Pasadena City Council
November 21, 2022

Planned Development #39 (Affinity Project)
City Council

ATTACHMENT F
JULY 13, 2022 PLANNING COMMISSION STAFF REPORT

PLANNING & COMMUNITY DEVELOPMENT DEPARTMENT

STAFF REPORT
DATE: JULY 13, 2022
TO: PLANNING COMMISSION
FROM: JENNIFER PAIGE, AICP, ACTING DIRECTOR OF PLANNING & COMMUNITY

DEVELOPMENT DEPARTMENT

SUBJECT: PLN2020-00127; PLANNED DEVELOPMENT #39 (AFFINITY PROJECT) 465-577 SOUTH ARROYO PARKYWAY
______________________________________________________________________

RECOMMENDATION

It is recommended that the Planning Commission:

1. Recommend that the City Council certify the Final Environmental Impact Report and adopt the accompanying Mitigation Monitoring and Reporting Program;

2. Recommend that the City Council adopt the Findings in Attachment A to approve a Zoning Map A mendment to reclassify the project site from CD-6 to PD -39 (Affinity Planned Development) with the Conditions of Approval in Attachment B;

3. Recommend that the City Council adopt the Findings in Attachment A to approve the PD Plan for PD-39 with the Conditions of Approval in Attachment B; and

4. Recommend that the City Council adopt the Findings in Attachment A to approve the Variance for Historic Resources, subject to the Conditions of Approval in Attachment B.

BACKGROUND

The applicant, The Arroyo Parkway, LLC, has submitted applications for a Planned Development (PD) District and Variance for Historic Resources (VHR) on a 3.3 acre site consisting of five parcels (5722-008-019, 5722-008-002, 5722-008-012, 5722-008-017, and 5722-008-016). The applications are to facilitate the Affinity Project (Project), which proposes demolition of six (of the nine) existing commercial buildings, and construction of two seven- story buildings consisting of medical office uses, assisted living and independent living uses (including up to 95 senior housing units), and ground floor commercial uses . Included is the ability to exchange the medical office uses for up to 197 residential dwelling units. Up to five new levels of subterranean parking would accommodate the uses. Three existing buildings would be retained as part of the Project including the Whole Foods Market and an associated subterranean parking structure at 465 South Arroyo Parkway, and two historic structures at 501 and 523 South Arroyo Parkway. Establishment of the

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PD zoning district requires an amendment to the zoning map to reclassify the Project site to PD, and approval of a PD Plan . The PD Plan prescribes the applicable land use and development standards. The VHR is a request for relief from maximum allowed building heights associated with the preservation and reuse of existing historic structures.

LOCATION AND SETTING

The Project site is located between 465 and 577 South Arroyo Parkway and is bound by East Bellevue Drive on the north, South Arroyo Parkway on the east, East California Boulevard on the south, and the Metro L Line on the west. The Project site is developed with nine commercial buildings that are one or two stories in height. Existing uses include a Whole Foods Market grocery store, retail sales, restaurants, and animal services. All existing land uses have surface parking except f or the Whole Foods Market, which has a 275 -space, subterranean parking structure for its use.

The Project area is an urban environment, and the site and surrounding area are fully built out with a broad mix of land uses. 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, Central Park, and single- and multi-family residential land uses. Commercial land uses are located opposite the Project site on Arroyo Parkway. Single- and multi -family residential land uses are situated to the east along Marengo Avenue and Arroyo Parkway. Land uses to the south include a mix of commercial, medical office, and single- and mult i-family residential land uses. To the west, there is a mix of commercial uses.

The Project site is relatively flat with limited ornamental vegetation present. The site has seven existing points of access, including two on California Boulevard, one on Bellevue Drive, and five on Arroyo Parkway 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.

PROJECT DESCRIPTION

The Project involves demolition of six (of nine) existing buildings totaling 45,912 square feet (sf), located at 491, 495, 499, 503, 541, and 577 South Arroyo Parkway, and construction of two new buildings:

• 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 senior housing units; and
• Up to 850 parking spaces in five subterranean levels.

Alternatively, the proposed PD would allow Building A to be developed with the following:

• Up to 197 residential dwelling units with 3,000 sf of commercial and a sales/leasing management office on the ground floor. Under this option up to 650 parking spaces in four subterranean levels would be constructed.

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The proposed site layout and the aboveground height, mass, and other parameters of the Building A design would remain the same, whether occupied by medical office uses or residential dwelling units. It is noted that based on a density of 87 dwelling units per acre (du/acre), 289 units could be constructed. Therefore, if 197 units were constructed in Building A, only 92 senior housing units could be constructed in Building B. Conversely, if 95 senior housing units were constructed in Building B, only 194 units could be constructed in Building A.

Approximately 79,553 square feet of existing development would be retained and integrated into the Project, including the Whole Foods Market and associated subterranean parking structure at 465 South Arroyo Parkway , and two historic structures at 501 and 523 South Arroyo Parkway.

The Applicant anticipates that restaurant uses would occupy the historic structures . In retaining these historic structures, the Applicant has requested a Variance for Historic Resources for relief from maximum allowed building heights . Specifically, when measured to the highest parapet, Building A is proposed at a height of 93’6”, and Building B is proposed at a height of 90’6”, where the maximum allowed is 50’ and 65’ with height averaging.

The proposed uses within the two new buildings and two historic structures to remain would have three vehicular ingress/egress points, one on California Boulevard and two on South Arroyo Parkway. Each access point from South Arroyo Parkway is proposed with a circular drop-off area, one on the north side of Building A , and one on the north side of Building B. The existing ingress/egress on East Bellevue Drive into the Whole Foods Market parking structure would remain and continue serving the grocery store; this parking structure would remain entirely separate from the newly proposed subterranean parking structure.

Approximately 31,605 s quare feet of open space, including public and private space would be provided across the Project site. The Project would remove 23 non-protected non-native trees on the Project site and two (of the 17) protected, non-native street trees (removal subject to approval by the Urban Forestry Advisory Committee). The Project would replace trees on private property with 38 new trees throughout the site. The 15 remaining street trees would be protected in place during construction and remain after the Project is implemented.

ENTITLEMENTS

The Project requires Certification of the Final EIR and approval of the following , with the City Council serving as the decision-making body:

1. Zoning Map Amendment : To re classify the Project site from CD -6 to Planned Development 39 (Affinity Planned Development);

2. P D Plan : To establish allowed and conditionally allowed land uses, development standards, and conditions of approval that are incorporated into Appendix A (Planned Developments) of the Zoning Code; and

3. V ariance for Historic Resources : To allow building heights up to 93’6” where the maximum allowed is 50’ and 65’ with height averaging.

As provided in Zoning Code Section 17.26.020.C (Purpose and Applicability of Special Purpose Zoning Districts – Planned Development (PD) District), the PD zoning district is intended for sites where an applicant proposes, and the City desires, to achieve a particular mix of uses,

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appearance, land use compatibility, or special sensitivity to neighborhood character. The rezoning of a site to PD requires simultaneous approval of a PD Plan.

As provided in Zoning Code Section 17.61.080.H (Variances – Variances for Historic Resources) a VHR 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.

PD District and Zoning Map Amendment

The proposed PD zoning district and accompanying PD Plan involve the Design Commission, Planning Commission, and City Council . The role of the Design Commission is to provide 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, the Design Commission may comment on cultural resources of a draft environmental study as appropriate. On May 25, 2021, the Design Commission provided advisory comments through the Preliminary Consultation phase that are included as Attachment C. Remaining phases of Design R eview (Concept and Final Design Review) would occur subsequent to approval of the Project.

The Planning Commission’s role is to consider the application for reclassification to a PD zoning district, and at the same time, consider the proposed PD Plan accompanying the application. The Planning Commission is responsible for making a recommendation to the City Council whether to approve, approve in modified form, or disapprove the proposed amendment and PD Plan. The City Council’s role is to consider the Planning Commission’s recommendation and to take action to approve, approve in modified form, or disapprove the proposed amendment and accompanying PD Plan. The recommendation and action taken by the Planning Commission and City Council shall be based upon the following two findings in Zoning Code Section 17.74.070 (Findings and Decision):

1. The proposed amendment is in conformance with the goals, policies, and objectives of the General Plan; and

2. The proposed amendment would not be detrimental to the public interest, health, safety, convenience, or general welfare of the City.

PD Plan

A PD Plan prescribes the applicable land use and development standards, and functions as the ordinance adopting the PD zoning district as well as accompanying conditions . Development regulations applicable to the PD district are specified through the PD Plan, except for the following:

1. The FAR (floor area ratio) of a PD shall not exceed the FAR allowed on the Land Use Diagram for the project site unless approved by the City Council, but only as high as 3.0, and only when it can be shown the architectural design of the PD is cont extual and of a high-quality.

2. The residential density of a PD shall not exceed the residential density allowed on the Land Use Diagram for the project site unless approved by the City Council, but only as high as 87 dwelling units per acre, and only when it can be shown the architectural design

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of the PD is contextual and of a high-quality. The residential density may also exceed that of the Land Use Diagram if the project is complying with the Density Bonus provisions of Chapter 17.42 (Affordable Housing Incentives and Requirements).

3. In the CD district, no PD plan may authorize a greater height than that permitted by Figure 3-8 - Central District Maximum Height.

4. The performance standards of Section 17.40.090 shall apply.

The proposed PD provides maximums for FAR and density that are at or below applicable maximums on the Land Use Diagram . Building heights proposed in excess of maximums are requested through the VHR application. Where approved, the PD Plan would reflect the authorized height limit. The Project would adhere to performance standards.

The proposed PD Plan is provided as Attachment D. The discussion that follows provides an overview of development regulations prescribed in the proposed PD Plan in relation to the current Central District zoning requirements and other related requirements and allowances in the Zoning Code.

Land Uses

Land use requirements in the CD are identified in Table 3 -1 (Allowed Uses and Permit Requirements for CD Zoning Districts), Zoning Code Section 17.30.030 (CD District Land Uses and Permit Requirements).

The PD Plan prescribes allowed and conditionally allowed land uses for the PD zoning district.

Proposed land uses and their permit requirements are generally consistent with the current CD-6 land use requirements. ‘Residential care facilities, general,’ ‘Life/care facilities,’ ‘Adult day- care, general’ land uses require Conditional Use Permits in the CD-6 zone, and ‘Medical Services Extended Care’ is not listed. Care related activities associated with these types of classifications are proposed as part of the Project and were considered as part of the review of the Project .

Therefore the PD Plan identifies these uses as permitted. Additional land uses included as part of the PD Plan that are not currently listed in CD -6 include,’ Alcohol Beverage Manufacturing,’ ‘Alcohol Beverage Manufacturing with Accessory Tasting Room,’ Custom Manufacturing/Artisan Production,’ and ‘Wireless Telecommunication Facilities, Co-Located (SCL).’

Density

The CD development standards allow a maximum density of 48 dwelling units per acre (du/acre) pursuant to Figure 3- 6 (Central District Maximum Residential Density [dwelling units/acre]) , Zoning Code Section 17.30.040 (CD General Development Standards). A density of 48 du/acre allows a maximum of 159 dwelling units based on a site area of 144,853 square feet. The General Plan Land Use Diagram High Mixed Use designation establishes a maximum density of 87 du/acre. A density of 87 du/acre allows for 289 dwelling units based on the site area. The Project proposes up to a maximum of 289 units (inclusive of independent living units). The PD Plan prescribes this maximum for the Project, which is consistent with the maximum on the Land Use Diagram.

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Setbacks

The CD development standards require a Type 2 setback along each of the three street frontages that the Project site adjoins (Bellevue Drive, Arroyo Parkway, and California Boulevard) pursuant to Figure 3 -7 (Central District Required Setbacks), Zoning Code Section 17.30.040. A Type 2 setback specifies a zero setback for non- residential (including mixed-use) uses, but may be set back up to 5’ maximum. No setback is required along the west property line that is interior to the site.

The PD Plan prescribes a 0’ minimum or no setback requirement at each street frontage and along the westerly property line. While the PD Plan expresses minimums, the Project has proposed additional building setbacks and recesses to allow for building articulation, and to create space for streetside plazas , patios, and building entrances. In particular, at the intersection of California Boulevard and Arroyo Parkway, portions of Building A are setback 28 feet to create space for entry. Ground floor portions on the north side of Building A are cutout and recessed for more than 90 feet to provide an entry into the building from the adjacent drive access. Northern portions of Building B are designed to be built to the street on Arroyo Parkway. However, substantial portions wrap behind and around the two historic structures to remain. These areas of Building B are setback a minimum of 60 feet from Arroyo Parkway, providing space for streetside plazas and patios.

Building Height

The CD development standards allow a maximum height of 50’ and 65’ with height av eraging pursuant to Figure 3-8 (Central District Maximum Height), Zoning Code Section 17.30.040. In the CD district, no PD P lan may allow a greater height than that permitted by the Central District Specific Plan. The Project proposes heights of the new buildings up to 93’6”, and has requested to exceed the maximum allowed through a Variance for Historic Resources. This request is discussed later in this report.

Floor Area Ratio (FAR)

The CD development standards allow a maximum floor area ratio of 1.50 pursuant to Figure 3-9 (Central District Maximum Floor Area Ratio), Zoning Code Section 17.30.040. An FAR of 1.5 allows for 217,280 square feet aboveground based on a site area of 144,853 square feet. The General Plan Land Use Diagram High Mixed Use designation establishes a maximum FAR of

3.0. An FAR of 3.0 allows for 434,559 square feet aboveground. The Project proposes 417,929 square feet aboveground (including Whole Foods, 501 and 523 S. Arroyo Parkway), for a FAR of

2.89. The PD Plan prescribes this maximum for the Project, which is less than the maximum on the Land Use Diagram.

Parking

The Project site is located within the CD Transit Oriented Development (TOD) a rea pursuant to Figure 3-5 (Central District Transit Oriented Development Area), Zoning Code Section 17.30.030.

Within the CD TOD area, there are mandatory and optional parking reductions that establish minimum and maximum parking requirements. Parking ratios used to calculate parking requirements are specific to each land use and are pursuant to Table 4- 6 (Off-Street Parking Space Requirements), Zoning Code Section 17.46.040 (Number of Off -Street Parking Spaces Required).

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The applicant proposes new subterranean parking levels to accommodate the two new buildings, and the two historic structures to remain at 501 and 523 South Arroyo Parkway. Wholefoods Market would continue to use an existing 275-space subterranean parking structure for its use.

The Project (development of Building A with medical office/commercial) includes medical offices and ground floor commercial uses in Building A, assisted living and independent living uses in Building B, and commercial uses within the two historic structures. To be conservative, ground floor com mercial uses in Building A and commercial uses within the historic structures were presumed to be restaurant uses. Medical office uses require 4 parking spaces for every 1,000 square feet of floor area, and restaurant uses require 10 parking spaces for every 1,000 square feet of floor area. The parking ratio for the uses in Building B (assisted living and independent living) are not specified in Table 4 -6 of the Zoning Code and are determined through the entitlement process. To determine parking requirements for the independent living units (dwelling units and guest parking) in Building B, the established parking ratios for multi-family use in Table 4-6 of the City’s Zoning Code were used as a guide. For the assisted living uses, the Los Angeles County parking requirement for developments with senior citizens and persons with disabilities was applied.

The Project (development of Building A with medical office/commercial) would provide up to 850 parking spaces in five subterranean levels for these uses. Table 1 outlines the required and proposed parking based on the mix of uses.

Table 1: Project Parking Requirements
Use SF/Units Ratio Requirement
Medical Office (Building A) 151,000 sf 4:1,000 sf 483-544^ Restaurants (Building A and Historic) 8,882 sf* 10:1,000 sf 71-80^ Assisted/Independent Living (Building B)
Independent Living
Assisted Living
Guest

95 85

1.5-1.75/du

0.50/du
1:10 units

143-166
43 18
Total Requirement (minimum-maximum) 758-851
New Parking Spaces Proposed 850
*Includes 3,000 sf of ground floor commercial (Building A), and 5,882 sf historic structures (501/523 S. Arroyo Parkway); ^Includes mandatory and optional TOD reductions (10-20%)

The Project with the option of developing Building A with residential/commercial includes up to 197 residential dwelling units and ground floor commercial uses in Building A, assisted living and independent living uses in Building B, and commercial uses within the two historic structures. To be conservative, ground floor commercial uses in Building A and commercial uses within the historic structures were presumed to be restaurant uses. Residential dwelling units were presumed to be equal to or larger than 650 square feet in size requiring 1.5 to 1.75 parking spaces per unit. The Project with Building A residential/commercial would provide up to 6 50 parking spaces in four subterranean levels for these uses. Table 2 outlines the required and proposed parking based on the mix of uses.

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Table 2: Project with Building A residential/commercial Parking Requirements Use SF/Units Ratio Requirement
Residential Dwellings (Building A)
Guest
197

1.5-1.75/du
1:10 units
296-345
19 Restaurants (Building A and Historic) 8,882 sf* 10:1,000 sf 71-80^ Assisted/Independent Living (Building B)
Independent Living
Assisted Living
Guest

92#
85 1.5-1.75/du

0.50/du
1:10 units

138-161
43 17
Total Requirement (minimum-maximum) 584-665
New Parking Spaces Proposed 650
*Includes 3,000 sf of ground floor commercial (Building A), and 5,882 sf historic structures (501/523 S. Arroyo Parkway); #289 (197 + 92) units maximum between Building A residential and Building B independent living units; ^Includes mandatory and optional TOD reductions (10-20%)

The PD Plan prescribes parking. Parking requirements for individual uses would continue to follow established ratios in the Zoning Code, with the exception of Building B, assisted living, which is identified above. In addition, the PD Plan prescribes allowances for automated, valet, tandem, triple stack, and compact parking within the development.

Open Space

Where Building A is developed for up to 197 residential dwelling units, it would be subject to mixed-use standards, Zoning Code Section 17.50.160 (Mixed- Use Projects). The PD Plan prescribes this Section as applicable. The mixed- use standards regulate location and depth of commercial uses, ground floor heights, community space requirements, requirements pertaining to balconies and parking, lighting, noise, loading and refuse. The Project would comply with all applicable requirements with the exception of the following that are specifically prescribed in the PD Plan.

Table 3: Minimum Community Space Requirements
Section Requirement PD Plan

17.50.160.H.2 A minimum of 150 square feet of
community space for each dwelling unit
A minimum of 140 square feet of
community space for each dwelling unit

17.50.160.H.4 The private open space shall not exceed
30 percent of the total requirement for
community space.

The private open space shall not exceed
60 percent of the total requirement for
community space.

Based on the availability of 31,605 square feet of open space, the Project has made a substantial commitment. The requirement prescribed in the PD Plan address es the intent of ensuring compatibility between a mix uses.

Draft Central District Specific Plan

The Central District Specific Plan (CDSP) is currently in the process of being updated and will be presented to the Planning Commission and City Council at a future meeting for consideration.

The draft CDSP has the Project site located within a mixed- use neighborhood. The Project is within the development intensities prescribed in the draft CDSP, with the exception of height, as summarized in Table 4.

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Table 4: Development Standards Compared
Standard Project and Project Exchange Draft CDSP (CD-MU-N) Density (max) 87 du/acre 87 du/acre
FAR (max) 2.89 3.0
Height (max) 93’6” 63’ (78’ w/ height averaging)
Setbacks
Bellevue (N)
Arroyo Parkway (E)
California (S)
Interior (W)

0’
0’
0’
10’

0 – 5’
0 – 3’
0 – 5’
None required

Variance for Historic Resources (VHR)

The Project proposes construction of two new buildings with maximum building heights that range from 93 feet 6 inches (Building A) to 90 feet 6 inches (Building B), when measured to the top of the parapet. Building heights are proposed in excess of applicable maximums (50’ and 65’ with height averaging) for the purpose of accommodating the historic resources. The additional height would allow the Project to reestablish developable floor area, from one area of the site to another, while preserving the existing historic resources.

A VHR 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 desig nation prior to completion of the proposed project or establishment of the proposed use. Within the Project site three previously recorded historic resources were identified: 1) Market Basket Warehouse (501 S. Arroyo Parkway); 2) Lewis Iron Building (523 S . Arroyo Parkway); and 3) Pacific Electric Railroad (465 S. Arroyo Parkway).

All three buildings would be retained as part of the Project. The buildings at 501 and 523 South Arroyo Parkway were previously recommended as eligible for the local register based on evaluations that occurred in 1989 and 2000. In 2010, the City Council upheld a 2009 decision by the Design Commission that found both buildings are eligible for designation as landmarks because they retain historic integrity and meet the Californi a Register of Historical Resources (CRHR) Criterion C.

The building at 501 South Arroyo Parkway is a two- story Moderne style warehouse and office building that was constructed in 1940 and is identified as the Market Basket Warehouse Offices.

It has been noted as “one of two or three best intact examples of 1940s Moderne design in the Arroyo Parkway Industrial Area” and “as an example of World War II era Modern vernacular commercial design.”

The building at 523 South Arroyo Parkway, is a single- story brick masonry commercial building that was constructed in 1922 and is identified as the former Lewis Iron Building. It is noted as “an example of commercial design by the prominent local architecture firm of Marston and Van Pelt.”

Through preparation of a H istorical Resources Assessment for the Project, no changes were observed that would compromise their historic integrity. The buildings remain eligible for the Local Register under CHRH Criterion C. The resources embody 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. Both buildings are also historical resources for the purposes of CEQA.

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The former Pacific Electric Railroad Garage, which was also previously recommended eligible for the Local Register, and may continue to be eligible, is partially present. 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.

A review of the VHR shall be concurrent with the zoning map amendment and PD Plan. The recommendation and action taken by the Planning Commission and City Council shall be based upon the following findings in Zoning Code Section 17. 61.080.H.3 (Variances – Variances for Historic Resources – Findings and decision):

1. The Variance for Historic Resource is necessary to facilitate the appropriate use of an existing historic structure;

2. The Variance for Historic Resource would not adversely impact property within the neighborhood or historic district; and

3. 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.

The Variance for Historic Resources to allow an increase in building height is intended to preserve and integrate the two historic resources into the Project. To facilitate their continued use for commercial purposes and to avoid compromising their historic integrity or distinctive characteristics, the design approach concentrated development intensity around, and behind, as opposed to above, in a manner that frames the historic buildings. Through this approach, the historic buildings maintain their lower scale and pedestrian centric appearance. An increase in allowed building height would not adversely impact historic al resources in the vicinity of the Project site that include historic and landmark districts. Historic resources located outside of the Project site w ould not be physically altered, would retain all character -defining features and historic materials, and would retain their existing relationship within their respective settings. As a result , the additional building height would not adversely impact property within the neighborhood or historic district.

GENERAL PLAN AND SPECIFIC PLAN

General Plan Consistency

General Plan Land Use Designation

The General Plan Land Use Diagram depicts the distribution of various uses and intensity of development that shall be permitted as the physical representation of the element’s goals and policies. These are implemented through the Zoning Code, Zoning Map, and Specific Plan.

Standards for the density and intensity of development are defined for each land use category depicted on the Land Use Diagram. The Project site is designated High Mixed Use (0.0–3.0 FAR, 0-87 du/ac) on the General Plan Land Use Diagram, which is intended to support the development of multi-story mixed use buildings with a variety of compatible commercial (retail and office) and residential uses.

The Project proposes development of multi- story buildings that would include a mix of uses, shared open spaces, landscaping, shared driveways and subterranean parking. As noted, the PD

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Plan that would regulate implementation of the Project, specifies a maximum FAR up to 2.89 and 87 du/acre, consistent with the High Mixed Use designation. A PD zoning district is consistent with all land use classifications of the General Plan. The proposed Amendment and VHR that would facilitate the Project is in conformance with the goals, policies and objectives of the General Plan as described in Attachment A, Findings.

Central District Specific Plan Consistency

The Project site is located in the Central District Specific Plan area. The CDSP includes planning concepts and strategies, principles, and criteria, as well as guidelines and approaches. Together, they fulfill planning objectives of the CDSP that respond to Guiding Principles in the General Plan Land Use Element. The proposed Project is consistent with the CDSP as demonstrated below.

The Arroyo Corridor/Fair Oaks subdistrict 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 this subdistrict is to establish Arroyo Parkway as a visually appealing entrance corridor. The Project site is further distinguished within the subdistrict as the Arroyo Corridor Transition. This section of Arroyo Parkway should begin the transition toward a more pedestrian- and transit-oriented, mixed-use character, including residential, commercial, and employment .

Among the preferred uses for this area are employment generators, including those with strong links to education, technology, research, and the arts. Key intersections along the corridor, namely California - Arroyo and near Del Mar - Arroyo should be redeveloped with a denser, street-oriented and mixed-use character. It is at these locations that housing is most suitably introduced into the subdistrict. The Project continues the the me of an active Central District by l ocating dense development close to Metro stations, and in particular the highest of intensities near the Del Mar and Fillmore stations where it is desired. The Project will improve underused parcels and strengthen a significant corridor by locating intensity towards a major intersection and stepping back intensity between major intersections. The Project will help the area establish a more consistent and identifiable character as a visually appealing entrance corridor through its pedestrian- and transit -oriented character, mix of uses, and integration of residential opportunities. The unified design would provide a more accommodating experience for pedestrians as they transition from the public realm to the private realm and vice versa. The Project along with the existing nearby Del Mar Station project will collectively contribute to the sense of place. The Project is designed to respect examples of modern commercial design, and commercial design by a prominent local architecture firm through the preservation and reuse of two historic structures.

The Project contributes to pedestrian vitality and promotes pedestrian activity by placing entries on the street, incorporating transparent facades, open space and opportunities for dining areas, while locating parking underground. Multi-modal movement is improved and enhanced through the reduction in existing curb cuts that contribute to disruptions in circulation. The Project is required to accommodate Dial -A-Ride and other accessible shuttles, prepare a Transportation Demand Management Program (TDM) Plan, and develop and implement a targeted Complete Streets Plan. The intent of the Complete Streets Plan is to encourage use of non-vehicular modes by the project’s patrons and residents, and implement measures to discourage use of residential streets to and from the project site. Bicycle parking facilities are also required of the Project. The provision of these resources, Plans, and public improvements would provide an improved connection between the site and nearby Metro rail stations.

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TREE PROTECTION ORDINANCE

Certified Arborist Cy Carlberg prepared a tree inventory for the project that identifies 40 trees. Of these, 23 are located on the subject property, and 17 are street trees. None of the trees on private property are protected, and therefore, are not subject to the City’s Tree Protection Ordinance and do not require a private tree removal permit for removal. The applicant plans to remove all of the unprotected trees and replace with 38 new trees across the Project site. The applicant anticipates removal of two protected street trees. As included in the conditions of approval in Attachment B, street trees are subject to tree protection and any request for removal shall be subject to review by the Urban Forestry Advisory Committee.

ENVIRONMENTAL REVIEW

An Environmental Impact Report (EIR) was prepared to identify, analyze, and mitigate, to the extent feasible, the potential environmental effects associated with implementation of the Project.

The EIR was prepared pursuant to the requirements of the California Environmental Quality Act (CEQA) and the Guidelines for the Implementation of CEQA (State CEQA Guidelines) (Title 14, California Code of Regulations, Chapter 3, Sections 15000 et. seq.). The Final EIR included as Attachment E constitutes the second and final part of the EIR for the Project and is intended to be a companion to the Draft EIR. The Draft EIR and technical appendices for the Project constitutes the first part of the EIR. The Final EIR includes responses to comments on the Draft EIR, revisions and clarifications to the Draft EIR, and a Mitigation Monitoring and Reporting Program (MMRP). The MMRP describes the mitigation program to be implemented by the City for the Project. Certification of the Final EIR by the City C ouncil would require adoption of environmental findings. A draft Findings of Fact is provided for Planning Commission consideration as Attachment F.

Throughout the CEQA documentation, the two development scenarios are 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).

The following discussion summarizes the public review process that has occurred, and the environmental analysis.

Public Review Process

On August 3, 2021, the City distributed an Initial Study (IS) and Notice of Preparation (NOP) to agencies, organizations, and individuals for a 30-day public review period (August 5, 2021 through September 3, 2021) to solicit comments and inform agencies and the public of the Project and the upcoming preparation of an EIR.

On August 11, 2021 (at a Planning Commission meeting) and August 26, 2021 (community meeting), the City held virtual scoping meetings to describe the Project, answer questions, and seek public input regarding the scope of the EIR analysis. During the scoping period, comments were received from agencies, organizations, and individuals. Written comments received were included in the Draft EIR, and environmental issues raised were considered in the preparation of the Draft EIR.

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On January 18, 2022, the City made available the Draft EIR for a 45 -day public review period (ended on March 3, 2022) and provided the public a Notice of Availability (NOA) of the Draft EIR.

On February 23, 2022, the Planning Commission held a virtual study session to inform the public about the Project and to solicit comments on the Draft EIR. The City received comment letters on the Draft EIR. All of the comment letters received by the City have been included and responded to in the Final EIR. Comments contained in the letters that raise significant environmental issues are addressed in Section 2.0 of the Final EIR. The Final EIR also includes minor revisions and clarifications to the Draft EIR, which are addressed in Section 3.0.

On May 25, 2022, the Ci ty made available the Final EIR. A n errata to the Final EIR was subsequently made available that addressed minor text revisions.

None of the revisions contained
in the errata constitutes significant new information or changes to the analysis or conclusions of the EIR. The Draft EIR, Final EIR, and errata are all available on the City website.

Environmental Topics Analyzed

Pursuant to 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. As part of the IS, the City determined there would be no impacts or less than significant impacts to the following environmental topics and/or thresholds:

• Aesthetics
• Agriculture 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 had the potential to impact the following environmental topics, which were further addressed in the 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 System

The Draft EIR identified potentially significant environmental impacts related to the following topics: Cultural Resources, Noise, and Tribal Cultural Resources. As summarized below, through the incorporation of mitigation measures, the identified significant impacts would be reduced to a less than significant level. The complete analysis of all environmental topics can be found in the Draft EIR.

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Cultural Resources (Mitigation Required)

Section 3.2 of the Draft EIR 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 for this environmental topic in the Draft EIR was derived from a Historical Resource Assessment Report prepared for the Project site, an archaeological records search, a Sacred Lands File search, Native American consultation, and a paleontological resource record search.

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. As proposed, the Project would not involve the physical destruction of the two buildings, nor would it result in any significant internal or external physical modifications that would compromise the historic integrity of the buildings. While the Project would not result in a substantive adverse change to the historic integrity of the buildings, the potential for future internal and external modifications to them does exist in the form of tenant improvements. Therefore, mitigation measure (MM) CUL-1 requires that the Project Applicant engage with a licensed architect and/or engineer that meets the Secretary of Interior’s (SOI) Professional Qualifications Standards to develop a series of protection interventions and protocols that would preserve the two historical resources – 501 and 523 South Arroyo Parkway – on the Project site during construction activities. These protocols shall t ake 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 under Noise, Section 3.7 of the Draft EIR. However, 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 and vicinity, unknown archaeological resources have potential to be present in native sediments beneath the Project site. Therefore, MM CUL-2, which identifies steps if cultural resources are discovered during cons truction, 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.

With implementation of MMs CUL- 1, CUL-2, and NOI-1, the Project and Project with Building A Residential/Commercial would result in less than significant impacts related to historic and archaeological resources.

Noise (Mitigation Required)

Section 3.7 of the Draft EIR analyzes potential noise and vibration impacts associated with the implementation of the proposed Project and Project with Building A Residential/Commercial.

Information for this environmental topic in the Draft EIR is derived from the noise analysis

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conducted by Psomas and the City of Pasadena General Plan and its Environmental Impact Report (EIR). Construction of the project would occur up to the property lines. These construction activities would generate vibration. However, construction related vibration would not be expected to interfere with the operation of land uses proximate to the construction area. Land uses nearby (about 50 feet) include restaurants, moving and storage facilities, a supermarket, and other non- vibration sensitive uses. Construction generated vibration from the Project would not interfere with their operation. However, heavy construction vehicles and activities may have the potential for cosmetic building damage of remaining on-site structures within the Project site (i.e., Whole Foods Market and 501 and 523 South Arroyo Parkway).

Therefore, to reduce the potential for vibration-induced cosmetic damage to the structures at 465, 501, and 523 South Arroyo Parkway, MM NOI -1 specifies implementation of the following three steps: (1) setbacks, (2) monitoring, and (3) restoration (if applicable). These steps outline setbacks distances for specific types of equipment, responsibilities for vibration monitoring, and responsibilities for restoration of cosmetic damage (if applicable).

With implementation of MM NOI -1, there would be less than significant noise and vibration impacts related to construction and operation of the Project and Project with Building A Residential/Commercial.

Tribal Cultural Resources (Mitigation Required)

Section 3.10 of the Draft EIR analyzes potential impacts to tribal cultural resources that could result from implementation of the Project or Project with Building A Residential/Commercial.

Information in this section is derived from consultation between the City and local tribal representatives (Gabrieliño Tongva Tribe and Gabrieliño Band of Mission Indians – Kizh Nation) consistent with Assembly Bill (AB) 52, an archaeological records search, the Sacred Lands File search, Native American consultation/cultural resources records search.

Based on consultation pursuant to AB 52 and the results of a records search, there are no tribal cultural resources listed on the California Register of Historical Resources (CRHR) or a local register within the Project site or otherwise known to the culturally affiliated Native American tribes. However, there is always the possibility that undiscovered intact cultural resources, including tribal cultural resources, may be present below the surface in native sediments.

Therefore, MM TCR-1 requires the Project Applicant to accommodate a Native American Monitor culturally affiliated with the site as recognized by the Native American Heritage Commission (NAHC) prior to the commencement of any ground-disturbing activity on the site. MM TCR-1 also defines the role of the Tribal Monitor, if such an individual elects to be present during construction of the Project, and the steps required if a potential tribal cultural resource is encountered during ground-disturbing activities.

With implementation of MM TCR-1, there would be less than significant impacts related to Tribal Cultural Resources under the Project and Project with Building A Residential/Commercial.

Final EIR

The City responded to comments received on the Draft EIR in the Final EIR. This includes a copy of each comment letter and the City’s responses to each applicable comment. In the process of responding to the comments, there were minor revisions to the text of the Draft EIR that are

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identified in the Final EIR. None of the comments or responses constitute significant new information.

The State CEQA Guidelines require a public agency to adopt a Mitigation Monitoring and Reporting Program (MMRP) for ensuring the implementation of required mitigation measures to reduce or avoid significant environmental effects as identified in the EIR. Mitigation Measures (MM) identified in the MMRP specify the timing of the measure, the agency or party responsible for implementing the measure, and the agency or party with the primary responsibility for monitoring and enforcing compliance. The MMRP is included as part of the Final EIR attached to this report.

REVIEW BY OTHER DEPARTMENTS

Several City Departments had the opportunity to review and comment on the proposed Project.

This included the Design and Historic Preservation Section, Community Planning Section, Building and Safety, Cultural Affairs Division, Department of Transportation (DOT), Fire Department, Department of Public Works, Public Health Department, Housing and Career Services Department, and Department of Water and Power. Preparation of the EIR also solicited information and input from the Police Department, Library and Information Services Department, and the Parks, Recreation and Community Services Department. Recommended conditions of approval have been included in Attachment B to this report.

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CONCLUSION

Staff is recommending approval with Findings in Attachment A and Conditions of Approval in Attachment B. The Proposed PD includes a PD Plan that prescribes land use and development regulations. The proposal is consistent with the Central District Specific Plan and does not exceed maximums for FAR or density on the General Plan Land Use Diagram. The Variance for Historic Resources procedure is in place to provide relief from development standards in conjunction with preservation and reuse of historic resources. The adaptive reuse of historic structure and request for relief from maximum building heights to accommodate those structures fulfills this intent and purpose.

Respectfully Submitted,

______________________________
Jennifer Paige, AICP
Acting Director of Planning & Community
Development Department

Prepared by: Reviewed by:

________________________ ________________________
Jason Van Patten Beilin Yu
Senior Planner Principal Planner/Zoning Administrator

Attachments:

Attachment A: Specific Findings
Attachment B: Conditions of Approval
Attachment C: Preliminary Consultation Comments
Attachment D: Draft PD Plan
Attachment E: Final EIR and Errata
Attachment F: Draft Findings of Fact
Attachment G: Response to Comments Received After End of Draft EIR Public Review Period Attachment H: Project Plans

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ATTACHMENT A

FINDINGS FOR ZONING MAP AMENDEMNT, ADOPTION OF A PD DISTRICT AND PD

PLAN, VARIANCE FOR HISTORIC RESOURCES

Zoning Map Amendment t o reclassify the Project site from CD- 6 to PD -39, adoption of a PD zoning district and accompanying PD Plan

1. The proposed amendment is in conformance with the goals, policies, and objectives of the General Plan.

The Project site is designated High Mixed Use (0.0-3.0 FAR, 0-87 du/ac) on the General Plan Land Use Diagram, which is intended to support the development of multi -story mixed-use buildings with a variety of compatible commercial (retail and office) and residential uses.

Development is characterized by shared open spaces, landscaping, and small to minimal separations between buildings, and shared driveways and parking. Sites may be exclusively commercial, but not exclusively residential. Mixed- use development projects containi ng housing shall incorporate amenities contributing to a quality living environment for residents including courtyards, recreation facilities, and similar elements. Where buildings face the street frontage, they shall be designed to enhance pedestrian activity with transparent facades for retail uses and distinctive entries for housing. Parking shall be located below or to the rear of the street. Projects constructed at High Mixed Use densities may be required to develop pedestrian-oriented streetscape amenities along their primary street frontages, consistent with the improvement concepts and plans defined by the City.

The Project is in conformance with the High Mixed Use designation because development consists of multi-story buildings that w ill include a mix of uses (medical office, assisted and independent living, ground floor commercial, multifamily housing) , shared open spaces, landscaping, shared driveways and subterranean parking. The accompanying PD Plan that will regulate implementation of the Project, specifies a maximum FAR up to 2.89 and 87 du/acre, consistent with the intensity and density of development prescribed by the General Plan Land Use Element. The PD zoning district is consistent with all land use classifications of the General Plan.

The proposed amendment that w ill facilitate the Project is in conformance with the goals, policies and objectives of the General Plan as described herein.

Guiding Principle 1. Growth will be targeted to serve community needs and enhance the quality of life. Higher density development will be directed away from residential neighborhoods and into the Central District, Transit Villages, and Neighborhood Villages.

These areas will have a diverse housing stock, job opportunities, exciting districts with commercial and recreational uses, and transit opportunities. New development will build upon Pasadena’s tradition of strong sense of place, great neighborhoods, gardens, plazas, parks, and trees.

The proposed amendment will facilitate high density development consisting of medical office, assisted living and independent living (senior housing), ground floor commercial uses, and/or housing. These uses are acutely needed when considering an aging population, are employment generating, and will leverage existing transit opportunities. The resulting Project will serve community needs and enhance quality of life, not limited to seniors, for residents of Pasadena and beyond.

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Guiding Principle 2. Pasadena’s historic resources will be preserved. Citywide, new development will be in harmony with and enhance Pasadena’s unique character and sense of place. New construction that could affect the integrity of historic resources will be compatible with, and differentiated from, the existing resource.

Historic resources within the Project site will be preserved and integrated into the Project.

Historic resources located outside of the Project site will not be physically altered, will retain all character-defining features and historic materials, and will retain their existing relationship within their respective settings. Implementation of a Mitigation, Monitoring and Reporting Program will ensure new construction does not affect the integrity of historic resources.

Guiding Principle 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.

Construction of the Project and Project uses will be employment- and revenue generating.

Medical office uses, assisted and independent living uses, and ground floor commercial uses will provide services to the community. These uses will complement existing uses in the vicinity and in the case of residential dwelling units in Building A, will expand the economic base and encourage existing business to stay and expand. As such, the Project provides opportunities for both potential employees and existing and future residents of the City.

Guiding Principle 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 is a critical component of being a socially sustainable community. The higher density of land uses on the P roject 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 will also be articulated with patios, window shades, and varying surface treatments to provide variation and break up the surface of the buildings. The Project will incorporate varying building setbacks and recesses to allow for building articulation, and to create space for streetside plazas, patios, and building entrances. Portions of both proposed buildings will be set back from the widest part of the building envelope and some portions of the buildings w ill extend only to Level 4 and Level 6. Additionally, the ground floor w ill be slightly taller than the remaining levels, at 15 feet high. This will act to differentiate the ground floor and, combined with some unique architectural features for this level, create a human- scale and pedestrian-friendly environment.

Construction and operation of the Project will not result in wasteful, inefficient, or unnecessary construction of energy resources, nor conflict with or obstruct the applicable State or local

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plans for renewable energy and energy efficiency. The EIR concluded that the Project will be consistent with State, regional, and City plans, policies, and regulations adopted for the purpose of reducing the emissions of GHGs.

Guiding Principle 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.

The Project proposes high density development in an area that is intended for the type of intensities and densities proposed. While the development provides new subterranean parking, it includes a mix of uses that complement existing uses along Arroyo Parkway. The development supports the guiding principle because the additional opportunities and services provided by the Project will build upon the City as a destination, further encourag ing pedestrian and transit activity. Two light rail stations are within one- quarter mile and the site is served by bus lines. Employees, customers, and residents of the site can shop for groceries, attend medical and other service related appointments, dine, and shop without a car. The mix of uses proposed and the existing ability to access other restaurant , dining, entertainment destinations proximate the site without a car support this guiding principle.

Guiding Principle 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.

Proposed medical office uses, assisted living and independent living uses support the objective of this area of the City being a corporate center for the region. These uses have the potential to support scientific research and will support the growing health/medical cluster immediately to the west along Raymond Avenue and South Fair Oaks Avenue. Project uses including housing will contribute to the economic base and provide long term growth for existing and new institutions. Project uses, transit accessibility, and proximity to other dining and shopping will encourage a healthy economy and foster other institutions.

Guiding Principle 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 participat e in shaping plans and policies for Pasadena’s future.

The City has provided the public with timely and understandable information on the Project and multiple opportunities for citizens to directly participate. The City’s environmental review process for the Project has met the requirements in CEQA for scoping and noticing. The City held two scoping meetings, including one with the Planning Commission. The City held a study session with the Planning Commission to receive input on the Draft EIR. These informational meetings allowed for direct citizen participation. As per City standards, the public hearings for the Project will be open to the public, and allow for direct citizen participation.

GOAL 1. Sustainable Growth. Sustainable growth and change in orderly and well- planned developments within targeted areas that allow for higher density development in an urban core setting and in close proximity to transit that provides for the needs of existing and future

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residents and businesses, ensures the effective provision of public services, and makes efficient use of land, energy, and infrastructure.

The Project is located within an area of the City that is targeted for higher density development (Central District). The setting is part of the urban core of the City and the Project site is proximate to light rail and bus lines (or routes) . The intensity and density of development proposed is consistent with the High Mixed Use Land Use designation. New construction will infill underutilized property predominantly occupied by one or two-story buildings and surface parking, with a dense, mixed development, making more efficient use of land, energy, and infrastructure. Therefore the Project ’s conformance with Policies 1.1 (Basic Growth Policy),

1.2 (Targeted Growth) and 1.3 (Development Capacities) carries-out Goal 1.

GOAL 2. Land Use Diversity. A mix of land uses meeting the diverse needs of Pasadena’s residents and businesses, fostering improved housing conditions, offering a variety of employment and recreational opportunities, and supporting a healthy population while protecting the environment.

The Project provides a mix of uses that will meet the needs of residents and businesses.

Independent living for seniors and multi -family residential units will contribute in addressing the community’s fair share of housing needs and enable residents to live close to businesses and employment. Opportunities for medical office uses, assisted living, and other commercial uses will serve both local and regional needs, capturing a greater share of local spending and offering a diversity of employment opportunities. Further, these uses will capture the economic value induced by the presence of transit stations and accommodate needed health facilities that are transit and pedestrian accessible. Therefore the Project’s conformance with Policies

2.1 (Housing Choice), 2.2 (Senior Housing), 2.3 (Commercial Businesses), 2.5 (Mixed Use),

2.6 (Transit-Related Land Uses), and 2.11 (Health Facilities) carries-out Goal 2.

GOAL 3. Compatible Land Uses. A mix and distribution of land uses characterized by their compatibility.

The mix of uses proposed will complement existing uses in the area and expands the distribution of land uses in the area. The Project will address a range of needs, from fully assisted living or memory care to fully independent living. Development of the Project w ill permit the City's senior population to be more integrated into the area, close to transit, grocery stores and other retail opportunities, service providers, and medical care. Therefore the Project’s conformance with Policy 3.2 (Care Facilities) carries-out Goal 3.

GOAL 4. Elements Contributing to Urban Form. A safe, well-designed, accessible City with a diversity of uses and forms. These diverse forms include distinct, walkable districts, corridors, and transit and neighborhood villages and cohesive, unique single and multi-family residential neighborhoods and open spaces where people of all ages can live, work shop and recreate.

The proposed Project will maintain and enhance the City’s urban form by offering additional choices that will serve community values, need, and varying demographics. The transition from low density development to a high density development continues the theme of an active Central District and continues to reinforce the area as a vital, pedestrian- oriented place that is focal to community identity, business activity, employment, and living. Locating dense development close to Metro stations, and in particular the highest of intensities near the Del Mar and Fillmore stations is a desired policy in the Land Use Element. The Project will improve

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underused parcels and strengthen a significant corridor by locating intensity towards a major intersection and stepping back intensity between major intersections. Therefore the Project’s conformance with Policies 4.2 (A Diversity of Places), 4.3 (An Active Central District) , 4.4 (Transit Villages), 4.5 (Transit Villages in Context), 4.7 (Strengthen Major Corridors) , 4.13 (Planned Developments) carries-out Goal 4.

GOAL 5. Pedestrian-Oriented Places. Development that contributes to pedestrian vitality and facilitates bicycle use in the Central District, Transit Villages, Neighborhood Villages, and community corridors.

The Project contributes to pedestrian vitality and promotes pedestrian activity by placing entries on the street, incorporating transparent facades, open space and opportunities for dining areas, while locating parking underground. The Project will provide bicycle parking and reduce the number of existing driveways, allowing for less disruption to pedestrian and bicyclists. Therefore the Project’s conformance with Policy 5.2 (Pedestrian-Oriented Development), carries-out Goal 5.

GOAL 6. Character and Scale of Pasadena. A built environment that evolves while maintaining Pasadena’s unique sense of place, character, and the urban fabric.

The Project will help the area establish a more consistent and identifiable character as a visually appealing entrance corridor through its pedestrian- and transit-oriented character, mix of uses, and integration of residential opportunities. The Project along with the existing nearby Del Mar Station project will collectively contribute to the sense of place. The Project is designed to respect examples of modern commercial design, and commercial design by a prominent local architecture firm through the preservation and reuse of two historic structures.

Incorporation of these unique elements as well as adding street -fronting uses (“eyes on the street”), adequate lighting, will cultivate a sense of community ownership. Therefore the Project’s conformance with Policies 6.1 (Sense of Place and History), 6.7 (Public Safety and Community Design) carries-out Goal 6.

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.

The Project will retain historic structures on the site and reuse for commercial purposes.

Available City processes such as a Variance for Historic Resource that are intended to accommodate historic resources undergoing development or change in use, incentive preservation. City support and assistance in pursuing designation of resources, and an equitable process based on adopted evaluation criteria will also contribute to preserving the historic assets. Therefore the Project’s conformanc e with Policies 8.1 (Identify and Protect Historic Resources), 8.2 (Historic Designation Support), 8.3 (Preservation Efforts), 8.4 (Adaptive Reuse) carries-out Goal 8.

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.

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The Project will 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. As discussed in Section

3.3, Energy, of the EIR, 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. The Project will involve the most energy -efficient buildings required under the current Title 24 Energy Efficiency Standards and w ill promote energy efficient transportation options by developing within a High Qua lity Transit Area ( HQTA) and Transit Priority Area (T PA). The Project will incorporate electric vehicle parking and charging, and provide for recycling. Infrastructure will be designed, constructed, and maintained based on the most current standards and best practices that will reduce impacts to the natural environment. The Project will retain and reuse structures as a means of supporting environmental sustainability. The Project will include 38 new trees and be required to plant new street trees as a condition of approval. Project implementation w ill result in a net gain in the urban forest. Therefore the Project’s conformance with Policies 10.1 (Environmental Quality and Conservation), 10.2 (Land Uses Supporting Sustainability), 10.4 (Sustainable Building Practices), 10.6 (Adaptive Reuse) ,

10.13 (Urban Forest), 10.16 (Infrastructure) carries-out Goal 10.

GOAL 11: Job Opportunities. Provide land use capacities that accommodate a diversity of job opportunities for Pasadena’s residents.

Project uses will provide for, and accommodate diverse job opportunities. Medical office uses and assisted living use will provide employment opportunities in research and outpatient care, in conjunction with the expanding medical cluster around Huntington Hospital. Other g round floor commercial uses to be provided by the Project also represent job opportunities. The Project presents an opportunity to attract new establishments that are complimentary to the Central District area and transit village. Therefore the Project’s conformance with Policy 11.1 (Business Expansion and Growth), 11.3 (New and Complementary Businesses) carries -out Goal 11.

GOAL 12. Shopping and Dining. Diversity of shopping opportunities enabling Pasadena’s residents to acquire desired goods and services in the City, as well as attracting customers from surrounding communities.

The Project will provide employment generating uses and housing opportuniti es. It will also attract customers and visitors from within the community and surrounding communities because of the diversity of opportunities within and around the site. The revitalization of the Project site will support other businesses nearby because those working, residing, or visiting the site will pursue their services and goods due to proximity. In addition, the new development will attract businesses, and positively enhance the corridor. Therefore the Project’s conformance with Policies 12. 2 ( Business Attraction), 12.4 (Revitalization of Commercial Areas) carries-out Goal 12.

GOAL 15. Sound Local Economy. A sound local economy which attracts investment, increases the tax base, creates employment for Pasadena residents and generates public revenues.

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The Project will attract investment, increase the tax base, create employment, and generate revenues. The Project represents a significant investment in the local community. Therefore the Project’s conformance with Policy 15.1 (Local Investment) carries-out Goal 15.

GOAL 16. Superior Services. A superior level of services meeting the needs of Pasadena’s diverse residents including schools, hospitals, parks, child and senior facilities and programs, libraries, shelters, public auditoriums, health facilities, social clubs and recreation centers

The Project will provide assisted living and independent living for seniors, which 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. Providing health related facilities and opportunities addresses and anticipates needs of the community. Further, locating these types of uses near transit and within proximity to other health related facilities such as Huntington Hospital improves the accessibility of these servi ces. Therefore the Project’s conformance with Policies 16.3 (Anticipated Needs), 16.6 (Accessible Services) carries-out Goal 16.

GOAL 18. Land Use/Transportation Relationship. Pasadena will be a City where there are effective and convenient alternatives to using cars and the relationship of land use and transportation is acknowledged through transit -oriented development, multi -modal design features, and pedestrian and bicycle amenities in coordination with and accordance with the Mobility Element.

The inclusion of medical offices, assisted and independent living, and/or residential units at the Project site brings a mix of uses that are not currently well represented along Arroyo Parkway. Patrons, employees, and residents of the development will benefit f rom access to nearby resources such as the Whole Foods Market on site and several restaurants and other amenities in the vicinity. This w ill be in addition to potential medical office appointments or visits to those being cared for. All will benefit from convenient access to two Metro stations within a ¼ mile of the site, and bus service. The mix and density of uses will induce a greater share of walking, bicycling, and transit use as an alternative to the automobile. In addition, in placing assisted living and independent living uses at this particular site, the Project has considered the mobility needs of the disabled, and especially seniors. Therefore the Project’s conformance with Policies 18.1 (Development Mix and Densities), 18.2 (Mobility) carries-out Goal 18.

GOAL 19. Parking Availability. The supply of parking will reflect Pasadena’s objective to protect residential neighborhoods; create a vital, healthy, and sustainable economy; establish Pasadena as a leader in environmental stewardship; encourage physical activity and a commitment to health and wellness; and encourage walking, biking, and transit. The supply of parking in an area will also reflect the type, mix, and density of uses; the availability of shared facilities; and the proximity to transit.

The Project removes all surface parking and replaces with subterranean parking, which reduces the land lost to parking. The location of the Project and mix of uses within and outside of the site provides an opportunity for residents, patrons, visitors, and employees to park once and visit many destinations. This will encourage a greater share of physical activity by encouraging walking, biking, and transit use to access other nearby destinations. Therefore the Project’s conformance with Policies 19.3 (Parking Management), 19.4 (Park Once) carries-out Goal 19.

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GOAL 20. Information and Participation. All Pasadena communities will be uniformly aware and participate in land use planning, entitlement processes, and decision- making processes through the communication of clear and understandable information and engagement opportunities

The review of the Project, including the environmental analysis, requires a public process and public involvement. Public notification through the use of new technology (ie. virtual meetings), mail, and the City ’s website have enabled the public to provide input in decision making.

Printed materials have also been made available at various City sites. Additionally, there have been multiple opportunities for public involvement. The city held two informational scoping meetings during a 30 -day public review period of the Initial Study to solicit comments and inform agencies and the public of the Project and the upcoming preparation of an Environmental Impact Report. The City held an information study session during a 45 -day public period of the Draft Environmental Impact Report to solicit comments and inform the public of the Project. Publicly noticed meetings before the Planning Commission and City Council are additional opportunities that enable the public to provide input. Therefore, the Project’s conformance with Policies 20.1 (Neighborhood Meetings), 20.2 (Brochures and Notices), 20.3 (Public Involvement and Proposed Projects), 20.5 (Public Discussion) carries- out Goal 20.

GOAL 28. Places to Live, Work, Shop and Recreate. A diversity of well- designed corridors and villages containing an integrated mix of commercial uses and/or housing that enable Pasadena’s residents to live close to businesses, services and employment.

The Project enables residents to live close to services, shopping, or work. The development of the property with a mix of uses that serve community needs, particularly in the Central District area and in proximity to Metro stations expands opportunities to reduce automobile use and actively engage and enhance pedestrian and transit activity. Therefore, the Project’s conformance with Policy 28.1 (Land Use Mix) carries out Goal 28.

GOAL 29. Transit Villages. Moderate to high density mixed -use clusters of residential and commercial uses developed in an integrated ‘village-like’ environment with buildings clustered on common plazas and open spaces in proximity to Metro Gold Line stations capitalizing on their induced market demands and land values, facilitating ridership, and reducing automobile use while increasing walkability

The Project accommodates a mix of uses that are acutely needed and not well represented along Arroyo Parkway. The clustering of medical office uses and care uses in proximity to other health related facilities in proximity to Metro stations will facilitate ridership, increase walkability, and better aligns with the City’s desire for transit villages. Therefore, the Project’s conformance with Policies 29.1 (Mix of Uses) carries-out Goal 29.

GOAL 31. Central District. The primary civic, business, financial, retail, entertainment, and cultural center of Pasadena with supporting housing enabling residents to live close and walk to these uses and access regional transit.

The Project is a high density development in proximity to Metro stations with opportunities for medical office, as sisted and independent living, restaurant, and/or housing. This growth is targeted to an area where growth and intensity of development is emphasized. The development will expand the customer base for business, both new and existing, and support

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Metro ridership. It will strengthen the Central District’s economic vitality and expand economic opportunities. Therefore the Project’s conformance with Policies 31.1 (Focus Growth), 31.3 (Del Mar, Memorial Park and Lake Transit Villages), 31.7 (Expanded Economic Opportunities) carries-out Goal 31.

2. The proposed amendment would not be detrimental to the public interest, health, safety, convenience, or general welfare of the City.

The proposed amendment will reclassify the Project site from CD-6 to PD-39 and facilitate the construction of the Affinity Project. The resulting Project will not be detrimental to public interest but instead will reinforce and strengthen Arroyo Parkway as a major corridor, provide jobs, services, revenues, and opportunities that wil l support Pasadena as an economically vital city and allow for continued fiscal health. The Project will improve Pasadena’s infrastructure and urban form through modernized buildings that are energy - and water - efficient. The Project w ill provide assisted living and independent living facilities for seniors that are acutely needed in the City and wider region because the U.S. population is living longer and a greater proportion of the population is considered senior or elderly. Medical office uses are employment -generating and will be located proximate to health care related land uses in the vicinity providing efficient synergy. These types of uses are in the public interest because they serve community needs and enhance quality of life for residents of Pasadena and beyond, and are not limited to seniors. Further, providing adequate care and multi-family housing (where constructed in Building A) for the 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 Project will retain and reuse existing historic structures, which is in the public interest.

Implementation of the Project will not result in the need for new or expanded fire protection, police protection, library service, or parks and recreation facilities that could otherwise present a detriment to the health, safety, convenience or general welfare of the City. An Environmental Impact Report (EIR) was prepared to identify, analyze, and mitigate, to the extent feasible, the potential environmental effects associated with implementa tion of the Project facilitated by the amendment. The EIR considered several environmental topics and identified potentially significant environmental impacts related to the following topics: Cultural Resources, Noise, and Tribal Cultural Resources . However, through the incorporation of mitigation measures, identified significant impacts would be reduced to a less than significant level.

Implementation of the Project pursuant to the PD Plan, conditions of approval, and Mitigation Monitoring and Reporting Program will ensure approval of the amendment and adoption of the PD zoning district, and accompanying PD Plan will not be detrimental to the public interest, health, safety, convenience, or general welfare of the City.

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Variance for Historic Resources to allow building heights up to 93’6” where the maximum allowed is 50’ or 65’ with height averaging

3. The Variance for Historic Resource is necessary to facilitate the appropriate use of an existing historic structure.

The buildings at 501 and 523 South Arroyo Parkway were previously recommended as eligible for the local register based on evaluations that occurred in 1989 and 2000. In 2010, the City Council upheld a 2009 decision by the Design Commission which found that both buildings are eligible for designation as landmarks because they retain historic integrity and meet the California Register of Historical Resources (CRHR) Criterion C. The building at 501 South Arroyo Parkway is a two- story Moderne style warehouse and office building that was constructed in 1940 and is identified as the Market Basket Warehouse Offices. It has been noted as “one of two or three best intact examples of 1940s Moderne design in the Arroyo Parkway Industrial Area” and “as an example of World War II era Modern vernacular commercial design.” The building at 523 South Arroyo Parkway, is a single- story brick masonry commercial building that was constructed in 1922 and is identified as the former Lewis Iron Building. It is noted as “an example of commercial design by the prominent local architecture firm of Marston and Van Pelt.” Through preparation of a Historical Resources Assessment for the Project, no changes were observed that would compromise their historic integrity. The buildings remain eligible for the Local Register under CHRH Criterion C. The resources embody 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. Both buildings are also historical resources for the purposes of CEQA.

The Variance for Historic Resources to allow an increase in building height is necessary to preserve and integrate the two historic resources into the Project. To facilitate their continued use for commercial purposes and to avoid compromising their historic integrity or distinctive characteristics, the design approach concentrated development intensity around, and behind, as opposed to above, in a manner that frames the historic buildings. Through this approach, the historic buildings maintain prominence and their lower scale, pedestrian centric appearance. Allowing the additional height reduces risk of resource loss, deterioration of integrity, or loss of prominence that may result if development intensity were located above or over the historic buildings.

4. The Variance for Historic Resource would not adversely impact property within the neighborhood or historic district.

Properties within the neighborhood would not experience any noticeable change as a direct result of allowing an increase in building height. An increase in allowed building height would not adversely impact historical resources in the vicinity of the Project site that include historic and landmark districts. Historic resources located outside of the Project site will not be physically altered, will retain all character- defining features and historic materials, and will retain their existing relationship within their respective settings. Further, the additional height would not prohibit or unreasonably restrict the use of solar energy systems on adjacent structures or create an adverse change in shade. Therefore, the additional building height granted through this Variance for Historic Resources would not adversely impact property within the neighborhood or historic district.

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5. 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.

A Guiding Principle of the Land Use Element of the General Plan is that Pasadena’s historic resources will be preserved. Goal 8 (Historic Preservation) of the General Plan seeks the preservation and enhancement of Pasadena’s cultural and historic buildings as valued assets and important representations of its past. The adaptive reuse of the historic buildings will ensure the preservation of a surviving early example of a particular building design and work of a prominent local architectural firm. Policy 10.6 (Adaptive Reuse) of the General Plan encourages adaptive reuse of structures, including non- historic structures, as a means of supporting environmental sustainability. The projec t site includes eligible historic resources that will be adaptively re- used as part of the proposed P roject. This approach respects the General Plan’s goals of not only protecting historic resources, but restoring and enabling continued economic and environmental value of such resources. The proposed project will allow the existing resource to be appropriately modernized and reused to reduce the risk of deterioration that may otherwise occur. Finally, the design of the Project demonstrates architectural sen sitivity to the historic buildings in its approach to height, massing, and modulation through the location of development intensity around, and behind, as opposed to above, in a manner that frames the historic buildings . Granting the Variance will allow the Project to satisfy a desire of the subdistrict, by raising the visual appeal of the site and corridor through dense development, and maintaining an attractive pedestrian- and transit-oriented character at the street.

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ATTACHMENT B

CONDITIONS OF APPROVAL

The applicant or successor in interest shall comply with the following conditions of approval:

1. The Planned Development 39 (PD-39) PD Plan dated _____ shall apply and supersede any inconsistent or different standards established by Title 17 of the Pasadena Municipal Code (PMC) but only for the development plan referred to in Section __ of Ordinance ____. Except as expressly provided in PD-39, PD-39 shall comply with all the requirements of Title 17 of the Pasadena Municipal Code and The Citywide Design Principles.

2. The site plan, floor plans, parking levels plans, elevations, and building sections submitted for building permits shall substantially conform to the site plan dated ______ submitted with this application, except as modified herein.

3. References herein to the applicant or developer shall mean the Project Applicant, and all references include not only the Project Applicant, but also any successors in interest.

4. All of the land use regulations and additional use regulations of CD-6 Central District Specific Plan, Arroyo Corridor/Fair Oaks subdistrict that are not inconsistent with this PD -39 shall apply. In cases of conflict, the PD-39 Ordinance shall prevail.

5. Compliance with these conditions and the intent of these conditions shall be to the satisfaction of the Planning Director, his or her designee, or, for conditions imposed by a specific City department, the department originally issuing the condition, and in accordance with any stated laws or regulations, or any amendments thereto. The implementing and enforcing departments may determine substantial conformance with these conditions of approval.

6. The final decision letter and conditions of approval shall be incorporated in the building plans submitted for building plan check.

7. The project shall adhere to the City regulations governing hours of construction, noise levels generated by construction and mechanical equipment, and the allowed level of ambient noise as specified in Chapter 9.36 of the PMC, unless otherwise stated in the conditions of approval, or as stated in the Mitigation Monitoring and Reporting Program.

8. Pursuant to Chapter 17.78 of the Zoning Code, the Zoning Administrator can call for a review of the approved conditions at a duly noticed public hearing before the Planning Commission if it can be reasonably shown that there are grounds for revocation or modification of this Planned Development. Any such Planning Commission review of these conditions may result in modifications or the addition of new conditions to address any issues related to the use. The Planning Commission may revoke the Planned Development if sufficient cause is shown.

9. The applicant or successor in interest shall comply with all mitigation measures contained within the approved Mitigation Monitoring and Reporting Program.

10. The proposed project, Activity Number PLN2020- 00127, is subject to the City's Condition Monitoring Program and Mitigation Measures Monitoring Program. Condition Monitoring

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and Mitigation Measures Monitoring are required for your project. Contact the Planning Division at (626) 744-4009 to schedule an inspection appointment.

Planning Division

11. Prior to issuance of any building or grading permits, the applicant or successor in interest shall record a lot tie covenant and agreement for purposes of calculating the maximum allowable gross floor area and density for the entire property (parcels 5722-008-019, 5722- 008-002, 5722-008-012, 5722-008-017, 5722-008-016). Each individual legal parcel shall be subject to the covenant whether or not such individual parcel is sold.

12. The applicant or successor in interest shall submit an application to designate 501 and 523 South Arroyo Parkway as Landmarks. Landmark Designation shall be required prior to issuance of any building or grading permits.

13. No grading permit shall be issued until the building permit for the project is ready to be issued.

14. All parking spaces reserved for residential uses in the subterranean parking garage shall be segregated from the parking for commercial uses. This may involve signage or the construction of fencing and/or vehicular gates to limit access, which shall be reviewed by the Department of Transportation and the Planning and Community Development Department.

15. An exterior lighting plan, including specifications of the proposed fixtures, shall be submitted to the Zoning Administrator prior to the issuance of any building permits. No light sources (e.g., bulb) shall be visible from any location off the site. The lighting shall comply with the standards of Section 17.40.080 (Outdoor Lighting) of the Zoning Code.

16. All exterior mechanical equipment shall be architecturally screened from view of the public right-of-way in a manner subject to review and approval by the Zoning Administrator and Design and Historic Preservation staff.

17. The project is subject to review and approval by the Design Commission through the Design Review process.

18. The applicant or the successor in interest, shall submit a final landscape and irrigation plan, in compliance with Zoning Code Chapter 17.44 (Landscaping) along with plans for a building permit. The plan shall be reviewed and approved to the satisfaction of the Zoning Administrator prior to the issuance of any building or grading permits. The landscape plan shall include a mix of plant size and materials. Plant materials shall emphasize drought - tolerant and/or native species.

19. This project meets the threshold for state- mandated water -efficient landscaping.

Accordingly, the final landscape plans (inclusive of planting and hardscape plans, the planting pallet, drainage plan, and irrigation system plan(s) and specifications), shall be reviewed by Planning Department staff for conformance with the standards and requirements specified within the 2015 California Model Water Efficient Landscape Ordinance (MWELO) prior to the issuance of a building permit. No certificate of occupancy shall be issued until such plans have been deemed compliant with the MWELO and the Planned Development #39 (Affinity Project) Page 31
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landscaping has been installed per such approved MWELO -compliant plans to the satisfaction of the department.

20. C
onstruction hours, allowable workdays, and the phone number of the job superintendent should be clearly posted at all construction entrances to allow surrounding property owners/users to contact the job superintendent if necessary. In the event the City receives a complaint, appropriate corrective actions should be implemented, and a report of the action should be provided to the reporting party.

21. T
he project shall comply with the City Trees and Tree Protection Ordinance - Chapter 8.52 of the PMC. The ordinance provides for the protection of specific types of trees on private property as well as all trees on public property.

22. I
f construction is initiated during the breeding season for nesting birds (i.e., March 1–September 15) and nesting raptors (i.e., January 1–July 31), the Project Applicant shall perform, or direct the performance of, a pre-construction survey for nesting birds and/or raptors shall be conducted by a qualified Biologist within three days prior to any construction activities on the Project site and in the immediately surrounding area (i.e., perform survey within 300 ft for nesting birds and within 500 ft for nesting raptors). A qualified Biologist shall be knowledgeable and experienced in conducting nesting bird surveys within Southern California and in determining appropriate buffer size to prevent bird nesting failure. If the Biologist does not find any active nests in or immediately adjacent to the Project site, construction work shall be allowed to proceed and no further action is required

23. I
f the Biologist finds an active nest in or immediately adjacent to the Project site and determines that the nest may be impacted or breeding activities substantially disrupted due to planned construction activities, the Biologist shall delineate an appropriate buffer zone around the nest depending on the sensitivity of the species and the nature of the construction activity. Any nest found during survey efforts shall be mapped on the construction plans. The active nest shall be protected until nesting activity has ended. To protect any nest site, the following restrictions to construction activities shall be required until nests are no longer active, as determined by a qualified Biologist: (1) construction limits shall be established within a buffer around any occupied nest (the buffer shall be 25–100 ft for nesting birds and 300– 500 ft for nesting raptors), unless otherwi se determined by a
q
ualified Biologist and (2) access and surveying shall be restricted within the buffer of any occupied nest, unless otherwise determined by a qualified Biologist. Encroachment into the buffer area around a known nest shall only be allowed if the Biologist determines that the proposed activity would not disturb the nest occupants. Construction in a buffer area can proceed when the qualified Biologist has determined that fledglings have left the nest or the nest has failed.

24. U
nanticipated Discovery of Human Remains and Associated Funerary Objects: Nativ e A
merican human remains are defined in PRC 5097.98 (d)(1) as an inhumation or cremation, and in any state of decomposition or skeletal completeness. Funerary objects, called associated grave goods in PRC 5097.98, are also to be treated according to this statute.

Health and Safety Code 7050.5 dictates that any discoveries of human skeletal material shall be immediately reported to the County Coroner and excavation halted until the coroner has determined the nature of the remains. If the coroner recognizes the human remains to be those of a Native American or has reason to believe that they are those of a Nativ e

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American, he or she shall contact, by telephone within 24 hours, the NAHC and PRC 5097.98 shall be followed.

25. Resource Assessment & Continuation of Work Protocol: Upon discovery of human remains, the tribal and/or archaeological monitor/consultant/consultant will immediately divert work at minimum of 100 feet and place an exclusion zone around the discovery location. The monitor/consultant(s) will then notify the Tribe, the qualified lead archaeologist, and the construction manager who will call the coroner. Work will continue to be diverted while the coroner determines whether the remains are human and subsequently Native American.

The discovery is to be kept confidential and secure to prevent any further disturbance. If the finds are determined to be Native American, the coroner will notify the NAHC as mandated by state law who will then appoint a Most Likely Descendent (MLD).

26. Kizh-Gabrieleno Procedures for burials and funerary remains: If the Gabrieleno Band of Mission Indians – Kizh Nation is designated MLD, the Koo -nas-gna Burial Policy shall be implemented. To the Tribe, the term “human remains” encompasses more than human bones. In ancient as well as historic times, Tribal Traditions included, but were not limited to, the preparation of the soil for burial, the burial of funerary objects with the deceased, and the ceremonial burning of human remains. The prepared soil and cremation soils are to be treated in the same manner as bone fragments that remain intact. Associated funerary objects are objects that, as part of the death rite or ceremony of a culture, are reasonably believed to have been placed with individual human remains either at the time of death or later; other items made exclusively for burial purposes or to contain human remains can also be considered as associated funerary objects.

27. Treatment Measures: Prior to the continuation of ground disturbing activities, the landowner shall arrange a designated site location within the footprint of the project for the respectful reburial of the human remains and/or ceremonial objects. In the case where discovered human remains cannot be fully documented and recovered on the same day, the remains will be covered with muslin cloth and a steel plate that can be moved by heavy equipment placed over the excavation opening to protect the remains. If this type of steel plate is not available, a 24-hour guard should be posted outside of working hours. The Tribe will make every effort to recommend diverting the project and keeping the remains in situ and protected. If the project cannot be diverted, it may be determined that burials will be removed. The Tribe will work closely with the qualified archaeologist to ensure that the excavation is treated carefully, ethically and respectfully. If data recovery is approved by the Tribe, documentation shall be taken which includes at a minimum detailed descriptive notes and sketches. Additional types of documentation shall be approved by the Tribe for data recovery purposes. Cremations will either be removed in bulk or by means as necessary to ensure completely recovery of all material. If the discovery of human remains includes four or more burials, the location is considered a cemetery and a separate treatment plan shall be created. Once complete, a final report of all activities is to be submitted to the Tribe and the NAHC. The Tribe does NOT authorize any scientific study or the utilization of any invasive and/or destructive diagnostics on human remains.

28. Each occurrence of human remains and associated funerary objects will be stored using opaque cloth bags. All human remains, funerary objects, sacred objects and objects of cultural patrimony will be removed to a secure container on site if possible. These items should be retained and reburied within six months of recovery. The site of reburial/repatriation shall be on the project site but at a location agreed upon between the

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Tribe and the landowner at a site to be protected in pe rpetuity. There shall be no publicity regarding any cultural materials recovered.

29. Professional Standards: Native American and Archaeological monitoring during construction projects will be consistent with current professional standards. All feasible care to avoid any unnecessary disturbance, physical modification, or separation of TCR’s shall be taken. The Native American Monitor shall be culturally affiliated with the site as recognized by the Native American Heritage Commission (NAHC). Principal personn el for Archaeology must meet the Secretary of Interior standards for archaeology and have a minimum of 10 years of experience as a principal investigator working with Native American archaeological sites in southern California.

Cultural Affairs

30. The project shall meet all requirements of the Public Art program. Prior to being issued a building permit, the property owner shall deposit twenty percent (20%) of the total one percent building valuation as the Public Art Deposit for the project. It is their responsibility to allocate the remaining eighty percent (80%) toward an onsite public art project, developed in accordance with the Guidelines for New Private Development. The property owner may also choose to pay the full 1% building valuation to the Cul tural Trust Fund, in lieu of developing an onsite public art project. Fulfillment of the Public Art Requirement via an onsite public art project or payment of the 1% in lieu fee shall occur in order to receive Final Signoff/Certificate of Occupancy.

Please note: For those property owners who choose to pursue the onsite public art project option, the following is required:
a. An art consultant shall manage any art project valued at $25,000 or more. After consulting with Cultural Affairs Staff, an art consultant should be contracted as soon as possible so they may work as an integral part of the design team from the inception of the project.
b. No project will receive Concept Design Review by the Design Commission without having first filed a Public Art Application with Cultural Affairs Staff. c. A draft Concept Art Plan shall be submitted to Cultural Affairs Staff within 45 days after Concept Design approval by the Design Commission.
d. Application for Final Design Review by the Design Commission is only possible after the Concept Art Plan has been approved by the Arts & Culture Commission.

Building & Safety

31. GOVERNING CODES: Comply with the Current Edition of California Building Code, California Electrical Code, California Plumbing Code, California Mechanical Code, California Energy Code, California Green Building Standard Code and the City of Pasadena Municipal Code. The governing edition is based on the date in which the project is submitted to the City of Pasadena for review.

32. BUILDING CODE ANALYSIS: Provide a Building Code Analysis on the title sheet. Include the code(s) information for each building proposed: Descriptive scope of work, occupancy, assessor’s parcel number, number of stories, type of construction, fire sprinklers, floor area, height, and allowable floor area.

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33. BEST MANAGEMENT PRACTICES: Photocopy to plans and complete the BEST MANAGEMENT PRACTICE page 1(form must be singed). Photocopy any other applicable pages and cross reference the location at the site plan, i.e. the material storage, the concrete waste management, etc. These forms can be found at
https://www.cityofpasadena.net/planning/building-and-safety/bs-applications- forms/#informational-handouts

34. PROPERTY LINE SURVEY REQUIRED. Per City of Pasadena Policy property line survey is required for:
a. New construction.
b. Auxiliary buildings and additions were setback is less than 5’-0” to property line. c. All buildings where specific Zoning Division Variance is issued for approved setbacks & whether newly constructed or altered.

35. SOILS REPORT REQUIRED. A soils engineer report is require for:
a. All new constructed single and multi-family residential, commercial, and industrial buildings.
b. An addition to a commercial or industrial building.
c. Second (2nd) story addition to existing one-story building. d. Hillside construction, i.e. decks, retaining walls, and swimming pools.

36. GRADING:
• Show compliance with CBC 2019 Appendix J – Grading with City of Pasadena Amendments.
• Clearly show the cubic yard quantities for excavation (cuts) and fills and label if site grading or foundation excavations.
• Clearly show the cubic yard quantities for excavation (cuts) and fills; and label if site grading or foundation excavations. A gr ading permit may not be required per section J103.2 Exemptions.

37. GREEN CODE: Photocopy to plans and complete the 2019 CALIFORNIA GREEN BUILDING STANDARDS CODE WITH CITY OF PASADENA AMENDMENTS FORMS.

These forms are being provided attach and can be found a t https://www.cityofpasadena.net/planning/building-and-safety/bs-applications- forms/#informational-handouts.

38. LOW IMPACT DEVELOPMENT (LID): Low Impact Development (LID) may be required for this project. Refer to the City of Pasadena link for further information on the requirements and submittal process: https://www.cityofpasadena.net/wp-content/uploads/sites/30/Form- PC.pdf?v=1599178168233.

39. MEANS OF EGRESS (EXITING): Clearly label and identify on plans fire-resistive corridors, exit enclosures, exit passageways, horizontal exits, occupancy separation walls and floors, fire resistive shafts, and fire walls, along with their fire-resistive ratings as applicable.

40. FIRE AND SMOKE PROTECTION FEATURES: Show materials, systems and assemblies used for structural fire resistance and fire-resistance-rated construction separation of adjacent spaces to safeguard against the spread of fire and smoke within a building and the spread of fire to or from buildings.

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41. ACCESSIBILITY:
• Provide compliance with accessibility per CBC Chapter 11A and 11B accordingly. • Provide an analysis for the minimum required units and parking spaces. Label the accessible units/parking spaces.
• Provide the minimum vertical clearance for VAN accessible to basement and garage per 11A and/or 11B accordingly.

42. REQUIRED PLANS AND PERMIT(S):
• In addition to architectural plans, provide Structural, Shoring, Plumbing, Mechanical, Electrical plans, and grading plans as required. No deferred submittal. • Separate permits are required for the following: Mechanical, Electrical, P lumbing, Fire Sprinkler, Demolition, Block walls, others.

Health Department

43. Per California Health and Safety Code (CHSC) Section 113789(c)(9), facilities licensed by Department of Social Services (DSS) Community Care Licensing are exempt from the health permit requirement. If the proposed business is licensed by DSS Community Car e Licensing, plan submittal to Environmental Health for the kitchen is not required, and a health permit for the kitchen is not required.

If the facility is unlicensed, or if the facility is licensed by the California Department of Public Health, the facility meets the CHSC definition of a food facility, and health plan approval and a health permit are required for the kitchen.

Examples
• Residential Care Facility for the Elderly (DSS Community Care Licensing): Exempt • Skilled Nursing Facility (CDPH): Health plan review and health permit required

If the facility is licensed by both DSS Community Care Licensing and CDPH, health plan approval and a health permit are required for the kitchen that provides foodservice to the CDPH portion of the facility.

44. Food facilities shall adhere to the regulations established in the Tobacco Use Prevention Ordinance (PMC 8.78). Smoking in outdoor public areas is prohibited throughout the City of Pasadena. Refer to the following link for more information:

8.78.071 – Prohibition of smoking in certain outdoor public places

45. If pools or spas are planned in this development, plan submittal to Environmental Health is likely to be required. Contact Pool Plan Check Specialist Elaine Zita at [email protected]
or at (626) 744-6026 for details.

Housing and Career Services Department

46. Where subject to the City’s Inclusionary Housing Requirements (Zoning Code, Chapter

17.42), the applicant or successor-in-interest shall obtain all necessary clearances from the Housing and Career Services Department, including the submission of an Inclusi onary Housing Plan for approval by the City Manager prior to any applicable discretionary action by the City.

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Fire Department

47. Assisted Living: 24 hour care facilities in a group R2.1 occupancy licensed by a government agency shall comply with the requirements of CBC Section 435.1 through 435.8.2.

48. H igh- rise building: Occupancies having occupied floors more than 75 feet above the lowest level of Fire Department Vehicle Access shall comply with CBC section 403.2 through 403.6.2.

49. Secondary Water Supply: A secondary on site water supply shall be provided for high- rise building CFC Section 903.3.5.2.

50. Emergency system: The detection, alarm and emergency voice/alarm communication system for high-rise building shall comply with CBC Section 403.4.1 through 403.4.8.

51. Fire Command Center: A fire command center complying with section 911 of CFC shall be provided in a location approved by the fire department.

52. Smoke Control System: High-rise building shall be provided with a passive or active smoke control system or combination thereof in accordance with CFC Section 909.

53. Standby power: A standby power system shall be provided per requirement of CBC Section 403.4.8

54. Means of Egress and Evacuation: The means of egress in high - rise building shall comply with CBC Section 403.5.1 through 403.5.6.

55. Elevator Car: At least one elevator shall be provided for fire department emergency access to all floors. The medical emergency service elevator shall comply with gurney size per CBC Section 3002.4.

56. Exit and exit access to public way: Each building shall comply with requirements of CBC chapter 10 for path of egress travel to public way.

57. Emergency Responder Radio Coverage: Building shall have approved radio coverage for emergency responders within the building based upon the existing coverage level of the public safety communication system per California Fire Code Section 510.

58. Minimum Fire Flow/Fire Hydrants: All structures shall have the minimum fire flow (GPM) required by Appendix B Table B 105.1 and the quantity and spacing of fire hydrants as required by Appendix C Table C105.1 of Title 24, California Fire Code. Plans shall be submitted to the Pasadena Fire Department for review and approval prior the review and approval of the building plans.

NOTE: A current fire flow report (not older than 6- months), performed by the Pasadena Water Department, shall be provided to the Fire Department when applying for building permits to construct or add to any structures.

59. Fire Department Access: Fire Department Access shall be provided to within 150-feet of all exterior portions of any structure. All access roads exceeding 150 -feet shall be provided

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with an approved Fire Department Hammerhead or Turnaround. Fire department acc ess shall be constructed of an all weather surface to support a minimum of 75,000 pounds with a minimum of 20- feet wide and unobstructed height of 13’ -6”, with No Parking on Either Side. No roadway way shall exceed 10% slope.

60. Aerial Fire Apparatus Access Roads: Building exceeding 30 feet in height above the lowest level of Fire Department Vehicle Access shall comply with requirements of CFC Section D105.1 though D105.3. Building shall have approved fire apparatus access roads capable of accommodating fire department aerial apparatus. Overhead utility and power lines shall not be located within the aerial fire apparatus access roadway.

61. Knox Box: All access gates across roadways or entrances to facilities shall fail unlocked/open in the event of any loss of power. All access gates and main entrance doors shall have a Know Box or Knox Control Key Switch installed. Obtain Knox Box Applications from the Pasadena Fire Department Permit Desk.

62. Automatic Fire Sprinkler System or Standpipe: An automatic sprinkler system shall be provided throughout building per CBC Section 903.2.1 and PMC amended CFC section 903.

Stand pipe system shall comply with the requirements of CBC Section 905.

63. Fire Department Fire Sprinkler Connections: Shall be comprised of:
• FDC shall be located a minimum of 25- feet from the building or surface mounted to 2- hours rated wall with no opening within 10 feet and FDC shall be located within 100 feet of a public hydrant.
• (2) 2-1/2” CLAPPERED internal swivel outlet X 2-1/2” CLAPPERED internal swivel outlet X 4” FDC
• 4” CLAPPERED internal swivel outlet X 4” FDC
• Shall be clearly labeled to indicate FDC for Fire Sprinklers and Standpipes. • A clear dimension of 3- feet shall be maintained around the perimeter of each fire department appliance.
• All fire appliances except for fire hydrants shall be cleaned, primed, and painted fire engine red enamel or krylon.

64. Automatic Fire Alarm/Detection System: All structures 10,000 square feet or any structure required by Title 24, California Building or Fire Codes, shall be provided with a fully automatic and manual fire detection and notification system. Shop drawings shall be submitted by contractor for review and approval prior to construction. PMC amended CFC Section 907.

65. Emergency Vehicle Traffic Signal Preemption Systems: Traffic signaling systems serving this complex are required to have emergency vehicle signal preemption controls installed.

The specific signals requiring this system is to be determined by both Pasadena Fire Department and Pasadena Department of Transportation. The fees for these systems will be determined based on the quantities and types of traffic signals being used and/or being retrofitted for the emergency vehicle controls.

Public Works Department

66. In reference to the Department of Transportation conditions of approval on sidewalk widening along Arroyo Parkway frontage and California Boulevard frontage, the applicant

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shall be responsible for all the costs required to complete the dedication. The dedication documents and processing fee shall be submitted to this office, at least three to four (3- 4) months prior to the issuance of any permits. The dedication documents shall be executed and recorded prior to the issuance of a Certificate of Occupancy.

67. No private improvements may be placed within the public right -of-way, including, but not limited to, soldier beams, tie-backs, utility conduits, backflow preventers, transformers, fire sprinkler valve, decorative sidewalk and applicable parade post holes on Colorado Boulevard per Standard Drawing S-419. Private improvements may only be placed in the public right -of-way by submitting a license agreement, which must be approved by the City. The license agreement application for any private improvement within the public right- of-way shall be submitted to the Department of Public Works for review and shall be approved by the City before any permits are granted.

The applicant shall submit the application, plan and processing fee, associated with processing the license agreement, at least three to four (3 -4) months prior to the issuance of any permits. An approved license agreement will allow the applicant to install and maintain the private improvements within the public right-of-way with conditions.

A license agreement for shoring requires an indemnity bond in order to guarantee that shoring and tie- backs are free from defect due to faulty material, workmanship and failure. Upon review of the license agreement exhibits, an indemnity bond estimate will be prepared and forwarded to the applicant. The estimated amount is equivalent to the cost of reconstructing the public right of way, including all affected util ities, public facilities, and infrastructures, based on the plane of failure at a 45- degree angle from the lowest point of excavation. The indemnity bond shall be submitted to the City prior to the execution of the agreement and the issuance of any building or demolition permits.

All steel rods in every tie- back unit shall be relieved of all tension and stresses, and any portion of soldier beams and any portion of the tie -backs located be removed entirely from the public right-of-way. A monthly monitoring report stamped and certified by a licensed surveyor shall be submitted to indicate that the deflection from any piles or soldier beams does not exceed one inch. Upon completion of construction, the developer or his contractor shall remove all tie -back rods within the public right -of-way. The removal shall be documented by a report certified by a licensed deputy inspector. The report shall be submitted to the City for review and approval. The applicant will be charged a penalty of $7,000 for each tie-back rod not removed from the public right -of-way. For temporary tie- backs or shoring, the maximum width of the license area fronting the development frontage(s) shall only extend to the centerline of the public right-of-way.

68. In order to accommodate an Americans with Disabilities Act (ADA) compliant curb ramp, the applicant shall verify, and reconstruct if necessary, standard curb ramps at all four corners of Arroyo Parkway and California Boulevard intersection, if possible, per Caltrans Standard A88A or City of Pasadena Standard No. S -414. The curb ramp construction shall be completed prior to the issuance of Certificate of Occupancy. A separate permit from the Department of Public Works is required for all construction in the public right-of-way. Please contact 626-744-4195 for the general process.

Additional striping, signal work, and/or poles/utility relocations might be necessary. The curb ramps construction shall be completed prior to the issuance of Certificate of

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Occupancy. A separate permit from the Department of Public Works is required for all construction in the public right -of-way. Please contact 626 -744-4195 for the general process.

The applicant shall submit to the City for review any proposed designs that will comply with the ADA requirements. The applicant is responsible for the design, preparation of plans and specifications, and construction of the new curb ramp. Plans for the curb ramp improvements shall be prepared by a civil engineer, registered in the State of California.

Upon submittal of improvement plans to the Departments of Public Works for review, the applicant will be required to submit fees, per the current General Fee Schedule, to cover the cost of plan checking and construction inspection of the improvements. Note that the building plans approved by the City’s Planning (Building) Department do not constitute approvals for work in the public right- of-way. Separate plans shall be submitted to the Department of Public Works – Engineering Division – at 175 North Garfield Avenue Window

6. The applicant shall submit the curb ramp improvement plans and the plan check fees at least two (2) months prior to the issuance of any building or demolition permits.

Upon review of the curb ramp improvement plans, the applicant may need to dedicate to the City for street purposes the land necessary at the property line corner rounding (Per S- 423) to provide for the minimum clearance required by the Americans with Disabilities Act standards. If so, the applicant shall remove and reconstruct the sidewalk for the dedicated area, per Standard Plan No. S -421. The applicant shall be responsible for all the cost required to complete the dedication, if it is required. The dedication document and processing fee shall be submitted to this off ice, at least three to four (3- 4) months, prior to issuance of any permits. The dedication documents shall be executed and recorded prior to the issuance of a Certificate of Occupancy.

69. The existing street lighting fronting the subject site are substandard. In order to improve pedestrian and traffic safety, the applicant shall replace/renovate the existing street lighting with LED lights, per the City requirements and current standards, along the following frontage:
a. One (1) street light along the California Boulevard frontage b. Five (5) street lights along the Arroyo Parkway frontage

In the event where the existing street light pole determined, by the City, to be deteriorated and/or damaged, the applicant shall replace the existing street light pole with a new street light pole in kind. The replacement shall include but not limited to new pole, new footing, new LED light(s), conduit, conductors, lamp socket, fuse, globe/lantern, globe holder, photo cell, and other miscellaneous related parts. The applicant shall schedule a street lighting pre-inspection with the Public Works inspector to determine the details/scope of the replacement/renovation of the existing street lighting. Please contact 626 -744-4195 or via email: [email protected]
to schedule a street lighting pre-inspection, prior to
the issuance of any permits.

70. The intersection of Arroyo Parkway and California Boulevard shall be upgraded as follow:
a. The intersection safety lighting are HPS luminaires. To continue on more efficient energy and lighting, the existing luminaires should be changed out to LED HBL’s to help in energy costs and more efficient lighting. SlaTS will provide specifications for model and wattage, when consultant submits the luminaire calculations for SLaTS review.

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b. The existing CCTV camera has reached its operating lifespan and needs to be replaced and upgraded. The new CCTV camera shall be a BOSCH MiC camera. SLaTS will provide the specifications.

Contact Rich Yee by phone at 626-744-4643 or email [email protected] for details.

71. The applicant shall restore and re -paint the existing metal street light pole along the California Boulevard frontage of the subject property in a manner acceptable to the Department of Public Works. In addition, the painting specification shall be per the Specific Plans and specifications. The cost of the street light pole and traffic signal pole/equipment restoration and painting is the applicant’s responsibility.

72. The applicant is responsible for the design, preparation of plans and specifications, and the construction of all required street lights and traffic signal modification. Plans for the improvements shall be prepared by a civil engineer, registered in the State of California.

Upon submission of improvement plans to the Departments of Public Works for checking, the applicant will be required to submit fees, per the current General Fee Schedule, to cover the cost of plan checking and construction inspection of the improvements. In addition, there is possibly considerable lead-time for the materials required for the construction and modification. In order to avoid delays in the development schedule, the applicant shall coordinate with this office at 626-744-4195 regarding this street light/traffic signal condition at least five (5) months in advance of the anticipated issuance of Certificates of Occupancy.

73. A section of Arroyo Parkway, fronting the subject development, is an asphalt concrete roadway. This reach shall be restored with half -width (from gutter to median island) cold milling and resurfacing of asphalt concrete roadway per Standard Plan S-415.

74. California Boulevard and portion of Arroyo Parkway is a concrete street, restoration of any utility trenches shall be per Standard Plan S-417. All street restoration shall be completed prior to the issuance of Certificate of Occupancy.

75. The applicant shall demolish existing and construct the following public improvements along the subject development frontage of Arroyo Parkway and California Boulevard, including concrete drive approach per Standard S-403; concrete sidewalk per Standard Plan S-421; concrete curb and gutter per Standard S-406. The public improvements shall be completed prior to the issuance of Certificate of Occupancy.

76. The proposed development shall connect to the public sewer with one or more new six-inch diameter house sewers laid at a minimum slope of two percent. In accordance with PMC Chapter 13.24.010, house sewer “means that part of the horizontal piping beginning 24 inches from the exterior wall of the building or structure and extending to its connection with the public sewer.” The section of house sewers within the public right -of-way - from the property line to the public sewer, or within easement, shall be vitrified clay or cast iron pipe.

The house sewer shall meet City Standards as determined by the Department of Public Works, and a permit issued by the Department of Public Works is required fo r work within the public right-of-way. The construction of all new house sewers shall be completed prior to the issuance of Certificate of Occupancy.

77. The applicant is responsible for the design, preparation of plans and specifications, and construction of all required public improvements. Plans for the above improvements shall be prepared by a civil engineer, registered in the State of California. Upon submittal of

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improvement plans to the Departments of Public Works for review, the applicant will be required to submit fees, per the General Fee Schedule, to cover the cost of plan checking and construction inspection of the improvements. Note that building plans approved by the City’s Planning (Building) Department do not constitute approvals for work in the public right- of-way. Separate plans shall be submitted to the Department of Public Works – Engineering Division – at 175 North Garfield Avenue Window 6. The applicant shall submit public improvements plans and the plan check deposit at least two (2) months prior to the issuance of any building or demolition permits.

78. On-site drainage, such as roof drain, area drain and subterranean garage discharge, shall be contained on-site per LA County Regional Water Quality Control Board’s current permit.

79. The applicant shall plant one (1) Fern pine, Afrocarpus gracilior , tree along S. Arroyo Parkway frontage and one (1) Brisbane Box, Lophostemon confertus , tree along E.

California Boulevard frontage, the officially designated street tree per the City’s approved Master Street Tree Plan. The Department of Public Works will confirm eligible planting sites, and will provide the applicant the location, quantity.

80. Trees planted by the applicant must meet the City’s tree stock standards, be inspected by the City, and be planted according to the details provided by the Parks and Natural Resources (PNR) Division. Planting shall include the installation of the following per tree: no less than two tree stakes; one arbor guard; and the use of slow-release fertilizer tablets. The applicant shall contact PNR (626- 744-3880) for tree planting approval, a minimum of two (2) months, prior to the issuance of a Certificate of Occupancy.

81. Trees planted by the applicant must be irrigated by either an existing or a new irrigation system constructed by the applicant. Plans for the irrigation system shall be prepared by a landscape architect registered in the State of California and sub mitted to PNR for review and approval. Irrigation facilities (main line, valve, pull box, timer, etc.) must be constructed within private property with the exception of the laterals and bubblers. The lateral shall be a minimum of 18” deep, and no above-ground structures are allowed.

82. Prior to issuance of the Certificate of Occupancy, the applicant shall submit a Tree Guarantee Deposit equal to the cost of all new trees planted to guarantee that newly planted trees are maintained by the applicant for a minimum of three calendar years. Tree maintenance during this period shall include the following: watering no less than once a week; weed removal; reconstruction of tree wells as needed; re -staking as needed; adjustment to grade of any trees that settle; and any other operations needed to assure normal tree growth. The applicant shall replace any newly planted trees which, for any reason, die or whose health is compromised, within the applicant’s three-year establishment period. The three- year tree establishment period shall commence on the day that the Certificate of Occupancy is issued. PNR shall inspect all trees planted by the applicant at the end of the three -year establishment period, and if the trees are found to be in good health, the applicant’s deposit will be released. If the trees are found to be in poor health, the establishment period may be extended by PNR and the applicant’s deposit shall be held accordingly. Said deposit may be included as part of the construction guarantee if applicable, and is subject to partial refund or additional billing.

83. To protect existing City trees during construction, the applicant shall fully conformed to the Tree Protection Guidelines signed by the City Manager. The full guidelines is available at

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the following link: https://www.cityofpasadena.net/public-works/engineering-and- construction/engineering/.

84. Any existing street trees proposed to be removed are subject to the approval of the Urban Forestry Advisory Committee (UFAC).

85. A Tree Protection Zone (TPZ) shall be established for all existing City trees within the scope of a construction project. The TPZ extends from the base of the tree to four (4) radial feet beyond the dripline of a tree and applies to the entirety of the tree – from the roots to the canopy of the tree.

The applicant is prohibited from the following within a designated TPZ: construction vehicle access, construction vehicle operation, staging of materials, and trenching without the consent of the Department of Public Works.

The applicant shall at minimum provide the following within a designated TPZ: mulching, irrigation, and protective fencing.

86. Prior to the issuance of any permit, the applicant shall submit a Preliminary Tree Protection Plan (PMC Ch. 8.52 – City Trees and Tree Protection Ordinance), prepared by a Landscape Architect or certified Arborist, showing the TPZ and all structures, footings, and grading that may impact City trees shall be submitted to the Department of Public Works, for review and approval. Given that each construction project poses unique conditions, it is the responsibility of the applicant to develop a Tree Protection Plan based off the TPZ standards to the extent feasible. The Plan shall conform to the Tree Protection Standards which specifically require showing the locations of all existing trees, their diameters, canopies, whether the tree is a public tree or private tree, as well as any trees to be planted with their canopy at mature size. The final conditions of the Tree Protection Plan shall be approved by the Forestry Superintendent. A non -refundable flat fee, per the current General Fee Schedule, will be required for staff time to review the Tree Protection Ordinance compliance.

87. Prior to any construction, tree protections including the installation of fencing to protect public trees must be in place. The fencing material shall be chain- link attached to posts inserted into the ground at the edge of the dripline and shall be a minimum of 6’ in height.

See Standard Plan S- 642 – Tree Protection Chain Link Fencing. Fencing shall maintain visual lines of sight in order to avoid vehicle and pedestrian hazards. Fencing shall include a minimum 8.5” x 11” warning sign with the following information: ‘Tree Protection Zone’; name and contact information of project owner or authorized representative; ‘Please contact the City of Pasadena Citizen Service Center to report any concerns (626) 744- 7311’. All protective fencing must be permitted, inspected and approved by Public Works prior to the commencement of any construction.

88. All new drive approaches shall be at least seven (7) feet clear of the existing street trees measured from the edge of the trunk closest to the drive approach. All public trees shall be protected and fenced with a posting on the fences advising of the tree protection. The proposed 24-ft wide curb return driveway south of the existing Whole Foods building, as shown below, is exempt from this condition. The straight edge of the driveway will be 7’-2” from the edge of the existing tree, while end of the curb return is 4’-0” from the edge of the existing tree. The tree shall be protected by fencing per Standard S-642, and caution shall be exercised during construction of the driveway per Standard Plan S-402.

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89. Prior to issuance of any permit, the applicant shall submit a valuation assessment report of the existing public tree(s) along the boundary of their project. The report shall be prepared by a registered Arborist and submitted to PNR for review and approval. If it is determined that the applicant has failed to care for any City tree within their Tree Protection Plan, and the health of the tree(s) was critically compromised requiring its removal, the applicant shall be liable for the following costs: assessed value of tree determined by a PNR Arborist using a current ISA assessment methodology; the removal cost determined by PNR; and any applicable infraction or administrative fines determined by Code Compliance.

90. Prior to issuance of any permit, a deposit in the amount of the applicant’s total liabilities based on the aforementioned approved tree assessment report shall be submitted to the City. The deposit is fully refundable, less administrative fees, upon the satisfaction of Public Works prior to the issuance of a Certificate of Occupancy.

91. Past experience has indicated that projects such as this tend to damage the abutting street improvements with the heavy equipment and truck traffic that is necessary during construction. Additionally, the City has had difficulty in requiring developers to maintain a clean and safe site during the construction phase of development. Accordingly, the applicant shall place a $20,000 deposit with the Department of Public Works prior to the issuance of a building or grading permit. This deposit is subject to refund or additional billing, and is a guarantee that the applicant will keep the site clean and safe, and will make

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permanent repairs to the abutting street improvements that are damaged, including striping, slurry seal/resurfacing, curb, gutter, and sidewalk, either directly or indirectly, by the construction on this site. The deposit may be used for any charges resulting from damage to street trees. A processing fee will be charged against the deposit.

92. Prior to the start of construction or the issuance of any permits, the applicant shall submit a Construction Staging and Traffic Management Plan to the Department of Public Works for review and approval. The template for the Construction Staging and Traffic Management Plan can be obtained from the Department of Public Works webpage at:
https://www.cityofpasadena.net/public-works/engineering-and-construction/engineering/ .

A non-refundable flat fee, based on the current General Fee Schedule, is required for plan review and on-going monitoring during construction. This plan shall show the impact of the various construction stages on the public right -of-way (and the private street) including all street occupations, lane closures, detours, staging areas, and routes of construction vehicles entering and exiting the construction site. An occupancy permit shall be obtained from the department for the occupation of any traffic lane, parking lane, parkway, or any other public right-of-way. All lane closures shall be done in accordance with the Manual of Uniform Traffic Control Devices (MUTCD) and California Supplement. If the public right-of- way occupation requires a diagram that is not a part of the MUTCD or California Supplement, a separate traffic control plan must be submitted as part of the Construction Staging and Traffic Management Plan to the department for review and approval. No construction truck idling or staging, material storage, or construction trailer are allowed in the public right-of-way.

In addition, prior to the start of construction or issuance of any permits, the applicant shall conduct a field meeting with an inspector from the Department of Public Works for review and approval of construction staging, parking, delivery and storage of materials, final sign- off procedure, and any of the specifics that will affect the public right -of-way. An appointment can be arranged by calling 626-744-4195.

93. In preparation for the New Year Rose Parade and Rose Bowl Game, the Department of Public Works will suspend all works within the public right-of-way during the holiday season in accordance to PMC 12.24.100 and City Policy.

In general, all public streets, sidewalks and parkways shall be free and clear of excavations and other construction related activities during the period of November through January of the following year. Specific dates will vary on an annual basis. Accordingly, contractors will be required to shut down construction operations which would impede traffic and pedestrian movements during these periods unless otherwise authorized by the City Engineer. Any existing excavations shall be backfilled, compacted and temporarily repaved before the beginning of the moratorium period.

The Holiday Moratorium Map, showing the appropriate shutdown period, and corresponding areas in the City, is available at the Department of Public Works Permit Counter (window #6), 175 N. Garfield Avenue, Pasadena, CA 91109, or at the following link:
https://www.cityofpasadena.net/public-works/engineering-and-construction/engineering/ .

94. All costs associated with these conditions shall be the applicant’s responsibility. Unless otherwise noted in this memo, all costs are based on the General Fee Schedule that is in effect at the time these conditions are met. A processing fee w ill be charged against all

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deposits. A Public Works permit is required for all construction and occupancies in the public right-of-way. If construction vehicles and equipment are parked off-site in the public right of way, the permit fee for street and sidewalk occupancy will be based on the area and duration corresponding to the current City’s General Fee Schedule. For more information, please contact Yannie Wu-Bowman at 626-744-3762.

In addition to the above conditions, the requirements of the following ordinances will apply to the proposed project:

• Sewer Facility Charge - Chapter 4.53 of the PMC
The ordinance provides for the sewer facility charge to ensure that new development within the city limits pays its estimated cost for capacity upgrades to the city sewer system, and to ensure financial solvency as the city implements the operational and maintenance practices set forth in the city's master sewer plan generated by additional demand on the system.

Based on sewer deficiencies identified in the City’s Master Sewer Plan, the applicant may be subject to a Sewer Facility Charge to the City for the project’s fair share of the deficiencies. The Sewer Facility Charge is based on the Taxes, Fees and Charges Schedule and will be calculated and collected at the time of Building Permit Issuance.

• Sidewalk Ordinance - Chapter 12.04 of the Pasadena Municipal Code (PMC) In accordance with Section 12.04.035, entitled “Abandoned Driveways” of the PMC, the applicant shall close any unused drive approach with standard concrete curb, gutter and sidewalk. In addition, the applicant shall repair any existing or newly damaged curb, gutter and sidewalk along the subject frontage prior to the issuance of a Certificate of Occupancy in accordance with Section 12.04.031, entitled “Inspection required for Permit Clearance” of the PMC.

• City Trees and Tree Protection Ordinance - Chapter 8.52 of the PMC The ordinance provides for the protection of specific types of trees on private property as well as all trees on public property. No street trees in the public right -of-way shall be removed without the support of the Urban Forestry Advisory Committee. No trees shall be damaged by the proposed construction, if a City tree is damaged, the applicant may be liable for the assessed value of the tree. Refer to
https://www.cityofpasadena.net/public-
works/parks-and-natural-resources/urban-forestry/ f or guidelines and requirements for tree protection.

• Construction and Demolition Waste Ordinance, Chapter 8.62 of the PMC The applicant shall submit the following plan and form which can be obtained from the Permit Center’s webpage at: https://www.cityofpasadena.net/public-works/recycling- resources/construction-demolition-recycling/construction-and-demolition-debris-recycling/ and the Recycling Coordinator, (626) 744-7175, for approval prior to the request for a permit:

a. C & D Recycling & Waste Assessment Plan – Submit plan prior to issuance of the permit. A list of Construction and Demolition Recyclers is included on the waste management application plan form and it can also be obtained from the Recycling Coordinator.

b. Summary Report with documentation must be submitted prior to final inspection.

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A security performance deposit of three percent of the total valuation of the project or $30,000, whichever is less, is due prior to permit issuance. For Demolition Only projects, the security deposit is $1 per square foot or $30,000, whichever is less. This deposit is fully refundable upon compliance with Chapter 8.62 of the PMC. A non- refundable Administrative Review fee is also due prior to permit issuance and the amount is based upon the type of project.

Department of Transportation

95. As a project adjacent to the Metro L line tracks, and an active at -grade light rail transit crossing, the project applicant will meet and confer with Metro regarding construction and coordination prior to the commencement of construction and shall continue through completion of construction.

96. In accordance with City Ordinance No. 7157, the project is subject to the City’s Trip Reduction Ordinance (TRO) requirements. As indicated in the ordinance, a Transportation Demand Management (TDM) Plan shall be prepared prior to the issuance of the first permit for construction.

To understand the TDM Plan requirements and associated review fees* for the report submittal, contact the Mobility, Planning, Operations and Engineering Division at (626) 744- 7526 to arrange a pre-design meeting.

* Based on the Current General Fee Schedule. Fees are subject to change.

97. The project traffic exceeds the street segment thresholds at the following locations:

• Marengo Avenue between Bellevue Drive and California Boulevard • Bellevue Drive between Arroyo Parkway and Marengo Avenue

DOT acknowledges that the project’s effects to the street segments will remain.

The applicant is required to develop and implement a targeted Complete Streets Plan with input from the affected residents, Council Districts, and DOT. There shall be a minimum of three (3) meetings with the community. The goals of the Plan include:

• Encouraging the use of non-vehicular transportation modes by the project’s patrons and residents.
• Developing feasible safety enhancements to encourage non-motorized use for travel. • Enhancing motorist safety through striping, signage, and physical improvements.

Public meetings shall be completed, and the Complete Streets Plan shall be submitted to DOT prior to the issuance of the Certificate of Occupancy for Building B. The referenced final Complete Streets Plan must be approved by DOT and any improvements must be implemented, or bonded for, prior to the issuance of the Certificate of Occupancy for Building A.

***The above condition does not apply if the project exchange is the chosen option for construction.

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98. The following equipment shall be installed at the designated locations:

• CCTV at the Arroyo Parkway and Bellevue Drive intersection • CCTV at the Raymond Avenue at California Boulevard intersection • Video data collection and performance m onitoring system at the Arroyo Parkway at Bellevue Drive intersection
• Video data collection and performance monitoring system at the Arroyo Parkway at California Boulevard intersection
• Video data collection and performance monitoring system at Raymond Avenue and California Boulevard intersection

The equipment shall be installed prior to the issuance of the Certificate of Occupancy.

Please contact the Traffic Operations Division at (626) 744 -8723 to arrange a pre- design meeting to understand the requirements for the project.

***The requirement to install video data collection equipment above does not apply if the project exchange is the chosen option, but the CCTVs at the intersections of Arroyo Parkway/Bellevue Drive and Raymond Avenue/California Boulevard are still required under the project exchange option.

99. Pursuant to the adopted Street Design Guide by the City Council, the applicant shall comply with the following:

• The existing sidewalk along Arroyo Parkway is 10' wide. The project shall provide a 3’ sidewalk easement to allow for a 13' wide concrete sidewalk that will begin south of the existing historic commercial building to be retained at 523 South Arroyo Parkway to California Boulevard. Up to six columns may encroach up to 3’ into the sidewalk easement, spaced a minimum of 20' apart. Any and all subsurface shoring, structure, parking or other required mechanical, electrical spaces may encroach to the existing property line. The remainder of the existing sidewalk along Arroyo Parkway shall remain 10’ wide.
• The existing sidewalk along California Boulevard is 10’ wide. The project shall provide a 2’ sidewalk easement to allow for a 12’ wide concrete sidewalk along the project’s frontage. Any and all subsurface shoring, structure, parking or other required mechanical, electrical spaces may encroach to the existing property line.

100. The site will have medical offices and senior housing elements. Both types of use are served regularly by Pasadena Dial-A-Ride and other accessible type shuttles. The property on-site shall accommodate the convenient, safe and accessible pick-up and drop-off of accessible type shuttles that are up to 25’ long, 8’ wide and 10’ tall. The turning radius wall to wall is 60’. This shall be the case even if the senior housing is considering having their own shuttle.

Please contact the Transit Division at (626) 744- 4055 to arrange a pre- design meeting to understand the requirements for the project.

101. All existing bus zones and transit amenities shall remain in place and protected duri ng construction. The existing bus zone will not be relocated without prior written approval from the Transit Division. Tree wells, street lights, fire hydrants and other items shall not be placed in the public right of way within bus zone(s) without prior approval. The proposed project

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shall not interfere with bus operations (this includes, but is not limited to, building overhangs, awnings, landscaping, etc.)

102. There is an existing active bus stop adjacent to the proposed California Boulevard driveway.

Additionally, the project is immediately adjacent to the existing Metro L line tracks. The development shall not interfere with any transit activity during and after construction without written permission on file by the appropriate transit agencies that may be affected.

103. Construction-related traffic (delivery trucks or haul trucks) shall be restricted to the hours between 9:00 AM to 3:00 PM, or as approved by the Department of Transportation, to limit the peak hour traffic conflict along the local street network.

104. Any project loading/unloading spaces shall be on- site. DOT will not install a loading zone for project use along the project’s street frontages.

105. The developer should provide the required vehicle and bicycle parking spaces required for the project as directed by the Planning Department.

106. All required parking shall be on-site. No permanent, on-street, overnight parking permits will be issued to future residents of this project. Future tenants shall be advised of this condition by the private development staff.

107. If a gate to the parking area is proposed, it shall be installed at least 40’ back from the property line to allow for adequate stacking for cars entering the parking garage.

108. Driveways should be a minimum 20’ wide to provide for adequate passing of two-way traffic.

109. Driveways shall be located a minimum distance of 50’ from any intersection and approved by the Department of Transportation prior to the issuance of the first permit for construction (demolition, grading, or building).

110. To improve the safety of pedestrians crossing the driveways as well as improve vehicular sight distance, there shall be a slope of 2% or less for a minimum of 20’ feet beyond the property line before the start of the subterranean ramp.

111. The project shall pay the Traffic Reduction and Transportation Improvement Fee (TR -TIF) for the project at the time of building permit issuance. The TR-TIF is subject to change based on the General Fee Schedule at the time of permit issuance. Total payment would be based on the final project scope.

Pasadena Water and Power – Power

Pasadena Water & Power (PWP), Power Delivery shall provide electric service to the proposed development contingent upon satisfying all the requirements listed below:

112. Power Infrastructure:
• There are existing 17KV underground distribution facilities in close proximity (located along Arroyo Pkwy) of the proposed project location.

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• Existing conduit infrastructure may be re- used if the size, number of conduits, and location coincides with new location of transformer vault. (contingent upon PWP approval).
• Extension the underground conduit infrastructure to the property line to feed the proposed development will be at the expense of the developer. • Underground distribution system upgrades may be re quired to accommodate large electrical services. System upgrades that are triggered by the development will be at the expense of the developer.
• Proposed power feed point for new electrical service is indicated below (street vault V3282).

113. Existing Electrical Services:
• PWP records indicate a private property transformer vault V6995 and six underground services within the proposed development area.
• Developer shall notify PWP of any underground electrical conduits, transformer vaults, or overhead lines in conflict with construction.
• Developer shall submit a demo request to de-energize existing services prior to start of construction.
• A single existing electrical service may be utilized as temporary power for construction should it meet the needs of the developer (contingent upon PWP approval).

114. Easements: A utility easement shall be required if the new electrical service crosses or feeds multiple parcels.

115. Power Delivery Requirements:
• Owner/developer shall install subterranean private property transformer vault room within development area close to the street and in close proximity to PWP underground distribution facilities.
• Owner/developer shall install an electrical room that is adjacent (sharing a wall) with the transformer room for a bus duct type installation.
• Multiple transformer vaults or rooms may be required. The size and number of transformer vaults shall be determined by PWP based on the size of electrical service.

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• Transformer vault/room shall have an access hatch from above (open to sky) for equipment installation purposes and drivable PWP truck access. • Transformer room(s) located within a building structure shall be rated for 4 -hour fire separation and meet all local Building & Fire Department requirements related to room ventilation and alarming.
• Owner/developer shall be responsible for installing lighting, receptacles, ground rods, and air blowers inside transformer vault/room.
• Owner/developer shall be responsible for installing vent pipes from transformer vault/room to open air for proper air circulation.
• Owner/developer shall be responsible for the maintenance of the transformer vault, and allow access to the transformer room at all times to Department personnel and vehicles in accordance with the Department Electric Service Requirements Regulation 21. • PWP shall install primary service laterals from the street vault to the property line (if necessary) at the developer’s expense.
• Owner/developer shall be responsible for picking up and extending primary service laterals from the property line to the transformer vault/room. • Owner/developer shall install secondary service conduits from transformer vault/room to electrical room.
• PWP shall install electrical service transformers, cables, and electric meters. • All PWP installation costs shall be paid by the developer prior to scheduling of any work.

116. D istributed Generation: Owner/developer installed distributed generation resources that will be interconnected to the Pasadena Electric Distribution System shall be installed in accordance with the Department Distributed Generation Interconnection Requirements Regulation 23. In addition, all customer installed solar photovoltaic (PV) resources shall meet all of the requirements of local building codes, Fire Department and the Pasadena Solar Initiative Program.

117. Coordination of Electric Service:
a. In order to determine the specific requirements of the electrical service for this project and to begin the coordination of service, the following items will need to be included in the submittal:
• Electric Service Application
• Electrical Plans (single-line diagram, load calculations). • Site plan & elevation plan showing proposed transformer vault/room location & electrical switchgear/meter location.
• $5,000.00 Deposit

b. Total cost for providing electric service to this development will depend on service size and the extent of civil work required in the public right of way. A cost shall be provided to the owner/developer after the submittal is received and a PWP power design is finalized.

Pasadena Water and Power – Water

118. Any change in water service will be reviewed when the building plans are submitted. Any change in service will be installed at actual cost and paid for by the owner/developer, pursuant to PWP Water Regulation Section XI. All service pipes shall be of suitable capacity

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as determined by applicable plumbing and fire codes. The minimum sized service installed by PWP is 1-inch.

119. Water Main Charge: If it is determined that a water main must be upgraded due to size, age, pressure deficiencies, and/or the integrity of the existing water main; the upgrade will be paid for by the owner/developer. A deposit will be requested for the water main design and a cost estimate will be provided to the owner/developer for the new water servic e installations, main design, and main construction. The owner/developer must be aware that the design of a new water main will take 3 to 4 months after the initial deposit is made by the owner/developer. Also, an additional 4 to 6 months will be needed for the construction of the water main after the balance of the estimate is paid in full by the owner/developer.

The design and construction estimated time depends on the size and length of the water main and other mains in the queue. For this reason, it is imperative that the initial deposit be submitted promptly. Also, the owner/developer will pay in full any street restoration that is required by PWD. PWD determines the limits of the street restoration.

120. Water Division Requirements:
• Water lines are not permitted to cross lot lines to serve adjoining lots without a utility easement; the Pasadena Water Division shall approve all proposed easements. • The Water Division will install the service tap, lateral, water meter and designate the distribution main and service tap.
• All services not in use must be abandoned at the distribution main at the applicable rate. • For subdivided lots with one unit behind the existing, show easement documentation and assessor parcel map showing the subdivision.

121. Cross Connection Requirements for Domestic Services:
• All city cross -connection prevention policies must be adhered to. The developer is required to provide back -flow protection at all connections whereby the plan arrangement or configuration could potentially contaminate the domestic water system. • There shall be no taps between the meter and the backflow assembly. • The owner/developer shall provide and install an approved double check valve backflow prevention assembly at each water service if more than one water ser vice serves property. The location of the back -flow prevention assembly shall be above ground within 20-feet of the property line.
• The property owner is responsible for the back-flow prevention assembly. The assembly will be registered and require an annual test certification. All manufacturer warranties shall be transferred upon installation and certification to the property owner. • The owner/developer is responsible for certifying and testing the assembly after installation by a person that possesses a current and valid license, and must be certified by the County of Los Angeles Department of Health Services. • The owner/developer shall submit the results of the test to the Water Utility Service Section for approval. Upon approval, the City will maintain domestic water to the property and will automatically register the assembly.
• All water services shall be protected from cross connections by means of approved backflow prevention techniques and assemblies.
• An administrative fee of $180.94 will be charged for each backflow prevention assembly installed.

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122. Cross Connection Requirements for Fire Service:
• The fire service requires a detector meter and back-flow prevention assembly. • The assembly shall be located in a readily accessible location for meter reading, test and maintenance.
• All fire sprinkler systems require installation of an approved double check valve backflow prevention assembly at the sprinkler lateral off the domestic system. • Contract service other than PWP, providing the backflow prevention assembly shall contact the Water Utility Services Section to verify assembly approval or contact the University of Southern California foundation for Cross Connection Control and Hydraulic Research for an approve list of assemblies.
• All manufacturer warranties shall be transferred upon installation and certification to the property owner. The property owner shall assume ownership of the back -flow prevention assembly. The assembly will be registered and require an annual test certification.
• If PWP is to provide DCDA for fire service, PWP will install Wilkins, model 450 DA. • Choose from one of the below listed options and incorporate into the fire sprinkler plans.

Option 1:

Detector meter located on double check detector check assembly (DCDA) outside the structure on private property.
• The Water Division will install the service tap, lateral, DCDA (optional Wilkins, models 350 DA or 450 DA) and designate the distribution main and service tap. • The location of the back -flow prevention assembly shall be a minimum of 12 -inches above grade within 10- feet of the property line, on private property. Reference Water Division Plan Check for certification and registration.

Option 2:

Detector meter located in a vault within the public right of way with a double check valve backflow prevention assembly (DCA) provided and installed inside or outside the building by the owner/developer.
• The Water Division will install the service tap, lateral, detector water meter and designate the distribution main and service tap.
• The location of the back -flow prevention assembly shall be a minimum of 12 -inches above grade within 20- feet of the property line on private property. Reference Water Division Plan Check for certification and registration.

123. All Other Cross Connection Requirements: The owner/developer is also responsible for additional cross connection requirements for irrigation system, swimming pool and/or spa, boiler / chilled water / cooling tower (using chemical additives), domestic water line at makeup to carbonation system, sewage ejector, decorative water fountain, and makeup water to reverse osmosis filtration equipment.

124. Residential Water Metering Requirements:

Senate Bill No. 7 (Housing: water meter: multiunit structures) approved by the Governor September 25, 2016, requires that individual meters or submeters be installed on all new multifamily residential units. Per Senate Bill No. 7: Each water purveyor that sells, leases, rents, furnishes, or delivers water service to a newly constructed multiunit residential structure or newly constructed mixed-use residential and commercial structure for which an application for a water connection, or more than one connection, is submitted after January

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1, 2018, shall require a measurement of the quantity of water supplied to each individual residential dwelling unit as a condition of new water service. The law exempts long- term health care facilities, low -income housing, residential care facilities, housing at a place of education, and time- share properties, as well as, other multiunit residential structures deemed infeasible by the Department of Housing and Community Development.

Per the Water Regulations adopted by City Council on June 4, 2012: “The water service will end at the curb, public right of way or property line at the option of PWP. Where the location of the meter box or vault on the City side of the property line is not practicable, the meter box or vault shall be located on the Customer’s premises or such other location that may be agreed upon by PWP at its option. The Customer shall be responsible for the expense of installation and maintenance of the lines on the Customer’s side of the property line connecting to PWP’s service where construction of the Customer’s facilities began.”

The following submetering options are available for PWP customers:

Option 1:

Individual metering located on the parkway.

The Water Division will install individual water meters on the parkway in front of the project site, if permitted by available space as per the General Requirements, for each residential unit. The owner/developer shall install an approved double check valve backflow prevention assembly at each domestic water service. All dedicated irrigation services must have a Reduced Pressure Zone Valve Assembly (“RP”). The location of the backflow prevention assemblies shall be above ground within 20- feet of the property line, and the assemblies require registration and annual test certifications. PWP’s responsibility of service ends at the meter and PWP will bill each tenant directly.

Option 2:

Individual metering located on private property.

The Water Division will install a service lateral up to the property line with a shut off valve.

The owner/developer shall provide and install an approved double check valve backflow prevention assembly after the shut off valve and will install all piping behind the property line. The location of the backflow prevention assembly shall be above ground within 20-feet of the property line, and the assembly requires registration and an annual test certification.

The owner/developer will pay for and install all water meters, provided by PWP, to each residential unit. Water meters must be installed horizontally and must be located in an open area or in a garage/parking area and must have a minimum 12 -inch above grade in order for meter readers to have unrestricted access to them if needed. All dedicated irrigation services must have a RP. PWP will inspect the individual meters as a condition of providing service. PWP’s responsibility of service ends at the property line and PWP will bill each tenant directly.

Option 3:

Submetering by third party vendor located on private property.

The Water Division will install master water meter(s) on the parkway, in front of the project site. The owner/developer must submit a statement on letterhead stating that a Contractor licensed by the California State License Board will install submeters, per Senate Bill No. 7, to all residential units. The owner/developer shall install an approved double check valve backflow prevention assembly on each submeter. All dedicated irrigation services must

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have a RP. The backflow prevention assemblies require registration and annual test certifications. PWP will inspect the submeters as a condition of providing service. PWP’s responsibility of service ends at the master meter and the owner/developer is responsible for billing each tenant per Senate Bill No. 7.

125. Fire Flow and Fire Hydrants:

The Pasadena Fire Department (PFD) has jurisdiction and establishes the requirements for fire protection within the City of Pasadena. PFD must be consulted in this regard. Any cost incidental to providing adequate fire protection for the project must be paid for by the owner/developer.

There are seven fire hydrants in close proximity to the project site:
• Fire hydrant 418-16 is located on the southwest corner of Arroyo Parkway and Bellevue Drive.
• Fire hydrant 418 -31 is located on the east curb of Arroyo Parkway, approximately 80 feet south of Bellevue Drive.
• Fire hydrant 418-22 is located on the east curb of Arroyo Parkway, approximately 350 feet south of Bellevue Drive.
• Fire hydrant 418-14 is located on the west curb of Arroyo Parkway, approximately 370 feet south of Bellevue Drive.
• Fire hydrant 418-32 is located on the east curb of Arroyo Parkway, approximately 200 feet north of California Boulevard.
• Fire hydrant 419-38 is located on the northeast corner of Arroyo Parkway and California Boulevard.
• Fire hydrant 419-18 is located on the southwest corner of Arroyo Parkway and California Boulevard.

There are no current fire flow tests available for these hydrants. If you would like to request a fire flow test, please contact Linette Vasquez at (626) 744-7064.

Fire Hydrant Details:

ATTACHMENT C

PRELIMINARY CONSULTATION COMMENTS

P L A N N I N G & C O M M U N I T Y D E V E L O P M E N T D E P A R T M E N T

PLANNING DIVISION

May 26, 2021

The Arroyo Parkway, LLC
716 Mission Street
South Pasadena, CA 91030

Via email: [email protected]

NOTICE OF DESIGN COMMISSION COMMENTS
Application for Preliminary Consultation
465-577 S. Arroyo Parkway (CD-6 Zoning District)
Case #: DHP2021-00040 Council District 6

Dear Applicant,

On May 25, 2021, at a virtually held public meeting, the Design Commission, acting under the provisions of Section 17.61.030 of the Pasadena Municipal Code, reviewed your application for Preliminary Consultation for the proposed demolition of 6 existing buildings, preservation of 3 existing historic buildings and construction of a new approximately 154,000 sf medical office building and an approximately 184,376 sf assisted & independent living building at the above- referenced addresses. The design guidelines applied to this review were the design-related goals and policies in the Land Use Element of the General Plan, the design guidelines in the Central District Specific Plan, and the Secretary of the Interior’s Standards for Rehabilitation.

The Commission generally agreed with the comments in the staff report, which are reiterated below, and provided additional comments on the preliminary design, also listed below:

1. The proposed buildings are substantially higher than existing surrounding development and also exceed the height limit for new development along Arroyo Parkway. While the current design appropriately places lower-scaled volumes at the street edge with taller volumes behind, and incorporates strategies to provide lower volumes and open access points adjacent to the historic buildings to be retained, the height and massing of the buildings should continue to be studied to incorporate street-edge volumes that comply with the height limit of the Zoning District, as well as additional lower-height volumes north of the historic buildings. Consider placing building volumes over portions of the central vehicular access driveway and drop-off zone, particularly toward the western side of the site, to allow for creation of additional massing articulation without significant reduction in proposed floor area. Additional lower-scaled volumes could be placed adjacent to the historic buildings to further complete the streetscape and site; the small two-story volume behind the buildings could be slightly increased in height to create a more evident height transition from the historic buildings to the taller volumes to the west. If Fire Department access is a constraint on the site, demonstrate this in future submittals.

The Arroyo Parkway, LLC
465-577 S. Arroyo Parkway (DHP2021-00040)

2. Continue to explore ways that the different buildings and uses on the site interact with and relate to each other, both functionally and architecturally, including the existing historic buildings and the Whole Foods Market. In future submittals, provide exhibits to demonstrate how the design features of the new buildings relate proportionally to those of the historic buildings to be retained. Further study creation of a base element that relates better to the smaller scale historic buildings and ensures they are not overwhelmed by the larger scale of the proposed new construction.

3. Incorporate additional entrances to the commercial space and medical office building lobby from Arroyo Parkway and California Boulevard. Provide architectural frontage elements and other architectural treatments to highlight the main building entries; consider incorporating an arcade at the street corner. Further define the proposed uses of the historic buildings and ensure that they maintain visual and functional engagement with the public realm. The middle portion of the block should be further activated.

4. Provide a pedestrian circulation plan that outlines the intended paths of travel for the various users of the site and ensure that the buildings, open spaces and vertical circulation points are integrated with public and private pedestrian pathways that are meaningful, comfortable and inviting. Provide additional detail of the design and orientation of stairs and elevators that terminate in outdoor locations adjoining the public realm, or consider removing/relocating these circulation points to better integrate them into the design of the buildings.

5. Further define the programming of open spaces and ground-level plazas and ensure that design features to support the intended uses of these spaces are incorporated into the design. The interior of the site feels crowded and the spaces between buildings are undefined. The massing of the two buildings should be completed/connected on the west side to enclose the open space and the gap between the medical office building and the historic building north of it should be narrowed. Consider placing drop-off zones underground. In general, the pedestrian scale of the project along the street edges should be improved.

6. Further study the treatment of rooflines and parapets in conjunction with the Central District design guidelines. Ensure that the tops of the buildings are articulated from the middle portions below and are visually attractive, sculptural and detailed in a manner consistent with the design of the buildings.

7. The historic buildings to be retained should be carefully reviewed by a qualified Historic Architect to identify rehabilitation treatments to be implemented in conjunction with the proposed project. Any structural or exterior cosmetic damage that is identified should be repaired and any missing or altered exterior features restored in conjunction with the project. Provide a rehabilitation plan for the buildings in future design review submittals.

8. Explore the ideas of wellness and inclusivity for seniors that will be occupying the site.

Search for ways to create greater synergy and connections between the uses on the site.

The Arroyo Parkway, LLC
465-577 S. Arroyo Parkway (DHP2021-00040)

NEXT STEPS

This completes the Preliminary Consultation process. As your project moves forward to Concept Design Review, the new building designs should endeavor to address and respond, in writing and/or graphically, to the comments above. If the comments are not satisfactorily addressed, revisions to the submitted plans may be required and the approval process for your project may be delayed.

Please contact me if you have any questions about this letter.

Sincerely,

Kevin Johnson
Senior Planner
Design and Historic Preservation Section
Tel: 626-744-7806
Email: [email protected]

cc: Energov; Address file

ATTACHMENT D

DRAFT PD PLAN

PD – 39 – The Affinity

Planned Development 39 – The Affinity shall comply with Pasadena Municipal Code Chapter

17.30 Central District Specific Plan and the Central District Specific Plan Design Guidelines. The following zoning standards shall apply and supersede any inconsistent or different standards established by the Pasadena Municipal Code, Central District Specific Plan and the Central District Specific Plan Design Guidelines, but only for the development plan referred to in Section [x] of Ordinance [xx]. The special development standards are as follows:

A. Development Program. The PD-39 Development Plan includes Area 1 and Area 2 as shown in Figure 1.

B. Allowed Uses. Table I (Land Use and Permit Requirements) identifies the land uses allowed and the land use permit required to establish each use, in compliance with applicable sections of Title 17 of the Pasadena Municipal Code as specified.

Symbol Permit Requirement Procedure is
in Section:

P Permitted use, Code Compliance Certificate required 17.61.020 MC Conditional use, Minor Conditional Use Permit required 17.61.050 C Conditional use, Conditional Use Permit required 17.61.050 E Conditional use, Expressive Use Permit required 17.61.060 TUP Temporary Use, Temporary Use Permit required 17.61.040 — Use not allowed. (See Section 17.21.030.A regarding uses not listed.)

Standards for specific land uses. Where the last column in the tables (“Specific Use Standards”) includes a section number, the regulations in the referenced section apply to the use in addition to all other applicable provisions of this Zoning Code.

Table I
Land Use and Permit Requirements Area 1 Area 2 Specific Use Standards

RESIDENTIAL USES
Boarding houses -- P
Caretakers quarters -- P
Dormitories C C
Fraternity/sorority housing -- C
Home occupations P P 17.50.110
Mixed-use projects P(1) P 17.50.160
Multi-family housing/urban housing P(1) P 17.50.350
Residential accessory uses and
structures P P 17.50.210, 17.50.250
Residential care facilities, general P C
Residential care facilities, limited -- P
Single-room occupancy -- P 17.50.300
Supportive housing -- P
Transitional housing -- P

RECREATION, EDUCATION & PUBLIC ASSEMBLY USES
Clubs, lodges, private meeting halls -- C
Colleges – traditional campus
setting -- C
Colleges – nontraditional campus
setting -- P
Commercial entertainment* E E(2) 17.50.130
Commercial recreation – indoor* C C 17.50.130
Commercial recreation – outdoor -- C(2) 17.50.130
Conference centers -- C(2)
Cultural institutions* P P(2)
Electronic game centers -- C(2) 17.50.100
Internet access studios -- C(2) 17.50.100
Park and recreation facilities -- C
Religious facilities -- MC 17.50.230
with columbarium -- MC 17.50.230
with temporary homeless
shelter -- MC 17.50.230
Schools – public and private C C 17.50.270
Schools – specialized education and
training -- P(2)
Street fairs -- P
Tents P P 17.50.320

OFFICE, PROFESSIONAL & BUSINESS SUPPORT USES
Automated teller machines (ATM)* P P 17.50.060
Banks, financial services* P P(2)
with walk up services* P P(2) 17.50.060
Business support services P P(2)
Offices - accessory P P
Offices - administrative business
professional P P(2)
Offices - government P P(2)
Offices - medical P P(2)
Research and development -
Offices P P(2) 17.50.240
Work/live units -- P(2) 17.50.370

RETAIL SALES USES
Alcohol sales - beer and wine C C 17.50.040
Alcohol sales - full alcohol sales C C 17.50.040
Animal services - retail sales* P P(2)
Bars or taverns* C C(2) 17.50.040
with live entertainment* C C(2) 17.50.130
Commercial nurseries -- P(2)
Convenience stores* C C
Food sales P P(2)
Internet vehicle sales -- P(2)
Liquor stores* C C(2)
Pawnshops* -- C(2) 17.50.200
Restaurants* P P(2) 17.50.260
Restaurants, fast food* P P(2) 17.50.260
Restaurants, formula fast food* P P(2) 17.50.260
Restaurants with limited live
entertainment* P P(2)
Restaurants with walk-up window* C C 17.50.260
Retail sales* P P(2)
Seasonal merchandise sales P P 17.50.180
Significant tobacco retailers* C C(2) 17.50.330
Swap meets -- C(2)
Temporary uses TUP TUP
Vehicle services – automobile rental -- C(2)
Vehicle services - sales and leasing
- limited* MC MC

SERVICES
Adult day-care, general P C
Adult day-care, limited -- P
Ambulance services P P(2)
Animal services – boarding C C(2)
Animal services – grooming P P(2)
Animal services – hospitals -- P(2) 17.50.050
Animal shelters -- C
Catering services P P(2)
Charitable institutions C C
Child day-care centers P P 17.50.080
Child day-care, large care homes,
9 to 14 persons -- P 17.50.080
Child day-care, small care homes,
1 to 8 persons -- P
Detention facilities -- C
Emergency shelters -- MC
Emergency shelters, limited -- P 17.50.105
Filming, long term C C
Filming, short term P P
Laboratories P P(2)
Life/care facilitiesa P C
Lodging – bed and breakfast inns -- P(2) 17.50.140
Lodging – hotels, motels -- C (2) 17.50.150
Maintenance or repair services P P(2)
Massage establishments -- C(2) 17.50.155
Medical Services – Extended Care P --
Medical Services – Hospital C C
Mortuaries, funeral homes -- C(2)
Personal Improvement Services* P P(2)
Personal Services* P P(2)
Personal services restricted -- C(2) 17.50.200
Printing and publishing* P P(2)
Printing and publishing, limited* P P
Public safety facilities -- C
Vehicle services - washing and
detailing, small-scale P P 17.50.290
Vehicle services – washing and
detailing, temporary -- P 17.50.290

INDUSTRY, MANUFACTURING AND PROCESSING USES
Alcohol beverage manufacturing -- C(2) 17.50.040
with accessory tasting room -- C(2) 17.50.040
Custom manufacturing/artisan
production -- P
Industry, restricted -- C(2)
Industry, restricted, small scale -- P
Industry, standard -- C(2)
Recycling – small collection facilities -- C 17.50.220
Research and development - Non-
Office P P(2) 17.50.240

TRANSPORTATION, COMMUNICATIONS, AND UTILITY USES
Accessory antenna array P P
Alternative fuel/recharging facilities -- C
Communications facility -- P(2)
Commercial off-street parking -- MC
Transit terminal -- C
Utility, major -- P
Utility, minor P P
Wireless telecommunication
facilities, co-located (SCL) P P 17.50.310
Wireless telecommunication
facilities, minor MC MC 17.50.310
*Pedestrian-oriented uses
aA life/care facility is an integrated facility that provides accommodations for, and varying level of care to, residents depending on need. The use shall contain the following components:
independent living units, assisted living, residential care facilities, and continuing care facilities.

The use may include but is not required to include skilled nursing, Alzheimer and related facilities.
(1) Allowed only as part of the Land Use Exchange, per Section D below. (2) Conditional Use Permit approval required for new construction exceeding 25,000 sq. ft. See Section 17.61.050.J for additional requirements.

C. Development Caps. Maximum development capacity is provided in Table II.

Table II
Development Caps Area 1 Area 2 Buildout
Gross Floor Area
(sf) 344,258a 73,671 417,929
Dwelling Units 289b - 289
a Up to 98,576 square feet of floor area may include independent living units. b Up to 95 dwelling units may be provided as independent living units.

D. Land Use Exchange. Up to 151,000 square feet of floor area in Area 1 may be devoted to multifamily residential dwelling units with up to a maximum of 3,000 square feet, on the ground floor, devoted to commercial uses. Residential amenities, including but not limited to a leasing office, gym, kitchen, conference, etc., shall not be counted against the maximum commercial square feet.

E. Development Standards

1. New Construction. Area 1 shall not exceed a maximum of 338,376 gross square feet of new construction. Inclusive of Area 1 and Area 2, the total Development Program shall not exceed 417,929 gross square feet.

2. Floor Area Ratio (FAR). The Development Program shall not exceed a maximum FAR of 2.89.

3. Density. The Development Program shall not exceed a maximum residential density of 87 dwelling units per acre.

4. Dwelling Units. The Development Program shall not exceed an aggregate of 289 dwelling units. Notwithstanding any other provision of the Pasadena Munici pal Code, r esidential uses and units shall be permitted on the ground floor.

5. Setbacks.
a. Bellevue Drive. A zero-foot minimum.
b. Arroyo Parkway. A zero-foot minimum.
c. California Boulevard. A zero-foot minimum.
d. Interior. A zero-foot minimum.

6. Building Height. Maximum building height shall be as set forth in Table III below. The height of each structure shall be measured from the lowest elevation of the existing grade at an exterior wall of the structure to the highest point of the structure , as defined in Pasadena Municipal Code Section 17. 40.060, Height Requirements and Exceptions .

Building appurtenances shall comply with Pasadena Municipal Code Section

17.40.060(D).

Table III
Maximum Building Height

Maximum Height
Area 1.A 93’6”
Area 1.B 50’ (65’)
Area 2 50’ (65’)

7. Parking. Every new use, including a change or expansion of a use shall maintain off - street parking in compliance with requirements in Pasadena Municipal Code Chapter

17.46 and Section 17.50.340 as applicable. Notwithstanding these requiremen ts and Table 4-6, required parking for independent living units in a life/care facility shall be the same as required parking for multi -family residential units, and required parking for assisted living units in a life/care facility shall be 0.5 spaces per unit, and one guest parking space for every 10 units (sum of independent and assisted living) shall be required. The following types of parking shall also be allowed:
a. Valet Parking. Valet parking on private property shall be allowed. b. Tandem & Triple Stack Parking. Notwithstanding Pasadena Municipal Code Section

17.46.080, tandem and triple stack parking shall be allowed for all uses. In the event that tandem or triple stack parking is provided for uses other than multi -family residential, independent living units, or commercial uses where the parking spaces are managed by individual building tenants or a third party, a parking attendant shall be on duty at all times the parking facility is available for tandem or triple stack parking by such uses. Tandem spaces shall be no less than nine feet wide by 34 feet deep. Triple stack spaces shall be no less than nine feet wide by 51 feet deep. Automated parking car lifts shall not be subject to these stall dimensions. c. Compact Parking. Notwithstanding Pasadena Municipal Code Section 17.46.090, compact parking spaces shall be permitted for up to 30 percent of the total provided parking stalls. Compact parking spaces shall be at least 15 feet long and 7 feet 6 inches wide.
d. Automated Parking. Automated parking, defined as vehicular storage and retrieval within a parking facility that is accomplished entirely using a mechanical conveyance system and/or computerized parking system to hoist individual vehicles from receiving areas to separate storage areas without requiring an attendant to maneuver a vehicle that is to be parked, shall be permitted for all provided parking. If automated parking is provided, automated parking storage areas may include compact parking spaces.

8. Residential Open Space. If residential units are developed in Area 1 per Section D, a minimum of 140 square feet of open or community space per residential dwelling unit shall be required. Private open space shall not exceed 60 percent of the total requirement for community space, notwithstanding Sections 17.50.160 and 17.50.350 or any other section of the Zoning Code.

9. Design Review. New construction shall be subject to Design Review as required by Pasadena Municipal Code Section 17.61.030 Design Review.

10. Public Art. New construction shall comply with the Public Art Design Standards of Pasadena Municipal Code Section 17.40.100 Public Art Requirements and Design Standards.

11. Signage. A master sign plan shall be prepared in accordance with Pasadena Municipal Code Chapter 17.48.

ATTACHMENT E

FINAL EIR AND ERRATA

https://www.cityofpasadena.net/planning/planned-development-39-affinity-project/

ATTACHMENT F

DRAFT FINDINGS OF FACT

Findings of Fact
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
May 2022

Affinity Project Final EIR
Findings of Fact

i Table of Contents

TABLE OF CONTENTS
Section Page
Section 1.0  Introduction ......................................................................................................... 1

1.1  Requirement For Findings of Fact ............................................................. 1

1.2  Project Summary ....................................................................................... 2

1.3  Finding Regarding Certification of the EIR ................................................ 3

1.4  Finding Regarding Adoption of Mitigation Monitoring and Reporting Program ..................................................................................................... 3

1.5  Finding Regarding Custodian of Records .................................................. 4 Section 2.0  Findings Regarding Environmental Issues not Analyzed in the EIR .............. 5 Section 3.0  Findings Regarding Impacts Determined to be Less Than Significant without Mitigation ................................................................................................ 6

3.1  Air Quality (Section 3.1 of the EIR) ............................................................ 6

3.2  Cultural and Paleontological Resources (Section 3.2 of the EIR) ............. 8

3.3  Energy (Section 3.3 of the EIR) ................................................................. 9

3.4  Greenhouse Gas Emissions (Section 3.4 of the EIR) .............................. 10

3.5  Hazards and Hazardous Materials /Wildfire (Section 3.5 of the EIR) ...... 12

3.6  Land Use and Planning (Section 3.6 of the EIR) ..................................... 13

3.7  Noise (Section 3.7 of the EIR) ................................................................. 15

3.8  Public Services and Recreation (Section 3.8 of the EIR) ........................ 17

3.9  Transportation (Section 3.9 of the EIR) ................................................... 20

3.10  Tribal Cultural Resources (Section 3.10 of the EIR) ................................ 22

3.11  Utilities and Service Systems (Section 3.11 of the EIR) .......................... 23 Section 4.0  Findings Regarding Impacts Mitigated to below a Level of Significance .... 28

4.1  Cultural and Paleontological Resources (Section 3.2 of the EIR) ........... 28

4.2  Noise (Section 3.7 of the Draft EIR) ........................................................ 32

4.3  Tribal Cultural Resources (Section 3.10 of the Draft EIR) ....................... 34 Section 5.0  Findings Regarding Alternatives ..................................................................... 37

5.1  Alternatives Considered But Rejected ..................................................... 38

5.2  Alternatives Selected for Further Analysis ............................................... 38

5.3  Environmentally Superior Alternative ....................................................... 43 Affinity Project Final EIR
Findings of Fact

ii Table of Contents
Section 6.0  Finding Regarding Significant Irreversible Environmental Changes ........... 44 Section 7.0  Finding Regarding Growth-Inducing Impacts ................................................ 45

Affinity Project Final EIR
Findings of Fact

1 Introduction
SECTION 1.0 INTRODUCTION

1.1 REQUIREMENT FOR FINDINGS OF FACT
The California Environmental Quality Act (CEQA) (Section 21002.1 of the California Public Resources Code [PRC]) and the State CEQA Guidelines (Section 15000 et. seq. of Title 14, California Code of Regulations [CCR]) require that the Lead Agency analyze and provide findings on a project’s environmental impacts before approving that project. If a project will generate significant environmental effects that cannot be avoided or substantially lessened, then before approving the project, the lead agency must provide a statement of overriding considerations documenting that the project’s benefits outweigh its unavoidable adverse significant environmental effects.

The City of Pasadena (City) in its capacity as the CEQA Lead Agency, has prepared these Findings of Fact (Findings) to comply with CEQA and the State CEQA Guidelines for the proposed Affinity Project (Project or Project with Building A Residential/Commercial). The determination that the City is the Lead Agency is made in accordance with Section 15051 of the State CEQA Guidelines, which defines the Lead Agency as the public agency that has the principal responsibility for carrying out or approving a proposed project. Regarding the Findings, Section 15091 of the State CEQA Guidelines establishes the following requirements:
(a) No public agency shall approve or carry out a project for which an EIR has been certified which identifies one or more significant environmental effects of the project unless the public agency makes one or more written findings for each of those significant effects, accompanied by a brief explanation of the rationale for each finding.

The possible findings are:

1. Changes or alterations have been required in, or incorporated into, the project which avoid or substantially lessen the significant environmental effect as identified in the final EIR.

2. Such changes or alterations are within the responsibility and jurisdiction of another public agency and not the agency making the finding. Such changes have been adopted by such other agency or can and should be adopted by such other agency.

3. Specific economic, legal, social, technol ogical, or other considerations, including the provision of employment opportunities for highly trained workers, make infeasible the mitigation measures or project alternatives identified in the final EIR. (b) The findings required by subdivision (a) shall be supported by substantial evidence in the record.
(c) The finding in subdivision (a)(2) shall not be made if the agency making the finding has concurrent jurisdiction with another agency to deal with identified feasible mitigation measures or alternatives. The finding in subdivision (a)(3) shall describe the specific reasons for rejecting identified mitigation measures and project alternatives. (d) When making the findings required in subdivision (a)(1), the agency shall also adopt a program for reporting on or monitoring the changes which it has either required in the project or made a condition of approval to avoid or substantially lessen significant environmental effects. These measures must be fully enforceable through permit conditions, agreements, or other measures.
(e) The public agency shall specify the location and custodian of the documents or other material which constitute the record of the proceedings upon which its decision is based.

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2 Introduction
(f) A statement made pursuant to Section 15093 does not substitute for the findings required by this section.

The “changes or alterations” under Section 15091(a)(1) that would avoid or substantially lessen a project’s significant environmental effects can include a variety of measures or actions, including but not limited to:
 Avoiding the impact altogether by not taking a certain action or parts of an action.  Minimizing impacts by limiting the degree or magnitude of the action and its implementation.
 Rectifying the impact by repairing, rehabilitating, or restoring the impacted environment.  Reducing or eliminating the impact over time by preservation and maintenance operations during the life of the action.
 Compensating for the impact by replacing or providing substitute resources or environments.

A Statement of Overriding Considerations states that the decision-making body has balanced the benefits of a project against its unavoidable significant environmental effects and has determined that the benefits of a project outweigh the adverse effects and, therefore, the adverse effects are considered acceptable. Because the Project would not result in any significant and unavoidable impacts, a Statement of Overriding Considerations is not required for the Project.

Having received, reviewed, and considered the Final Environmental Impact Report (Final EIR) for the Affinity Project (State Clearinghouse [SCH] No. 2021080103), as well as all other information in the record of proceedings on this matter, the following Findings are hereby adopted by the City of Pasadena. The Findings set forth the environmental and other bases for current and subsequent discretionary actions to be undertaken by City, as the Lead Agency, and responsible agencies for the implementation of the Project.

1.2 PROJECT SUMMARY
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. Regi onal 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.

The Project Applicant requests approval to rezone the Project site from CD-6 (Central District Specific Plan [CDSP], Arroyo Corridor/Fair Oaks subdistrict), to a Planned Development (PD) zone, and approval of a PD Plan. The Project involves demolition of six (of the nine) existing buildings totaling 45,912 sf, located at 491, 495, 499, 503, 541, and 577 South Arroyo Parkway and construction of two new buildings: (1) a 154,000-sf, 7-story (aboveground) medical office building with ground-floor commercial uses (Building A); and (2) 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 one- and two-bedroom senior housing units (Building B). As proposed, there would be five subterranean levels providing up to 850 parking spaces. Approximately 31,605 sf of open space, including public and private (for solely resident and staff use) space would be provided across the Project site.

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3 Introduction
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 (one less than the Project).

Although the Project is the choice that is anticipated to be constructed, the flexibility to exchange 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 regardless of the scenario constructed, if approved. 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 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.

A total of approximately 79,553 sf of the existing development on site would be retained and integrated into the Project, including the Whole Foods grocery store and associated 275-space subterranean parking structure at 465 South Arroyo Parkway and the two 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.

A total of five levels of subterranean parking spanning both proposed buildings with up to 850 parking spaces would also be constructed to serve the new development as well as the existing structures at 501 and 523 Arroyo Parkway under the Project. For the Project with Building A Residential/Commercial, a total of four levels of subterranean parking spanning both proposed buildings with up to 650 parking spaces would be constructed. The Project uses south of Whole Foods Grocery would have three ingress/egress points–one on California Boulevard and two on South Arroyo Parkway. Whole Foods Grocery would retain the entrance on East Bellevue Drive and the exit onto South Arroyo Parkway.

1.3 FINDING REGARDING CERTIFICATION OF THE EIR
Pursuant to Section 15090 of the State CEQA Guidelines, the City Council certifies that: (1) it has reviewed and considered the Final EIR prior to approving the project; (2) the Final EIR is an accurate and objective statement that fully complies with CEQA, the State CEQA Guidelines, and the City’s local environmental guidelines; and (3) the Final EIR reflects the independent judgement of the City of Pasadena. The City Council certifies the Final EIR based on the findings and conclusions presented herein.

1.4 FINDING REGARDING ADOPTION OF MITIGATION MONITORING AND

REPORTING PROGRAM
Pursuant to Section 21081.6 of the PRC, the City Council hereby adopts the Mitigation Monitoring and Reporting Program (MMRP) attached to this Resolution as Attachment 1, and incorporated herein. This MMRP includes all of the mitigation measures analyzed in the Draft EIR, inclusive of any clarifications or revisions associated with the Reponse to Comments on the Draft EIR, which Affinity Project Final EIR
Findings of Fact

4 Introduction
are applicable to the Project, Project with Building A Residential/Commercial, and Alternatives 2 through 4.

1.5 FINDING REGARDING CUSTODIAN OF RECORDS
The documents and materials that constitute the record of proceedings on which these findings are based are located at the City of Pasadena, Planning and Community Development Department, 175 North Garfield Avenue, Pasadena, California 91101 and with the Director of Planning and Community Development, who serves as the custodian of these records.

Affinity Project Final EIR
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5 Findings Regarding Environmental Issues
Not Analyzed in the EIR
SECTION 2.0 FINDINGS REGARDING ENVIRONMENTAL ISSUES NOT

ANALYZED IN THE EIR
The City Council hereby finds that the following environmental issues were found to have no impacts or less than significant impacts in the Initial Study (see Appendix A-1 of the Draft EIR), did not require the imposition of mitigation measures, and therefore did not require analyses in the Draft EIR:
 Aesthetics;
 Agricultural and Forestry Resources;
 Air Quality (Odors);
 Biological Resources;
 Cultural Resources (Human Remains);
 Geology and Soils;
 Hazards and Hazardous Materials (Accidental Release of Hazardous Materials, Location Near Airport, Emergency Response/Evacuation Plan, Wildfire);  Hydrology and Water Quality;
 Land Use and Planning (Dividing a Community);
 Mineral Resources;
 Noise (Location Near Airport);
 Population and Housing; and
 Wildfire.

Affinity Project Final EIR
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6 Findings Regarding Impacts Determined to be
Less Than Significant without Mitigation
SECTION 3.0 FINDINGS RE GARDING IMPACTS DETERMINED TO BE LESS

THAN SIGNIFICANT WITHOUT MITIGATION
Consistent with Section 21002.1 of the PRC and Section 15128 of the State CEQA Guidelines, the Final EIR focused its analysis on topics wi th potentially significant impacts, and limited discussion of other topics with no potential for significant adverse environmental impacts. For each environmental topic within this category, the discussion below includes: (1) a listing of the environmental topics evaluated in the Draft EIR for which there would be no impact or a less than significant impact without mitigation and the Draft EIR page citations where the relevant discussion begins, (2) indication that no mitigation measures (MMs) are required, (3) findings pursuant to Section 15091 of the State CEQA Guidelines for that topic, and (4) explanation of the substantial evidence in support of the Draft EIR conclusion that there would be no impact or a less than significant impact related to the identified topics (i.e., thresholds).

Section 15091 of the State CEQA Guidelines does not require specific findings to address environmental effects that an EIR identifies as “no impact” or a “less than significant” impact.

Nonetheless, the City Council hereby finds that the Project and Project with Building A Residential/Commercial would have either no impact or a less than significant impact pertaining to the following resource areas and environmental checklist questions.

3.1 AIR QUALITY (SECTION 3.1 OF THE EIR)
Potential Impacts Evaluated
 Would the project conflict with or obstruct implementation of the applicable air quality plan? (Draft EIR, p. 3.1-14)
 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? (Draft EIR, p. 3.1-16)
 Would the project expose sensitive receptors to substantial pollutant concentrations? (Draft EIR, p. 3.1-24)
Proposed Mitigation
None required.

Findings Pursuant to Section 15091 of the State CEQA Guidelines As noted above and explained below, the Draft EIR analysis determined that implementation of both the Project and Project with Building A Residential/Commercial would not result in significant impacts related to air quality. As such, findings under Section 15091 of the State CEQA Guidelines are not warranted.

Supporting Explanation
Project and Project with Building A Residential/Commercial Construction and operation of the Project and Project with Building A Residential/Commercial would not result in a cumulatively considerable net increase of any criteria pollutant for which the region is in non-attainment under applicable federal or State Ambient Air Quality Standards (AAQS) (refer to Tables 3.1-6 through 3.1-13 and associated analysis on pages 3.1-17 through Affinity Project Final EIR
Findings of Fact

7 Findings Regarding Impacts Determined to be
Less Than Significant without Mitigation

3.1-24 of the Draft EIR). There would be less than significant impacts, and no mitigation is required. (Draft EIR, p. 3.1-15 through 3.1-24)
Accordingly, the Project and Project with Building A Residential/Commercial would not result in an increase in the frequency or severity of existing air quality violations, cause or contribute to new violations, or delay timely attainment of air quality standards or the interim emissions reductions in the South Coast Air Quality Management District’s (SCAQMD’s) 2016 Air Quality Management Plan (AQMP). Therefore, neither the Project nor Project with Building A Residential/Commercial would conflict with AQMP first criterion of AQMP consistency. Regarding the second criterion, the Project site is within both a High-Quality Transit Area (HQTA) and Transit Priority Area (TPA). 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.

Positioning a mix-use development, under either scenario, in proximity of the L Line and bus lines would encourage the use of mass transit which is consistent with the AQMP’s goal of using non- single occupancy vehicles. Additionally, the Project and Project with Building A Residential/Commercial would be consistent with the existing General Plan designation for the site of High Mixed-Use; as such, the Project and Project with Building A Residential/Commercial would not exceed the anticipated growth accounted for within the Land Use Element of the City’s General Plan, which helped formed the basis of the AQMP. Therefore, the Project and Project with Building A Residential/Commercial would not result in a conflict with or obstruct implementation of the applicable air quality plan–SCAQMD’s 2016 AQMP. There would be less than significant impacts, and no mitigation is required. (Draft EIR, p. 3.1-13 through 3.1-15) Exposure of sensitive receptors was addressed for emissions from construction and operation of the Project and Project with Building A Residential/Commercial. To address construction activities, the analysis below addresses the following issues: localized air quality impacts; and toxic air contaminants (TACs), specifically di esel 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 carbon monoxide (CO) hotspots. The proposed residential and commercial uses do not generate substantial quantities of TACs and are therefore not addressed in the Draft EIR.

Localized impacts from construction and operation were found to be less than the applicable SCAQMD localized significance thresholds (LST) screening thresholds (see Tables 3.1-7, 3.1-9,

3.1-11, and 3.1-13 and associated analysis on pages 3.1-18 through 3.1-24 of the Draft EIR).

Regarding TACs (DPM), there would be relatively few pieces of off-road, heavy-duty diesel equipment in operation, and the total constructi on period of approximately 34 months would be relatively short when compared to a 40-year exposure period, consistent with Office of Environmental Health Hazard Assessment methodology. Combined with the highly dispersive properties of DPM and additional reductions in par ticulate emissions from newer construction equipment, as required by federal and State regulations, construction emissions of TACs for both the Project and Project with Building A Residential/Commercial were determined not to represent a substantial exposure to sensitive receptors. In an urban setting, vehicle exhaust is the primary source of CO. Localized areas where ambient concentrations exceed federal and/or State standards for CO are termed CO “hotspots”. If impacts are less than significant close to congested intersections (as measured by level of service [LOS]), impacts also would be less than significant at more distant sensitive receptor locations. Based on data in the Transportation Impact Analysis – Outside of CEQA Analysis prepared for Project and Project with Building A Residential/Commercial, based on PM peak hour traffic volumes average daily traffic at the Arroyo Parkway/California Street intersection under Existing Plus Project conditions is conservatively estimated at 48,000 vehicles for the Project and a conservatively estimated 45,000 vehicles for the Project with Building A Residential/Commercial. The 48,000 or 45,000 daily trips at this intersection is substantially less than the 400,000 vehicles per day needed to exceed the CO Affinity Project Final EIR
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8 Findings Regarding Impacts Determined to be
Less Than Significant without Mitigation
standards. Therefore, CO concentrations at the intersection would be substantially less than the CO ambient air quality standards. There would be less than significant impacts, and no mitigation is required. (Draft EIR, p. 3.1-24 through 3.1-27)
Cumulative Impacts
Project and Project with Building A Residential/Commercial Consistency with the SCAQMD’s AQMP is not subject to cumulative impact analysis. However, cumulative construction and operational impacts were analyzed and found to be less than significant, as discussed above. 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. 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 expressly addressed in the Transportation Impact Analysis – Outside of CEQA Analysis reports, the Existing Plus Project traffic volume at the Arroyo Parkway/California Street intersection (which has the worst LOS) 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 implementation of the Project or Project with Building A Residential/Commercial, and no mitigation is required. (Draft EIR, p. 3.1-27 through 3.1-29)

3.2 CULTURAL AND PALEONTOLOGICAL RESOURCES (SECTION 3.2 OF THE EIR) Potential Impacts Evaluated
 Would the project directly or indirectly destroy a unique paleontological resource or site or unique geologic feature? (Draft EIR, p. 3.2-14)
Proposed Mitigation
None required.

Findings Pursuant to Section 15091 of the State CEQA Guidelines As noted above and explained below, the Draft EIR analysis determined that implementation of both the Project and Project with Building A Residential/Commercial would not result in significant impacts related to paleontological resources. As such, findings under Section 15091 of the State CEQA Guidelines are not warranted.

Supporting Explanation
Project and Project with Building A Residential/Commercial No unique geologic features are known to exist, and no fossils have been documented on the Project site. The Project would involve excavation for five subterranean parking levels spanning both proposed buildings; the Project with Building A Residential/Commercial would have one less level of subterranean parking. The City’s General Plan EIR states that grading and excavations deeper than six feet into the Topanga Formation have the potential to impact significant fossils.

However, neither the Project nor Project with Building A Residential/Commercial would involve excavation in the Topanga Formation. There would be less than significant impacts, and no mitigation is required. (Draft EIR, p. 3.2-12 through 3.2-15) Affinity Project Final EIR
Findings of Fact

9 Findings Regarding Impacts Determined to be
Less Than Significant without Mitigation
Cumulative Impacts
Project and Project with Building A Residential/Commercial Although cultural resources (which includes paleontological resources) are site-specific regarding any given resource, impacts may be considered cumulative simply because they relate to the loss of cultural resources in general over time throughout the region. Regarding paleontological resources, 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 paleontological resources. (Draft EIR, p. 3.2-15 through 3.2-16)

3.3 ENERGY (SECTION 3.3 OF THE EIR)
Potential Impacts Evaluated
 Would the project result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation? (Draft EIR, p. 3.3-4)
 Would the project conflict with or obstruct a state or local plan for renewable energy or energy efficiency? (Draft EIR, p. 3.3-7)
Proposed Mitigation
None required.

Findings Pursuant to Section 15091 of the State CEQA Guidelines As noted above and explained below, the Draft EIR analysis determined that implementation of both the Project and Project with Building A Residential/Commercial would not result in significant impacts related to energy. As such, findings under Section 15091 of the State CEQA Guidelines are not warranted.

Supporting Explanation
Project and Project with Building A Residential/Commercial Construction and operation of the Project and Project with Building A Residential/Commercial would require the use of energy (refer to Tables 3.3-1 through 3.3-4 on pages 3.3-4 through 3.3- 7 of the Draft EIR). 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. 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. Further, short-term energy usage for construction would result in long-term energy savings from newly constructed buildings that are compliant with the current State energy efficiency requirements.

Strategies and measures for increased energy efficiency have been implemented at the State level with California’s Title 24 Energy Effi ciency Standards for Residential and Nonresidential Buildings and the CALGreen Code. The Project and Project with Building A Residential/Commercial would be more energy-efficient than the existing buildings in the vicinity Affinity Project Final EIR
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10 Findings Regarding Impacts Determined to be
Less Than Significant without Mitigation
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 and Project with Building A Residential/Commercial 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 transportation. Also, the Project site is within both HQTA and TPA; the proposed land uses near transit support alternative transportation modes.

Construction and operation of the Project and 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 a less than significant impacts, and no mitigation is required. (Draft EIR, p. 3.3-4 through 3.3-8)
Cumulative Impacts
Project and Project with Building A Residential/Commercial 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 [SCAG]) planning documents support a denser land use pattern with a focus on proximity to transit. Therefore, neither the Project nor Project with Building A Residential/Commercial would result in a cumulatively considerable impact related to energy. (Draft EIR, p. 3.3-8)

3.4 GREENHOUSE GAS EMISSIONS (SECTION 3.4 OF THE EIR)
Potential Impacts Evaluated
 Would the project generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment? (Draft EIR, p. 3.4-14)  Would the project conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of greenhouse gas emissions? (Draft EIR, p. 3.4-19) Proposed Mitigation
None required.

Findings Pursuant to Section 15091 of the State CEQA Guidelines As noted above and explained below, the Draft EIR analysis determined that implementation of both the Project and Project with Building A Residential/Commercial would not result in significant impacts related to greenhouse gas emissions. As such, findings under Section 15091 of the State CEQA Guidelines are not warranted.

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11 Findings Regarding Impacts Determined to be
Less Than Significant without Mitigation
Supporting Explanation
Project and Project with Building A Residential/Commercial Construction and operation of the Project and Project with Building A Residential/Commercial would result in greenhouse gas (GHG) emissions. The principal source of construction-related GHG emissions would be from internal com bustion engines of construction equipment, on-road construction vehicles, and workers’ commuting vehicles. 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.

The Climate Action Plan (CAP), adopted by the City in March 2018, is a long-range planning document that guides the City towards long-term emissions reductions in accordance with State of California goals. The CAP Checklist is a tool for new development projects to demonstrate consistency with the CAP, as a qualified GHG reduction plan in accordance with Section 15183.5 of the State CEQA Guidelines. The Option B GHG efficiency metric of the City’s CAP was 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). Neither the Project’s GHG efficiency metric of 3.52 metric tons of carbon dioxide equivalent per service person (MTCO
2e/SP) nor the Project with Building A
Residential/Commercial’s GHG efficiency metric of 2.15 MTCO 2e/SP would exceed the City’s CAP GHG efficiency threshold of 3.57 MTCO 2e/SP for 2026 (refer to Tables 3.4-6 and 3.4-9 on pages 3.4-16 and 3.4-19 of the Draft EIR).

To provide further substantiation that the Project and Project with Building A Residential/Commercial would be consistent with State plans, policies, and regulations, consistency with the SCAG 2020–2045 Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS) Connect SoCal, CARB’s California’s Climate Change Scoping Plan (Scoping Plan), and Statewide GHG reduction goals for 2030 or 2050 was addressed in the Draft EIR. The Project and Project with Building A Residential/Commercial were determined not to conflict with SCAG’s Connect SoCal plan and not to impede the State’s trajectory toward Statewide GHG reduction goals for 2030 or 2050. The Project and Project with Building A Residential/Commercial would not generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment and 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. (Draft EIR, p. 3.4-14 through 3.4-22) Cumulative Impacts
Project and Project with Building A Residential/Commercial 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. Therefore, the analysis summarized above represents the cumulative impact analysis of Affinity Project Final EIR
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12 Findings Regarding Impacts Determined to be
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GHG emissions. As discussed, there would be less than significant impacts, and no mitigation is required. (Draft EIR, p. 3.4-22)

3.5 HAZARDS AND HAZARDOUS MATERIALS /WILDFIRE (SECTION 3.5 OF THE EIR) Potential Impacts Evaluated
 Would the project create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials? (Draft EIR, p. 3.5-10)  Would the project emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter-mile of an existing or proposed school? (Draft EIR, p. 3.5-11)
 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? (Draft EIR, p. 3.5-12) Proposed Mitigation
None required.

Findings Pursuant to Section 15091 of the State CEQA Guidelines As noted above and explained below, the Draft EIR analysis determined that implementation of both the Project and Project with Building A Residential/Commercial would not result in significant impacts related to hazards and hazardous materials. As such, findings under Section 15091 of the State CEQA Guidelines are not warranted.

Supporting Explanation
Project and Project with Building A Residential/Commercial The Project site is not on the State of California Hazardous Waste and Substances Sites List of sites published by California Environmental Protection Agency (CalEPA) and compiled pursuant to Section 65962.5 of the California Government Code (referred to as the Cortese List). Further, 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. Compliance with SCAQMD Rule 1403 and the California Division of Occupational Safety and Health’s (CalOSHA’s) Title 8 regulations on asbestos and lead abatement would be a condition of 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 transport of hazardous materials, that would represent a significant hazard to construction workers, the public, or the environment, is not anticipated.

Operation of medical and medical-related faciliti es, such as the medical offices in Building A and/or 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). Health care facilities in California are licensed, regulated, inspected, and/or certified by several public and private agencies at the State and federal levels. All hazardous materials and/or wastes associated with the Project and Project with Building A Residential/Commercial, including those related to proposed commercial uses and the presence of diesel emergency generators, would be managed Affinity Project Final EIR
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13 Findings Regarding Impacts Determined to be
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and disposed in compliance with local, regional, State, and federal regulations. Thus, the Project and Project with Building A Residential/Commercial 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. Construction and operation of the Project would not adversely affect schools in the vicinity through compliance with applicable regulations. There would be a less than significant impacts, and no mitigation is required. (Draft EIR, p. 3.5-10 through 3.5-13) Cumulative Impacts
Project and Project with Building A Residential/Commercial 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 and Project with Building A Residential/Commercial, with pertinent regulations would preserve public health and safety and would prevent hazards to existing and future developments.

Therefore, the Project’s and Project with Building A Residential/Commercial’s contribution to cumulative impacts would be less than significant, and no mitigation is required. (Draft EIR, p.

3.5- through 3.5-13)

3.6 LAND USE AND PLANNING (SECTION 3.6 OF THE EIR)
Potential Impacts Evaluated
 Would the proposed 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? (Draft EIR, p. 3.6-6)
Proposed Mitigation
None required.

Findings Pursuant to Section 15091 of the State CEQA Guidelines As noted above and explained below, the Draft EIR analysis determined that implementation of both the Project and Project with Building A Residential/Commercial would not result in significant impacts related to land use and planning. As such, findings under Section 15091 of the State CEQA Guidelines are not warranted.

Supporting Explanation
Project and Project with Building A Residential/Commercial The Project would not require a General Plan amendment and would be consistent with the Guiding Principles of the City’s General Plan Land Use Element and numerous goals and policies related to avoiding or reducing environmental impacts. The primary land use planning documents that govern the Project site are the City’s Gener al Plan, Central District Specific 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 Affinity Project Final EIR
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14 Findings Regarding Impacts Determined to be
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demographic growth. The Project would redevelop an underutilized site with transit and pedestrian accessibility with multi-story buildings that provide complementary commercial, assisted living, and medical office uses (or the Project with Building A Residential/Commercial that provide complementary commercial, assisted living, and residential uses) while integrating two historic structures. (Draft EIR, p. 3.6-13 and p. 3.6-22) The City’s General Plan includes goals and policies that have the purpose of avoiding or mitigating an environmental effect; for the City of Pasadena, these include historic resources and GHG emissions/sustainability. (Draft EIR, p. 3.6-10 and p. 3.6-19) Consistent with Goal 8 and Policy 8.1, 8.4, and 8.5 of the General Plan, a 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. Additionally, mitigation measures have been identified to protect the on- site historic structures during construction acti vities and ensure there are no significant impacts to historic resources, consistent with the General Plan. (Draft EIR, p. 3.6-13 and 3.6-19 through -20)
Consistent with Goal 10 and Policy 10.1, 10.4, and 10.6 of the General Plan, as concluded in Section 3.4, GHG Emissions, of the Draft EIR, the Project and Project with Building A Residential/Commercial 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. As concluded in Section 3.3, Energy, of the Draft EIR, construction and operation of the Project and Project with Building A Residential/Commercial would not result in wasteful, inefficient, or unnecessary use 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. (Draft EIR, p. 3.6-11 and 3.6-20) The City’s General Plan land use designation for the site is High Mixed-Use, which 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 417,929 1 sf of floor area
(aboveground), which would include up to 95 senior housing 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 and Project with Building A Residential/Commercial would not require a General Plan amendment. Both the Project and Project with Building A Residential/Commercial were determined to be consistent with the General Plan Land Use Element’s Guiding Principles and goals and policies whose purpose is avoiding or mitigating an environmental effect.

The Project and 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 would require adoption of a PD

1 Of this, a total of 338,376 sf would be new development in Buildings A and B.

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Plan. The regulations and standards that dictate allowed and conditionally allowed land uses and development would be prescribed in the accompanying PD Plan. 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. A subsequent review of a proposed PD zone and PD Plan would occur at a public hearing by the Planning Commission. Therefore, with adherence to the PD Plan processes, including consideration of a variance for historic resources to increase the height of the proposed buildings, the Project would be considered consistent with the zoning code. The Project and Project with Building A Residential/Commercial would not conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect. There would be less than significant impacts, and no mitigation is required. (Draft EIR, p. 3.6-6 through 3.6-24)
Cumulative Impacts
Project and Project with Building A Residential/Commercial The cumulative impacts related to demographic growth are analyzed for the City of Pasadena.

Growth and development in the City would be accompanied by potential changes in existing land uses. All future projects requiring General Plan amendments or zone changes/variances would need to show consistency with the applicable goals, policies, and/or actions in the General Plan and/or Zoning Code, respectively, and thus are not expected to lead to land use incompatibilities or conflicts. Planned or required infrastructure and public facilities associated with individual projects would provide the necessary facilities and services to existing and future developments.

Thus, these projects would complement the private development projects planned in the City. The Project and Project with Building A Residential/Commercial would not result in a cumulatively considerable impacts, and no mitigation is required. (Draft EIR, p. 3.6-25)

3.7 NOISE (SECTION 3.7 OF THE EIR)
Potential Impacts Evaluated
 Would the project result in the generation of substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance or applicable standards of other agencies? (Draft EIR, p. 3.7-11)
Proposed Mitigation
None required.

Findings Pursuant to Section 15091 of the State CEQA Guidelines As noted above and explained below, the Draft EIR analysis determined that implementation of both the Project and Project with Building A Residential/Commercial would not result in significant impacts related to noise. As such, findings under Section 15091 of the State CEQA Guidelines are not warranted.

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16 Findings Regarding Impacts Determined to be
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Supporting Explanation
Project and Project with Building A Residential/Commercial Construction of the Project and Project with Building A Residential/Commercial would generate noise from demolition, site preparation, grading/excavation, building construction and architectural coating activities. Noise levels for the Project’s construction phase would be based on a typical construction equipment mix for a mixed-use project and do not include use of atypical, very loud, and vibration-intensive equipment (e.g., pile drivers). The Draft EIR determined that noise levels from construction activities at the nearest noise sensitive use/receptor would be less than the City’s noise limit of 85 dBA as measured at 100 feet, and would be lower than 85 dBA for almost all receptors and/or all construction phases (refer to Table 3.7-4 page 3.7-12 of the Draft EIR). Noise from construction activities on- site would be clearly audible above the existing ambient noise environment. However, construction would occur during the least noise-sensitive portions of the day, and it would not exceed the City's construction noise limit of 85 dBA at 100 feet. Additionally, off-site noise from the addition of construction-related truck trips would not be discernable.

Operation of the Project and Project with Building A Residential/Commercial would increase traffic compared to the existing uses on the site, which has the potential to increase noise levels on local roadways proximate to the site. The Project would result in a greater increase in net average daily trips (ADT) than the Project with Building A Residential/Commercial and would result between 0 percent and 19 percent increase in ADT (refer to Table 3.7-6 on page 3.7-14 of the Draft EIR). A 3-decibel increase occurs when traffic volumes double or a project increases the percentage of noisy trucks on roadways. With a maximum increase of 19 percent, the increase in off-site traffic- related noise would be less than 1 decibel. This increment is not discernable to human hearing even under laboratory conditions. On-site operational noise sources associated with the Project would include, but not limited to, mechanical equipment (e.g., HVAC units), landscape maintenance equipment, and noise generated by outdoor open spaces and dining. The Project would be required to comply with City of Pasadena noise ordinances Sections 9.36.090 and

9.36.050. In summary, construction and operation of the Project and Project with Building A Residential/Commercial would not result in a substantial temporary or permanent change in ambient noise levels. There would be less than significant impacts, and no mitigation is required. (Draft EIR, p. 3.7-10 through 3.7-16)
Cumulative Impacts
Project and Project with Building A Residential/Commercial Noise generated during construction of the Project and Project with Building A Residential/Commercial would be localized and would occur intermittently for varying periods of time throughout the construction period. Noise generated by construction of the Project or Project with Building A Residential/Commercial in combination with another project with major construction activity within approximately 1,000 feet of the site could adversely impact sensitive receptors in the vicinity of the site with a cumulative noise level greater than the noise generated solely at the Project site. At the time of preparation of the Draft EIR, there were no projects within 1,000 feet that were anticipated to be constructed concurrently with the Project or Project with Building A Residential/Commercial that would have the potential to generate cumulatively considerable noise or vibration levels. The City al so limits noise from construction equipment to 85 dBA at 100 feet. Because construction noise would be substantially attenuated prior to reaching land uses proximate to the site and imposes a noise limit on construction equipment, Affinity Project Final EIR
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cumulative noise from proximate construction projects, if applicable, would not be substantially different than that generated by the Project or Project with Building A Residential/Commercial.

Cumulative traffic noise was evaluated by the City’s General Plan EIR, in which buildout traffic noise levels along Arroyo Parkway north of California Boulevard were found to increase by 0.5 dBA. The Project or Project with Building A Residential/Commercial would not result in increases in cumulative traffic noise above the 5 dBA CNEL significance threshold used in the General Plan EIR. Individual stationary sources of noise are regulated by the City’s Municipal Code for both the Project and the Project with Building A Residential/Commercial as well as any future projects in the vicinity. The stringent noise limitations established for each of these noise sources, the infrequency of occurrence, and the separation distance for these noise sources would limit cumulative noise exposure near the Project site to a less than significant level. As such, construction and operation of the Project or Project with Building A Residential/Commercial would not result in a cumulatively considerable noise impact, and no mitigation is required. (Draft EIR, p. 3.7-19 through 3.7-20)

3.8 PUBLIC SERVICES AND RECREATION (SECTION 3.8 OF THE EIR) Potential Impacts Evaluated
 Would the proposed project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for any of the public services:
o Fire protection; (Draft EIR, p. 3.8-10)
o Police protection; (Draft EIR, p. 3.8-11)
o Schools; (Draft EIR, p. 3.8-12)
o Parks; or (Draft EIR, p. 3.8-13)
o Other public facilities? (Draft EIR, p. 3.8-12)
 Would the project include recreational facilities or require the construction or expansion of recreational facilities, which might have an adverse physical effect on the environment? (Draft EIR, p. 3.8-13)
 Would the project increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated? (Draft EIR, p. 3.8-13)
Proposed Mitigation
None required.

Findings Pursuant to Section 15091 of the State CEQA Guidelines As noted above and explained below, the Draft EIR analysis determined that implementation of both the Project and Project with Building A Residential/Commercial would not result in significant impacts related to public services and recreation. As such, findings under Section 15091 of the State CEQA Guidelines are not warranted.

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Supporting Explanation
Project and Project with Building A Residential/Commercial Fire Protection and Emergency Medical Services
The Pasadena Fire Department (PFD) anticipates that the Project and Project with Building A Residential/Commercial would result in an increased call for fire protection and emergency medical services because there would be larger development on the site than the existing conditions; however, the increase would not result in the need to construct new or expanded facilities whose construction may cause an environm ental impact. Further, the Project or Project with Building A Residential would comply with the California Fire Code, regulations related to fire protection, and be subject to the City’s routine construction permitting process. This includes a review by PFD for compliance with building and site design standards related to fire life safety and coordinating with Pasadena Water and Power (PWP) to ensure that local fire flow infrastructure meets current code standards for the type and intensity of land uses involved. The Project and Project with Building A Residential/Commercial would generate revenues towards the City’s general fund (e.g., property taxes, sales tax, business tax) that could potentially be applied toward the funding of PFD fire protection and emergency services. There would be less than significant impacts related to the need for new or expanded PFD facilities, and no mitigation is required. (Draft EIR p. 3.8-10 through 3.8-11 and p. 3.8-14 through 3.8-15) Police Protection Services
The Pasadena Police Department (PPD) anticipates that the Project and Project with Building A Residential/Commercial would result in an increase in calls for service in and around the site, primarily due to traffic (i.e., traffic stops, accidents), potential theft on the premises and in vehicles, and disturbances related to unhoused individuals. PPD states that whenever additional businesses and/or residents move into an area, there is a presumption that calls for service increase. Further, the Project and Project with Building A Residential/Commercial would be reviewed by the PPD and be required to comply with any requirements in effect when the review is conducted. The Project and Project with Building A Residential/Commercial would generate revenues towards the City’s general fund (e.g., property taxes, sales tax, business tax) that could potentially be applied toward the funding of PPD police protection services. These revenues would help offset the increased demand for PPD services with buildout of the General Plan.

Construction and operation of new or expanded facilities, if necessary, as an allowed land use were evaluated throughout the General Plan EIR. However, the PPD does not indicate the Project and Project with Building A Residential/Commercial would result in the need to construct new or expanded facilities that may cause an environmental impact. There would be less than significant impacts related to the need for new or expanded PPD facilities, and no mitigation is required. (Draft EIR, p. 3.8-11 and p. 3.8-15)
Schools
The Project would not generate school-age children that would utilize Pasadena Unified School District (PUSD) schools or programs, as the only dwelling units proposed are for senior-age persons. As allowed under the SB 50, school districts serving the City can assess school impact fees based on the floor area of new dwelling units and non-residential developments. The Project with Building A Residential/Commercial would generate school-age children and would be required to remit SB 50 fees. These fees, to be remitted prior to issuance of building permits, are used to fund school services and facilities needed to provide the necessary school services. There would be no impact associated with the Project and a less than significant impact associated with Affinity Project Final EIR
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the Project with Building A Residential/Commercial, and no mitigation is required. (Draft EIR, p.

3.8-12)
Other Public Facilities (Libraries)
While the Project and Project with Building A Residential/Commercial would result in an increase in the population being served by the Pasadena Public Library (PPL), their total collection exceeded national per capita standards at the time the General Plan EIR was prepared. As such, the PPL concluded that the Project’s and Project with Building A Residential/Commercial’s population would be adequately served by the existing facilities and related collections and would not result in the need to construct new or expanded PPL facilities that may cause an environmental impact. There would be a less than significant impact, and no mitigation is required. (Draft EIR, p. 3.8-12)
Parks and Recreation Services
The City’s Parks, Recreation, and Community Services Department does not have a minimum service ratio for parks. However, based on the existing parkland with a 0.7-mile radius of the site and proposed private and public open space proposed as part of the Project and Project with Building A Residential/Commercial, the Parks, Recreation, and Community Services Department concluded that the increase in population associated with the Project and Project with Building A Residential/Commercial would not result in the need for new or expanded off-site park facilities that may cause an environmental impact. Additionally, the Parks, Recreation, and Community Services Department concluded that the Project or Project with Building A Residential/Commercial would not increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facilities would occur or be accelerated through payment of a park impact fee (Section 4.17 of the Pasadena Municipal Code [PMC]) whose purpose is to of fset increased demand for parks and impact on existing parks. There would be a less than significant impact, and no mitigation is required. (Draft EIR, p. 3.8-13 through 3.8-14)
Cumulative Impacts
Project and Project with Building A Residential/Commercial For PFD, PPD, PPL, and parks services, the service area for consideration of cumulative impacts is the City. For PUSD, the geographic area for consideration of cumulative impacts is the PUSD service area, which includes the City and some adjacent areas. The PFD and PPD have mutual aid agreements with other fire protection and police agencies in the surrounding region. Individual developments in the City would be reviewed by the PFD and PPD and required to comply with any requirements in effect when the review is conducted. Future development in the City would generate revenues towards the City’s general fund (e.g., property taxes, sales tax, business tax) that could potentially be applied toward the funding of PFD and PPD facilities. These revenues would help offset the increased demand for PFD and PPD services with buildout of the General Plan. Construction and operation of new or expanded facilities, if necessary, as an allowed land use were evaluated throughout the General Plan EIR.

The General Plan EIR states that the existing library system (in 2015) and PUSD would have adequate resources to serve the anticipated population increase, including student population, with General Plan buildout. PUSD determined that there would be excess classroom capacity for all grade levels. Individual developments in the City would be required to pay SB 50 fees as appropriate at the time that project is implem ented. Additionally, PUSD can utilize Measure TT Affinity Project Final EIR
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funds. As discussed in the Initial Study, the development of the Project or the Project with Building A Residential/Commercial would be within the remaining development capacity of the General Plan for the CDSP.

Individual developments in the City would be required to pay the residential impact fee consistent with the park impact fee nexus study prepared in 2013 and updated every five years. Compliance with the residential impact fee program ensures that there is adequate parkland based on General Plan standards, and that there would not be substantial deterioration of existing facilities. In addition to City of Pasadena, the surrounding cities, County of Los Angeles, and National Forest Service have policies and programs to maintain and/or develop regional recreation facilities to meet increased demand. It is not expected that t here would be regional growth, without some parallel growth of recreation facilities, such that the existing facilities would experience substantial physical deterioration.

Therefore, the Project and Project with Building A Residential/Commercial would not result in a cumulatively considerable impact to fire protection and emergency medical services, police protection, schools, libraries, and parks and recreation facilities, and no mitigation is required. (Draft EIR, p. 3.8-14 through p. 3.8-16)

3.9 TRANSPORTATION (SECTION 3.9 OF THE EIR)
Potential Impacts Evaluated
 Would the project conflict with a program plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities? (Draft EIR, p. 3.9-9)
 Would the project conflict or be inconsistent with CEQA Guidelines Section 15064.3, subdivision (b)(1)? (Draft EIR, p. 3.9-9)
 Would the project substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)? (Draft EIR, p. 3.9-11)
 Would the project result in inadequate emergency access? (Draft EIR, p. 3.9-12) Proposed Mitigation
None required.

Findings Pursuant to Section 15091 of the State CEQA Guidelines As noted above and explained below, the Draft EIR analysis determined that implementation of both the Project and Project with Building A Residential/Commercial would not result in significant impacts related to transportation. As such, findings under Section 15091 of the State CEQA Guidelines are not warranted.

Supporting Explanation
Project and Project with Building A Residential/Commercial The City of Pasadena Transportation Impact Analysis Current Practice and Guidelines (TIA Guidelines) address two vehicular performance metrics: Vehicle Miles Traveled (VMT) per Capita and Vehicle Trips (VT) per Capita. The City’s TIA methodology assesses both the vehicular and Affinity Project Final EIR
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non-vehicular (i.e., transit, bicycle, pedestrian) transportation facilities together with a total of five transportation performance measures (see Table 3.9-4 on page 3.9-7 of the Draft EIR). Proposed projects are analyzed using the City’s calibrated travel demand forecasting (TDF) model built on SCAG’s regional model.

Compared to the Project, the Project with Building A Residential/Commercial would have substantively lower VMT per Capita and somewhat lower VT per Capita. The Pasadena Department of Transportation (DOT) determined that neither the Project nor Project with Building A Residential/Commercial would exceed any of the CEQA transportation thresholds defined in the City’s TIA Guidelines. As such, the Project and Project with Building A Residential/Commercial would not conflict with the City’s plan addressi ng the circulation system under CEQA (i.e., TIA Guidelines), which includes transit, roadway, bicycle and pedestrian facilities; or conflict or be inconsistent with Section 15064.3(b)(1) of the State CEQA Guidelines.

The Pasadena DOT was consulted regarding the collision history for the South Arroyo Parkway and California Boulevard intersection. While collisions have occurred at this intersection, it is not considered a high collision location, and Pasadena DOT continues to monitor operations at this intersection and along the corridor to address traffic signal operations and reduce the potential for collisions. The Pasadena DOT concluded that the additional trips generated by the Project, on its own, are not expected to generate a safety concern at this intersection. Moreover, the Project would not increase hazards due to a geometric design feature or incompatible use. No sharp curves or dangerous intersections are proposed, and the proposed uses are consistent and compatible with the existing uses onsite and in the vicinity. Implementation of the Project or Project with Building A Residential/Commercial would not create new obstructions to emergency access in the Project area. There would be a less than significant impacts, and no mitigation is required. (Draft EIR, p. 3.9-9 through 3.9-12)
Cumulative Impacts
Project and Project with Building A Residential/Commercial Cumulative transportation impacts within the City were recently evaluated in the City’s General Plan EIR, which evaluated transportation impacts within the City associated with buildout of the General Plan in 2035. The General Plan EIR analysis considered impacts associated with the five transportation performance measures identified in the TIA Guidelines. The analysis found that transportation impacts associated with all five performance measures from buildout of the General Plan would be less than significant. As the Project and Project with Building A Residential/Commercial are consistent with the land use designation associated with the site that was evaluated in the General Plan EIR, the analysis of transportation impacts in the General Plan EIR is representative of cumulative impacts associated with the Project and Project with Building A Residential/Commercial. Also, as discussed above, the Project and Project with Building A Residential/Commercial would result in less than significant impacts for all five transportation performance measures. The Project and Project with Building A Residential/Commercial would not result in a cumulatively considerable impact related to transportation, and no mitigation is required. (Draft EIR, p. 3.9-13)
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22 Findings Regarding Impacts Determined to be
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3.10 TRIBAL CULTURAL RESOURCES (SECTION 3.10 OF THE EIR) Potential Impacts Evaluated
 Would the project cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is: listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code section 5020.1(k). (Draft EIR, p. 3.10-3)
Proposed Mitigation
None required.

Findings Pursuant to Section 15091 of the State CEQA Guidelines As noted above and explained below, the Draft EIR analysis determined that implementation of both the Project and Project with Building A Residential/Commercial would not result in significant impacts related to tribal cultural resources. As such, findings under Section 15091 of the State CEQA Guidelines are not warranted.

Supporting Explanation
Project and Project with Building A Residential/Commercial Based the results on an archaeological records search conducted by the South Central Coastal Information Center (SCCIC) on July 24, 2020 and Native American Heritage Commission (NAHC) Sacred Lands File search received on July 15, 2020, there are no tribal cultural resources listed on the California Register of Historical Resources (CRHR) or a local register within the Project site or otherwise known to the culturally affiliated Native American tribes. There would be no impact related to documented tribal cultural resources, and no mitigation is required. (Draft EIR, p. 3.10-3 through 3.10-4).

Cumulative Impacts
Project and Project with Building A Residential/Commercial Direct impacts to cultural resources are generally site specific. However, development throughout the City could potentially result in the disturbance of prehistoric archaeological resource sites (including tribal cultural resources/Native American remains). Because there are no documented tribal cultural resources on the Project site, the Project and Project with Building A Residential/Commercial would not result in a cumu latively considerable impact to tribal cultural resources, and no mitigation is required. (Draft EIR, p. 3.10-5 through 3.10-6) Affinity Project Final EIR
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23 Findings Regarding Impacts Determined to be
Less Than Significant without Mitigation

3.11 UTILITIES AND SERVICE SYSTEMS (SECTION 3.11 OF THE EIR) Potential Impacts Evaluated
 Would the project require or result in the relocation or construction of new or expanded water, wastewater treatment facilities or stormwater drainage, electric power, natural gas, or telecommunications facilities, the construction of which could cause significant environmental effects? (Draft EIR, p. 3.11-13)
 Would the project result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments? (Draft EIR, p. 3.11-13)  Would the project have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years? (Draft EIR, p. 3.11-15)
 Would the project generate solid waste in excess of State or local standards, in in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste goals? (Draft EIR, p. 3.11-24)
 Would the project comply with federal, state, and local management and reduction statutes and regulations related to solid waste? (Draft EIR, p. 3.11-26) Proposed Mitigation
None required.

Findings Pursuant to Section 15091 of the State CEQA Guidelines As noted above and explained below, the Draft EIR analysis determined that implementation of both the Project and Project with Building A Residential/Commercial would not result in significant impacts related to utilities and service systems. As such, findings under Section 15091 of the State CEQA Guidelines are not warranted.

Supporting Explanation
Project and Project with Building A Residential/Commercial Water Supply and Infrastructure
Pasadena Water and Power (PWP) provides potable water to City residents and businesses. The water supply analysis was derived from the Affinity Project Water Supply Assessment (WSA), prepared for the Project and Project with Building A Residential/Commercial by ESA and dated January 2022 (provided as Appendix I of the Draft EIR). It is noted that the Project and Project with Building A Residential/Commercial do not qualify as a “project” under Senate Bill (SB) 610, which requires preparation of a WSA (Section 10912[a] of the Water Code). Nonetheless, based on comments received on the Notice of Preparation of this Draft EIR and given that all of California’s 58 counties are under a drought emergency proclamation as of the preparation of the Draft EIR, a WSA was prepared for the Project and Project with Building A Residential/Commercial to inform the environmental analysis.

Construction activities would use approximately 4.61 million gallons (MG) or 14.1 acre-feet (af) of water for dust control purposes during demolition, excavation, grading activities, equipment Affinity Project Final EIR
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24 Findings Regarding Impacts Determined to be
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cleaning, vehicle wash downs, washout basins, and re-compaction of backfill materials, concrete pouring, and other uses. Once operational, in all water year types, including single-dry and multiple-dry years, it is anticipated that the worst case (conservative estimate) net demand of approximately 76 acre feet per year (afy) for the Project and net demand of approximately 68 afy for the Project with Building A Residential/Commercial would remain unchanged, unless consumers within the City’s service area are specifically asked to reduce water use through active conservation measures (refer to Tables 3.11-8 and 3.11-13 on pages 3.11-18 and 3.11-24). The water demand estimates include all indoor uses and landscape irrigation in all water year types.

In normal years, an annual water demand of 76 afy represents about 0.24 percent of the City’s anticipated total system supply of 31,078 afy in 2025, 0.24 percent of the supply of 31,537 afy in 2040, and 0.24 percent of the supply of 31,409 afy in 2045. An annual water demand of 68 afy represents 0.22 percent of the City’s anticipated total system supply of 31,078 afy in 2025, 0.22 percent of the supply of 31,537 afy in 2040, and 0.22 percent of the supply of 31,409 afy in 2045.

The water demand for the Project with Building A Residential/Commercial scenario is approximately 8 afy lower than for the Project. The 2020 Urban Water Management Plan (UWMP) aligns with Pasadena’s population and land use and is consistent with SCAG population and employment projections; and thereby includes potential water demands that would be generated by land use changes and new commercial and residential developments like the Project and Project with Building A Residential/Commercial. Additionally, PWP staff reviewed the WSA and concluded that the WSA meets the requirements of SB 610 and SB 221 and concurred that PWP would have sufficient water supplies to meet existing demands combined with the estimated demands of up to 76 afy and cumulative demands anticipated in the 2020 UWMP. Therefore, there would be sufficient water supplies available to serve the Project or Project with Building A Residential/Commercial and reasonably foreseeable future development during normal, dry, and multiple dry years.

The Project would include installation of new potable and fire water connections to the existing PWP water lines. As discussed in the Draft EIR, all connections to wet and dry utilities would occur to the east on South Arroyo Parkway. The proposed water infrastructure would be constructed within the site, as defined in Section 2.0 and the potential for construction-related impacts are analyzed throughout the Draft EIR, including short-term air quality (Section 3.1) and noise (Section 3.7). There would be a less than significant impacts related to water supply or infrastructure, and no mitigation is required. (Draft EIR, p. 3.11-13 through 3.11-24) Wastewater Conveyance and Treatment
The Project or Project with Building A Residential/Commercial would tie into the existing 8-inch diameter City of Pasadena sewer line within the eastern portion of Arroyo Parkway and would flow east at the connection with the 8-inch-diameter line in California Boulevard. Wastewater flow in the City’s local sewer lines serving the site discharge to either or both the Los Angeles County Sanitation Districts’ (LACSD’s) 21-inch-diameter Arroyo Seco Section 4 Trunk Sewer or 16-inch- diameter Arroyo Seco Section 5 Trunk Sewer. LACSD indicates that wastewater would be conveyed and treated at either the Whittier Narrows Water Reclamation Plant (WRP), which has a remaining capacity of 5.1 mgd, or the Los Coyotes Whittier Narrows WRP, which has a remaining capacity of 16.2 mgd. The LACSD estimates a total of 92,642 gallons per day (gpd) of wastewater generation, not including Whole Foods Market, from the Project or Project with Building A Residential/Commercial. Based on the estimated wastewater generation from existing uses on-site (not including Whole Foods Market) of 15,798 gpd of wastewater, the Project or Project with Building A Residential/Commercial would result in a net wastewater generation of approximately 76,844 gpd (0.076 million gallons a day [mgd]). Wastewater flows of approximately

0.076 mgd represent 0.1 percent of the Arroyo Seco Section 4 Trunk Sewer, 1.8 percent of the Affinity Project Final EIR
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25 Findings Regarding Impacts Determined to be
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Arroyo Seco Section 5 Trunk Sewer, 1.5 percent of the Whittier Narrows WRP, and 0.5 percent of the Los Coyotes WRP remaining capacity. Sewer line capacity is part of the City’s standard plan check/project approval process. No relocation or construction of new or expanded City- owned sewer lines has been determined necessary with Project implementation. There would be less than significant impacts related to wastewater conveyance and treatment, and no mitigation is required. (Draft EIR, p. 3.11-13 through 3.11-15)
Dry Utilities (Electrical, Natural Gas, and Telecommunications) The Project or Project with Building A Residential/Commercial would tie into existing underground electric and telecommunications lines located in the sidewalk on the west side of South Arroyo Parkway (adjacent to the site) and the existing natural gas line located along the east side of Arroyo Parkway. There are four existing natural gas meters within the eastern portion of the site; the Project or Project with Building A Residential/Commercial proposes to tie in and reuse these gas meters and associated laterals crossing under Arroyo Parkway.

Electric and natural gas services are regulated by the California Public Utilities Commission (CPUC), which requires that these utilities provide services as required by the public.

Telecommunications services are provided on demand in a free market system. The need for new, expanded, and/or relocated dry utilities would be determined as part of future individual projects and dependent on the conditions at each project site. There would be less than significant impacts related to the relocation or construction of dry utility infrastructure to serve the Project or Project with Building A Residential/Commercial, and no mitigation is required. (Draft EIR, p. 3.11- 14 and 3.11-15)
Solid Waste
Solid waste would be collected by a private hauler and may be transported to any landfill in the State with capacity that can accept the municipa l waste. The primary location that accepts City waste is Scholl Canyon Landfill. Construction of the Project or Project with Building A Residential/Commercial is conservatively estimated to generate approximately 1,125 cy of waste requiring landfill disposal after implementation of a 75 percent waste diversion pursuant to the City’s Construction and Demolition Recycling Ordinance.

The one-time disposal of approximately 1,125 cy would represent approximately 0.07 percent of Scholl Canyon Landfill’s remaining permitted capacity. Implementation of the Project was estimated to generate approximately 2,175 tons per year (approximately 5.96 tons per day) of solid waste requiring disposal after diversion or approximately 0.06 percent of Scholl Canyon Landfill’s remaining permitted capacity. The Project with Building A Residential/Commercial was estimated to generate approximately 1,433 tons per year (approximately 3.9 tons per day) of solid waste requiring disposal after diversion; this is slightly less daily solid waste generation than the Project and would represent approximately 0.04 percent of Scholl Canyon Landfill’s remaining permitted capacity.

The City implements the California Integrated Waste Management Act through Section 8.61 of the PMC, which establishes the City’s “Solid Waste Collection Franchise System”. The Project and Project with Building A Residential Commercial would be required to comply with the applicable solid waste franchise’s recycling system and would therefore meet local and State solid waste diversion regulations. In addition, the Project and Project with Building A Residential Commercial would be required to comply with the City’s Construction and Demolition Ordinance that requires diversion of at least 75 percent of the construction waste stream from landfill disposal Affinity Project Final EIR
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(Section 8.62 of the PMC). There would be less than significant impacts related to solid waste, and no mitigation is required. (Draft EIR, p. 3.11-24 through 3.11-26) Cumulative Impacts
Project and Project with Building A Residential/Commercial Water
As the Project and Project with Building A Residential/Commercial are consistent with the Project’s land use designation in the General Plan as part of planned growth within the City’s Central District, potential demand for the Project was considered as part of the PWP 2020 UWMP.

Therefore, the WSA finds that the Metropolitan Water District (MWD), as the wholesale potable water supplier has sufficient water supplies available to serve its member agencies, including PWP, now and over a 20-year planning horizon. In addition, PWP’s groundwater, including its annual groundwater credits stored in the RB, are reliable in all water year types. With that understanding, the WSA concludes that PWP has sufficient water supplies in all water year types provided through MWD and supplemented with local groundwater to meet existing demands combined with the Project demands and cumulative demands through the 20-year planning horizon of the PWP 2020 UWMP. Therefore, the Project or Project with Building A Residential/Commercial would not result in a cumulatively considerable impact related to water supplies, and no mitigation is required. (Draft EIR, p. 3.11-26 and 3.11-27) Wastewater
For wastewater conveyance and treatment services, the geographic area for consideration of cumulative impacts is the City of Pasadena (for locally owned sewer lines) and the LACSD service area (for regional facilities). The City manages its wastewater infrastructure through the Sewer Master Plan, prepared by the City’s Department of Public Works and based on forecasts of wastewater flows with buildout of the General Plan. Individual development projects in the City would be required to remit the appropriate sewer facility charge consistent with Chapter 4.53 of the PMC, which ensures that new development pays its estimated cost for any capacity upgrades to the City sewer system. Also, as discussed in the Initial Study, the Project and Project with Building A Residential/Commercial would be within the remaining development capacity of the General Plan for the Central District Specific Plan. Regarding LACSD facilities, as discussed above, the Project and Project with Building A Residential/Commercial would represent a nominal incremental contribution to regional wastewater flows requiring conveyance to and treatment at the LACSD’s WRPs. All future development projects in the LACSD’s service area would be subject to the LACSD’s Wastewater Ordinance, which includes the Connection Fee program. The Project or Project with Building A Residential/Commercial would not result in a cumulatively considerable impact to wastewater conveyance or treatment facilities, and no mitigation is required. (Draft EIR, p. 3.11-27 and 3.11-26)
Dry Utilities
Because electricity, natural gas, and teleco mmunications are provided on demand, including CPUC-regulated utilities, the expansion of services based on regional growth is part of each provider’s business strategy. Therefore, growth and development in the City is not expected to result in adverse impacts on dry utilities. The Project or Project with Building A Residential/Commercial would not contribute to a cumulatively considerable impact related to the need for new or expanded dry utilities, and no mitigation is required. (Draft EIR, p. 3.11-27 and

3.11-26)
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27 Findings Regarding Impacts Determined to be
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Solid Waste
Solid waste collection services are provided on demand by private haulers and cumulative impacts on their services from future development in the City are not expected to result in adverse impacts on solid waste collection services. Available landfill capacity is expected to decrease over time with future growth and development in the City; however, waste reduction and recycling programs and regulations are expected to reduce this demand and extend the life of existing landfills. CalRecycle is responsible for administering and monitoring State solid waste reduction initiatives, and individual jurisdiction’s ability to meet these requirements. It is assumed that CalRecycle’s role would continue into the future. Based on the available capacity of landfills in the region and the Project’s nominal contributi on of additional solid waste requiring disposal– approximately 0.06 percent of Scholl Canyon Landfill’s remaining daily permitted capacity, as a conservative analysis–the Project would not contribute to a cumulatively considerable impact to landfill capacity or solid waste regulations, and no mitigation is required. While the Project with Building A Residential/Commercial would result in slightly less solid waste generation, this would not result in a difference in the cumulative impact finding for this scenario. (Draft EIR, p. 3.11-27 and 3.11-26)
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SECTION 4.0 FINDINGS REGARDING IMPACTS MITIGATED TO BELOW A

LEVEL OF SIGNIFICANCE
The City Council finds that mitigation measures have been identified in the Final EIR that will reduce the following potentially significant environmental impacts to below a level of significance.

For each environmental topic within this category, the discussion below includes: (1) a listing of the potential impacts evaluated in the EIR related to that topic and the Draft EIR page citations where the relevant discussion begins, (2) present ation of the mitigation measure(s) (MM[s]) identified in the EIR for that topic, (3) findings pursuant to Section 15091 of the State CEQA Guidelines for that topic, and (4) explanation of the substantial evidence in support of the EIR conclusion that the impact would be reduced to a less than significant level with implementation of identified MM(s).

4.1 CULTURAL AND PALEONTOLOGICAL RESOURCES (SECTION 3.2 OF THE EIR) Potential Impacts Evaluated
 Would the Project cause a substantial adverse change in the significance of a historical resource pursuant to Section 15064.5? (Draft EIR, p. 3.2-12)  Would the project cause a substantial adverse change in the significance of an archaeological resource as defined in Section 15064.5? (Draft EIR, p. 3.2-14) Proposed Mitigation
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 (SOI) 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 Affinity Project Final EIR
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29 Findings Regarding Impacts Mitigated
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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 tr eatment 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.

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.

Findings Pursuant to Section 15091 of the State CEQA Guidelines Changes or alterations have been required in, or incorporated into, the project which avoid or substantially lessen the significant environmental effect as identified in the EIR (Section 15091[a][1] of the State CEQA Guidelines).

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Supporting Explanation
Project and Project with Building A Residential/Commercial As determined in the Historic Resources Assessment prepared for the Project and Project with Building A Residential/Commercial, the Project site contains two historic resources: the buildings at 501 and 523 South Arroyo Parkway. The buildings at 491, 495, 499, 503, and 541 South Arroyo Parkway were determined not to be individually eligible for inclusion in the California Register of Historical Resources (CRHR) or the Local Regist er. Collectively, the bu ildings located at 491, 495, 499, 501, 503, 523, and 541 South Arroyo Parkway (referred to herein as the South Arroyo Parkway Industrial District) were determined to not be locally eligible for the CRHR under Criterion A and as a City Landmark District. The assessment by PaleoWest found that the South Arroyo Parkway Industrial 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 s ubstantially altered over time, fragmenting the association of the extant buildings with their interrelated historical use, and compromising the integrity of setting, feeling, and association. (Draft EIR, p. 3-12-12) The Project or Project with Building A Residential/Commercial would not involve the demolition or other 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 or Project with Building A Residential/Commercial would change the setting of the buildings at 501 and 523 South Arroyo Parkway, 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 or Project with Building A Residential/Commercial would not result in a substantive adverse change to the historic integrity of the buildings at 501 and 523 South Arroyo Parkway. However, potential for future internal and external modifications to the buildings does exist in the form of tenant improvements. 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, to ensure any alterations to the buildings are appropriate, 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 installa tion 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 was addressed, and it was determined there is potential for some construction equipment that would be used on the site to cause cosmetic damage to these buildings because of vibration. As addressed in Section 3.7, Noise, of the 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. This is discussed Affinity Project Final EIR
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further below in Section 4.2 of this document. With implementation of MM CUL-1 and NOI-1, there would be less than significant impacts related to historic resources.

In addition, while there are no known archaeological resources within the Project site nor within ½-mile of the Project site, there is always potential to encounter previously unidentified archaeological resources during excavation in native sediments. The Project with Building A Residential/Commercial would have one less level of subterranean parking spanning both proposed buildings than the Project. However, the possibility of unknown, intact archaeological resources being present in native sediments beneath the Project site remains the same as the Project. Therefore, MM CUL-2 requires attendance by a qualified archaeologist at the pre-grade conference and identifies actions to take if cultural resources (i.e., prehistoric sites, historic sites, and/or isolated artifacts) are discovered. With implementation of MM CUL-2, there would be less than significant impacts related to archaeological resources. (Draft EIR, p. 3.2-12 through 3.2-14) Cumulative Impacts
Project and Project with Building A Residential/Commercial 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.

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 or Project with Building A Residential/Commercial would not cause a substantial adverse change in the significance of either resource as defined in Section 15064.5 with implementation of MM CUL-1. Also, implementation of MM NOI-1 would reduce t he potential for cosmetic damage to these two buildings, during construction, to a less than significant level. Therefore, the Project or Project with Building A Residential/Commercial would not result in a cumulatively considerable impact to historical resources.

Regarding archaeological resources, implementation of MM CUL-2 would reduce potential impacts to archaeological resources to a less than significant level. The more limited excavation associated with one less level of subterranean parking for the Project with Building A Residential/Commercial would not reduce the possibility of unknown, intact archaeological resources being present in native sediments beneath the site compared to the Project. 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. Therefore, the Project would not result in a cumulatively considerable impact to archaeological resources. (Draft EIR, p. 3.2-15 and 3.2-16)
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4.2 NOISE (SECTION 3.7 OF THE DRAFT EIR)
Potential Impacts Evaluated
 Would the project result in generation of excessive ground-borne vibration or ground-borne noise levels? (Draft EIR, 3.7-17)
Proposed Mitigation
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 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 Affinity Project Final EIR
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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 preservati on 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.

Findings Pursuant to Section 15091 of the State CEQA Guidelines Changes or alterations have been required in, or incorporated into, the project which avoid or substantially lessen the significant environmental effect as identified in the EIR (Section 15091[a][1] of the State CEQA Guidelines).

Supporting Explanation
Project and Project with Building A Residential/Commercial During construction, neither pile driving nor blasting (generally the sources of the most severe vibration) would be used during Project construction. The Project would generate vibration during demolition, grading and excavation, and building construction. Estimated vibration levels when construction activities occur under the closest distance to each receptor would not exceed the vibration annoyance criteria but may exceed the building damage threshold at remaining on-site structures within the Project site (i.e., Whole Foods Market and 501 and 523 South Arroyo Parkway) during nearby construction activity (refer to Table 3.7-9 on page 3.7-18 of the Draft EIR). The only difference in the construction scenario for the Project with Building A Residential/Commercial is that subterranean parking is reduced to four levels (instead of five).

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to Below a Level of Significance
because there would be the same daily construction activities. Therefore, MM NOI-1 requires that certain construction activities/equipment be set back from these buildings, that vibration monitoring is implemented, and, if cosmetic damage does occur despite setbacks and monitoring, the Project Applicant shall be responsible for restoring the damage. With implementation of MM NOI-1, there would be less than significant impac ts related to vibration causing damage to the three on-site buildings being retained during construction of the Project or Project with Building A Residential/Commercial. (Draft EIR, p. 3.7-17 and 3.7-18) Cumulative Impacts
Project and Project with Building A Residential/Commercial Vibration generated during construction of the Project or Project with Building A Residential/Commercial would be localized and would occur intermittently for varying periods of time throughout the construction period. Short-term cumulative vibration generated by construction of the Project or Project with Building A Residential/Commercial could occur with the combination with another project with major construction activity within approximately 1,000 feet of the site. At the time of preparation of the Draft EIR, there were no projects within 1,000 feet that were anticipated to be constructed concurrently with the Project or Project with Building A Residential/Commercial. As such, the Project would not result in a cumulatively considerable construction vibration impact. (Draft EIR, p. 3.7-19 and 3.7-20)

4.3 TRIBAL CULTURAL RESOURCES (SECTION 3.10 OF THE DRAFT EIR)  Would the project cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is: a resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code Section 5024.1? In applying the criteria set forth in subdivision (c) of Public Resources Code Section 5024.1, the lead agency shall consider the significance of the resource to a California Native American tribe. (Draft EIR, p. 3.10-4) Proposed Mitigation
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 on-site 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 descrip tions 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 Affinity Project Final EIR
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35 Findings Regarding Impacts Mitigated
to Below a Level of Significance
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 or igin, 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 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.

Findings Pursuant to Section 15091 of the State CEQA Guidelines Changes or alterations have been required in, or incorporated into, the project which avoid or substantially lessen the significant environmental effect as identified in the EIR (Section 15091[a][1] of the State CEQA Guidelines).

Supporting Explanation
Project and Project with Building A Residential/Commercial Based on consultation with the Gabrieliño Tongva Tribe and Gabrieliño Band of Mission Indians – Kizh Nation pursuant with AB 52; the results of an archaeological records search conducted by the SCCIC on July 24, 2020; and NAHC Sacred Lands File search received on July 15, 2020, there are no tribal cultural resources listed on the CRHR or a local register within the site or otherwise known to the culturally affiliated Native American tribes. However, there is always the possibility that undiscovered intact cultural resources, including tribal cultural resources, may be present below the surface and encountered during excavation in native sediments. Although the Project with Building A Residential/Commercial would involve slightly less excavation and therefore somewhat less likelihood of encountering an unknown tribal cultural resource, there is Affinity Project Final EIR
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36 Findings Regarding Impacts Mitigated
to Below a Level of Significance
always the possibility that unknown resources may be present. Therefore, MM TCR-1 requires the Project Applicant to accommodate a Native American Monitor culturally affiliated with the site as recognized by the NAHC prior to the commencement of any ground-disturbing activity on the site. MM TCR-1 also defines the role of the Tribal Monitor, if such an individual elects to be present during construction of the Project, and the steps required if a potential tribal cultural resource is encountered during ground-disturbing activities. With implementation of MM TCR-1, there would be a less than significant impact related to tribal cultural resources. (Draft EIR, p. 3.10-4 and 3.10-5)
Cumulative Impacts
Project and Project with Building A Residential/Commercial The cumulative impacts related to demographic growth are analyzed for the City of Pasadena.

Direct impacts to tribal cultural resources are generally site specific. However, development throughout the City could potentially result in the disturbance of prehistoric archaeological resource sites (including tribal cultural resources/Native American remains). The City participates in Native American consultation consistent with AB 52 and SB 18 (when applicable). This process, in combination with site-specific archaeological studies, and any resulting site-specific mitigation measures (typically monitoring and processe s to manage any unanticipated resources), would contribute to the reduction of potential tribal cultural resource impacts to the maximum extent feasible. Because there are no documented tribal cultural resources on the site and MM TCR-1 would be implemented, the Project or Project with Building A Residential/Commercial would not result in a cumulatively considerable impact to tribal cultural resources. (Draft EIR, p. 3.10-5 and 3.10-6)
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37 Resolution Regarding Alternatives
SECTION 5.0 FINDINGS REGARDING ALTERNATIVES
The City Council declares that the City has considered and rejected as infeasible Alternatives 1 through 4 identified in the EIR as set forth herein. In compliance with Section 15126.6(a) of the State CEQA Guidelines, an EIR must describe and evaluate the comparative merits of a reasonable range of alternatives to the project, or to the location of the project, which would (1) feasibly attain most of the basic objectives of the project but would avoid or substantially lessen any significant effects of the project and (2) may be feasibly accomplished in a successful manner within a reasonable period of time considering the economic, environmental, social, and technological factors involved. Additionally, an EIR need not address alternatives that are infeasible, and the consideration of alternatives is governed by the rule of reason. (Draft EIR, p. 4-1)
The Lead Agency is required to identify the environmentally superior alternative, but it is not required to choose the environmentally superior alternative for approval over the project if the alternative does not provide substantial advantages over the project (i.e., does not avoid or substantially reduce to less than significant impact[s] that would otherwise occur from the project); does not attain most of the project objectives; or is infeasible due to social, economic, technological, or other considerations.

The EIR identified the following objectives for the Project and Project with Building A Residential/Commercial (see Draft EIR, p. 4-2 and 4-3):

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.

The alternatives analyzed in the EIR represent a reasonable range of alternatives to the Project and Project with Building A Residential/Commercial based on the applicable provisions of CEQA and the State CEQA Guidelines.

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38 Resolution Regarding Alternatives

5.1 ALTERNATIVES CONSIDERED BUT REJECTED
The following alternatives were considered during the scoping and planning process but were not selected for detailed analysis in the Final EIR, as discussed below.

Alternative Site
CEQA requires that the discussion of alternatives focus on alternatives to the project or its location, which are capable of avoiding or substantially lessening any significant effects of the Project. Only locations that would avoid or substantially lessen any of the significant effects of the Project need be considered for inclusion in the Final EIR (Section 15126.6[f][2][B] of the State CEQA Guidelines). The Project site is a 3.3-acre property that is presently owned by the Applicant.

There are no vacant or underutilized sites of sufficient size along Arroyo Parkway and within walking distance of multiple transit facilities that could feasibly accommodate the Project.

Additionally, the Applicant does not own other feasible alternative sites, and the City is not aware of any other feasible alternative location that would avoid or substantially lessen any potential significant impact of the Project. Further, the Applicant cannot be expected nor required to acquire, control, or have access to another site that could accommodate the Project. Therefore, due to lack of viable and comparable sites in the site vicinity that would allow for development of the Project in a manner that would avoid or subs tantially lessen the Project’s significant impacts (before mitigation), development of the Project on an alternative site was rejected from consideration. (Draft EIR, p. 4-4 through 4-5)
Project with No Variance for Historic Resources
An alternative PD project without a variance for historic resources to increase the height of Buildings A and B was considered. This alternative would result in a total of 401,171 sf of aboveground development (including the 73,671-sf Whole Foods Market). To accommodate a project of this size, this alternative would involve demolition of 8 (of the 9) existing buildings, including the two historic buildings, totaling 51,794 sf, and construction of 327,500 sf of new development in 2 buildings representing a FAR of 2.77. These buildings would have up to 5 stories and maximum heights, including parapets, of 65 feet (with height averaging). This alternative would have up to 709 parking spaces in 5 subterranean levels. While there are no significant and unavoidable impacts associated with the Project or Project with Building A Residential/Commercial, this alternative would result in a new significant impact due to demolition of two historic buildings that would be considered significant and unavoidable. Therefore, this alternative was rejected from consideration. (Draft EIR, p. 4-5)

5.2 ALTERNATIVES SELECTED FOR FURTHER ANALYSIS
The alternatives described below were determined to represent a reasonable range of alternatives and were carried forward for detailed consideration in the EIR, which are further described in this section:
 Alternative 1: No Project/No Development,
 Alternative 2: Project Development with Existing Zoning,  Alternative 3: All Residential Project with Variance for Historic Resources, and  Alternative 4: All Medical Office Project with Variance for Historic Resources. (Draft EIR, p. 4-3)
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39 Resolution Regarding Alternatives
With respect to the No Project alternative, Section 15126.6(e) of the State CEQA Guidelines requires than a Draft EIR evaluate a “no project” alternative to allow decision makers to compare the impacts of approving a proposed Project with the impacts of not approving that proposed Project. Section 15126.6(e)(3) of the State CEQA Guidelines describes the two general types of no project alternative: (1) when the proposed Project is the revision of an existing land use or regulatory plan, policy, or ongoing operation, the no project alternative would be the continuation of that plan and (2) when the proposed Project is other than a land use/regulatory plan, such as a specific development on an identifiable property, the no project alternative is the circumstance under which that proposed Project is not processed (i.e., no development). The second type of no project alternative was addressed in the EIR (refer to Alternative 1). (Draft EIR, p. 4-6) For the build alternatives, it is assumed t hat regulatory requirements and project-specific mitigation measures identified for the Project and Project with Building A Residential/Commercial would also be implemented with these alternatives (Alternatives 2 through 4), and thus serve to reduce or avoid the potentially significant impacts similar to the Project and Project with Building A Residential/Commercial. (Draft EIR, p. 4-6)

5.2.1 ALTERNATIVE 1: NO PROJECT/NO DEVELOPMENT
Description: Under the No Project/No Development Alternative, as required by CEQA, the existing environmental setting would remain unchanged. The City would not approve a PD Plan and rezone the site to a PD zone 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 improvements and would continue the use and operation of the existing land uses present at the time the NOP was distributed in August 2021. (Draft EIR, p. 4-6)
Finding: The No Project/No Development Alternative would avoid all potential impacts from the Project or Project with Building A Residential/Commercial, which are less than significant for each environmental topic addressed in this Draft EIR with adherence to applicable regulations and implementation of mitigation, which would be required during construction only. However, in the absence of the Project or Project Building A Residential/Commercial, no land use benefits would be achieved. Also, Alternative 1 would not meet any of the Project objectives. Therefore, the City rejects Alternative 1: No Project/No Development. (Draft EIR, p. 4-9)

5.2.2 ALTERNATIVE 2: PROJECT DEVELOPMENT WITH EXISTING ZONING Description: 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). The site is zoned CD-6 (Central District, Arroyo Corridor/Fair Oaks subdistrict).

Alternative 2 is analyzed with two scenarios, where appropriate based on the results of the comparative analysis, same as the Project. Alternative 2 would result in a total of 217,280 sf of aboveground development, including the 79,553 sf of existing development to be retained. This amount of total aboveground development reflects the 1.5 FAR consistent with CD-6 zoning. This alternative would involve demolition of 6 (of the 9) existing buildings totaling 45,912 sf, same as the Project or Project with Building A Residential/Commercial, and construction of 2 new buildings with 137,727 sf of new development. Based on the same proportions of proposed land uses with the Project and Project with Building A Residential, Alternative 2 would result in the following:
 Building A: a 62,682-sf, 5-story (aboveground) medical office building with 3,000 sf ground-floor commercial uses;
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40 Resolution Regarding Alternatives
 Building B: a 75,045-sf, 5-story (aboveground) assisted living building with 34,922 sf of assisted living uses and 40,123 sf of independent living uses including up to 51 2 senior housing units; and
 Up to 387 parking spaces in 3 subterranean levels.3
Like the Project with Building A Residential/Commercial, Alternative 2 could result in the following in Building A (referred to herein as Alternative 2 with Building A Residential/Commercial):
 3,000 sf of commercial and a sales/leasing management office on the ground floor;  Up to 108 residential dwelling units 4; and
 Up to 282 parking spaces in 2 subterranean levels (1 fewer level than Alternative 2 as proposed above)2.

Alternative 2 would have maximum building heights, including parapets, of 50 feet or 65 feet with height averaging. This alternative assumes the historic resources would be retained and incorporated into the design, but with no variance proposed. Alternative 2 assumes the retained historic buildings would operate as restaurants, same as the Project. Because the same building footprints as the Project are assumed under Alternative 2, the same number and locations of trees would be removed, and the planting of two new street trees would be required. The points of ingress/egress and on-site circulation would be the same as the Project.

Alternative 2 would involve the same construction phases and overall schedule as the Project, with construction beginning in 2023 over approximately 34 months. While the overall scope of this alternative is reduced compared to the Project, it would remain as a substantial building effort.

Because there would be fewer levels of subterranean parking, based on a proportional reduction in grading per level for the Project, this alternative would involve the following volumes of excavation and export:
 Alternative 2: approximately 110,406 cy of soil generating an estimated 7,886 one-way truck trips over the course of 4 months (103 workdays); and  Alternative 2 with Building A Residential/Commercial: approximately 73,604 cy of soil, generating an estimated 5,257 one-way truck trips over the course of 4 months (103 workdays). (Draft EIR, p. 4-9 through 4-11)
Finding: Alternative 2 and Alternative 2 with Building A Residential/Commercial would result in comparatively reduced impacts related to air q uality, GHG emissions, noise, public services, recreation, transportation, and utilities and service systems. This alternative would result in similar impacts related to cultural and paleontological resources, hazards and hazardous materials, land

2 Based on the same proportion of housing units with implementation of t he Project with Building A Residential/Commercial (68 percent market rate resident ial and 32 percent senior living units) to the maximum dwelling units that would be permitted with 48 du/ac (159). In other words, 159 * 0.68 = 108 residential units; 159 – 108 = 51 senior units.
3 Based on off-street parking requir ements specified in Chapter 17.46 of the PMC. For building B assisted living where parking is determined through t he entitlement process, the allocation is based on the same proportion of parking spaces with implementation of the Project and Project with Building A Residential/Commercial. 4 Based on the same proportion of housing unit s with implementation of t he Project with Building A Residential/Commercial (68 percent market rate resident ial and 32 percent senior living units) to the maximum dwelling units that would be permitted with 48 du/ac (159). In other words, 159 * 0.68 = 108 residential units; 159 – 108 = 51 senior units.

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41 Resolution Regarding Alternatives
use and planning, and tribal cultural resources. Regarding energy, while this Alternative would result in a reduced VT and VMT compared to the Project and Project with Building A Residential/Commercial, it would also represent a less efficient use of the site. This Alternative would result in the same amount of demolition to redevelop an underutilized site and the resulting development would be approximately half as dense as the Project. Notably, this Alternative would not reduce any of the impacts identified for the Project or Project with Building A Residential/Commercial that would require mitigation during construction to reduce the impacts to a less than significant level. This alternative fails to meet many of the Project objectives.

Specifically, Alternative 2 and Alternative 2 with Building A Residential/Commercial would only partially meet Project objectives 1 through 7. Therefore, the City rejects Alternative 2: Project Development with Existing Zoning. (Draft EIR, p. 4-15)

5.2.3 ALTERNATIVE 3: ALL RESIDENTIAL PROJECT WITH VARIANCE FOR HISTORIC

RESOURCES
Description: Alternative 3 assumes the demolition of 6 (of the 9) existing buildings totaling 45,912 sf, construction of 2 new buildings totaling 338,376 sf, and 79,553 sf of existing development to be retained, same as the Project or Project with Building A Residential/Commercial. 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.

Alternative 3 would result in a total of 417,929 sf of aboveground development, including the existing buildings to be retained, as follows:
 Building A: a 154,000-sf, 7-story (aboveground) residential building and ground-floor commercial uses;
 Building B: a 184,376-sf, 7-story (aboveground) residential building; and  Up to 607 parking spaces in 4 subterranean levels.

Alternative 3 would have maximum building heights, including parapets, of 93.5 feet, the same as the Project. This alternative assumes the historic resources would be retained and incorporated into the design with a variance for historic resources proposed. Alternative 3 assumes the retained historic buildings would operate as restaurants, same as the Project. Because the same building footprints are assumed under Alternative 3 as the Project, the same number and locations of trees would be removed, and the planting of two new street trees would also be required as a planned condition of approval. The points of ingress/egress and on-site circulation would be the same as the Project.

Alternative 3 would involve the same construction phases and overall schedule as the Project, with construction beginning in 2023 over approximately 34 months. Because there would be one fewer level of subterranean parking, like the Project with Building A Residential/Commercial that has one less subterranean level than the Project, Alternative 3 would involve 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. (Draft EIR, p. 4-15 through 4-16)
Finding: Alternative 3 would result in comparatively reduced impacts related to air quality, energy, GHG emissions, public services, recreation, transportation, and utilities and service systems. For all other topics, including cultural and paleontological resources, hazards and hazardous materials, land use and planning, noise, and tribal cultural resources, Alternative 3 would result in similar impacts. Notably, this alternative would not reduce any of the impacts identified for the Affinity Project Final EIR
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42 Resolution Regarding Alternatives
Project and Project with Building A Residential/Commercial that would require mitigation during construction to reduce the impacts to a less than significant level. This alternative fails to meet many of the Project objectives. Specifically, Al ternative 3 would meet objectives 5, 6, and 7; partially meet objectives 1 and 2; and not meet objectives 3 and 4. Therefore, the City rejects Alternative 3: All Residential with Variance for Historic Resources. (Draft EIR, p. 4-20)

5.2.4 ALTERNATIVE 4: ALL MEDICAL OFFICE WITH VARIANCE FOR HISTORIC

RESOURCES
Description: Alternative 4 assumes the demolition of 6 (of the 9) existing buildings totaling 45,912 sf, construction of 2 new buildings totaling 338,376 sf, and 79,553 sf of existing development to be retained, the same as the Project or Project with Building A Residential/Commercial. However, Alternative 4 assumes the new buildings would in clude solely medical office uses except for ground-floor commercial in Building A. Alternative 4 would result in a total of 417,929 sf of aboveground development, including the existing buildings to be retained, as follows:
 Building A: a 154,000-sf, 7-story (aboveground) medical office building and ground-floor commercial uses;
 Building B: a 184,376-sf, 7-story (aboveground) medical office building; and  Up to 1,218 parking spaces in 7 subterranean levels.

Alternative 4 would have maximum building heights, including parapets, of 93.5 feet, the same as the Project. This alternative assumes the historic resources would be retained and incorporated into the design with a variance for historic resources proposed. Alternative 4 assumes the retained historic buildings would operate as restaurants, the same as the Project. Because the same building footprints are assumed under Alternative 4 as the Project, the same number and locations of trees would be removed, and the planting of two new street trees would be required. The points of ingress/egress and on-site circulation would be the same as the Project.

Alternative 4 would involve the same construction phases and overall schedule as the Project, with construction beginning in 2023 over approximately 34 months. Because Alternative 4 would propose two additional levels of subterranean parking, based on a proportional increase in grading per level for the Project, Alternative 4 would involve the excavation and export of approximately 257,614 cy of soil generating an estimated 18,401 one-way truck trips over the course of 4 months (103 workdays). This alternative would result in approximately 40 percent more excavation (or 73,604 cy) than the Project and approximately 75 percent more excavation (or 110,406 cy) than the Project with Building A Residential/Commercial. (Draft EIR, p. 4-21) Finding: Alternative 4 would result in comparatively increased impacts related to air quality, energy, GHG emissions, land use and planning, and utilities and service systems. For transportation, the impacts of Alternative 4 related to conflict with the City’s TIA Guidelines would be comparatively greater, and impacts related to all other transportation issues (circulation system policies, traffic safety, and emergency access) would be similar. For public services and recreation, Alternative 4 would result in comparatively reduced impacts. For all other topics, including cultural and paleontological resources, hazards and hazardous materials, noise, and tribal cultural resources, Alternative 4 would result in similar impacts. Notably, this Alternative would not reduce any of the impacts identified for the Project and Project with Building A Residential/Commercial that would require mitigation during construction to reduce the impacts to a less than significant level. This alternative fails to meet several of the Project objectives.

Specifically, Alternative 4 would meet objectives 1, 2, 6, and 7; would not meet objectives 3 and 4; Affinity Project Final EIR
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43 Resolution Regarding Alternatives
and would partially meet objective 5. Therefore, the City rejects Alternative 4: All Medical Office with Variance for Historic Resources. (Draft EIR, p. 4-25 through 4-26)

5.3 ENVIRONMENTALLY SUPERIOR ALTERNATIVE
CEQA requires the identification of an environmentally superior alternative. Section 15126.6(e)(2) of the State CEQA Guidelines states that if the No Project Alternative is the environmentally superior alternative, then the EIR shall also identify an environmentally superior alternative among the other alternatives. Accordingly, in accordance with the State CEQA Guidelines, a comparative evaluation of the alternatives discussed above indicates that Alternative 3 is the environmentally superior alternative because of (1) reduced comparative impacts, (2) the extent of the reduction in VT and VMT per capita compared to both the Project and Project with Building A Residential/Commercial while maximizing the redevelopment of an underutilized site near transit, and (3) a greater consistency with local, regional, and State policies adopted for the purpose of avoiding or reducing an environmental effect. However, none of the build alternatives would reduce or eliminate the significant impacts of the Project and Project with Building A Residential/Commercial with or without mitigation. This is because these impacts are related to construction activity and would occur regardle ss of the scope of construction. Specifically, potential impacts to cultural and tribal cultural resources are associated with any excavation in both disturbed and native soils. The potential impact related to vibration damage to the existing on-site buildings to remain would occur with any of the alternatives because the same type(s) of construction activity and equipment that could result in this impact would be used. (Draft EIR, p. 4-26 through 4-29)
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44 Finding Regarding Significant Irreversable Environmental Shanges SECTION 6.0 FINDING REGARDING SIGNIFICANT IRREVERSIBLE

ENVIRONMENTAL CHANGES
Section 15126(c) of the State CEQA Guidelines requires an EIR to discuss the significant irreversible environmental changes that would occur because of the project. Generally, an impact would occur under this category if, for example: (1) the proposed consumption of resources is not justified (e.g., the project involved the wasteful or inefficient use of energy); (2) the project would involve a large commitment of nonrenewable resources; or (3) the project would involve uses in which irreversible damage could result from any potential environmental accidents associated with the project.

Implementation of the Project would convert all but two of existing commercial buildings to a medical office building, commercial uses, and an assisted living building with subsurface parking and related improvements. The Project with Building A Residential/Commercial would convert the site into a residential building, commercial uses, and an assisted living building. Because the proposed uses would be a redevelopment of the site, neither the Project nor Project with Building A Residential/Commercial is considered a new long-term commitment of land resources.

Nevertheless, construction activities would result in the irretrievable commitment of nonrenewable energy resources, primarily in the form of fossil fuels (including fuel oil), natural gas, and gasoline for automobiles and construction equipment. However, the Project or Project with Building A Residential/Commercial would not be creating a need for jobs or housing. The resulting growth under either scenario would fulfill an existing and anticipated future need that is based on estimates of local and regional population growth. Therefore, the non-renewable resources used in construction would be expected to be consumed by housing and employment-generating land uses that are anticipated, and are unfulfilled, in the City and the wider region. Additionally, the land uses proposed are not unusually wasteful or excessive in terms of construction materials and fossil fuel use.

Over the long term, operation of the new land uses would require the commitment and reduction of nonrenewable and slowly renewable resources, including petroleum fuels and natural gas (for vehicle emissions, lighting, heating, and cooling of structures). Other resources that are slow to renew and/or recover from environmental stressors would also be impacted by long-term implementation of the Project or Project with Building A Residential/Commercial. However, the proposed uses would be required to meet Title 24 energy efficiency standards and applicable CALGreen requirements. As such, operation of the proposed uses would be more energy efficient than any existing uses on the site. Additionally, the land uses proposed are not unusually wasteful or excessive in terms of fossil fuel use. This is in part because of the higher density development for the Project site. Nonetheless, the Project or Project with Building A Residential/Commercial represent a long-term commitment of essentially non-renewable resources.

Regarding the potential for irreversible damage caused by environmental accidents, while construction and operation of the Project or Project with Building A Residential/Commercial would result in the use, transport, storage, and disposal of hazardous materials and/or wastes typical of urban areas, such as associated with medical/health care facilities, dry cleaners, restaurant and office cleaning/maintenance, and landscape maintenance, all activities would comply with applicable State and federal laws related to hazardous materials transport, use, and storage. This would significantly reduce the likelihood and severity of accidents that could result in irreversible environmental damage, and such an accident resulting in irreversible damage is not considered reasonably foreseeable. (Draft EIR, p. 5-1 and 5-2)
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45 Finding Regarding Growth Inducing Impacts
SECTION 7.0 FINDING REGARDI NG GROWTH-INDUCING IMPACTS
Sections 15126(d) and 15126.2(e) of the State CEQA Guidelines require and EIR to discuss the ways in which the project could foster economic or population growth, or the construction of additional housing, either directly or indirectly, in the surrounding environment. Growth inducements; however, is not considered necessarily detrimental, beneficial, or significant to the environment.

Removing Obstacles to Growth
No major new infrastructure facilities are required to support the Project or Project with Building A Residential/Commercial beyond the new connections to existing utilities that would be constructed on the site. Approval of the PD Zoning District and PD Plan (this includes approval of the Affinity Project, zoning map amendment to rezone the property from CD-6 to PD-39, and variance for Historic Resources for Building Height) would be required to allow for development of the Project or Project with Building A Residential/Commercial. But these changes would be specific to the Project site and would not remove obstacles to growth in the surrounding area. The proposed uses under either scenario are in line with the collective uses and growth within the area and part of the development in the City that has been trending toward greater density development. (Draft EIR, p. 5-3)
Expansion of Public Services
None of the public service agencies consulted—Pasadena Fire Department; Pasadena Police Department; Pasadena’s Parks, Recreation, and Community Services Department; and Pasadena Public Library—during the preparation of this Draft EIR indicated that the Project or Project with Building A Residential/Commercial would necessitate the immediate expansion of their existing resources to maintain desired levels of service. While Pasadena Unified School District was consulted, there was no response. However, Senate Bill 50 establishes developer fees that are considered full and complete mitigation for school facilities. If any public service agency’s resources do need to be expanded because of Citywide growth, funding mechanisms are in place through existing regulations to accommodate such growth. (Draft EIR, p. 5-4) Facilitating Economic Effects
During construction of the Project or Project with Building A Residential/Commercial, a number of design, engineering, and construction-related jobs would be created at the site. This would be a temporary situation, lasting until construction is completed. The construction crew would obtain commercial goods and services from existing businesses near the site. This would provide economic stimulus in the area; however, these jobs are typically filled by existing residents of the region and would not be substantial enough to foster other activities (e.g., new real estate development) that would have significant effects on the environment.

Operation of the Project would result in up to 222 residents, 737 employees, and up to 694 visitors per day. Operation of the Project with Building A Residential/Commercial would result in up to 715 residents, 95 employees, and up to 128 visitors per day. This would represent an increased demand for economic goods and services in the Project area and could, therefore, encourage the creation of new businesses, the expansion of existing businesses, or investment in commercial uses near the site that address these economic needs. At any given time, there are a variety of vacant commercial buildings for sale or lease available throughout the City that can accommodate future business. New commercial or mixed-use development not utilizing existing buildings at the Affinity Project Final EIR
Findings of Fact

46 Finding Regarding Growth Inducing Impacts
respective site would generally involve site redevelopment. Regarding expansion of commercial uses in the City resulting in environmental impacts, both the use of existing buildings (and related updates) or redevelopment of a site are generally relatively low impact activities compared to development on greenfields and/or locations without existing utility and transportation infrastructure. While there could be an indirect, growth-inducing effect caused by the Project (or Project with Building A Residential/Commercial), such development would be within the growth anticipated for the City. As of the time of Draft EIR preparation, there is over 3.3 million commercial square feet of remaining development capacity throughout the City pursuant to the City’s General Plan (refer to Table 2-5 on page 2-17 of the Draft EIR). Demand for housing from on-site employees not already living in the City may also increase occupancy in the City’s vacant dwelling units (estimated at 11,479 dwelling units in May 2021). Additionally, any demand for housing from employees would also be within the growth anticipated for the City, as there are 2,483 residential units in the City’s remaining development capacity as of October 2021. The environmental impacts of future development near the site would have to be considered by the City as part of individual environmental reviews, in accordance with CEQA. (Draft EIR, p. 5-4 and 5-5) Precedent-Setting Action
The Project and Project with Building A Residential/Commercial would not require a General Plan amendment, but approval of a PD district and PD Plan. 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 Resident ial/Commercial is developed as intended.

Development of the Project site using a PD Plan is not precedent setting because it is an existing, accepted part of the Pasadena Zoning Code.

No changes to any of the City’s building safety standards (i.e., building, grading, plumbing, mechanical, electrical, fire codes) are proposed or required to implement this Project or Project with Building A Residential/Commercial. Mitigation measures have been identified to require that Project implementation complies with all applicable federal, State, regional, and City standards and ordinances to ensure that there are no conflicts with applicable land development regulations and that environmental impacts are minimized. Finally, creation of commercial, medical, assisted living, and/or residential facilities is not unique, such that its implementation would set a precedent, facilitating other activities and resulting in significant impacts to the environment.

While the Project may induce development or redevelopment at parcels within the Project area, the potential for reuse of unutilized commercial structures and the (re)development of lands in the surrounding area are subject to property owner discretion and often largely influenced by regional economic conditions and market demands that may have limited or major links to the Project. Site improvements may make adjacent areas more attractive to investors and promote redevelopment. These future projects would require independent environmental review under CEQA. Therefore, the impacts of subsequent proposals would require environmental analysis and associated mitigation to avoid or minimize their potential subsequent impacts. (Draft EIR, p. 5-5)

ATTACHMENT G

RESPONSE TO COMMENTS RECEIVED AFTER END OF DRAFT EIR PUBLIC REVIEW PERIOD

225 South Lake Avenue, Suite 1000 Pasadena, CA 91101 T: (626) 351-2000 F: (626) 351-2030

MEMORANDUM

June 3, 2022

To: From:

Jason Van Patten
City of Pasadena
Planning and Community Development Department

Jillian Neary
Tin Cheung
Subject: Response to Comments Received After End of Draft EIR Public Review Period (1 of 2)

The following presents responses to comments submitted by Advocates for the Environment, in a letter dated May 2, 2022 (Attachment A), on the Affinity Project Draft Environmental Impact Report (EIR). The 45-day public comment period for the Affinity Draft EIR closed on March 3, 2022. Accordingly, there is no requirement in the California Environmental Quality Act (CEQA) that the City of Pasadena (City) respond to these comments. However, in the interest of full disclosure and public participation, the City responds herein. This comment letter has been divi ded into sequential numbered comments, is attached, and corresponding City of Pasadena responses are provided below.

Advocates for the Environment
May 2, 2022
Response 1. As discussed first on page 3.4-19 of the Draft EIR, “A lead agency may assess the significance of GHG emissions by determining a project’s consiste ncy with a local GHG reduction plan or CAP [that qualifies under Section 15183.5 of the State CEQA Guidelines”. While many municipalities do not yet have a local GHG reduction plan, the City of Pasadena adopt ed its current climate action plan (CAP) on March 5, 2018.

Section 3.4, Greenhouse Gas Emissions, of the Draf t EIR provides a detailed quantitative analysis of greenhouse gas (GHG) emissions for both the Project and Project with Building A Residential/Commercial as part of the Threshold 3.4a analysis beginning on page 3.4-14 with suppor ting data in Appendix B.

Furthermore, the analysis of Threshold 3.4b does discu ss the appropriate efficiency metric from the CAP, as being a relevant plan, policy, or regulation adopted for the purpose of reducing GHG emissions.

However, most of the analysis under Threshold 3.4b discusses the most relevant State and regional plans, policies, and regulations. As such, the assertions that the GHG emissions analysis “almost exclusively” focuses on Threshold 3.4b and the Draft EIR “briefly and conclusively” mentions consistency with plans other than the CAP are both inaccurate and unsubstantia ted. Further, there is no requirement in CEQA or the State CEQA Guidelines nor is it generally appropr iate or warranted to assess a project against every relevant program or policy. The GHG emissions analysis was prepared fully in accordance with both CEQA and the State CEQA Guidelines and the state of the practice. Finally, note that the comments regarding the analysis in Threshold 3.4b center around the CAP’s Checklist and the alignment of the Checklist with the CAP; however, this is not the question posed by CEQA related to GHG emissions. Threshold 3.4b asks whether the Project (or Project with Building A Resi dential/Commercial) conflicts with the CAP, and not whether the CAP and Checklist are “in alignment” (which they are). Accordingly, as an overarching matter, the comments in this regard are i rrelevant to whether an adequate CE QA analysis and disclosure were presented. Please refer to Responses 2 through 10 and 14 below.

Response 2. As expressed on page 10 of the Pasadena CAP, the purpose of the CAP is, “to analyze GHG emissions at a programmatic-level, outline a strate gy to reduce and mitigate municipal and community- wide GHG emissions, demonstrate Pasadena’s commitment to achieving the state-wide emissions reduction Jason Van Patten
June 3, 2022