Pasadena City Council
July 10, 2023

BROOKSIDE GOLF COURSE

IMPROVEMENTS PROJECT
MAY 2023

INITIAL STUDY/MITIGATED NEGATIVE DECLARATION

RESPONSE TO COMMENTS

May 2023 | IS/MND Response to Comments

BROOKSIDE GOLF COURSE

IMPROVEMENTS PROJECT
Prepared for:

Rose Bowl Operating Company
Contact: Jenessa Castillo, Senior Chief Operations Officer 1001 Rose Bowl Drive
Pasadena California 91103
(626) 577-3104

Prepared by:

PlaceWorks
Contact: Addie Farrell, Principal
700 South Flower Street, Suite 600
Los Angeles, California 90017
213.623.1443
[email protected]
www.placeworks.com

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Table of Contents
May 2023 Page i

Section Page

1. INTRODUCTION ........................................................................................................................... 1-1

1.1 BROOKSIDE GOLF COURSE IMPROVEMENTS PROJECT ............................................................ 1-1

1.2 INITIAL STUDY/MITIGATE NEGATIVE DECLARATION ............................................................ 1-1

1.3 RESPONSE TO COMMENTS DOCUMENT FORMAT ....................................................................... 1-1

1.4 CEQA REQUIREMENTS REGARDING COMMENTS AND RESPONSES ................................. 1-2

1.5 PUBLIC ENGAGEMENT ............................................................................................................................... 1-3

1.5.1 Document Availability ........................................................................................................................ 1-3

1.5.2 Community Outreach ......................................................................................................................... 1-3

1.6 NEED FOR RECIRCULATION OF AN MND PRIOR TO ADOPTION ........................................ 1-4

2. RESPONSE TO COMMENTS ...................................................................................................... 2-1

2.1 TOPICAL RESPONSES TO COMMENTS ................................................................................................ 2-3

2.1.1 Topical Response 1: Unstable Project Description ....................................................................... 2-4

2.1.2 Topical Response 2: Lighting ............................................................................................................ 2-5

2.1.3 Topical Response 3: Tree Removal and Wildlife............................................................................ 2-7

2.1.4 Topical Response 4: Land Use and Planning ............................................................................... 2-10

2.1.5 Topical Response 5: Noise ............................................................................................................... 2-11

2.1.6 Topical Response 6: Recreation ...................................................................................................... 2-13

2.1.7 Topical Response 7: Transportation and Parking ........................................................................ 2-14

2.1.8 Topical Response 8: Project Alternatives ...................................................................................... 2-16

2.2 RESPONSES TO WRITTEN AND VERBAL COMMENTS .............................................................. 2-18

2.2.1 Responses to Written Comments ................................................................................................... 2-19

2.2.2 Responses to Verbal Comments .................................................................................................. 2-215

3. REVISIONS TO THE INITIAL STUDY/MITIGATED NEGATIVE DECLARATION ...................... 3-1

3.1 INTRODUCTION ............................................................................................................................................. 3-1

3.2 IS/MND REVISIONS IN RESPONSE TO WRITTEN COMMENTS ............................................... 3-1

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Table of Contents
Page ii PlaceWorks

LIST OF TABLES
Table Page
Table 1 Written Comments Submitted ......................................................................................................... 2-1 Table 2 Verbal Comments Submitted ........................................................................................................... 2-2 Table 3 Brookside Golf Course Parking Lots .......................................................................................... 2-16

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1. Introduction

1.1 BROOKSIDE GOLF COURSE IMPROVEMENTS PROJECT
The Rose Bowl Operating Company (RBOC) proposes the implementation of the Brookside Golf Course Improvements Project (Project) to reorient, expand the existing driving range, and construct a new miniature golf facility within the existing driving range area at the Brookside Golf Course (or golf course). Project improvements would occur on approximately 16 acres within the exi sting driving range, Hole 10 of the C.W .

Koiner Course, and Holes 6 and 7 of the E.O. Nay Course (Project Site). The Project consists of two main components within the 16-acre Project Site: (1) reorient and expand the existing driving range toward the north; and (2) develop a new miniature golf course adjacent and west of the expanded driving range.

1.2 INITIAL STUDY/MITIGATE NEGATIVE DECLARATION
An Initial Study (IS) was prepared for the Project and concluded that there will be less than significant impacts on the environment with the incorporation of mitigation measures; therefore, a mitigated negative declaration (MND) was prepared. Possible impacts on Aesthetics (Lighting), Biological Re sources, Cultural Resources, Tribal Cultural Resources, and Mandatory Findings of Significance were identified in the IS and mitigated to a less than significant level. This document includes the public comments received on the IS /MND as well as the RBOC’s responses to those comments.

Under the California Environmental Quality Act (CEQA) (Public Resources Code, Division 13, Sections 21000 et seq.) and the CEQA Guidelines (California Code of Regulations, Title 14, Division 6, Chapter 3, Section s 15000 et seq.), a lead agency has no affirmative duty to prepare formal responses to comments on an MND.

The lead agency, however, should have adequate information on the record explaining why the comments do not affect the conclusion of the MND. In the spirit of public disclosure and engagement, the RBOC—as the lead agency for the P roject—has responded to all written and verbal comments submitted during the public review period.

1.3 RESPONSE TO COMMENTS DOCUMENT FORMAT
This document is organized as follows:

Section 1, Introduction. This section describes CEQA requirements and content of this document.

Additionally, this section describes the public engagement and community outreach that was conducted for the Project.

Section 2, Response to Comments. This section provides a list of organizations and interested persons commenting on the Initial Study/Mitigated Negative Declaration (IS/MND) ; copies of comment letters received during the public review period; summary of verbal comments; and topical and individual responses

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1. Introduction

to written and verbal comments. References to “Comment letters” or “written comments” as used herein refers to any written communication, including emails, letters, and comment cards. References to “Verbal comments” as used herein refers to verbal comments provided at the community informational meeting on February 13, 2023, and the RBOC board meeting on March 2, 2023 . To facilitate review, each comment letter has been reproduced and assigned a number —R-1 through R -48 for comment letters and verbal comments received from residents and interested parties , and O -1 through O -14 for comment le tters received from local organizations. Individual comments have been numbered for each letter, and the letter is followed by responses with references to the corresponding comment number.

Section 3, Revisions to the IS/MND . This section contains revisions to the IS/MND text and figures as a result of the comments received by organizations and interested persons as described in Section 2, and/or to correct any minor errors and omissions discovered subsequent to release of the IS/MND for public review.  Attachment A, Informational Community Meeting Presentation . This appendix contains the presentation materials from the Informational Community Meeting on February 13, 2023.  Attachment B, Historic Photographs of Brookside Golf Course. This appendix contains photographs of the existing conditions on the Brookside Golf Course from previous decades.  Attachment C, Existing Light at Brookside Golf Course. This appendix contains photographs of existing lighting conditions at the Project Site and Brookside Golf Course parking lots.  Attachment D, Potential Location of Trees to Be Removed. This appendix contains the anticipated locations of trees that would be removed for the Project.  Attachment E, Parking Lot Locations and Improvements. This appendix contains an illustration of proposed parking improvements as a result of the Project.

1.4 CEQA REQUIREMENTS REGARDING COMMENTS AND RESPONSES
CEQA Guidelines Section 15204(b) outlines parameters for submitting comments on MNDs and reminds persons and public agencies that the focus of review and comment should be “on the proposed finding that the project will not have a significant effect on the en vironment.” If the commenter believes that the project may have a significant effect, it should: (1) Identify the specific effect, (2) Explain why they believe the effect would occur, and (3) Explain why they believe the effect would be significant.

Comments are most helpful when they suggest additional specific alternatives or mitigation measures that would provide better ways to avoid or mitigate potentially significant environmental effects. At the same time, reviewers should be aware that the adequacy of an MND is determined in terms of what is reasonably feasible.

Section 15204(d) also states, “Each responsible agency and trustee agency shall focus its comments on environmental information germane to that agency’s statutory responsibility.” Section 152 04(e) states, “This

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1. Introduction
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section shall not be used to restrict the ability of reviewers to comment on the general adequacy of a document or of the lead agency to reject comments not focused as recommended by this section.” Finally, CEQA does not require a lead agency to conduct every test or perform all research, study, and experimentation recommended or demanded by commenters. Written responses to comments are not required for MNDs; however, the RBOC understands the importance of this Project to the community and therefore is choosing to respond in writing to received comments. When responding to comments, lead agencies need only respond to potentially significant environmental issues ; they do not need to provide all information requested by reviewers or respond to nonenvironmental comments as long as a good -faith effort at full disclosure is made in the environmental document.

1.5 PUBLIC ENGAGEMENT
Notice of Intent to Adopt a Mitigated Negative Declaratio n. Per CEQA Guidelines Sections 15072 and 15073, after preparation of an IS, the RBOC determined that an MND would be appropriate for the Project and circulated a Notice of Intent (NOI) to Adopt a Mitigated Negative Declaration. The public review period for the IS/MND was from January 13, 2023, to March 3, 2023. This was a 45-day public comment period which exceeds the 30 -day minimum review for projects submitted to State Clearinghouse set forth in CEQA Guidelines Section 15073(b). Public notification of the IS/MND included the following methods.  NOI sent to addresses within 500 feet of the Brookside Golf Course — 531 owner/occupant mailings.  NOI sent to 74 state and local agencies and 2 Native American tribes.  Emailed notification to the RBOC interested parties distribution list, consisting of over 1,200 recipients.

1.5.1 Document Availability
The NOI and IS/MND were available for review at the following locations:
 Rose Bowl Administration Office, 1001 Rose Bowl Drive, Pasadena, CA 91103  RBOC’s webpage at https://rosebowlstadium.com/public-notices  CEQAnet Web Portal: https://ceqanet.opr.ca.gov/2023010324

1.5.2 Community Outreach
During preparation of the IS/MND, the RBOC led 11 community informational meetings (see Attachment A for more details). In addition, over 42,000 emails were sent to golfers and residents in the Rose Bowl campus databases. An informational community meeting to take comments on the IS/MND was held on February 13, 2023, at the Brookside Golf Course, Mediterranean Room, 1133 Rosemont Avenue, Pasadena, CA 91103, at 5:00 pm and was noticed in the NOI as distributed above. The meeting included an overview of the IS/MND and gave agencies, organizations, and residents the opportunity to make verbal and written comments on the Project and the IS/ MND. Approximately 71 people attend ed, 17 individuals made verbal comments, and

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1. Introduction

2 submitted comments cards during the meeting . Attachment A to this document includes the presentation materials that were shared during that meeting. On March 2, 2023 (and also during the public comment period), the Project was presented as an informational item at the publicly noticed RBOC board meeting . Four individuals provided verbal comments during this meeting.

During the public review period, 41 letters and emails we re received from local residents and organization s providing comments on the Project and the IS/MND (see Table 1, Written Comments Submitted, and Table 2, Verbal Comments Submitted ). Summaries and responses to the written and verbal comments can be found in Section 2.2, Responses to Written and Verbal Comments, below.

1.6 NEED FOR RECIRCULATION OF AN MND PRIOR TO ADOPTION
Section 15073.5(a) of the CEQA Guidelines states that a lead agency is required to recirculate a n IS/MND when the document must be substantially revised after public notice of its availability has previously been given pursuant to Section 15072, but prior to its adoption. Notice of recirculation shall comply with Sections 15072 and 15073. A “substantial revision” of the IS/MND refers to the following:

1. A new, avoidable significant effect is identified and mitigation measures or project revisions must be added in order to reduce the effect to insignificance, or

2. The lead agency determines that the proposed mitigation measures or project revisions will not reduce potential effects to less than significance and new measures or revisions must be required.

The IS/MND would not be required to be recirculated under the following circumstances:

1. Mitigation measures are replaced with equal or more effective measures pursuant to Section 15074.1.

2. New project revisions are added in response to written or verbal comments on the project’s effects identified in the proposed negative declaration which are not new avoidable significant effects.

3. Measures or conditions of project approval are added after circulation of the negative declaration which are not required by CEQA, which do not create new significant environmental effects and are not necessary to mitigate an avoidable significant effect.

4. New information is added to the negative declaration which merely clarifies, amplifies, or makes insignificant modifications to the negative declaration.

As a result of the comments received and revisions made in this document, the RBOC has determined that the requirements in Section 15073.5 are not met and that recirculation of the IS/MND is not required. The analysis and conclusions in the IS/MND demonstrate substantial evidence in light of the whole record that the Project would not have a significant effect on the environment.

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2. Response to Comments
As described above, an IS/MND analyzing and disclosing potential environmental effects resulting from the Project was prepared and circulated for public review from January 13, 202 3, to March 3, 2023. The RBOC’s responses to the comments on the IS /MND represent a good -faith, reasoned effort to address the environmental issues identified by the comments.

Table 1, Written Comments Submitted, and Table 2, Verbal Comments Submitted, list the individuals and organizations that provided written or verbal comments on the IS/MND during the 45-day public review period, and the dates that the comment s were received. In total, 39 comment letters or emails and 2 comment cards were received; 17 individuals provided verbal comments during the public informational meeting on February 13, 2023; and 4 individuals provided verbal comments at the RBOC board meeting on March 2, 2023.

Table 1 Written Comments Submitted
Comment # Commenter Date Received
Residents
R1 Lawrence Deady January 31, 2023
R2 John Landis February 13, 2023
R3 John Landis February 13, 2023
R4 Andrea Bland February 13, 2023
R5 Megan Foke February 14, 2023
R6 Brian Elerding February 14, 2023
R7 John Callas February 14, 2023
R8 Mary Bucci Bush February 14, 2023
R9 Petrea Burchard February 14, 2023
R10 William Morris February 14, 2023
R11 William Morris February 15, 2023
R12 Vicki Livingstone February 15, 2023
R13 Susan Whichard February 16, 2023
R14 Jill Sigler February 16, 2023
R15 Patricia Crook February 18, 2023
R16 James Treidler February 18, 2023
R17 Jennifer Jacobs February 18, 2023
R18 Ellen G. Strauss February 26, 2023
R19 Maureen Hosp March 1, 2023
R20 Frank Clem March 1, 2023
R21 Nancy Gadel March 1, 2023

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Table 1 Written Comments Submitted
Comment # Commenter Date Received
R22 Patty Montbriand March 1, 2023
R23 Patrick Feely March 2, 2023
R24 Geoff Bland March 2, 2023
R25 Irena Petrack March 2, 2023
R26 Susan Burns March 2, 2023
R27 Michael Clayton March 2, 2023
R28 Carlos Chacon March 2, 2023
R29 Allen Gharapetian March 2, 2023
R30 Laura Burke March 3, 2023
R31 Marcus Renner March 3, 2023
R32 Marie Levine March 3, 2023
R33 Arnold Siegel March 3, 2023
R34 Adry Furchtgott March 3, 2023
Organizations
O1 Evan Davis (West Pasadena Residents Association) February 23, 2023 O2 Geoffrey Baum (West Pasadena Residents Association) February 23, 2023 O3 Robert Baderian (First Tee) March 2, 2023
O4 Greg King (Pasadena Beautiful) March 3, 2023
O5 Nina Chomsky (LVAA) March 3, 2023
O6 Tim Martinez (Arroyo & Foothills Conservancy) March 3, 2023 O7 Tim Brick (Arroyo Seco Foundation) March 3, 2023

Table 2 Verbal Comments Submitted
Comment # Commenter Date Received
Residents
R35 Nina Chomsky February 13, 2023
R36 Bill Fennessy February 13, 2023
R37 Doug Philbin February 13, 2023
R38 Craig Kessler February 13, 2023
R39 Dianne Philibosian February 13, 2023
R40 Alan Behr February 13, 2023
R41 Betsy Nathane February 13, 2023
R42 Mark Whichard February 13, 2023
R43 Jamie Scott February 13, 2023
R44 Felix Breden February 13, 2023

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Table 2 Verbal Comments Submitted
Comment # Commenter Date Received
R45 Philip Jespersen February 13, 2023
R46 Mario February 13, 2023
R47 Kelly Holmes February 13, 2023
R48 Patty Brugman February 13, 2023
Organizations
O8 Nina Chomsky (Linda Vista-Annandale Association) February 13, 2023 O9 Pete Ewing (West Pasadena Residents Association) February 13, 2023 O10 Tim Brick (Arroyo Seco Foundation) February 13, 2023 O11 Craig Kessler (Southern California Golf Association) March 2, 2023 O12 Andy Gantner (Linda Vista-Annandale Association) March 2, 2023 O13 Doug Philbin (Brookside Men’s Golf Club) March 2, 2023 O14 Geoffrey Baum (West Pasadena Residents
Association) March 2, 2023

2.1 TOPICAL RESPONSES TO COMMENTS
To reduce repetitive responses, this document includes “Topical Responses to Comments” specifically focusing on the concerns raised through out the IS/MND public review. The topical responses to comments address comments related to general issues that are common throughout several comment letters. The intent of a topical response is to provide a comprehensive response to an issue so that all aspects of the issue are addressed in a co ordinated, organized manner in one location, reducing repetition of responses. Main environmental concerns that were raised during the public review period include:
 Topical Response 1: Unstable Project Description
 Topical Response 2: Impacts Related to Lighting
 Topical Response 3: Tree Removal and Wildlife
 Topical Response 4: Consistency with the Arroyo Seco Master Plan and Arroyo Seco Public Lands Ordinance
 Topical Response 5: Increased Noise
 Topical Response 6: Changes to the Brookside Golf Course

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2. Response to Comments

 Topical Response 7: Traffic and Parking
 Topical Response 8: Alternative Project Design and Location

2.1.1 Topical Response 1: Unstable Project Description

2.1.1.1 SUMMARY OF COMMENTS RECEIVED
Comments received expressed concerns that the Project Description is considered unstable because there is not a final design in the IS/MND. Comments assert that the Project Description is too conceptual and contains insufficient detail from which to conduct an environmental analysis and inform the public. Comments further assert that the RBOC, in serving as the lead agency for its own project, does not meet the requirements in the CEQA Guidelines regarding the amount of information available in the Project Description.

2.1.1.2 RESPONSE TO COMMENTS
The analysis in the IS/MND is based on a comprehensive discussion of details of the Project in Section 1.5, Description of Project, of the IS/MND, which reflects the Project as proposed by the applicant, which in this case is the RBOC. Section 15124 of the CEQA Guidelines (specific to an EIR but directly relevant for this purpose) states that a description of the P roject should contain the following information but should not supply extensive detail beyond what is needed for evaluation and review of environmental impacts.  The precise location and boundaries of the proposed project.  A clear statement of the project objectives.
 A general description of the project’s technical, economic, and environmental characteristics.  A statement briefly describing the intended uses of the environmental document.

As stated on page 1 of the IS/MND, the RBOC seeks to build bureaucratic, public, and financial momentum behind the Project at this time , and to ensure that all environmental concerns of the Project that can be reasonably foreseen and analyzed are properly studied and disclosed now . The Project Description in the IS/MND provides all the details necessary for a thorough and comprehensive environmental impact analysis that meets and exceeds the requirements of CEQA. The location of the Project and boundaries of the Project Site are in Section 1.2.1, Project Location and Surrounding Uses. The Project’s objectives are stated in Section 1.5.1, Purpose of Project . All p roject components, including the proposed driving range and miniature golf course ; Project Site boundaries; and operational details , as well as proposed construction activities , have been adequately described in Sections 1.5.2, Project Description; Section 1.5.3, Project Design ; Section 1.5.4, Operational Changes; and Section 1.5.5, Construction Activities. And the intended uses of this environmental document are stated in Section 1.6, Intended Use of the MND, Responsible Agencies, and Project Approvals.

Though there was not a “final approved design” at the time the IS/MND was prepared, CEQA does not require such, and all components of the Project have been adequately disclosed and properly evaluated. In lieu of having a “final approved design ,” the IS/MND appropriately analyzes the maximum extent of physical impacts to the environment from Project implementation. Upon completion of the final Project design, as with any Project approval, the RBOC and the City of Pasadena, through future approval of a Conditional Use Permit

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(CUP), will ensure that the Project description remains within the parameters set in the IS/MND. As part of the City’s process to issue a future CUP, the Project would be subject to the City’s Design Review process , as defined in the Pasadena Municipal Code, to ensure that the findings of the IS/MND address the final design and that all impacts and mitigation measures are appropriate. All components of the Project must be consistent with the Pasadena Municipal Code , and this is discussed in the IS/MND in Section 1 .5.3, Project Design .

Approval of this CEQA document does not replace the need for the RBOC to comply with mitigation measures and comply with the various policies and regulatory requirements of the City of Pasadena.

Specific comments regarding Project components and potential impacts regarding lighting, biological resources, land use consistency, noise, recreation, traffic and parking, and Project alternatives are discussed further in the topical responses below.

By approving the IS/MND now, the RBOC is consistent with CEQA Guidelines Section 15323, which defines “approval” of a project as occurring “ upon the earliest commitment to issue or the issuance by the public agency of a discretionary contract, grant, subsidy, loan, or other form of financial assistance, lease, permit, license, certificate, or other entitlement for use of the project.” As stated in the IS/MND and above, the RBOC will commit substantial public funds to the pursuit of the Project now and will use that approval and adoption of the IS/MND to seek additional funds (public and private) necessary to finalize the design and begin construction of the P roject. CEQA requires environmental review before a project ’s approval, which is not necessarily its final approval , consistent with the definition of “approval” as occurring when the agency first exercises its discretion, not when the last discretionary decision is made. In acting now, the RBOC specifically seeks to avoid postponing environmental analysis until after bureaucratic and financial momentum b uild irresistibly behind the Project, and to complete CEQA e arly enough to allow for meaningful contribution to public decisions.

Therefore, the IS/MND contains sufficient information to inform the public about all elements of the Project—from design to construction and long -term operation—and to adequately analyze environmental impacts of Project implementation and define appropriate mitigation. Therefore, the P roject Description is adequate and stable and meets the requirements of CEQA. No revisions to the IS/MND are necessary.

2.1.2 Topical Response 2: Lighting

2.1.2.1 SUMMARY OF COMMENTS RECEIVED
Comments expressed concerns with potential lighting impacts from the Project. Current operational hours of the existing driving range and golf course are from sunrise to sunset, seven days a week. As stated on page 15 of the IS/MND, the proposed driving range and miniature golf course would be open to the public between 6:00 am and 10:00 pm , seven days a week. Lighting could be on from dusk until closing (not during daytime hours), with lighting levels dimmed significantly (i.e., reduced to 75 percent illum ination) to allow for limited cleaning/staff needs after closing. Comments assert that the proposed increase in hours of operation would result in excessive illumination on the Project Site that could potentially have a negative impact on residents and wildlife in the Arroyo Seco , and that there will be a permanent night glow resulting from the Project .

Comments further assert that the proposed lighting for the Project was not adequately analyzed and that the

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2. Response to Comments

mitigation measures provided in the IS/MND would not sufficiently mitigate potential lighting impacts of the Project.

Additionally, comments assert that with the implementation of new operational hours for the driving range and miniature golf course, Brookside Golf Course does not provide sufficient lighting to ensure pedestrian safety in areas surrounding the Project Site, including walkways and parking lots.

2.1.2.2 RESPONSE TO COMMENTS
As stated on page 9 of the IS/MND, a n estimated 14 of the 56 poles would be light -mounted (at 60 feet in height and, importantly, not at the tops of the poles) on the perimeter of the driving range on the east and west sides and directed at the driving range with leading -edge, light-emitting diode (LED) technology . A detailed analysis of t he proposed lighting is discussed beginning on page 26 of the IS/MND, and the analysis appropriately relies on the lighting threshold required by the City of Pasadena Zoning Code Section

17.40.080(a). As described in Section 3.1, Aesthetics , of the IS/MND, the Project would comply with Section

17.40.080, Outdoor Lighting, of the Pasadena Municipal Code. Section 17.40.080(a) states:

Lighting shall be energy -efficient, and shielded. Lighting shall be energy -efficient, and shielded or recessed so that direct g lare and reflections are confined to the maximum extent feasible within the boundaries of the site, and shall be directed downward and away from adjoining properties and public rights -of-way. No lighting on private property shall produce an illumination level greater than one foot-candle on any property within a residential zoning district except on the site of the light source.

The Project would have a significant impact on neighboring areas if the Project S ite lighting produces an illuminance greater tha n 1 foot -candle on any residential property. However, lighting assessments of a conceptual lighting layout for the driving range, the most substantial element of proposed lighting, indicate that the light loss spill factor would be 0.95, less than the 1 foot-candle threshold, at the property line. Although the proposed driving range poles would have an average pole height of 90.67 feet, lighting on the proposed poles would not be fixed at the top of the poles, but at approximately 60 feet in height. As detailed in the IS/MND, the lighting to be installed would be a leading -edge LED technology with wireless remote -control capability and directionality focused downward to the driving range. The lighting technology would include spill and glare control, high-definition, and precise light targeting capabilities , and all LED lighting would be individually adjustable to ensure proper direction and avoidance of light spill into surrounding neighborhoods.

Lighting on the Project Site, which as part of the existing g olf course would continue to be fenced in and actively used for recreational purposes thereby deterring wildlife movement in its current condition, would not further impact the movement of wildlife. The impact of the additional lighting during the limited hours from dusk until the lights are turned off is not expected to significantly impact birds or other wildlife that may occur in this high-use area any more than existing lighting in the activated Central Arroyo or from residential lighting in the adjacent neighborhoods. Additionally, implementation of Mitigation Measure BIO -2 would minimize potential indirect impacts to nesting birds that may utilize ornamental/landscape vegetation on- site and/or wildlife movement along the Arroyo Seco, by requiring nighttime lighting associated with the driving range and miniature golf course to be shielded downward to limit spillage.

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Additionally, with 1 foot-candle or less of lighting, t he Project would not result in a permanent glow in the Arroyo Seco. Currently, there is lighting throughout the Central Arroyo associated with the Rose Bowl Stadium, the Rose Bowl Loop, parking lots, the Rose Bowl Aquatic Center, numerous Jackie Robinson sports fields, and other uses. It is the most highly activated recreational area in Pasadena and is illuminated in its current condition.

There are a multitude of events that occur throughout the year at the Rose Bowl Stadium and Brookside Golf Course itself that include substantial event lighting. Additionally, though the driving range currently has no lighting, lighting was used on a nightly basis at the driving range from approximately 1968 to 1974. Lighting at the driving range is not a new concept but a return to prior condition s (only with a much more advanced- control lighting system as proposed). T he Project would continue golf activities that have occurred along the Arroyo Seco for decades, as shown in Attachment B; therefore, implementation of the proposed lighting at the driving range would not substantially differ from current (or historical) conditions on the Project Site.

Lighting for the Project would be screened from off-site residential receptors by the existing topography, mature vegetation, and the Brookside Clubhouse. The quantified lighting analysis in the IS/MND concludes that the proposed lighting would not exceed the established 1 foot- candle threshold. However, Mitigation Measure AES-1 is required to further ensure the requirements are met. The Brookside Golf Course has a land use and zoning designation of Open Space (OS); thus, the Project would comply with Section 17.40.070, Limited Hours of Operation, of the Pasadena Municipal Code, whic h allows limited hours of operation for specified land uses, including OS. Section 17.40.070(2) states:
…identified uses may only operate between the hours of 7:00 a.m. and 10:00 p.m. by right; and between the hours of 10:00 p.m. and 7:00 a.m. subject to the issuance of a Conditional Use Permit.

Therefore, implementation of the Project, including the proposed hours of operation of the driving range and lights until 10:00 p.m., would be consistent with the Pasadena Municipal Code.

With respect to public safety in the Project Site and the surrounding areas, Attachment C shows that walkways and parking lots leading to and from the existing driving range provide sufficient lighting to ensure the safe ty of visitors and staff that exit the Brookside Golf Course after sunset, in current conditions.

There were no specific comments attesting that the threshold employed, the lighting analysis conducted, or the mitigation measures are insufficient. The IS/MND provides a supported analysis of potential lighting impacts and appropriate mitigation. Therefore, the information provided regarding lighting, and the resulting impacts and mitigation, are appropriate and meet the requirements of CEQA. No further analy sis or changes to the IS/MND are necessary.

2.1.3 Topical Response 3: Tree Removal and Wildlife

2.1.3.1 SUMMARY OF COMMENTS RECEIVED
Comments expressed concerns with potential impacts to the trees and wildlife as a result of the Project.

Comments assert that the removal of several mature trees from the Project Site for the expansion of the driving range and implementation of the miniature golf course would be excessive and unnecessary, because it would

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negatively alter the natural landscape of the Central Arroyo Seco and p otentially result in negative effects to birds and other wildlife in the Arroyo Seco.

2.1.3.2 RESPONSE TO COMMENTS
Trees
As previously described, the IS/MND appropriately analyzes the maximum extent of physical impacts to the environment from Project implementation, including when evaluating the number of trees that could potentially be removed or relocated . As described in Section 3.4, Biological Resources , of the IS /MND, implementation of the Project could potentially require the removal of up to 47 trees from the Project Site.

Because these trees are on City-owned property, they fall under the City’s Trees and Tree Protection Ordinance (Title 8, Chapter 8.52), which defines a protected tree as a native, specimen, landmark, landmark-eligible, mature (except for the trees in RS or RM -12 Zones), or public tree. That does not imply that all trees to be removed are native trees.

The golf course area is not a wild and natural space, nor has it been for nearly 100 years. As stewards of the Brookside Golf Course and the over 1,400 trees that have been planted, relocated, or removed since 1967, the RBOC, as a matter of practice, works in close cooperation with the City’s Urban Forestry Advisory Committee (UFAC), and the City Manager, who has ultimate approval authority for removal of any trees, including those that display health and public safety concerns . The RBOC must and will continue in that management role , particularly to protect public safety regarding unsafe or dying trees, regardless of whether the Project is ultimately approved.

Upon further review by RBOC, it is estimated that the number of trees that could be removed or relocated (resulting from improvements to the driving range only , as the proposed miniature golf does not necessitate tree removals) may be reduced to 27 trees—25 pepper trees (nonnative), one ash tree (nonnative), and one pine tree (nonnative), as shown in A ttachment D. No native trees are anticipated to be removed. However, as discussed in the IS/MND, the final number of trees that would require removal or relocation is dependent on the final design of the Project and on consideration of the health and/or safety condition of the trees at that time.

Upon completion of the final Project design, all construction activities, includ ing potential removal of trees, will be analyzed i n accordance with the City’s Tree Ordinance, including the identification and protection of specimen trees within the P roject Site. Additionally, consistent with previous efforts at Brookside, RBOC is committed to replanting replacement trees for all trees removed, at appropriate ratios determined in consultation with UFAC, and at locations that ensure no implications to RBOC operations.

When the Project goes through the design development, as stated on page 48 of the IS/MND, the RBOC will ensure that tree removals are limited and that as many trees are retained as public safety and feasibility regarding Project design allow. Th e RBOC would coordina te with the City’s UFAC and Planning and Community Development Department, and all tree removals as well as construction activities in proximity to trees that would be retained would be required to follow the City’s Tree Protection Guidelines (City of Pasadena 2019).

Additionally, as described in the IS/MND, the Project would be required to go through the City’s Design Review

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process, which ensures the protection and retention of landmark, native, and specimen trees and other significant landscaping of aesthetic and environmental value to the extent feasible . Overall, compliance with the City’s Design Review process and Tree Ordinance, including preparation of the required Tree Protection Plan and identification of a tree replacement ratio , would ensure that impacts related to the protection of biological resources, such as a tree preservation policy or ordinance, would be less than significant.

Wildlife
Comments were received regarding effects to wildlife in the Arroyo Seco as a result of the Project, to birds that nest in the trees within the Project Site, and to animals that use the Central Arroyo Seco as a wildlife corridor.

The Arroyo-Seco Brookside wildlife corridor runs north-south adjacent to the Project Site and generally outside of the fenced and netted golf course that contains the Project site. As described in Section 3.4, Biological Resources, of the IS/MND, the miniature golf course and driving range would be adjacent to the Arroyo Seco channel , which provides connectivity to the Upper Arroyo/Hahamonga Watershed Park to the north of the Project Site.

This segment of the Arroyo Seco is concrete lined with no vegetation and does not support sensitive species.

The Project Site is in the Central Arroyo subarea, which is a highly activated and lands caped area used as a recreational resource. As discussed in Appendix C, Biological Resources Assessment , to the IS/MND, though databases identified species that were previously documented within or in close proximity to the survey area (most in the early - to mid -1900s), in the current state of the Project Site , suitable habitat is not present.

Therefore, s ince the Brookside Golf Course includes landscaped vegetation, developed land uses, and unvegetated concrete-lined channel, the Project Site is not considered a natural habitat. Implementation of the Project involves the continuation of the same golf uses that have occurred on the site for decades, as shown in Attachment B—there is no change in use.

The IS/MND describes that mature trees that occur on and adjacent to the Project Site, including within the surrounding area, provide foraging and breeding opportunities for common wildlife. Additionally, the Central Arroyo Seco, outside of the fenced golf course that contains the Project Site, could serve as a suitable corridor for native resident wildlife to move through the area , particularly small to medium mammals such as coyote, opossum, and raccoon, which may forage in the landscaped vegetation of the golf course during nighttime hours when it is close d. It is possible that larger mammals such as deer or mountain lion could pass through the Arroyo outside of the larger fenced area of the golf course . The landscaping and mature trees on and surrounding the Project Site could provide suitable nesting habitat for avian species protected under the Migratory Bird Treaty Act (MBTA), particularly during the nesting season that generally occurs from February through August.

The IS/MND acknowledges on page 46 that disturbing or destroying active nests is a violation of the MBTA (16 U.S.C. 703 et seq.) and that active nests and eggs are protected in accordance with Fish and Game Code Section 3503. However, as described in the IS /MND, avian species that could establish nests on the Project Site are species that would typically occur in urban environments and already occur on the golf course, and they would be accustomed to a high level of human presence and noise and light disturbance , consistent with the residentially developed areas surrounding the golf course . It is important to noted that the golf course and driving range have included safety netting for decades and there has not been an observed bird mortality due to the netting; therefore there is no reason to assume that birds would be affected by replacement of netting.

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The Project requires the implementation of Mitigation Measures MM-BIO-1, which would require a qualified biologist to conduct a nesting bird survey within 3 days prior to the proposed start date, to identify any active nests within 500 feet of the P roject Site, if any construction activities occur within the bird nesting seas on (generally defined as February 15 through September 15). If an active nest is found, the nest will be avoided, and a suitable buffer zone (300 feet for passerines and up to 500 feet for any raptor species) will be delineated in the field so that no impacts will occur until the chicks have fledged , as determined by a qualified biologist.

Additionally, implementation of Mitigation Measure MM-BIO-2 would require nighttime lighting associated with the driving range and miniature golf course to be shielded downward to limit spillage onto nesting birds that may utilize ornamental/landscape vegetation on-site and/or wildlife movement along the Arroyo Seco.

Therefore, impacts to wildlife in the P roject Site would be less than significant with mitigation incorpor ated.

The IS/MND adequately analyzes all impacts of the Project to wildlife, and no revisions are necessary.

2.1.4 Topical Response 4: Land Use and Planning

2.1.4.1 SUMMARY OF COMMENTS RECEIVED
Comments received expressed concerns regarding the Project’s consistency with the Arroyo Seco Master Plan and the Arroyo Seco Public Lands Ordinance. Comments assert that the IS/MND fails to consider the Project’s consistency with the Arroyo Seco Public Lands Ordinance, and the Project could potentially be in violation of this policy.

2.1.4.2 RESPONSE TO COMMENTS
Comments were received regarding P roject consistency with adopted land use plans , policies, or regulations, specifically the Arroyo Seco Master Plan or the Arroyo Seco Public Lands Ordinance. The Project consists of two main components within the approximately 16-acre Project Site: (1) reorient and expand the existing driving range toward the north; and (2) develop a new miniature golf course adjacent to the west of the proposed driving range. Consistent with Chapter 3.32, Arroyo Seco Public Lands, of the Pasadena Municipal Code, the golf uses, which would not change as a result of the Project, are permitted within the Brookside Golf Course (see Section 3.32.460, Brookside Golf Course Area–Permitted Uses). Comments on the IS/MND assert that the Project would be in violation of the Arroyo Seco Public Lands Ordinance because it would be considered a commercial use in the Arroyo Seco. However; Section 3.32.060(c) states:

No portion of lands within the Arroyo Seco shall be used for any commercial, industrial or institutional purposes other than those which existed at the effective date of the ordinance codified in this chapter.

The Brookside Golf Course has been in operation as a public golf course within the Arroyo Seco since 1928.

Implementation of the Project would not introduce new commercial establishments to the Project Site but would operate with recreational uses similar to what already exists on the Brookside Golf Course. Thus, the Project would not violate the Arroyo Seco Public Lands Ordinance. As discussed on page 86 of the IS/MND, Section 5.5, Recreational Courses and Ranges , of the Arroyo Seco Design Guidelines (2003) states that improvements to the recreational courses and ranges in the Arroyo Seco shall be made under the regulation

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and industry standard for the sport the course/range is serving; and improvements to recreational courses and ranges shall be of the highest quality craftsmanship and utilize the highest quality materials. In accordance with Section 17.61.030, Design Review, of the Pasadena Municipal Code, the Project would be subject to the City’s Design Review process to ensure that all components of the P roject reflect the values of the community, enhance the surrounding environment, and visually harmonize with the surroundings.

Additionally, Section 11.2, Lighting, of the Arroyo Seco Design Guidelines states that lighting shall consider surrounding residential areas and “ dark sky ” considerations and use appropriate shields; that athletic field lighting (new installations and renovations) should be reduced to minimize impacts to the surrounding ecosystem; that lighting improvements in the Central Arroyo subarea must consider the impact to slopes that serve as a wildlife corridor for the larger Arroyo Seco; that exterior lighting around built structures and the surrounding ecosystem must serve both safety and aesthetic purposes; and that lighting of structures of architectural or historical merit must be done by a design professional and reviewed by the Design Commission for aesthetic sensitivities, to protect from over-illumination, and to ensure that the architectural integrity of the structure is maintained. The proposed lights to be used in the driving range and miniature golf course would be consistent with this policy.

In addition, as described in Section 5.3, Cultural Resources , of the IS /MND, the Project would implement Mitigation Measure CUL -1 to ensure that the ultimate Projec t design (including lighting components) is executed to achieve a maximum level of compatibility with the Pasadena Arroyo Park and Recreational District, and would require the RBOC to retain a qualified historic preservation professional to ensure that alt erations to the driving range, design of the miniature golf course, and overall modifications to the Golf Course are compatible with the existing Brookside Golf Course landscape and the Pasadena Arroyo Park and Recreational District.

As describe above, im plementation of the Project would comply with the Arroyo Seco Master Plan and the Arroyo Seco Public Lands Ordinance. Revisions will be made to the IS/MND to demonstrate the Project’s consistency with these policies.

2.1.5 Topical Response 5: Noise

2.1.5.1 SUMMARY OF COMMENTS RECEIVED
Comments expressed concerns with potential noise impacts from the P roject. Comments assert that t he proposed hours of operation of the driving range and miniature golf course would result in a new visitors to the Brookside Golf Course, which would increase levels of noise in the existing golf course and surrounding residential areas. Several comments on the IS /MND raised concerns that the P roject would exceed noise thresholds or be inconsistent with the General Plan Noise Element and/or Pasadena Municipal Code.

2.1.5.2 RESPONSE TO COMMENTS
The noise analysis in Section 3. 13, Noise, of the IS/MND concludes that noise from implementation of the Project would not cause noise levels to exceed the standards in Chapter 9.36, Noise Restrictions Ordinance, of the Pasadena Municipal Code, which establishes acceptable ambient noise levels to regulate intrusive noises

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(i.e., stationary noise) within specific land use zones and provides procedures and criteria for measur ing the sound level of noise sources. Under Section s 9.36.040 and 9.36.050 of the Noise Ordinance, a noise level increase of 5 dBA over the existing or presumed ambient noise level at an adjacent property line is considered a violation, with adjustments made for steady audible tones, repeated impulsive noise, and noise occurring for limited time periods. The 5 dBA increase above ambient is applicable to City-regulated noise sources, and it is applicable any time of the day. The ambient noise is defined as the actual measured ambient noise level averaged over a period of 15 minutes, or Leq (L
25). To account for people’s increased tolerance for short-duration noise events, the City’s Noise Ordinance provides the following adjustments:
 A 5 dBA allowance for noise sources occurring for more than 5 minutes but less than 15 minutes in any 1-hour period (for a total of 10 dBA above the ambient),  A 10 dBA allowance (total of 15 dBA above the ambient) for noise sources occurring for 5 minutes or less in any 1-hour period,
 A 20 dBA allowance (total of 25 dBA above the ambient) for noise sources occurring for less than 1 minute in any 1-hour period.

These additional allowances for short-duration noise sources are applicable to noise sources occurring during daytime (6:00 am to 11:00 pm) periods only. The proposed driving range and miniature golf course would be open to the public between 6:00 am and 10:00 pm seven days a week . Therefore, the Project would comply with the allowable hours as stated in the City’s Noise Ordinance.

As discussed on page 89 of the IS/MND, ambient noise monitoring was conducted at four locations in April 2021 to determine noise levels at the nearest residential receptors . The primary noise source observed during measurements was roadway traffic. Secondary noises such as birds chirping and pedestrian activity also contributed to the overall noise environment. Short-Term Location 1 (ST-1) was on West Drive, south of Salvia Canyon Road, approximately 12 feet west of the nearest southbound travel lane centerline; Short- Term Location 2 (ST -2) was at the intersection of Parkview Avenue and Afton Street, overlooking the Brookside Golf Course; Short -Term Location 3 (ST -3) was on Rosemont Avenue, north of Rose Bowl Drive, and approximately 20 feet east of the nearest northbound travel lane centerline; and Short-Term Location 4 (ST-4) was on Rosemont Avenue, south of Rose Bowl Drive, approximately 25 feet east of the nearest northbound travel lane centerline.

Physical damage to human hearing begins at prolonged exposure to noise levels higher than 85 dBA. Exposure to high noise levels affects o ur entire system, with prolonged noise exposure in excess of 75 dBA increasing body tensions, and thereby affecting blood pressure, functions of the heart, and the nervous system. Extended periods of noise exposure above 90 dBA can result in permanent hearing damage. When the noise level reaches 120 dBA, a tickling sensation occurs in the human ear even with short -term exposure. This level of noise is called the threshold of feeling. As the sound reaches 140 dBA, the tickling sensation is replaced by the feeling of pain in the ear. This is called the threshold of pain. A sound level of 190 dBA will rupture the eardrum and permanently damage the inner ear.

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It was determined that construction noise associated with the driving range would be well under 85 dBA at 100 feet. As described on page 95 of the IS/MND, heavy equipment, such as a dozer or a loader, can have maximum, short- duration noise levels of up to 85 dBA at 50 feet. However, overall noise emissions vary considerably depending on the specific construction activity performed at any given moment. Since noise from construction equipment is intermittent and diminishes at a rate of at least 6 dBA per doubling of distance (conservatively ignoring other attenuation effects from air absorption, ground effects, and shielding effects), the average noise levels at noise -sensitive receptors could vary considerably, because mobile construction equipment would move around the site with different loads and power requirements. Thus, construction noise impacts of the would not be considered significant.

Additionally, as described on page 97 of the IS/MND, noise associated with operation of the Project would be similar to existing noise sources (e.g., voices, club to ball impact noise, and maintenance noise associated with the facilities), and the Project would not include any sound amplification. The nearest receptors to the site are single-family homes approximately 440 to 900 feet to the east and west, respectively, from the edge of the Project Site. At that d istance, noise levels from unamplified noise sources would substantially decrease and would not significantly increase noise levels above existing conditions. Implementation of the Project involves a continuation of the same golf uses that have occurred on the site for decades—there is no change in use. It is a golf project on an existing golf course.

The noise study conducted for the Project indicated that at that distance of the nearest sensitive receptors are located from the Project Site , noise levels f rom unamplified noise sources would substantially decrease and would not significantly increase noise levels above existing conditions. Additionally, construction and operation of the Project would not expose any sensitive receptors near the Project Site to potential health risks related to noise. Therefore, impacts from operation of the driving range and miniature golf course would not be significant to neighboring residents in the area, and no revisions to the IS/MND are necessary.

2.1.6 Topical Response 6: Recreation

2.1.6.1 SUMMARY OF COMMENTS RECEIVED
Comments expressed concerns with potential impacts to the Brookside Golf Course itself as a result of the Project. With alterations to Holes 6 and 7 of the E.O. Nay Course and Hole 10 of the C.W . Koiner Course, comments assert that the course may not retain its championship course of play.

2.1.6.2 RESPONSE TO COMMENTS
As described in Section 3.16, Recreation, of the IS/MND, expansion and reorientation of the driving range could potentially result in the shortening of Hole 6 and Hole 7 of the E.O. Nay Course, which is approximately 60 yards north of the existing driving range. Approximately 220 yards on the golf course could be removed from play. Staff intends to work with a golf course architect in an effort to keep a par 70 for the E.O. Nay Course to continue having a championship layout. There is a high probability that Hole 6 can remain a similar experience to present day. With the help of a golf course architect, staff feel there may be a way to comply with minimum distances for keeping Hole #7 a p ar 4. In addition, the Project would res ult in alterations to Hole 10 of the C.W. Koiner Course, but Hole 10 would maintain a similar distance and shape. The hole would be relocated

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approximately 20 yards to the north, altering the two holes of the E.O. Nay (Hole 6 and Hole 7). The existing golf courses, with the exception of Hole 10 of the C.W. Koiner Course, and Hole 6 and Hole 7 of the E.O.

Nay Course, would remain unchanged by the Project.

As described in Section 1.5.1, Project Purpose, the expansion of the driving range is necessary because there is currently an inadequate number of driving range stalls (fewer stalls than holes), and on most days there is a line to use the driving range. Additionally, the implementation of the new miniature golf course is necessary because miniature golf would enable the golf course to further engage the youth and community that already live, recreate, and visit the Central Arroyo Seco area for recreational purposes. Based on a market study of the surrounding areas and other facilities in the area, it is antic ipated that the miniature golf component of the Project would help further the engagement of youth and families into the game, the same way that the First Tee of Greater Pasadena has over the past decade.

Therefore, implementation of the Project would not negatively impact the existing use of either the C.W. Koiner Course or the E.O. Nay Course, and the Brookside Golf Course would continue to have a championship layout while improving the pace of play. No revisions to the IS/MND are necessary.

2.1.7 Topical Response 7: Transportation and Parking

2.1.7.1 SUMMARY OF COMMENTS RECEIVED
Comments expressed concerns with potential traffic and parking impacts from the Project, including potential impacts on local traffic circulation, the lack of parking for the Brookside Golf Course, and whether there is a need for additional parking to accommodate new visitors to the Project Site.

2.1.7.2 RESPONSE TO COMMENTS
Traffic
The IS/MND includes a Transportation Impact Analysis (TIA) that was prepared for the Project (Appendix F), consistent with the City’s requirements for addressing transportation- related impacts under CEQA.

Intersection turning data and volumes provided in the City -prepared TIA are sufficient for inclusion in the IS/MND, as impacts to intersections and roadways are not considered impacts under CEQA. In November 2014, Pasadena’s City Council adopted new transportation review guidelines, metrics, and CEQA thresholds of significance that were designed to align with Senate Bill (SB) 743. The resolution adopted by Pasadena City Council replaced the City’s two existing transportation CEQA thresholds of significance (intersection LOS and Street Segment analysis) that focused entirely on automobile travel, with five new transportation CEQA thresholds of significance that include measures of automobile, transit, bicycle, and pedestrian travel. The five adopted transportation CEQA thresholds of significance are, (1) Vehicle Miles Traveled (VMT) per Capita, (2) Vehicle Trips (VT) per Capita, (3) Proximity and Quality of Bike Facilities, (4) Proximity and Quality of Transit Facilities; and (5) Pedestrian Accessibility
The existing uses in the Project Site currently generate approximately 136 daily vehicle trips, and it is estimated that implementation of the P roject would generate approximately 539 daily vehicle trips; therefore,

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implementation of the Project would result in 403 net new daily vehicle trips. The TIA appropriately assumes that no additional staffing would be required by the Project (see page 15 of the IS/MND).

The Pasadena Department of Transportation (DOT) uses mobility performance measures to assess the quality of walking, biking, transit, and vehicular travel in the c ity. As described on page 106 of the IS/MND, the Pasadena DOT determined that the Project would not have a significant impact on the surrounding circulation system and would not conflict with the Mobility Element policies pertaining to the circulation system.

Additionally, as described on page 60 of the IS/MND, though implementation of the Project would result in an increase in trips to the Project S ite, the increase in capacity of the driving range and new miniature golf course would serve the local population as well as pent up demand from users lining up on site to wait for hitting bays to open. Serving the local community could contribute to reducing VMT by providing the local community with closer options. Therefore, potential impacts to traffic circulation were determined to be less than significant, as described in Section 3.17, Transportation, of the IS/MND.

Parking
Several comments were received on the IS /MND regarding the Project’s impact on parking in the areas surrounding the Brookside Golf Course, and the potential need for additional parking for the P roject. It is anticipated that the general hours of use for the new range and miniature golf course would occur primarily during the evenings and would not typically overlap with other uses on the golf course. Since golfers commonly finish their rounds before sunset, parking lots are not anticipated to be filled in the evenings. Staff are discussing potential options for additional parking in lots CH, B and D when the miniature golf course and driving range are implemented. There is existing pave d areas that are not currently being used for parking in Lot D. In addition, these three parking lots are currently separated which leaves voided space with curbs, mulch and fencing instead of additional parking stalls.

As described in Section 1.5, Description of Project, of the IS/MND, the primary serving parking lots (CH and D) closest to the Brookside Clubhouse and the driving range, contain sufficient parking to accommodate the existing capacity of the golf course . Parking l ot CH contains approximately 66 space s, and parking lot D contains approximately 310 spaces for a total of 376 spaces. Additional short-term parking is along Rosemont Avenue for visitors who would typically visit the driving range and miniature golf course for short periods of time. The IS/MND determined that additional parking would not be necessary because visitors would not exceed the existing capacity of the golf course, and sufficient existing parking is available to meet the needs of the Project. However, if additional parking is needed, parking lot D can be expanded to add approximately 50 new parking spaces on the western portion of the parking lot, as shown in Attachment E. Additionally, parking lot B, which is directly south of parking lot D, would be available to all visitors of the Brookside Golf Course, including the driving range and miniature golf course (see Attachment E). As shown in Table 3, Brookside Golf Course Parking Lots, the paved parking lots surrounding the Project S ite contain a total of 646 parking spaces within walking distance of the driving range and miniature golf course . Additional lots and street parking are located throughout the Central Arroyo area. Although some of these walking distances may take more than a couple of minutes, this is not an environmental effect but rather an issue of convenience. The RBOC is aware of this comment and can consider it during its business operations planning.

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Table 3 Brookside Golf Course Parking Lots
Parking Lot Spaces
CH 66
B 220
D 360 (including the additional 50 spaces)
Total 646
As described in Topical Response 2, comments were received regarding public safety in the Project Site and the surrounding areas due to the extended hours of operation of the driving range and the miniature golf course, which would operate from 6:00 am to 10:00 pm, seven days a week. Comments assert that the Project Site does not contain sufficient lighting for visitors exiting the Brookside Golf Course after sunset. However, as shown in Attachment C, walkways and parking lots leading to and from the existing driving range provide sufficient lighting to ensure the safety of visitors and staff, and would continue to operate similar to existing conditions with the implementation of the Project.

Therefore, operation of the Project would not result in increased traffic in areas surrounding the Project Site.

No changes to the existing circulation system, including the Rose Bowl Recreational Loop or equestrian trails, would occur, and implementation of the Project would not impede the City’s policies with respect to mobility.

Additionally, during operation of the Project, the Project Site would be accessed via existing adjacent parking lots and Brookside Golf Course pathways , similar to existing condi tions. As demonstrated above, existing parking lots surrounding the Project Site and parking along Rosemont would provide sufficient parking spaces for existing and future uses of the Brookside Golf and all components of the Project. No revisions to the IS/MND are necessary.

2.1.8 Topical Response 8: Project Alternatives

2.1.8.1 SUMMARY OF COMMENTS RECEIVED
Comments expressed interest in potential alternatives to the Project, including alternate designs of the driving range and alternate locations of the miniature golf course.

2.1.8.2 RESPONSE TO COMMENTS
Alternate Design
Several comments were received regarding alternate designs of the Project, including the implementation of a two-story driving range , which would reduce the expanded size of the proposed driving range. In a ddition, comments asserted that an alternate location should be considered for the miniature golf course. Although Project alternatives are not required to be analyzed in an IS/MND under CEQA, the RBOC considered several other design and location scenarios for the Project during the process and determined that the Project presented in the IS/MND is the most feasible and logical option, compatible with operational needs of the Brookside Golf Course and the RBOC’s economic need to support and grow the game of golf and as it relates to the Rose Bowl Stadium.

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Although implementation of a new two-story driving range could potentially reduce the anticipated footprint of the proposed driving range, construction of a two-story driving range would increase environmental impacts to the Project Site and the Arroyo Seco with respect to aesthetics, biological resources, historical resources, noise, traffic, and other environmental topics. The addition of a second level to the proposed driving range would require netting heights and lighting to be raised by a minimum of 20 feet from the proposed Project lighting, which c ould negatively affect views from the Brookside Clubhouse and potentially result in light spillage into neighboring residences that would not be in compliance with the City of Pasadena’s Municipal Code.

A two-story driving range would also result in additional impacts to the Project Site, including restrictions to Americans with Disabil ities Act (ADA) access and emergency access issues for events at the Rose Bowl Stadium, including UCLA football games, other sporting events, concerts, and music festivals. Additionally, a two-story driving range would only include approximately 40 bays in stead of the proposed 60 bays of the Project, which would not meet the Project’s objectives to increase memberships and return to historical (higher) levels of use by expanding services to attract a broader range of visitors , including families, and improve the pace of play on the driving range.

This is not an alternative scenario that RBOC is considering, nor would it reduce environmental impacts.

Alternate Location
Additionally, implementation of the miniature golf course in an alternate location (such as near Kidspace) could result in additional environmental impacts or land use incompatibility in the Arroyo Seco. As described on page 10 of the IS/MND, t he location of the miniature golf course is designed to minimize impac ts to the remainder of the Brookside Golf Course and to maintain proximity to the Brookside Clubhouse and parking areas, which would not be possible in other locations of the Brookside Golf Course or the Arroyo Seco.

As described on page 6 of the IS/MND, the addition of miniature golf would enable the golf course to further engage the youth and community that already live, recreate, and visit the Central Arroyo Seco area for recreational purposes. Based on a market study of the surrounding areas and other facilities in the area, it is anticipated that the miniature golf component of the Project will help further the engagement of youth and families with the game, the same way that the First Tee of Greater Pasadena has over the past decade. Finally, the mini ature golf course is intended to complement and strengthen existing and highly successful youth programs (such as First Tee) that already exist on the golf course —that connection would be lost if it were moved to Kidspace. This is not an alternative scenar io that RBOC is considering, nor would it reduce environmental impacts.

Though other concepts were explored by RBOC during this process, the Project as proposed is what is being recommended for approval to the RBOC board. Additionally, as documented throughout the IS/MND and in this document, an MND is the appropriate level of CEQA review.

The purpose of an alternative analysis is to look at ways to avoid or reduce the significant environmental impacts of a proposed project. An IS/MND is only prepared for projects that are demonstrated not to have any significant environmental impacts, or where mitigation can be adopted to reduce all significant impacts to a

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less-than-significant level. Therefore, because projects supported by MNDs have been determined to have no significant environmental impacts, no analysis of alternatives is required in these documents. Therefore , no evaluation of alternatives is required.

2.2 RESPONSES TO WRITTEN AND VERBAL COMMENTS
Individual written and verbal comments on the IS/MND received during the public review period are addressed in this section. During that time, the RBOC received 7 comment letters from a local organization, 34 comment letters from individual residents, and several verbal comments provided at the community meeting on February 13, 2023. Several comments received on the IS /MND focused on several main issues and topics associated with the Project and the CEQA analysis of Project impacts, including lighting, tree removal, noise, recreation, traffic and parking. As described in Section 2.1, Topical Responses to Comments, the RBOC determined it would be appropriate to provide topical responses to address these comments and provide the necessary context for considering the issues raised. All other comments are addressed below.

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2.2.1 Responses to Written Comments

COMMENT R1- Lawrence Deady (1 page)

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R1. Response to Comments from Lawrence Deady, submitted via email January 31, 2023.

R1-1 This comment states that parking at the Brookside Golf Course is limited on specific days, and recommends the use of one hour parking signs. Please see Topical Response 7, Transportation and Parking , which describes that IS/MND accurately assesses impacts related to transportation consistent with the CEQA Guidelines and the City’s adopted methodology, and also addresses comments received regarding parking. The one hour parking is setup for the restaurant users in mind. The same could be said for the two-hour parking on Rosemont Avenue outside of the Brookside Clubhouse. Changing the signage would not create additional parking spaces. Staff can certainly revisit how the parking areas are setup. At this time, it is provides-limited spaces provide short time users a needed quicker in and out experience, and those choosing to spending many hours a more expansive selection. Additionally, a game of golf takes approximately 5 hours, and mini golf or driving range uses are estimated to take at least an hour, if not more). Removing short-term parking could contribute to traffic circulation impacts, and is therefore not under consideration as potential mitigation.

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COMMENT R2 - John Landis (2 pages)

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R2. Response to Comments from John Landis, submitted via email February 13, 2023.

R2-1 This comment states that IS/MND does not provide the costs, expenditures, and revenues of the Project and requests to see the revenue projections for the Project. The comment’s recommendation of providing of revenue projections will be provided to the RBOC for its consideration as part of its decision-making for this Project. However, this comment is not a direct comment on the content or adequacy of the IS/MND and does not raise a specific environmental issue. As directed by Section 15131(a) of the CEQA Guidelines, economic or social effects of a project shall not be treated as significant effects on the environment. Therefore, no further response is required.

R2-2 This comment states that the traffic and parking study is vague and expresses concern regarding additional parking requirements in the areas surrounding the Brookside Golf Course. Please see Topical Response 7, Transportation and Parking , which describes that IS/MND accurately assesses impacts related to transportation consistent with the CEQA Guidelines and the City’s adopted methodology, and also addresses comments received regarding parking demand.

It should also be noted that when the golf course hosts large golf tournaments there are actually less golfers per day and less vehicles. Even with outside catered events (weddings, reunions, etc.) parking demand rarely exceeds capacity . The exception would be the monthly flea market where parking is limited based on that vendor using half of lot D.

As described in Topical Response 7, Transportation and Traffic, parking lots CH, B and D, which would contain approximately 646 parking spaces combined, would have sufficient space to accommodate all event participants in addition to visitors of the miniature golf course and driving range.

R2-3 This comment states that the Project would decrease the use and desirability of the golf course. Please see Topical Response 6, Recreation, regarding potential impacts to the existing golf course.

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COMMENT - R3 John Landis (1 page)

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R3. Response to Comments from John Landis, submitted via email February 13, 2023.

R3-1 This comment states that the transportation impact assessment for prepared for the Project provided unclear and/or insufficient information regarding the Project’s potential impacts on traffic. Although portions of the data used in the TIA are from 2011 and 2012, existing conditions within the Project Site and areas surrounding the Brookside Golf Course have not changed substantially since then; thus, the data is still applicable.

Additionally, the TIA appropriately assumes that no additional staffing would be required by the Project (see page 15 of the IS/MND); therefore, implementation of the Project would not result in additional traffic impacts. Please see Topical Response 7, Transportation and Parking , which describes that IS/MND accurately assesses imp acts related to transportation consistent with the CEQA Guidelines and the City’s adopted methodology, and also addresses comments received regarding parking.

R3-2 This commenter states that they are unclear how the number of employees and service population for the Project would not increase. As stated on page 15 of the IS/MND, the Project does not propose any changes to the types and frequency of events that currently occur on the Brookside Golf Course; the golf course and the clubhouse is currently served by approximately 100 employees, and operation of the Project would not require additional employees. The Brookside Golf Course currently employs sufficient staff to operate and maintain the proposed components of the Project because operation and maintenance of the miniature golf can be worked into the responsibilities of existing employees, approximately 90 percent of which is part- time staff whose hours can be modified/expanded; as such, the proposed driving range and miniature golf course would not result in an increase of staff. Therefore, no revisions to the IS/MND are necessary and transportation impacts are adequately addressed.

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COMMENT R4 - Andrea Bland (1 page)

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R4. Response to Comments from Andrea Bland, submitted via comment card February 13, 2023. (1 page)
R4-1 This comment states that the Project’s lighting would have negative effects on the natural views in the Arroyo Seco. Please see Topical Response 2 , Lighting, regarding the City’s lighting regulations and how the Project complies with all policies regarding lighting, and requires additional mitigation measures to ensure impacts associated with lighting would be less -than-significant. Additionally, as described in Section 3.1, Aesthetics, of the IS/MND, viewer sensitivity is considered high when views are provided that are commonly held as an important component of the recreational experience, which in this case would include views of the Rose Bowl Stadium, the canyon-like setting of the Arroyo Seco, and views of the surrounding hillsides with residential uses are considered an important part of the aesthetic backdrop.

The proposed driving range would include 56 total poles, including 20 existing poles to remain and 36 new poles to be installed. The poles would support new netting and have a pole height ranging from 38 feet to 130 feet above ground level (increasing height with distance from the hitting bays) with an average pole height of 90.67 feet. An estimated 14 of the 56 poles would be light-mounted (at 60 feet in height) surrounding the perimeter of the driving range on the east and west sides.

However, each pole would be constructed with sufficient spacing throughout the perimeter of the proposed driving range similar to existing poles, and the new netting would be nearly transparent similar to existing netting. The driving range would not block or interfere with the existing views of the surrounding areas, including the San Gabriel Mountains, the Rose Bowl Stadium, or other scenic features located within the Pasadena Arroyo Seco Parks and Recreation District. Finally, given the elevation of the proposed project (well below the ridge where private homes are located), lighting in this location will not impact sunset views from those private homes as they will look out well over the top of the project site, nor will it impact sunset views from the Arroyo as those views are obscured by the rims of the Arroyo. Therefore, no revisions to the IS/MND are necessary and potential impacts to scenic views are adequately addressed.

R4-2 This comment states that the Project will result in an increase of noise in the areas surrounding the Project Site. Please see Topical Response 5 , Noise, regarding the City’s noise regulations and how the Project complies with all policies regarding noise to ensure impacts associated with noise would be less-than-significant.

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COMMENT R5 - Megan Foke (1 page)

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R5. Response to Comments from Megan Foke, submitted via comment card February 13, 2023.

R5-1 This comment expresses concern regarding the number of trees that may be removed as a result of the Project. Please see Topical Response 3, Tree Removal and Wildlife, regarding the procedures that would be taken by the RBOC to minimize potential impacts to trees within the Project Site. Please also see historical photos of the golf courses, showing that the Central Arroyo has, throughout its entire history, been considered and managed as a recreational area and not a natural forest. (see Attachment B, Historic Photographs of Brookside Golf Course)

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COMMENT R6 - Brian Elerding (1 page)

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R6. Response to Comments from Brian Elerding, submitted via email February 14, 2023.

R6-1 This comment expresses the commenter’s opposition to the Project, due to potential impacts on wildlife, increased lighting, and the removal of trees in the Project Site. Please see Topical Response 3, Tree Removal and Wildlife, regarding the procedures that would be taken by the RBOC to minimize potential impacts to trees and wildlife within the Project Site. Additionally, please see Topical Res ponse 2, Lighting , regarding the City’s lighting regulations and how the Project complies with all policies regarding lighting, and requires additional mitigation measures to ensure impacts associated with lighting would be less - than-significant.

R6-2 This comment states that more should be done to preserve the wildlife corridor within the Arroyo Seco. Please see Topical Response 3, Tree Removal and Wildlife , regarding the procedures that would be taken by the RBOC to minimize potential impacts to trees and wildlife within the Project Site. Please also see historical photos of the golf courses, showing that the Central Arroyo has, throughout its entire history, been considered and managed as a recreational area and not a natural forest

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COMMENT R7 - John Callas (1 page)

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R7. Response to Comments from John Callas, submitted via email February 14, 2023.

R7-1 This comment expresses the commenter’s opposition to the proposed expansion of the driving range and implementation of the miniature golf course because the Project would result in the removal of trees in the Project Site and would require the addition of new lighting.

The comment provides no specific issue regarding the detailed technical analyses contained within the IS/MND regarding these topics. Please see Topical Response 3, Tree Removal and Wildlife, regarding the regarding procedures that would be ta ken by the RBOC to minimize potential impacts to trees within the Project Site; and Topical Response 2, Lighting , regarding the City’s lighting regulations and how the Project complies with all policies regarding lighting, and requires additional mitigation measures to ensure impacts associated with lighting would be less-than-significant. Please also see historical photos of the golf courses, showing that the Central Arroyo has, throughout its entire history, been considered and managed as a recreational area and not a natural forest (see Attachment B, Historic Photographs of Brookside Golf Course).

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COMMENT R8 - Mary Bucci Bush (1 page)

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R8. Response to Comments from Mary Bucci Bush, submitted via email February 14, 2023.

R8-1 This comment expresses support for the Project if no negative impacts related to noise and lighting result from the implementation of the project. The comment provides no specific issue regarding the detailed technical analyses contained within the IS/MND regarding these topics. Please see Topical Response 2, Lighting , and Topical Response 5, Noise, regarding the City’s lighting and noise regulations and how the Project complies with all policies regarding noise and lighting, and requires additional mitigation measures to ensure impacts associated with lighting would be less-than-significant.

R8-2 This comment states the commenter’s opposition to the construction of the miniature golf course within the Project Site or anywhere in the Arroyo Seco, due to excessive lighting and potential impacts to the wildlife and the natural landscape of the Arroyo Seco.

Please see Topical Response 3, Tree Removal and Wildlife , regarding the procedures that would be taken by the RBOC to minimize potential impacts to trees and wildlife within the Project Site. Additionally, please see Topical Response 2, Lighting, regarding the City’s lighting regulations and how the Project complies with all policies regarding lighting, and requires additional mitigation measures to ensure impacts associated with lighting would be less-than-significant.

In addition this recommends an alternate location for the proposed miniature golf course, near the Rose Bowl children’s playground. Please see Topical Response 8, Project Alternatives.

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COMMENT R9 - Petrea Burchard (1 page)

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R9. Response to Comments from Petrea Burchard, submitted via email February 14, 2023.

R9-1 This comment states that they are opposed to the implementation of the Project because of the removal of trees and increase in lighting in the Project Site. Additionally, the comment states that the Project would be illegal because it would not be in compl iance with the Arroyo Seco Master Plan or the Arroyo Seco Public Lands Ordinance. Please see Topical Response 3, Tree Removal and Wildlife, regarding the procedures that would be taken by the RBOC to minimize potential impacts to trees and wildlife within the Project Site; and Topical Response 2, Lighting , regarding the City’s lighting regulations and how the Project complies with all policies regarding lighting, and requires additional mitigation measures to ensure impacts associated with lighting would be less-than-significant.

Additionally, please see Topical Response 4, Land Use and Planning , regarding how implementation of the Project would comply with the Arroyo Seco Master Plan and the Arroyo Seco Public Lands Ordinance. It should also be noted that no trees would be impacted as a result of the development of miniature golf. All tree impacts are related to the driving range improvements, as shown in Attachment D, Potential Locations of Trees to be Removed.

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COMMENT R10 - William Morris (1 page)

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R10. Response to Comments from William Morris, submitted via email February 14, 2023.

R10-1 This comment states that the E.O. Nay course should remain as a Par 70, and alterations to hole 10 should not damage the course. Please see Topical Response 6, Recreation, regarding the procedures that would be taken by the RBOC to minimize potential impacts to the recreational facilities in the Project Site, including potential impacts to the E.O. Nay course to ensure impacts associated with recreational facilities would be less -than- significant.

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COMMENT R11 - William Morris (1 page)

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R11. Response to Comments from William Morris, submitted via email February 15, 2023.

R11-1 This comment provided recommendations and examples for the types of miniature golf course that could be implemen ted for the Project. The comment provides no specific issue regarding the detailed technical analyses contained within the IS/MND regarding these topics. Th is comment’s recommendation will be provided to the RBOC for its consideration as part of its decision-making for this Project. This comment is not a direct comment on the content or adequacy of the IS/MND and does not raise a specific environmental issue; therefore, no further response is required.

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COMMENT R12 - Vicki Livingstone (1 page)

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R12. Response to Comments from Vicki Livingstone, submitted via email February 15, 2023.

R12-1 This comment expresses opposition to the miniature golf course because of the removal of trees within the Project Site. They reference commentary provided by Tim Brick of the Arroyo Seco Foundation – please see response to comments O7-4 and O10-1. Please see Topical Response 3, Tree Removal and Wildlife, regarding the procedures that would be taken by the RBOC to minimize potential impacts to trees within the Project Site .

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COMMENT R13 - Susan Whichard (2 pages)

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R13. Response to Comments from Susan Whichard, submitted via email February 16, 2023.

R13-1 This comment states that the commenter does not believe the expansion of the driving range and implementation of the miniature golf course is a functional or safe Project.

The commenter’s statements will be provided to the RBOC for its consideration as part of its decision-making for this project. However, this comment is not a direct comment on the content or adequacy of the IS/MND and does not raise a specific environmental issue; therefore, no further response is required.

R13-2 This comment states that the alterations to the E.O. Nay and C.W . Koiner course would reduce the championship status of the Brookside Golf Course, and would cause more backup on the existing courses. Please see Topical Response 6, Recreation , which demonstrates how implementation of the Project would not negatively impact the existing use of either the C.W . Koiner Course or the E.O. Nay Course, and the Brookside Golf Course would continue to have a championship layout while improving the pace of play.

R13-3 This comment states that the Project would impact the First Tee teaching area, the Brookside instructor’s area, and the short game area. The commenter’s statements will be provided to the RBOC for its consideration as part of its decision-making for this Project.

This comment is not a direct comment on the content or adequacy of the IS/MND and does not raise a specific environmental issue; therefore, no further response is required.

R13-4 This comment expresses concern for the safety of families and children that would visit the proposed miniature golf course, due to the swinging golf clubs at the driving range, walking distance from the parking lot, and proximity to Arroyo Seco channel, which would create the western boundary of the Project Site. The existing Project Site is currently fenced along the Arroyo Seco channel, and implementation of the Project would continue to include fencing along the perimeter of the Project Site, including around the miniature golf course. The existing Brookside Golf Course is currently open to families and children that participate in programs such as First Tee – Greater Pasadena. Although the implementation of the miniature golf course would incr ease the number of visitors, additional safety impacts to families and children would not be anticipated.

With respect to public safety in the Project Site and the surrounding areas, Attachment C, Existing Light at Brookside Golf Course, shows that walkways and parking lots leading to and from the existing driving range provide sufficient lighting to ensure the safety of visitors and staff that exit the Brookside Golf Course after sunset, in current conditions.

Additionally, please see Topical Response 2, Lighting, which describes that IS/MND accurately assesses impacts related lighting and pedestrian safety wi thin the Project Site and the parking lot areas

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R13-5 This comment expresses concerns regarding financial analysis for the Project. The commenter’s statements will be provided to the RBOC for its consideration as part of its decision-making for this project. This comment is not a direct comment on the content or adequacy of the IS/MND and does not raise a specific environmental issue. As directed by Section 15131(a) of the CEQA Guidelines, economic or social effects of a project shall not be treated as si gnificant effects on the environment. Therefore, no further response is required. Additionally, the commenter states that there is a possibility for increased noise that would disrupt residents surrounding the Project Site and golfers within the Brookside Golf Course. Please see Topical Response 5, Noise, regarding the City’s noise regulations and how the Project complies with all policies regarding noise to ensure impacts associated with noise would be less-than-significant.

R13-6 This comment expresses th e commenter’s concern with staffing and maintenance costs of the Project. The Brookside Golf Course currently employs sufficient staff to operate and maintain the proposed components of the Project; as such, the proposed driving range and miniature golf course would not result in an increase of staff. The commenter’s statements regarding labor costs will be provided to the RBOC for its consideration as part of its decision-making for this project. This comment is not a direct comment on the content or adequacy of the IS/MND and does not raise a specific environmental issue.

As directed by Section 15131(a) of the CEQA Guidelines, economic or social effects of a project shall not be treated as significant effects on the environment. Therefore, no further response is required. .

R13-7 This comment states the commenter’s concern with parking impacts that would result from the Project. Please see Topical Response 7, Transportation and Parking, which describes that IS/MND accurately assesses impacts related to tra nsportation consistent with the CEQA Guidelines and the City’s adopted methodology, and also addresses comments received regarding parking, and ensure pedestrian safety within the Project Site and the parking lot areas. The commenter’s statements will be provided to the RBOC for its consideration as part of its decision-making for this project.

R13-8 This comment discusses the potential loss of revenue due to the double shotgun tournament. The commenter’s statements will be provided to the RBOC for its consideration as part of its decision-making for this project. This comment is not a direct comment on the content or adequacy of the IS/MND and does not raise a specific environmental issue. As directed by Section 15131(a) of the CEQA Guidelines, economic or social effects of a project shall not be treated as significant effects on the environment.

Therefore, no further response is required.

R13-9 This comment also expresses concern for the safety of children that would visit the proposed miniature golf course, due golf carts on the golf course. The existing Brookside Golf Course is currently open to families and children that participate in programs such as First Tee – Greater Pasadena, and safety risks to young golfers have not been an issue

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over the life of the program. Although the implementation of the miniature golf course would increase the number of visitors, additional safety impacts to families and children are not anticipated, particularly given the distance separation between the mini golf area and anywhere that golf carts may be driven.

The comment provides no specific issue regarding the detailed technical analyses contained within the IS/MND regarding these topics. The commenter’s statement will be provided to the RBOC for its consideration as part of its decision-making for this Project.

This comment is not a direct comment on the content or adequacy of the IS/MND and does not raise a specific environmental issue; therefore, no further response is required.

R13-10 This comment states that the RBOC should consider the implementation of a multi-tier driving range and an alternate location for the proposed miniature golf course, near the Rose Bowl children’s playground. Please see Topical Response 8, Project Alternatives, regarding the alternatives and how the IS/MND is sufficient in not evaluating environmental impacts of other alternatives. With respect to the alternative suggested, it would result in environmental impacts beyond those associated with the Project and created emergency access issues with the site.

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COMMENT R14 - Jill Sigler (1 page)

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R14. Response to Comments from Jill Sigler, submitted via email February 16, 2023.

R14-1 This comment opposes the implementation of the miniature golf course because of the removal of trees within the Project Site. Please see Topical Response 3, Tree Removal and Wildlife, regarding the procedures that would be taken by the RBOC to minimize potential impacts to trees within the Project Site. It should also be noted that no trees would be removed due to development of the miniature golf. It should also be noted that no trees would be removed due to the miniature golf project. All tree impacts are related to the driving range improvements, as shown in Attachment D, Potential Locations of Trees to be Removed.

R14-2 This comment states that the Project would increase traffic in areas surround the Project Site. Please see Topical Response 7, Transportation and Parking , which describes that IS/MND accurately assesses impacts related to transportation consistent with the CEQA Guidelines and the City’s adopted methodology.

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COMMENT R15 - Patricia Crook (1 page)

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R15. Response to Comments from Patricia Crook, submitted via email February 18, 2023.

R15-1 This comment expresses the commenter’s opposition to the removal of trees for the construction of the Project. Please see Topical Response 3, Tree Removal and Wildlife , regarding the procedures that would be taken by the RBOC to minimize potential impacts to trees within the Project Site. Additionally, the comment expresses opposition to the implementation of the miniature golf course. The comment provides no specific issue regarding the detailed technical analyses contained within the IS/MND regarding thes e topics. The commenter’s recommendation regarding opposition to the miniature golf course will be provided to the RBOC for its consideration as part of its decision-making for this Project. It should also be noted that no trees would be removed due to development of the miniature golf project. However, this comment is not a direct comment on the content or adequacy of the IS/MND and does not raise a specific environmental issue; therefore, no further response is required.

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COMMENT R16 - James Treidler (10 pages)

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R16. Response to Comments from James Treidler, submitted via email February 18, 2023.

R16-1 This comment states that the distance to the parking lot from the proposed miniature golf site is too far, and would also result in insufficient parking within the existing lots. Please see Topical Response 7, Transportation and Parking , which describes th at IS/MND accurately assesses impacts related to transportation consistent with the CEQA Guidelines and the City’s adopted methodology, and also addresses comments received regarding parking. The commenter also states the components of the Project would be unattractive and the design of the Project does not include any additional amenities. As stated throughout the IS/MND, the RBOC would ensure that the design of the expanded and reoriented driving range and miniature golf course are compatible with existin g design elements of the Brookside Golf Course Complex and are sensitive to the location within the Historic District, the Arroyo Seco, and the adjacent Rose Bowl. Additionally, the Project would be subject to the City’s Design Review process as defined in the Pasadena Municipal Code. The commenter’s recommendation regarding opposition to the miniature golf course will be provided to the RBOC for its consideration as part of its decision-making for this Project. However, this comment is not a direct comment on the content or adequacy of the IS/MND and does not raise a specific environmental issue; therefore, no further response is required.

R16-2 This comment provides an alternative location for the miniature golf course, near parking lot K. Please see Topical Response 8, Project Alternatives, regarding the alternatives and how the IS/MND is sufficient in not evaluating environmental impacts of other alternatives.

It should also be noted that Lot K is contractually obligated to UCLA and the Tournament of Roses; therefore, alterations or removal of parking spaces is not feasible.

R16-3 This comment states that the project would have negative impact to the E.O. Nay course.

Please see Topical Response 6, Recreation, which demonstrates how implementation of the Project would not negatively impact the existing use of either the C.W . Koiner Course or the E.O. Nay Course, and the Brookside Golf Course would continue to have a championship layout while improving the pace of play. Additionally, the comment states that the Project would require extensive and unnecessary removal of trees within the Project Site, and the proposed lighting for the driving range would not be compatible with the historic use of the Arroyo Seco. Please see Topical Response 3, Tree Removal and Wildlife, regarding the procedures that would be taken by the RBOC to minimize potential impacts to trees within the Project Site ; and Topical Response 2, Lighting , regarding the City’s lighting regulations and how the Project complies with all policies regarding lighting, and requires additional mitigation measures to ensure impacts associated with lighting would be less-than-significant.

R16-4 This comment provides alternative design for the proposed driving range, including expansion of the Project Site boundaries, and implementation of a two -story driving range. Please see Topical Response 8, Project Alternatives, regarding the alternatives and how

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the IS/MND is sufficient in not evaluating environmental impacts of other alternatives.

With respect to the alternative suggested, it would result in environmental impacts beyond those associated with the Project and create emergency access issues within the Project Site. The current driving range tee line is an emergency exit path for Rose Bow l events such as the Rose Bowl Game and music festivals. A permanent two-story structure would restrict access for emergency responders to the Project Site and the surrounding golf course during events at the Rose Bowl Stadium, including UCLA football game s, other sporting events, concerts, and music festivals.

R16-5 This comment states that the proposed lighting for the driving range would not be compatible with the historic use of the Project Site. Additionally, the commenter suggests that the proposed li ghting is unnecessary and that the Project Site should remain unlit because it is a benefit to the wildlife in the area. Finally, the commenter states that the Project should include mitigation measures that result in net lower level of foot candles with the Project Site. Please see Topical Response 2, Lighting, regarding the City’s lighting regulations and how the Project complies with all policies regarding lighting, and requires additional mitigation measures to ensure impacts associated with lighting wo uld be less- than-significant. In addition, please see Topical Response 3, Tree Removal and Wildlife , regarding the procedures that would be taken by the RBOC to minimize potential lighting impacts to wildlife within the Project Site, including Mitigation Measure BIO-1 to reduce lighting impacts to wildlife.

R16-6 This comment contains images provided by the commenter for the purpose of demonstrating the existing infrastructure and illustrated the impact of the existing lighting on the Project Site. As described in Topical Response 2, Lighting, the Project, through both compliance with City of Pasadena requirements and through the implementation of additional mitigation, would not exceed established lighting thresholds applicable to the Project. Therefore, no revisions are necessary.

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COMMENT R17 - Jennifer Jacobs (1 page)

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R17. Response to Comments from Jennifer Jacobs, submitted via email February 18, 2023.

R17-1 This comment states the commenter’s opposition to the removal of trees for the Project.

Please see Topical Response 3, Tree Removal and Wildlife , regarding the procedures that would be taken by the RBOC to minimize potential impacts to trees within the Project Site. It is important to note that no rules are being sidestepped by the RBOC, that it works closely with the City’s Public Works Department to manage trees, and complies with the City’s Tree Protection Ordinance. It should also be noted that no trees would be impacted as a result of the development of miniature golf. All tree impacts are related to the driving range improvements, as shown in Attachment D, Potential Locations of Trees to be Removed .

Any tree removals needed would go through UFAC and then to the City Manager just as is the case for any open space trees in Pasadena.

R17-2 This comment expresses the commenter’s opposition to the implementation of the miniature golf course. The comment provides no specific issue regarding the detailed technical analyses contained within the IS/MND regarding these topics. The comment will be provided to the RBOC for its consideration as part of its decision-making for this Project. However, this comment is not a direct comment on the content or adequacy of the IS/MND and does not raise a specific environmental issue; therefore, no further response is required.

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COMMENT R18 - Ellen G. Strauss (3 pages)

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R18. Response to Comments from Ellen G. Strauss, submitted via email February 26, 2023.

R18-1 This comment expresses concern with the information that was provided at the February 13, 2023 community information meeting and those who were in attendance. The comment provides no specific issue regarding the detailed technical analyses contained within the IS/MND regarding these topics. The commenter’s statement will be provided to the RBOC for its consideration as part of its decision-making for this Project. However, this comment is not a direct comment on the content or adequacy of the IS/MND and does not raise a specific environmental issue; therefore, no further response is required.

R18-2 This comment states that the two components of the Project, the expansion of the driving range and the implementation of the miniature golf course, should be considered separately. Given the financing mechanisms necessary for implementation, the RBOC has determined that both elements of this Project should be considered together as one Project, and that should the two aspects of the Project be considered separately, it could be considered “piecemealing” under CEQA, which is expressly prohibited by CEQA Guidelines.

R18-3 The commenter questions who will benefit from the implementation of the Project. The comment provides no specific issue regarding the detailed tech nical analyses contained within the IS/MND regarding these topics. The commenter’s statement will be provided to the RBOC for its consideration as part of its decision- making for this P roject. This comment is not a direct comment on the content or adequacy of the IS/MND and does not raise a specific environmental issue; therefore, no further response is required.

R18-4 The commenter provides information gathered during review of other miniature golf courses in the region to illustrate the other courses are not overly crowded, run down, or provide activities beyond those proposed by the RBOC for this Project. The comment also states that alternate an alternate location should be considered for the miniature golf course, near the Rose Bowl Aquatic Center and playgrounds. Please see Topical Response 8, Project Alternatives, regarding the alternatives and how the IS/MND is sufficient in not evaluating environmental impacts of other alternatives . This comment is not a direct comment on the content or adequacy of the IS/MND and does not raise a specific environmental issue; therefore, no further response is required.

R18-5 This comment states that the RBOC should consider the implementation of a double - decker driving range to double capacity without requiring more space on the Project Site.

Please see Topical Response 8, Project Alternatives, regarding the alternatives and how the IS/MND is sufficient in not evaluating environmental impacts of other alternatives. With respect to the alternative suggested, it would result in environmental impacts beyond those associated with the Project and created emergency access issues with the site. Additionally, the commenter states their disagreement with the proposed increased hours of operation for the driving range, which would increase use of nighttime lighting on the Project Site

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and that current hours of operation are not provided for comparison. As states on page 15 of the IS/MND, current operational hours of the driving range and golf course are from 6:00 a.m. to 8:00 p.m . seven days a week. The driving range and miniature golf course would be open to the public between 6:00 a.m. and 10:00 p.m. seven days a week (no change to golf course operation). Lighting could be on from dusk until closing, with lighting levels dimmed significantly (i.e., reduced to 75 percent illumination) to allow for limited cleaning/staff needs after closing . Please see Topical Response 2, Lighting, regarding the City’s lighting regulations and how the Project complies with all policies regarding lighting, and requires additional mitigation measures to ensure impacts associated with lighting would be less-than-significant.

R18-6 This comment expresses concern that the Project will negatively impact wildlife in the Brookside Golf Course and the proposed tree removal would harm nesting birds in the area. Please see Topical Response 3, Tree Removal and Wildlife, regarding the procedures that would be taken by the RBOC to minimize potential impacts to trees and wildlife within the Project Site, including the implementation of Mitigation Measures MM-BIO-1 and MM-BIO-2.

R18-7 This comment expresses concern with the proposed lighting for the driving range, and how it will impact wildlife, as well as neighboring residents in the Arroyo Seco. Since the Brookside Golf Course includes landscaped vegetation, developed land uses, and unvegetated concrete-lined channel, the Project Site would not be considered a natural habitat. Please see Topical Response 2, Ligh ting, regarding the City’s lighting regulations and how the Project complies with all policies regarding lighting, and requires additional mitigation measures to ensure impacts associated with lighting would be less -than- significant.

R18-8 This comment sta tes that the Project would result in increased traffic congestion and parking issues in areas surrounding the Brookside Golf Course. Please see Topical Response 7, Transportation and Parking, which describes that IS/MND accurately assesses impacts related to transportation consistent with the CEQA Guidelines and the City’s adopted methodology, and also addresses comments received regarding parking. The commenter also states that implementation of the Project would result in increased levels of lighting and noise. Please see Topical Response 2, Lighting, regarding the City’s lighting regulations and how the Project complies. Additionally, please see Topical Response 5, Noise, regarding the City’s noise regulations and how the Project complies with all policies regarding light and noise, and requires additional mitigation measures to ensure impacts associated with lighting would be less-than-significant.

R18-9 This comment states that the Project could states that the project would not be consistent with the Ci ty of Pasadena’s land use regulations for the Arroyo. Please see Topical Response 4, Land Use and Planning , regarding how implementation of the Project would comply with the Arroyo Seco Master Plan and the Arroyo Seco Public Lands Ordinance.

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Additionally t his comment states that implementation of the Project would have a negative effect on wildlife habitats and lighting in the Project Site. Please see Topical Response 2, Lighting, regarding the City’s lighting regulations and how the Project complies with all policies regarding lighting, and requires additional mitigation measures to ensure impacts associated with lighting would be less -than-significant; and please see Topical Response 3, Tree Removal and Wildlife, regarding the procedures that would be taken by the RBOC to minimize potential impacts to wildlife within the Project Site.

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COMMENT R19 - Maureen Hosp (1 page)

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R19. Response to Comments from Maureen Hosp, submitted via email March 1, 2023.

R19-1 This comment expresses concern regarding the increased lighting for the driving range and corresponding noise impacts that would result from the driving range’s proposed hours of operation. Please see Topical Response 2, Lighting, regarding the City’s lighting regulations and how the Project complies with all policies regarding lighting, and requires additional mitigation measures to ensure impacts associated with lighting would be less - than-significant. Additionally, please see T opical Response 5, Noise , regarding the City’s noise regulations and how the Project complies with all policies regarding noise to ensure impacts associated with noise would be less-than-significant.

R19-2 This comment states that the project would result in increased traffic in the areas surrounding the Project Site. Please see Topical Response 7, Transportation and Parking , which describes that IS/MND accurately assesses impacts related to transportation consistent with the CEQA Guidelines and the City’s adopted methodology.

R19-3 This comment states that the noise and lighting from the driving range and miniature golf course would negatively impact wildlife in the area. Please see Topical Response 3, Tree Removal and Wildlife , regarding the procedu res that would be taken by the RBOC to minimize potential impacts to wildlife within the Project Site.

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COMMENT R20 - Frank Clem (1 page)

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R20. Response to Comments from Frank Clem, submitted via email March 1, 2023.

R20-1 This comment expresses the commenter’s opposition to the implementation of the miniature golf course within the existing Brookside Golf Course, due to the potential effects it would have on the E.O. Nay and C.W . Koiner course. Please see Topical Response 6, Recreation, which demonstrates how implementation of the Project would not negatively impact the existing use of either the C.W . Koiner Course or the E.O. Nay Course, and the Brookside Golf Course would continue to have a championship layout while improving the pace of play. Additionally, the commenter recommends an alternate location for the proposed miniature golf course, near the Kidspace museum. Please see Topical Response 8, Project Alternatives, regarding the alternatives and how the IS/MND is sufficient in not evaluating environmental impacts of other alternatives.

R20-2 This comment states that the Project would result in increased lighting in the area, that they would have to deal with every night. Please see Topical Response 2, Lighting, regarding the City’s lighting regulations and how the P roject complies with all policies regarding lighting, and requires additional mitigation measures to ensure impacts associated with lighting would be less-than-significant. Additionally, the commenter states that the Project would result in negative impacts to parking in the areas surrounding the Project Site. Please see Topical Response 7, Transportation and Parking , which describes that IS/MND accurately assesses impacts related to transportation consistent with the CEQA Guidelines and the City’s adopted methodology, and also addresses comments received regarding parking.

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COMMENT R21 - Nancy Gadel (1 page)

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R21. Response to Comments from Nancy Gadel, submitted via email March 1, 2023.

R21-1 This comment expresses the commenter’s opposition to the Project due to the removal of trees, and potential impacts to wildlife located within the Arroyo Seco. Please see Topical Response 3, Tree Removal and Wildlife, regarding the procedures that would be taken by the RBOC to minimize potential impacts to wildlife within the Project Site . This comment’s recommendation will be provided to the RBOC for its consideration as part of its decision-making for this Project.

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COMMENT R22 - Patty Montbriand (2 pages)

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R22. Response to Comments from Patty Montbriand, submitted via email March 1, 2023.

R22-1 This comment states that notices were not sent to neighbors surrounding the Project Site.

However, as stated in Section 1.5, Public Engagement , the RBOC circulated a Notice of Intent (NOI) to Adopt a Mitigated Negative Declaration (MND) to addresses within 500 feet of Project Sit e, which included a total of 531 residences. Additionally, the RBOC emailed notification to the interested party distribution list consisting of over 1,000 recipients. The Project was properly noticed consistent with CEQA Guidelines Section 15072.

R22-2 This comment states that the RBOC is consideri ng removing dozens of trees in the Project Site and replacing them with “directional light posts”. A s discussed in the IS/MND, the final number of trees that would require removal or relocation is dependent on the final design of the Project. Please see Topical Response 3, Tree Removal and Wildlife, regarding the procedures that would be taken by the RBOC to minimize potential impacts to trees within the Project Site.

R22-3 This comment states that the Project would triple the size of the existing driving r ange.

As stated on page 6 of the IS/MND, expanding the number of stalls would serve the existing demand of golfers who now may wait over an hour for a hitting bay to open.

The RBOC would ensure that the design of the expanded and reoriented driving range and miniature golf course are compatible with existing design elements of the Brookside Golf Course Complex and are sensitive to the location within the Historic District, the Arroyo Seco, and the adjacent Rose Bowl. Additionally, the Project would be subject to the City’s Design Review process as defined in the Pasadena Municipal Code.

R22-4 This comment states that a previous project was implemented in the Arroyo Seco. The comment provides no specific issue regarding the detailed technical analyses contai ned within the IS/MND regarding these topics. This comment is not a direct comment on the content or adequacy of the IS/MND and does not raise a specific environmental issue; therefore, no further response is required.

R22-5 This comment states that the location of the miniature golf course would be unsafe for families due to the golfing activities that would be occurring on the golf course. The existing Brookside Golf Course is currently open to families and children that participate in programs such as Fi rst Tee – Greater Pasadena. Although the implementation of the miniature golf course would increase the number of visitors, additional safety impacts to families and children are not anticipated, and in any event safety is a key element of the proposed net ting around the driving range. The comment provides no specific issue regarding the detailed technical analyses contained within the IS/MND regarding these topics. The commenter’s statements will be provided to the RBOC for its consideration as part of its decision-making for this Project. This comment is not a direct comment on

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the content or adequacy of the IS/MND and does not raise a specific environmental issue; therefore, no further response is required.

R22-6 This comment expresses the commenter’s opposition to the Project due to the loss of trees within the Project Site, the addition of new lighting in the Arroyo Secco, and increase in traffic that could result from the Project. Please see Topical Response 3, Tree Removal and Wildlife , regarding the p rocedures that would be taken by the RBOC to minimize potential impacts to trees within the Project Site, and Topical Response 2, Lighting , regarding the City’s lighting regulations and how the Project complies with all policies regarding lighting, and requires additional mitigation measures to ensure impacts associated with lighting would be less -than-significant. Additionally, p lease see Topical Response 7, Transportation and Parking, which describes that IS/MND accurately assesses impacts related to tran sportation consistent with the CEQA Guidelines and the City’s adopted methodology.

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COMMENT R23 - Patrick Feely (1 page)

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R23. Response to Comments from Patrick Feely, submitted via email March 2, 2023.

R23-1 This comment states that the Brookside Golf Course should not be viewed as a “business” and should instead be viewed a service to the community, not a commercial endeavor. The commenter also provides recommendations for increasing revenues, without the implementation of the Project. The commenter’s recommendation s will be provided to the RBOC for its consideration as part of its decision-making for this project.

This comment is not a direct comment on the content or adequacy of the IS/MND and does not raise a specific environmental issue . As directed by Section 15131(a) of the CEQA Guidelines, economic or social effects of a project shall not be treated as significant effects on the environment. Therefore, no further response is required.

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COMMENT R24 - Geoff Bland (1 page)

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R24. Response to Comments from Geoff Bland, submitted via email March 2, 2023.

R24-1 This comment states that there is a lack of transparency, because they have just now been made aware of the Project. In accordance with Section 15072 of the CEQA Guidelines, the RBOC has provided public notice of the Project within a reasonable period of time prior to adoption of the IS/MND. As stated in Section 1.5, Public Engagement, the RBOC circulated a NOI to addresses within 500 feet of Project Site, which included a total of 531 residences. Additionally, the RBOC emailed notification to the interested party distribution list consisting of over 1,000 recipients. Therefore, th e Project was appropriately noticed in compliance with the CEQA Guidelines.

R24-2 This comment states that the removal of trees would be harmful to wildlife in the Project Site. Please see Topical Response 3, Tree Removal and Wildlife, regarding the procedures that would be taken by the RBOC to minimize potential impacts to wildlife within the Project Site.

R24-3 This comment states that the Project would result in more traffic congestion in areas surrounding the Project Site, without the addition of new p arking. Please see Topical Response 7, Transportation and Parking, which describes that IS/MND accurately assesses impacts related to transportation consistent with the CEQA Guidelines and the City’s adopted methodology, and also addresses comments received regarding parking.

R24-4 This comment states that the Project would result in increased noise but provides no specificity regarding analysis of noise impacts presented in the IS/MND. Please see Topical Response 5, Noise, regarding the City’s noise regulations and how the Project complies with all policies regarding noise to ensure impacts associated with noise would be less-than-significant.

R24-5 This comment expresses concern regarding funding of the Project. The commenter’s statements will be provided to the RBOC for its consideration as part of its decision- making for this project. However; this comment is not a direct comment on the content or adequacy of the IS/MND and does not raise a specific environmental issue. As directed by Section 15131(a) of the CEQA Guidelines, economic or social effects of a project shall not be treated as significant effects on the environment. Therefore, no further response is required.

R24-6 This comment states that lighting for the Project would make sleeping more difficult for neighbors surrounding the Project Site, would negatively affect wildlife, and permanently change the Arroyo Seco. P lease see Topical Response 2, Lighting , regarding the City’s lighting regulations and how the Project complies with all policies regarding lighting, and requires additional mitigation measures to ensure impacts associated with lighting would be less-than-significant.

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COMMENT R25 - Irena Petrack (1 page)

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R25. Response to Comments from Irena Petrack, submitted via email March 2, 2023.

R25-1 This comment states that the areas surrounding the Project Site already have excessive noise and traffic, and the increase in lighting from the Project would make conditions unpleasant for current residents. Please see Topical Response 7, Transportation and Parking, Topical Response 5, Noise, and Topical Response 2, Lighting , regarding the City’s noise, lighting, and traffic regulations and how the Project complies with all policies to ensure impacts would be less-than-significant.

R25-2 This comment states that legal action should be taken in opposition of the Project to protect the quality of life within the neighborhood. The comment provides no specific issue regarding the detailed technical analyses contained within the IS/MND regardin g these topics. The commenter’s statements will be provided to the RBOC for its consideration as part of its decision-making for this project. This comment is not a direct comment on the content or adequacy of the IS/MND and does not raise a specific environmental issue; therefore, no further response is required.

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COMMENT R26 - Susan Burns (1 page)

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R26. Response to Comments from Susan Burns, submitted via email March 2, 2023.

R26-1 This comment states the commenter’s opposition to the miniature golf course and questions why notices were not sent to impacted neighbors surrounding the Project Site.

However, as stated in Section 1.5, Public Engagement , the RBOC circulated a NOI to addresses within 500 feet of Project Sit e, which included a total of 531 residences.

Additionally, the RBOC e mailed notification to the interested party distribution list consisting of over 1,000 recipients. Therefore, the Project was appropriately notice d in compliance with the CEQA Guidelines.

In addition, the commenter questions if the historical foundation has been involved.

RBOC met with Pasadena Heritage as described above in Section 1.5, Public Engagement, regarding the Project and the historical ev aluation that was conducted for the IS/MND (see Appendix D to the IS/MND). To date, Pasadena Heritage did not provide a comment letter regarding the analysis contained in the report or the mitigation measures that are required in order to reduce impacts to historical resources.

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COMMENT R27 - Michael Clayton (2 pages)

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R27. Response to Comments from Michael Clayton, submitted via email March 2, 2023.

R27-1 This comment states that the Project should increase the size of the driving range by 50 percent to reduce the removal of trees and additional lighting that would be required on the Project Site. Please see Topical Response 8, Project Alternatives , regarding the alternatives and how the IS/MND is sufficient in not evaluating environmental impacts of other alternatives. The RBOC would ensure that the design of the expanded and reoriented driving range and miniature golf course are compatible with existing design elements of the Brookside Golf Course Complex. Additionally, the Project would be subject to the City’s Design Review process as defined in the Pasadena Municipal Code.

Please see Topical Response 3, Tree Removal and Wildlife , regarding the procedures that would be taken by the RBOC to minimize potential impacts to trees within the Project Site. Additionally, p lease see Topical Response 2, Lighting , regarding the City’s lighting regulations and how the Project complies with all policies regarding lighting, and requires additional mitigation measures to ensure impacts associated with lighting would be less - than-significant.

R27-2 This comment expresses the commenter’s opposition to the implementation of the miniature golf course, because it would increase traffic, noise, and lighting in the Project Site. No specific comments were provided regarding deficiencies in the analysis provided in the IS/MND regarding these issues. Please see Topical Response 7, Transportation and Parking, Topical Response 2, Lighting, and Topical Response 5, Noise, regarding the City’s noise, lighting and traffic regulations and how the P roject complies with all policies to ensure impacts would be less-than-significant.

R27-3 This comment states that no cost/income analysis was shared for the construction and operation of the proposed driving range and/or miniature golf course. The commenter’s statements will be provided to the RBOC for its consideration as part of its decision- making for this project. However; this comment is not a direct comment on the content or adequacy of the IS/MND and does not raise a specific environmental issue. As directed by Section 15131(a) of the CEQA Guidelines, economic or social effects of a project shall not be treated as significant effects on the environment. Therefore, no further response is required.

R27-4 This comment states that they did not receive notice regarding the Project from the RBOC. In accordance with Section 15072 of the CEQA Guidelines, the RBOC has provided public notice of the Project within a reasonable period of time prior to adoption of the IS/MND. As stated in Section 1.5, Public Engagement, the RBOC circulated a NOI to addresses within 500 feet of Project Site, which included a total of 531 residences.

Additionally, the RBOC emailed notification to the interested party distribution list consisting of over 1,000 recipients. This list included residents and members of the West Pasadena Residents’ Association (WPRA) and East Pasadena Residents Association.

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Therefore, the Project was appropriately noticed in compliance with the CEQA Guidelines.

R27-5 This comment states that not parking plans have been completed for the Project to identify additional parking location near the Project Site; in addition to increase in traffic, and entry and exit from the Project Site. Please see Topical Response 7, Transportation and Parking, which describes that IS/MND accurately assesses impacts related to transportation consistent with the CEQA Guidelines and the City’s adopted methodology, and also addresses comments received regarding parking.

R27-6 This comment states that the Project would eventually result in additional visitors to the Project Site, which would result in additional noise impacts for neighbors of the Brookside Golf Course from amplified sound. No amplified sound is proposed for the Project.

Please see Topical Response 5, Noise, regarding the City’s noise regulations and how the Project complies with all policies regarding noise to ensure impacts associated with noise would be less-than-significant.

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COMMENT R28 - Carlos Chacon (1 page)

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R28. Response to Comments from Carlos Chacon, submitted via email March 2, 2023.

R28-1 This comment states that implementation of the Project would impact the historical significance of the E.O. Nay and C.W . Koiner golf course. As stated on page 27 of the IS/MND, to ensure that the ultimate Project design (including lighting components) is executed to achieve a maximum level of compatibility with the Pasadena Arroyo Park and Recreational District, Mitigation Measure CUL -1 requires the RBOC retain a qualified historic preservation professional to ensure that alterations to the driving range, design of the miniature golf course, and overall modifications to the Golf Course are compatible with the existing Brookside Golf Course landsc ape and the Pasadena Arroyo Park and Recreational District. Therefore, Mitigation Measure CUL-1 would ensure that design of the Project would avoid any impacts to the historical resource.

R28-2 This comment states that the proposed hours of operation would result in increased nighttime lighting, which would be an intrusion of the neighborhood and would draw unwanted activity to the Project Site. Please see Topical Response 2, Lighting , regarding the City’s lighting regulations and how the Project complies with all policies regarding lighting, and requires additional mitigation measures to ensure impacts associated with lighting would be less-than-significant.

R28-3 This comment states that increasing the size of the existing facility would result in parking issues. Please see Topical Response 7, Transportation and Parking , which describes that IS/MND accurately assesses impacts related to transportation consistent with the CEQA Guidelines and the City’s adopted methodology, and also addresses comments receive d regarding parking.

R28-4 This comment expresses concerns regarding financial analysis for the Project. The commenter’s statements will be provided to the RBOC for its consideration as part of its decision-making for this project. This comment is not a direct comment on the content or adequacy of the IS/MND and does not raise a specific environmental issue. As directed by Section 15131(a) of the CEQA Guidelines, economic or social effects of a project shall not be treated as significant effects on the env ironment. Therefore, no further response is required.

R28-5 This comment states that the Arroyo Seco should be treated with historic value and should not be exploited by commercialization ventures. As stated in Section 3.5, Cultural Resources, of the IS/MND, the Historic Resources Technical Report completed for the Project (Appendix D to the IS/MND) ensured that alterations to the driving range, design of the miniature golf course, and overall modifications to the Golf Course are compatible with the existin g Brookside Golf Complex landscape and the Pasadena Arroyo Park and Recreational District so that the historic integrity of the Pasadena Arroyo Park and Recreational District is maintained. The Historic Resources Technical Report determined that alterations included in the Project would be in areas that have previously been altered

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and changed over time. Additionally, the Project would not destroy or alter the physical characteristics that make the Brookside Golf Course a historical listing as a contributing feature of the Pasadena Arroyo Park and Recreation District. Because the majority of the site elements that characterize the Brookside Golf Course would continue to retain their original location, general overall boundaries, and routing, the Brookside Golf Course would continue to convey its historic significance.

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COMMENT R29 - Allen Gharapetian (1 page)

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R29. Response to Comments from Allen Gharapetian, submitted via email March 2, 2023.

R29-1 This comment expresses the commenter’s opposition to the Project. The comment provides no specific issue regarding the detailed technical analyses contained within the IS/MND regarding these topics. The commenter’s statements will be provided to the RBOC for its consideration as part of its decision-making for this project. This comment is not a direct comment on the content or adequacy of the IS/MND and does not raise a specific environmental issue; therefore, no further response is required.

R29-2 This comment states the at the removal of 45 trees, construction of new lighting, and expansion of the existing driving range, and increase in traffic within areas surround the Project Site, irresponsible, environmentally problematic, and unacceptable. The comment provides no specific comment regarding the environmental analysis contained in the IS/MND regarding these issues. Please see Topical Response 7, Transportation and Parking, Topical Response 2, Lighting, and Topical Response 3, Tree Removal and Wildlife, for more information.

R29-3 The comment states that traffic and parking issues in the areas surround the Brookside Golf Course have increased in recent years. Please see Topical Response 7, Transportation and Parking , which describes that IS/MND accurately assesses impacts related to transportation consistent with the CEQA Guidelines and the City’s adopted methodology, and also addresses comments received regarding parking. Additionally, the commenter states that excessive sound and increased lighting are issues that the RBOC has fail ed to address or remedy, despite complaints from residents. Please see Topical Response 2, Lighting, and Topical Response 5, Noise, regarding the City’s lighting and noise regulations and how the Project complies with all policies regarding noise and light ing, and requires additional mitigation measures for potential lighting impacts, to ensure impacts associated with noise and lighting would be less-than-significant.

R29-4 This comment states that implementation of the Project will negatively impact the Arroyo Seco. The comment provides no specific issue regarding the detailed technical analyses contained within the IS/MND regarding these topics. The commenter’s statements will be provided to the RBOC for its consideration as part of its decision -making for this project. However; this comment is not a direct comment on the content or adequacy of the IS/MND and does not raise a specific environmental issue; therefore, no further response is required.

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COMMENT R30 - Laura Burke (1 page)

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R30. Response to Comments from Laura Burke, submitted via email March 3, 2023.

R30-1 This comment states that the implementation of the Project would result in an increase of vehicular traffic in areas surrounding the Project Site, which would make nonvehicular recreational activities like walking, running, and cycling, unsafe. As described in Section

3.17, Transportation, of the IS/MND, the Project would be developed entirely within the Brookside Gol f Course and would be accessed via existing adjacent parking lots and Brookside Golf Course pathways, similar to existing conditions. Operation of the Project would not require any changes to the existing circulation system, including the Rose Bowl Recreational Loop or equestrian trails. Additionally, the miniature golf course would serve existing users of the Brookside Golf Course and Central Arroyo recreational users, and the Project is not anticipated to increase attendance at the golf course, but rather to capture existing users. Existing driveways and parking areas are sufficient to serve both the project and the many user groups that access the Central Arroyo.

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COMMENT R31 - Marcus Renner (2 pages)

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R31. Response to Comments from Marcus Renner, submitted via email March 3, 2023.

R31-1 This comment states that the location of the proposed miniature golf course would not be appropriate because it would disrupt the flow of the flood control channel. As described on page 80 of the IS/MND, the Arroyo Seco channel, a subgrade concrete - lined feature, crosses the Brookside Golf Course and forms the western boundary of the reoriented driving range. However, the Project would not require any physical construction within the channel nor would it result in indirect impacts to the channel. The majority of the Project would result in similar amounts of impervious surfaces as the existing driving range (all natural turf). The Project is a continued use of golf activities that have occurred along the Arroyo Seco for decades. The recent storm events and water within the channel did not affect the adjacent golf course uses. No inhabitable structures are proposed within the golf course. As stated on page 80 of the IS/MND, the increase in bays within the proposed driving range, as well as limited new impervious features associated with the miniature golf course, would result in an increase of impervious surfaces and would be similar to current conditions. Thus, the Project would not create or contribute runoff water that would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff.

Additionally, as described on page 82 of the IS/MND, incorporation of landscaping and replacement of pervious surfaces would ensure that the Project would result in similar drainage patterns as the existing golf course and would not substantially increase the rate or amount of surface run-off in which would result in flooding on- or offsite. Therefore, no revisions to the IS/MND are necessary.

R31-2 This comment recommends an alternate location for the proposed miniature golf course.

Please see Topical Response 8, Project Alternatives, regarding the alternatives and how the IS/MND is sufficient in not evaluating environmental impacts of other alternatives. The RBOC has no jurisdiction over lands associated with I -710 and this is not a viable alternative for consideration.

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COMMENT R32 - Marie Levine (2 pages)

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R32. Response to Comments from Marie Levine, submitted via email March 3, 2023.

R32-1 This comment states their concern regard the Project’s potential impacts to wildlife including birds in the Arroyo Seco. The commenter states that the information provided in the IS/MND and Appendix C, Biological Resources Assessment, is minimal and incomplete.

Additionally, the commenter states that the Central Arroyo Seco is part of a complex Wildlife Corridor and habitat system.

In addition to a field survey conducted by a qualified biologist for this project, the Biological Resources Assessment include d a review of multiple biological diversity databases, including California Department of Fish and Wildlife’s (CDFW) California Natural Diversity Data Base (CNDDB), California Native Plant Society’s (CNPS) Inventory of Rare and Endangered Vascular Plants of California, U.S. Fish and Wildlife Service’s (USFWS) Critical Habitat Portal, to determine the potential for special -status species and other sensitive biological resources to occur within the Project Site and survey area. While the databases identified species have been previously documented within or in close proximity to the survey area (most in the early- to mid-1900’s), in its current state, suitable habitat within the Project Site is not present. As discussed on page 45 of the IS/MND, implementation of Measures MM-BIO-1 would ensure avoidance of impacts to nesting birds during construction as well as any potential indirect impacts that may be created by the Project. A qualified biologist will conduct a nesting bird survey within 3 days prior to the proposed start date, to identify any active nests within 500 feet of the Project Site. If an active nest is found, the nest shall be avoided, and a suitable buffer zone shall be delineated in the field such that no impacts shall occur until the chicks have fledged the nest as determined by a qualified biologist. Please see Topical Response 3, Tree Removal and Wildlife , regarding the procedures that would be taken by the RBOC to minimize potential impacts to wildlife within the Project Site.

R32-2 The comment states that Brookside Golf Course, including the Project Site, is home to many bird species and is a part of a significant Migratory Bird “flyaway”. Implementation and operation of the Project would not be anticipated to negatively affect birds in the Project because conditions during operation of the Project would be essentially the same as existing conditions of the Brookside Golf Course. Thus, inclusion of the proposed netting surrounding the driving range would not negatively affect birds on the Project Site, including hawks and owls, since the Project Site currently contains netting within the existing driving range. There has never been a recorded incident of wildlife getting caught in the current netting.

Additionally, implementation of Mitigation Me asure BIO -2 would minimize potential indirect impacts to nesting birds that may utilize ornamental/landscape vegetation onsite and/or wildlife movement along the Arroyo Seco, requiring nighttime lighting associated with the driving range and miniature golf course to be shielded downward to limit spillage.

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comparison to the large events held in the Arroyo Seco throughout the year. Even with those events, which include thousands of cars parking on the golf course, amplified sound, and significantly increased activity, birds still continue to utilize this area .

Accordingly, there is no evidence that human activities in the Arroyo negatively impact the presence of birds. There has never been a recorded incident of wildlife getting caught in the current netting. There is no reason to believe that this Project would have a different result.

R32-3 This comment questions how lighting and noise from the Project will negatively impact wildlife within the Central Arroyo Seco, and the surrounding areas . As demonstrated in the IS/MND, the Project applies the appropriate threshold used for all projects in the City of Pasadena, including other projects in the Central Arroyo. In this case, the Project would have a significant impact on neighboring areas if the site lighting produces an illuminance of greater than 1.0 foot- candle on any residential property. The lighting assessment included in the IS/MND demonstrates that the light loss spi ll factor would be 0.95, less than the 1 -foot candle threshold, at the property line. Given the precise lighting specifications are not known at this time (nor required to be known), the IS/MND requires a quantified, measurable mitigation measure with performance standards in place that must be met before lighting is installed (see mitigation measure AES -1). Please also see Topical Response 2, Lighting , regarding the City’s lighting regulations and how the Project complies with all policies regarding lighting, and requires additional mitigation measures to ensure impacts associated with lighting would be less -than-significant. As such, the IS/MND includes a well- supported impact assessment (including appropriate performance-based mitigation) to ensure that i mpacts related to lighting would be less than significant. Additionally, there is a discussion regarding impacts to wildlife from lighting which is addressed beginning on page 45 of the IS/MND, and mitigation measure BIO-2 is required in order to reduce potential lighting impacts. The RBOC must, through adoption of this mitigation measure, enforce and demonstrate compliance and will do so as the Lead Agency for this project. Finally, the implication that the lighting will be on all night is not accurate.

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COMMENT R33 - Arnold Siegel (1 page)

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R33. Response to Comments from Arnold Siegel, submitted via email March 3, 2023.

R33-1 This comment states that the increased number of projects in the Arroyo Seco are commercializing the area and increasing traffic and noise, and reducing the number of trees in the area. Additionally, the commenter states that Project is being piecemealed, and the RBOC has failed to consider cumulative impacts. As described on page 118 of the IS/MND, the potential for cumulative impacts occurs when the independent impacts of a given project are combined with the impacts of related projects in proximity to the Project Site that would create impacts that are greater than those of the proje ct alone.

Related projects include past, current, and/or probable future projects whose development could contribute to potentially significant cumulative impacts in conjunction with a given project. The RBOC is undergoing a broad planning process to consi der various improvements at the Rose Bowl and Brookside Golf Course to assist in meeting long-term revenue needs. While a variety of different options are under review, including operational changes and potentially other improvements, none of these changes are funded or considered reasonably foreseeable at this time. Therefore, there are no known reasonably foreseeable cumulative projects located in the immediate vicinity of the Project. As demonstrated in this analysis, there would be no long -term signific ant operational impacts that would result from the Project. As such, there is no contribution to cumulative impacts from the Project. Additionally, based on the relatively small and localized scale of this Project, and that no other cumulative projects are identified in the area, the Project would not result in impacts that are individually limited but cumulatively considerable.

R33-2 This comment states that it is the RBOC’s responsibility to consider alternatives for the Project. However, as stated in Top ical Response 8, Alternatives , t he purpose of an alternatives analysis is to look at ways to avoid or reduce identified significant environmental impacts of a proposed project. An IS/MND is only prepared for projects that are demonstrated not to have any s ignificant environmental impacts, or where mitigation can be adopted to reduce all significant impacts to a less-than-significant level.

The case cited by the commenter is in relation to an EIR and is not relevant to this Project.

Therefore, because the P roject, which a s supported throughout the IS/ MND and corresponding detailed technical analyses, has been determined to have no significant environmental impacts, no analysis of alternatives is required. Therefore, no revisions are required.

R33-3 This comment states that the Project description is insufficient. Please see Topical Response 1, Unstable Project Description , regarding the required contents of the Project Description, which in this IS/MND, contains sufficient information to inform the public about all elements of the Project – from design, through construction, and long -term operation – and to adequately analyze environmental impacts of Project implementation and define appropriate mitigation. Additionally, the commenter poses questions regarding tree removal, increase of light, and additionally traffic impacts that would result from the

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Project. Please see Topical Response 3, Tree Removal and Wildlife , Topical Response 2, Lighting, and Topical Response 7, Transportation and Parking, for more information. All of the information requested by the commenter has been provided in the IS/MND and these responses. No further revisions are required.

R33-4 This comment expresses concerns regarding financial analysis for the Project. The comment provides no specific issue regarding the detailed technical analyses contained within the IS/MND regarding these topics. The commenter’s statements will be provided to the RBOC for its consideration as part of its decision-making for this project. However; this comment is not a direct comment on the content or adequacy of the IS/MND and does not raise a specific environmental issue . As directed by Section 15131(a) of the CEQA Guidelines, economic or social effects of a project shall not be treated as significant effects on the environment. Therefore, no further response is required. .

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COMMENT R34 - Adry Furchtgott (1 page)

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R34. Response to Comments from Adry Furchtgott, submitted via email March 3, 2023.

R34-1 This comment states the commenter’s opposition to the implementation of the miniature golf course in the Project Site, because it will be detrimental to the natural habitat of local wildlife in the Arroyo Seco. Since the Brookside Golf Course includes land scaped vegetation, developed land uses, and unvegetated concrete-lined channel, the Project Site would not be considered a natural habitat. Please see Topical Response 3, Tree Removal and Wildlife, regarding the procedures that would be taken by the RBOC to minimize potential impacts to wildlife within the Project Site. Additionally, the commenter states that the Project would include unnecessary and harmful non -native turf to the Arroyo Seco. As stated on page 49 of the IS/MND, the Project would be consistent with Section 2.2, “Landscape Improvements” of the Arroyo Seco Design Guidelines, and would preserve the historical heritage of the City of Pasadena and the Arroyo Seco, preserve and protect natural resources, use California native/drought tolerant plan t species, and use turf varieties that are water conserving, tolerant of heavy use, and not dependent on chemical fertilizers for their success.

R34-2 This comment expresses the commenter’s opposition to the implementation of the miniature golf course. Th e comment provides no specific issue regarding the detailed technical analyses contained within the IS/MND regarding these topics. The commenter’s statements will be provided to the RBOC for its consideration as part of its decision - making for this project. However; this comment is not a direct comment on the content or adequacy of the IS/MND and does not raise a specific environmental issue; therefore, no further response is required.

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COMMENT O1 - Evan Davis (West Pasadena Residents Association) (3 pages)

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O1. Response to Comments from Evan Davis of the West Pasadena Residents Association, submitted via email February 23, 2023.

O1-1 This comment summarizes West Pasadena Residents Association (WPRA) involvement and acknowledges the RBOC’s efforts to achieve self-sufficiency but oppose the Project.

The comment provides no specific issue regarding the detailed technical analyses contained within the IS/MND regarding these topics. This comment will be provided to the RBOC for its consideration as part of its decision-making for this Project.

O1-2 This comment states that the IS/MND does not provide an accurate, stable, and finite Project Description for the Project. Please se e Topical Response 1, Unstable Project Description, regarding the required contents of the Project Description, which in this IS/MND, contains sufficient information to inform the public about all elements of the Project – from design, through construction, and long-term operation – and to adequately analyze environmental impacts of Project implementation and define appropriate mitigation.

O1-3 This comment expresses concerns regarding financial analysis for the Project. The commenter’s statements will be provided to the RBOC for its consideration as part of its decision-making for this project. However; this comment is not a direct comment on the content or adequacy of the IS/MND and does not raise a specific environmental issue .

As directed by Section 15131(a) of the CEQA Guidelines, economic or social effects of a project shall not be treated as significant effects on the environment. Therefore, no further response is required. The commenter also refers to a separate letter provided by Nina Chomsky. Please see responses to this letter O5 below.

O1-4 This comment states that implementation of the Project would result in increased levels of lighting and noise. Please see Topical Response 2, Lighting, regarding the City’s lighting regulations and how the Project complies with all policies regarding lighting, and requires additional mitigation measures to ensure impacts associated with lighting would be less - than-significant. Additionally, please see Topical Response 5, Noise , regarding the City’s noise regulations and how the Project complies with all policies regarding noise to ensure impacts associated with noise would be less -than-significant. No amplified noise is proposed. The commenter also states that the Project would result in increased traffic issues in areas surrounding the Brookside Golf Course. Please see Topical Response 7, Transportation and Parking , which describes that IS/MND acc urately assesses impacts related to transportation consistent with the CEQA Guidelines and the City’s adopted methodology, and also addresses comments received regarding parking.

O1-5 This comment expresses concern regarding tree removals and that the Proj ect will negatively impact wildlife in the Brookside Golf Course. Please see Topical Response 3, Tree Removal and Wildlife, regarding the procedures that would be taken by the RBOC to minimize potential impacts to trees and wildlife within the Project Site . Additionally, the

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comment states that implementation of the Project would impact the historical fabric of the Arroyo Seco. The IS/MND includes a comprehensive historical analysis and provides a well-supported conclusion that there would be no impact to the historical resource. The comment provides no specific issue or concern with the analysis provided.

O1-6 This comment expresses concerns regarding financial analysis for the Project. The commenter’s statements will be provided to the RBOC for its consideration as part of its decision-making for this project. However; this comment is not a direct comment on the content or adequacy of the IS/MND and does not raise a specific environmental issue .

As directed by Section 15131(a) of the CEQA Guidelines, economic or social effects of a project shall not be treated as significant effects on the environment. Therefore, no further response is required.

O1-7 This comment states that the Project has not released a thorough “proof of concept”.

Assuming the comment is regarding the amount of detail provided in the project description, please see Topical Response 1, Project Description . To the extent that this comment is not a direct comment on the content or adequacy of the IS/MND , it does not raise a specific environmental issue.

O1-8 This comment states that the Rose Bowl Stadium and the Brookside Golf Course are on the National Register of Historic Places. This is a correct statement and potential impacts to the historical resource are comprehensively addressed in th e Historical Resources Technical Report found as Appendix D to the IS/MND, which was prepared by local experts at Historic Resources Group (HRG). As summarized on page 27 of the IS/MND, to ensure that the ultimate Project design (including lighting compone nts) is executed to achieve a maximum level of compatibility with the Pasadena Arroyo Park and Recreational District, Mitigation Measure CUL -1 requires the RBOC retain a qualified historic preservation professional to ensure that alterations to the driving range, design of the miniature golf course, and overall modifications to the Golf Course are compatible with the existing Brookside Golf Course landscape and the Pasadena Arroyo Park and Recreational District. The RBOC would ensure that the design of the expanded and reoriented driving range and miniature golf course are compatible with existing design elements of the Brookside Golf Course Complex and are sensitive to the location within the Historic District, the Arroyo Seco, and the adjacent Rose Bowl. Additionally, the Project would be subject to the City’s Design Review process as defined in the Pasadena Municipal Code. Therefore, Mitigation Measure CUL-1 would ensure that design of the Project would avoid any impacts to the historical resource.

O1-9 This comment states that the Project may be in violation of the Arroyo Seco Master Plan and/or the Arroyo Seco Public Lands Ordinance. Please see Topical Response 4, Land Use and Planning , regarding how implementation of the Project would comply with the Arroyo Seco Master Plan and the Arroyo Seco Public Lands Ordinance.

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COMMENT O2 - Geoffrey Baum (West Pasadena Residents Association) (3 pages)

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O2. Response to Comments from Geoffrey Baum of the West Pasadena Residents Association, submitted via email March 3, 2023. This is the same comment letter as O1 above.

Please see responses O1-1 through O1-9 for responses.

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COMMENT O3 - Greg King (Pasadena Beautiful) (2 pages)

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O3. Response to Comments from Greg King of Pasadena Beautiful, submitted via email March 3, 2023.

O3-1 This comment summarizes the role of Pasadena Beautiful as an organization, and expresses concerns regarding financial analysis for the Project. The commenter’s statements will be provided to the RBOC for its consideration as part of its decision- making for this project. However; this comment is not a direct comment on the content or adequacy of the IS/MND and does not raise a specific environmental issue. As directed by Section 15131(a) of the CEQA Guidelines, economic or social effects of a project shall not be treated as significant effects on the environment. Therefore, no further response is required.

O3-2 This comment expresses opposition to the proposed tree removal. Please see Topical Response 3, Tree Removal and Wildlife, regarding the procedures that would be taken by the RBOC to minimize potential impacts to trees and wildlife within the Project Site.

O3-3 This comment expresses concerns regarding financial analysis for the Project. The commenter’s statements will be provided to the RBOC for its consideration as part of its decision-making for this project. This comment is not a direct comment on the content or adequacy of the IS/MND and does not raise a specific environmental issue. As directed by Section 15131(a) of the CEQA Guidelines, economic or social effects of a project shall not be treated as significant effects on the environment. Therefore, no further response is required.

O3-4 Please see comment response O3-2 above. The potential loss of trees and tree canopies (as providing nesting habitat) on the entirely landscaped golf course is adequately addressed in the IS/MND and supporting technical analysis (see Appendix C, Biological Assessment).

O3-5 This comment states that there is no environmental assessment of light pollution to wildlife. However, there is a discussion regarding impacts to wildlife from lighting which is addressed beginning on page 45 of the IS/MND, and mitigation measure BIO -2 is required in order to reduce potential lighting impacts. Please also see Topical Response 2, Lighting, regarding the City’s lighting regulations and how the Project complies with all policies regarding lighting, and requires additional mitigation measures to ensure impacts associated with lighting would be less-than-significant.

O3-6 The comment asks what the negative environmental impacts will be associated with increased congestion. Impacts associated with traffic, including air quality, greenhouse gas emissions, and noise, are addressed throughout the IS/MND. Please also see Topical Response 7, Transportation and Parking, which describes that IS/MND accurately assesses impacts related to transportation consistent with the CEQA Guidelines and the City’s adopted methodology.

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O3-7 This comment summarizes previous comments provided by the commenter. Please comment responses O3-1 through O3-6 above.

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COMMENT O4 - Robert Baderian (First Tee) (1 page)

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O4. Response to Comments from Robert Baderian of First Tee Greater Pasadena, submitted via email March 2, 2023.

O4-1 This comment expresses support for the Project. The comment will be provided to the RBOC for its consider ation as part of its decision- making for this Project. No further response is required.

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COMMENT O5 - Nina Chomsky (LVAA) (7 pages)

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O5. Response to Comments from Nina Chomsky of Linda Vista-Annandale Association, submitted via email March 3, 2023.

O5-1 This comment states that the IS/MND does not provide a stable and “finite” description of the Project and cites case law for the stopthemillenniumhollywood.com v City of Los Angeles. Comparison of the Project analyzed in the IS/MND to the case law cited is not comparable here, where that project included a land use equivalency review in a project description with multiple scenarios. That is n ot applicable here. While the commenter asserts there is misleading and insufficient information, they provide no specific detail or information that is lacking or is contradictory in nature. The Project evaluates a conceptual site plan, a project site for which all potential activities would occur, operational details, and construction information. While there is not a “final approved design” available at the time the IS/MND was prepared, nor does CEQA require such, all components of the Project have been adequately disclosed and properly evaluated. In lieu of having a “final approved design,” the IS/MND appropriately analyzes what the maximum extent of physical impacts to the environment would be from Project implementation. The scope and details of the Project are clearly detailed and sufficient for which to inform the public, conduct a comprehensive analysis, and impose mitigation measures where necessary.

Regarding tree removals, the IS/MND appropriately determines a maximum extent of physical impacts a ssociated with the Project. The IS/MND also details the process for future implementation of the Project, which includes City issuance of a Conditional Use Permit (CUP). As part of the City’s process to issue a future CUP, the City will be required to revi ew the IS/MND and make findings that the CEQA review addresses the final design and that all impacts and mitigation measures are appropriate. Approval of this CEQA document does not replace the need for the RBOC to comply with mitigation measures and comply with the various policies and regulatory requirements set forth by the City of Pasadena.

Please also see Topical Response 1, Unstable Project Description , regarding the required contents of the Project Description, which in this IS/MND, contains sufficient information to inform the public about all elements of the Project – from design, through construction, and long-term operation – and to adequately analyze environmental impacts of Project implementation and define appropriate mitigation.

O5-2 This comment states that the IS/MND defers mitigation measures and states that the regulatory processes in place that assure City policies and objectives are met, is deferral of mitigation. This is not the case. The processes set forth by the Urban Forestry Advisory Commission (UFAC), City of Pasadena Design Commission, and City Manager are regulatory requirements imposed on this and all projects. Reliance on these requirements, and applying mitigation measures where needed in the event of significant impacts, is appropriate and adequate.

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O5-3 This comment states that the IS/MND does not fully study and analyze lighting impacts of the Project as it relates to wildlife, and cites the Central Arroyo Seco as an environmentally sensitive recreational area subject to Ro se Bowl Stadium events and activities, and cites the City of Land Use Element goal 10.11 around the balance of land uses and activities. The comment assumes, without basis, there will be a permanent night glow resulting from the Project, and implies that t his is a natural area that is devoid of lighting in the existing condition. On the contrary, there is lighting throughout the Central Arroyo, associated with the Rose Bowl Stadium, the Rose Bowl Loop, the parking lots, the Rose Bowl Aquatic Center, the numerous Jackie Robinson sports fields, and other uses. It is the most highly activated recreational area in Pasadena, including for evening events.

Additionally, there are a multitude of events that occur throughout the year at the Rose Bowl Stadium and Brookside Golf Course itself, which include substantial event lighting.

As demonstrated in the IS/MND, the Project applies the appropriate threshold used for all projects in the City of Pasadena, including other projects in the Central Arroyo. In this case, the Project would have a significant impact on neighboring areas if the site lighting produces an illuminance of greater than 1.0 foot-candle on any residential property. The lighting assessment included in the IS/MND demonstrates that the light loss spill factor would be 0.95, less than the 1-foot candle threshold, at the property line – and will not be lit all night, as implied by the comment. Given the precise lighting specifications are not known at this time (nor required to be known), the IS/MND requir es a quantified, measurable mitigation measure with performance standards in place that must be met before lighting is installed (see mitigation measure AES-1). Additionally, there is a discussion regarding impacts to wildlife from lighting which is addres sed beginning on page 45 of the IS/MND, and mitigation measure BIO -2 is required in order to reduce potential lighting impacts. The RBOC must, through adoption of this mitigation measure, enforce and demonstrate compliance and will do so as the Lead Agency for this project. The commenter has no basis to assume that the RBOC will not enforce the mitigation measures it adopts. Please also see Topical Response 2, Lighting, regarding the City’s lighting regulations and how the Project complies with all policies regarding lighting, and requires additional mitigation measures to ensure impacts associated with lighting would be less -than-significant. As such, the IS/MND includes a well- supported impact assessment (including appropriate performance-based mitigation) to ensure that impacts related to lighting would be less than significant.

In addition, p lease see Topical Response 4, Land Use and Planning , regarding how implementation of the Project would comply with the Arroyo Seco Master Plan and the Arroyo Seco Public Lands Ordinance.

O5-4 This comment states that the project does not adequately analyze noise and lighting impacts that could result from the Project. Please see response to comment O5-3 above, Topical Response 2, Lighting, and Topical Response 5, Noise, regarding the City’s lighting and noise regulations and how the Project complies with required policies and regulations

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and sets forth appropriate enforceable mitigation measures where appropriate . With respect to noise, it is worth noting that P roject involves a continuation of the same golf uses that have occurred on the site for decades – there is no change in use. It is a golf project on an existing golf course.

O5-5 This comment states that the Project fails to consider and apply the Arroyo Seco Public Lands Ordinance. Please see Topical Response 4, Land Use and Planning , regarding how implementation of the Project would comply with the Arroyo Seco Master Plan and the Arroyo Seco Public Lands Ordinance.

O5-6 This comment states that the use of a MND for the Project is inadequate, and instead the RBOC should prepare and Environmental Impact Report (EIR). All issues raised by the commenter have been thoroughly addressed in the responses herein and there remains no credible evidence that the Proj ect, which includes improvements to the existing driving range serving an existing golf demand, and a miniature golf course entirely within the limits of the existing golf course on one acre, would result in significant unavoidable impacts. In accordance w ith CEQA Guidelines Section 15070, a mitigated negative declaration can be prepared when a lead agency, the RBOC in this case, has identified potentially significant effects on the environment, but (1) revisions in the project plans or proposals made by, or agreed to by, the applicant before the proposed negative declaration and initial study are released for public review would avoid the effects or mitigate the effects to a point where clearly no significant effect on the environment would occur, and (2) there is no substantial evidence in light of the whole record before the public agency that the project, as revised, may have a significant effect on the environment.

All potentially significant impacts have been adequately disclosed, addressed and mitigated. Therefore, the IS/MND remains the appropriate level of environmental documentation for the Project.

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COMMENT O6 - Tim Martinez (Arroyo & Foothills Conservancy) (6 pages)

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O6. Response to Comments from Tim Martinez of the Arroyo & Foothills Conservancy, submitted via email March 3, 2023.

O6-1 This comment states that that the IS/MND does not adequately consider impacts to wildlife in the Arroyo Seco. The commenter states that the proposed outdoor lighting and LED lighting will have a negative effect on wildlife species and habitats. The commenter recommends that additional mitigation measures should be considered for the Project, and should consider direction, duration, intensity, and spectrum of the proposed lighting to reduce impacts on wildlife. As demonstrated in the IS/MND, the Project appl ies the appropriate threshold used for all projects in the City of Pasadena, including other projects in the Central Arroyo. In this case, the Project would have a significant impact on neighboring areas if the site lighting produces an illuminance of grea ter than 1.0 foot - candle on any residential property. The lighting assessment included in the IS/MND demonstrates that the light loss spill factor would be 0.95, less than the 1 -foot candle threshold, at the property line. Given the precise lighting specifications are not known at this time (nor required to be known), the IS/MND requires a quantified, measurable mitigation measure with performance standards in place that must be met before lighting is installed (see mitigation measure AES- 1). As described i n mitigation measure AES -1, upon design of the Project, including both miniature golf and the driving range, RBOC will prepare a quantified lighting study, which would consider the four lighting attributes described in “Hazard or Hope? LEDs and Wildlife” b y Travis Longcore, including direction, duration, intensity, and spectrum, to ensure that the Project would not result in additional environmental impacts. Additionally, there is a discussion regarding impacts to wildlife from lighting which is addressed b eginning on page 45 of the IS/MND, and mitigation measure BIO-2 is required in order to reduce potential lighting impacts. The RBOC must, through adoption of this mitigation measure, enforce and demonstrate compliance and will do so as the Lead Agency for this project. Please also see Topical Response 2, Lighting, regarding the City’s lighting regulations and how the Project complies with all policies regarding lighting, and requires additional mitigation measures to ensure impacts associated with lighting would be less -than-significant. As such, the IS/MND includes a well- supported impact assessment (including appropriate performance -based mitigation) to ensure that impacts related to lighting would be less than significant .

O6-2 This comment states that the Project should consider noise impacts to wildlife that pass through the Arroyo Seco and Brookside Golf Course during operation of the driving range and miniature golf course. Please Topical Response 5, Noise, regarding the City’s noise regulations and how the Project complies with required policies and regulations. No amplified sound is proposed for the Project. The Project involves a continuation of the same golf uses that currently occur on the Project Site. Therefore, operational noise and vibration levels would be similar to existing conditions.

O6-3 The commenter states that the “Surrounding Land Uses and Setting” section should include a description of the Arroyo Seco Wildlife Corridor. This description is included

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in Section 3.4, Biological Resourc es, of the IS/MND. As stated on page 46, t he Arroyo Seco channel, which would be located along the western edge of the Project Site, could serve as a suitable corridor for native resident wildlife to move through the area, particularly medium to large mamm als such as coyote, bear, deer, and mountain lion.

Therefore, no revisions to the IS/MND are necessary.

O6-4 This comment states that this comment does not adequately address impacts of habitat loss that would occur from the removal of trees within the Project Site. Additionally, the commenter questions how Project impacts can be considered less than significant if the ultimate Project design has not been fully developed yet. As discussed in Appendix C, Biological Resources Assessment, w hile the databases i dentified species have been previously documented within or in close proximity to the survey area (most in the early- to mid-1900’s), in its current state, suitable habitat within the Project Site is not present.

As such, since the Brookside Golf Course includes landscaped vegetation, developed land uses, and unvegetated concrete-lined channel, the Project Site would not be considered a natural habitat. Additionally, as discussed on page 45 of the IS/MND, implementation of Measures MM -BIO-1 would ensure avoid ance of impacts to nesting birds during construction as well as any potential indirect impacts that may be created by the Project.

A qualified biologist will conduct a nesting bird survey within 3 days prior to the proposed start date, to identify any active nests within 500 feet of the Project Site. If an active nest is found, the nest shall be avoided, and a suitable buffer zone shall be delineated in the field such that no impacts shall occur until the chicks have fledged the nest as determined by a qualified biologist. Please see Topical Response 3, Tree Removal and Wildlife, regarding the procedures that would be taken by the RBOC to minimize potential impacts to wildlife within the Project Site.

In regards to the commenter’s question about the ult imate design of the Project, t he Project evaluates a conceptual site plan, a project site for which all potential activities would occur, operational details, and construction information. While there is not a “final approved design” available at the time the IS/MND was prepared, nor does CEQA require such, all components of the Project have been adequately disclosed and properly evaluated. In lieu of having a “final approved design,” the IS/MND appropriately analyzes what the maximum extent of physical impacts to the environment would be from Project implementation. The scope and details of the Project are clearly detailed and sufficient for which to inform the public, conduct a comprehensive analysis, and impose mitigation measures where necessary.

Regarding tree removals, the IS/MND appropriately determines a maximum extent of physical impacts associated with the Project. The IS/MND also details the process for future implementation of the Project, which includes City issuance of a Conditional Use Permit (CUP). As part of the City’s process to issue a future CUP, the City will be required to review the IS/MND and make findings that the CEQA review addresses the final design and that all impacts and mitigation measures are appropriate. Approval of this

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CEQA document does not replace the need for the RBOC to comply with mitigation measures and comply with the various policies and regulatory requirements set forth by the City of Pasadena.

Please also see Topical Response 1, Unstable Project Description , regar ding the required contents of the Project Description, which in this IS/MND, contains sufficient information to inform the public about all elements of the Project – from design, through construction, and long-term operation – and to adequately analyze environmental impacts of Project implementation and define appropriate mitigation.

O6-5 This comment states that the removal of trees within the Project Site and implementation of hardscape and artificial turf conflict with the Central Arroyo Master Plan. As stewards of the Brookside Golf Course and the over 1,400 trees that have been planted, relocated, or removed; the RBOC as a matter of practice, works in close cooperation with the City’s Urban Forestry Advisory Committee (UFAC), Planning and Community Deve lopment Department, and City Manager, who has ultimate approval authority for removal of any trees. The RBOC must and will continue in that management role, particularly to protect public safety regarding unsafe or dying trees, regardless of whether the Pr oject is ultimately approved. Please see Topical Response 3, Tree Removal and Wildlife, regarding the procedures that would be taken by the RBOC to minimize potential impacts to trees within the Project Site.

O6-6 This comment states that implementation of the miniature golf course adjacent to the Arroyo Seco Channel would impede future Arroyo Seco stream restoration through the area, which would conflict with the Arroyo Seco Master Plan and the Arroyo Seco Design Guidelines. As described on page 80 of the IS/MND, the Arroyo Seco channel, a subgrade concrete -lined feature, crosses the Brookside Golf Course and forms the western boundary of the reoriented driving range. However, the Project would not require any construction within the channel, and would not result in indirect impacts to the channel. The increase in bays within the proposed driving range, as well as limited new impervious features associated with the miniature golf course, would result in an increase of impervious surfaces and would be similar to current conditions. Implementation of the Project, include the miniature golf course, would not impede any future restoration within the Arroyo Seco channel. Therefore, no revisions to the IS/MND are necessary.

O6-7 This comment states that the Project would conflict with the Arroyo Seco Design Guidelines of limiting construction of man- made objects, through the implementation of hardscape, structures, tree removal, and installation of artificial turf. The golf course area is not a wild and natural space, nor has it been for nearly 100 years. Implementation of the Project involves a continuation of the same golf uses that have occurred on the site for decades – there is no change in use; therefore, implementation of the Project would result in similar structures and objects that are currently located on the Project Site.

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2. Response to Comments

O6-8 This comment summarizes the concerns raised in the previous comments. Please see responses O6-1 through O6-7.

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2. Response to Comments
May 2023 Page 2-211
COMMENT O7 - Tim Brick (Arroyo Seco Foundation) (2 pages)

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2. Response to Comments

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2. Response to Comments
May 2023 Page 2-213
O7. Response to Comments from Tim Brick of the Arroyo Seco Foundation, submitted via email March 3, 2023.

O7-1 This comment states that the use of a [Mitigated] Negative Declaration (MND) for the Project is inadequate, and instead the RBOC should prepare and E nvironmental Impact Report (EIR). As addressed in the responses below, the commenter does not provide a fair argument that implies the project would result in significant unavoidable impacts.

Please see responses to comments below.

O7-2 This comment states that the RBOC needs to consider the natural beauty and character of the Arroyo Seco for future plans within the Project Site. As stated throughout the IS/MND, RBOC will ensure that the final design of the expanded and reoriented driving range and miniatu re golf course are compatible with existing design elements of the Brookside Golf Course Complex and are sensitive to the location within the Historic District, the Arroyo Seco, and the adjacent Rose Bowl. Additionally, the Project would be subject to the City’s Design Review process as defined in the Pasadena Municipal Code.

The Project includes enhancement to a one-acre portion of the existing golf course and to the driving range and would be consistent with the historical uses of the Brookside Golf Course. It should be noted that those historical uses at the golf course, spanning 100 years, include maintaining the public recreational area for public golf, public parking, and other recreational uses.

O7-3 This comment states that there is a possibility that the Project Site would flood in the future. The Project is a continued use of golf activities that have occurred along the Arroyo Seco for decades. The recent storm events and water within the channel did not affect the adjacent golf course uses. No inh abitable structures are proposed within the golf course. As described on page 80 of the IS/MND, the Arroyo Seco channel, a subgrade concrete -lined feature, crosses the Brookside Golf Course and forms the western boundary of the reoriented driving range. However, the Project would not require any construction within the channel, and would not result in indirect impacts to the channel. The majority of the Project would result in similar amounts of impervious surfaces as the existing driving range (all natural turf). The increase in bays within the proposed driving range, as well as limited new impervious features associated with the miniature golf course, would result in an increase of impervious surfaces; however, stormwater from the Project would flow to the existing stormwater drainage system within the Project Site, similar to current conditions. Thus, the Project would not create or contribute runoff water that would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff.

Additionally, as described on page 82 of the IS/MND, incorporation of landscaping and replacement of pervious surfaces would ensure that the Project would result in similar drainage patterns as the existing golf course and would not substantially increase the rate or amount of surface run-off in which would result in flooding on- or offsite. Therefore, no revisions to the IS/MND are necessary.

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2. Response to Comments

O7-4 This comment states that tree removal, increased lighting, and addi tional traffic would result in negative impacts in the Project Site. The comment provides no specific issue regarding the detailed technical analyses contained within the IS/MND regarding these topics. Please see Topical Response 3, Tree Removal and Wildlife , Topical Response 2, Lighting, and Topical Response 7, Transportation and Parking, O7-5 The commenter states that the IS/MND fails to adequately address the elements of the Project stated in response O7 -4. Please see previous response. Additionally, th e analysis contained in the IS/MND appropriately assumes the existing conditions present at the site, and not former natural conditions that were present before the development of the golf course, 100 years ago (see Attachment B, Historic Photographs of Brookside Golf Course).

O7-6 This comment states that the RBOC needs to plan how to deal with the future effects of climate change, including the Arroyo Seco stream and canyon. The RBOC, nor this golf course project within the existing golf course, are resp onsible for restoration of the Arroyo Seco channel. That is outside the scope of this IS/MND and the RBOCs jurisdiction. The comment’s recommendation will be provided to the RBOC for its consideration as part of its decision- making for this project. Howeve r; this comment is not a direct comment on the Project or adequacy of the IS/MND; therefore, no further response is required.

O7-7 This comment requests that the RBOC should not ignore community support for the Project, and that the lack of care and improvements contained in the Project undermine the credibility of the RBOC. The comment provides no specific issue regarding the detailed technical analyses contained within the IS/MND regarding these topics. T his comment is not a direct comment on the content or adequacy of the IS/MND; therefore, no further response is required.

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2. Response to Comments
May 2023 Page 2-215

2.2.2 Responses to Verbal Comments
COMMENT R35 - Nina Chomsky
R35. Response to Comments from Nina Chomsky, submitted verbally on February 13, 2023. Please also see responses to Comment Letter O5, provided by the same commenter.

R35-1 The commenter states that the Project Description is not complete, and does not provide sufficient information regarding design and mitigation for the Project. Please see Topical Response 1, Unstable Project Descri ption, and response to comment O5 -2, regarding the required contents of the Project Description, which in this IS/MND, contains sufficient information to inform the public about all elements of the Project – from design, through construction, and long-term operation – and to adequately analyze environmental impacts of Project implementation and define appropriate mitigation.

R35-2 The commenter states that the Project does not comply with the Arroyo Seco Public Lands Ordinance which bans commercialization o f the Arroyo Seco. Please see Topical Response 4, Land Use and Planning , and response to comment O5 -5, regarding how implementation of the Project would comply with the Arroyo Seco Master Plan and the Arroyo Seco Public Lands Ordinance.

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2. Response to Comments

COMMENT R36 - Bill Fennessy
R36. Response to Comments from Bill Fennessy, submitted verbally on February 13, 2023.

R36-1 The commenter expressed support of the project as long as the RBOC sets aside some of the revenue for the capital projects that the golf course requires and can maintain the E.O. Nay course at a Par 70. Please see Topical Response 6, Recreation , regarding the procedures that would be taken by the RBOC to minimize potential impacts to the recreational facilities in the P roject Site, including potential impacts to the E.O. Nay course.

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2. Response to Comments
May 2023 Page 2-217
COMMENT R37 - Doug Philbin
R37. Response to Comments from Doug Philbin, submitted verbally on February 13, 2023.

R37-1 The commenter does not support the Project because it will devalue the golf course. The Project would result in the golf course going from par 70 to par 69 and would not be a championship course anymore. Please see Topical Response 6, Recreation, regarding the procedures that would be taken by the RBOC to minimize potential impacts to the recreational facilities in the P roject Site, including potential impacts to the E.O. Nay course.

R37-2 The commenter states parking needs to be further studied for the project. Please see Topical Response 7, Transportation and Parking, which describes that IS/MND accurately assesses impacts related to transportation consistent with the CEQA Guidelines and the City’s adopted methodology, and also addresses comments received regarding parking.

R37-3 There needs to be lighting for nighttime use of the miniature golf course. P lease see Topical Response 2, Lighting, regarding the City’s lighting regulations and how the Project complies with all policies regarding lighting, and requires additional mitigation measures to ensure impacts associated with lighting would be less-than-significant.

R37-4 The commenter states that the purpose statement is misleading because the actual purpose is to regain revenues for the RB OC. The comment provides no specific issue regarding the detailed technical analyses contained within the IS/MND regarding these topics. This comment expresses concerns regarding financial analysis for the Project. The commenter’s statements will be provided to the RBOC for its consideration as part of its decision-making for this Project. This comment is not a direct comment on the content or adequacy of the IS/MND and does not raise a specific environmental issue. As directed by Section 15131(a) of the CEQA Guidelines, economic or social effects of a project shall not be treated as significant effects on the environment. Therefore, no further response is required.

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2. Response to Comments

COMMENT R38 - Craig Kessler
R38. Response to Comments from Craig Kessler, submitted verbally on February 13, 2023. Please also see responses to Comment Letter O11, provided by the same commenter.

R38-1 The commenter states that they will not oppose the Project. The comment provides no specific issue regarding the detailed technical analyses containe d within the IS/MND regarding these topics. The commenter’s statements will be provided to the RBOC for its consideration as part of its decision-making for this project. This comment is not a direct comment on the content or adequacy of the IS/MND and doe s not raise a specific environmental issue; therefore, no further response is required.

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2. Response to Comments
May 2023 Page 2-219
COMMENT R39 - Dianne Philibosian
R39. Response to Comments from Dianne Philibosian, submitted verbally on February 13, 2023.

R39-1 The commenter states light pollution cannot be mitigated without the lights being turned completely off. Please see Topical Response 2, Lighting, regarding the City’s lighting regulations and how the Project complies with all policies regarding lighting, and requires additional mitigation measures to ensure impacts associated with lighting would be less - than-significant.

R39-2 The commenter expresses concern that the Project will negatively impact wildlife in the Brookside Golf Course and the proposed tree removal would harm nesting birds in the area. Please see Topical Response 3, Tree Removal and Wildlife, regarding the procedures that would be taken by the RBOC to minimize potential impacts to trees and wildlife within the Project Site.

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2. Response to Comments

COMMENT R40 - Alan Behr
R40. Response to Comments from Alan Behr, submitted verbally on February 13, 2023.

R40-1 The commenter states that the RBOC should consider the implementation of a double- decker driving range to double capacity without requiring more space on the Project Site.

Please see Topical Response 8, Project Alternatives, the alternatives and how the IS/MND is sufficient in not evaluating environmental impacts of other alternatives. With respect to the alternative suggested, it would result in environmental impacts beyond those associated with the Project and created emergency access issues with the site.

R40-2 The commenter expresses concern regarding the increased lighting for the driving range and corresponding noise impacts that would result from the driving range’s pr oposed hours of operation. Please see Topical Response 2, Lighting, regarding the City’s lighting regulations and how the Project complies with all policies regarding lighting, and requires additional mitigation measures to ensure impacts associated with l ighting would be less- than-significant.

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2. Response to Comments
May 2023 Page 2-221
COMMENT R41 - Betsy Nathane
R41. Response to Comments from Betsy Nathane, submitted verbally on February 13, 2023.

R41-1 This comment expresses the commenter’s opposition to the Project due to the required removal of trees located within the Arroyo Seco. Please see Topical Response 3, Tree Removal and Wildlife , regarding the procedures that would be taken by the RBOC to minimize potential impacts to trees and wildlife within the Project Site.

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2. Response to Comments

COMMENT R42 - Mark Whichard
R42. Response to Comments from Mark Whichard, submitted verbally on February 13, 2023.

R42-1 The commenter expresses concerns regarding the financial analysis fo r the Project. The commenter’s statements will be provided to the RBOC for its consideration as part of its decision-making for this project. This comment is not a direct comment on the content or adequacy of the IS/MND and does not raise a specific environmental issue. As directed by Section 15131(a) of the CEQA Guidelines, economic or social effects of a project shall not be treated as significant effects on the environment. Therefore, no further response is required.

R42-2 This commenter recommends an alternate location for the miniature golf course, possibly next to the Rose Bowl Aquatic Center. Please see Topical Response 8, Project Alternatives , regarding the alternatives and how the IS/MND is sufficient in not evaluating environmental impacts of other alternatives.

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2. Response to Comments
May 2023 Page 2-223
COMMENT R43 - Jaime Scott
R43. Response to Comments from Jaime Scott, submitted verbally on February 13, 2023.

R43-1 The commenter opposes lighting be extended from 6:30 pm ( current) to 10:00 pm (proposed). Topical Response 2, Lighting, regarding the City’s lighting regulations and how the Project complies with all policies regarding lighting, and requires additional mitigation measures to ensure impacts associated with lighting would be less-than-significant.

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2. Response to Comments

COMMENT R44 - Felix Brenden
R44. Response to Comments from Felix Brenden, submitted verbally on February 13, 2023.

R44-1 This comment states the commenter’s opposition to the removal of trees for the Project.

Please see Topical Response 3, Tree Removal and Wildlife, regarding the procedures that would be taken by the RBOC to minimize potential impacts to trees within the Project Site.

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2. Response to Comments
May 2023 Page 2-225
COMMENT R45 - Philip Jespersen
R45. Response to Comments from Philip Jespersen, submitted verbally on February 13, 2023.

R45-1 This comment expresses support for the Project because it will be kid/family friendly.

The comment provides no specific issue regarding the detailed technical analyses contained within the IS/MND regarding these topics. The comments in support of the Project are acknowledged and will be provided to the RBOC for its consideration as part of its decision-making for this Project. No further response is required.

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2. Response to Comments

COMMENT R46 - Mario
R46. Response to Comments from Mario, submitted verbally on February 13, 2023.

R46-1 This comment expresses support for the Project because it will be kid/family friendly.

The comment provides no specific issue regarding the detailed technical analyses contained within the IS/MND regarding these topics. The comments in support of the Project are acknowledged and will be provided to the RBOC for its consideration as part of its decision-making for this Project. No further response is required.

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2. Response to Comments
May 2023 Page 2-227
COMMENT R47 - Kelly Holmes
R47. Response to Comments from Kelly Holmes, submitted verbally on February 13, 2023.

R47-1 This comment expresses concern regarding the trees and wildlife , a nd would like the project to be further reviewed. Please see Topical Response 3, Tree Removal and Wildlife, regarding the procedures that would be taken by the RBOC to minimize potential impacts to trees and wildlife within the Project Site.

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2. Response to Comments

COMMENT R48 - Patty Brugman
R48. Response to Comments from Patty Brugman, submitted verbally on February 13, 2023.

R48-1 This commenter is concerned about the heights of the fences and would prefer height restricted balls for the driving range. The comment provides no specific issue regarding the detailed technical analyses contained within the IS/MND regarding these topics. The commenter’s statements will be provided to the RBOC for its consideration as part of its decision-making for this project. However, this comment is not a direct comment on the content or adequacy of the IS/MND and does not raise a specific environmental issue; therefore, no further response is required.

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2. Response to Comments
May 2023 Page 2-229
COMMENT O8 - Nina Chomsky (Linda Vista-Annandale Association) O8. Response to Comments from Nina Chomsky from Linda Vista-Annandale Association, submitted verbally on February 13, 2023. Please also see responses to Comment Letter O5, provided by the same commenter.

O8-1 This comment states that the appropriate document for the Project would be a focused Environmental Impact Report, not an IS/MND. Refer to response to comment O2 -6 above.

O8-2 This comment expresses concern that the lights are going to be on all the time , resulting in permanent lighting in the Central Arroyo due to the proposed hours of operation.

Please see Topical Response 2, Lighting, regarding the City’s lighting regulations and how the Project complies with all policies regarding lighting, and requires additional mitigation measures to ensure impacts associated with lighting would be less-than-significant.

O8-3 This comment states that a focused EIR would provide alternatives to the Project and should have been considered for the Project. Please see Topical Response 8, Project Alternatives, regarding the alternatives and how the IS/MND is sufficient in not evaluating environmental impacts of other alternatives.

O8-4 This comment states that LVAA is concerned with the amount of trees that would be cut down for the Project. Please see Topical Response 3, Tree Removal and Wildlife, regarding the procedures that would be taken by the RBOC to minimize potential impacts to trees within the Project Site.

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2. Response to Comments

COMMENT O9 - Pete Ewing (West Pasadena Residents Association) O9. Response to Comments from Pete Ewing from the West Pasadena Residents Association), submitted verbally on February 13, 2023. Please also see responses to Comment Letter O1, provided by the Evan Davis of the WPRA.

O9-1 The commenter states that it is a problem that the Project is not fully designed. Please refer to comment response O1 -2 above, regarding the required contents of the Project Description, which in this IS/MND, contains sufficient information to inform the public about all elements of the Project – from design, through construction, and long -term operation – and to adequately analyze environmental impacts of Project implementation and define appropriate mitigation.

O9-2 The commenter states that the proposed lights will be intrusive to residents, and there will be amplified noise from the Project. Please see Topical Response 2, Lighting, and Topical Response 5, Noise, regarding the City’s lighting and noise regulations and how the Project complies with all policies regarding noise and lighting, and requires additional mitigation measures for potential lighting impacts, to ensure impacts associated with noise and lighting would be less-than-significant. No amplified noise is proposed.

O9-3 The commenter states that there is no analytical data for the financial costs of the Project.

The commenter’s statements will be provided to the RBOC for its consideration as part of its decision-making for this project. However; this comment is not a direct comment on the content or adequacy of the IS/MND and does not raise a specific environmental issue. As directed by Section 15131(a) of the CEQA Guidelines, economic or social effects of a project shall not be treated as significant effects on the environment. Therefore, no further response is required.

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2. Response to Comments
May 2023 Page 2-231
COMMENT O10 - Tim Brick (Arroyo Seco Foundation)
O10. Response to Comments from Tim Brick from Arroyo Seco Foundation, submitted verbally on February 13, 2023. Please also see responses to Comment Letter O7, provided by the same commenter.

O10-1 The commenter expresses concern with the trees that would be removed from the Project Site. Please see Topical Response 3, Tree Removal and Wildlife, regarding the procedures that would be taken by the RBOC to minimize potential impacts to trees within the Project Site.

O10-2 The commenter states that the RBOC is ignoring the flood channel located adjacent to the Project Site, which would eventually flood because the flood cha nnel does not have the capacity to handle the flooding that will eventually occur. As described on page 80 of the IS/MND, the Arroyo Seco channel, a subgrade concrete -lined feature, crosses the Brookside Golf Course and forms the western boundary of the reoriented driving range.

However, the Project would not require any construction within the channel, and would not result in indirect impacts to the channel. The majority of the Project would result in similar amounts of impervious surfaces as the existing driving range (all turf). The increase in bays within the proposed driving range, as well as limited new impervious features associated with the miniature golf course, would result in an increase of impervious surfaces; however, stormwater from the Project would flow to the existing stormwater drainage system within the Project Site, similar to current conditions. Thus, the Project would not create or contribute runoff water that would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff. Additionally, as described on page 82 of the IS/MND, incorporation of landscaping and replacement of pervious surfaces would ensure that the Project would result in similar drainage patterns as t he existing golf course and would not substantially increase the rate or amount of surface run -off in which would result in flooding on- or offsite.

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2. Response to Comments

COMMENT O11 - Craig Kessler (Southern California Golf Association) O11. Response to Comments from Craig Kessler from the Southern California Golf Association, submitted verbally on February 13, 2023. Please also see responses to Comment Letter R38, provided by the same commenter.

O11-1 The commenter states that they are warm to the concept and understand concern. The express confidence that p arking and lighting expressed during the meeting will be resolved. Please see Topical Response 7, Transportation and Parking, which describes that IS/MND accurately assesses impacts related to transportation consistent with the CEQA Guidelines and the City’s adopted methodology, and also addresses comments received regarding parking. Additionally, please see Topical Response 2, Lighting , regarding the City’s lighting regulations and how the Project complies with all policies regarding lighting, and requires additional mitigation measures to ensure impacts associated with lighting would be less-than-significant.

O11-2 Commenter states that trees on the golf course are regularly removed. That trees on golf courses are often replaced, have come, have gone, and this will continue. Please see Topical Response 3, Tree Removal and Wildlife, regarding the procedures that would be taken by the RBOC to minimize potential impacts to trees within the Project Site O11-3 This comment expresses financial concerns regarding the Project. The commenter’s statements will be provided to the RBOC for its consideration as part of its decision- making for this project. However; this comment is not a direct comment on the content or adequacy of the IS/MND and does not raise a specific environmental issue. As directed by Section 15131(a) of the CEQA Guidelines, economic or social effects of a project shall not be treated as significant effects on the environment. Therefore, no further response is required.

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2. Response to Comments
May 2023 Page 2-233
COMMENT O12 - Andy Gantner (Linda Vista-Annandale Association) O12. Response to Comments from Andy Gantner from the Linda Vista-Annandale Association), submitted verbally on February 13, 2023. Please also see responses to Comment Letter O5, provided by Nina Chomsky of LVAA.

O12-1 The commenter is concerned with the number of trees that would be removed for the project. The commenter asked if the trees that are removed would be replaced. Please see Topical Response 3, Tree Removal and Wildlife, regarding the procedures that would be taken by the RBOC to minimize potential impacts to trees within the Project Site.

O12-2 The commenter expresses concerns regarding lighting and hours of operation. Until 10:00 p.m., seven days a week is too much, and suggests 8:00 p.m. as a compromise. Please see Topical Response 2, Lighting, regarding the City’s lighting regulations and how the Project complies with all policies regarding lighting, and requires additi onal mitigation measures to ensure impacts associated with lighting would be less-than-significant.

O12-3 The commenter is concerned with shortening of hole 6 and 7, and states that the removal of holes would diminish the value of the golf course. Please see the Topical Response 6, Recreation, regarding the procedures that would be taken by the RBOC to minimize potential impacts to the recreational facilities in the P roject Site, including potential impacts to the E.O. Nay course.

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2. Response to Comments

COMMENT O13 - Doug Philbin (Brookside Men’s Golf Club)
O13. Response to Comments from Doug Philbin from the Brookside Men’s Golf Club), submitted verbally on February 13, 2023. Please also see responses to Comment Letter R37, provided by the same commenter.

O13-1 The commenter expresses concern regarding reduction of the golf course from a par 70 to par 69, and that this reduction would devalue the property as it would no longer be a championship course. The project would eliminate the short key and practice areas. Please see Topical Response 6, Recreation , regarding the procedures that would be taken by the RBOC to minimize potential impacts to the recreational facilities i n the Project Site, including potential impacts to the E.O. Nay course.

O13-2 The commenter expresses conce rns regarding financial analysis for the Project. The commenter’s statements will be provided to the RBOC for its consideration as part of its decision-making for this project. However; this comment is not a direct comment on the content or adequacy of the IS/MND and does not raise a specific environmental issue .

As directed by Section 15131(a) of the CEQA Guidelines, economic or social effects of a project shall not be treated as significant effects on the environment. Therefore, no further response is required.

O13-3 The commenter states that parking is not adequately addressed and that it is not realistic to park in outer parking lots for families and golfers. Please see Topical Response 7, Transportation and Parking , which describes that IS/MND accurately assesses impacts related to transportation consistent with the CEQA Guidelines and the City’s adopted methodology, and also addresses comments received regarding parking.

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2. Response to Comments
May 2023 Page 2-235
COMMENT O14 - Geoffrey Baum (West Pasadena Residents Association) O14. Response to Comments from Geoffrey Baum from the West Pasadena Residents Association), submitted verbally on February 13, 2023. Please also see responses to Comment Letter O2, provided by the same commenter.

O14-1 The commenter expresses they are not opposed to concept of ideas to generating revenue.

Concerns expressed by the commenter include insufficient community input, and meetings but no dialogue. The commenter recommends that the RBOC should pause the Project. Please refer to comment response O1 though O8 above.

O14-2 The commenter expressed concerns regarding noise. Please see Topical Response 5, Noise, regarding the City’s noise regulations and how the P roject complies with all policies regarding noise to ensure impacts associated with noise would be less-than-significant.

O14-3 The commenter expressed concerns regarding light , the proposed hours of operation, and if the lights would bleed into the neighborhood. Please see Topical Response 2, Lighting, regarding the City’s lighting regulations and how the Project complies with all policies regarding lighting, and requires additional mitigation measures to ensure impacts associated with lighting would be less-than-significant.

O14-4 The commenter expressed concern regarding the commercialization of the Arroyo Seco.

Please see Topical Response 4, Land Use and Planning, regarding how implementation of the Project would comply with the Arroyo Seco Master Plan and the Arroyo Seco Public Lands Ordinance.

O14-5 The commenter expressed concerns regarding the scale of the miniature golf course. As described on page 10 of the IS/MND, the Project includes development of a 36 -hole miniature golf course on approximately one acre (approximate 0.4 percent of the Brookside Golf Course) within the footprint of the existing driving range (relatively flat grassy area). Concept ideas for the design of the miniature golf course are provided in Appendix A to this document, which were shared during the public informational meeting on date. The location of the miniature golf course is designed to minimize impacts to the remainder of the golf course, and to maintain proximity to the Brookside Clubhouse and parking areas.

The design of the miniature golf area, however, would differ from a typical putting green, incorporating a complex arrangement of pathways and landscape elements with intermittent objects and structures.

O14-6 The commenter states that the IS/MND does not provide an accurate or stable project description. Please see Topical Response 1, Unstable Project Description , and response to comment O5-1, regarding the required contents of the Project Description, which in this IS/MND, contains sufficient information to inform the public about all elements of the Project – from design, through construction, and long-term operation – and to adequately

BROOKSIDE GOLF COURSE IMPROVEMENTS PROJECT IS/MND RESPONSE TO COMMENTS

ROSE BOWL OPERATING COMPANY

2. Response to Comments

analyze environmental impacts of Project implementation and define appropriate mitigation.

O14-7 This comment expresses concerns regarding financial analysis for the Project. The commenter’s statements will be provided to the RBOC for its consideration as part of its decision-making for this project. However; this comment is not a direct comment on the content or adequacy of the IS/MND and does not raise a specific environmental issue .

As directed by Section 15131(a) of the CEQA Guidelines, economic or social effects of a project shall not be treated as significant effects on the environment. Therefore, no further response is required.

May 2023 Page 3-1

3. Revisions to the Initial Study/Mitigated Negative
Declaration

3.1 INTRODUCTION
This section contains revisions to the IS /MND based on (1) additional or revised information required to prepare a response to a specific comment, (2) applicable updated information that was not available at the time of IS/MND publication, and/or (3) typographical errors. Changes made to the IS/MND are identified here in strikeout text to indicate deletions and in double underlined text to signify additions.

3.2 IS/MND REVISIONS IN RESPONSE TO WRITTEN COMMENTS
The following text has been revised in response to comments received on the IS/MND.

Changes; Page 16, Section 1.5.5, Construction Activities ; and Page 106, Section 3.17, Transportation, are hereby modified based on comments received.

Parking Lot 1A in the IS/MND will be revised to Parking Lot CH.

As part of the reorientation of the driving range, some trees could be removed and/or relocated, which would be subject to review and approval by the City’s Urban Forestry Advisory Committee (UFAC), and the City Manager. Surficial grading would be required (no excavation) over the total approximately 16-acre Project Site.

All soils would be balanced onsite, and no soil export would be required. Consistent with all other Rose Bowl construction and production delivery, any construction vehicles entering the area would use the Mountain/Seco exit off I-210 for ingress and egress.

The Project Site is located within lands designated as Open Space by the Pasadena General Plan Land Use Element, primarily surrounded by land uses designated as Low Density Residential (0 -6 DU/Acre)(City of Pasadena 2016). According to the Pasadena General Plan Land Use Element, the Open Space classification is intended to provide active and passive recreational opportunities for Pasadena’s residents, and is characterized by a variety of public and private natural and developed open spaces including City-owned open space facilities,

BROOKSIDE GOLF COURSE IMPROVEMENTS PROJECT IS/MND RESPONSE TO COMMENTS

ROSE BOWL OPERATING COMPANY

3. Revisions to the Initial Study/Mitigated Negative Declaration

private golf courses, natural open spaces and areas which have been designated as environmentally and ecologically significant, and land which is publicly owned though in some instances public access may be restricted (City of Pasadena 2016). Implementation of the Project would expand the existing driving and develop and new miniature golf course within the existing Brookside Golf Course; however, the Project would continue to provide recreational uses and would continue to maintain the Open Space land use designation and zone. The Project would be consistent with Chapter 3.32, Arroyo Seco Public Lands, of the Pasadena Municipal Code. Implementation of the miniature golf course and reorientation of the driving range would result in continued golf uses on the Project Site, in compliance with Section 3.32.460, Brookside Golf Course Area – Permitted Uses, which permits golf uses within the Brookside Golf Course. Additionally, Section 3.32.060(c) states that no portion of lands within the Arroyo Seco shall be used for any commercial, industrial or institutional purposes other than those which existed at the effective date of the ordinance codified in this chapter. However, the Brookside Golf Course has been in operation as a public golf course within the Arroyo Seco since 1928. Implementation of the Project would not introduce new commercial establishments to the Project Site but would operate with recreational uses similar to what already exists on the Brookside Golf Course. Thus, the Project would be consistent with the Arroyo Seco Public Lands Ordinance. This is consistent with the Pasadena General Plan and the Municipal Code. Thus, the Project would not conflict with any land use plans, policies, or regulations adopted for the purpose of avoiding or mitigating an environmental effect.

B R O O K S I D E G O L F C O U R S E I M R P O V E M E N T S I N I T I A L S T U D Y R E S P O N S E T O C O M M E N T S

R O S E B O W L O P E R A T I N G C O M P A N Y
May 2023
Attachment A. Informational Community Meeting
Presentation

BROOKSIDE G OLF COURSE
February 13, 2023

P U B L I C I N F O R M A T I O N M E E T I N G
AGENDA
x Team Introductions
x Overview of Proposed Project
x Outreach Summary
x CEQA Process
x Initial Study/MND Content
x Public Comment
x Next Steps

TEAM

INTRODUCTIONS
x Rose Bowl Operating Company
¾ Jens Weiden, General Manager
¾ Brandon Fox, Director of Golf
Operations
¾ Jenessa Castillo, Chief Operations
Officer
• PlaceWorks – Independent CEQA
Consultant
¾ Addie Farrell, Project Director
¾ Alen Estrada-Rodas, Planner

PROJECT OVERVIEW
x RBOC proposes to reorient and expand the existing driving range and construct a new miniature golf facility within the existing driving range area at the Brookside Golf Course.

Project improvements would occur on 16 acres within the exiting driving range, Hole 10 of the C.W. Koiner Course, and Holes 6 and 7 of the E.O. Nay Course (Project Site). x The driving range would be expanded from 20 hitting bays to 60 hitting bays. Expanding the number of stalls would serve the existing demand of golfers.
x The driving range would include 56 total poles, including 20 existing poles to remain and 36 new poles to be installed.

The poles would support new netting and lighting (on 14 poles). Pole height would range from 38 feet to 130 feet above ground level (increasing height with distance from the hitting bays) with an average pole height of 90.67 feet. x The project would add 36 family-friendly holes of
miniature golf on approximately one acre within the
footprint of the existing driving range and adjacent to the Arroyo channel.
x The design of the miniature golf area would incorporate an arrangement of pathways and landscape elements.

PROJECT OVERVIEW
(Continued)
x New turf and modified irrigation system, as well as other minor landscape modifications would be installed. Site
furniture, signage, and markers would be updated. A new electrical service line with generator would be provided. x The RBOC is undertaking this environmental review
concurrent with a substantial allocation of public funds toward the Project, even though the RBOC is not yet ready to break ground. There is no final design of the project at this stage.
x The ultimate design would be subject to the City’s Design Review process as defined in the Pasadena Municipal Code to ensure compatibility policies and objectives of the
Arroyo Seco Design Guidelines and overall visual harmony with surroundings.
x Project is intended to serve existing demand on driving range and further engage the youth and community that
already live, recreate, and visit the Central Arroyo Seco area for recreational purposes. No new staff required.

Figure 2
Existing Project Site

Figure 3
Driving Range and
Miniature Golf
Conceptual Site Plan

Figure 4
Driving Range Poles
and Netting

Case Study
Examples:

Indianapolis
Children’s
Museum

Case Study
Examples:

Cox Science
Center

Case Study
Examples:

Heritage Asante
by
Lennar Homes

Case Study
Examples:

Popstroke

Case Study
Examples:

Valley Golf
Center Driving
Range

POSITIVE IMPACT FOR

FIRST TEE OFGREATER

PASADENA
The expansion and reorientation of the driving range, as well a s the addition to the 36 hole miniature golf course would create positive impact on the First T ee of Greater Pasadena. As a non-profit organization that annually
welcomes and services more than 40,000 youth and
veterans to the chapter’s programs through the game of
golf, these improvements at Brookside will undoubtedly
provide expanded areas for training, teaching, and
learning amongst all skill levels. The range expansion also accounts for the current range needs of the First T ee of Greater Pasadena enabling to continue their programing at Brookside.

OUTREACH
x 9/22/2021 – Pasadena Heritage Meeting
x 9/20/2022 – Virtual Neighborhood Meeting
x 10/4/2022 – Golf Committee Presentation
x 10/5/2022 – Golf Advisory Committee
x 10/5/2022 – Virtual West Pasadena Residents
Association Meeting
x 10/6/2022 – RBOC Board Presentation
x 10/11/2022 – Ladies Club EO Nay Presentation
x 10/11/2022 – Greens Committee Presentation
x 10/12/2022 – Ladies Club Presentation
x 11/8/2022 – Men’s Club Presentation
x 11/17/2022 – Linda Vista | Annandale
Association Resident In-Person Meeting
x 1/17/2023 – Mailer to 1k+ Residents
x 1/30/2023 – Email Men’s Club Database
x 1/30/2023 – Email RBOC Board and Stakeholders
x 2/1/2023 – Email 15k RBOC Resident Database
x 2/2/2023 – Email 27k in Brookside Database
x 2/13/2023 – Today’s Informational Meeting

CALIFORNIA ENVIRONMENTAL QUALITY ACT (CEQA)

ENVIRONMENTAL REVIEW
Informm thee Publicc
Facilitatee Interagencyy Coordination
Fosterr Communicationn inn Planning
Transparentt Communicationn
Reducee orr Avoidd Environmentall Impactss
Disclosee Reasonn forr Approvall Evenn iff
Significantt Environmentall Effects
¾ Rose Bowl Operating Company as Lead Agency under CEQA ¾ City of Pasadena Responsible Agency for future CUP and Design Review

CEQA PROCESS

MITIGATED NEGATIVE DECLARATION
RBOC Board
Hearing
Prepare
Response to
Comments
Approve
Project
Circulate
CEQA Document
(45-Day Public Review)
Deny
Project
Prepare
Concept Design &
Environmental Studies
Prepare CEQA
Environmental
Impact Analysis
Community
Information
Meeting
January 17 – March 3, 2023
Adopt CEQA
Document
Opportunities for
Public Input
RBOC Initiate Fundraising
Efforts
Hire Contractors
Develop Design
Ensure Consistency with
IS/MND
CUP from City
Ensure Consistency with
IS/MND
Design Review Process
Construction and
Implement Mitigation
Measures
Anticipated Spring 2023
We Are Here

INITIAL STUDY/MND
x Project Description and Background
x CEQA Process
x Analysis of 21 Topical Areas
x Supporting Technical Appendices
¾ Lighting Study
¾ Air Quality and Greenhouse Gas Modeling
¾ Biological Resources
¾ Historical Resources
¾ Noise
¾ Transportation
No Impact
x Agricultural and Forestry Resources
x Energy
x Hazards and Hazardous Materials
x Hydrology and Water Quality
x Land Use
x Mineral Resources
x Population and Housing
Less than Significant Impact
x Air Quality
x Geology and Soils
x Greenhouse Gas Emissions
x Noise
x Public Services
x Recreation
x Transportation
x Utilities
x Wildfire

AESTHETICS
Light and Glare
x Quantified Lighting Study
x 14 lighting poles
x LED technology, remote operated, precise lighting
directionality
x Low-level illumination from miniature golf
x Demonstrates lighting spill would not exceed 1 foot
candle
x Given no final design at this time, potentially
significant

MITIGATION MEASURES
Lighting plan for final design and further testing to
confirm no exceedance of 1 footcandle

BIOLOGICAL

RESOURCES
x Biological Survey and Research
x Tree Survey and Report
x Approx 47 Trees Potentially Removed
x Compliance with City Tree Ordinance

MITIGATION MEASURES
Preconstruction surveys for nesting raptors.

Ensure lighting is directed downward away
from trees.

CULTURAL

RESOURCES
Historical Resources
• First Opened in 1925
• National Register of Historical Places &
California Register of Historic Resources
• Contributing feature of Arroyo Park and
Recreation District
• Changes consistent with historical uses
• Changes to approx. 0.4% of District
• Uses consistent with historical use
x While no impact to integrity of resource, no
final design – therefore potential impact

MITIGATION MEASURES
RBOC to retain a qualified historic preservation
professional to ensure alterations to the driving
range, design of the miniature golf course, and
overall modifications to the Course are
compatible with the existing Brookside Golf
Course landscape, the Pasadena Arroyo Park
and Recreational District, and the Arroyo

TRIBAL AND

ARCHAEOLOGICAL

RESOURCES
x Consultation with Native American
tribes pursuant to AB 52
x Potential impacts from ground
disturbing activities in native soils

MITIGATION MEASURES
Tribal and archeological monitors
during construction activities.

PUBLIC COMMENTS
x State Name
x Limit to 3 Minutes
x Focus on Content of Initial Study/MND
x Accepting Comments through March 3, 2023
x Prepare Response to Comments
x RBOC Board to Consider Adoption (Anticipated Spring)
x Funding Æ Design Æ CUP Æ Design Review Æ Construction

HOW TO COMMENT
x Verbal or Written Comments During Meeting
x Email Comments to [email protected]
x RBOC Board Meeting March 2, 2023

NEXT STEPS

B R O O K S I D E G O L F C O U R S E I M R P O V E M E N T S I N I T I A L S T U D Y R E S P O N S E T O C O M M E N T S

R O S E B O W L O P E R A T I N G C O M P A N Y
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R O S E B O W L O P E R A T I N G C O M P A N Y
May 2023
Attachment B. Historic Photographs of Brookside
Golf Course

Source: Rose Bowl Operating Company, 2023
PlaceWorks

1. Brookside Golf Course - 1930’s 2. Brookside Golf Course - 1940’s 3. Brookside Golf Course - 1950’s

4. Brookside Golf Course - 1960’s 5. Brookside Golf Course - 1970’s Attachment B: Historic Photographs of Brookside Golf Course

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ROSE BOWL OPERATING COMPANY

B R O O K S I D E G O L F C O U R S E I M R P O V E M E N T S I N I T I A L S T U D Y R E S P O N S E T O C O M M E N T S

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R O S E B O W L O P E R A T I N G C O M P A N Y
May 2023
Attachment C. Existing Lighting at Brookside Golf Course

Source: Rose Bowl Operating Company, 2023
PlaceWorks

2. Driving Range View from Clubhouse.1. Brookside Golf Course Clubhouse. 3. W alkway towards Rosemont Avenue.

4. Golf Course View from Clubhouse. 5. Walkway towards Parking Lot CH from Driving Range and Clubhouse.

Attachment C: Existing Lighting at Brookside Golf Course

6. Walkway towards Driving Range.

BROOKSIDE GOLF COURSE IMPROVEMENTS INITIAL STUDY RESPONSE TO COMMENTS

ROSE BOWL OPERATING COMPANY
Source: Rose Bowl Operating Company, 2023
PlaceWorks

7. Walkway from Parking Lot CH to Clubhouse. 8. W alkway Towards Clubhouse from Parking Lot CH. 9. Parking Lot CH - Facing South.

10. Parking Lot CH - Facing North. 11. Walkway Towards Clubhouse from Parking Lot D. 12. Parking Lot D - Facing South.

BROOKSIDE GOLF COURSE IMPROVEMENTS INITIAL STUDY RESPONSE TO COMMENTS

ROSE BOWL OPERATING COMPANY
Attachment C: Existing Lighting at Brookside Golf Course

B R O O K S I D E G O L F C O U R S E I M R P O V E M E N T S I N I T I A L S T U D Y R E S P O N S E T O C O M M E N T S

R O S E B O W L O P E R A T I N G C O M P A N Y
May 2023
Attachment D. Potential Location of Trees to Be Removed

PlaceWorks
Source: Rose Bowl Operating Company, 2023
0 Scale (Feet)
320
Attachment D: Potential Locations of Trees to be Removed Rosemont AveRosemont Ave
Arroyo
Seco
Wash
Brookside
Clubhouse
Rosemont AveRosemont Ave

BROOKSIDE GOLF COURSE IMPROVEMENTS INITIAL STUDY RESPONSE TO COMMENTS

ROSE BOWL OPERATING COMPANY
Proposed Miniature Golf Course

B R O O K S I D E G O L F C O U R S E I M R P O V E M E N T S I N I T I A L S T U D Y R E S P O N S E T O C O M M E N T S

R O S E B O W L O P E R A T I N G C O M P A N Y
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R O S E B O W L O P E R A T I N G C O M P A N Y
May 2023
Attachment E. Parking Lot Locations and Improvements

PlaceWorks
Source: Nearmap, 2021
Project Site
West DrWest Dr
Rose Bowl DrRose Bowl Dr
SalviaSalviaCanyon RdCanyon Rd
Rose Bowl DrRose Bowl Dr
N Arroyo BlvdN Arroyo Blvd
Solita RdSolita Rd
Laurel StLaurel St
0 Scale (Feet)
400
Attachment E: Parking Lot Locations and Improvements
Rosemont AveRosemont Ave

BROOKSIDE GOLF COURSE IMPROVEMENTS INITIAL STUDY RESPONSE TO COMMENTS

ROSE BOWL OPERATING COMPANY
Zanja StZanja St
Armada DrArmada Dr
Armada DrArmada Dr
Richland PlRichland Pl
Rose Bowl
Stadium
Brookside
Clubhouse
Additional 50 Spaces
in Parking Lot D
Parking
Lot D
Parking Lot
CH
Parking
Lot B
Available Street Parking
along Rosemont Avenue
Brookside
Golf Course
Arroyo
Seco
Wash

B R O O K S I D E G O L F C O U R S E I M R P O V E M E N T S I N I T I A L S T U D Y R E S P O N S E T O C O M M E N T S

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