Pasadena City Council
November 21, 2022

Planned Development #39 (Affinity Project)
City Council

ATTACHMENT G

FINAL EIR AND ERRATA
Final Environmental Impact Report
Affinity Project
SCH No. 2021080103
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
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TABLE OF CONTENTS
Section Page
Section 1.0 Introduction ......................................................................................................... 2

1.1 Public Review Process .............................................................................. 2 Section 2.0 Responses to Comments ................................................................................... 4

2.1 List of Environmental Impact Report Commenters .................................... 5

2.2 Written Comments and City of Pasadena Responses ............................. 14 Section 3.0 Draft EIR Clarifications and Revisions ............................................................ 79 Section 4.0 Mitigation Monitoring and Reporting Program ............................................... 83 TABLES
Table Page
1 List of Commenters ........................................................................................................... 5 2 Doubled Additional Street Segment ADT with the Project (Year 2026) .......................... 64 3 Affinity Project Mitigation Monitoring and Reporting Program ......................................... 84 Appendices
A Attachments to Los Angeles County Metropolitan Transportation Authority Letter B Certified Arborist Resume (David T. Hughes)
Affinity Project Final EIR
R:\Projects\PAS_Pasaden\3PAS012100\Environmental Documentation\RTC\Final_Affinity RTC_Revisions_MMRP-051222.docx 2 Introduction SECTION 1.0 INTRODUCTION
In accordance with Section 15088, 15089, and 15132 of the California Environmental Quality Act (CEQA) Guidelines, the City of Pasadena (City), as the Lead Agency, has prepared this Final Environmental Impact Report (EIR) for the Affinity Project (Project or Project with Building A Residential/Commercial) (State Clearinghouse [SCH] No. 2021080103).

According to Section 15132 of the State CEQA Guidelines, the Final EIR shall consist of:
a) The draft EIR or a revision of the draft;
b) Comments and recommendations received on the Draft EIR either verbatim or in summary;
c) A list of persons, organizations, and public agencies commenting on the draft EIR;
d) The responses of the Lead Agency to significant environmental points raised in the review and consultation process; and
e) Any other information added by the Lead Agency.

Accordingly, this Final EIR constitutes the second 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 and is hereby incorporated by reference under separate cover.

This Final EIR document is organized as follows:

Section 1.0 provides a brief introduction to this document and a summary of the public review process.

Section 2.0 provides a list of the parties that commented on the Draft EIR is provided, followed by a copy of each comment letter and the City’s responses to each comment received.

Section 3.0 contains revisions and clarifications to the Draft EIR because of the comments received from all commenting parties.

Section 4.0 provides the Mitigation Monitoring and Reporting Program (MMRP), which describes the mitigation program to be implemented by the City for the Project.

1.1 PUBLIC REVIEW PROCESS
In compliance with Section 15201 of the State CEQA Guidelines, the City has provided opportunities for the public, organizations, and public agencies to participate in the environmental review process (as discussed below) and/or to provide comments on the Draft EIR.

On August 3, 2021, the City distributed an Initial Study (IS)/ Notice of Preparation (NOP) to 291 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. The IS/NOP was submitted to the State Clearinghouse, and the NOP was filed with the Los Angeles County Registrar-Recorder/County Clerk.

The City held two virtual scoping meetings–one on August 11, 2021 (at Planning Commission) and one on August 26, 2021–to describe the Project, answer questions, and seek public input Affinity Project Final EIR
R:\Projects\PAS_Pasaden\3PAS012100\Environmental Documentation\RTC\Final_Affinity RTC_Revisions_MMRP-051222.docx 3 Introduction regarding the scope of the EIR analysis. Notice of the scoping meetings was included in the NOP.

During the scoping period, comments were received from 5 agencies, 10 organizations, and 21 individuals. The IS/NOP is included in Appendix A-1, and the written comments received are included in Appendix A-2 of the Draft EIR. Issues raised in the comment letters and at the scoping meetings are summarized in Table 1-1 in Section 1.0, Introduction, of the Draft EIR. These issues were considered in the preparation of the Draft EIR. The IS/NOP and technical appendices are on file at the City’s Planning and Community Development Department, 175 North Garfield Avenue, Pasadena, California 91101.

The Draft EIR was distributed for public review and comment for the required 45-day public review period that began on January 18, 2022 and ended on March 3, 2022. In compliance with Section 15087(a) of the State CEQA Guidelines, City provided public Notice of Availability (NOA) of the Draft EIR at the same time it transmitted a Notice of Completion (NOC) to the State Clearinghouse (a division of the Governor’s Office of Planning and Research). The City used several methods to solicit comments on the Draft EIR. The NOA was distributed to all parties that received the NOP and additionally to those who provided comments during the scoping period and were not already on the mailing list. The NOA and Draft EIR (including technical appendices) were made available on the City’s website and hardcopies of the NOA and Draft EIR (and appendices) were available for public review during regular business hours at the City of Pasadena Permit Center, City of Pasadena Office of the City Clerk, and City of Pasadena Allendale Branch Library. The NOA and Draft EIR were submitted to the State Clearinghouse for distribution to and review by applicable State agencies; and the NOA was filed with the Los Angeles County Registrar-Recorder/County Clerk. Finally, on February 23, 2022, the City’s Planning Commission held a virtual study session to inform the public about the Project and to receive comments on the Draft EIR.

The City received a total of 144 comment letters on the Draft EIR. Of these, there were 29 letters in support, 9 letters in opposition to the Project and/or regarding adequacy of the Draft EIR, and 106 letters from either union members or others that were neither in support nor in opposition.

Some parties sent more than one comment letter. All of the comment letters received by the City have been included and responded to in this 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 (refer to Section 3.0). The City has reviewed this information and determined that it does not constitute significant new information, and recirculation of the Draft EIR for further comment (pursuant to Section 15088.5 of the State CEQA Guidelines) is not required. The Final EIR, including all responses to comments submitted on the Draft EIR, was provided to all commenters via e-mail, at least 10 days before final action on the Project.

The Planning Commission will consider recommending the certification of the EIR and approval of the Project to the City Council, as the final decision-making body. The City Council will then consider the Project, Draft and Final EIRs, and all comments received during the CEQA process, including oral commentary received during all public hearings held as part of the City’s decisionmaking process.

Affinity Project Final EIR
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All of the comment letters received by the City have been included and responded to in this Final EIR. Comments that raise significant environmental issues have been addressed in these responses. Comments that do not require a response include those that (1) do not address the adequacy or completeness of the Draft EIR; (2) do not raise substantive environmental/CEQA issues; (3) do not address the proposed project; or (4) request the incorporation of additional information not relevant to environmental issues.

Section 15088 of the State CEQA Guidelines, Evaluation of and Response to Comments, states:
f) The lead agency shall evaluate comments on environmental issues received from persons who reviewed the draft EIR and shall prepare a written response.

The Lead Agency shall respond to comments raising significant environmental issues received during the noticed comment period and any extensions and may respond to late comments.
b) The Lead Agency shall provide a written proposed response, either in a printed copy or in an electronic format, to a public agency on comments made by that public agency at least 10 days prior to certifying an environmental impact report.
c) The written response shall describe the disposition of significant environmental issues raised (e.g., revisions to the proposed project to mitigate anticipated impacts or objections). In particular, the major environmental issues raised when the Lead Agency’s position is at variance with recommendations and objections raised in the comments must be addressed in detail giving reasons why specific comments and suggestions were not accepted. There must be good faith, reasoned analysis in response. Conclusory statements unsupported by factual information will not suffice. The level of detail contained in the response, however, may correspond to the level of detail provided in the comment (i.e., responses to general comments may be general). A general response may be appropriate when a comment does not contain or specifically refer to readily available information, or does not explain the relevance of evidence submitted with the comment.
d) The response to comments may take the form of a revision to the draft EIR or may be a separate section in the final EIR. Where the response to comments makes important changes in the information contained in the text of the draft EIR, the lead agency should either:

1. Revise the text in the body of the EIR; or

2. Include marginal notes showing that the information is revised in the response to comments.

This section includes responses to substantive Draft EIR comments received by the City as well as oral comments raised during the Planning Commission hearing held during the Draft EIR public review period. With respect to comments letters received, aside from certain courtesy statements, introductions, and closings, individual comments within the body of each letter have been identified and numbered. A copy of each comment letter and the City’s responses to each applicable comment are included in this section. Brackets delineating the individual comments and a numeric identifier have been added to the right margin of the letter. Responses to each comment identified are included on the page(s) following each comment letter. In the process of responding to the comments, there were minor revisions to the text of the Draft EIR shown in this section and in Section 3.0, Draft EIR Clarifications and Revisions, of this Final EIR. None of the Affinity Project Final EIR
R:\Projects\PAS_Pasaden\3PAS012100\Environmental Documentation\RTC\Final_Affinity RTC_Revisions_MMRP-051222.docx 5 Responses to Comments comments or responses constitute “significant new information”, and none of the conditions set forth in Section 15088.5 of the State CEQA Guidelines that would require recirculation of the Draft EIR has been met. Therefore, this Response to Comments section, along with the Draft EIR Clarifications and Revisions section, are included as part of this Final EIR along with the Draft EIR for consideration by the City Council.

2.1 LIST OF ENVIRONMENTAL IMPACT REPORT COMMENTERS
In accordance with Section 15132 of the State CEQA Guidelines, Table 1 presents a list of the agencies, organizations, and individuals that submitted written comments on the Draft EIR. The date the comments were received by the City is noted as well as the page number the responses begin for each comment letter. Each written comment letter has been divided into sequential numbered comments (i.e., Letter 1, comments 1.1, 1.2, 1.3 etc.) in Section 2.2, Written Comments and City of Pasadena Responses. Duplicate comment letters with different dates are treated as one comment letter but both (i.e., two) dates of correspondence are provided. It is noted that the comment letters received from members of the Carpenters Local 661 Union (104 in total) were identical except for the name of the individual member; regardless, these are identified as separate letters.

TABLE 1

LIST OF COMMENTERS
No. Commenter Date(s) of Correspondence
Follows
Page
Agencies
1 Los Angeles County Metropolitan Transportation
Authority (Metro) March 3, 2022 8
Organizations
Local 661 Carpenters Union
2 Alvarez, Alejandro February 22, 2022 16
3 Alvarez, Marcos February 22, 2022 16
4 Andrade Salas, Celedonio February 22, 2022 16
5 Andrade, Freddy February 22, 2022 16
6 Apodaca, Enrique February 22, 2022 & March 2, 2022 16 7 Apodaca, Marielena February 22, 2022 & March 2, 2022 16 8 Arenas, Juan March 2, 2022 16
9 Arias, Christian February 22, 2022 16
10 Barajas, Luis February 22, 2022 16
11 Beltran, Danny February 22, 2022 16
12 Benzie, David A. February 22, 2022 16
13 Bradley, Sage February 22, 2022 16
14 Bran, Kenneth February 22, 2022 16
15 Burgara, Ivan February 22, 2022 16
16 Calderon, Alex February 22, 2022 16
17 Camacho, Alberto February 22, 2022 16
18 Camposeco, Victor February 22, 2022 16
19 Carbajal, Carlos February 22 & March 2, 2022 16
20 Casillas, Andres February 22, 2022 16
21 Casillas, Alejandro February 22, 2022 16
22 Chavez, Hector March 2, 2022 16
23 Cipagauta, Omar February 22, 2022 16
Affinity Project Final EIR
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LIST OF COMMENTERS
No. Commenter Date(s) of Correspondence
Follows
Page
24 Contreras, Javier February 22, 2022 16
25 Contreras, Sal February 22, 2022 16
26 Cruz, Jose February 22, 2022 16
27 Cummings, Thomas February 22, 2022 16
28 Dammeier, Sean February 22, 2022 16
29 Delapinia, Dre February 22, 2022 16
30 Delgado, Emmanual February 22, 2022 & March 2, 2022 16 31 Diamond, Steve February 22, 2022 16
32 Diaz, Fred February 22, 2022 16
33 Dunlap, Donte February 22, 2022 16
34 Erickson, Ryan February 22, 2022 16
35 Esquivel, Alejandro March 2, 2022 16
36 Esquivel, Manual Jorge March 2, 2022 16
37 Galindo, Daniel March 2, 2022 16
38 Genaro (no last name) February 22, 2022 16
39 Giron, Jose February 22, 2022 16
40 Gonzales, Ceśar February 22, 2022 16
41 Gonzalez, Rudy E. March 2, 2022 16
42 Green, Jason February 22, 2022 & March 3, 2022 16
43 Gridley, Jake March 2, 2022 16
44 Guardado, Israel February 22, 2022 16
45 Guitron, German February 22, 2022 16
46 Hamilton, Sandra February 23, 2022 16
47 Hernandez, Armando February 22, 2022 16
48 Hernandez, Jimmy February 22, 2022 16
49 Hernandez, Juan February 22, 2022 16
50 Hernández, Marcelino February 22, 2022 16
51 Jovel, Luis March 2, 2022 16
52 Kukuczka, Michael February 22, 2022 16
53 Ledesma, Joe February 22, 2022 16
54 Ledesma, Joseph February 22, 2022 16
55 Lemos, Josh February 22, 2022 16
56 Mann, Melissa February 22, 2022 16
57 Mann, Sean February 22, 2022 & March 2, 2022 16
58 Martinez, Jose March 2, 2022 16
59 Martinez, Pascual March 2, 2022 16
60 Martinez, Santos February 22, 2022 16
61 Mcclenthen, Steven February 22, 2022 16
62 Mendoza, Roberto March 2, 2022 16
63 Mieure, Erin February 22, 2022 16
64 Mieure, Shaun February 22, 2022 16
65 Mondragon, Jaime March 2, 2022 16
66 Montiel, Deanna Asa February 22, 2022 16
67 Myerly, Cole March 2, 2022 16
Affinity Project Final EIR
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LIST OF COMMENTERS
No. Commenter Date(s) of Correspondence
Follows
Page
68 Nevarez, Omar February 22, 2022 16
69 Ocampo, Leo February 22, 2022 16
70 Olivares, Rafael February 23, 2022 16
71 Ortiz, Francisco February 22, 2022 16
72 Peralta Vargas, Juan Carlos February 22, 2022 16
73 Perez, Joel February 23, 2022 & March 2, 2022 16
74 Perez, Jorge March 2, 2022 16
75 Phillips, Laton February 23, 2022 16
76 Portillo, Luis February 22, 2022 16
77 Powell, Blake February 22, 2022 16
78 Ramirez, Abraham February 22, 2022 16
79 Resendiz, Alfredo March 2, 2022 16
80 Reyes, Miguel Ángel March 2, 2022 16
81 Reyes, Nelson February 22, 2022 16
82 Reyes, Nicolás February 22, 2022 & March 2, 2022 16
83 Reyes, Ramiro February 22, 2022 16
84 Reyes, Roberto February 22, 2022 16
85 Rivas, Jose February 22, 2022 16
86 Rocha, Victor February 22, 2022 16
87 Rodriguez, Peter February 22, 2022 16
88 Rojas, Bonifasio February 22, 2022 16
89 Saenz, Jonathan February 22, 2022 16
90 Sandoval, Emilio February 22, 2022 16
91 Sepanlou, Kamran February 22, 2022 & March 2, 2022 16 92 Serrano, Leonel February 22, 2022 16
93 Servera, Matthew February 22, 2022 16
94 Solis, Alejandro March 2, 2022 16
95 Solorzano, Brandon Alexander February 22, 2022 16
96 Tadeo, Eduardo February 22, 2022 16
97 Tapia, Samuel February 22, 2022 16
98 Tejeda, Gonzalo March 2, 2022 16
99 Va, Lorren February 22, 2022 16
100 Velázquez, Jose March 2, 2022 16
101 Valencia, Armando March 2, 2022 16
102 Vargas, Jr., Oscar February 22, 2022 16
103 Villagran, Martin February 22, 2022 16
104 Zambrano, David February 22, 2022 16
Other Organizations
105 Livable Pasadena August 25, 2021 & February 19, 2022 17 106 Madison Heights Neighborhood Association February 23, 2022 78 107 Old Pasadena Management District May 25, 2021 78
108 Pasadena Chamber of Commerce and Civic
Association February 16, 2022 78
109 Protect Pasadena Trees February 4, 2022 44
Affinity Project Final EIR
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LIST OF COMMENTERS
No. Commenter Date(s) of Correspondence
Follows
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110 Residents of Magnolia Landmark District February 10, 2022 50 111 Supporters Alliance for Environmental
Responsibility
March 2, 2022 57
112 West Pasadena Residents Association March 2, 2022 59 Individuals
113 Albrektson MD, Josh February 20, 2022 78
114 Aronoff, Bob February 23, 2022 65
115 Bazarevitsch, Natalie August 10, 2021 78
116 Chomsky, Nina March 2, 2022 67
117 Crawford, Maggie August 11, 2021 78
118 Dailey, Sydney February 16, 2022 78
119 Done, Darrell May 23, 2021 78
120 Dusseault, Sarah February 22, 2022 78
121 Erickson, Cyndi February 17, 2022 78
122 Feldmann, Scott August 11, 2021 78
123 Ficarra, Michelle August 11, 2021 78
124 Foy, Erika February 26, 2022 71
125 Gamb, Jim August 3, 2021 78
126 Akila Gibbs August 10, 2021 78
127 Kitchens, Dean August 10, 2021 78
128 Kong, Stan August 11, 2021 78
129 Erik Landswick August 11, 2021 78
130 Maciejowski, Nikki February 22, 2022 78
131 Marissa Marchioni May 8, 2021 78
132 Plotkin, James R. August 11, 2021 78
133 Rawlings, Andrea February 23, 2022 75
134 Rosenberg, Julie August 10, 2021 78
135 Round, Michelle February 22, 2022 78
136 Schillaci, Mary Frances August 8, 2021 78
137 Smith, Gregg May 24, 2021 78
138 Stratman, Victoria D. August 4, 2021 78
139 Trytten, Steven E. August 10, 2021 78
140 Walker, Carol August 11, 2021 78
141 Worrell, Julianne May 24, 2021 78
Finally, verbal comments were received from the commissioners and the public during the Planning Commission hearing held on February 23, 2022. Section 2.3, Verbal Comments and City of Pasadena Responses, includes a summary of (1) commissioners’ comments and staff’s responses provided during the hearing and (2) public comments received during the hearing.

Table 2.3 also provides responses to all public comments recorded during this hearing.

Affinity Project Final EIR
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Affinity Project Final EIR
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2.2 WRITTEN COMMENTS AND CITY OF PASADENA RESPONSES
Response to Comment Letter 1
Los Angeles County Metropolitan Transportation Authority1 March 3, 2022
Response 1.1. This comment related to Metro’s statutory responsibility and documents provided is acknowledged. The comment does not address the content or adequacy of the Draft EIR under CEQA or the State CEQA Guidelines; however, the comment is noted for the administrative record and will be provided to the decision-makers for review and consideration.

Response 1.2. This comment related to development adjacent to the Metro L Line is acknowledged. It is noted that the body of this letter and the associated attachment “Metro Adjacent Development Handbook” (Handbook) dated February 2021 is the same as the scoping period comment letter submitted by Metro, dated September 3, 2021. The Draft EIR acknowledges that coordination with Metro would be required as part of Project implementation, if approved, due to the site’s location within 100 feet of a Metro ROW in Table 2-6 on page 2-18.

Based on the Handbook, it is uncertain whether the Applicant would only require a review or also a permit or other approval from Metro based on the level of Project design prepared to date. While the identified issues are not germane to the CEQA analysis, as discussed further below, it is understood these are issues of relevance and concern to Metro for planning and procedural purposes. The City of Pasadena and the Applicant would consult with Metro, as required and appropriate outside of the CEQA process, to ensure the continuance and safety of activities on all party’s properties.

In the comment letter Metro signifies its area of statutory responsibility under CEQA and the State CEQA Guidelines, specifically pursuant to (1) Section 15064.3(a) of the State CEQA Guidelines and (2) the Governor’s Office of Planning and Research’s Technical Advisory on Evaluating Transportation Impacts in CEQA (Technical Advisory), dated December 2019 (page 19). Both Section 15064.3 et. seq. and the Technical Advisory relate to changes in the CEQA analysis of transportation pursuant to SB 743.

Section 15064.3(a) “Purpose” of the State CEQA Guidelines states (emphasis added):

This section describes specific considerations for evaluating a project’s transportation impacts. Generally, vehicle miles traveled is the most appropriate measure of transportation impacts. For the purposes of this section, “vehicle miles traveled” refers to the amount and distance of automobile travel attributable to a project. Other relevant considerations may include the effects of the project on transit and non-motorized travel. Except as provided in subdivision (b)(2) below (regarding roadway capacity), a project’s effect on automobile delay shall not constitute a significant environmental impact.

Because criteria for determining the significance of transportation impacts must promote “the development of multimodal transportation networks” pursuant to Public Resources Code section 21099, subd. (b)(1), lead agencies should consider project impacts to transit systems and bicycle and pedestrian networks. For example, a project that blocks access to a transit stop or blocks a transit route itself may interfere with transit functions. Lead agencies should consult with transit 1 Attachments provided with this comment letter provided as Appendix A.

Affinity Project Final EIR
R:\Projects\PAS_Pasaden\3PAS012100\Environmental Documentation\RTC\Final_Affinity RTC_Revisions_MMRP-051222.docx 15 Draft EIR Clarifications and Revisions agencies as early as possible in the development process, particularly for projects that are located within one half mile of transit stops. When evaluating impacts to multimodal transportation networks, lead agencies generally should not treat the addition of new transit users as an adverse impact. An infill development may add riders to transit systems and the additional boarding and alighting may slow transit vehicles, but it also adds destinations, improving proximity and accessibility. Such development also improves regional vehicle flow by adding less vehicle travel onto the regional network. Increased demand throughout a region may, however, cause a cumulative impact by requiring new or additional transit infrastructure. Such impacts may be adequately addressed through a fee program that fairly allocates the cost of improvements not just to projects that happen to locate near transit, but rather across a region to all projects that impose burdens on the entire transportation system, since transit can broadly improve the function of the transportation system (OPR 2018).

As established by the text above from the technical advisory, the analysis of potential impacts to transit under SB 743 pertains to changes in ridership, accessibility, and proximity and represent possible long-term, operational effects of a project. As discussed on page 3.9-5 of the Draft EIR, the City of Pasadena developed and adopted its Transportation Impact Analysis Current Practice and Guidelines (TIA Guidelines), which are consistent with the requirements of SB 743. As stated on page 3.9-10, “As shown in Table 3.9-5, using the City’s Transportation Demand Model, the Pasadena DOT determined that the Project would not exceed any of the CEQA transportation thresholds defined in the City’s TIA Guidelines (Pasadena DOT 2020). As such, the Project would not conflict with the City’s plan addressing 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. There would be less than significant impacts, and no mitigation is required.” As discussed later on the same page, the Pasadena DOT prepared a TIA for the Project with Building A Residential/Commercial using the same methodology as applied for the Project. This analysis also determined there would be less than significant transportation impacts, and no mitigation is required.

Temporary, construction-phase effects due to proximity (i.e., within 100 feet) to a Metro ROW are not established by SB 743 or the State CEQA Guidelines as “effects of the project on transit…”.

The comment identifies potential construction-phase and/or design-related “impacts” pertaining to adjacency to the Metro L Line and recommends several “mitigation measures.” However, the “mitigation measures” recommended by Metro do not correspond to any expressed environmental impact, nor would they reduce an environmental impact. Rather, the recommended “mitigation measures” are related to best management practices for construction adjacent to the Metro L Line to further ensure protection of Metro’s built facilities. Since the “impacts” and “mitigation measures” expressed in this comment are not environmental in nature and since they do not relate to the transit-related aspects of the SB 743-compliant transportation analysis presented in Section 3.9 of the Draft EIR, no CEQA mitigation measures are warranted. Regardless, the comment is noted for the administrative record and will be provided to the decision-makers for review and consideration.

California Governor’s Office of Planning and Research (OPR). 2018 (December). Technical Advisory on Evaluating Transportation Impacts in CEQA. Sacramento, CA: OPR. Revised Proposal on Updates to the CEQA Guidelines on Evaluating Transportation Impacts in CEQA (ca.gov).

Affinity Project Final EIR
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The comment does not address the content or adequacy of the Draft EIR under CEQA or the State CEQA Guidelines; however, the comment is noted for the administrative record and will be provided to the decision-makers for review and consideration.

Response 1.4. This comment related to transit-supportive planning is acknowledged. The comment does not address the content or adequacy of the Draft EIR under CEQA or the State CEQA Guidelines; however, the comment is noted for the administrative record and will be provided to the decision-makers for review and consideration.

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Local 661 Carpenters Union
February 22, February 23, and March 2, 2022
Responses 2.1—104.1. These comments related to development of a Community Wealth Plan by the City are acknowledged. The comments do not address the content or adequacy of the Draft EIR under CEQA or the State CEQA Guidelines; however, the comments are noted for the administrative record and will be provided to the decision-makers for review and consideration.

Affinity Project Final EIR
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Livable Pasadena
August 25, 2021 and February 19, 2022
Response 105.1. As discussed on page 2-7 of the Draft EIR:
“Section 15124 of the State CEQA Guidelines defines what information shall be contained in a project description for purposes of analysis in an EIR. The concept of a stable and finite project description is shaped by selected published CEQA court decisions. The project description provided in this Draft EIR meets the requirements of Section 15124 and is also stable and finite. A stable and finite project description, as interpreted in the relevant legal cases, is not synonymous with allowing only a single development scenario.

The siting, mass, and outward appearance of the Project, regardless of scenario, is clearly defined both in this EIR and in the Initial Study. The upper limits of development of both buildings for both scenarios is clearly defined, and the Initial Study and this EIR address both scenarios in distinct, separate analyses. Therefore, the project description provided in this Draft EIR is legally adequate and allows for a full and robust analysis of all potential impacts of implementing either the Project or Project with Building A Residential/Commercial, if approved.”
Therefore, the assertion that the project description is not stable, as provided in the comment letter received during the scoping period and resubmitted during the Draft EIR review period, inaccurately presumes that a project description is inadequate simply because it provides two development scenarios. Importantly, the Draft EIR carefully articulated each scenario in detail, laying out their similarities and differences, and fully disclosed the maximum possible scope of each scenario. The Draft EIR then evaluated the environmental effects of each scenario, both in terms of physical plan and use/operation, thereby allowing informed decision-making and public participation. Accordingly, the project description is adequate and fulfills CEQA’s purpose to enable the public to participate meaningfully in the environmental review and analysis of any potential environmental effects.

Response 105.2. As discussed beginning on page 3.11-1 of the Draft EIR, a water supply assessment (WSA) was prepared for the Project. As stated on page 3.11-1:
“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 this EIR (California 2021), a WSA was prepared for the Project and Project with Building A Residential/Commercial to inform the environmental analysis.” The results of the WSA were summarized in Section 3.11, Utilities and Service Systems, of the Draft EIR and provided as Appendix I. As discussed on page 3.11-23:

Therefore, there would be sufficient water supplies available to serve the Project and reasonably foreseeable future development during normal, dry, and multiple dry years.

There would be a less than significant impact related to water supplies…” The WSA also assessed water demand for the Project with Building A Residential/Commercial and concluded there would be a less than significant impact. Accordingly, the Draft EIR included a thorough analysis of water supply consistent with the request in this comment letter Affinity Project Final EIR
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Response 105.3. As discussed on page 2-11 of the Draft EIR:
“Regarding the creation of a heat island and/or increase of the local heat index, the Project would result in at worst a neutral contribution to the heat index in the area. Heat islands are created by a combination of heat-absorbing surfaces (such as dark pavement and roofing), heat-generating activities (such as engines and generators), and the absence of vegetation (which provides evaporative cooling).

It is noted that of the 23 on-site trees to be removed, 19 are queen palms (Syagrus romanzoffiana), which provide little shade. They do provide some measure of evaporative cooling, which can help offset the heat index, but not at ground level. Additionally, the site currently contributes to the urban heat island effect by consisting almost entirely of asphalt or concrete surface and buildings. The hydrology study prepared for the Project (and provided as Appendix of the Initial Study) assessed that the site is currently 97 percent impervious surface area. With implementation of the Project, the site would be 98 percent ground-level impervious surface area. However, with the Project there is a net increase in vegetation on the site compared to the existing condition, with landscaping at the ground level and on levels 2, 3, and 6. All vegetation, whether in ground or planters, provides evaporative cooling. Under the Project with Building A Residential/Commercial, the landscape (including tree removal and planting), hardscape, and lighting would be the same as that discussed for the Project.”
The ability of trees to reduce a heat island effect is a function of the shade they provide, which is dependent on the species and the area provided for root development whether in the ground or an above ground planter. Of the 23 on-site trees to be removed, 2 are mature Canary Island pine trees that produce significant shade, 19 are queen palms with a canopy width of approximately 15 feet that produce only moderate shade (at the ground level), 1 is an African fern pine with a canopy diameter of approximately 15 feet that produces moderate shade, and a small pecan tree that produces minimal shade. The 38 trees that would be planted (15 more than being removed) include species that produce canopies at maturity that are at least as wide as the canopies that are being removed (i.e., tipu tree, desert willow, gingko, western redbud, palo verde). At the time of planting, the replacement trees would have canopies that provide approximately 75 percent of the shade as the existing trees. However, the proposed tree planters are distributed in areas where there is expected to be pedestrian activity, whereas the existing trees are primarily along the western site boundary (queen palms) or are otherwise not in locations with notable pedestrian activity in the existing condition. As a result of the Project, more trees would be planted on the site and the average canopy spread of these trees at maturity would be at least as wide as the existing trees. The assertion that implementation of the Project (or Project with Building A Residential/Commercial) would exacerbate the heat island effect associated with the site is unfounded.

Response 105.4. Please refer to Responses 105.1 through 105.3, above.

Affinity Project Final EIR
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Madison Heights Neighborhood Association
February 23, 2022
Response 106.1. This comment that summarizes the commenter’s concerns regarding historic resources, trees, traffic and parking, mountain views, walkability, green space, and community outreach is acknowledged. Regarding mountain views, aesthetic issues were addressed in Section 2.1, Aesthetics, of the Initial Study that was provided as Appendix A-1 to the Draft EIR.

As discussed, consistent with SB 743 (Section 21099[d] of the Public Resources Code), the aesthetic effects of the Project are not considered significant environmental impacts pursuant to CEQA and the topic was not carried forward for further evaluation in the Draft EIR. The City has met, and exceeded, the public outreach requirements for an EIR pursuant to CEQA–one public scoping meeting–holding two scoping meetings as well as a Planning Commission meeting during the Draft EIR review period. Please refer to Responses 106.2 through 106.9 below for all other concerns listed.

Response 106.2. As indicated in Figure 1 provided by the commenter, the language introducing the trip generation table indicates the application of rates from the ITE Trip Generation manual (ITE manual) is a standard procedure. The purpose of having standard procedures is to ensure different projects are assessed in a consistent way for both existing and proposed uses, and the use of the ITE manual is established as part of the City’s adopted Transportation Impact Analysis Current Practice and Guidelines. Regardless, the trip generation presented in commenter’s Figure 1 is unrelated to the transportation analysis performed as part of the Draft EIR, which is a methodology revolving around vehicle miles traveled (VMT). The table in commenter’s Figure 1 and the associated methodology revolves around level of service (LOS), which is no longer addressed as part of CEQA, pursuant to implementation of Senate Bill 743 and associated changes to CEQA and the State CEQA Guidelines. This is addressed in the “Outside CEQA” studies prepared by the City of Pasadena Department of Transportation (Pasadena DOT). The Outside CEQA analysis does not factor into the results of the CEQA transportation analysis, or vice versa, as they measure different metrics and are used for different purposes. Since the existing uses on the Project site are currently active, and with many unknowns due to the inability to conduct accurate traffic count surveys, the City made the decision to continue their practice of using industry-accepted trip generation rates found in the ITE manual to calculate land use traffic volumes to estimate the number of total Project trips minus the number of existing trips to determine the net project trips for evaluation. Furthermore, traffic count data collection was suspended since conducting traffic counts during the pandemic would undercount baseline traffic on the street network. Traffic from existing developments and on street networks during the pandemic have been significantly different from what was typically occurring prior to the pandemic. Solo driving, transit use, and even social gatherings were once daily activities, but the pandemic created not only social isolation and uncertainty in using other travel modes like appbased rideshare services and public transit, but also created opportunities in telework and increases in online shopping services. Empirical site surveys during the pandemic to verify the existing land use trip volumes does not provide a representation of normal non-pandemic conditions. Traffic count data used in the analysis is based on counts on file and Streetlight Data Analytics information from the annual average daily traffic from 2017 to 2019 along the study segment and intersection locations.

Regardless, the CEQA transportation analysis does not use existing traffic count data to evaluate a project’s impact and its effect to the City’s established thresholds. The CEQA analysis is based on the 2013 Travel Demand Forecasting (TDF) model developed and validated for the City of Pasadena. The City’s 2013 TDF model captures and reflects local conditions using GPS and cell phone data, traffic counts, parcel level land use, vehicular availability, and street network and Affinity Project Final EIR
R:\Projects\PAS_Pasaden\3PAS012100\Environmental Documentation\RTC\Final_Affinity RTC_Revisions_MMRP-051222.docx 38 Responses to Comments travel time information. In addition, the TDF model used information from the Southern California Association of Government (SCAG) Planning Model, the National Household Travel Survey, census data, parcel level land use data, and other data sources. The City’s TDF model is consistent with State requirements to develop localized CEQA thresholds to evaluate development growth through the lens of accessibility, mobility, multi-modal transportation systems, diverse land uses, and the related reduction of greenhouse gas emissions. The City recognizes that occupancy changes may have occurred on the project parcels as well as changes to the City’s transportation network since the development of the TDF model. However, the 2017 TDF model, approved by City Council in November 2020, applies to new project applications deemed complete as of February 15, 2021, which does not apply since the Project application was completed prior to February 15, 2021. The City’s transportation analysis methodology applied in CEQA documents is discussed on pages 3.9-4, 3.9-5, and 3.9-7 through 3.9-9 of the Draft EIR and in Draft EIR Appendices G-1 and G-2.

Regarding how trip calculation would affect the “CEQA study overall”, it is noted that net trip generation data is used solely in the noise and vibration analysis (refer to Table 3.7-5, Net Trip Generation for the Project, on page 3.7-13 and Table 3.7-7, Net Trip Generation for the Project with Building A Residential/Commercial, on page 3.7-16 of the Draft EIR). The air quality, energy, and GHG emissions modeling is not based on net increase in trips but on total operational trips for the proposed uses (for both project scenarios). No changes to the Draft EIR are necessary; however, the comments are noted for the administrative record and will be provided to the decision-makers for review and consideration.

Response 106.3. The Pasadena DOT reports that they have worked closely with Metro in recent years to reduce delay at the intersection caused by the Metro L Line operation and have implemented an adaptive traffic control system to better manage operations along this corridor.

There have been substantial changes to the signal operations at the intersections near the Metro L Line crossing near California Boulevard in the past approximately five years, and the changes have contributed to a reduction in collisions during this period.

The intersections of Arroyo Parkway at California Boulevard and Marengo Avenue at California Boulevard are currently being operated by the City’s Sydney Coordinated Adaptive Traffic System (SCATS). The SCATS allows for the real-time adjustment of signal timing at traffic signals to manage congestion. The system balances the vehicle demand for signals along a corridor or network using data from in-ground loops or video detection at each intersection. Adaptive controls are beneficial along arterials that experience variable and changing demands in traffic, such as areas near the Metro light rail crossings. The City first installed this system along the South Fair Oaks Avenue corridor, and it resulted in favorable traffic conditions.

In 2019, Pasadena DOT expanded the SCATS network to include streets that parallel the Metro light rail crossings; this included the intersections of Arroyo Parkway at California Boulevard and Marengo Avenue at California Boulevard. Since installation of the SCATS, there has been a reduction of traffic collisions at both intersections. In the past five years, the intersection of Arroyo Parkway at California Boulevard has averaged four collisions per year. Even with the increase in traffic volumes at both these signalized intersections and observed instances of congestion, the safety of the intersections has not declined. Pasadena DOT is currently in construction of the next phase of the adaptive network. The signals along California Boulevard at Los Robles Avenue, El Molino Avenue, Hudson Avenue, and Lake Avenue will be added to the SCATS network. The expansion of the adaptive signals will facilitate continued improvements along the California Boulevard corridor. The City is also actively working with Metro to obtain data from approaching trains. This data will be analyzed to further enhance signal timing of the intersections adjacent to the grade crossings.

Affinity Project Final EIR
R:\Projects\PAS_Pasaden\3PAS012100\Environmental Documentation\RTC\Final_Affinity RTC_Revisions_MMRP-051222.docx 39 Responses to Comments As discussed beginning on page 3.9-11 of the Draft EIR, Pasadena DOT tracks the City’s intersection collision history, which is inclusive of all transportation modes. For the intersection of California Boulevard and Marengo Avenue, City records indicate that, for the five-year period from January 1, 2017, through December 31, 2021, there were a total of 13 reported collisions at this intersection, broken down by year as follows: 3 in 2017, 4 in 2018, 2 in 2019, 3 in 2020, and 1 in 2021. Of the 13 collisions, 6 resulted in injuries and 0 resulted in fatalities. On average, there were

2.6 reported collisions per year at this intersection over this five-year period. The collision history for the intersection of California Boulevard and Magnolia Avenue was also reviewed. For the fiveyear period from January 1, 2017, through December 31, 2021, there were a total of two reported collisions at the intersection of California Boulevard and Marengo Avenue, resulting in an annual average of 0.4 collisions per year. These two intersections are also not considered high collision locations, as discussed for the South Arroyo Parkway and California Boulevard intersection in the Draft EIR. Pasadena DOT continues to monitor operations along the corridor to address traffic signal operations and reduce the potential for collisions.

To compare crash rates for facilities throughout the State, the California Department of Transportation (Caltrans) annual crash data for roadways and intersections was reviewed. The latest published data was released on October 6, 2020 and includes data for 2018. The Basic Average Crash Rate for Intersections provides crash rates as crashes per million vehicles entering the intersection. The basic average crash rate for intersections controlled by a traffic signal in an urban area is 0.24 crashes per million vehicles entering the intersection. The crash rate for the intersection of Marengo Avenue and California Boulevard is 0.20 crashes per million vehicles entering the intersection is, therefore, below the State average for a signalized urban intersection.

To reiterate, the City’s collision data is inclusive of all transportation modes, including pedestrian and bicycle. While it may appear that safety is an issue for non-vehicular modes as a day-to-day experience, the numerical data do not support this assertion at either the local or State level.

It is common throughout the State for a city or county transportation department to prepare the necessary analyses both for CEQA and circulation planning (i.e., outside CEQA) purposes. There is no conflict, and no evidence has been presented that substantiates the assertion that the Pasadena DOT has a conflict in preparing transportation related studies for the Project.

Additionally, there is nothing in CEQA Guidelines stating that an outside transportation company should conduct the analyses for a project’s environmental review process. To the contrary, Section 15084(d)(1) of the State CEQA Guidelines expresses that the Lead Agency may prepare the EIR directly with its own staff.

Please refer to Response 106.2 for information regarding trip credits, which are not applicable to the CEQA-compliant transportation analysis.

Response 106.4. Pasadena DOT has reviewed the proposed driveway on California Boulevard and determined that it does not introduce any additional safety concerns from the transportation standpoint. There are currently two driveways along this section of California Boulevard. These two existing driveways would be consolidated into one proposed driveway serving the Project and would operate as a right-in-right-out only driveway, similar to the existing condition. Left turns are physically restricted into or out of the driveway on California Boulevard by the existing raised median. East of the Arroyo Parkway at California Boulevard intersection, there are currently two approach lanes for westbound. West of the intersection, a westbound right-turn-only lane currently exists in addition to the two westbound through lanes. This roadway configuration would remain with Project implementation. The dedicated right turn lane allows traffic entering the Project to be separated from traffic in the two through travel lanes. When exiting the driveway, motorists would be able to see the multiple warning devices that activate when a train is approaching.

Affinity Project Final EIR
R:\Projects\PAS_Pasaden\3PAS012100\Environmental Documentation\RTC\Final_Affinity RTC_Revisions_MMRP-051222.docx 40 Responses to Comments As discussed further in Response 106.3 above, the City controls the intersections along the California Boulevard corridor rather than Metro. Metro has control of light rail operations and other activities solely within their right-of-way.

Response 106.5. As discussed beginning on page 2-15 of the Draft EIR, the analysis of cumulative impacts for all topics is based on growth pursuant to buildout of the City’s General Plan, which in turn is based on buildout of all specific plan areas. Cumulative impacts are analyzed within each topical section addressed in the Draft EIR. As discussed on page 3.9-13:
“Cumulative transportation impacts within the City were recently evaluated in the Pasadena General Plan Draft EIR, which evaluated transportation impacts within the City associated with buildout of the General Plan in 2035 (City of Pasadena 2015). The General Plan EIR analysis considered impacts associated with the five transportation performance measures identified in the TIA Guidelines, namely VMT per Capita, VT per Capita, proximity and quality of the bicycle network, proximity and quality of the transit network, and pedestrian accessibility. The analysis found that transportation impacts associated with all five performance measures would be less than significant.

As the Project is 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 Draft EIR is representative of cumulative impacts associated with the Project. Also, as discussed above, the Project would result in less than significant impacts for all five transportation performance measures. Therefore, Project-related cumulative impacts were considered in the cumulative analysis conducted for the Pasadena General Plan Draft EIR. The Project would not result in a cumulatively considerable impact related to transportation, and no mitigation is required.”
The finding is the same for the Project with Building A Residential/Commercial (refer to page 3.9- 13 of the Draft EIR). As such, the assumption of a significant transportation impact based on development of the Project in addition to other projects in the Central District is unfounded.

Regarding Alternative 4, as described on page 4-21 of the Draft EIR, this alternative assumes medical office uses in both proposed Building A and Building B (i.e., 338,376 square feet of medical office) and not “just one additional medical building” in the area. Additionally, the CEQA transportation analysis methodology focusing on VMT is not intended to scale up; its purpose is to assess individual projects/land uses to determine whether they support a local jurisdiction’s transportation goals. Moreover, the City’s VMT, VT, and proximity metrics for evaluating transportation impacts are inherently cumulative analyses, as they measure changes at the citywide level (e.g., change in Citywide VMT/capita). That said, as discussed above, the cumulative impact analysis for the Project uses the projection method consistent with Section 15130(b)(1)(B) of the State CEQA Guidelines, which is one of two allowable methods to assess cumulative impacts under CEQA.

Finally, the purpose of the alternatives analysis in an EIR is to provide a comparative analysis to determine whether feasible alterations in a project as proposed may lessen or avoid a significant impact. Also, as discussed further above in Response 107.2, the trip generation figures referenced by the commenter have no correlation or relevance to the CEQA-compliant transportation analysis. The signs of “failure” in an intersection referenced by the commenter relate to LOS, which is no longer addressed as part of the CEQA transportation analysis.

Accordingly, the cumulative or incremental impact of Alternative 4 related to vehicle trips is immaterial to the Draft EIR transportation analysis. This is addressed in the “Outside CEQA” studies prepared by the Pasadena DOT and used for circulation planning. It is noted that net trip generation data is used in the noise and vibration analysis (refer to Table 3.7-5, Net Trip Generation for the Project, on page 3.7-13 and Table 3.7-7, Net Trip Generation for the Project Affinity Project Final EIR
R:\Projects\PAS_Pasaden\3PAS012100\Environmental Documentation\RTC\Final_Affinity RTC_Revisions_MMRP-051222.docx 41 Responses to Comments with Building A Residential/Commercial, on page 3.7-16 of the Draft EIR) to assess off-site traffic noise. The air quality, energy, and GHG emissions modeling is not based on net increase in trips but on total operational trips for the proposed uses. Regarding the VMT calculation summary for Alternative 4, this is provided in Table 4-5 on page 4-24 of the Draft EIR. As indicated above, this analysis is based on application of the City’s TDF model and bears no relationship to trip generation figures (or credits) derived from the ITE manual.

Response 106.6. The Project site is situated away from residential neighborhoods. Except for the five-story, mixed-use building at 482 South Arroyo Parkway, approximately 100 feet to the east from the site on the opposite side of Arroyo Parkway, the nearest residential uses are located more than 250 feet to the east and are buffered by commercial development along the east side of Arroyo Parkway. As such, the Project is an appropriate siting for infill redevelopment and is consistent with the City’s General Plan and Central District Specific Plan, as discussed beginning on page 3.6-6 of the Draft EIR.

Regarding how the Project would impact residents in the vicinity, CEQA analyses for all projects are based on effects to the existing conditions. This includes the existing land uses both adjacent to, and in the wider vicinity of, a proposed use. Where sensitive receptor locations are critical to an analysis, such as air quality and noise, the nearest residential uses at 482 South Arroyo Parkway are identified as the nearest receptors. Environmental effects farther away than 482 South Arroyo Parkway (approximately 100 feet) would be less than at this location. However, the whole of the CEQA documentation can be “considered a comment on” how the Project would impact the environment, which includes all those living or working in the vicinity.

Regarding trees, the existing tree inventory is presented in Table 2-2 on page 2-3 of the Draft EIR. As shown by the headers in this table, there are trees on private property and trees in the public right-of-way (ROW) (i.e., street trees). These are treated differently pursuant to the City’s tree protection ordinance. Specifically, as stated on page 2-2 of the Draft EIR:
“Of these [40 trees inventoried on the site], 17 trees located in the ROW are protected under the City Trees and Tree Protection Ordinance. The remaining 23 trees are located on private property within the Project site and are not protected.” As discussed, beginning on page 2-10 of the Draft EIR:
“the Project would result in the removal of 23 non-protected non-native trees on the Project site and 2 protected, non-native street trees.”

trees (one on Arroyo Parkway and one on California Boulevard). Additionally, the Draft EIR states that the Urban Forestry section of the City’s Public Works Department typically requires a fee to be remitted into the City’s street tree fund. This discussion referred solely to protected street trees.

Furthermore, the new street trees are not intended to be replacements for all trees removed nor is this asserted in the Draft EIR. The condition requiring two new street trees is not tied to the proposed street tree removals, but is related to existing vacancies along the sidewalk and/or locations that could accommodate a tree. Were the Applicant to pursue street tree removal through the City, including the Urban Forestry Advisory Committee (UFAC), the approval would require remittance of a fee–depending on the size of the tree(s) being removed– into the street tree fund and covering the cost of the tree removals.

Exhibits 2.16a–e, Conceptual Landscape Plan, following page 2-11 of the Draft EIR, illustrate the concept for proposed hardscape and landscape including the permanent installation of 38 trees of various species. As discussed further below, based on consultation with an International Affinity Project Final EIR
R:\Projects\PAS_Pasaden\3PAS012100\Environmental Documentation\RTC\Final_Affinity RTC_Revisions_MMRP-051222.docx 42 Responses to Comments Society of Arboriculture (ISA) – certified arborist,2 the proposed landscape plan would more than double the tree canopy of the existing condition when mature. Of the 23 on-site trees to be removed, 2 are mature Canary Island pine trees that produce significant shade, 19 are queen palms with a canopy width of approximately 15 feet that produce only moderate shade (at the ground level), 1 is an African fern pine with a canopy diameter of approximately 15 feet that produces moderate shade, and 1 is a small pecan tree that produces minimal shade. The existing tree canopies range from 10 to 15 feet wide. Based on the number and size of existing trees, the total canopy on the site is approximately 4,100 square feet (sf). The 38 trees that would be installed (15 more than being removed) include species that produce canopies at maturity that are at least as wide as the canopies that are being removed (e.g., tipu tree, desert willow, gingko, western redbud, palo verde). At the time of planting, the replacement trees would have canopies that provide approximately 75 percent of the shade as the existing trees. However, the proposed tree planters are distributed in areas where pedestrian activity is expected, whereas the existing trees are primarily along the western site boundary (queen palms) or are otherwise not in locations with notable pedestrian activity in the existing condition. As a result of the Project, more trees would be planted on the site and the average canopy spread of these trees at maturity would be at least as wide as the existing trees. Based on the planter size, species, and number of each tree proposed, the proposed on-site trees would create a canopy of approximately 3,100 sf at planting and approximately 9,200 sf at maturity.

Regarding in-ground trees versus potted trees, the amount and quality of soil provided to the tree are defining factors in a tree’s maximum size and usable life span in an urban environment. The street trees near the site and through much of the City are planted in four-foot by eight-foot sidewalk cutouts, which can be considered a tougher environment than an above ground planter for a variety of reasons, including limited usable soil for root growth, poor drainage, and damage by people or vehicles. The landscape plan indicates 8-foot-diameter circular planters and several rectangular planters that range from 9 to 12 feet. These size planters are adequate to grow trees that will have a canopy width of at least 15 feet wide, similar to what is currently on the site. This is based on the following guidelines: providing 300 cubic feet (ft3) of soil will generally support growth of a small-sized tree to maturity (6-inch trunk diameter and 15-foot canopy), 600 ft3 of soil will generally support growth of a medium-sized tree (10-inch trunk diameter and 25-foot canopy), and 1,000 ft3 will generally support growth of a large tree (16-inch trunk diameter and 30-foot canopy) (Smiley 2022). Assuming a soil depth of 4 feet in the proposed planters, the smaller circular planters would have about 200 ft3 of soil, smaller square planters would have about 325 ft3, and the larger planters would provide 500 to 800 ft3. It is acknowledged than in-ground trees may convey a perception of greater permanence than trees in planters; however, from an arboriculture perspective, there is little difference. If fact, planter trees have more flexibility to be provided adequate root space and soil conditions. The tree planters proposed on the site range in size from 8 to 12 feet wide. While this is less space than trees have in a natural open space setting (i.e., non-urban setting), it is sufficient to allow for long-term establishment of small to medium sized trees in an urban setting.

Smiley, E. Thomas, PhD. 2022 (April 1, last accessed). Soils for Urban Tree Planting, Bartlett Tree Research Laboratory Technical Report. San Gabriel, CA: Bartlett Tree Expert Company; Dr. Smiley. Soil for Urban Tree Planting (bartlett.com).

Response 106.7. The Draft EIR included preparation of a Historical Resource Assessment, provided as Appendix C-1, that addressed all existing structures on the site over 45 years old, including 501 and 523 South Arroyo Parkway on the Project site, and addressed direct and indirect impacts to both the on-site historic resources and historic resources in the vicinity. The resources considered include landmark districts. The Historical Resource Assessment and associated analysis of direct, indirect, and cumulative impacts related to historic resources is 2 A resume for the arborist consulted on the Project – David T. Hughes of Psomas – is provided in Appendix B.

Affinity Project Final EIR
R:\Projects\PAS_Pasaden\3PAS012100\Environmental Documentation\RTC\Final_Affinity RTC_Revisions_MMRP-051222.docx 43 Responses to Comments presented in Section 3.2, Cultural and Paleontological Resources, in the Draft EIR. It is noted that CEQA requires that environmental impacts be assessed based on the existing conditions (baseline) which, for an EIR, are the conditions at the time the Notice of Preparation is distributed, with certain exceptions that must be supported by substantial evidence. As such, proposed or other possible future historic resources (such as the designation of the Madison Heights Neighborhood as a historic district) are not considered the same as those resources that were listed at the local, State, and/or federal levels at the time the IS/NOP for the Project was circulated.

Regarding impacts on historic resources pursuant to CEQA, as stated on page 3.2-13 of the Draft EIR:
“As determined in the Historical Resource Assessment, the Project site contains two historic resources: the buildings at 501 and 523 South Arroyo Parkway. Based on available plans, the Project would not involve the physical destruction of the buildings at 501 and 523 South Arroyo Parkway, nor would it result in any significant internal or external physical modifications that would compromise the historic integrity of the buildings. The Project would change the setting, but those changes would not physically alter the buildings and are not substantial enough to compromise the overall historic integrity or obstruct the view of the buildings from the public right-of-way. The surrounding area has been modified over time by new construction and modifications to existing buildings, including the construction of multi-story buildings, which has resulted in the disruption of the historical setting. Therefore, the Project would not result in a substantive adverse change to the historic integrity of the buildings at 501 and 523 South Arroyo Parkway.”
The historic resources in the Project vicinity considered in the Historical Resource Assessment are identified beginning on page 36 of that report (Appendix C-1 to the Draft EIR). These include the: Cornet Building, The Home Laundry Building, Bryan’s Cleaners, Pasadena Humane Society Building, Royal Laundry Complex, Raymond Flowers, George S. Hunt Studio & Shop Building, Wallace Neff Office, Don Carlos Court, Evanston Inn, Bryan Court, South Marengo Historic District, and the Marengo-Pico Landmark District.

The analysis of historic resources in the Project vicinity begins on page 54 of the Historical Resource Assessment (Appendix C-1 to the Draft EIR). In summary, based on the Historical Resource Assessment, prepared by architectural historians that meet the Secretary of the Interior’s Professional Qualifications Standards, no significant indirect impacts to existing historic resources in the Project site vicinity would occur with implementation of the Project (or Project with Building A Residential/Commercial). While it is acknowledged that architectural style and compatibility can be a subjective issue for the layperson, there is no evidence provided to support the assertion that the Project “could destroy the preservation and enhancement of this entire street, and nearby districts” with approval of the proposed height variance to facilitate preservation of the historic structures at 501 and 523 South Arroyo Parkway.

Please refer to Response 106.6 above for discussion of street tree replacement.

Regarding greenhouse gas (GHG) sequestration, an overall net increase in vegetation, including but not solely from trees, can be a factor in sustainable development. To that end, the proposed landscape plan would more than double the canopy of trees when mature in addition to the GHG sequestration from the non-tree landscape plantings proposed on the site. Rates of carbon sequestration vary among tree species but is a function of the tree growth rate. Urban trees will typically have a shorter life span than those in a natural environment due to the stresses of the urban environment, but they often have a faster growth rate when they receive regular irrigation. Because potted plants may have a shorter life span than in-ground trees, the total sequestration over a tree’s life span will be greater for an in-ground tree but the annual Affinity Project Final EIR
R:\Projects\PAS_Pasaden\3PAS012100\Environmental Documentation\RTC\Final_Affinity RTC_Revisions_MMRP-051222.docx 44 Responses to Comments sequestration rate will likely be comparable or higher for a tree in a planter. Like many issues pertaining to biological resources, there are numerous factors and nuances to each situation.

However, an approach that requires an exact project-by-project balancing of GHGs produced and sequestered, by a measure of parking spaces or vehicle trips, is neither feasible nor warranted to gauge the meeting State, federal, or local GHG reduction targets; it is also not the intent of Policy

10.13 of the City’s General Plan. Further, as discussed in Section 3.4, Greenhouse Gas Emissions, of the Draft EIR, implementation of the Project (or Project with Building A Residential/Commercial) would result in less than significant impacts related to both generation of GHG emissions or conflict with applicable plans, policies, or regulations adopted to reduce GHG emissions. It is acknowledged that the proposed vegetation would not offset all GHG emission generated by the Project; however, the Project is consistent with the vision and goals of the City’s Climate Action Plan, which seeks to reduce GHG emissions overall within the City.

Further, as discussed in Section 3.4 (pages 3.4-19 through 3.4-22), the Project is also consistent with the SCAG 2020–2045 Regional Transportation Plan/Sustainable Communities Strategy (Connect SoCal), the California Air Resources Board’s California’s Climate Change Scoping Plan, and Statewide GHG reduction goals for 2030 or 2050 identified in Executive Order S-3-05 and Senate Bill 32. This is because the reduction of VMT and VT per capita is of greater consequence to reduction of GHG emissions. The number of trips a project generates is not the key value, but rather the VMT and VT per capita as vehicles with combustion engines are a primary driver of climate change. High-density infill redevelopment that is situated near transit, like the Project or Project with Building A Residential/Commercial, results in a lower VMT and VT per capita for the site than in the existing condition regardless of how much landscaping and/or parking is included.

Response 106.8. The concept of walkability is not limited to the public ROW but is intended to also encompass private property areas through inclusion of plazas, seating areas, public art, human scale architecture at ground level and/or other features that make areas on and adjacent to the public ROW energized and inviting. These features exist whether any businesses are operating or not. In the existing condition, the Project site is not inviting to pedestrian movement both because of the disparate styles and scattered nature of existing structures as well as the lack of shade–as most trees on the site are tall queen palms that line the western property boundary–and extent of asphalt paving. In contrast, the Project includes a cohesive circulation system (both vehicular and pedestrian), a continuity in design throughout the site, and would provide more tree canopy cover at maturity. The architecture is designed to be human scale at ground level through facade articulation and setbacks for higher levels, among other characteristics.

Response 106.9. Please refer to Responses 106.1 through 106.8, above.

Affinity Project Final EIR
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R:\Projects\PAS_Pasaden\3PAS012100\Environmental Documentation\RTC\Final_Affinity RTC_Revisions_MMRP-051222.docx 47 Responses to Comments Response to Comment Letter 109
Protect Pasadena Trees
February 16, 2022
Response 109.1. Regarding tree replacement, the existing tree inventory is presented in Table 2-2 on page 2-3 of the Draft EIR. As shown by the headers in this table, there are trees on private property and trees in the public ROW (i.e., street trees). These are treated differently pursuant to the City’s tree protection ordinance. Specifically, as stated on page 2-2:
“Of these [40 trees inventoried on the site], 17 trees located in the ROW are protected under the City Trees and Tree Protection Ordinance. The remaining 23 trees are located on private property within the Project site and are not protected.” As discussed beginning on page 2-10 of the Draft EIR:
“the Project would result in the removal of 23 non-protected non-native trees on the Project site and 2 protected, non-native street trees.”

trees (one on Arroyo Parkway and one on California Boulevard). Additionally, the Draft EIR states that the Urban Forestry section of the City’s Public Works Department typically requires a fee to be remitted into the City’s street tree fund. This discussion referred solely to protected street trees.

Furthermore, the new street trees are not intended to be replacements for all trees removed nor is this asserted in the Draft EIR. The condition requiring two new street trees is not tied to the proposed street tree removals, but is related to existing vacancies along the sidewalk and/or locations that could accommodate a tree. Were the Applicant to pursue street tree removal through the City, including the Urban Forestry Advisory Committee (UFAC), the approval would require remittance of a fee–depending on the size of the tree(s) being removed–into the street tree fund and covering the cost of the tree removals. Additionally, it is noted that conditions of approval are the purview of the planning process, which is a parallel and separate process to the environmental (i.e., CEQA) process. Description of conditions of approval, where defined at the time the Draft EIR was prepared, are included in the Draft EIR only where relevant to the environmental analysis.

The statement that the Project removes trees with “no intention for a permanent replacement” is incorrect as Exhibits 2.16a–e, Conceptual Landscape Plan, following page 2-11 of the Draft EIR, illustrate the concept for proposed hardscape and landscape including the permanent installation of 38 trees of various species. As discussed further below, based on consultation with an ISA– certified arborist,3 the proposed landscape plan would more than double the tree canopy of the existing condition when mature. Moreover, the proposed landscape concept is consistent with the requirements of the Pasadena Municipal Code and, as discussed above, the Project would not conflict with the City’s tree protection ordinance. Therefore, this comment does not raise significant environmental issues not addressed in the Draft EIR.

Response 109.2. Regarding greenhouse gas (GHG) sequestration, an overall net increase in vegetation, including but not solely from trees, can be a factor in sustainable development. To that end, the proposed landscape plan would more than double the canopy of trees when mature in addition to the GHG sequestration from the non-tree landscape plantings proposed on the site.

Rates of carbon sequestration vary among tree species but is a function of the tree growth rate.

Urban trees will typically have a shorter life span than those in a natural environment due to the stresses of the urban environment, but they often have a faster growth rate when they receive 3 A resume for the arborist consulted on the Project – David T. Hughes of Psomas – is provided in Appendix B.

Affinity Project Final EIR
R:\Projects\PAS_Pasaden\3PAS012100\Environmental Documentation\RTC\Final_Affinity RTC_Revisions_MMRP-051222.docx 48 Responses to Comments regular irrigation. Because potted plants may have a shorter life span than in-ground trees, the total sequestration over a tree’s life span will be greater for an in-ground tree but the annual sequestration rate will likely be comparable or higher for a tree in a planter. Like many issues pertaining to biological resources, there are numerous factors and nuances to each situation.

However, an approach that requires an exact project-by-project balancing of GHGs produced and sequestered is neither feasible nor warranted to gauge the meeting State, federal, or local GHG reduction targets; it is also not the intent of Policy 10.13 of the City’s General Plan. Further, as discussed in Section 3.4, Greenhouse Gas Emissions, of the Draft EIR, implementation of the Project (or Project with Building A Residential/Commercial) would result in less than significant impacts related to both generation of GHG emissions or conflict with applicable plans, policies, or regulations adopted to reduce GHG emissions. It is acknowledged that the proposed vegetation would not offset all GHG emission generated by the Project; however, the Project is consistent with the vision and goals of the City’s Climate Action Plan, which seeks to reduce GHG emissions overall within the City. The reduction of VMT and VT per capita is of greater consequence to reduction of GHG emissions. The number of trips a project generates is not the key value, but rather the VMT and VT per capita as vehicles with combustion engines are a primary driver of climate change. High-density infill redevelopment that is situated near transit, like the Project, results in a lower VMT and VT for the site than in the existing condition regardless of how much landscaping is included.

Regarding wildlife diversity, the replacement of the street trees, as discussed in Response 109.1 above, is not specifically intended to provide support for wildlife diversity nor is this intention asserted in the Draft EIR. Regardless, the existing environment on the site does little to support wildlife diversity and it is expected that in both the existing and proposed conditions only urbanadapted wildlife species would use the site. However, there would be a 65 percent increase in the number of trees on the site with Project implementation. This fact, along with the presence of vegetation on multiple levels, would make the site comparatively more inviting for wildlife than in the existing condition. This is in part because most of the trees on the site are mature queen palms that only a relatively small subset of urban wildlife species routinely uses for roosting, foraging, or nesting.

Regarding the heat island effect, the assertion that the trees and other plants installed in pots do not contribute to the reduction of a heat island is unsupported by evidence. The ability of trees to mitigate a heat island effect is a function of the shade they provide, which is dependent on the species and the area provided for root development whether in the ground or an above ground planter. As discussed on page 2-11 of the Draft EIR:
“Regarding the creation of a heat island and/or increase of the local heat index, the Project would result in at worst a neutral contribution to the heat index in the area. Heat islands are created by a combination of heat-absorbing surfaces (such as dark pavement and roofing), heat-generating activities (such as engines and generators), and the absence of vegetation (which provides evaporative cooling).

It is noted that of the 23 on-site trees to be removed, 19 are queen palms (Syagrus romanzoffiana), which provide little shade. They do provide some measure of evaporative cooling, which can help offset the heat index, but not at ground level. Additionally, the site currently contributes to the urban heat island effect by consisting almost entirely of asphalt or concrete surface and buildings. The hydrology study prepared for the Project (and provided as Appendix C of the Initial Study) assessed that the site is currently 97 percent impervious surface area. With implementation of the Project, the site would be 98 percent ground-level impervious surface area. However, with the Project there is a net increase in vegetation on the site compared to the existing condition, with landscaping at the ground level and on levels 2, 3, and 6. All vegetation, whether in ground or planters, provides Affinity Project Final EIR
R:\Projects\PAS_Pasaden\3PAS012100\Environmental Documentation\RTC\Final_Affinity RTC_Revisions_MMRP-051222.docx 49 Responses to Comments evaporative cooling. Under the Project with Building A Residential/Commercial, the landscape (including tree removal and planting), hardscape, and lighting would be the same as that discussed for the Project.

Furthermore, of the 23 on-site trees to be removed, 2 are mature Canary Island pine trees that produce significant shade, 19 are queen palms with a canopy width of approximately 15 feet that produce only moderate shade (at the ground level), 1 is an African fern pine with a canopy diameter of approximately 15 feet that produces moderate shade; and 1 is a small pecan tree that produces minimal shade. The existing tree canopies range from 10 to 15 feet wide. Based on the number and size of existing trees, the total canopy on the site is approximately 4,100 square feet (sf). The 38 trees that would be installed (15 more than being removed) include species that produce canopies at maturity that are at least as wide as the canopies that are being removed (e.g., tipu tree, desert willow, gingko, western redbud, palo verde). At the time of planting, the replacement trees would have canopies that provide approximately 75 percent of the shade as the existing trees. However, the proposed tree planters are distributed in areas where pedestrian activity is expected, whereas the existing trees are primarily along the western site boundary (queen palms) or are otherwise not in locations with notable pedestrian activity in the existing condition. As a result of the Project, more trees would be planted on the site and the average canopy spread of these trees at maturity would be at least as wide as the existing trees. Based on the planter size, species, and number of each tree proposed, the proposed on-site trees would create a canopy of approximately 3,100 sf at planting and approximately 9,200 sf at maturity.

Regarding in-ground trees versus potted trees, the amount and quality of soil provided to the tree are defining factors in a tree’s maximum size and usable life span in an urban environment. The street trees near the site and through much of the City are planted in four-foot by eight-foot sidewalk cutouts, which can be considered a tougher environment than an above ground planter for a variety of reasons, including limited usable soil for root growth, poor drainage, and damage by people or vehicles. The landscape plan indicates 8-foot-diameter circular planters and several rectangular planters that range from 9 to 12 feet. These size planters are adequate to grow trees that will have a canopy width of at least 15 feet wide, similar to what is currently on the site. This is based on the following guidelines: providing 300 cubic feet (ft3) of soil will generally support growth of a small-sized tree to maturity (6-inch trunk diameter and 15-foot canopy), 600 ft3 of soil will generally support growth of a medium-sized tree (10-inch trunk diameter and 25-foot canopy), and 1,000 ft3 will generally support growth of a large tree (16-inch trunk diameter and 30-foot canopy) (Smiley 2022). Assuming a soil depth of 4 feet in the proposed planters, the smaller circular planters would have about 200 ft3 of soil, smaller square planters would have about 325 ft3, and the larger planters would provide 500 to 800 ft3. It is acknowledged than in-ground trees may convey a perception of greater permanence than trees in planters; however, from an arboriculture perspective, there is little difference. In fact, planter trees have more flexibility to provide adequate root space and soil conditions. The tree planters proposed on the site range in size from 8 to 12 feet wide. While this is less space than trees have in a natural open space setting (i.e., non-urban setting), it is sufficient to allow for long-term establishment of small to medium sized trees in an urban setting. Thus, the Project is not in conflict with General Plan Policy 10.13.

Smiley, E. Thomas, PhD. 2022 (April 1, last accessed). Soils for Urban Tree Planting, Bartlett Tree Research Laboratory Technical Report. San Gabriel, CA: Bartlett Tree Expert Company; Dr. Smiley. Soil for Urban Tree Planting (bartlett.com).

Response 109.3. Regarding effects on street trees protected in place during construction, the assertion that construction activity that abuts lot lines will necessarily “destroy all trees” (assumed to be street trees to be protected in place) is unsubstantiated. If this were the case, there would be numerous cases of extensive street tree failure adjacent to the many infill redevelopment projects, which generally have subterranean parking, that have been developed in the past Affinity Project Final EIR
R:\Projects\PAS_Pasaden\3PAS012100\Environmental Documentation\RTC\Final_Affinity RTC_Revisions_MMRP-051222.docx 50 Responses to Comments several years throughout the City. Based on consultation with a certified arborist,4 the depth of a tree’s root zone varies based on the species and the soil conditions. However, most trees have a root mass (especially in an urban environment) within 4 feet of ground surface. A tree can die when their root zone, which extends out to the canopy edge in open space situations and to the hardscape boundary in urban situations, is significantly affected. What constitutes a significant effect would vary based on the tree species, existing condition of the tree(s), and type of disturbance. At the Project site, the street trees are placed in wells that abut the street ROW rather than the property or lot line and the sidewalks are eight feet wide; this positions the street tree trunks approximately six feet from the lot line. As such, there is adequate space for the majority, if not all, of the root mass to be protected within 4 feet from the lot line and 4 feet in depth while allowing Project construction.

Regarding consistency of the Project with treatment of street trees and the City’s “urban forest policy”, please refer to Responses 109.1 and 109.2, above.

Regarding conditions of approval pertaining to trees, please refer to Response 109.1, above.

Response 109.4. Please refer to Responses 109.1 through 109.3, above, regarding GHG sequestration and on-site landscaping.

Response 109.5. This comment related to street trees and development patterns in the City is acknowledged. The comment does not address the content or adequacy of the Draft EIR under CEQA or the State CEQA Guidelines; however, the comments are noted for the administrative record and will be provided to the decision-makers for review and consideration.

Response 109.6. Please refer to Responses 109.1 and 109.2, above, regarding street tree replacement and General Plan consistency.

4 A resume for the arborist consulted on the Project – David T. Hughes of Psomas – is provided in Appendix B.

Affinity Project Final EIR
R:\Projects\PAS_Pasaden\3PAS012100\Environmental Documentation\RTC\Final_Affinity RTC_Revisions_MMRP-051222.docx 51 Responses to Comments Affinity Project Final EIR
R:\Projects\PAS_Pasaden\3PAS012100\Environmental Documentation\RTC\Final_Affinity RTC_Revisions_MMRP-051222.docx 52 Responses to Comments Affinity Project Final EIR
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R:\Projects\PAS_Pasaden\3PAS012100\Environmental Documentation\RTC\Final_Affinity RTC_Revisions_MMRP-051222.docx 54 Responses to Comments Response to Comment Letter 110
Residents of Magnolia Landmark District
February 10, 2022
Response 110.1. Please refer to Response 106.2, above, regarding vehicle trips. In summary, trip generation and trip credits, based on the ITE manual, are unrelated to the transportation analysis performed as part of the Draft EIR, which is a methodology revolving around VMT.

Calculation of trip generation and the associated methodology are related to LOS, which is not addressed as part of CEQA. This is addressed in the “Outside CEQA” studies prepared by the Pasadena DOT and used for circulation planning. It is noted that net trip generation data is used solely in the noise and vibration analysis (refer to Table 3.7-5, Net Trip Generation for the Project, on page 3.7-13 and Table 3.7-7, Net Trip Generation for the Project with Building A Residential/Commercial, on page 3.7-16 of the Draft EIR) to assess off-site traffic noise. The air quality, energy, and GHG emissions modeling is not based on net increase in trips but on total operational trips for the proposed uses. The Outside CEQA analysis does not factor into the results of the CEQA transportation analysis, or vice versa, as they measure different metrics and are used for different purposes. Further, the number of parking spaces is not correlated with net trip generation but is based on the City’s zoning code.

Regarding circulation along the California Boulevard corridor, the intersections of Arroyo Parkway at California Boulevard and Marengo Avenue at California Boulevard are currently being operated by the City’s SCATS. SCATS allows for the real-time adjustment of signal timing at traffic signals to manage congestion. The system balances the vehicle demand for signals along a corridor or network using data from in-ground loops or video detection at each intersection. Adaptive controls are beneficial along arterials that experience variable and changing demands in traffic, such as areas near the Metro light rail crossings. The City first installed this system along the South Fair Oaks Avenue corridor, and it resulted in favorable traffic conditions. In 2019, Pasadena DOT expanded the SCATS network to include streets that parallel the Metro light rail crossings; this included the intersections of Arroyo Parkway at California Boulevard and Marengo Avenue at California Boulevard. Since installation of the SCATS, there has been a reduction of traffic collisions at both intersections. In the past five years, the intersection of Arroyo Parkway at California Boulevard has averaged four collisions per year. Even with the increase in traffic volumes at both these signalized intersections and observed instances of congestion, the safety of the intersections has not been reduced. Pasadena DOT is currently in construction of the next phase of the adaptive network. The signals along California Boulevard at Los Robles Avenue, El Molino Avenue, Hudson Avenue, and Lake Avenue will be added to the SCATS network. The expansion of the adaptive signals will facilitate continued improvements along the California Boulevard corridor. The City is also actively working with Metro to obtain data from approaching trains. This data will be analyzed to further enhance signal timing of the intersections adjacent to the grade crossings.

For the intersection of California Boulevard and Marengo Avenue, City records indicate that, for the five-year period from January 1, 2017, through December 31, 2021, there were a total of 13 reported collisions at this intersection, broken down by year as follows: 3 in 2017, 4 in 2018, 2 in 2019, 3 in 2020, and 1 in 2021. Of the 13 collisions, 6 resulted in injuries and 0 resulted in fatalities.

On average, there were 2.6 reported collisions per year at this intersection over this five-year period. The collision history for the intersection of California Boulevard and Magnolia Avenue was also reviewed. For the five-year period from January 1, 2017, through December 31, 2021, there were a total of two reported collisions at the intersection of California Boulevard and Marengo Avenue, resulting in an annual average of 0.4 collisions per year. These two intersections are also not considered high collision locations, as discussed for the South Arroyo Parkway and Affinity Project Final EIR
R:\Projects\PAS_Pasaden\3PAS012100\Environmental Documentation\RTC\Final_Affinity RTC_Revisions_MMRP-051222.docx 55 Responses to Comments California Boulevard intersection in the Draft EIR. Pasadena DOT continues to monitor operations along the corridor to address traffic signal operations and reduce the potential for collisions.

To compare crash rates for facilities throughout the State, Caltrans annual crash data for roadways and intersections was reviewed. The latest published data was released on October 6, 2020 and includes data for 2018. The Basic Average Crash Rate for Intersections provides crash rates as crashes per million vehicles entering the intersection. The basic average crash rate for intersections controlled by a traffic signal in an urban area is 0.24 crashes per million vehicles entering the intersection. The crash rate for the intersection of Marengo Avenue and California Boulevard is 0.20 crashes per million vehicles entering the intersection is, therefore, below the State average for a signalized urban intersection.

To reiterate, the City’s collision data is inclusive of all transportation modes, including pedestrian and bicycle. While it may appear that safety is an issue for non-vehicular modes as a day-to-day experience, the numerical data do not support this assertion at either the local or State level.

Response 110.2. Please refer to Response 110.1, above, regarding vehicle trips and transportation safety. Please refer to Response 106.7, above, regarding historic resources. In summary, based on the Historical Resource Assessment, no significant indirect impacts to existing historic resources in the Project site vicinity would occur with implementation of the Project (or Project with Building A Residential/Commercial). Additionally, it is noted that conditions of approval are the purview of the planning process, which is a parallel and separate process to the environmental (i.e., CEQA) process. Description of conditions of approval, defined at the time the Draft EIR was prepared, are included in the Draft EIR only where relevant to the environmental analysis.

Regarding off-site traffic noise, Section 3.7 of the Draft EIR determined that neither the project nor Project with Building A Residential/Commercial, would result in a substantial permanent change in noise levels. There would be less than significant related to traffic noise.

Response 110.3. Please refer to Responses 106.3 and 110.1, above, regarding transportation safety. In summary, it is noted the City’s collision data is inclusive of all transportation modes, including pedestrian and bicyclist. While it may appear that safety is an issue for non-vehicular modes as a day-to-day experience in the Project area, the numerical data do not support this assertion at either the local or State level. Traffic issues, including delay at traffic signals and other intersections, is addressed as part of the “Outside CEQA” or LOS-based analysis that Pasadena DOT prepares for development projects as part of Citywide circulation planning.

Response 110.4. Please refer to Responses 110.1 through 110.3, above, regarding vehicle trips and transportation. As discussed, the CEQA-compliant transportation analysis relies on the City’s TDF model and not trip calculation and the associated LOS methodology. There would be no significant impact related to transportation pursuant to CEQA, and no mitigation is required.

It is noted that in CEQA, mitigation measures are applied only when a significant environmental impact is identified. There would be no significant direct or indirect impacts related to historic resources or land use and planning, as addressed in Sections 3.2 and 3.6, respectively, of the Draft EIR. No evidence has been presented that substantiates the assertion that the Project would “erode our surrounding historical neighborhood”.

Response 110.5. Please refer to Response 106.7, above, regarding historic resources. In summary, the analysis of historic resources in the Project vicinity begins on page 54 of the Historical Resource Assessment (Appendix C-1 to the Draft EIR). In summary, based on the Historical Resource Assessment, prepared by architectural historians that meet the Secretary of the Interior’s Professional Qualifications Standards, no significant indirect impacts to existing Affinity Project Final EIR
R:\Projects\PAS_Pasaden\3PAS012100\Environmental Documentation\RTC\Final_Affinity RTC_Revisions_MMRP-051222.docx 56 Responses to Comments historic resources in the Project site vicinity would occur with implementation of the Project (or Project with Building A Residential/Commercial). There would be no significant direct or indirect impacts related to historic resources or land use and planning, as addressed in Sections 3.2 and

3.6, respectively, of the Draft EIR. The Project would be consistent with the City’s General Plan and Central District Specific Plan, as discussed beginning on page 3.6-6 of the Draft EIR. The City’s current General Plan and the Central District Specific Plan were reviewed pursuant to CEQA and the State CEQA Guidelines prior to their adoption.

Response 110.6. Please refer to Response 106.6, above, regarding street trees. In summary, page 2-10 of the Draft EIR states a condition of approval will require planting of two new street trees (one on Arroyo Parkway and one on California Boulevard). Additionally, the Draft EIR states that the Urban Forestry section of the City’s Public Works Department typically requires a fee to be remitted into the City’s street tree fund. This discussion referred solely to protected street trees.

Furthermore, the new street trees are not intended to be replacements for all trees removed nor is this asserted in the Draft EIR. The condition requiring two new street trees is not tied to the proposed street tree removals, but is related to existing vacancies along the sidewalk and/or locations that could accommodate a tree. Were the Applicant to pursue street tree removal through the City, including the Urban Forestry Advisory Committee (UFAC), an approval would require remittance of a fee–depending on the size of the tree(s) being removed–into the street tree fund and covering the cost of the tree removals. It is noted that in CEQA, mitigation measures are applied only when a significant environmental impact is identified. The potential impacts of the Project have been identified in the Draft EIR, and feasible mitigation measures have been incorporated.

Response 110.7. Please refer to Responses 106.1, 106.3, 106.6, and 110.1 above, regarding aesthetics, landscape planning, vehicle trips, and safety; and Response 109.1, above, regarding landscape planning. In summary, regarding building height, aesthetic issues were addressed in Section 2.1, Aesthetics, of the Initial Study that was provided as Appendix A-1 to the Draft EIR.

As discussed, consistent with SB 743 (Section 21099[d] of the Public Resources Code), the aesthetic effects of the Project are not considered significant environmental impacts pursuant to CEQA and the topic was not carried forward for further evaluation in the Draft EIR. Exhibits

2.16a–e, Conceptual Landscape Plan, following page 2-11 of the Draft EIR, illustrate the concept for proposed hardscape and landscape. The proposed landscape concept is consistent with the requirements of the Pasadena Municipal Code and, as discussed above in Response 112.6, the Project would not conflict with the City’s tree protection ordinance.

Regarding infrastructure, Section 3.8, Public Services and Recreation, of the Draft EIR addresses fire protection and emergency medical services, police protection, school services, library services, and parks and recreation services, and Section 3.11, Utilities and Service Systems, addresses wet (i.e., water and sewer) and dry (i.e., electric, natural gas, telecommunications) utilities and solid waste disposal. As discussed beginning on page 3.8-10, the Pasadena Fire Department, Pasadena Police Department, Pasadena Public Library, and City Parks, Recreation, and Community Services Department concluded that implementation of the Project or Project with Building A Residential/Commercial would not result in the need for new or expanded facilities to adequately serve the community. Regarding schools, the General Plan EIR states that Pasadena Unified School District has capacity to accommodate the student population estimated for the City at General Plan buildout, which would include the Project and Project with Building A Residential/Commercial, with excess classroom capacity for all grade levels. It is noted that only the Project with Building A Residential/Commercial would generate school-age children.

Additionally, as discussed beginning on page 3.11-13, there is sufficient capacity in the existing water and wastewater lines to adequately serve the Project (or Project with Building A Residential/ Commercial), both individually and cumulatively, and no relocation or construction of new or expanded wet utilities would be necessary. Dry utilities are provided as required by the public Affinity Project Final EIR
R:\Projects\PAS_Pasaden\3PAS012100\Environmental Documentation\RTC\Final_Affinity RTC_Revisions_MMRP-051222.docx 57 Responses to Comments pursuant to regulation by the California Public Utilities Commission. As discussed in Response 110.1, the City’s collision data is inclusive of all transportation modes, including pedestrian and bicycle. While it may appear that safety is an issue for non-vehicular modes as a day-to-day experience, the numerical data do not support this assertion at either the local or State level. No evidence has been presented to substantiate there would be additional impacts than those disclosed in the Draft EIR.

Response 110.8. Please refer to Responses 106.6 and 110.6, above, regarding conditions of approval and street trees. In summary, Page 2-10 of the Draft EIR states a condition of approval will require planting of two new street trees (one on Arroyo Parkway and one on California Boulevard). Additionally, the Draft EIR states that the Urban Forestry section of the City’s Public Works Department typically requires a fee to be remitted into the City’s street tree fund. This discussion referred solely to protected street trees. Furthermore, the new street trees are not intended to be replacements for all trees removed nor is this asserted in the Draft EIR. The condition requiring two new street trees is not tied to the proposed street tree removals, but is related to existing vacancies along the sidewalk and/or locations that could accommodate a tree.

Were the Applicant to pursue street tree removal through the City, including the Urban Forestry Advisory Committee (UFAC), the approval would require remittance of a fee–depending on the size of the tree(s) being removed–into the street tree fund and covering the cost of the tree removals. As noted previously, description of conditions of approval, where defined at the time the Draft EIR was prepared, are included in the Draft EIR only where relevant to the environmental analysis.

Affinity Project Final EIR
R:\Projects\PAS_Pasaden\3PAS012100\Environmental Documentation\RTC\Final_Affinity RTC_Revisions_MMRP-051222.docx 58 Responses to Comments Affinity Project Final EIR
R:\Projects\PAS_Pasaden\3PAS012100\Environmental Documentation\RTC\Final_Affinity RTC_Revisions_MMRP-051222.docx 59 Responses to Comments Response to Comment Letter 111
Supporters Alliance for Environmental Responsibility
March 2, 2022
Response 111.1. This comment related to inadequacy of the Draft EIR is acknowledged. The comment does not raise any significant environmental issues (see Section15088[a] of the State CEQA Guidelines) nor provides any evidence supporting the assertion that the Draft EIR is inadequate and a Recirculated EIR should be prepared. No changes to the Draft EIR are necessary and a revised EIR is not required. However, the comments are noted for the administrative record and will be provided to the decision-makers for review and consideration.

Affinity Project Final EIR
R:\Projects\PAS_Pasaden\3PAS012100\Environmental Documentation\RTC\Final_Affinity RTC_Revisions_MMRP-051222.docx 60 Responses to Comments Affinity Project Final EIR
R:\Projects\PAS_Pasaden\3PAS012100\Environmental Documentation\RTC\Final_Affinity RTC_Revisions_MMRP-051222.docx 61 Responses to Comments Affinity Project Final EIR
R:\Projects\PAS_Pasaden\3PAS012100\Environmental Documentation\RTC\Final_Affinity RTC_Revisions_MMRP-051222.docx 62 Responses to Comments Response to Comment Letter 112
West Pasadena Residents Association
March 2, 2022
Response 112.1. Based on consideration of all comments received on the Draft EIR, as provided in this document, the assertion that the Draft EIR has “legal issues and are potentially flawed or unacceptable” is unsubstantiated. Please refer to Responses 112.2 through 112.7, below.

Response 112.2. As discussed on page 2-7 of the Draft EIR:
“Section 15124 of the State CEQA Guidelines defines what information shall be contained in a project description for purposes of analysis in an EIR. The concept of a stable and finite project description is shaped by selected published CEQA court decisions. The project description provided in this Draft EIR meets the requirements of Section 15124 and is also stable and finite. A stable and finite project description, as interpreted in the relevant legal cases, is not synonymous with allowing only a single development scenario.

The siting, mass, and outward appearance of the Project, regardless of scenario, is clearly defined both in this EIR and in the Initial Study. The upper limits of development of both buildings for both scenarios is clearly defined, and the Initial Study and this EIR address both scenarios in distinct, separate analyses. Therefore, the project description provided in this Draft EIR is legally adequate and allows for a full and robust analysis of all potential impacts of implementing either the Project or Project with Building A Residential/Commercial, if approved.”
The assertion that an Applicant must define and commit to the specific use of a project (i.e., the Project or Project with Building A Residential/Commercial) is not supported in CEQA case law.

Response 112.3. Please refer to Responses 106.2, 106.3, and 106.7, above, regarding vehicle trips. As discussed, the CEQA-compliant transportation analysis relies on the City’s TDF model and not trip calculation and the associated LOS methodology. Per the detailed analysis contained in the Transportation section of the Draft EIR, there would be no significant impacts related to transportation, and no mitigation is required. The application of rates from the ITE manual is a standard industry procedure. Moreover, traffic counts from existing developments and on street networks during the pandemic are significantly different from what was typically occurring prior to the pandemic. Traffic count data used in the analysis is based on counts on file and Streetlight Data Analytics information from the annual average daily traffic from 2017 to 2019 along the study segment and intersection locations. Regarding the statement that existing daily traffic counts are “likely less than 10% of this [2,454 trips] figure”, empirical site surveys during the pandemic to verify the existing land use trip volumes would not provide a representation of normal nonpandemic conditions. Since the existing uses on the Project site are currently active, and with many unknowns due to the inability to conduct traffic count surveys, the City made the decision to use industry accepted trip generation rates found in the ITE manual to calculate land use traffic volumes to estimate the number of total project trips minus the number of existing trips to determine the net project trips for evaluation.

Regarding the reference to a table named “Net Trip Generation for the Project”, this is Table 3.7- 5 in Section 3.7, Noise, of the Draft EIR. The trip generation data in this table (Table 3.7-5 on page 3.7-13) and Table 3.7-7, Net Trip Generation for the Project with Building A Residential/Commercial, on page 3.7-16, is used in relation solely to the noise and vibration analysis. The air quality, energy, and GHG emissions modeling is not based on net increase in trips but on total estimated trips for operation of the proposed uses.

Affinity Project Final EIR
R:\Projects\PAS_Pasaden\3PAS012100\Environmental Documentation\RTC\Final_Affinity RTC_Revisions_MMRP-051222.docx 63 Draft EIR Clarifications and Revisions Response 112.4. Please refer to Response 112.3, above, regarding vehicle trips. As discussed, it is acknowledged that traffic counts from existing developments and on street networks during the pandemic are significantly different from what was typically occurring prior to the pandemic.

Empirical site surveys during the pandemic to verify the existing land use trip volumes would not provide a representation of normal non-pandemic conditions. Since the existing uses on the Project site are currently active, and with many unknowns due to the inability to conduct traffic count surveys, the City made the decision to use industry accepted trip generation rates found in the ITE manual to calculate land use traffic volumes to estimate the number of total project trips minus the number of existing trips to determine the net project trips for evaluation.

Regarding off-site traffic noise, there would be no change in the noise analysis even if the total and not net trip generation (based on the ITE manual) were applied. First, as stated on page 3.7-14 of the Draft EIR, “A three-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 [see Table 3.7-6 on page 3.7-14 in the Draft EIR], 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.” Furthermore, as stated on page 3.7-14, “It is noted that the percent change in trips is 6 percent or below on all street segments except on (1) Arroyo Parkway between California Boulevard and (2) Bellevue Drive and on Bellevue Drive between Arroyo Parkway and Marengo Avenue.” It is noted that 3 decibels is considered just perceptible to human hearing. In other words, the percentage change in average daily trips on any street segment in the vicinity would need to be 100 percent or more to result in a noise increase that may be perceptible to some individuals. Doubling the net traffic trips of the Project estimated at 3,913 trips equals 7,826 trips; this is higher than the estimated total (i.e., not net) Project trips of 6,366. As such, the traffic volumes from the Project (or Project with Building A Residential/Commercial), theoretically even doubled–in other words a maximum increase of 38 percent–would not result in a perceptible change in the traffic noise level on any street segment. To demonstrate that even if the estimated additional ADT shown in Table 3.7-6 on page 3.7-14 of the Draft EIR were doubled, Table 2 below presents this information and the corresponding percent change in traffic levels on each segment.

As shown, the highest increase would be 38 percent, which remains well below the 100 percent (or doubling of total traffic levels) to result in a 3 dBA increase. Even if the analysis did not apply a trip reduction for the existing uses, the Project’s contribution to roadway noise would still be well below the significance thresholds. For example, a simple approach to considering the effects of a higher contribution of trips from the Project is to double the Project’s contribution of trips to each of the studies street segments, as presented above. This is a conservative approach because it assumes more total trips (7,826) than the Project would generate at buildout without any reduction in trips for existing uses (6,366). Because the Project with Building A Residential/Commercial would generate fewer daily trips than the Project, this comparison of anticipated versus doubled additional trips would result in the same conclusion as for the Project.

Affinity Project Final EIR
R:\Projects\PAS_Pasaden\3PAS012100\Environmental Documentation\RTC\Final_Affinity RTC_Revisions_MMRP-051222.docx 64 Responses to Comments TABLE 2

DOUBLED ADDITIONAL STREET SEGMENT ADT WITH THE PROJECT
(YEAR 2026)
Street Segment Existing ADT
Double Additional
ADT Net Change
Bellevue Dr. b/t Arroyo Prkwy. and Marengo Ave. 850 320 38% Bellevue Dr. west of Arroyo Prkwy. 4,690 0 0%
Arroyo Prkwy. b/t Bellevue Dr. and Del Mar Blvd. 17,040 980 6% Arroyo Prkwy. b/t Bellevue Dr. and California Blvd. 16,200 1300 8% California Blvd. b/t Raymond Ave. and Arroyo Prkwy. 17,060 1800 11% California Blvd. b/t Raymond Ave. and Fair Oaks Ave. 14,640 600 4% Raymond Ave. b/t California Blvd. and Bellevue Dr. 9,780 1200 12% Raymond Dr. b/t California Blvd. and Pico Street 9,140 0 0% California Blvd. b/t Arroyo Prkwy. and Marengo Ave. 24,750 2,560 10% California Blvd. b/t Arroyo Prkwy. and Raymond Ave. 21,020 1080 5% Arroyo Prkwy. b/t California Blvd. and Bellevue Dr. 17,990 4,960 28% Arroyo Prkwy. b/t California Blvd. Pico Street 26,540 1960 7% Arroyo Prkwy. b/t Del Mar Blvd. and Bellevue Dr. 16,220 960 6% Arroyo Prkwy. b/t Glenarm Street and Fillmore Street 24,000 1960 8% ADT: average daily trips; b/t: between; Dr.: Drive; Prkwy.: Parkway; Ave.: Avenue; Blvd.: Boulevard Response 112.5. As noted from the Draft EIR in Response 112.2 above, both “the Initial Study and the Draft EIR address both scenarios in distinct, separate analyses.” There are differences in the effects between the development of Building A as a medical office building or a residential building. The two development scenarios and their associated impacts are separately and clearly defined throughout Draft EIR. Moreover, as discussed above, the difference in trip generation between the two possible development scenarios is immaterial to the Draft EIR transportation analysis.

Response 112.6. Please refer to Response 106.5, above, regarding cumulative traffic effects. In summary, cumulative impacts were thoroughly considered in the Draft EIR, using the most conservative assumption possible–the buildout of the General Plan. Based on this, the Project would not result in a cumulatively considerable impact related to transportation, and no mitigation is required. The finding is the same for the Project with Building A Residential/Commercial (refer to page 3.9-13 of the Draft EIR).

Response 112.7. The portion of the comment related to the City’s planning process for the Project (items A, B, and C) is acknowledged; as they do not directly raise any significant environmental issues, no further response is presented. However, these comments are noted for the administrative record and will be provided to the decision-makers for review and consideration.

Regarding historic resources in the Project vicinity, please refer to Responses 106.6 and 106.7 above. In summary, the Project site is situated away from residential neighborhoods. Except for the five-story, mixed-use building at 482 South Arroyo Parkway, approximately 100 feet from the site on the east side of Arroyo Parkway across the street from the site, the nearest residential uses are located more than 250 to the east and are buffered by commercial development along the east side of Arroyo Parkway. As such, the Project is an appropriate siting for infill redevelopment and is consistent with the City’s General Plan and Central District Specific Plan, as discussed beginning on page 3.6-6 of the Draft EIR. Additionally, the Draft EIR included preparation of a Historical Resource Assessment (provided as Appendix C-1) that addressed direct and indirect impacts to both the on-site historic resources and historic resources in the Affinity Project Final EIR
R:\Projects\PAS_Pasaden\3PAS012100\Environmental Documentation\RTC\Final_Affinity RTC_Revisions_MMRP-051222.docx 65 Responses to Comments vicinity. No significant indirect impacts to existing historic resources in the Project site vicinity would occur with implementation of the Project (or Project with Building A Residential/Commercial).

Affinity Project Final EIR
R:\Projects\PAS_Pasaden\3PAS012100\Environmental Documentation\RTC\Final_Affinity RTC_Revisions_MMRP-051222.docx 66 Responses to Comments Affinity Project Final EIR
R:\Projects\PAS_Pasaden\3PAS012100\Environmental Documentation\RTC\Final_Affinity RTC_Revisions_MMRP-051222.docx 67 Responses to Comments Response to Comment Letter 114
Bob Aronoff
February 23, 2022
Response 114.1. Water supply was addressed in Section 3.11, Utilities and Service Systems, of the Draft EIR. Also, as discussed beginning on page 3.11-1 of the Draft EIR, a water supply assessment (WSA) was prepared for the Project. As stated on page 3.11-1:
“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 this EIR (California 2021), a WSA was prepared for the Project and Project with Building A Residential/Commercial to inform the environmental analysis.” The results of the WSA were summarized in Section 3.11, Utilities and Service Systems, of the Draft EIR and provided as Appendix I. As discussed on page 3.11-23:

Therefore, there would be sufficient water supplies available to serve the Project and reasonably foreseeable future development during normal, dry, and multiple dry years.

There would be a less than significant impact related to water supplies…” The WSA also assessed water demand for the Project with Building A Residential/Commercial and concluded there would be a less than significant impact.

Response 114.2. Please refer to Responses 106.2, 106.3, and 106.7, above, regarding traffic.

As discussed, the CEQA-compliant transportation analysis relies on the City’s TDF model and not trip calculation and the associated LOS methodology. There would be no significant impacts related to transportation, and no mitigation is required.

Response 114.3. This comment related to development patterns in the City is acknowledged.

The comment does not address the content or adequacy of the Draft EIR under CEQA or the State CEQA Guidelines; however, the comments are noted for the administrative record and will be provided to the decision-makers for review and consideration.

Response 114.4. This comment related to whom the possible future residents of the Project would be is acknowledged. The comment does not address the content or adequacy of the Draft EIR under CEQA or the State CEQA Guidelines; however, the comments are noted for the administrative record and will be provided to the decision-makers for review and consideration.

Affinity Project Final EIR
R:\Projects\PAS_Pasaden\3PAS012100\Environmental Documentation\RTC\Final_Affinity RTC_Revisions_MMRP-051222.docx 68 Responses to Comments Affinity Project Final EIR
R:\Projects\PAS_Pasaden\3PAS012100\Environmental Documentation\RTC\Final_Affinity RTC_Revisions_MMRP-051222.docx 69 Responses to Comments Affinity Project Final EIR
R:\Projects\PAS_Pasaden\3PAS012100\Environmental Documentation\RTC\Final_Affinity RTC_Revisions_MMRP-051222.docx 70 Draft EIR Clarifications and Revisions Response to Comment Letter 116
Nina Chomsky
March 2, 2022
Response 116.1. As discussed on page 2-7 of the Draft EIR:
“Section 15124 of the State CEQA Guidelines defines what information shall be contained in a project description for purposes of analysis in an EIR. The concept of a stable and finite project description is shaped by selected published CEQA court decisions. The project description provided in this Draft EIR meets the requirements of Section 15124 and is also stable and finite. A stable and finite project description, as interpreted in the relevant legal cases, is not synonymous with allowing only a single development scenario.

The siting, mass, and outward appearance of the Project, regardless of scenario, is clearly defined both in this EIR and in the Initial Study. The upper limits of development of both buildings for both scenarios is clearly defined, and the Initial Study and this EIR address both scenarios in distinct, separate analyses. Therefore, the project description provided in this Draft EIR is legally adequate and allows for a full and robust analysis of all potential impacts of implementing either the Project or Project with Building A Residential/Commercial, if approved.”
While the Draft EIR is not required to cite a legal authority to support the analysis of the Project and Project with Building A Residential/Commercial, which are clearly defined in Section 2.0 of the Draft EIR, multiple cases support this approach with the South of Market Community Action Network et al. v. City and County of San Francisco case being a recent example. The comment provides no specific examples or other evidence to support the assertion the “Project Description and the Draft EIR” are misleading to the public and is therefore legally inadequate. To the contrary, the Draft EIR carefully articulated each scenario in detail, laying out their similarities and differences, and fully disclosed the maximum possible scope of each scenario. The Draft EIR then evaluated the environmental effects of each scenario, both in terms of physical plan and use/operation, thereby allowing informed decision-making and public participation. Accordingly, the project description is adequate and fulfills CEQA’s purpose to enable the public to participate meaningfully in the environmental review and analysis of any potential environmental effects.

Response 116.2. The availability of the proposed Planned Development (PD) Plan for review is immaterial and unrelated to the adequacy and completeness of the Draft EIR. Section 15124 “Project Description” of Article 9. Contents of Environmental Impact Reports of the State CEQA Guidelines states:

The description of the project shall contain the following information but should not supply extensive detail beyond that needed for evaluation and review of the environmental impact [emphasis added].
(a) The precise location and boundaries of the proposed project shall be shown on a detailed map, preferably topographic. The location of the project shall also appear on a regional map. [refer to Exhibits 2-1 through 2-3 of the Draft EIR] (b) A statement of the objectives sought by the proposed project. A clearly written statement of objectives will help the lead agency develop a reasonable range of alternatives to evaluate in the EIR and will aid the decision makers in preparing findings or a statement of overriding considerations, if necessary. The statement of objectives should include the underlying purpose of the project and may discuss the project benefits. [refer to Section 2.3 Project Objectives on page 2-5 of the Draft EIR] Affinity Project Final EIR
R:\Projects\PAS_Pasaden\3PAS012100\Environmental Documentation\RTC\Final_Affinity RTC_Revisions_MMRP-051222.docx 71 Draft EIR Clarifications and Revisions (c) A general description of the project’s technical, economic, and environmental characteristics, considering the principal engineering proposals if any and supporting public service facilities. [refer to pages 2-1 through 2-15 of the Draft EIR] (d) A statement briefly describing the intended uses of the EIR. [refer to Section 2.7 Intended Uses of the EIR on page 2-18 of the Draft EIR] (1) This statement shall include, to the extent that the information is known to the Lead Agency,
(A) A list of the agencies that are expected to use the EIR in their decision making, and
(B) A list of permits and other approvals required to implement the project. (C) A list of related environmental review and consultation requirements required by federal, state, or local laws, regulations, or policies. To the fullest extent possible, the lead agency should integrate CEQA review with these related environmental review and consultation requirements. (2) If a public agency must make more than one decision on a project, all its decisions subject to CEQA should be listed, preferably in the order in which they will occur. On request, the Office of Planning and Research will provide assistance in identifying state permits for a project. [refer to Section 2.7.1 on page 2-18 of the Draft EIR]
The planning process is a parallel but separate process to the environmental (i.e., CEQA) process. As indicated in the emphasized text from Section 15124 of the State CEQA Guidelines, there is no requirement in CEQA or other statute that the underlying planning documentation (whatever that may be) is finalized and available for review prior to or alongside the public review of the CEQA document. The planning and environmental processes overlap and, because of this, when adequate information is available to prepare the environmental analysis to the degree that no potential impacts may be missed or undisclosed, the EIR preparation can commence.

Commenter’s assertion that the Draft EIR is inadequate is unsubstantiated.

Affinity Project Final EIR
R:\Projects\PAS_Pasaden\3PAS012100\Environmental Documentation\RTC\Final_Affinity RTC_Revisions_MMRP-051222.docx 72 Responses to Comments Affinity Project Final EIR
R:\Projects\PAS_Pasaden\3PAS012100\Environmental Documentation\RTC\Final_Affinity RTC_Revisions_MMRP-051222.docx 73 Responses to Comments Affinity Project Final EIR
R:\Projects\PAS_Pasaden\3PAS012100\Environmental Documentation\RTC\Final_Affinity RTC_Revisions_MMRP-051222.docx 74 Responses to Comments Affinity Project Final EIR
R:\Projects\PAS_Pasaden\3PAS012100\Environmental Documentation\RTC\Final_Affinity RTC_Revisions_MMRP-051222.docx 75 Draft EIR Clarifications and Revisions Response to Comment Letter 124
Erika Foy
February 26, 2022
Response 124.1. Please refer to Responses 106.2 through 106.5, above, regarding traffic. In summary, the transportation analysis performed as part of the Draft EIR is based on a methodology revolving around VMT. The methodology related to trip generation and intersection function relate to LOS, which is no longer addressed as part of CEQA pursuant to implementation of Senate Bill 743 and associated changes to CEQA and the State CEQA Guidelines. This is addressed in the “Outside CEQA” studies prepared by the Pasadena DOT. The Outside CEQA analysis does not factor into the results of the CEQA transportation analysis, or vice versa, as they measure different metrics and are used for different purposes. However, traffic and transportation are addressed as part of the project development process, but only the VMT-based analysis is addressed as part of CEQA, consistent with State law and regulations.

Response 124.2. Regarding off-site traffic noise, please refer to Response 112.4 above. In summary, there would be no change in the noise analysis even in the scenario in which the Project’s net trip generation is doubled (a more conservative analysis than even evaluating the Project’s total trip generation), there would not be a significant increase in noise along any roadway segment. The net increase of 41 trips (as shown in Table 3.7-7 on page 3.7-16 of the Draft EIR) is related to the Project with Building A Residential/Commercial. The Project, as proposed, would result in a net trip generation of 3,913 average daily trips (refer to Table 3.7-5 on page 3.7-13 of the Draft EIR). As stated on page 3.7-14 of the Draft EIR, “A three-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 [see Table 3.7-6 on page 3.7-14 in the Draft EIR], 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.” Furthermore, as stated on page 3.7-14, “It is noted that the percent change in trips is 6 percent or below on all street segments except on (1) Arroyo Parkway between California Boulevard and (2) Bellevue Drive and on Bellevue Drive between Arroyo Parkway and Marengo Avenue.” It is noted that 3 decibels is considered just perceptible to human hearing. In other words, the percentage change in average daily trips on any street segment in the vicinity would need to be 100 percent or more to result in a noise increase that may be perceptible to some individuals. Doubling the net traffic trips of the Project estimated at 3,913 trips equals 7,826 trips; this is higher than the estimated total (i.e., not net) Project trips of 6,366. As such, the traffic volumes from the Project (or Project with Building A Residential/Commercial), theoretically even doubled–in other words a maximum increase of 38 percent–would not result in a perceptible change in the traffic noise level on any street segment. Even if the analysis did not apply a trip reduction for the existing uses, the Project’s contribution to roadway noise would still be well below the significance thresholds. For example, a simple approach to considering the effects of a higher contribution of trips from the Project is to double the Project’s contribution of trips to each of the studies street segments, as presented above. This is a conservative approach because it assumes more total trips (7,826) than the Project would generate at buildout without any reduction in trips for existing uses (6,366). Table 2 in Response 112.4 illustrates the percent change on surrounding street segments with the additional ADT doubled, which would be more than the total (not net) trips estimated for the Project. Because the Project with Building A Residential/Commercial would generate fewer daily trips than the Project, this comparison of anticipated versus doubled additional trips would result in the same conclusion as for the Project.

Response 124.3. Please refer to Response 106.7, above, regarding historic resources. In summary, based on the Historical Resource Assessment, prepared for the Project by architectural historians that meet the Secretary of the Interior’s Professional Qualifications Standards, no significant indirect impacts to existing historic resources in the Project site vicinity would occur with implementation of the Project (or Project with Building A Residential/Commercial).

Affinity Project Final EIR
R:\Projects\PAS_Pasaden\3PAS012100\Environmental Documentation\RTC\Final_Affinity RTC_Revisions_MMRP-051222.docx 76 Responses to Comments Affinity Project Final EIR
R:\Projects\PAS_Pasaden\3PAS012100\Environmental Documentation\RTC\Final_Affinity RTC_Revisions_MMRP-051222.docx 77 Responses to Comments Response to Comment Letter 133
Andrea Rawlings
February 23, 2022
Response 133.1. This comment recommending preparation of a “HSR” (Historic Structure Report) as a mitigation measure for both 501 and 523 South Arroyo Parkway is acknowledged.

In CEQA, mitigation measures are applied only when a significant environmental impact is identified. The comment does not provide evidence that a significant impact to historic resources would occur with Project implementation, under either scenario. It is noted the Draft EIR included preparation of a Historical Resource Assessment that addressed all existing structures on the site over 45 years old, including 501 and 523 South Arroyo Parkway, and addressed direct and indirect impacts to both the on-site historic resources and historic resources in the vicinity. Additionally, the Draft EIR included analysis of potential vibration-related impacts to 501 and 523 South Arroyo Parkway during construction. Mitigation measures CUL-1 and NOI-1 relate to protection of the on-site historic structures and their character-defining features during implementation of the Project. As such, preparation of a HSR is not considered necessary as part of the CEQA process, and no changes to the Draft EIR are required. However, the comment is noted for the administrative record and will be provided to the decision-makers for review and consideration.

Affinity Project Final EIR
R:\Projects\PAS_Pasaden\3PAS012100\Environmental Documentation\RTC\Final_Affinity RTC_Revisions_MMRP-051222.docx 78 Responses to Comments Response to Comment Letters in Support of the Project
 107 Old Pasadena Management District (May 25, 2021)
 108 Pasadena Chamber of Commerce and Civic Association (February 16, 2022)  113 Josh Albrektson, MD (February 20, 2022)
 115 Natalie Bazarevitsch (August 10, 2021)
 117 Maggie Crawford, (August 11, 2021)
 118 Sydney Dailey, (February 16, 2022)
 119 Darrell Done (May 23, 2021)
 120 Sarah Dusseault (February 22, 2022)
 121 Cyndi Erickson (February 17, 2022)
 122 Scott Feldmann (August 11, 2021)
 123 Michelle Ficarra (August 11, 2021)
 125 Jim Gamb (August 3, 2021)
 126 Akila Gibbs (August 10, 2022)
 127 Dean Kitchens (August 10, 2021)
 128 Stan Kong (August 11, 2021)
 129 Erik Landswick (August 11, 2022)
 130 Nikki Maciejowsk (February 22, 2022)
 131 Marissa Marchioni (May 8, 2021)
 132 James R. Plotkin (August 11, 2021)
 134 Julie Rosenberg (August 10, 2021)
 135 Round, Michelle (February 22, 2022)
 136 Mary Frances Schillaci (August 8, 2021)
 137 Gregg Smith (No date)
 138 Victoria D. Stratman (August 4, 2021)
 139 Trytten, Steven E. (August 10, 2021)
 140 Carol Walker (August 11, 2021)
 141 Julianne Worrell (May 24, 2021)
Response to Letters Listed Above: These comments expressing support for the Project (or Project with Building A Residential/Commercial) are acknowledged. The comments do not address the content or adequacy of the Draft EIR under CEQA or the State CEQA Guidelines; however, the comments are noted for the administrative record and will be provided to the decision-makers for review and consideration.

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1 Letter 139
1 Letter 140
1 Letter 141
1 Affinity Project Final EIR
R:\Projects\PAS_Pasaden\3PAS012100\Environmental Documentation\RTC\Final_Affinity RTC_Revisions_MMRP-051222.docx 79 Draft EIR Clarifications and Revisions SECTION 3.0 DRAFT EIR CLARIFICATIONS AND REVISIONS
Any revisions to the Draft EIR text, tables, and figures generated either from responses to comments or independently by the City, are stated in this section of the Final EIR. The Draft EIR text, tables, and figures have not been modified and then published as the Final EIR in its entirety as a single document to reflect these EIR modifications.

These Draft EIR revisions are provided to clarify and amplify the Draft EIR. Changes may be corrections or clarifications to the text and tables of the original Draft EIR. Other changes to the Draft EIR clarify the analysis in the Draft EIR based upon the information and concerns raised by comments during the public review period. None of the information contained in these Draft EIR revisions constitutes significant new information or changes to the analysis or conclusions of the Draft EIR.

The changes to the Draft EIR included in these EIR revisions do not constitute “significant” new information. Therefore, recirculation of the Draft EIR is not required because the new information added to the EIR through these revisions clarify or amply information already provided or make insignificant modifications to the already adequate Draft EIR.

The EIR revisions contained in the following pages are in the same order as the information appears in the Draft EIR. Changes in text are signified by strikeouts (strikeouts) where text has been removed and by bold underlining (underline) where text has been added. The applicable page numbers from the Draft EIR are also provided where necessary for ease of reference.

Exhibit 2-4, Project Site Plan, following page 2-7 in Section 2.0, Environmental Setting and Project Description
A new label for Building A was added, as shown on the exhibit on the following page, that indicates the structure may be Medical Office and Commercial or Residential and Commercial.

Pages 2-10 to 2-11 in Section 2.0, Environmental Setting and Project Description Approximately 31,605 sf of open space, including public and private (for solely resident and staff use space), would be provided across the site for both the Project and Project with Building A Residential/Commercial scenarios. As discussed previously, the Project would result in the removal of 23 non-protected non-native trees on the Project site and 2 protected, non-native street trees. As shown on Exhibit 2-16a, Conceptual Landscape Plan, the Project would include a total of 25 38 trees in above-grade planters within the site. The 15 remaining protected street trees would be protected in place during construction and remain after the Project is implemented. As discussed in Section 2.4, Biological Resources, of the Initial Study, the Urban Forestry section of the City’s Public Works Department typically requires a fee, dependent on the size of the tree(s) being removed, to be remitted into the City’s street tree fund. For the Project, a planned condition of approval calls for planting of one new street tree along both Arroyo Parkway and California Boulevard. The Project would also include a total of 25 38 trees in above-grade planters within the site.

2.7 INTENDED USES OF THE EIR

2.7.1 CITY OF PASADENA
Map not to scale
Source: Adept 2021
(04/26/2022 JVR) R:\Projects\PAS_Pasaden\3PAS012100\Graphics\EIR\Final_EIR\ex_project_site_plan.pdf D:\Projects\3PAS\012100\GRAPHICS\EIR\Final_EIR\ex2-4_project_site_plan_20220426.ai Affinity Project
Project Site Plan Exhibit 2-4

MEDICAL OFFICE

COMMERCIAL

OR RESIDENTIAL

COMMERCIAL

MEDICAL BUILDING
7 LEVELS / 90 FT HT.

TYPE I CONSTRUCTION
154,000 FAR SF
Affinity Project Final EIR
R:\Projects\PAS_Pasaden\3PAS012100\Environmental Documentation\RTC\Final_Affinity RTC_Revisions_MMRP-051222.docx 80 Draft EIR Clarifications and Revisions The City of Pasadena is expected to use the information contained in the EIR for consideration of approvals related to and involved in Project implementation. Actions to be considered by the City, after implementation of the CEQA process, include, but not be limited to:
 Approval of the Planned Development (PD) Zoning District and PD Plan (this includes approval of the Affinity Project, zoning map amendment to rezone the property from CD6 to PD-39, and variance for historic resources for building height);  Certification of the Affinity Project Environmental Impact Report;  Public Street Tree Removal Approval;
 Design Review;
 Landmark Designation;
 Vesting Tentative Tract Map or Tentative Tract Map Approval (only if residential units for sale); and
 Other discretionary and ministerial permits and approvals that may be deemed necessary, including but not limited to: master sign plan, temporary street closure permits, encroachment permits, grading permits, excavation permits, foundation permits, and building permits (including lot tie agreement).

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

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

TABLE 2-6

OTHER AGENCY REVIEW APPROVALS AND REQUIREMENTS
Agency Review by Other Agency Approval Required
Los Angeles County Metropolitan Transportation Authority (Metro) Construction within 100 feet of Metro light rail Los Angeles Regional Water Quality Control Board Construction General Permit South Coast Air Quality Management District Permit for Operation of Diesel Backup Generator

Zoning Code Variances
A zoning variance acts as a waiver to some aspect of the zoning law, but it cannot violate the expressed basis of the controlling code. Section 17.61.080 of the PMC, Variances, allows for variances from the development standards of this Zoning Code, variances for historic resources, and modifications for individuals with disabilities. The Project Applicant requests a variance for historic resources, which is addressed in Section 17.61.080(H) et. seq. of the PMC. Variances for historic resources only apply if the property has a historic designation or is required, as a condition of approval of the Variance, to submit an application for historic designation prior to Affinity Project Final EIR
R:\Projects\PAS_Pasaden\3PAS012100\Environmental Documentation\RTC\Final_Affinity RTC_Revisions_MMRP-051222.docx 81 Draft EIR Clarifications and Revisions completion of the proposed project or establishment of the proposed use. Section 17.62.050 of the PMC, Process for Designating Individual Historic Resources, addresses the process.

The analysis of the proposed tree removals pursuant to the “City Trees and Tree Protection Ordinance” (codified in Chapter 8.52 of the PMC) was included in Section 2.4, Biological Resources, of the Initial Study (refer to Appendix A-1) prepared for the Project. As discussed, the Urban Forestry section of the City’s Public Works Department typically requires a fee, dependent on the size of the tree(s) being removed, to be remitted into the City’s street tree fund. For the Project, a planned condition of approval calls for planting of one new street tree along both Arroyo Parkway and California Boulevard. The Project would also include a total of 25 38 trees in abovegrade planters within the site. With compliance with the Project’s conditions of approval, the Project would not conflict with the City’s tree protection ordinance and there would be a less than significant impact. Project implementation would result in a net gain in the urban forest, with no loss of street trees and a greater amount of landscaping at ground level and on upper levels of Building B than in the existing condition. Based on this analysis, it can be concluded that the Project would not conflict with applicable goals and policies related to the urban forest.

As discussed, for the Project, a planned condition of approval calls for planting of one new street tree along both Arroyo Parkway and California Boulevard. The Project would also include 25 38 trees in above-grade planters within the site. With compliance with the conditions of approval, the Project would not conflict with the City’s tree protection ordinance and there would be a less than significant impact. Implementation of the Project would result in a net gain in the urban forest, with no loss of street trees and a greater amount of landscaping at ground level and on upper levels of Building B than in the existing condition. Based on this analysis, it can be concluded that the Project would not conflict with applicable objectives related to the urban forest.

The analysis of the proposed tree removals pursuant to the City’s “City Trees and Tree Protection Ordinance” (codified in Chapter 8.52 of the PMC) was included in Section 2.4, Biological Resources, of the Initial Study (refer to Appendix A-1) prepared for the Project with Building A Residential/Commercial. As discussed, the Urban Forestry section of the City’s Public Works Department typically requires a fee, dependent on the size of the tree(s) being removed, to be remitted into the City’s street tree fund. For the Project with Building A Residential/Commercial, a planned condition of approval calls for planting of one new street tree along both Arroyo Parkway and California Boulevard. The Project with Building A Residential/Commercial would also include a total of 25 38 trees in above-grade planters within the site. With compliance with the conditions of approval, the Project with Building A Residential/Commercial would not conflict with the City’s tree protection ordinance and there would be a less than significant impact.

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

Threshold 3.27a: Result in generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards Affinity Project Final EIR
R:\Projects\PAS_Pasaden\3PAS012100\Environmental Documentation\RTC\Final_Affinity RTC_Revisions_MMRP-051222.docx 82 Draft EIR Clarifications and Revisions established in the local general plan, local noise ordinance, or applicable standards of other agencies.

Threshold 3.27b: Result in generation of excessive ground-borne vibration or ground-borne noise levels.

3.7.5 ENVIRONMENTAL IMPACTS
Threshold 3.27a Would the Project result in generation of a 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?

Threshold 3.27b Would the Project result in generation of excessive ground-borne vibration or ground-borne noise levels?
Affinity Project Final EIR
R:\Projects\PAS_Pasaden\3PAS012100\Environmental Documentation\RTC\Final_Affinity RTC_Revisions_MMRP-051222.docx 83 Mitigation Monitoring and Reporting Program SECTION 4.0 MITIGATION MONITORING AND REPORTING PROGRAM Section 21081.6 of CEQA and Section 15097 of 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. The specific reporting and/or monitoring requirements that will be enforced during Project implementation shall be adopted simultaneously with final Project approval by the responsible decision-making body (City Council).

The MMRP for the Affinity Project, presented in Table 3, consists of Mitigation Measures (MMs) identified in the EIR that are required for Project implementation. The MMs for the Project are listed in the first column, the timing of each MM’s implementation is in the second column, and the agency or party responsible for implementing the mitigation is in the third column, and the agency or party with primary responsibility for monitoring and enforcing compliance is in the fourth column.

Affinity Project Final EIR
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AFFINITY PROJECT MITIGATION MONITORING AND REPORTING PROGRAM Mitigation Measure Mitigation Timing
Responsible
Agency/Party
Monitoring
Agency/Party
Cultural Resources
MM CUL-1. To the satisfaction of the City, the Project Applicant shall engage with a licensed architect and/or engineer that meets the Secretary of the Interior’s Professional Qualifications Standards for historic architect to develop a series of protection interventions and protocols that will preserve the two historical resources on the Project site – 501 and 523 South Arroyo Parkway – during all construction activities in, on, and near these two buildings. These measures shall take into consideration the protection of and security of both resources, particularly the preservation of the character-defining features through the installation of physical protective barriers around each resource and the creation of site protocols that will eliminate the potential for physical damage resulting from impacts with construction and transport equipment. To ensure the protection of these resources and their character-defining features, all protective barriers (which shall be installed prior to the initiation of any construction activity) and protocols shall be compliant with the Secretary of the Interior’s Standards for Rehabilitation and Guidelines for Rehabilitating Historic Buildings (Weeks and Grimmer 1995) (Standards) and be subject to review and approval by the City planning staff. Site protocols for protecting the historical resources shall outline issues related to site access and navigation by contractors and construction personnel to reduce the potential for any inadvertent accidents between equipment and the two on-site historical resources. Additionally, a series of emergency measures shall be developed that outlined specific step-by-step processes in the event that an accident involves one of the historical resources. This will likely include the following:
1) Stop-work protocols after an accident involving a historical resource occurs,
2) Notification procedures and identification key contacts, 3) Identification of qualified historic preservation professionals to investigate the historical resources following the determination that the area is safe, 4) Thorough conditions assessment of the resource by the qualified consultant to ascertain the level and extent of the damage, and 5) Preparation of a historical resource treatment plan to stabilize the historical resource and address the damage, which will be submitted  Protective barriers, site
protocols, and emergency measures in place prior to initiation of any construction activity  During all construction
activity
 Report submitted to
City for approval prior to issuance of a Certificate of Occupancy Applicant, Construction Contractor, Qualified Historic Preservation Consultant City of Pasadena Planning & Community Development Department Affinity Project Final EIR
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AFFINITY PROJECT MITIGATION MONITORING AND REPORTING PROGRAM Mitigation Measure Mitigation Timing
Responsible
Agency/Party
Monitoring
Agency/Party
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.

During all construction activity involving excavation/ground disturbance Applicant, Construction
Contractor, Registered
Professional Archaeologist
City of Pasadena
Planning & Community
Development
Department, SCCIC
Affinity Project Final EIR
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AFFINITY PROJECT MITIGATION MONITORING AND REPORTING PROGRAM Mitigation Measure Mitigation Timing
Responsible
Agency/Party
Monitoring
Agency/Party
Noise
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 During preparation of construction specifications, prior to initiation of construction, and during construction activity Applicant, Construction
Contractor
City of Pasadena
Planning & Community
Development
Department
Affinity Project Final EIR
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AFFINITY PROJECT MITIGATION MONITORING AND REPORTING PROGRAM Mitigation Measure Mitigation Timing
Responsible
Agency/Party
Monitoring
Agency/Party
shall immediately halt, and alternative methods for achieving the construction activity shall be determined and employed to reduce the construction-generated vibration exposure to the building(s) to less than the thresholds. While the specific alternative methods to be employed cannot be foreseen, as it would be depending on situation-specific factors, the performance objective of maintaining activity that results in vibration below the applicable thresholds shall guide all decisions. (3) If cosmetic damage does occur to one or more of these three buildings because of vibration from Project-related construction activities despite setbacks and monitoring, the Project Applicant shall be responsible for restoring the damage. Cosmetic damage includes things like, for example, cracks in paint/plaster, fallen plaster/stucco from a facade, and cracked glass. Specifically, any restorations to Whole Foods Market shall be implemented to return the damaged area to the same condition (e.g., materials, colors, style) as present at the start of construction. Any restorations to the buildings at 501 and 523 South Arroyo Parkway shall conform to the Secretary of the Interior’s Standards for the Rehabilitation and Guidelines for Rehabilitating Historic Buildings (Weeks and Grimmer 1995) (Standards), and the determination of whether the planned restorations is consistent with the Standards shall be made by a qualified historic preservation professional meeting the Secretary of the Interior’s Professional Qualifications Standards for architectural history or historic architecture (Professional) and to the satisfaction of the City. The restorations to the historic buildings, if necessary, may be either to the conditions present before construction was initiated or, if the planned updates to these buildings are underway may be conducted to meet proposal conditions.

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

Affinity Project Final EIR
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AFFINITY PROJECT MITIGATION MONITORING AND REPORTING PROGRAM Mitigation Measure Mitigation Timing
Responsible
Agency/Party
Monitoring
Agency/Party
Tribal Cultural Resources
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 descriptions of the day’s activities, including construction activities, locations, soil, and any cultural materials identified. The on-site monitoring shall end when all ground-disturbing activities on the Project site are completed, or when the Tribal Representatives and Tribal Monitor have indicated that all upcoming ground-disturbing activities at the Project Site have little to no potential for impacting Tribal Cultural Resources. Upon discovery of any Tribal Cultural Resources, construction activities shall cease in the immediate vicinity of the find (not less than the surrounding 50 feet) until the find can be assessed. All Tribal Cultural Resources unearthed by Project construction activities shall be evaluated by the Tribal Monitor approved by the Consulting Tribe and a qualified Archaeologist (if one is present). If the resources are Native American in origin, the Consulting Tribe will retain it/them in the form and/or manner the Tribe deems appropriate, for educational, cultural and/or historic purposes. If human remains and/or grave goods are discovered or recognized at the Project Site, all ground disturbance in the immediate vicinity of the find shall be halted, and the County Coroner shall be notified per Section 5097.98 of the Public Resources Code and Section 7050.5 of the Health & Safety Code. Human remains and grave/burial goods shall be treated alike per Section 5097.98(d)(1) and (2) of the Public Resources Code. Work may continue in other parts of the Project site while evaluation and, if necessary, mitigation takes place (Section 15064.5[f] of the State CEQA Guidelines). Preservation in place (i.e., avoidance) is the preferred manner of treatment. If preservation in place is not feasible, treatment may include implementation of archaeological data recovery excavations to remove the resource along with subsequent laboratory processing and analysis. Any historic archaeological material that is not Native Prior to any construction activity involving excavation/ground disturbance, during excavation activity Applicant, Construction
Contractor, Consulting
Tribe/Tribal Monitor
(culturally affiliated with the
site as recognized by the
NAHC)
City of Pasadena
Planning & Community
Development
Department, NAHC
Affinity Project Final EIR
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AFFINITY PROJECT MITIGATION MONITORING AND REPORTING PROGRAM Mitigation Measure Mitigation Timing
Responsible
Agency/Party
Monitoring
Agency/Party
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. SCCIC: South Central Coastal Information Center; NAHC: Native American Heritage Commission

APPENDIX A

ATTACHMENTS TO LOS ANGELES COUNTY METROPOLITAN

TRANSPORTATION AUTHORITY LETTER

Metro Adjacent Development Handbook | a

METRO ADJACENT

DEVELOPMENT HANDBOOK
Los Angeles County
Metropolitan Transportation Authority
February 2021

A GUIDE FOR CITIES AND DEVELOPERS
b | Metro Adjacent Development Handbook
Metro and Regional Rail Map
Metro is currently undertaking the largest rail infrastructure expansion effort in the United States. A growing transit network presents new opportunities to catalyze land use investment and shape livable communities.

RIVERSIDE
COUNTY

SAN BERNARDINO
COUNTY

LOS ANGELES COUNTY

VENTURA
COUNTY
COUNTY

SAN LUIS OBISPO
COUNTY

SANTA BARBARA
ORANGE
COUNTY

SAN DIEGO
COUNTY

PACIFIC OCEAN

PURPLE (D LINE) EXTENSION

TRANSIT PROJECT

CRENSHAW/LAX

TRANSIT PROJECT

REGIONAL

CONNECTOR
LAX

GOLD LINE FOOTHILL

EXTENSION PROJECT
Little Tokyo/
Arts Dist
OxnardCamarilloMoorparkSimi ValleyNorthridgeVan NuysBurbank AirportSouth Ventura - East
Sun Valley
Burbank Airport North
Sylmar/San Fernando
Newhall
Santa Clarita
Via Princessa
Vincent Grade/Acton
Palmdale
Lancaster
Antelope Valley Line
Amtrak Pacific Surfliner
San Bernardino Line
Riverside Line
91/Perris Valley Line
Inland Empire -
Orange County Line
Ventura County Line
Orange County Line
Inland Empire -
Orange County Line
Ventura
Carpinteria
Santa Barbara
Goleta
LompocSurf
GuadalupeSanta Maria
Grover Beach
San Luis Obispo
Burbank - Downtown
Glendale
El MonteBaldwin ParkCovinaPomona - NorthClaremontMontclairUplandRancho CucamongaFontanaRialtoSan Bernardino DepotSan Bernardino Downtown IndustryPomona - Downtown
Ontario - East
Jurupa Valley/Pedley
Commerce
Norwalk/Santa Fe Springs
Buena Park
Corona - North Main
Riverside - Downtown
Riverside - Hunter Park/UCR
Moreno Valley/March Field
Perris - Downtown
Perris - South
Anaheim Canyon
Riverside - La Sierra
Corona - West
Fullerton
Anaheim
Orange
Santa Ana
Irvine
San Juan Capistrano
San Clemente
San Clemente Pier
Oceanside
Solana Beach
Tustin
Laguna Niguel/Mission Viejo
BUR
Montebello/Commerce
San Diego
Amtrak Pacific Surfliner

STATION CLOSED
Universal City/Studio City
Hollywood/Vine
Hollywood/Highland
Civic Ctr/GrandPark
Westlake/MacArthur Park
Roscoe
Pico/Aliso
Mariachi Plaza
Long Beach Bl Artesia
Del Amo
Civic Ctr/GrandPark
LakeAllenSierra Madre VillaArcadiaMonroviaDuarte/City of HopeIrwindaleAzusa Downtown APU/Citrus College Lincoln/Cypress
Heritage Sq
Southwest Museum
Highland Park
Fillmore
Del Mar
Memorial Park
South Pasadena
Westlake/MacArthur Park
Wilshire/Vermont
Pershing
Chinatown
Union Station
Square
7th St/Metro Ctr
Pico
LATTC/Ortho Institute
Jefferson/USC
LAX FlyAway
Amtrak & Metrolink
LAX FlyAway
Metrolink
Sherman Way
Roscoe
Nordhoff
Chatsworth
Hollywood/Western
Vermont/Santa Monica
Hollywood/Highland
North Hollywood
CanogaDe SotoPierce CollegeTampaReseda
Balboa
WoodleySepulvedaVan NuysWoodman
Valley CollegeLaurel Canyon
Vermont/Beverly
Vermont/Santa Monica
Vermont/Sunset
Amtrak & Metrolink
Soto
Indiana
Maravilla
East LA Civic Ctr
Atlantic
LAC+USC Medical CtrCal State LAEl Monte
Pico/Aliso
Mariachi Plaza
Wilshire/WesternWilshire/Normandie
Downtown Santa Monica17th St/SMC26th St/BergamotExpo/Bundy Expo/Sepulveda
Westwood/Rancho ParkPalms
Culver City
La Cienega/Jefferson
Expo/La BreaFarmdaleExpo/CrenshawExpo/WesternExpo/VermontExpoPark/USC Mariposa
El Segundo
Douglas
Redondo Beach
37th St/
USC
Rosecrans
Harbor
Carson
Pacific
Coast
Hwy
Gateway
Transit Ctr
Aviation/LAXHawthorne/Lennox
Crenshaw
Vermont/AthensAvalonLong Beach BlLakewood BlNorwalk
Slauson
Manchester
Harbor Fwy
5th St
1st St
PacificAv
Downtown Long
Beach
Washington
Vernon
Slauson
Florence
Firestone
Compton
Artesia
Del Amo
Wardlow
Willow St
Pacific Coast Hwy
Anaheim St
103rd St/
Willowbrook/
Rosa Parks
Watts Towers
Downtown Long
Beach
Grand/LATTC
San Pedro St
Watts Towers
Union Station
Hollywood/Vine
LAX FlyAway
LAX Shuttle G

SAN FERNANDO VALLEY

SAN GABRIEL VALLEY

EASTSIDE

SOUTH BAY
San Pedro

GATEWAY CITIES

DOWNTOWN
LA

SOUTH LA

CENTRAL LA

SAN FERNANDO VALLEY

SAN GABRIEL VALLEY

EASTSIDE

SOUTH BAY
San Pedro

GATEWAY CITIES

DOWNTOWN
LA
SANTA
MONICA

SOUTH LA

CENTRAL LA

WESTSIDE
Metro & Regional Rail
metro.net
pacicsuriner.com
metrolinktrains.com
21-1290MM ©2020 LACMTA
Antelope Valley Line
San Bernardino Line
Riverside Line
91/Perris Valley Line
Ventura County Line
Amtrak Pacific Surfliner
Orange County Line
Inland Empire -
Orange County Line
Regional Rail
amtrak.com
metrolinktrains.com
Airport Shuttle
Rail Station
Station
Transfer
Regional
Rail
Station
Busway Station
UNDER

CONSTRUCTION
Busway Street
Service
Amtrak
Metrolink
LAX FlyAway
lawa.org/flyaway
LAX Shuttle (free)
lawa.org
Little Tokyo/Arts District Station is closed
effective Fall 2020. Use the free L Line
(Gold) Shuttle for connecting service.

Station closure
Street Service in Downtown LA
and San Pedro
A Line (Blue) Downtown LA to Long Beach
B Line (Red) North Hollywood to Union Station
C Line (Green) Redondo Beach to Norwalk
D Line (Purple) Wilshire/Western to Union Station
E Line (Expo) Downtown LA to Santa Monica
L Line (Gold) East Los Angeles to Azusa
G Line (Orange) Chatsworth to North Hollywood
J Line (Silver) San Pedro to El Monte
Metro Rail
Metro Busway
OCT 2020 Subject to Change
Metro Adjacent Development Handbook | c
Quick Overview 1
Background 2
Metro Purview & Concerns 4
Metro Coordination Process 6
Best Practices 8

1. Site Plan & Conceptual Design 11

1.1 Supporting Transit Oriented Communities 12

1.2 Enhancing Access to Transit 13

1.3 Building Setback 14

1.4 Overhead Catenary System (OCS) Clearance 15

1.5 Underground Station Portal Clearance 16

1.6 Shared Barrier Construction & Maintenance 17

1.7 Project Orientation & Noise Mitigation 18

1.8 At-Grade Rail Crossings 19

1.9 Sight-Lines at Crossings 20

1.10 Driveway/Access Management 21

1.11 Bus Stop & Zones Design 22

2. Engineering & Technical Review 25

2.1 Excavation Support System Design 26

2.2 Proximity to Tunnels 27

2.3 Protection from Explosion/Blast 28

3. Construction Safety & Management 31

3.1 Pre-Construction Coordination 32

3.2 Track Access and Safety 33

3.3 Construction Hours 34

3.4 Excavation/Drilling Monitoring 35

3.5 Crane Operations 36

3.6 Construction Barriers & Overhead Protection 37

3.7 Pedestrian & Emergency Access 38

3.8 Impacts to Bus Routes & Stops 39

3.9 Utility Coordination 40

3.10 Air Quality & Ventilation Protection 41
Glossary 42
Table of Contents
d | Metro Adjacent Development Handbook
Metro Adjacent Development Handbook | 1
Quick Overview
Purpose of Handbook
The Metro Adjacent Development Handbook
(Handbook) is intended to provide information and guide coordination for projects adjacent to, below, or above
Metro transit facilities (e.g. right-of-way, stations, bus stops) and services.

Overarching Goal
By providing information and encouraging early
coordination, Metro seeks to reduce potential conflicts with transit services and facilities, and identify potential synergies to expand mobility and improve access to
transit.

Intended Audience
The Handbook is a resource for multiple stakeholder
groups engaged in the development process, including:
• Local jurisdictions who review, entitle, and permit
development projects,
• Developers,
• Property owners,
• Architects, engineers, and other technical
consultants,
• Builders/contractors,
• Utility companies, and
• other Third Parties.

Handbook Content
The Handbook includes:
• Introduction of Metro’s Development Review
coordination process, common concerns, and typical
stages of review.
• Information on best practices during three key
coordination phases to avoid potential conflicts or
create compatibility with the Metro transit system:
• Planning & Conceptual Design,
• Engineering & Technical Review, and
• Construction Safety & Monitoring.
• Glossary with definitions for key terms used
throughout the Handbook.

RULE OF THUMB: 100 FEET
Metro’s Development Review process applies to
projects that are within 100 feet of Metro transit
facilities.

While the Handbook summarizes key concerns and
best practices for adjacency conditions, it does
not replace Metro’s technical requirements and
standards.

Prior to receiving approval for any construction
activities adjacent to, above, or below Metro
facilities, Third Parties must comply with the Metro
Adjacent Construction Design Manual, available on
Metro’s website.

Contact Us
For questions, contact the Development Review Team:
• Email: [email protected]
• Phone: 213.418.3484
• Online In-take Form: https://jpropublic.metro.net/
in-take-form
Additional Information & Resources
• Metro Development & Construction Coordination
website:
https://www.metro.net/devreview
• Metro GIS/KML ROW Files:
https://developer.metro.net/portfolio-item/metroright-of-way-gis-data • Metrolink Standards and Procedures:
https://www.metrolinktrains.com/about/agency/
engineering--construction
Metro will continue to revise the Handbook, as needed,
to reflect updates to best practices in safety, operations, and transit-supportive development.
2 | Metro Adjacent Development Handbook
Who is Metro?
The Los Angeles County Metropolitan Transportation Authority (Metro) plans, funds, builds, and operates rail, bus, and other mobility services (e.g. bikeshare, microtransit) throughout Los Angeles County (LA County). On average, Metro moves 1.3 million people each day on buses and trains. With funding from the passage of Measure R (2008) and Measure M (2016), the Metro system is expanding. Over the next 40 years, Metro will build over 60 new stations and over 100 miles of transit right-of-way (ROW). New and expanded transit lines will improve mobility across LA County, connecting riders to more destinations and expanding opportunities for development that supports transit ridership. Metro facilities include:

Metro Rail: Metro operates heavy rail (HRT) and light rail (LRT) transit lines in underground tunnels, along streets, off-street in dedicated ROW, and above street level on elevated structures. Heavy rail trains are powered by a “third rail” along the tracks. Light rail vehicles are powered by overhead catenary systems (OCS). To support rail operations, Metro owns and maintains traction power substations (TPSS), maintenance yards, and other infrastructure.

Metro Bus Rapid Transit (BRT): Metro operates accelerated bus transit, which acts as a hybrid between rail and traditional bus service. Metro BRT may operate in a dedicated travel lane within a street or freeway, or off-street along dedicated ROW. Metro BRT stations may be located on sidewalks within the public right-of-way, along a median in the center of streets, or off-street on Metro-owned property.

Metro Bus: Metro operates 170 bus lines across more than 1,400 square miles in LA County. The fleet serves over 15,000 bus stops with approximately 2,000 buses. Metro operates “Local” and “Rapid” bus service within the street, typically alongside vehicular traffic, though occasionally in “bus-only” lanes.

Metro bus stops are typically located on sidewalks within the public right-ofway, which is owned and maintained by local jurisdictions. Metro’s NextGen Bus Plan re-envisions bus service across LA County to make service improvements that better serve riders.

Metrolink/Regional Rail: Metro owns a majority of the ROW within LA County on which the Southern California Regional Rail Authority (SCRRA) operates Metrolink service. Metrolink is a commuter rail system with seven lines that span 388 miles across five counties, including: Los Angeles, Orange, Riverside, San Bernardino, Ventura, and North San Diego. As a SCRRA member agency and property owner, Metro reviews development activity adjacent to Metro-owned ROW on which Metrolink operates, and coordinates with Metrolink on any comments or concerns. Metrolink has its own set of standards and processes, see link on page 1.

Background
Metro Adjacent Development Handbook | 3
Why is Metro interested in adjacent development?
Metro Supports Transit Oriented Communities: Metro is redefining the role of the transit agency by expanding mobility options, promoting sustainable urban design, and helping transform communities throughout LA County. Metro seeks to partner with local, state, and federal jurisdictions, developers, property owners and other stakeholders across LA County on transit-supportive planning and developments to grow ridership, reduce driving, and promote walkable neighborhoods. Transit Oriented Communities (TOCs) are places (such as corridors or neighborhoods) that, by their design, allow people to drive less and access transit more. TOCs maximize equitable access to a multi-modal transit network as a key organizing principle of land use planning and holistic community development.

Adjacent Development Leads to Transit Oriented Communities: Metro supports private development adjacent to transit as this presents a mutually beneficial opportunity to enrich the built environment and expand mobility options. By connecting communities, destinations, and amenities through improved access to public transit, adjacent developments have the potential to:
• reduce auto dependency,
• reduce greenhouse gas emissions,
• promote walkable and bikeable communities that accommodate more healthy and active lifestyles, • improve access to jobs and economic opportunities, and • create more opportunities for mobility – highly desirable features in an increasingly urbanized environment.

Opportunity: Acknowledging an unprecedented opportunity to influence how the built environment develops along and around transit and its facilities, Metro has created this document. The Handbook helps ensure compatibility between private development and Metro’s transit infrastructure to minimize operational, safety, and maintenance issues. It serves as a crucial first step to encourage early and active collaboration with local stakeholders and identify potential partnerships that leverage Metro initiatives and support TOCs across LA County.
4 | Metro Adjacent Development Handbook
Metro Purview for Review & Coordination
Metro is interested in reviewing development, construction, and utility projects within 100 feet of Metro transit facilities, real estate assets, and ROW – as measured from the edge of the ROW outward – both to ensure the structural safety of existing or planned transit infrastructure and to maximize integration opportunities with adjacent development. The Handbook seeks to:
• Improve communication and coordination between developers, jurisdictions, and Metro. • Identify common concerns associated with developments adjacent to Metro ROW. • Highlight Metro operational needs and requirements to ensure safe, continuous service. • Prevent potential impacts to Metro transit service or infrastructure. • Maintain access to Metro facilities for riders and operational staff. • Avoid preventable conflicts resulting in increased development costs, construction delays, and safety impacts.
• Streamline the review process to be transparent, clear, and efficient. • Assist in the creation of overall marketable and desirable developments.

Key Audiences for Handbook
The Handbook is intended to be used by:
• Local jurisdictions who review, entitle, and permit development projects and/or develop policies related to land use, development standards, and mobility,
• Developers, property owners,
• Architects, engineers, design consultants,
• Builders/contractors,
• Entitlement consultants,
• Environmental consultants,
• Utility companies, and
• other Third Parties.

Metro Assets & Common Concerns for Adjacent Development The table on the facing page outlines common concerns for development projects and/or construction activities adjacent to Metro transit facilities and assets. These concerns are discussed in greater detail in the following chapters of the Handbook.

Metro Purview & Concerns
Metro Adjacent Development Handbook | 5

METRO ASSETS

AT-GRADE ROW

NON-REVENUE/OPERATIONAL

BUS STOPS
Transit operates below ground in
tunnels.

Transit operates on elevated
guideway, typically supported by
columns.

Transit operates in dedicated
ROW at street level; in some
cases tracks are separated from
adjacent property by fence or
wall.

Metro operates bus service on
city streets. Bus stops are located
on public sidewalks.

Metro owns and maintains
property to support operations
(e.g. bus and rail maintenance
facilities, transit plazas, traction
power substations, park-and-ride
parking lots).
• Excavation near tunnels and infrastructure
• Clearance from support structures (e.g. tiebacks,
shoring, etc)
• Coordination with utilities
• Clearance from ventilation shafts, surface
penetrations (e.g. emergency exits)
• Surcharge loading of adjacent construction
• Explosions
• Noise and vibration/ground movement
• Storm water drainage
• Excavation near columns and support structures
• Column foundations
• Clearance from OCS
• Overhead protection and crane swings
• Setbacks from property line for maintenance activities to occur without entering ROW
• Coordination with utilities
• Noise reduction (e.g. double-paned windows)
• Pedestrian and bicycle movements and safety
• Operator site distance/cone of visibility
• Clearance from OCS
• Crane swings and overhead protection
• Trackbed stability
• Storm water drainage
• Noise/vibration
• Driveways near rail crossings
• Setbacks from property line for maintenance
activities to occur without entering ROW
• Utility coordination
• Lane closures and re-routing service during
construction
• Temporary relocation of bus stops
• Impacts to access to bus stops
• Excavation and clearance from support structures
(e.g. tiebacks, shoring, etc)
• Ground movement
• Drainage
• Utility coordination
• Access to property

UNDERGROUND ROW

AERIAL ROW

COMMON ADJACENCY CONCERNS
6 | Metro Adjacent Development Handbook
Typical Stages of Metro Review and Coordination
Early coordination helps avoid conflicts between construction activities and transit operations and maximizes opportunities to identify synergies between the development project and Metro transit services that are mutually beneficial.

Metro Coordination Process
*Phases above may include fees for permits and reimbursement of Metro staff time for review and coordination.

Coordination Goal: Metro encourages developers to consult with the Development Review Team early in the design process to ensure compatibility with transit infrastructure and minimize operational, safety, and maintenance issues with adjacent development. The Development Review team will serve as a case manager to developers and other Third Parties to facilitate the review of plans and construction documents across key Metro departments.

Level of Review: Not all adjacent projects will require significant review and coordination with Metro. The level of review depends on the Project’s proximity to Metro, adjacency conditions, and the potential to impact Metro facilities and/or services. For example, development projects that are excavating near Metro ROW or using cranes near transit facilities require a greater level of review and coordination. Where technical review and construction monitoring is needed, Metro charges fees for staff time, as indicated by asterisk in the above diagram.

Permit Clearance: Within the City of Los Angeles, Metro reviews and clears Building & Safety permits for projects within 100 feet of Metro ROW, pursuant to Zoning Information 1117. To ensure timely clearance of these permits, Metro encourages early coordination as noted above.

To begin consultation, submit project information via an online In-Take Form, found on Metro’s website. Metro staff will review project information and drawings to screen the project for any potential impacts to transit facilities or services, and determine if require further review and coordination is required. The sample sections on the facing page illustrate adjacency condition information that helps Metro complete project screening.

Contact:

Metro Development Review Team
Website: https://www.metro.net/devreview
Online In-take Form: https://jpropublic.metro.net/in-take-form Email: [email protected]
Phone: 213.418.3484
Early Planning/
Conceptual Design
Technical
Review*
Real Estate
Agreements*
& Permits
Construction
Safety &
Monitoring*
Metro Adjacent Development Handbook | 7
Sample Section: Adjacency Conditions
LVL 1
LVL 2
LVL 3
LVL 4
B

AT-GRADE CONDITION
A
PL
OCS C
D

BUILDING
LVL 1
PL 3
PL 2
PL 1
CL CL
E

SOLDIER PILE
PL

TIEBACK
F
G

BELOW-GRADE CONDITION
F
L
E
L
C

T EBA K

SOLDIER P LE
LVL 2
LVL 3 BUILDING
E. Vertical distance from top of Metro tunnel
to closest temporary and/or permanent
structure (e.g. tiebacks, foundation). Refer
to Section 2.2, Proximity to Tunnels &
Underground Infrastructure of Handbook.

F. Horizontal distance from exterior tunnel
wall to nearest structure.

G. Horizontal distance from Metro track
centerline to nearest structure.

A. Distance from property line to nearest
permanent structure (e.g. building facade,
balconies, terraces). Refer to Section 1.3
Building Setback of Handbook.

B. Distance from property line to nearest
temporary construction structures (e.g.
scaffolding).

C. Distance from property line to nearest
Metro facility.

D. Clearance from nearest temporary
and/or permanent structure to overhead
catenary system (OCS). Refer to Section

1.4, OCS Clearance of Handbook.
8 | Metro Adjacent Development Handbook
Best Practices for Developer Coordination
Metro encourages developers of projects adjacent to Metro ROW and/or Real Estate Assets to take the following steps to facilitate Metro project review and approval:

1. Review Metro resources and policies: The Metro Development & Construction Coordination website and Handbook provide important information for those interested in constructing on, adjacent, over, or under Metro ROW, non-revenue property, or transit facilities. Developers and other Third Parties should familiarize themselves with these resources and keep in mind common adjacency concerns when planning a project.

2. Contact Metro early during design process: Metro welcomes the opportunity to provide feedback early in project design, allowing for detection and resolution of important adjacency issues, identification of urban design and system integration opportunities, and facilitation of permit approval. Metro encourages project submittal through the online In-Take Form to begin consultation.

3. Maintain communication: Frequent communication with Metro during project design and construction will reinforce relationships and allow for timely project completion. Contact us at [email protected] or at 213.418.3484.

Best Practices
Metro Adjacent Development Handbook | 9
Best Practices for Local Jurisdiction Notification
To improve communication between Metro and the development community, Metro suggests that local jurisdictions take the following steps to notify property owners of coordination needs for properties adjacent to Metro ROW by:
• Updating GIS and parcel data: Integrate Metro ROW files into the City/County GIS and/or Google Earth Files for key departments (e.g. Planning, Public Works, Building & Safety) to notify staff of Metro adjacency and need for coordination during development approval process.Download Metro’s ROW files here.
• Flag Parcels: Create an overlay zone as part of local Specific Plan(s) and/or Zoning Ordinance(s) to tag parcels that are within 100 feet Metro ROW and require coordination with Metro early during the development process [e.g. City of Los Angeles Zone Information and Map Access System (ZI-1117)]. • Provide Resources: Direct all property owners and developers interested in parcels within 100 feet of Metro ROW to Metro’s resources (e.g. website, Handbook).

Site Plan
& Conceptual
Design
12 | Metro Adjacent Development Handbook
Site Plan & Conceptual Design

1.1 Supporting Transit Oriented Communities
Transit-oriented communities (TOCs) are places that, by their design, make it more convenient to take transit, walk, bike or roll than to drive. By working closely with the development community and local jurisdictions, Metro seeks to ensure safe construction near Metro facilities and improve compatibility with adjacent development to increase transit ridership.

RECOMMENDATION: Consider site planning and building design strategies to that support transit ridership, such as:
• Leveraging planning policies and development incentives to design a more compelling project that capitalizes on transit adjacency and economy of scales.
• Programming a mix of uses to create lively, vibrant places that are active day and night.
• Utilizing Metro policies and programs that support a healthy, sustainable, and welcoming environment around transit service and facilities.
• Prioritizing pedestrian-scaled elements to create spaces that are comfortable, safe, and enjoyable.
• Activating ground floor with retail and outdoor seating/activities to bring life to the public environment.
• Reducing and screening parking to focus on pedestrian activity. • Incorporating environmental design elements that help reduce crime (e.g. windows and doors that face public spaces, lighting).

The Wilshire/Vermont Metro Joint Development
project leveraged existing transit infrastructure
to catalyze a dynamic and accessible urban
environment. This project accommodates portal
access into the Metro Rail system and on-street
bus facilities.

Metro Adjacent Development Handbook | 13

1.2 Enhancing Access to Transit
Metro seeks to create a comprehensive, integrated transportation network and supports infrastructure and design that allows safe and convenient access to its multi-modal services. Projects in close proximity to Metro’s services and facilities present an opportunity to enhance the public realm and connections to/from these services for transit riders as well as users of the developments.

RECOMMENDATION: Design projects with transit access in mind.

Project teams should capitalize on the opportunity to improve the built environment and enhance the public realm for pedestrians, bicyclists, persons with disabilities, seniors, children, and users of green modes. Metro recommends that projects:
• Orient major entrances to transit service, making access and travel safe, intuitive, and convenient.
• Plan for a continuous canopy of shade trees along all public right-of-way frontages to improve pedestrian comfort to transit facilities.
• Add pedestrian lighting along paths to transit facilities and nearby destinations.
• Integrate wayfinding and signage into project design. • Enhance nearby crosswalks and ramps.
• Ensure new walkways and sidewalks are clear of any obstructions, including utilities, traffic control devices, trees, and furniture. • Design for seamless, multi-modal pedestrian connections, making access easy, direct, and comfortable.

The City of Santa Monica leveraged investments
in rail transit and reconfigured Colorado Avenue
to form a multi-modal first/last mile gateway to
the waterfront from the Downtown Santa Monica
Station. Photo by PWP Landscape Architecture
14 | Metro Adjacent Development Handbook
Site Plan & Conceptual Design

1.3 Building Setback
Buildings and structures with a zero lot setback that closely abut Metro ROW can pose concerns to Metro during construction.

Encroachment onto Metro property to construct or maintain buildings is strongly discouraged as this presents safety hazards and may disrupt transit service and/or damage Metro infrastructure.

RECOMMENDATION: Include a minimum setback of five (5) feet from the property line to building facade to accommodate the construction and maintenance of structures without the need to encroach upon Metro property. As local jurisdictions also have building setback requirements, new developments should comply with the greater of the two requirements.

Entry into the ROW by parties other than Metro and its affiliated partners requires written approval. Should construction or maintenance of a development necessitate temporary or ongoing access to Metro ROW, a Metro Right of Entry Permit must be requested and obtained from Metro Real Estate for every instance access is required. Permission to enter the ROW is granted solely at Metro’s discretion.

Coordination between property owners of fences, walls, and other barriers along property line is recommended. See Section 1.5.

Refer to Section 3.2 – Track Access and Safety for additional information pertaining to ROW access in preparation for construction activities.

Property Line
Adjacent
Building
A minimum setback of five (5) feet between an
adjacent structure and Metro ROW is strongly
encouraged to allow project construction and
ongoing maintenance without encroaching on
Metro property.
5’
Min. Setback
Metro Adjacent Development Handbook | 15

1.4 Overhead Catenary System (OCS) Clearance
Landscaping and tree canopies can grow into the OCS above light rail lines, creating electrical safety hazards as well as visual and physical impediments for trains. Building appurtenances facing rail ROW, such as balconies, may also pose safety concerns to Metro operations as objects could fall onto the OCS.

RECOMMENDATION: Design project elements facing the ROW to avoid potential conflicts with Metro transit vehicles and infrastructure. Metro recommends that projects:
• Plan for landscape maintenance from private property and prevent growth into Metro ROW. Property owners will not be permitted to access Metro property to maintain private development.
• Design buildings such that balconies do not provide building users direct access to Metro ROW.
• Maintain building appurtenances and landscaping at a minimum distance of ten (10) feet from the OCS and support structures.

If Transmission Power (TP) feeder cable is present, twenty (20) feet from the OCS and support structures is required. Different standards will apply for Metro Trolley Wires, Feeder Cables (wires) and Span Wires.

Adjacent structures and landscaping should be
sited and maintained to avoid conflicts with the
rail OCS.

R = 20’
R = 20’
Scaffolding and construction equipment should be
staged to avoid conflicts with the rail OCS.

R = 20’
R = 20’
Scaffolding
16 | Metro Adjacent Development Handbook
Site Plan & Conceptual Design

1.5 Underground Station Portal Clearance
Metro encourages transit-oriented development. Where development is planned above station entrances, close coordination is needed for structural safety as well as access for patrons, operations, and maintenance. Below are key design rules of thumb for development planned to cantilever over an entrance to an underground Metro Rail station.

RECOMMENDATION:

1. Preserve 25 feet clearance at minimum from plaza grade and the building structure above.

2. Preserve 10 feet clearance at minimum between portal roof and building structure above.

3. Coordinate structural support system and touchdown points to ensure a safe transfer of the building loads above the station portal.

4. Coordinate placement of structural columns and amenities (e.g. signage, lighting, furnishings) at plaza level to facilitate direct and safe connections for people of all mobile abilities to and from station entrance(s).

5. Develop a maintenance plan for the plaza in coordination with Metro.
25’ 10’
Station Box
Projects that propose to cantilever over Metro
subway portals require close coordination with
Metro Engineering.

Structural
Touch
Point
Station Entrance
Metro Adjacent Development Handbook | 17

1.6 Shared Barrier Construction & Maintenance
In areas where Metro ROW abuts private property, barrier construction and maintenance responsibilities can be a point of contention with property owners. When double barriers are constructed, the gap created between the Metro-constructed fence and a private property owner’s fence can accumulate trash and make regular maintenance challenging without accessing the other party’s property.

RECOMMENDATION: Coordinate with Metro Real Estate to create a single barrier condition along the ROW property line. With an understanding that existing conditions along ROW boundaries vary throughout LA County, Metro recommends the following, in order of preference:
• Enhance existing Metro barrier: if structural capacity allows, private property owners and developers should consider physically affixing improvements onto and building upon Metro’s existing barrier. Metro is amenable to barrier enhancements such as increasing barrier height and allowing private property owners to apply architectural finishes to their side of Metro’s barrier. • Replace existing barrier(s): if conditions are not desirable, remove and replace any existing barrier(s), including Metro’s, with a new single “shared” barrier built on the property line.

Metro is amenable to sharing costs for certain improvements that allow for clarity in responsibilities and adequate ongoing maintenance from adjacent property owners without entering Metro’s property.

Metro Real Estate should be contacted with case-specific questions and will need to approve shared barrier design, shared financing, and construction.

Metro prefers a single barrier condition along its
ROW property line.

Shared Barrier
Adjacent
Building
Double barrier conditions allow trash
accumulation and create maintenance challenges
for Metro and adjacent property owners.

Private Wall
Metro Barrier
Adjacent
Building
Property Line Property Line
18 | Metro Adjacent Development Handbook
Site Plan & Conceptual Design

1.7 Project Orientation & Noise Mitigation
Metro may operate in and out of revenue service 24 hours per day, every day of the year, which can create noise and vibration (i.e. horns, power washing). Transit service and maintenance schedules cannot be altered to avoid noise for adjacent developments. However, noise and vibration impacts can be reduced through building design and orientation.

RECOMMENDATION: Use building orientation, programming, and design techniques to reduce noise and vibration for buildings along Metro ROW:
• Locate secondary or “back of house” rooms (e.g. bathrooms, stairways, laundry rooms) along ROW, rather than primary living spaces that are noise sensitive (e.g. bedrooms and family rooms). • Use upper level setbacks and locate living spaces away from ROW. • Enclose balconies.
• Install double-pane windows.
• Include language disclosing potential for noise, vibration, and other impacts due to transit proximity in terms and conditions for building lease or sale agreements to protect building owners/ sellers from tenant/buyer complaints.

Developers are responsible for any noise mitigation required, which may include engineering designs for mitigation recommended by Metro or otherwise required by local municipalities. A recorded Noise Easement Deed in favor of Metro may be required for projects within 100 feet of Metro ROW to ensure notification to tenants and owners of any proximity issues.

Building orientation can be designed to face away
from tracks, reducing the noise and vibration
impacts.

Strategic placement of podiums and upper-level
setbacks on developments near Metro ROW can
reduce noise and vibration impacts.

Podium helps buffer
sound from ROW
Landscaping
absorbs sound
from ROW
Primary rooms/spaces do
not face tracks
Enclosed balcony
buffers sound
Metro Adjacent Development Handbook | 19

1.8 At-Grade Rail Crossings
New development is likely to increase pedestrian activity at rail crossings. Safety enhancements may be needed to upgrade existing rail crossings to better protect pedestrians.

RECOMMENDATION: Coordinate with Metro, the California Public Utilities Commission (CPUC), and any other transit operators using the crossing (e.g. Metrolink) to determine if safety enhancements are needed for nearby rail crossings.

While Metro owns and operates the rail ROW, the CPUC regulates all rail crossings. Contact the CPUC early in the design process to determine if they will require any upgrades to existing rail crossings.

The CPUC may request to review development plans and hold a site visit to understand future pedestrian activity. Metro’s Corporate Safety Department can support the developer in coordination with the CPUC.

Gates and pedestrian arms are common types of
safety elements for pedestrians at rail crossings.

Safety elements of a gate and pedestrian arms have
been constructed at the Monrovia Station.
20 | Metro Adjacent Development Handbook
Site Plan & Conceptual Design

1.9 Sight-Lines at Crossings
Developments adjacent to Metro ROW can present visual barriers to transit operators approaching vehicular and pedestrian crossings.

Buildings and structures in close proximity to transit corridors can reduce sight-lines and create blind corners where operators cannot see pedestrians. This requires operations to reduce train speeds, which decreases efficiency of transit service.

RECOMMENDATION: Design buildings to maximize transit service sight-lines at crossings, leaving a clear cone of visibility to oncoming vehicles and pedestrians.

Metro Rail Operations will review, provide guidance, and determine the extent of operator visibility for safe operations. If the building envelope overlaps with the visibility cone near pedestrian and vehicular crossings, a building setback may be necessary to ensure safe transit service. The cone of visibility at crossings and required setback will be determined based on vehicle approach speed. Limited sight-lines for trains approaching street crossings create unsafe conditions.

Visibility cones allow train operators to respond to
safety hazards.

Minimum
Setback from
Property Line
Train Operator
Visibility Cone
Additional
Setback for
Visibility
Limited Visibility
for Train Operator

PED X-ING
Property Line
Metro Adjacent Development Handbook | 21

1.10 Driveway/Access Management
Driveways adjacent to on-street bus stops can create conflict for pedestrians walking to/from or waiting for transit. Additionally, driveways accessing parking lots and loading zones at project sites near Metro Rail and BRT crossings can create queuing issues along city streets and put vehicles in close proximity to fast moving trains and buses, which pose safety concerns.

RECOMMENDATION: Site driveways and other vehicular entrances to avoid conflicts with pedestrians, bicycles, and transit vehicles by:
• Placing driveways along side streets and alleys, away from onstreet bus stops and transit crossings to minimize safety conflicts between active ROW, transit vehicles, and people, as well as queuing on streets.
• Locating vehicular driveways away from transit crossings or areas that are likely to be used as waiting areas for transit services. • Placing loading docks away from sidewalks where transit bus stop activity is/will be present.
• Consolidating vehicular entrances and reduce width of driveways. • Using speed tables to slow entering/exiting automobiles near pedestrians.
• Separating pedestrian walkways to minimize conflict with vehicles. • Encouraging safe non-motorized travel.

Driveways in close proximity to each other
compromise safety for those walking to/from
transit and increase the potential for vehiclepedestrian conflicts. 22 | Metro Adjacent Development Handbook
Site Plan & Conceptual Design

1.11 Bus Stop & Zones Design
Metro Bus serves over 15,000 bus stops throughout the diverse landscape that is LA County. Typically located on sidewalks within public right-of-way owned and maintained by local jurisdictions, existing bus stop conditions vary from well-lit and sheltered spaces to uncomfortable and unwelcoming zones. Metro is interested in working with developers and local jurisdictions to create a vibrant public realm around new developments by strengthening multi-modal access to/ from Metro transit stops and enhancing the pedestrian experience.

RECOMMENDATION: When designing around existing or proposed bus stops:
• Review Metro’s Transit Service Policy, which provides standards for design and operation of bus stops and zones for near-side, farside, and mid-block stops. • Review Metro’s Transfers Design Guide for more information at https://www.metro.net/projects/station-design-projects/ • Accommodate 5’ x 8’ landing pads at bus doors (front and back door, which are typically 23 to 25 feet apart).
• Locate streetscape elements (e.g. tree planters, street lamps, benches, shelters, trash receptacles and newspaper stands) outside of bus door zones to protect transit access and ensure a clear path of travel.
• Install a concrete bus pad within each bus stop zone to avoid street asphalt damage.
• Replace stand-alone bus stop signs with bus shelters that include benches and adequate lighting.
• Design wide sidewalks (15’ preferred) that accommodate bus landing pads as well as street furniture, landscape, and user travel space.
• Consider tree species, height, and canopy shape (higher than 14’ preferred) to avoid vehicle conflicts at bus stops. Trees should be set back from the curb and adequately maintained to prevent visual and physical impediments for buses when trees reach maturity. Avoid planting of trees that have an invasive and shallow root system.

Well-designed and accessible bus stops are
beneficial amenities for both transit riders and
users of adjacent developments.

A concrete bus pad should be located at bus stops
and bus shelters should be located along sidewalks
to ensure an accessible path of travel to a clear
boarding area.

Bus Pad Clear Boarding Zone
8’ clear sidewalk to
accommodate
5’ x 8’ pad at bus doors
Metro Adjacent Development Handbook | 23
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Engineering
& Technical
Review
26 | Metro Adjacent Development Handbook
Engineering & Technical Review

2.1 Excavation Support System Design
Excavation near Metro ROW has the potential to disturb adjoining soils and jeopardize support of existing Metro infrastructure. Any excavation which occurs within the geotechnical foul zone relative to Metro infrastructure is subject to Metro review and approval and meet Cal/OSHA requirements. This foul zone or geotechnical zone of influence shall be defined as the area below a track-way as measured from a 45-degree angle from the edge of the rail track ballast.

Construction within this vulnerable area poses a potential risk to Metro service and requires additional Metro Engineering review.

RECOMMENDATION: Coordinate with Metro Engineering staff for review and approval of the excavation support system drawings and calculations prior to the start of excavation or construction. Tiebacks encroaching into Metro ROW may require a tieback easement or license, at Metro’s discretion.

Any excavation/shoring within Metrolink operated and maintained ROW will require compliance with SCRRA Engineering standards and guidelines.

See page 7 for a sample section showing Metro adjacent conditions.

An underground structure located within the
ROW foul zone would require additional review by
Metro.

Property Line
Adjacent
Building
Parking
Tiebacks
ROW
45 Foul Zone
Metro Adjacent Development Handbook | 27
Tiebacks

2.2 Proximity to Tunnels & Underground
Infrastructure
Construction adjacent to, over, or below underground Metro facilities (tunnels, stations and appendages) is of great concern and should be coordinated closely with Metro Engineering.

RECOMMENDATION: Coordinate with Metro early in the design process when proposing to build near underground Metro
infrastructure. Metro typically seeks to maintain a minimum eight (8) foot clearance from existing Metro facilities to new construction (shoring or tiebacks). It will be incumbent upon the developer to demonstrate, to Metro’s satisfaction, that both the temporary support of construction and the permanent works do not adversely affect the structural integrity, safety, or continued efficient operation of Metro facilities.

Dependent on the nature of the adjacent construction, Metro will need to review the geotechnical report, structural foundation plans, sections, shoring plan sections and calculations.

Metro may require monitoring where such work will either increase or decrease the existing overburden (i.e. weight) to which the tunnels or facilities are subjected. When required, the monitoring will serve as an early indication of excessive structural strain or movement. See Section 3.4, Excavation Drilling/Monitoring for additional information regarding monitoring requirements.

See page 7 for a sample section showing Metro adjacent conditions.

Adjacent project structures in close proximity to
underground Metro infrastructure will require
additional review by Metro.

Foundation Parking
Building
Building
R=8’
Min. from tunnels
28 | Metro Adjacent Development Handbook
Engineering & Technical Review
An underground structure proposed within twenty
(20) feet of a Metro structure may require a Threat
Assessment and Blast/Explosion Study.

Parking
Property Line

2.3 Protection from Explosion/Blast
Metro is obligated to ensure the safety of public transit infrastructure from potential explosive sources which could originate from adjacent underground structures or from at-grade locations, situated below elevated guideways or near stations. Blast protection setbacks or mitigation may be required for large projects constructed near critical Metro facilities.

RECOMMENDATION: Avoid locating underground parking or
basement structures within twenty (20) feet from an existing Metro tunnel or facility (exterior face of wall to exterior face of wall).

Adjacent developments within this 20-foot envelope may be required to submit a Threat Assessment and Blast/Explosion Study for Metro review and approval.
20’
BLAST
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Construction
Safety &
Management
32 | Metro Adjacent Development Handbook
Construction Safety & Management

3.1 Pre-Construction Coordination
Metro is concerned with impacts to service requiring rail single line tracking, line closures, speed restrictions, and bus bridging occurring as a result of adjacent project construction. Projects that will require work over, under, adjacent, or on Metro property or ROW and include operation of machinery, scaffolding, or any other potentially hazardous work are subject to evaluation in preparation for and during construction to maintain safe transit operations and passenger wellbeing.

RECOMMENDATION: Following an initial screening of the project, Metro may determine that additional on-site coordination may be necessary. Dependent on the nature of the adjacent construction, developers may be requested to perform the following as determined on a case-by-case basis:
• Submit a construction work plan and related project drawings and specifications for Metro review.
• Submit a contingency plan, show proof of insurance coverage, and issue current certificates.
• Provide documentation of contractor qualifications.
• Complete pre-construction surveys, perform baseline readings, and install movement instrumentation.
• Complete readiness review and perform practice run of transit service shutdown per contingency plan.
• Designate a ROW observer or other safety personnel and an inspector from the project’s construction team.
• Establish a coordination process for access and work in or adjacent to ROW for the duration of construction.

Project teams will be responsible for the costs of adverse impacts to Metro transit operations caused by work on adjacent developments, including remedial work to repair damage to Metro property, facilities, or systems. Additionally, a Construction Monitoring fee may be assessed based on an estimate of required level of effort provided by Metro.

All projects adjacent to Metrolink infrastructure will require compliance with SCRRA Engineering Standards and Guidelines.

Metro may need to monitor development
construction near Metro facilities.

Metro Adjacent Development Handbook | 33

3.2 Track Access and Safety
Permission from Metro is required to enter Metro property for rail construction and maintenance along, above, or under Metro ROW as these activities can interfere with Metro utilities and service and pose a safety hazard to construction teams and transit riders. Track access is solely at Metro’s discretion and is discouraged to prevent electrocution and collisions with construction workers or machines.

RECOMMENDATION: Obtain and/or complete the following to work in or adjacent to Metro Rail ROW:

1. Construction Work Plan: Dependent on the nature of adjacent construction, Metro may request a construction work plan, which describes means and methods and other construction plan details, to ensure the safety of transit operators and riders.

2. Safety Training: All members of the project construction team will be required to attend Metro Rail Safety Training before commencing work activity. Training provides resources and procedures when working near active rail ROW.

3. Right of Entry Permit/Temporary Construction Easement: All access to and activity on Metro property, including easements necessary for construction of adjacent projects, must be approved through a Right-of-Entry Permit and/or a Temporary Construction Easement obtained from Metro Real Estate and may require a fee.

4. Track Allocation: All work on Metro Rail ROW must receive prior approval from Metro Rail Operations Control. Track Allocation identifies, reserves, and requests changes to normal operations for a specific track section, line, station, location, or piece of equipment to allow for safe use by a non-Metro entity. If adjacent construction is planned in close proximity to active ROW, flaggers must be used to ensure safety of construction workers and transit riders.

Trained flaggers ensure the safe crossing
of pedestrians and workers of an adjacent
development.
34 | Metro Adjacent Development Handbook
Construction Safety & Management

3.3 Construction Hours
Building near active Metro ROW poses safety concerns and may require limiting hours of construction which impact Metro ROW to night or off-peak hours so as not to interfere with Metro revenue service. To maintain public safety and access for Metro riders, construction should be planned, scheduled, and carried out in a way to avoid impacts to Metro service and maintenance.

RECOMMENDATION: In addition to receiving necessary construction approvals from the local jurisdiction, all construction work on or in close proximity to Metro ROW must be scheduled through the Track Allocation Process, detailed in Section 3.2.

Metro prefers that adjacent construction with potential to impact normal, continuous Metro operations take place during non-revenue hours (approximately 1am-4am) or during non-peak hours to minimize impacts to service. The developer may be responsible for additional operating costs resulting from disruption to normal Metro service.

Construction during approved hours ensures
the steady progress of adjacent development
construction and minimizes impacts to Metro’s
transit service.

Metro Adjacent Development Handbook | 35

3.4 Excavation/Drilling Monitoring
Excavation is among the most hazardous construction activities and can pose threats to the structural integrity of Metro’s transit infrastructure.

RECOMMENDATION: Coordinate with Metro Engineering to review and approve excavation and shoring plans during design and development, and well in advance of construction (see Sections 2.1 and 2.2).

Geotechnical instrumentation and monitoring will be required for all excavations occurring within Metro’s geotechnical zone of influence, where there is potential for adversely affecting the safe and efficient operation of transit vehicles. Monitoring of Metro facilities due to adjacent construction may include the following as determined on a case-by-case basis:
• Pre- and post-construction condition surveys
• Extensometers
• Inclinometers
• Settlement reference points
• Tilt-meters
• Groundwater observation wells
• Movement arrays
• Vibration monitoring
Excavation and shoring plans must be reviewed
by Metro to ensure structural compatibility with
Metro infrastructure and safety during adjacent
development construction.

A soldier pile wall used for Regional Connector
station at 2nd/Hope.
36 | Metro Adjacent Development Handbook
Construction Safety & Management

3.5 Crane Operations
Construction activities adjacent to Metro ROW may require moving large, heavy loads of building materials and machinery using cranes.

Cranes referenced here include all power-operated equipment that can hoist, lower, and horizontally move a suspended load. To ensure safety for Metro riders, operators, and transit facilities, crane operations adjacent to Metro ROW must follow the safety regulations and precautions below and are subject to California Occupational Safety and Health Administration (Cal/OSHA) standards.

RECOMMENDATION:

Coordinate with Metro to discuss construction methods and confirm if a crane work plan is required. Generally, crane safety near Metro’s ROW and facilities largely depends on the following factors: 1) Metro’s operational hours and 2) swinging a load over or near Metro power lines and facilities. Note:

1. Clearance: A crane boom may travel over energized Metro OCS only if it maintains a vertical 20-foot clearance and the load maintain a horizontal 20-foot clearance.

2. Power: Swinging a crane boom with a load over Metro facilities or passenger areas is strictly prohibited during revenue hours.

To swing a load in the “no fly zone” (see diagrams to right), the construction team must coordinate with Metro to de-energize the OCS.

3. Weathervaning: When not in use, the crane boom may swing 360 degrees with the movement of the wind, including over energized Metro OCS, only if the trolley is fully retracted towards the crane tower and not carrying any loads.

4. Process: Developers and contractors must attend Metro Track Allocation (detailed in Section 3.2) to determine if Metro staff support is necessary during crane erection and load movement.

5. Permit: Developers must apply for a Metro Right-of-Entry permit to swing over Metro facilities.

Project teams will bear all costs associated with impacts to Metro Rail operations and maintenance.

Plan View: While crane boom swings over “no
fly zone,” the trolley and load are retracted to
maintain clearance from OCS.

Cranes and construction equipment should be
staged to avoid conflicts with the rail OCS.
“No fly zone”
20’
20’
Load
Trolley
Tower
(Mast)
Boom
(Jib)
20’ Setback from OCS “No fly zone”
Construction Site
Metro ROW
Adjacent Building
OCS
Load
Tower
Plan View: Crane swing and load are restricted
near Metro ROW.
20’ Setback from OCS “No fly zone”
Construction Site
Metro ROW
Adjacent Building
Load
Tower
Metro Adjacent Development Handbook | 37

3.6 Construction Barriers & Overhead Protection
During construction, falling objects can damage Metro facilities and pose a safety concern to the riders accessing them.

RECOMMENDATION: Erect vertical construction barriers and overhead protection compliant with Metro and Cal/OSHA requirements to prevent objects from falling into Metro ROW or areas designed for public access to Metro facilities. A protection barrier shall be constructed to cover the full height of an adjacent project and overhead protection from falling objects shall be provided over Metro ROW as necessary. Erection of the construction barriers and overhead protection for these areas shall be done during Metro non-revenue hours.

Overhead protection is required when moving
heavy objects over Metro ROW or in areas
designated for public use.

Constructed above is a wooden box over the
entrance portal for overhead protection at the
4th/Hill Station.
38 | Metro Adjacent Development Handbook
Construction Safety & Management

3.7 Pedestrian & Emergency Access
Metro’s riders rely on the consistency and reliability of access and wayfinding to and from stations, stops, and facilities. Construction on adjacent property must not obstruct pedestrian access, fire department access, emergency egress, or otherwise present a safety hazard to Metro operations, its employees, riders, and the general public. Fire access and safe escape routes within all Metro stations, stops, and facilities must be maintained at all times.

RECOMMENDATION: Ensure pedestrian and emergency access
from Metro stations, stops, and transit facilities is compliant with the Americans with Disabilities Act (ADA) and maintained during construction:
• Temporary fences, barricades, and lighting should be installed and watchmen provided for the protection of public travel, the construction site, adjacent public spaces, and existing Metro facilities.
• Temporary signage should be installed where necessary and in compliance with the latest California Manual on Uniform Traffic Control Devices (MUTCD) and in coordination with Metro Art and Design Standards.
• Emergency exits shall be provided and be clear of obstructions at all times.
• Access shall be maintained for utilities such as fire hydrants, stand pipes/connections, and fire alarm boxes as well as Metro-specific infrastructure such as fan and vent shafts.

Sidewalk access is blocked for a construction
project, forcing pedestrians into the street or to use
less direct paths to the Metro facility.

Metro Adjacent Development Handbook | 39

3.8 Impacts to Bus Routes & Stops
During construction, bus stop zones and routes may need to be temporarily relocated. Metro needs to be informed of activities that require stop relocation or route adjustments in order to ensure uninterrupted service.

RECOMMENDATION: During construction, maintain or relocate existing bus stops consistent with the needs of Metro Bus Operations.

Design of temporary and permanent bus stops and surrounding sidewalk areas must be compliant with the ADA and allow passengers with disabilities a clear path of travel to the transit service. Existing bus stops must be maintained as part of the final project. Metro Bus Operations Control Special Events Department and Metro Stops & Zones Department should be contacted at least 30 days before initiating construction activities.

Temporary and permanent relocation of bus
stops and layover zones will require coordination
between developers, Metro, and other municipal
bus operators and local jurisdictions.
40 | Metro Adjacent Development Handbook
Construction Safety & Management

3.9 Utility Coordination
Construction has the potential to interrupt utilities that Metro relies on for safe operations and maintenance. Utilities of concern to Metro include, but are not limited to, condenser water piping, potable/fire water, storm and sanitary sewer lines, and electrical/ telecommunication services.

RECOMMENDATION: Coordinate with Metro Real Estate during project design to gauge temporary and permanent utility impacts and avoid conflicts during construction.

The contractor shall protect existing above-ground and underground Metro utilities during construction and coordinate with Metro to receive written approval for any utilities pertinent to Metro facilities that may be used, interrupted, or disturbed.

When electrical power outages or support functions are required, approval must be obtained through Metro Track Allocation in coordination with Metro Real Estate for a Right of Entry Permit.

To begin coordination with Metro Real Estate, visit www.metro.net/ devreview and select the drop-down “Utility Project Coordination.” Coordination of underground utilities is critical to
safely and efficiently operate Metro service.

Metro Adjacent Development Handbook | 41

3.10 Air Quality & Ventilation Protection
Hot or foul air, fumes, smoke, steam, and dust from adjacent construction activities can negatively impact Metro facilities, service, and users.

RECOMMENDATION: Ensure that hot or foul air, fumes, smoke, and steam from adjacent facilities are discharged beyond 40 feet from existing Metro facilities, including but not limited to ventilation system intake shafts and station entrances. Should fumes be discharged within 40 feet of Metro intake shafts, a protection panel around each shaft shall be required.

A worker breaks up concrete creating a cloud of
silica dust.
42 | Metro Adjacent Development Handbook
Glossary
Cone of Visibility
A conical space at the front of moving transit vehicles allowing for clear visibility of travel way and/or conflicts.

Construction Work Plan (CWP)
Project management document outlining the definition
of work tasks, choice of technology, estimation of
required resources and duration of individual tasks, and identification of interactions among the different work tasks.

Flagger/Flagman
Person who controls traffic on and through a construction project. Flaggers must be trained and certified by Metro Rail Operations prior to any work commencing in or
adjacent to Metro ROW.

Geotechnical Foul Zone
Area below a track-way as measured from a 45-degree
angle from the edge of the rail track ballast.

Guideway
A channel, track, or structure along which a transit
vehicle moves.

Heavy Rail Transit (HRT)
Metro HRT systems include exclusive ROW (mostly
subway) trains up to six (6) cars long (450’) and utilize a contact rail for traction power distribution (e.g. Metro Red Line).

Joint Development (JD)
JD is the asset management and real estate development
program through which Metro collaborates with
developers to build housing, retail, and other amenities on Metro properties near transit, typically through
ground lease. JD projects directly link transit riders with destinations and services throughout LA County.

Light Rail Transit (LRT)
Metro LRT systems include exclusive, semi-exclusive, or street ROW trains up to three (3) cars long (270’) and
utilize OCS for traction power distribution (e.g. Metro Blue Line).

Measure R
Half-cent sales tax for LA County approved in November
2008 to finance new transportation projects and
programs. The tax expires in 2039.

Measure M
Half-cent sales tax for LA County approved in November
2016 to fund transportation improvements, operations
and programs, and accelerate projects already in the
pipeline. The tax will increase to one percent in 2039
when Measure R expires.

Metrolink
A commuter rail system with seven lines throughout Los
Angeles, Orange, Riverside, San Bernardino, Ventura,
and North San Diego counties governed by the Southern
California Regional Rail Authority (SCRRA).

Metro Adjacent Construction Design Manual
Volume III of the Metro Design Criteria & Standards,
which outlines the Metro adjacent review procedure as
well as operational requirements when constructing over, under, or adjacent to Metro facilities, structures, and property.

Metro Bus
Metro “Local” and “Rapid” bus service runs within
the street, typically alongside vehicular traffic, though occasionally in “bus-only” lanes.

Metro Bus Rapid Transit (BRT)
High quality bus service that provides faster and
convenient service through the use of dedicated ROW,
branded vehicles and stations, high frequency and
intelligent transportation systems, all-door boarding, and intersection crossing priority. Metro BRT may run within dedicated ROW or in mixed flow traffic on streets.

Metro Adjacent Development Handbook | 43
Metro Design Criteria and Standards
A compilation of documents that govern how Metro
transit service and facilities are designed, constructed, operated, and maintained.

Metro Rail
Urban rail system serving LA County consisting of six lines, including two subway lines and four light rail lines.

Metro Rail Design Criteria (MRDC)
Volume IV of the Metro Design Criteria & Standards
which establishes design criteria for preliminary
engineering and final design of a Metro Rail Project.

Metro Transit Oriented Communities
Land use planning and community development program
that seeks to maximize access to transportation as a key organizing principle and promote equity and sustainable living by offering a mix of uses close to transit to support households at all income levels, as well as building
densities, parking policies, urban design elements, and first/last mile facilities that support ridership and reduce auto dependency.

Noise Easement Deed
Easement granted by property owners abutting Metro
ROW acknowledging noise due to transit operations and
maintenance.

Overhead Catenary System (OCS)
One or more electrified wires situated over a transit ROW that transmit power to light rail trains via pantograph, a current collector mounted on the roof of an electric
vehicle. Metro OCS is supported by hollow poles placed
between tracks or on the outer edge of parallel tracks.

Right of Entry Permit
Written approval granted by Metro Real Estate to enter
Metro ROW and property.

Right of Way (ROW)
Legal right over property reserved for transportation
purposes to construct, protect, maintain and operate
transit services.

Southern California Regional Rail Authority (SCRRA)
A joint powers authority made up of an 11-member
board representing the transportation commissions
of Los Angeles, Orange, Riverside, San Bernardino and
Ventura counties. SCRRA governs and operates Metrolink
service.

Threat Assessment and Blast/Explosion Study
Analysis performed when adjacent developments are
proposed within twenty (20) feet from an existing Metro tunnel or facility.

Track Allocation/Work Permit
Permit granted by Metro Rail Operations Control to
allocate a section of track and perform work on or
adjacent to Metro Rail ROW. This permit should be
submitted for any work that could potentially foul the
envelope of a train.

Wayfinding
Signs, maps, and other graphic or audible methods used
to convey location and directions to travelers.
44 Metro Adjacent Development Handbook
metro.net/projects/devreview/

APPENDIX B
CERTIFIED ARBORIST RESUME (DAVID T. HUGHES)
City of Pasadena | Statement of Qualifications 1

David Hughes is a Senior Project Manager and Certified Arborist with 19 years of experience in environmental consulting, specifically, mitigation planning, restoration monitoring, wetland delineations, and regulatory permitting. David has been a Certified Arborist by the International Society of Arboriculture since 2006 with expertise in tree inventories, appraisals, construction protection plans, tree replacement plans, and construction monitoring. He has extensive experience working with assisting both private and public entities with obtaining regulatory authorizations from a variety of city, county, state, and federal agencies.

Experience
On-call Arborist Consulting Services, Pasadena, CA: Mr. Hughes has served as Senior Arborist to support the Pasadena Planning Department with tree assessment services on an on-call basis. Since 2019, Mr.

Hughes has provided assistance to the City by evaluating tree removal permit applications that are submitted by private homeowners to help staff determine if tree removal is warranted. Review of tree removal applications consist of reading the applicant materials provided, performing a site visit to the subject residence, and preparing a summary report to staff.

Affordable Housing Development, 690 North Orange Grove Boulevard, Pasadena, CA: Mr. Hughes performed an inventory of trees on the project site located at 690 North Orange Grove Boulevard for the project applicant, Haven Ponderosa, LLC. The purpose of the tree survey was to map and identify all trees that were subject to regulation by the City of Pasadena Tree Ordinance to assist the applicant acquire a tree removeal permit from the City. In addition to the tree inventory and report, Mr.

Hughes prepared all the application materials for a private tree removal request and assisted the applicant to prepare the City’s Environmental Assessment Form.

University of California, Los Angeles, On-Call Contract Tree Inventory Studies, Los Angeles, CA: Mr. Hughes has performed tree inventory studies as part of an On-Call Contract. Projects for which tree studies have been performed include: the Pauley Pavilion Expansion Project, the Northwest Housing Infill Project, the Weyburn Terrace Housing Project, and the Wasserman Eye Research Center Project, all of which are located on the University of California, Los Angeles (UCLA) campus. Tree inventory methods followed requirements set forth in the UCLA Long Range Development Plan, a programmatic Environmental Impact Report that addresses all campus projects and the City of Los Angeles Tree Protection Ordinance.

David Hughes
Senior Project Manager/Certified Arborist

EDUCATION
2003/MS/Ecological Restoration
and Management/University of
Wisconsin, Madison
1991/BS/Ecology, Behavior and
Evolution/University of California,
San Diego

CERTIFICATIONS
Certified Arborist/WE7752A/International Society of
Arboriculture
Certified Ecological Restoration
Practitioner/No. 243/Society for
Ecological Restoration
Trained Practitioner, California
Rapid Assessment Method,
Riverine and Depressional
Wetland Modules/
U.S. Army Corps of Engineers
Jurisdictional Delineation
Training/Richard Chinn
Environmental Training, Inc.

PROFESSIONAL

AFFILIATIONS
Western Chapter, International
Society of Arboriculture
California Society for Ecological
Restoration

EXPERIENCE
With Psomas: 19 years
With Other Firms: 1 year

David Hughes
(Continued)
City of Pasadena | Statement of Qualifications 2
Oak Grove Park Habitat Restoration Project, Pasadena, CA: Mr. Hughes assisted the Parks and Natural Resources Division of Pasadena Department of Public Works to plan and implement a habitat restoration project in Oak Grove Park, west of Devil’s Gate Reservoir in the City of Pasadena. The restoration planning consisted of identifying over 100 non-native trees to provide possible areas for conversion to native habitat. The list of non-native trees was provided to the Pasadena Urban Forest Advisory Council to facilitiate their removal as part of the overall restoration program.

Upper Arroyo Seco Bridge Replacement, Oak Tree Protection and Monitoring, Hahamongna Watershed Park, Pasadena, CA: Mr. Hughes provided tree monitoring services to assist Pasadena Water and Power replace a damaged wood bridge over the Upper Arroyo Seco. Mr.

Hughes identified all trees in the vicinity of the project site and provided monitoring services to ensure the bridge construction contractor did not damage any adjacent trees and to ensure that all conditions of their environemental permits were followed. Mr. Hughes also prepared a mitigation plan to offset temporary impacts that occurred to the banks of the Arroyo Seco during construction.

Sterling Development Project, Restoration and Regulatory Services, West Hills, CA. The project consists of an approximate 200-home residential development along with associated infrastructure. Mr. Hughes serves as the Project Manager for this project and has provided regulatory permitting and mitigation planning services; and performed a delineation of jurisdictional waters. As Project Arborist, Mr. Hughes prepared a tree protection and mitigation plan to minimize construction impacts and provided monitoring services during construction to minimize tree impacts. Mr. Hughes also prepared a tree mitigation plan to meet the requirements of the City of Los Angeles.

Alamo Heights Development Project, Oak Tree Replacement Planning and Monitoring, Glendora, CA: As a consultant to the City of Diamond Bar, Mr. Hughes assisted Horizon Pacific Construction to comply with the requirements of their resource agency permits and the requirements of the City of Diamond Bar Tree Ordinance by preparing a tree mitigation plan and overseeing its implementation. Mr. Hughes identified a local land conservancy as a partner to the project, helped the developer to hire a reputable landscape contractor, and worked to successfully implement the tree mitigation plan. The mitigation program consisted of the establishment of over 400 coast live oak, scrub oak, and Southern California black walnut trees and is on track to successfully meet all plan requirements within the long-term maintenance period.

Tesoro del Valle Residential Development Project, Restoration and Regulatory Services, Los Angeles County: Mr. Hughes surveyed the 800- acre Tesoro del Valle project site to document all oak trees subject to the Los Angeles County Oak Tree Ordinance and all oak woodlands as defined by the Los Angeles County Oak Woodlands Conservation Plan.

Mr. Hughes prepared an oak tree survey report that documented the results of the survey and prepared an oak tree Burden of Proof to assist the client to receive an oak tree permit from the County of Los Angeles.

Mr. Hughes also performed a delineation of jurisdictional waters on the project site for the purpose of extending the existing USACE permit for the project.

Errata to Affinity Project Final EIR (SCH No. 2021080103)

ERRATA ON THE FINAL EIR
JULY 2022
This errata sheet presents the revisions to the Final Environmental Impact Report (Final EIR) prepared for the Affinity Project (SCH No. 2021080103) and dated May 2022.

This errata is provided to clarify. None of the revisions contained in this errata constitutes significant new information or changes to the analysis or conclusions of the EIR. Changes in text are signified by strikeouts (strikeouts) where text has been removed and by bold underlining (underline) where text has been added.

Section 2.0, Environmental Setting and Project Description

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

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