disclosure enables emergency response agencies to respond quickly and appropriately to accidents involving dangerous substances.

The State requires the owner or operator of any business that handles hazardous materials in quantities equal to or greater than 55 gallons, 500 pounds, or 200 cubic feet of gas at standard temperature and pressure, to develop and submit a business plan. The Governor’s Office of Emergency Services (OES), acting pursuant to Section 25503.3 of the Health and Safety Code, has developed a single comprehensive hazardous materials inventory form for businesses to use to submit their individual hazardous materials inventories. This form contains all State and federally required inventory information and use of this form is mandatory.

California Hazardous Waste Control Act
The California Hazardous Waste Control Act (HWCA), as found in the California Health and Safety Code (see Division 20, Chapter 6.5, Article 2, Section 25100, et seq.) authorizes the DTSC and local CUPA to regulate facilities that generate or treat hazardous waste. The HWCA authorizes CUPAs to perform the following actions:
• Conduct inspections of any factory, plant, construction site, waste disposal site, transfer station, establishment, or any other place or environment where hazardous wastes are stored, handled, processed, disposed of, or being treated to recover resources • Maintain records of compliance with the HWCA
• Require hazardous waste generators to pay inspection and administration fees to cover the costs of administering the provisions in the HWCA. Fees may include but shall not be limited to the costs of inspection, document development and processing, recordkeeping, enforcement activities, and informational materials development and distribution • Issue authorization for on-site treatment of hazardous waste to persons eligible to operate pursuant to permit-by-rule, conditional authorization, or conditional exemption • Enforce against violations of the HWCA
Local
Certified Unified Program Agency
Senate Bill (SB) 1082 (1993) established the Unified Hazardous Waste and Hazardous Materials Management Regulatory Program, which consolidates, coordinates, and makes consistent six different hazardous material/waste programs. A CUPA is an agency of a county or city that administers these State programs regulating hazardous materials and hazardous wastes.

Currently, there are 83 CUPAs in California.

The Los Angeles County Fire Department (LACFD) is the CUPA for much of Los Angeles County.

However, the Pasadena Fire Department (PFD) is designated as a participating agency and is authorized to implement one or more of the program elements within their jurisdiction. The LACFD and PFD administer the following programs:
• Hazardous Materials Release Response and Inventory Program; Affinity Project Draft EIR

3.5-9 Hazards and Hazardous Materials
• California Accidental Release Prevention Program (CalARP), a combination of federal and state programs for the prevention of accidental release of regulated toxic and flammable substances;
• Underground Storage Tanks (UST) Program;
• Aboveground Storage Tanks (AST) Program; and
• Hazardous Waste Generator Program.

Pasadena Municipal Code
Chapter 8.80, Handling and Disclosure of Hazardous Materials, of the Pasadena Municipal Code (PMC) is applicable to all businesses in the City that handle hazardous materials. It establishes uniform standards for disclosure, fees, and penalties associated with the proper handling of hazardous materials. The Pasadena fire chief is empowered to enforce compliance, and the PFD is authorized to clean up or abate the effects of any hazardous materials deposited on public or private property in the City.

3.5.3 THRESHOLDS OF SIGNIFICANCE
The following significance criteria are derived from Appendix G of the State CEQA Guidelines. A project would result in a significant adverse hazards and hazardous materials impact if it would:

Threshold 3.5a: Create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials; Threshold 3.5b: Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter-mile of an existing or proposed school; and/or
Threshold 3.5c: Be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would create a significant hazard to the public or the environment.

The Initial Study (provided in Appendix A-1) concluded the following thresholds related to hazards and hazardous materials were determined to result in no impacts or less than significant impacts and were not carried forward into the Draft EIR for further analysis:
• Would the project create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment?
• For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard or excessive noise for people residing or working in the project area? • Would the project impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan?
• Would the project expose people or structures, either directly or indirectly, to a significant risk of loss, injury, or death involving wildland fires? Affinity Project Draft EIR

3.5-10 Hazards and Hazardous Materials

3.5.4 METHODOLOGY
The contents of Phase I ESAs are defined by national record review requirements in accordance with both the ASTM E1527-13 Standard Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process and the USEPA Standards and Practices for All Appropriate Inquiries (40 Code of Federal Regulations [CFR] Part 312). The Phase I ESA for the proposed Project was conducted in accordance with these standards. The findings of the Phase I ESA would apply equally to the Project and Project with Building A Residential/Commercial.

3.5.5 ENVIRONMENTAL IMPACTS
Threshold 3.5a: Would the Project create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials?
Project
Hazardous materials are routinely used by businesses and private individuals. Common community businesses in urban areas that utilize hazardous materials include service stations, medical labs, dry cleaners, and photo-processing centers. In addition, commonly used household products such as paints, cleaners, oils, batteries, and pesticides contain hazardous materials.

Accordingly, hazardous materials that may be commonly encountered in a typical urban environment generally include petroleum products (including oil and gasoline); automotive fluids (antifreeze, hydraulic fluid); paint; cleaners (dry cleaning solvents, cleaning fluids); and pesticides from current or historical agricultural uses (if in significant concentrations). Accidental spills or leaks, illegal dumping of hazardous waste, improper storage, or a transportation accident could release hazardous materials or wastes in the community and pose public health and safety risks.

Operation of medical and medical-related facilities, such as the medical offices in Building A and assisted living facilities in Building B, would involve the routine transport, use, and disposal of hazardous materials (e.g., pharmaceutical products, medical gases, radioisotopes and x-ray producing machines, cleaners, solvents, medical and biological wastes). This would include the use of hazardous materials for various medical procedures and facility maintenance and generation of biomedical waste. These types of materials are typical of any medical facility and would not be considered acutely or unusually hazardous. Also, each proposed building would have a 50-kilovolt standby emergency engine diesel generator.

Health care facilities in California are licensed, regulated, inspected, and/or certified by several public and private agencies at the State and federal levels. In particular, the DPH Licensing and Certification Program is responsible for ensuring health care facilities comply with State laws and regulations. All medical and medical-related uses proposed for the Project would obtain required licenses/permits for the operation of the facility, including those needed for the laboratories, radiologic equipment, medical devices, workplace safety, radioactive materials, and certified professionals. Health care professionals at both the medical offices in Building A and the assisted living facilities in Building B would also be licensed individuals, where necessary.

All hazardous materials and/or wastes associated with the Project, including those related to proposed commercial uses and the presence of diesel generators, would be transported only by a Licensed Hazardous Waste Hauler, who must meet all applicable State and federal requirements, including U.S. DOT regulations under 49 Code of Federal Regulations (Hazardous Materials Transportation Act) and Caltrans standards pursuant to the Hazardous Materials Transportation Act to be licensed. Additionally, the Project would be required to comply with all applicable permitting, reporting, and other requirements of the following CUPA programs, Affinity Project Draft EIR

3.5-11 Hazards and Hazardous Materials
administered by the PFD and/or LACFD: Hazardous Materials Release Response and Inventory Program; CalARP; AST Program; and Hazardous Waste Generator Program.

These regulations would require permits, disclosure and inventory, spill prevention and response plans, monitoring and inspections, spill reporting, emergency procedures, employee training, remedial actions, and other compliance measures to prevent the release of hazardous materials into the environment. Thus, no public health hazards associated with the day-to-day operations of the Project would be created at the site. With compliance with all applicable regulations, the Project would not result in a significant hazard to the public or the environment related to the routine transport, use, disposal, and storage of hazardous materials. The Project would result in less than significant impacts, and no mitigation is required.

Project with Building A Residential/Commercial
The Project with Building A Residential/Commercial would not generate as much biomedical waste (categorized as hazardous materials) as the Project, since only the assisted living building would generate such materials. This development scenario would instead generate a mix of nonhazardous municipal waste and biomedical waste. Like the Project, the buildings would each have a standby emergency generator. Therefore, the same regulations for health care facilities would remain applicable to Building B, and the same regulations for commercial uses and the presence of diesel generators would remain applicable. Even though this scenario would not result in generating as much biomedical waste as the Project, the risk to the public or the environment would not be appreciably reduced under this scenario because 1) health care facilities are strictly regulated in California, and 2) the types of medical facilities and related materials used in either the Project or this scenario are typical of medical facilities and not acutely or unusually hazardous.

As with the Project, the Project with Building A Residential/Commercial would result in less than significant impacts, and no mitigation is required.

Threshold 3.5b: Would the Project emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within onequarter-mile of an existing or proposed school? Project
The Project site is within approximately one-quarter mile of the following three schools:
• Mayfield Junior School, 405 South Euclid Avenue;
• The Waverly School, 67 West Bellevue Drive; and
• Aria Montessori School, 693 South Euclid Avenue.

The emission or handling of hazardous materials or substances could pose hazards to nearby schools in the event of an accidental release or spill. As discussed under Thresholds 3.5(a) above and 3.5(c) below, construction and operation of the Project would involve the use of common hazardous substances, potential encounter of hazardous building materials (ACMs and LBP), and use of medical and medically related materials that can be categorized as hazardous.

As discussed below, compliance with SCAQMD Rule 1403 and the CalOSHA’s Title 8 regulations on asbestos and lead abatement would be a condition of Project approval and would ensure that handling and disposal of these materials is conducted safely and accident conditions during demolition activities would not be reasonably foreseeable. Handling and use of common hazardous materials, such as fuel, oil, and solvents, during construction was addressed in the Initial Study.

Affinity Project Draft EIR

3.5-12 Hazards and Hazardous Materials
As discussed above, there are several regulations pertaining to management of hazardous materials and wastes, including materials associated with health care facilities, that would apply to the operation of the Project. As noted, health care facilities are strictly regulated in California and the types of medical facilities and related materials used in the Project are typical of medical facilities and not acutely or unusually hazardous. All hazardous materials and/or wastes associated with the Project, including those related to proposed commercial uses and the presence of diesel generators, would be transported and handled in compliance with the Hazardous Materials Transportation Act and applicable CUPA programs. As such, an accidental release capable of affecting nearby schools is not reasonably foreseeable.

The Project would result in less than significant impacts related to emission of hazardous emissions or handling hazardous or acutely hazardous materials, substances, or waste within proximity to schools in the Project site vicinity, and no mitigation is required.

Project with Building A Residential/Commercial
As discussed above under Threshold 3.5(a), while the Project with Building A Residential/Commercial would generate relatively less biomedical waste than the Project, this development scenario would still generate biomedical waste. This is the only difference in construction or operation related to hazardous materials compared to the Project. Therefore, the same regulations for health care facilities would remain applicable to Building B, and the same regulations for commercial uses and the presence of diesel generators would remain applicable.

As such, like the Project, the Project with Building A Residential/Commercial would result in less than significant impacts related to schools in the Project site vicinity, and no mitigation is required.

Threshold 3.5c: Would the Project be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment?
Project
Cortese List and Other Listed Sites
Based on review of the Cortese List data resources, the Project site is not located on the State of California Hazardous Waste and Substances Sites List of sites published by CalEPA and compiled pursuant to Section 65962.5 of the California Government Code (referred to as the Cortese List). There is one site on the Cortese List located in the City of Pasadena, which is the Jet Propulsion Laboratory (CalEPA 2020), located approximately 4.25 miles to the northwest.

As discussed above, a Phase I ESA was conducted and identified no RECs related to current or historic land uses on or surrounding the Project site. The Phase I ESA did identify one Historical REC on the southern portion of the Project site based on a former service station and associated gasoline release that was remediated. Based on the “no further action” regulatory status of this portion of the Project site, the Phase I ESA states no further action or investigation is recommended (EMG 2020; Appendix E). As noted above, there are no controls on this portion of the site related to this past gasoline release and remediation.

Furthermore, a Historical REC is not a REC, defined under ASTM E1527-13 as the presence or likely presence of any hazardous substances or petroleum products in, on, or at a property:
(1) due to any release to the environment; (2) under conditions indicative of a release to the environment; or (3) under conditions that pose a material threat of a future release to the environment. For a past release to be determined a Historical REC, the release or other event must have been previously cleaned up or meet current regulatory standards without clean up. As Affinity Project Draft EIR

3.5-13 Hazards and Hazardous Materials
such, there are no conditions present on the site such that excavation activities would be expected to encounter on-site contamination. Handling and transport of hazardous materials, that would represent a significant hazard to construction workers, the public, or the environment, is not anticipated.

Hazardous Building Materials
The likely presence of ACMs and LPB at the site, due to the age of the buildings, was disclosed in the Initial Study (see Appendix A of this Draft EIR). Compliance with SCAQMD Rule 1403 and the CalOSHA’s Title 8 regulations on asbestos and lead abatement would be conditions for the Project approval and would ensure that handling and disposal of these materials is conducted safely, and accident conditions during demolition activities would not be reasonably foreseeable.

As such, the transport, use, and disposal of hazardous materials required for construction and the presence of ACMs and LBP in buildings to be demolished would not present a significant hazard to the construction workers, the public, or the environment. The Project would result in less than significant impacts, and no mitigation is required.

Project with Building A Residential/Commercial
The analysis of potential hazards related to location on a site identified on the Cortese List, past or present land uses, and/or hazardous building materials would be the same for both the Project and the Project with Building A Residential/Commercial. The analysis is based entirely on the history and/or current land uses on the site and the planned demolition of buildings that likely contain ACMs and/or LBP, and planned land uses have no bearing on the conclusions. The Project with Building A Residential/Commercial would result in less than significant impacts, and no mitigation is required.

3.5.6 CUMULATIVE IMPACTS
Project
Existing developments in the City, including health care facilities, pose risks to public health and safety with respect to the use, storage, handling, generation, transport, and disposal of hazardous materials. Future developments throughout the City would increase these risks as more facilities or operations may utilize hazardous materials or may be located on the Cortese list or other hazardous materials databases.

Regulations for a variety of activities and uses to protect public health and safety exist at all levels of government. Compliance of individual projects, including the Project, with pertinent regulations would preserve public health and safety and would prevent hazards to existing and future developments. Thus, with compliance with regulations, future growth and development in the City is not expected to present significant risks to public health and safety. Also, future growth and development would be subject to review and approval by the PFD and LACFD (i.e., CUPA), as applicable to land uses that handle hazardous materials and/or generate hazardous waste. The Project’s compliance with existing health and safety regulations as discussed in this section would prevent the creation of health risks and public safety hazards. Therefore, the Project’s contribution to cumulative impacts would be less than significant, and no mitigation is required.

Project with Building A Residential/Commercial
The cumulative impact analysis of hazards and hazardous materials for the Project with Building A Residential/Commercial would be the same as that of the Project.

Affinity Project Draft EIR

3.5-14 Hazards and Hazardous Materials

3.5.7 MITIGATION MEASURES
No significant impacts related to hazards and hazardous materials would occur, and no mitigation is required.

3.5.8 LEVEL OF SIGNIFICANCE AFTER MITIGATION
Less than significant.

3.5.9 SUMMARY OF ANALYSIS
Project
Construction and operation of the Project would not result in a significant hazard to the public or the environment related to the routine transport, use, disposal, and storage of hazardous materials through compliance with all applicable regulations. There would be a less than significant impact, and no mitigation is required. Construction and operation of the Project would not result adversely affect schools in the vicinity through compliance with applicable regulations.

There would be a less than significant impact, and no mitigation is required. There are no conditions present on the site due to current or historic land uses such that excavation activities would be expected to encounter on-site contamination. Handling and transport of hazardous materials, that would represent a significant hazard to construction workers, the public, or the environment, is not anticipated. There would be a less than significant impact, and no mitigation is required.

Project with Building A Residential/Commercial
The summary of findings for the Project with Building A Residential/Commercial would be comparable to the findings for the Project. The only difference is that this scenario would not generate as much biomedical waste (categorized as hazardous materials) as the Project. As with the Project, the Project with Building A Residential/Commercial would result in less than significant impacts related to hazards and hazardous materials, and no mitigation is required.

3.5.10 REFERENCES
EMG. 2020 (April 30). Phase I Environmental Site Assessment; 465, 491, 503, 525 and 577 South Arroyo Parkway, Pasadena, California 91105. Owings Bills, MD: EMG. Appendix E.

Affinity Project Draft EIR

3.6-1 Land Use and Planning

3.6 LAND USE AND PLANNING
This section discusses consistency of the proposed Project and Project with Building A Residential/Commercial with applicable City land use and planning documents and regulations as well as land use consistency. Information in this section is derived in part from City of Pasadena General Plan and its Environmental Impact Report (EIR) and the Central District Specific Plan (CDSP).

3.6.1 EXISTING CONDITIONS
On-Site and Surrounding Land Uses
The Project site consists of five parcels developed with a total of nine commercial buildings with seven businesses. All existing buildings on the site are one or two stories with heights ranging between 17 feet and 63 feet. All existing land uses have surface parking except for the Whole Foods Market, which has a 275-space subterranean parking structure for its sole use. Table 3.6-1 summarizes the existing on-site land uses; and Exhibit 2-2, Existing Project Site, in Section 2.0, Environmental Setting and Project Description, illustrates the addresses and locations of the nine existing buildings and other on-site land uses.

TABLE 3.6-1

SUMMARY OF EXISTING LAND USES
Address Existing Use Building Size Disposition
465 S. Arroyo Parkway Whole Foods Grocery 73,671 sf To Be Retained 491/495 S. Arroyo Parkway K9 Loft 12,676 sf To Be Demolished 499/503 S. Arroyo Parkway Corporate Furniture Resource 21,437 sf To Be Demolished 501 S. Arroyo Parkway Gold Line Pilates 2,880 sf Historic Resource; To Be Retained 523 S. Arroyo Parkway Town & Country Event Rentals 3,002 sf Historic Resource; To Be Retained 541 S. Arroyo Parkway Little Lily’s Kitchen 7,493 sf To Be Demolished 577 S. Arroyo Parkway Guisado’s Restaurant 4,306 sf To Be Demolished Total Existing Building Area 125,465 sf
S.: South; sf: square feet
The Project area is an urban environment, and the site and surrounding area are fully built out with a broad mix of land uses. These land uses also represent a variety of ages, architectural styles, heights, and conditions. Exhibit 2-3, Aerial Photograph, in Section 2.0 shows the site and existing land use types in the surrounding area.

Commercial land uses are primarily located to the north, including retail, services, and restaurants. Other land uses to the north include medical offices; Pasadena Humane Society, located approximately 0.1-mile to the northwest; Central Park, located approximately 0.2-mile northwest of the site; and single- and multi-family residential land uses located, at the nearest, approximately 0.2-mile to the north on Del Mar Boulevard and approximately 0.1-mile to the northnortheast on Bellevue Drive. Commercial land uses are located opposite the Project site on Arroyo Parkway. Single- and multi-family residential land uses are situated less than 0.1-mile to the east along Marengo Avenue and Arroyo Parkway. Land uses to the south include a mix of commercial, medical office, and single- and multi-family residential land uses; the latter is located along Marengo Avenue and California Boulevard to the southeast. To the west, there is a mix of commercial and non-profit (i.e., npr/KPCC and Union Station Homeless Services) uses. Further from the site, land uses include a mix of commercial, medical, light industrial, single- and multifamily residential, and public (e.g., schools, churches, parks).

Affinity Project Draft EIR

3.6-2 Land Use and Planning

3.6.2 RELEVANT PROGRAMS AND REGULATIONS
Regional
Southern California Association of Governments
The Southern California Association of Governments (SCAG) is the Metropolitan Planning Organization (MPO) for six counties: Los Angeles, Orange, San Bernardino, Riverside, Ventura, and Imperial Counties, an area that encompasses more than 38,000 square miles. As the designated MPO, the federal government mandates that SCAG research and draw up plans for transportation, growth management, hazardous waste management, and air quality. Among the many activities SCAG undertakes are the following:
 Maintaining a continuous, comprehensive, and coordinated planning process resulting in a Regional Transportation Plan (RTP) and a Federal Transportation Improvement Program (FTIP);
 Developing a Sustainable Communities Strategy (SCS) to reduce greenhouse gas emissions as required by applicable State law (SB 375) as an element of the RTP.

The RTP is a long-range transportation plan that is developed and updated by SCAG every four years to guide transportation investments throughout the region. The SCS is a required element of the RTP that integrates land use and transportation strategies to achieve California Air Resources Board emissions reduction targets pursuant to Senate Bill (SB) 375.

On September 3, 2020, the SCAG Regional Council adopted the 2020–2045 RTP/SCS (RTC/SCS; also referred to as Connect SoCal) and the addendum to the Connect SoCal Program Environmental Impact Report. The 2020–2045 RTP/SCS is a long-range visioning plan that builds upon and expands land use and transportation strategies established over several planning cycles to increase mobility options and achieve a more sustainable growth pattern. It charts a path toward a more mobile, sustainable, and prosperous region by making connections between transportation networks, between planning strategies, and between the people whose collaboration can improve the quality of life for Southern Californians (SCAG 2020).

High-Quality Transit Areas and Transit Priority Areas
High-Quality Transit Areas (HQTAs) are areas within one-half mile of a fixed guideway transit stop or a bus transit corridor where buses pick up passengers at a frequency of every 15 minutes or less during peak commuting hours. Transit Priority Areas (TPAs) are areas within one-half mile of a major transit stop that is existing or planned. The Project site is within both a HQTA and TPA.

City
Pasadena General Plan
The City adopted the current Pasadena General Plan in August 2015. In accordance with State law, the General Plan provides the overall framework for translating broad community values and expectations into goals and policies for managing growth and enhancing the quality of life in the City. The Land Use Element of the General Plan includes a series of Guiding Principles, which cumulatively represent the City’s vision for the future. Each of the Guiding Principles is addressed in the analysis below. In implementing the Guiding Principles, the Land Use Element establishes a framework for development that promotes higher density, mixed-use, urban environments oriented to transit and pedestrian activity within specific, high-quality areas of the City that reflect the historic scale and character of Pasadena. Targeted areas include distinctly urban locations, Affinity Project Draft EIR

3.6-3 Land Use and Planning
such as the urban core, underutilized properties, transit-oriented development areas, mixed-use areas, and urban villages.

Central District Specific Plan
The Land Use Element of the City’s General Plan establishes an overall pattern of development that directs growth “into specific areas in order to protect residential neighborhoods and create mixed-use urban environments.” These areas are based on a concept of higher density, mixeduse environments that support transit- and pedestrian-oriented mobility strategies. The Central District is one of eight areas throughout the City requiring preparation of a specific plan to implement this goal.

The CDSP encompasses 960 acres corresponding to the area recognized by Pasadena residents as “downtown”. The CDSP’s vision statement is:

The Central District will function as the City of Pasadena’s vibrant urban core, providing a diversity of economic, residential, and cultural opportunities. Downtown will be a place to work, shop, live, and play, with convenient access by foot, bicycle, and transit, as well as by car. Physical and economic growth will support this role and respect the numerous resources of historical and cultural significance that contribute to Downtown’s unique identity (Pasadena 2004).

The CDSP’s Policy Framework established planning objectives to support this vision and further defines the role of the Central District in the City. In addition, the CDSP has established specific development standards, codified in Chapter 17.30 of the Pasadena Municipal Code (PMC), for permitted land use types, maximum housing density, maximum floor area ratio (FAR), minimum and maximum building heights, required setbacks, open space, signage, and parking.

Within the CDSP, the site is identified as within the Arroyo Corridor Transition precinct within the Arroyo Corridor/Fair Oaks sub-district, which is an important gateway to downtown that also supports a broad, but rather undefined, mixture of uses at the periphery of the urban core. The objective of the Arroyo Corridor/Fair Oaks sub-district is to establish Arroyo Parkway as a visually appealing entrance corridor. Additionally, the intent of sub-district is to provide an attractive opportunity for employment-generating uses adaptable to changing economic conditions–such as arts, technology, and knowledge-based enterprise–within a revitalized low-scale, mixed-use setting at the periphery of Downtown Pasadena. The emphasis of the Arroyo Corridor Transition precinct is the transitional character of the area towards more pedestrian and transit-oriented development with a mix of land uses including residential, commercial, and employment (Pasadena 2004).

Pasadena Zoning Code
The City’s zoning code (Title 17 of the PMC) implements the General Plan’s Land Use Element.

The intent of the zoning code is to protect public health, safety, and the general welfare of residents and visitors in the City. Together with the zoning map, the zoning code identifies the particular use permitted on each parcel in the City and sets forth regulations and standards for development to ensure that the policies, goals, and objectives of the General Plan are implemented.

In addition to land use regulations, the zoning code provides development standards. The standards regulate things such as height, setbacks, parking, lot coverage, and gross floor area of structures. It also regulates what uses are permitted in each of the City’s zoning districts to ensure compatibility between land uses.

Affinity Project Draft EIR

3.6-4 Land Use and Planning
Zoning Code Variances
A zoning variance acts as a waiver to some aspect of the zoning law, but it cannot violate the expressed basis of the controlling code. Section 17.61.080 of the PMC, Variances, allows for variances from the development standards of this Zoning Code, variances for historic resources, and modifications for individuals with disabilities. The Project Applicant requests a variance for historic resources, which is addressed in Section 17.61.080(H) et. seq. of the PMC.

According to the PMC, a variance for historic resources is intended to accommodate historic resources that are undergoing development, change in use, or are being relocated. This unique type of variance is designed to provide relief from the strict compliance with the development standards of the zoning code that may impair the ability of a historic resource to be properly used or to be relocated onto a new site. The PMC states that this type of variance shall not allow a use of land or structure not otherwise allowed in the zoning district in which the subject property is located. It only applies if the property has a historic designation or is required, as a condition of approval of the variance, to submit an application for historic designation prior to completion of the proposed project or establishment of the proposed use.

The review authority may approve a variance for historic resources application, with or without conditions, only after first finding that:
a) The variance for historic resource is necessary to facilitate the appropriate use of an existing historic structure;
b) The variance for historic resource would not adversely impact property within the neighborhood or historic district; and
c) Granting the variance for historic resource application would be in conformance with the goals, policies, and objectives of the General Plan and the purpose and intent of any applicable specific plan.

Because the Project would involve concurrent permit processing, rather than the variance as a standalone permit, the variance for historic resources would be considered as part of the Project’s entitlements by the highest level review authority. In this case, it would be Planning Commission review followed by consideration by City Council.

Planned Development Zoning District
As discussed in Section 2.0, Environmental Setting and Project Description, implementation of the Project would require approval of a Planned Development (PD) zoning district for the site.

According to the City of Pasadena zoning code, the specific purposes of the PD zoning district are to:
 Establish a procedure for the development of large parcels of land in order to reduce or eliminate the rigidity, delays, and inequities that otherwise would result from application of land use regulations and administrative procedures designed primarily for small parcels;
 Ensure orderly and thorough planning and review procedures that will result in quality urban design.
 Encourage variety and avoid monotony in large developments by allowing greater freedom in selecting the means to provide access, light, open space, and amenity; Affinity Project Draft EIR

3.6-5 Land Use and Planning
 Allow certain types of development consistent with the general plan that can be acceptable at a specific location only under standards significantly more restrictive than those of a base district in which the use is permitted;  Provide a mechanism whereby the city may authorize desirable developments in conformity with the general plan without inviting speculative rezoning applications that if granted, often could deprive subsequent owners of development opportunities that do not necessarily result in construction of the proposed facilities;  Encourage allocation and improvement of common open space in residential areas, and provide for maintenance of the open space at the expense of those who will directly benefit from it;
 Encourage the preservation of serviceable existing structures of historic value or artistic merit by providing the opportunity to use them imaginatively for purposes other than that for which they were originally intended; and
 Encourage the assembly of properties that might otherwise be developed in unrelated increments to the detriment of surrounding neighborhoods.

Adoption of a PD zoning district would reclassify the Project site from CD-6 to PD-39, while simultaneously establishing applicable land use regulations and development standards that are specific to the newly established zoning district. The regulations and standards that dictate permitted and conditionally permitted land uses and development would be prescribed in the accompanying PD Plan. This ensures the Project or Project with Building A Residential/Commercial is developed as intended. PD Plans are developed in consideration of existing zoning requirements that are applicable to a project site while also providing flexibility in site usage and building design.

The City’s process allows a property owner to initiate an amendment to reclassify a property two acres or larger to a PD zoning district. A proposed PD zoning district and the permitted or conditionally permitted land uses are required to be consistent with the City’s General Plan.

However, development cannot exceed maximums for floor area ratio or density on the Land Use Diagram (but only as high as a 3.0 FAR and 87 du/acre) unless approved by the City Council.

The review process of a new PD Application requires input from the City’s Design Commission, Planning Commission, and City Council. The review process for a proposed Planned Development is outlined in Sections 17.26.020(C)(3)(d) (Commission and Council Action),

17.61.030(I)(5)(b) (Design Conditions), and 17.74 (Amendments) of the PMC. The role of the Design Commission is limited to recommendations to the Planning Commission and City Council on aesthetic and urban design issues related to architecture, landscaping, site plan, and related aesthetic issues, as well as historic preservation. Additionally, comments on the aesthetic/cultural resources of a draft environmental study are appropriate. Therefore, review and advisement by the Design Commission regarding the proposed PD zone and PD Plan would occur first at a public meeting.

A subsequent review of a proposed PD zone and PD Plan would occur at a public hearing by the Planning Commission. The Planning Commission’s role is to make a written recommendation to the City Council to approve, approve with modifications, or deny the proposed reclassification and PD Plan. The City Council’s role is to hold a public hearing to consider the recommendation of the Planning Commission and to hear evidence regarding the proposal. Upon receipt of the Planning Commission's recommendation, the City Council would move to approve, approve with modifications, or deny the proposed PD zoning district and PD Plan. Prior to any approval, the City Council is required to certify the Final EIR. Planned Developments and the accompanying Affinity Project Draft EIR

3.6-6 Land Use and Planning
PD Plan are made a part of the Zoning Code when approved to ensure implementation occurs as approved.

The basic design of a project, including compatibility with surroundings, massing, proportion, siting, solid-to-void relationships, and compliance with applicable design guidelines is evaluated through the City’s Design Review process and is a role for the City’s Design Commission. This phase of review generally occurs after approval of the PD Application, if received. An approved PD zoning district and accompanying PD Plan cannot be later revised without requiring a formal application from the Applicant, noticed public hearings before the Planning Commission and City Council, and further appropriate environmental review pursuant to CEQA.

3.6.3 THRESHOLDS OF SIGNIFICANCE
The following significance criteria are derived from Appendix G of the State CEQA Guidelines. A project would result in a significant adverse land use and planning impact if it would:

Threshold 3.6a: Cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect.

The Initial Study (provided in Appendix A-1) concluded the following threshold related to land use and planning was determined to result in no impacts and was not carried forward into the Draft EIR for further analysis:
 Would the project physically divide an established community?

3.6.4 METHODOLOGY
The analysis of potential land use impacts considers the Project’s consistency with applicable land use plans, policies, and regulations adopted for the purpose of reducing or avoiding an environmental impact. This analysis considers the land use development controls on the site and the compatibility of the proposed uses with surrounding land uses. A project is considered consistent with the provisions of the identified regional and local plans if it meets the general intent of the plans and would not preclude the attainment of the primary intent of the land use plan or policy. A given project need not be in perfect conformity with each and every policy nor does State law require precise conformity of a proposed project with every policy or land use designation for a site.

3.6.5 ENVIRONMENTAL IMPACTS
Threshold 3.6a: Would the Project cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect? Project
The primary land use planning documents that govern the Project site are the City’s General Plan, CDSP, and the City’s zoning code. Additionally, the 2020–2045 RTP/SCS is prepared, in part, based on data from cities and counties related to their respective general plans, land uses, and expected demographic growth. While the Project is considered consistent with the General Plan, based on comments received during the scoping period for the Project, a consistency analysis is also provided herein for the Land Use Element’s Guiding Principles, General Plan goals and policies that have the purpose of avoiding or mitigating an environmental effect, and applicable objectives of the CDSP.

Affinity Project Draft EIR

3.6-7 Land Use and Planning
The paragraphs below evaluate the Project’s consistency with these documents.

Pasadena General Plan
The City’s General Plan land use designation for the site is High Mixed-Use, which is intended to support multi-story mixed-use buildings with a variety of compatible commercial and residential uses. Development within this designation is characterized by shared open spaces, extensive landscaping, minimal building separations, and shared driveways with parking located underground or to the rear of the street. The High Mixed-Use General Plan land use category allows maximum densities of 3.0 floor area ratio (FAR) and 87 dwelling units per acre (du/acre).

Based on the site area (144,853 sf), the site would allow up to 434,559 sf of floor area and up to 289 dwelling units. Development of the Project would result in a total of 417,9291 sf of floor area (aboveground), which would include up to 95 senior housing units. The Project would not require a General Plan amendment. Also, as discussed in Section 2.14, Population and Housing, of the Initial Study (refer to Appendix A-1), there is adequate remaining development capacity in the Central District to accommodate the Project.

These Guiding Principles are:
1) Growth will be targeted to serve community needs and enhance the quality of life. Higher density development will be directed away from residential neighborhoods and into the Central District, Transit Villages, and Neighborhood Villages. These areas will have a diverse housing stock, job opportunities, exciting districts with commercial and recreational uses, and transit opportunities. New development will build upon Pasadena’s tradition of strong sense of place, great neighborhoods, gardens, plazas, parks, and trees.

The Project would provide senior living facilities and several related amenities that are acutely needed in the City and wider region as the U.S. population is generally living longer and a greater proportion of the population is considered senior or elderly with the large “boomer” segment, in particular, reaching this threshold. The medical office building would be robustly employment-generating and be located near the abundant health care land uses on Fair Oaks Avenue, providing an efficient synergy. These uses would therefore serve community needs and enhance quality of life, not limited to seniors, for residents of Pasadena and beyond.
2) Pasadena’s historic resources will be preserved. Citywide, new development will be in harmony with and enhance Pasadena’s unique character and sense of place. New construction that could affect the integrity of historic resources will be compatible with, and differentiated from, the existing resource.

An historic resources variance is being sought by the Applicant to preserve and adaptively reuse two previously recorded historic structures on the site (501 and 523 South Arroyo Parkway). Specifically, the Applicant is requesting an increase in allowable building height to offset the reduction in developable area due to preserving the two historic structures. The City provides incentives to owners of historic properties, including several as part of the zoning code. The zoning code incentives are consistent with the General Plan, which directs the City to implement flexible zoning regulations to promote the preservation of historic properties. This variance is being considered consistent with the General Plan as well as the City’s historic preservation program, which promotes the identification, evaluation, rehabilitation, adaptive use, and restoration of historic structures. Within the zoning code, a purpose of a planned development (PD) district is to “encourage the preservation of serviceable existing structures of historic value or artistic merit by providing the opportunity 1 Of this, a total of 338,376 sf would be new development in Buildings A and B.

Affinity Project Draft EIR

3.6-8 Land Use and Planning
to use them imaginatively for purposes other than that for which they were originally intended.” This provision facilitates the adaptive re-use of historic resources and encourages their long-term preservation on large sites designated for new development, as is the case with the Project. Mitigation measure (MM) CUL-1 requires that the Project Applicant engage with a licensed architect and/or engineer that meets the SOI’s Professional Qualifications Standards to develop a series of protection interventions and protocols that would preserve the two historical resources on the Project site – 501 and 523 South Arroyo Parkway – during construction activities. These protocols shall take into consideration the protection of and security of both resources, particularly the preservation of the characterdefining features through the installation of physical protective barriers around each resource and the creation of site protocols that will eliminate the potential for physical damage resulting from impacts associated with construction and transport of equipment.

Additionally, implementation of MM NOI-1, which outlines setbacks, monitoring, and (if needed) restoration related to the potential for cosmetic damage to these two buildings because of operation of vibration-causing construction equipment would reduce impacts to a less than significant level. Therefore, the proposed variance for historic resources and related PD Plan is consistent with the City’s policies to preserve and protect historic resources.
3) Pasadena will be an economically vital City by providing jobs, services, revenues, and opportunities. A diverse economic base with jobs for Pasadena residents will be fostered; existing businesses will be encouraged to stay or expand; affordable housing will be provided for the labor pool; the continued fiscal health of the city will be ensured.

The proposed uses in both Buildings A and B would be employment- and revenuegenerating. Additionally, the medical office and assisted living uses would provide services to the community. As such, the Project provides opportunities for both potential employees and existing and future residents of the City.
4) Pasadena will be a socially, economically, and environmentally sustainable community.

Safe, well designed, accessible and human-scale residential and commercial areas will be provided where people of all ages can live, work and play. These areas will include neighborhood parks, urban open spaces and the equitable distribution of public and private recreational facilities; new public spaces will be acquired. Human services will be coordinated and made accessible to those who need them.

Providing adequate care and housing for the senior community is a critical component of being a socially sustainable community. The higher density of land uses on the Project site compared to the existing condition is both economically and environmentally sustainable, particularly due to the site’s proximity to bus and light rail transit facilities. The urban public spaces proposed as part of the Project invite gathering on the site in an aesthetically pleasing and safe environment whereas the existing site conditions are disjointed and do not provide open spaces for gathering not associated with a restaurant.

The proposed building facades incorporate numerous window openings to provide views and to avoid blank, massive-looking building faces. The facades would also be articulated with patios, window shades, and varying surface treatments to provide variation and break up the surface of the buildings. Portions of both proposed buildings would be set back from the widest part of the building envelope and some portions of the buildings would extend only to Level 4 and Level 6. Additionally, the ground floor would be slightly taller than the remaining levels, at 15 feet high. This would act to differentiate the ground floor and, combined with some unique architectural features for this level, create a human-scale and pedestrian-friendly environment.

Affinity Project Draft EIR

3.6-9 Land Use and Planning
Finally, Section 3.3, Energy, and Section 3.4, GHG Emissions, of this EIR provide analyses of energy use/efficiency and GHG emissions, respectively, with construction and operation of the Project. Section 3.3 concludes that construction and operation of the Project would not result in wasteful, inefficient, or unnecessary construction of energy resources, nor conflict with or obstruct the applicable State or local plans for renewable energy and energy efficiency. As discussed above, Section 3.4 of this EIR concludes that the Project would be consistent with State, regional, and City plans, policies, and regulations adopted for the purpose of reducing the emissions of GHGs. Refer to these sections of this EIR for the complete analysis of these topics. 5) Pasadena will be a City where people can circulate without cars. Specific plans in targeted development areas will emphasize a mix of uses, pedestrian activity, and transit; public and private transit will be made more available; neighborhood villages and transit villages will reduce the need for auto use.

While this has been sometimes interpreted to mean the City wants circulation with an absence of cars, what this realistically means is that the City can be navigated without cars if desired. This is in contrast to a car-first culture, where primacy of vehicular circulation is typical with alternative transportation modes being limited or inaccessible.

Placing the proposed land uses and a higher density of land uses than existing on the site near transit, regardless of the amount of parking provided, supports this principle.

The Project would facilitate senior residents being able to shop for groceries and household items, attend some medical appointments, and dine at on-site buildings that would be accessible even to those with mobility aids. Additionally, there are abundant dining options and other retail/commercial facilities within walking distance of the Project site. Within walking distance, light rail/bus ride, or a short drive/rideshare, there are medical facilities, including Huntington Hospital and emergency rooms; additional restaurants, shopping, and services; and numerous cultural amenities, such as ArtCenter, Pasadena Playhouse, Pasadena Civic Center, museums, theater, and music venues. As such, implementation of the Project would enable the site to become an active part of the neighborhood fabric.
6) Pasadena will be a cultural, scientific, corporate, entertainment, and educational center for the region. Long-term growth opportunities will be provided for existing institutions; a healthy economy will be fostered to attract new cultural, scientific, corporate, entertainment and educational institutions.

The proposed uses in both Buildings A and B support the City being a corporate center.

Medical office uses have the potential to also support scientific research, depending on the tenants that occupy the space. Adding medical office uses on the site also supports the growing medical office cluster immediately to the west in the nearby South Fair Oaks Specific Plan Area along Raymond Avenue and South Fair Oaks Avenue. As discussed above under principle 5, the Project site is within walking distance, light rail/bus ride, or a short drive/rideshare to extensive cultural and educational offerings within the City. 7) Community participation will be a permanent part of achieving a greater City. Citizens will be provided with timely and understandable information on planning issues and projects; citizens will directly participate in shaping plans and policies for Pasadena’s future.

The City’s environmental review process for the Project has met, and exceeded, the requirements in CEQA and the State CEQA Guidelines for scoping and noticing. The City held two scoping meetings, including one with Planning Commission. As per City Affinity Project Draft EIR

3.6-10 Land Use and Planning
standards, the hearings for the Project will be public, where citizens may comment on the Project and make their views known further and above than what has already occurred. 8) Pasadena is committed to public education and a diverse educational system responsive to the broad needs of the community.

The Project would neither support nor conflict with this principle. No public or private educational facilities are included in the Project; however, no educational facilities are currently located on the site. It is noted that ArtCenter College of Design South Campus facilities are located within ½-mile of the Project site on Arroyo Parkway and Raymond Avenue to the south and southwest, respectively. ArtCenter Extension offers non-degree courses for adults, teens, and kids.

The City’s General Plan also includes goals and policies that have the purpose of avoiding or mitigating an environmental effect; for the City of Pasadena, these are focused on historic resources, GHG emissions/sustainability, and trees/open space. The discussion below presents some applicable General Plan goals and policies followed by a discussion of how the Project relates to those goals and policies. As shown, the Project would not conflict with the General Plan with regard to goals and policies adopted to avoid or reduce an environmental effect.

Goal 8. Historic Preservation. Preservation and enhancement of Pasadena’s cultural and historic buildings, landscapes, streets and districts as valued assets and important representations of its past and a source of community identity, and social, ecological, and economic vitality.

Policy 8.1 Identify and Protect Historic Resources. Identify and protect historic resources that represent significant examples of the City’s history.

Policy 8.4 Adaptive Reuse. Encourage sensitive adaptive re-use including continuing the historic use of historic resources to achieve their preservation, sensitive rehabilitation, and continued economic and environmental value.

Policy 8.5 Scale and Character of New Construction in a Designated Landmark and Historic Districts. Promote an architecturally sensitive approach to new construction in Landmark and Historic districts. Demonstrate the proposed project’s contextual relationship with land uses and patterns, spatial organization, visual relationships, cultural and historic values, and relationships in height, massing, modulation, and materials.

Section 3.2, Cultural and Paleontological Resources, of this EIR provides an analysis of impacts to historic resources. A Historical Resource Assessment (HRA) was prepared for the Project site (refer to Appendix C-1) that analyzed all existing buildings on the site over 45 years of age to determine whether or not they were eligible historic resources and, for those buildings determined to be historic (501 and 523 South Arroyo Parkway), analyzed whether implementation of the Project would result in a significant impact to those resources. As discussed in Section 3.2, while the Project’s tenant improvements do not anticipate demolishing, moving, or making major alterations to these historic resources, these plans remain conceptual and have not yet been finalized. Therefore, there may be a potential for impact, and MM CUL-1 (described above) would be required. Additionally, the HRA assessed whether the Project’s scale, massing, and design would result in an indirect impact to these historic resources. The HRA determined there would not be a significant impact related to development of the proposed Buildings A and B in proximity to the historic buildings on the site. Additionally, implementation of MM NOI-1, which outlines setbacks, monitoring, and (if needed) restoration related to the potential for cosmetic damage to these two buildings because of operation of vibration-causing construction equipment would reduce impacts to a less than significant level. With implementation of MM CUL-1 and MM NOI- Affinity Project Draft EIR

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1, it was determined there would be a less than significant impact to historic resources. Based on this assessment, it can be concluded that the Project would not conflict with applicable goals and policies related to historic resources and their preservation.

Goal 10. City Sustained and Renewed. Development and infrastructure practices that sustain natural environmental resources for the use of future generations and, at the same time, contribute to the reduction of greenhouse gas emissions and impacts on climate change.

Policy 10.1 Environmental Quality and Conservation. Establish Pasadena as a leader on environmental stewardship efforts, including air quality protection, energy and water efficiency, renewable energy standards, natural resource conservation, and greenhouse gas emission standards in the areas of energy, water, air and land.

Policy 10.4 Sustainable Building Practices. Foster sustainable building practices and processes specified by the City’s Green Building Code by incorporating energy and water savings, toxic and solid waste reduction strategies into the building of new structures and remodeling of existing structures.

Policy 10.6 Adaptive Reuse. Encourage adaptive reuse of structures, including non-historic structures, as a means of supporting environmental sustainability.

Section 3.4, GHG Emissions, provides an analysis of GHG emissions including the consistency of the Project with applicable plans, policies, or regulations adopted for the purpose of reducing the emissions of GHGs. As concluded in Section 3.4 of this EIR, the Project would be consistent with the City’s Climate Action Plan (CAP), SCAG’s 2020–2045 RTP/SCS Connect SoCal, the California Air Resources Board (CARB), California’s Climate Change Scoping Plan (Scoping Plan), and Statewide GHG reduction goals for 2030 or 2050 identified in Executive Order (EO) S3-05 and Senate Bill (SB) 32. Also, as discussed above, Section 3.3, Energy, of this EIR concludes that construction and operation of the Project would not result in wasteful, inefficient, or unnecessary construction of energy resources, nor conflict with or obstruct the applicable State or local plans for renewable energy and energy efficiency. Based on these analyses, it can be concluded that the Project would not conflict with applicable goals and policies related to GHG emissions and sustainability as it relates to energy efficiency.

Policy 10.13 Urban Forest. Maintain and plant additional trees along the City’s sidewalks, civic places, parks, and in private developments to support the health and diversity of wildlife, sequester GHG emissions, and contribute to the reduction of the urban heat-island.

The analysis of the proposed tree removals pursuant to the City’s “City Trees and Tree Protection Ordinance” (codified in Chapter 8.52 of the PMC) was included in Section 2.4, Biological Resources, of the Initial Study (refer to Appendix A-1) prepared for the Project. As discussed, the Urban Forestry section of the City’s Public Works Department typically requires a fee, dependent on the size of the tree(s) being removed, to be remitted into the City’s street tree fund. For the Project, a planned condition of approval calls for planting of one new street tree along both Arroyo Parkway and California Boulevard. The Project would also include a total of 25 trees in abovegrade planters within the site. With compliance with the Project’s conditions of approval, the Project would not conflict with the City’s tree protection ordinance and there would be a less than significant impact. Project implementation would result in a net gain in the urban forest, with no loss of street trees and a greater amount of landscaping at ground level and on upper levels of Building B than in the existing condition. Based on this analysis, it can be concluded that the Project would not conflict with applicable goals and policies related to the urban forest.

Based on the Project’s consistency with the land use designation for the site, furtherance of applicable Guiding Principles of the Land Use Element, and applicable General Plan policies that Affinity Project Draft EIR

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focus on avoiding or reducing an environmental impact, the Project would be considered consistent with the General Plan.

CDSP and Zoning Code
The Project site is zoned CD-6 (Central District, Arroyo Corridor/Fair Oaks subdistrict). The City considers the Central District to be Pasadena’s urban core, and the CDSP includes a “diverse mix of land uses designed to create the primary business, financial, retailing, and government center of the City” (Pasadena 2004). The CDSP includes both Public Realm and Private Realm Design Guidelines, which apply to all development in this district, including the Project. The CDSP also provides District-wide land use, mobility, and urban design concepts. The CDSP identifies sub-districts, and within the sub-districts, precincts that include more specific goals, policies, and standards targeted toward the vision for each neighborhood.

The site is in the Arroyo Corridor Transition precinct within the Arroyo Corridor/Fair Oaks subdistrict, which is an important gateway to Downtown Pasadena that also supports a broad, but rather undefined, mixture of uses at the periphery of the urban core. The objective of the Arroyo Corridor/Fair Oaks sub-district is to establish Arroyo Parkway as a visually appealing entrance corridor, as well as to provide an attractive opportunity for employment-generating uses adaptable to changing economic conditions, such as arts, technology, and knowledge-based enterprise, within a revitalized low-scale, mixed-use setting at the periphery of Downtown Pasadena. The emphasis of the Arroyo Corridor Transition precinct is the transitional character of the area towards more pedestrian and transit-oriented development with a mix of land uses including residential, commercial, and employment (Pasadena 2004). The Project would include this mix of land uses–senior residents, commercial, and employment–in one location thereby supporting the transition from single-use parcels and disjointed, disparate land uses to a cohesive mix of uses that are near transit and support pedestrian accessibility within and through the site.

The Project would establish a PD zoning district (via a zone change from CD-6 to PD-39) for the site and requires adoption of a PD Plan. Adoption of a PD zoning district simultaneously establishes applicable land use regulations and development standards that are specific to the newly established zoning district. The regulations and standards that dictate allowed and conditionally allowed land uses and development would be prescribed in the accompanying PD Plan.

Within the Arroyo Corridor/Fair Oaks sub-district, building height is limited to 50 feet, or 65 feet using height averaging. As discussed previously, the Applicant is requesting a variance for historic resources (described above in Section 3.6.2) to increase the allowable building height to offset the reduction in developable area due to preserving the two historic structures. The maximum height of all proposed structures would be one of the land use regulations prescribed in the PD Plan prepared by the City.

The review process of a new PD Application requires input from the City’s Design Commission, Planning Commission, and City Council. The City’s PD process is detailed above in Section 3.6.2.

As discussed, the PD Plan, implemented via the zone change, would define all aspects of Project design and cannot be deviated from with further discretionary action, and related environmental review. With approval of the PD application and PD Plan (including approval of the Affinity Project, zoning map amendment to rezone the property from CD-6 to PD-39, variance for historic resources for building height, and Design Review), the proposed Project would be compatible with the City’s zoning designations and Zoning Code.

Section 3, Policy Framework of the CDSP includes planning objectives applicable to new development in the Specific Plan area. The CDSP has a total of 33 objectives associated with the 7 General Plan Guiding Principles. The CDSP objectives that correspond with each Guiding Affinity Project Draft EIR

3.6-13 Land Use and Planning
Principle are summarized below, followed by discussion, with focus on the purpose of avoiding or mitigating an environmental effect, where relevant.
1) Summary of CDSP Guiding Principle 1 and Associated Objectives: Promoting growth appropriately and enhancing the Downtown through the development of multi-story buildings with a variety of complementary commercial and/or residential uses in underutilized areas with higher development capacity.

The Project would redevelop an underutilized site with transit and pedestrian accessibility multi-story buildings that provide complementary commercial, assisted living, and medical office uses. The Project integrates two existing historic structures with the ground floor layout designed to provide spacing and setbacks to blend the scales of the existing and proposed structures.
2) Summary of Guiding Principle 2 and Associated CDSP Objectives: Preservation of the City’s historic character and environment which would be accomplished through preservation and integration of Pasadena’s historic resources as part of a complementary development that reduces the risk of resource demolition, deterioration by neglect, and/or impacts from natural circumstances.

As discussed previously, an historic resources variance is being sought by the Applicant to preserve and adaptively reuse two previously recorded historic structures on the site (501 and 523 South Arroyo Parkway). Specifically, the Applicant is requesting an increase in allowable building height to offset the reduction in developable area due to preserving the two historic structures. This variance is being considered consistent with the General Plan as well as the City’s historic preservation program, which promotes the identification, evaluation, rehabilitation, adaptive use, and restoration of historic structures. Within the zoning code, a purpose of a PD district is to “encourage the preservation of serviceable existing structures of historic value or artistic merit by providing the opportunity to use them imaginatively for purposes other than that for which they were originally intended.” This provision facilitates the adaptive re-use of historic resources and encourages their long-term preservation on large sites designated for new development, as is the case with the Project.

An HRA was prepared for the Project site (refer to Appendix C-1) that analyzed whether implementation of the Project would result in a significant impact to historic resources. As discussed in Section 3.2 of this Draft EIR, while the Project’s tenant improvements do not anticipate demolishing, moving, or making major alterations to these historic resources, these plans remain conceptual and have not yet been finalized. Therefore, there may be a potential for impact, and MM CUL-1 (described above) would be required. Additionally, the HRA assessed whether the Project’s scale, massing, and design would result in an indirect impact to these historic resources. The HRA determined there would not be a significant impact related to development of the proposed Buildings A and B in proximity to the historic buildings on the site. Additionally, implementation of MM NOI-1, which outlines setbacks, monitoring, and (if needed) restoration related to the potential for cosmetic damage to these two buildings because of operation of vibration-causing construction equipment would reduce impacts to a less than significant level. With implementation of MM CUL-1 and MM NOI-1, it was determined there would be a less than significant impact to historic resources. Based on this assessment, it can be concluded that the Project would not conflict with applicable objectives related to historic resources and their preservation.
3) Summary of CDSP Guiding Principle 3 and Associated Objectives: Supporting economic growth and sustainability by providing jobs, services, revenues, and opportunities for the City’s economic vitality and fiscal health.

Affinity Project Draft EIR

3.6-14 Land Use and Planning
As discussed previously, the proposed uses in both Buildings A and B would be employment- and revenue-generating. Additionally, the medical office and assisted living uses would provide services to the community. As such, the Project provides opportunities for both potential employees and existing and future residents of the City. 4) Summary of CDSP Guiding Principle 4 and Associated Objectives: Creating a thriving community that meets basic needs and provides opportunities for wellness and quality of life through improving Pasadena’s infrastructure and urban form through modernized buildings that are energy- and water-efficient, and the development of the area’s urban forest.

Providing adequate care and housing for the senior community is a critical component of a City that is meeting the basic needs for all segments of its population. The Project would facilitate senior residents being able to shop for groceries and household items, attend some medical appointments, and dine at on-site buildings that would be accessible even to those with mobility aids. There are abundant dining options and other retail/commercial facilities within walking distance of the Project site. Within walking distance, light rail/bus ride, or a short drive/rideshare, there are medical facilities, including Huntington Hospital and emergency rooms; additional restaurants, shopping, and services; and numerous cultural amenities, such as ArtCenter, Pasadena Playhouse, Pasadena Civic Center, museums, theater, and music venues. As such, implementation of the Project would enable the site to become an active part of the neighborhood fabric.

As discussed, for the Project, a planned condition of approval calls for planting of one new street tree along both Arroyo Parkway and California Boulevard. The Project would also include 25 trees in above-grade planters within the site. With compliance with the conditions of approval, the Project would not conflict with the City’s tree protection ordinance and there would be a less than significant impact. Implementation of the Project would result in a net gain in the urban forest, with no loss of street trees and a greater amount of landscaping at ground level and on upper levels of Building B than in the existing condition. Based on this analysis, it can be concluded that the Project would not conflict with applicable objectives related to the urban forest. 5) Summary of CDSP Guiding Principle 5 and Associated Objectives: Providing a community that supports efficient transportation and multi-modal options through development of land uses that are pedestrian friendly and transit-accessible As discussed previously, the higher density of land uses on the Project site compared to the existing condition is both economically and environmentally sustainable, particularly due to the site’s proximity to bus and light rail transit facilities. 6) Summary of CDSP Guiding Principle 6 and Associated Objectives: Supporting institutional growth through development of commercial uses and quality medical and assisted living uses.

The Project would support institutional growth by providing high-quality redevelopment of the site with complementary commercial, assisted living, and medical office uses. Adding medical office uses on the site also supports the growing medical office cluster immediately to the west in the nearby South Fair Oaks Specific Plan Area along Raymond Avenue and South Fair Oaks Avenue.
7) Summary of CDSP Guiding Principle 7 and Associated Objectives: Enhancing a local community identify through supporting the continued modernization and development of the Arroyo Parkway as a major commercial corridor.

Affinity Project Draft EIR

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As discussed previously, the higher density of land uses on the Project site compared to the existing condition is both economically and environmentally sustainable, particularly due to the site’s proximity to bus and light rail transit facilities and underutilized condition.

The urban public spaces proposed as part of the Project invite gathering on the site in an aesthetically pleasing and safe environment whereas the existing site conditions are disjointed and do not provide open spaces for gathering not associated with a restaurant.

The proposed building facades incorporate numerous window openings to provide views and to avoid blank, massive-looking building faces. The facades would also be articulated with patios, window shades, and varying surface treatments to provide variation and break up the surface of the buildings. Portions of both proposed buildings would be set back from the widest part of the building envelope and some portions of the buildings would extend only to Level 4 and Level 6. Additionally, the ground floor would be slightly taller than the remaining levels, at 15 feet high. This would act to differentiate the ground floor and, combined with some unique architectural features for this level, create a human-scale and pedestrian-friendly environment. Therefore, the Project would support Arroyo Parkway continuing to modernize and be a major commercial corridor in the City.

SCAG 2020–2045 RTP/SCS
As discussed above, the Project would not require a General Plan amendment and would be consistent with the Land Use Element’s Guiding Principles and applicable goals and policies that pertain to environmental effects. Additionally, as the Project is an urban infill development located within both a High-Quality Transit Area (HQTA) and a Transit Priority Area (TPA), the proposed land uses would be consistent with the applicable goals of the 2020–2045 RTP/SCS. The Project would increase density, including senior housing, in an area within ½-mile of two light rail stations (Fillmore and Del Mar). As discussed above, the Project would enable senior residents to shop for groceries and household items, attend some medical appointments, and dine at on-site buildings that would be accessible even to those with mobility aids. Additionally, there are abundant dining options and other retail/commercial facilities within walking distance of the Project site. With a light rail and or short drive/rideshare, abundant dining, entertainment, and services in the City are accessible from the site. The Project would also provide bicycle parking and bicycle serving amenities, and electric car charging would be provided in the subterranean parking garage. Furthermore, the Project would include this mix of land uses–senior residents, commercial, and employment–in one location thereby supporting the transition from single-use parcels and disjointed, disparate land uses to a cohesive mix of uses that are near transit and support pedestrian accessibility within and through the site. As such, the Project would promote and maximize regional mobility, livability, prosperity, and sustainability compared to the existing uses on the site and contribute to a healthier community and region as a whole.

As discussed in Section 3.2, Air Quality, the Project would not result in a conflict with or obstruct implementation of the applicable air quality plan–South Coast Air Quality Management District’s (SCAQMD) 2016 Air Quality Management Plan (AQMP)– nor result in a cumulatively considerable net increase of any criteria pollutant for which the Project region is in non-attainment under an applicable federal or State ambient air quality standards (AAQS). Accordingly, the Project is consistent with SCAG’s 2020–2045 RTP/SCS as it regards land use and transportation patterns that, in turn, help CARB achieve its air quality attainment goals as defined in the applicable State Implementation Plan (SIPs). As discussed above, Section 3.4, GHG Emissions, determined the Project would be consistent with the City’s CAP, SCAG’s 2020–2045 RTP/SCS, CARB, California’s Scoping Plan, and Statewide GHG reduction goals for 2030 or 2050. As discussed in Section 3.9, Transportation, using the City’s Transportation Demand Model, the Pasadena Department of Transportation (DOT) determined that the Project would not exceed any of the California Environmental Quality Act (CEQA) transportation thresholds defined in the City’s Affinity Project Draft EIR

3.6-16 Land Use and Planning
Transportation Impact Analysis Guidelines (TIA Guidelines), including vehicle trips (VT) per capita and vehicle miles traveled (VMT) per capita. SCAG’s 2020–2045 RTP/SCS has a focus on transitoriented development as a means to reduce VMT to improve air quality, reduce GHG emissions, and improve mobility.

The Project would result in a less than significant impact on any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect, and no mitigation is required.

Project with Building A Residential/Commercial
The analysis of consistency with land use plans, policies, or regulations adopted to avoid or mitigate an environmental impact for the Project with Building A Residential/Commercial would be essentially the same as that of the Project, with some differences focused on the provision of multi-family housing instead of medical office space. The scale, massing, and site layout for the Project with Building A Residential/Commercial would be the same as the Project.

Pasadena General Plan
As discussed for the Project, the High Mixed-Use General Plan land use category allows maximum densities of 3.0 FAR and 87 du/acre and the site would allow up to 434,559 sf of floor area and up to 289 dwelling units. Development of the Project with Building A Residential/Commercial would also result in a total of 417,929 sf of floor area (aboveground) but would include 289 dwelling units balanced between market rate apartments/condominiums in Building A and independent senior living units in Building B. The Project with Building A Residential/Commercial would not require a General Plan amendment.

As included above for the Project, a consistency analysis of the Project with Building A Residential/Commercial with the Land Use Element’s Guiding Principles is also provided herein:

These Guiding Principles are:
1) Growth will be targeted to serve community needs and enhance the quality of life. Higher density development will be directed away from residential neighborhoods and into the Central District, Transit Villages, and Neighborhood Villages. These areas will have a diverse housing stock, job opportunities, exciting districts with commercial and recreational uses, and transit opportunities. New development will build upon Pasadena’s tradition of strong sense of place, great neighborhoods, gardens, plazas, parks, and trees.

The Project with Building A Residential/Commercial would provide senior living facilities and several related amenities that are acutely needed in the City and wider region as the U.S. population is generally living longer and a greater proportion of the population is considered senior or elderly with the large “boomer” segment, in particular, reaching this threshold. The ground floor commercial uses in Building A would also be employmentgenerating, and the housing provided under this scenario is also acutely needed in the region. These uses would therefore serve community needs and enhance quality of life, not limited to seniors, for residents of Pasadena and beyond. 2) Pasadena’s historic resources will be preserved. Citywide, new development will be in harmony with and enhance Pasadena’s unique character and sense of place. New construction that could affect the integrity of historic resources will be compatible with, and differentiated from, the existing resource.

Affinity Project Draft EIR

3.6-17 Land Use and Planning
An historic resources variance is being sought by the Applicant to preserve and adaptively reuse to two previously recorded historic structures on the site (501 and 523 South Arroyo Parkway). Specifically, the Applicant is requesting an increase in allowable building height to offset the reduction in developable area due to preserving the two historic structures. The City provides incentives to owners of historic properties, including several as part of the zoning code consistent with the General Plan, which directs the City to implement flexible zoning regulations to promote the preservation of historic properties. This variance is being considered consistent with the General Plan as well as the City’s historic preservation program, which promotes the identification, evaluation, rehabilitation, adaptive use, and restoration of historic structures. Within the zoning code, a purpose of a PD district is to “encourage the preservation of serviceable existing structures of historic value or artistic merit by providing the opportunity to use them imaginatively for purposes other than that for which they were originally intended.” This provision facilitates the adaptive re-use of historic resources and encourages their long-term preservation on large sites designated for new development, as is the case with the Project. Additionally, MM CUL-1 requires that the Project Applicant engage with a licensed architect and/or engineer that meets the SOI’s Professional Qualifications Standards to develop a series of protection interventions and protocols that would preserve the two historical resources on the Project site – 501 and 523 South Arroyo Parkway – during construction activities. These protocols shall take into consideration the protection of and security of both resources, particularly the preservation of the character-defining features through the installation of physical protective barriers around each resource and the creation of site protocols that will eliminate the potential for physical damage resulting from impacts associated with construction and transport of equipment. Additionally, implementation of MM NOI-1, which outlines setbacks, monitoring, and (if needed) restoration related to the potential for cosmetic damage to these two buildings because of operation of vibration-causing construction equipment would reduce impacts to a less than significant level. Therefore, with implementation of required mitigation, the proposed variance for historic resources and related PD Plan is consistent with the City’s policies to preserve and protect historic resources. 3) Pasadena will be an economically vital City by providing jobs, services, revenues, and opportunities. A diverse economic base with jobs for Pasadena residents will be fostered; existing businesses will be encouraged to stay or expand; affordable housing will be provided for the labor pool; the continued fiscal health of the city will be ensured.

The proposed ground floor commercial uses in Building A and all uses in Building B would be employment- and revenue-generating. Also, the assisted living uses in Building B would provide services to the community. Additionally, the market-rate housing proposed in Building A in this scenario would contribute to the local economic base as their patronage may encourage existing businesses to stay and/or expand. As such, the Project with Building A Residential/Commercial provides opportunities for both potential employees and existing and future residents of the City. 4) Pasadena will be a socially, economically, and environmentally sustainable community.

Safe, well designed, accessible and human-scale residential and commercial areas will be provided where people of all ages can live, work and play. These areas will include neighborhood parks, urban open spaces and the equitable distribution of public and private recreational facilities; new public spaces will be acquired. Human services will be coordinated and made accessible to those who need them.

Providing adequate care and housing for the senior community as well as market-rate housing is a critical component of being a socially sustainable community. The higher density of land uses on the Project site is both economically and environmentally Affinity Project Draft EIR

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sustainable, particularly due to the site’s proximity to bus and light rail transit facilities. The urban public spaces proposed as part of the Project with Building A Residential/Commercial invite gathering on the site in an aesthetically pleasing and safe environment whereas the existing site conditions are disjointed and do not provide open spaces for gathering not associated with a restaurant.

The proposed building facades incorporate numerous window openings to provide views and to avoid blank, massive-looking building faces. The facades would also be articulated with patios, window shades, and varying surface treatments to provide variation and break up the surface of the buildings. Portions of both proposed buildings would be set back from the widest part of the building envelope and some portions of the buildings would extend only to Level 4 and Level 6. Additionally, the ground floor would be slightly taller than the remaining levels, at 15 feet high. This would act to differentiate the ground floor and, combined with some unique architectural features for this level, create a human-scale and pedestrian-friendly environment.
5) Pasadena will be a City where people can circulate without cars. Specific plans in targeted development areas will emphasize a mix of uses, pedestrian activity, and transit; public and private transit will be made more available; neighborhood villages and transit villages will reduce the need for auto use.

While this has been sometimes interpreted to mean the City wants circulation with an absence of cars, what this realistically means is that the City can be navigated without cars if desired. This is in contrast to a car-first culture, where primacy of vehicular circulation is typical with alternative transportation modes being limited or inaccessible.

Placing the proposed land uses and a higher density of land uses than existing on the site near transit, regardless of the amount of parking provided, supports this principle.

The Project with Building A Residential/Commercial would facilitate residents being able to shop for groceries and household items and dine at on-site buildings that would be accessible even to those with mobility aids. There are abundant dining options and other retail/commercial facilities within walking distance of the Project site. Within walking distance, a light rail/bus ride, or a short drive/rideshare, there are medical facilities, including Huntington Hospital and emergency room; additional restaurants, shopping, and services; and numerous cultural amenities, such as ArtCenter, Pasadena Playhouse, Pasadena Civic Center, museums, theater, and music venues. As such, implementation of the Project with Building A Residential/Commercial would enable the site to become an active part of the neighborhood fabric.
6) Pasadena will be a cultural, scientific, corporate, entertainment, and educational center for the region. Long-term growth opportunities will be provided for existing institutions; a healthy economy will be fostered to attract new cultural, scientific, corporate, entertainment and educational institutions.

All proposed uses in Building A and assisted living uses, and related amenities in Building B support the City being a corporate center. As discussed above under principle 5, the Project site is within walking distance, a light rail/bus ride, or a short drive/rideshare to extensive cultural and educational offerings within the City. 7) Community participation will be a permanent part of achieving a greater City. Citizens will be provided with timely and understandable information on planning issues and projects; citizens will directly participate in shaping plans and policies for Pasadena’s future.

Affinity Project Draft EIR

3.6-19 Land Use and Planning
The City’s environmental review process for the Project with Building A Residential/Commercial has met, and exceeded, the requirements in CEQA and the State CEQA Guidelines for scoping and noticing. The City held two scoping meetings, including one with Planning Commission. As per City standards, the hearings for the Project with Building A Residential/Commercial will be public, where citizens may comment on the project and make their views known further and above than what has already occurred. 8) Pasadena is committed to public education and a diverse educational system responsive to the broad needs of the community.

The Project with Building A Residential/Commercial would neither support nor conflict with this principle. No public or private educational facilities are included in the Project with Building A Residential/Commercial; however, no educational facilities are currently located on the site. As noted above, the ArtCenter College of Design South Campus facilities are located within ½-mile of the Project site on Arroyo Parkway and Raymond Avenue to the south and southwest, respectively. ArtCenter Extension (ACX) offers nondegree courses for adults, teens, and kids.

As discussed above, the City’s General Plan also includes goals and policies that have the purpose of avoiding or mitigating an environmental effect; for the City of Pasadena, these are focused on historic resources, GHG emissions/sustainability, and trees/open space. The discussion below presents some applicable General Plan goals and policies followed by a discussion of how the Project with Building A Residential/Commercial relates to those goals and policies. As shown, the Project with Building A Residential/Commercial would not conflict with the General Plan with regard to goals and policies adopted to avoid or reduce an environmental effect.

Goal 8. Historic Preservation. Preservation and enhancement of Pasadena’s cultural and historic buildings, landscapes, streets and districts as valued assets and important representations of its past and a source of community identity, and social, ecological, and economic vitality.

Policy 8.1 Identify and Protect Historic Resources. Identify and protect historic resources that represent significant examples of the City’s history.

Policy 8.4 Adaptive Reuse. Encourage sensitive adaptive re-use including continuing the historic use of historic resources to achieve their preservation, sensitive rehabilitation, and continued economic and environmental value.

Policy 8.5 Scale and Character of New Construction in a Designated Landmark and Historic Districts. Promote an architecturally sensitive approach to new construction in Landmark and Historic districts. Demonstrate the proposed project’s contextual relationship with land uses and patterns, spatial organization, visual relationships, cultural and historic values, and relationships in height, massing, modulation, and materials.

Section 3.2, Cultural and Paleontological Resources, of this EIR provides an analysis of impacts to historic resources, including an HRA (refer to Appendix C-1) that analyzed whether implementation of the Project with Building A Residential/Commercial would result in a significant impact to those resources. As discussed in Section 3.2, while the tenant improvements do not anticipate demolishing, moving, or making major alterations to these historic resources, these plans remain conceptual and have not yet been finalized. Therefore, there may be a potential for impact, and MM CUL-1 (described above) would be required. Additionally, the HRA assessed whether the scale, massing, and design of the Project with Building A Residential/Commercial would result in an indirect impact to these historic resources. The HRA determined there would not be a significant impact related to development of the proposed Buildings A and B in proximity Affinity Project Draft EIR

3.6-20 Land Use and Planning
to the historic buildings on the site. Additionally, implementation of MM NOI-1, which outlines setbacks, monitoring, and (if needed) restoration related to the potential for cosmetic damage to these two buildings because of operation of vibration-causing construction equipment to a less than significant level. With implementation of MM CUL-1 and MM NOI-1, it was determined there would be a less than significant impact to historic resources. Based on this assessment, it can be concluded that the Project with Building A Residential/Commercial would not conflict with applicable goals and policies related to historic resources and their preservation.

GOAL 10. City Sustained and Renewed. Development and infrastructure practices that sustain natural environmental resources for the use of future generations and, at the same time, contribute to the reduction of greenhouse gas emissions and impacts on climate change.

Policy 10.1 Environmental Quality and Conservation. Establish Pasadena as a leader on environmental stewardship efforts, including air quality protection, energy and water efficiency, renewable energy standards, natural resource conservation, and greenhouse gas emission standards in the areas of energy, water, air and land.

Policy 10.4 Sustainable Building Practices. Foster sustainable building practices and processes specified by the City’s Green Building Code by incorporating energy and water savings, toxic and solid waste reduction strategies into the building of new structures and remodeling of existing structures.

Policy 10.6 Adaptive Reuse. Encourage adaptive reuse of structures, including non-historic structures, as a means of supporting environmental sustainability.

Section 3.4, GHG Emissions, provides an analysis of GHG emissions including the consistency of the Project with Building A Residential/Commercial with applicable plans, policies, or regulations adopted for the purpose of reducing the emissions of GHGs. As concluded in Section

3.4 of this EIR, the Project would be consistent with the City’s Climate Action Plan (CAP), SCAG’s 2020–2045 RTP/SCS Connect SoCal, the California Air Resources Board (CARB), California’s Climate Change Scoping Plan (Scoping Plan), and Statewide GHG reduction goals for 2030 or 2050 identified in Executive Order (EO) S-3-05 and Senate Bill (SB) 32. Also, as discussed above, Section 3.3, Energy, of this EIR concludes that construction and operation of the Project with Building A Residential/Commercial would not result in wasteful, inefficient, or unnecessary construction of energy resources, nor conflict with or obstruct the applicable State or local plans for renewable energy and energy efficiency. Based on these analyses, it can be concluded that the Project with Building A Residential/Commercial would not conflict with applicable goals and policies related to GHG emissions and sustainability as it relates to energy efficiency.

Policy 10.13 Urban Forest. Maintain and plant additional trees along the City’s sidewalks, civic places, parks, and in private developments to support the health and diversity of wildlife, sequester GHG emissions, and contribute to the reduction of the urban heat-island.

The analysis of the proposed tree removals pursuant to the City’s “City Trees and Tree Protection Ordinance” (codified in Chapter 8.52 of the PMC) was included in Section 2.4, Biological Resources, of the Initial Study (refer to Appendix A-1) prepared for the Project with Building A Residential/Commercial. As discussed, the Urban Forestry section of the City’s Public Works Department typically requires a fee, dependent on the size of the tree(s) being removed, to be remitted into the City’s street tree fund. For the Project with Building A Residential/Commercial, a planned condition of approval calls for planting of one new street tree along both Arroyo Parkway and California Boulevard. The Project with Building A Residential/Commercial would also include a total of 25 trees in above-grade planters within the site. With compliance with the conditions of approval, the Project with Building A Residential/Commercial would not conflict with the City’s tree protection ordinance and there would be a less than significant impact. Implementation of the Affinity Project Draft EIR

3.6-21 Land Use and Planning
Project with Building A Residential/Commercial would result in a net gain in the urban forest, with no loss of street trees and a greater amount of landscaping at ground level and on upper levels of Building B than in the existing condition. Based on this analysis, it can be concluded that the Project with Building A Residential/Commercial would not conflict with applicable goals and policies related to the urban forest.

Based on the Project with Building A Residential/Commercial’s consistency with the land use designation for the site, furtherance of applicable Guiding Principles of the Land Use Element, and applicable General Plan policies that focus on avoiding or reducing an environmental impact, the Project with Building A Residential/Commercial would be considered consistent with the General Plan.

CDSP and Zoning Code
As with the Project, the Project with Building A Residential/Commercial would establish a PD zoning district (via a Zone Change from CD-6 to PD-39) for the site and requires adoption of a PD Plan. The regulations and standards that dictate allowed and conditionally allowed land uses and development would be prescribed in the accompanying PD Plan. As discussed previously, the Applicant is requesting a variance for historic resources (described above in Section 3.6.2) to increase the allowable building height to offset the reduction in developable area due to preserving the two historic structures. The maximum height of all proposed structures would be one of the land use regulations prescribed in the PD Plan prepared by the City. With approval of the zone change from CD-6 to PD-39 and approval of the Project with Building A Residential/Commercial, including Design review, the proposed Project with Building A Residential/Commercial would be compatible with the City’s zoning designations.

The City considers the Central District to be Pasadena’s urban core, and the CDSP includes a “diverse mix of land uses designed to create the primary business, financial, retailing, and government center of the City” (Pasadena 2004). The CDSP includes both Public Realm and Private Realm Design Guidelines, which apply to all development in this district, including the Project with Building A Residential/Commercial. The CDSP also provides District-wide land use, mobility, and urban design concepts. The CDSP identifies sub-districts, and within the subdistricts, precincts that include more specific goals, policies, and standards targeted toward the vision for each neighborhood.

As discussed previously, the site is in the Arroyo Corridor Transition precinct within the Arroyo Corridor/Fair Oaks sub-district, which is an important gateway to Downtown Pasadena that also supports a broad, but rather undefined, mixture of uses at the periphery of the urban core. The objective of the Arroyo Corridor/Fair Oaks sub-district is to establish Arroyo Parkway as a visually appealing entrance corridor, as well as to provide an attractive opportunity for employmentgenerating uses adaptable to changing economic conditions, such as arts, technology, and knowledge-based enterprise, within a revitalized low-scale, mixed-use setting at the periphery of Downtown Pasadena. The emphasis of the Arroyo Corridor Transition precinct is the transitional character of the area towards more pedestrian and transit-oriented development with a mix of land uses including residential, commercial, and employment (Pasadena 2004). The Project with Building A Residential/Commercial would include this mix of land uses–senior residents, residents, commercial, and employment–in one location thereby supporting the transition from single-use parcels and disjointed, disparate land uses to a cohesive mix of uses that are near transit and support pedestrian accessibility within and through the site.

Section 3, Policy Framework of the CDSP includes planning objectives applicable to new development in the Specific Plan area. The CDSP has a total of 33 objectives associated with the 7 General Plan Guiding Principles. The CDSP objectives that correspond with each Guiding Affinity Project Draft EIR

3.6-22 Land Use and Planning
Principle are summarized below, followed by discussion, with focus on the purpose of avoiding or mitigating an environmental effect, where relevant.
1) Summary of CDSP Guiding Principle 1 and Associated Objectives: Promoting growth appropriately and enhancing the Downtown through the development of multi-story buildings with a variety of complementary commercial and/or residential uses in underutilized areas with higher development capacity.

The Project with Building A Residential/Commercial would redevelop an underutilized and deteriorating site with transit and pedestrian accessibility multi-story buildings that provide complementary commercial, assisted living, and residential uses. The Project with Building A Residential/Commercial integrates two existing historic structures with the ground floor layout designed to provide spacing and setbacks to blend the scales of the existing and proposed structures.
2) Summary of Guiding Principle 2 and Associated CDSP Objectives: Preservation of the City’s historic character and environment which would be accomplished through preservation and integration of Pasadena’s historic resources as part of a complementary development that reduces the risk of resource demolition, deterioration by neglect, and/or impacts from natural circumstances.

As discussed previously, an historic resources variance is being sought by the Applicant to preserve and adaptively reuse two previously recorded historic structures on the site (501 and 523 South Arroyo Parkway). This provision facilitates the adaptive re-use of historic resources and encourages their long-term preservation on large sites designated for new development, as is the case with the Project with Building A Residential/Commercial. An HRA was prepared for the site (refer to Appendix C-1) that analyzed whether implementation of the Project with Building A Residential/Commercial would result in a significant impact to historic resources. As discussed in Section 3.2 of this Draft EIR, while the tenant improvements do not anticipate demolishing, moving, or making major alterations to these historic resources, these plans remain conceptual and have not yet been finalized. Therefore, there may be a potential for impact, and MM CUL1 (described above) would be required. Additionally, the HRA assessed whether the Project with Building A Residential/Commercial’s scale, massing, and design would result in an indirect impact to these historic resources. The HRA determined there would not be a significant impact related to development of the proposed Buildings A and B in proximity to the historic buildings on the site. Additionally, implementation of MM NOI-1, which outlines setbacks, monitoring, and (if needed) restoration related to the potential for cosmetic damage to these two buildings because of operation of vibration-causing construction equipment would reduce impacts to a less than significant level. With implementation of MM CUL-1 and MM NOI-1, it was determined there would be a less than significant impact to historic resources. Based on this assessment, it can be concluded that the Project with Building A Residential/Commercial would not conflict with applicable goals and policies related to historic resources and their preservation. 3) Summary of CDSP Guiding Principle 3 and Associated Objectives: Supporting economic growth and sustainability by providing jobs, services, revenues, and opportunities for the City’s economic vitality and fiscal health.

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