RESPONSES TO COMMENTS ON THE
INITIAL STUDY / MITIGATED NEGATIVE
DECLARATION & MITIGATION
MONITORING AND REPORTING
PROGRAM
740 –790 East Green Street
Mixed -Use Project
Prepared for:
City of Pasadena
175 North Garfield Avenue
Pasadena, California 91101-1704
Prepared by:
38 North Marengo Avenue
Pasadena, California 91101
JUNE 2023
ATTACHMENT E1
Printed on 30% post-consumer recycled material.
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TABLE OF CONTENTS
SECTION PAGE NO.
ACRONYMS AND ABBREVIATIONS ................................ ................................ ................................ .. III PREFACE ................................ ................................ ................................ ................................ ............. V 1 RESPONSES TO COMMENTS RECEIVED ................................ ................................ .............. 1 Response to Comment Letter No. 1 ................................ ................................ ................ 5 Response to Comment Letter No. 2 ................................ ................................ .............. 59 Response to Comment Letter No. 3 ................................ ................................ .............. 73 Response to Comment Letter No. 4 ................................ ................................ .............. 81 Response to Comment Letter No. 5 ................................ ................................ .............. 87 Response to Comment Letter No. 6-PC ................................ ................................ ........ 91 Response to Comment Letter No. 7 ................................ ................................ .............. 97 Response to Comment Letter No. 8 ................................ ................................ ............ 105 Response to Comment Letter No. 9-PC ................................ ................................ ...... 115 Response to Comment Letter No. 10 ................................ ................................ .......... 119 Response to Comment Letter No. 11 ................................ ................................ .......... 129 Response to Comment Letter No. 12 ................................ ................................ .......... 135 Response to Comment Letter No. 13-PC ................................ ................................ .... 139 Response to Comment Letter No. 14 ................................ ................................ .......... 143 Response to Comment Letter No. 15 ................................ ................................ .......... 147 2 OVERVIEW OF CHANGES TO THE IS/MND ................................ ................................ ........ 149 3 MITIGATION MONITORING AND REPORTING PROGRAM ................................ ................ 151 TABLES
1-1 List of Commenters ................................ ................................ ................................ ..................... 1 3-1 Mitigation Monitoring and Reporting Program Checklist ................................ ............................. 153
ATTACHMENTS
A-1 Revised IS/MND
A-2 Revised IS/MND Appendix A through H
B Transportation Impact Analysis, prepared by Pasadena Department of Transportation on February 24, 2022
C Protected Tree Report, prepared by Carlberg Associates on February 4, 2022
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ACRONYMS AND ABBREVIATIONS
Acronym/Abbreviation Definition
AAQS ambient air quality standards
CARB California Air Resources Board
CEQA California Environmental Quality Act
City City of Pasadena
DTSC Department of Toxic Substances Control
EIR Environmental Impact Report
ESA Environmental Site Assessment
FAR floor-to-area ratio
HMCP Hazardous Material Contingency Plan
IS/MND Initial Study/Mitigated Negative Declaration
LACSD Los Angeles County Sanitation Districts
LEED Leadership in Energy and Environmental Design
LOS level of service
MM Mitigation Measure
MMRP Mitigation Monitoring and Reporting Program
NO2 nitrogen dioxide
PD Planned Development
PM2.5 particulate matter less than or equal to 2.5 microns in diameter Project 740–790 East Green Street Mixed-Use Project
TDF Travel Demand Forecasting
UST underground storage tank
VMT vehicle miles traveled
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PREFACE
An Initial Study and proposed Mitigated Negative Declaration (IS/MND) for the proposed 740–790 East Green Street Mixed -Use Project (Project) was circulated for public review from December 3, 2020 to January 4, 2021. This document includes a copy of each comment letter that was received by the City of Pasadena (City) during the public review period for the IS/MND. The purpose of this document is to provide the City’s responses to the public comment s received during the review period, to show minor changes that have been made to the IS/MND since publication in December 2020 as a result of these comments, and to set forth a Mitigation Monitoring and Reporting Program (MMRP) for the proposed Project. In addition, the Project Applicant has withdrawn the Planned Development (PD) application and changed components of the proposed Project accordingly. The changes to the project description and other applicable sections are located in Section 2.0 of this Fina l MND. As part of this Final MND, the following attachments are included:
Attachment A Revised IS/MND
Attachment B Transportation Impact Analysis, prepared by Pasadena Department of Transportation on February 24, 2022
Attachment C Protected Tree Report, prepared by Carlberg Associates on February 4, 2022 The comment letters received during the public review period and the City’s associated responses are presented in Section 1.0 of this document. The changes that have been made to the IS/MND are shown in Section 2.0, and the MMRP constitutes Section 3.0. The MMRP has been prepared pursuant to California Environmental Quality Act (CEQA) Guidelines, Section 15074(d), which requires that a lead or responsible agency adopt a mitigation monitoring plan when approving or carrying out a project when an MND identifies measures to mitigate or avoid significant environmental effects.
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1 RESPONSES TO COMMENTS RECEIVED
The City has prepared responses to each comment received, which are ordered as presented in Table 1-1, List of Commenters. Each comment letter received has been categorized a nd labeled, then divided into sequential numbered comments (i.e., Letter 1, Comments 1 -1, 1 -2, 1 -3 etc.). The City’s responses to comments on the proposed IS/MND represent a good-faith, reasoned effort to address the environmental issues identified in the comments. Pursuant to State CEQA Guidelines Section 15074(b), the decision makers will consider the IS/MND together with the comment received during the public review process.
Table 1-1. List of Commenters
Comment
Letter Name Type Date
Federal or State Agencies
None N/A N/A
Regional or Local Agencies
1 Los Angeles County Sanitation Districts Regional
Agency
December 28, 2020
Organizations and Individuals
2 Rebecca L. Davis, Lozeau Drury LLP on
behalf of Supporters Alliance for
Environmental Responsibility (“SAFER”)
Organization January 18, 2021
3 David Diaz, MPH (ActiveSGV) Organization December 16, 2020 4 Richard A. McDonald, Esq.
(Carlson & Nicolas, LLP)
Organization December 10, 2020
5 Andrew Salimian (Pasadena Heritage) Organization December 17, 2020 6-PC Andrew Salimian (Pasadena Heritage) (2) Organization December 17, 2020 7 Barry Brenner Individual January 4, 2021
8 Nina Chomsky Individual January 17, 2021
9-PC Nina Chomsky Individual December 17, 2020
10 Christine Fedukowski Individual January 18, 2021
11 Erika Foy Individual January 15, 2021
12 Erika Foy Individual December 17, 2020
13-PC Mic Hansen Individual December 17, 2020
14 Joseph Paggi Individual December 10, 2020
15 Gail Price Individual December 22, 2020
N/A = not applicable
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Response to Comment Letter No. 1
Los Angeles County Sanitation Districts
Facilities Planning Department
Adriana Raza, Customer Service Specialist
December 28, 2020
1-1 This comment states the Los Angeles County Sanitation Districts ( LACSD) received the Notice of Intent to Adopt a Mitigated Negative Declaration for the proposed Proj ect. The comment further provides information and background on existing conditions and facilities serving the Project site. This comment does not contain any specific concerns related to the adequacy of the environmental analysis in the Initial Study/Mitigated Negative Declaration (IS/MND). However, t he information presented in the comment has been added to the IS/MND. These additions clarify minor facts and do not result in any new significant impacts or a substantial increase in the severity of any environmental impacts. See Attachment A to this Final MND for revisions to Section 2.19, Utilities and Service Systems, page 120. 1-2 This comment notes which wastewater facilities would serve the proposed Project and cites the anticipated average flow and capacity. The information presented in the comment has been added to the IS/MND. These additions clarify minor facts and do not result in any new significant impacts or a substantial increase in the severity of any environmental impacts .
Since the publication of the IS/MND, the Project Applicant has changed components of the proposed Project. For example, the Project would continue to include 263 residential units (including 41 affordable housing units). However, the Project has been revise d to include 14,346 square feet of office instead of 16,481 square feet of commercial uses. The revisions do not result in any new significant impacts or a substantial increase in the severity of any environmental impacts. See Response to Comment 1-3 and Section 2.0 of this Final MND for more details. See Attachment A to this Final MND for revisions to Section 2.19, Utilities and Service Systems, pages 125 and 126.
Furthermore, the commenter’s letter has now been cited in the IS/MND. Thus, Section 3.1, References Cited, of the IS/MND has been revised. See Attachment A to this Final MND for revisions to Section 3.1, page 136.
1-3 This comment states the Notice of Intent described the Project as 16,481 square feet of commercial and 264 residential units. The comment correctly cites the previously proposed square footage for commercial uses; however, the Project is proposing 263 units of residential.
The comment further cites LACSD’s average wastewater generation factors based on each class of land use designation and anticipates an average wastewater flow of 34,101 gallons per day after the structures on the Project site are demolished (LA CSD 2020). The calculations and particular generation factors were not specific by the comment. As noted, the comment incorrectly cited the number of residential units propos ed, thus the comment’s average wastewater flow of 34,101 gallons per day is not correct. Since the publication of the IS/MND, the Project Applicant has withdrawn the Planned Development application and changed components of the proposed Project. For exampl e, the Project would continue to include 263 residential units (including 41 affordable housing units); however, the Project has been revised to include 14,346 square feet of office instead of 16,481 square feet of 740-790 East Green Street Mixed-Use Project / Responses to Comments on the IS/MND & MMRP
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commercial uses. See Section 2.0 of this Final MND for more details. These revisions do not result in any new significant impacts or a substantial increase in the severity of any environmental impacts . Using the generation factors provided by LACSD, the previously proposed project would have result in approximately 57,509 gallons per day 1 (without considering the existing uses) and the revised Project is anticipated to result in 43,897 gallons per day.2 As such, the revised Project would generate less wastewater as compared to the previously proposed project.
1-4 This comment discussed LACSD’s jurisdiction under the California Health and Safety Code to charge a fee for connecting facilities to LACSD’s Sewerage System or for increasing the strength or quantity of wastewater discharged from connected facilities. The information presented in the comment has been added to the IS/MND. These additions clarify minor facts and does not result in any new significant impacts or a substantial increase in the severity of any environmental impacts. The addition of an LACSD connection fee is a ministerial action and is included under the proposed Project’s permits and approvals , see Attachment A , Revised IS/MND, page 10.
1-5 This comment outlines the LACSD’s methodology for available capacity at treatment facilities as defined by the Federal Clean Air Act, the Southern California Association of Governments’ regional growth forecast, and clean air plans as mandated by the California Clean Act. In addition, the comment states “this letter does not constitute a guarantee of wastewater service, but is to advise the developer that the Districts intend to provide this service up to the levels that are legally permitted and to inform the developer of the currently ex isting capacity and any proposed expansion of the Districts’ facilities.” This comment does not contain any specific concerns related to the adequacy of the environmental analysis in the IS/MND.
1 (263 units x 156 gallons per day) + [16,481 sf x (1000 gallons per day/1000 square feet)] = 57,509 gallons per day 2 (263 units x 156 gallons per day) + [14,346 sf x (200 gallons per day/1000 square feet)] = 43,897 gallons per day 740-790 East Green Street Mixed-Use Project / Responses to Comments on the IS/MND & MMRP
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Response to Comment Letter No. 2
Supporters Alliance for Environmental Responsibility (“SAFER”) Rebecca L. Davis, Lozeau Drury LLP
January 18, 2021
2-1 This comment requests an Environmental Impact Report (EIR) be prepared. Additionally, the comment notes further discussion by Francis “Bud” Offermann, PE, CIH with his curriculum vitae attached as Exhibit A of the letter (see Response to Comment 2-14, below). This portion of the comment letter does not express specific concerns with the adequacy of the IS/MND.
Instead, this is a general statement that introduces subsequent comments that identify the commenter’s specific alleged inadequacies. Responses to su ch alleged inadequacies are provided below.
2-2 This comment correctly summarizes the project description of the previously proposed Project.
This comment does not express any environmental comments or concerns; no further response is required.
2-3 This comment outlines certain instances of prior case law from the California Supreme Court defining certain legal standard s for the California Environmental Quality Act (CEQA). For example, the comment notes an EIR shall be prepared if substantial evidence supports a fair argument that a project may result in significant adverse impacts. However, on page 3, the comment incorrectly summarizes CEQA Guidelines Section 15064(f)(1), which states “If the lead agency determines there is substantial evidence in the record that the project may have a significant effect on the environment …(emphasis added),” whereas the commenter stated “… that a project may have an adverse environmental effect… (emphasis added)”.
An adverse environmental effect and a significant effect are not the same under CEQA. CEQA Section 21068 defines a “significant effect on the environment” as a “substantial, or potentially substantial, adverse change in the environment.” This comment does not ex press specific concerns with the adequacy of the IS/MND. As such, no further response is required. 2-4 This comment states that a fair argument can be made that the proposed Project would result in a significant impact related to indoor air quality. In summary , the comment states the Project’s emissions of formaldehyde into the air would result in significant cancer risks to future residents and, therefore, would result in a signific ant impact to air quality related to health risks impacts of toxic air contaminants.
Discussion of impacts on indoor air quality is not specified or required by the State CEQA Guidelines or California’s air district guidelines. California air districts base their thresholds of significance for CEQA purposes on the levels that scientific and factual data demonstrate that the air basin can accommodate without affecting the attainment date for the state and federal ambient air quality standards (AAQS). The AA QS is based on maximum pollutant levels in outdoor air that would not harm the public’s health. Furthermore, building materials are required to reduce exposure to toxic substances through compliance with the U.S.
Environmental Protection Agency and the California Air Resources Board (CARB) regulations, such as 40 CFR Part 770, Formaldehyde Emission Standards for Composite Wood Products.
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retailers of the products. All building materials used for the Project would be required to comply with the applicable federal and state standards.
In any event, the assertion by the commenter of a fair argument is incorrect as the Project will need to comply with the 2019 CalGreen Code, which specifies that composite wood products (such as hardwood plywood and particleboard) meet the requirements for formaldehyde as specified in CARB’s Air Toxic Control Measures. The 2019 CalGreen building code also does not allow added formaldehyde -based resins or ultra -low emitting formaldehyde resins, and requires documentation of compliance with CARB’s Air Toxic Control Measures. (See Section
5.504.4.5, Chapter 5, Part 11, 2019 California Green Building Standards Code, January 1, 2020, incorporated herein by this reference.) Furthermore, the commenter is speculating in the assertion that composite wood materials would be used in the interior of the building. Indoor building materials will not be known until the building permit stage, and as stated above, these materials will be required to comply with the CARB and the 2019 CalGreen building code.
The commenter’s conclusions were not based on the assumption that the Project would be built in accordance with CARB’s Air Toxic Control Measures, 2019 CalGreen building code, and Leadership in Energy and Environmental Design ( LEED) certification requirements. The commenter provides no evidence to substantiate a contrary conclusion that in spite of the Project using materials that comply with the standards of CARB’s Air Toxic Control Measures, the Project would still expose occupants to toxic substances that results in exceeding the South Coast Air Quality Management District ’s CEQA significance threshold. Moreover, CEQA generally requires analysis of the effects of a project on the environment, as opposed to the effects of the environment on a project (CEQA Guidelines Section 15126.2 )(California Building Industry Association. v. Bay Area Air Quality Management District [2015] [Case No.
S213478]). Therefore, this comment does not provide evidence of any new impacts, there would be no new impacts that were not previously analyzed in the IS/MND, and no revisions to the IS/MND are required.
2-5 This comment suggests the presumed cancer risk associated with the proposed Project ’s indoor air emissions may be exacerbated b y the vehicle emissions from nearby roadways.
The comment cites the South Coast Air Basin is in non -attainment for particulate matter less than or equal to 2.5 microns in diameter (PM2.5) and potential cumulative air quality impacts may occur related to toxic air contaminants.
The comment correctly notes the South Coast Air Basin is in non -attainment for PM2.5; however, the IS/MND states implementation of the proposed Project would not generate emissions of PM2.5 that would exceed the South Coast Air Quality Management District ’s thresholds (as shown in IS/MND Table 2.3 -4, Estimated Maximum Daily Operational Emissions). Accordingly, the proposed Project’s PM2.5 emissions are not expected to cause any increase in related regional health effects for these pollutants. Furthermore, the IS/MND states the proposed Project would not result in a potentially significant contribution to regional concentrations of non-attainment pollutants and would not result in a significant contribution to the adverse health effects associated with those pollutants. As such, impacts were found 740-790 East Green Street Mixed-Use Project / Responses to Comments on the IS/MND & MMRP
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to be less than significant and no mitigation is required (see Attachment A, Revised IS/MND Section 2.3, Air Quality, page 38).3
As discussed above in Response to Comment 2-4, discussion of impacts on indoor air quality is not specified or required by the State CEQA Guidelines or California’s air district guidelines.
California air districts base their thresholds of significance for CEQA purposes on the levels that scientific and factual data demonstrate that the air basin can accommodate without affecting the attainment date for the state and federal AAQS. The AAQS is based on maximum pollutant levels in outdoor air that would not harm the public’s health. Furthermore, building materials are required to reduce exposure to toxic substances through compliance with the U.S. Environmental Protection Agency and the CARB regulations, such as 40 CFR Part 770, Formaldehyde Emission Standards for Composite Wood Products. The regulations typically apply to manufacturers, distributors, importers, fabricators, and retailers of the products. All building materials used for the Project would be required to comply with the applicable federal and state standards.
Further, the California Supreme Court issued its opinion in California Building Industry Association v. Bay Area Air Quality Management District (2015) (Case No. S213478), stating in summary that “agencies subject to CEQA generally are not required to analyze the impact of existing environmental conditions on a pro ject’s future users or residents. But when a proposed project risks exacerbating those environmental hazards or conditions that already exist, an agency must analyze the potential impact of such hazards on future residents or users. In those specific instances, it is the project’s impact on the environment – and not the environment’s impact on the project – that compels an evaluation of how future residents or users could be affected by exacerbated conditions.” As summarized above, the proposed Project would not result in any significant impacts related to adverse health effects from PM2.5 and would therefore not exacerbate an existing condition related to adverse health effects.
The assertion by the commenter of a “fair argument” is incorrect as the IS/MND analyzed the proposed Project’s potential impacts related to toxic air contaminants, in accordance with the aforementioned State and local guidance. Therefore, this comment does not provide evidence of any new impacts there would be no new impacts that were not previously analyzed in the IS/MND, and no revisions to the IS/MND are required.
2-6 This comment suggests the Project site has the potential to be impacted with hazardous substances as a result of past land uses and cites the findings of a Phase I Environmental Site Assessment (ESA) and Vapor Intrusion Risk Assessment prepared for the IS/MND (included as Appendix E -3 of the IS/MND). The comment states the site investigation was insufficient related to potential vapor encroachment and soil contamination from the former gas station on the eastern portion of the Project site and the former gas station and auto repair operations north of the eastern portion of the Project site. Finally, the comment states the
3 As further described in Section 2.0, Overview of Changes to the Draft IS/MND, of this Final MND, changes to the proposed Project description since publication of the Draft IS/MND do not result in any new significant impacts or a substantial increase in the severity of any environmental impacts.
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testing is out of date and that the potential presence of underground storage tanks at the former gas station on the Project site has not been evaluated.
The commenter’s concerns are addressed through the required implementation of Mitigation Measure (MM) HAZ-1. The Hazardous Material Contingency Plan required by MM -HAZ-1 is designed to identify, delineate, report and address contaminated soils, for which the potential to encounter such soils was appropriately identified and described in the Desktop Environmental Review and Document Review and Phase I Environmental Site Assessment (ESA documents; Appendix E-1 and Appendix E-2) for the IS/MND. Furthermore, MM-HAZ-1 has been modified to also include assessment, characterization, and management of soil vapor in the area of the former gas station. For example, MM -HAZ-1 has been revised to include the following, “[s]hould soil vapor contamination be identified above applicable regulatory levels, as outlined in the HMCP, soil vapor intrusion methods will be outlined in the final report based on the findings on site and in accordance with February 2023 DTSC Final Draft Supplemental Guidance for Screening and Evaluating Vapor Intrusi on. Proposed engineering methods for attenuation of vapor intrusion will be prepared and submitted with building plans and approved by the permitting agency prior to issuance of construction permits.” These specific requirements would ensure that all site activities are conducted in conformance with applicable regulations. See Attachment A , Revised IS/MND, Section 2.9, Hazards and Hazardous Materials , page 74. Implementation of MM-HAZ-1 will adequately identify, characterize, and manage previously unremoved USTs and impacted soils, if any, on the Project site. Upon implementation of MM -HAZ-1 requirements, all potential site hazards identified in the Phase I ESA (Appendix E -2 of the IS/MND) would be reduced to levels less than significant. Therefore, this comment does not provide evidence of any new impacts that were not previously analyzed in the IS/MND.
2-7 This comment asserts that construction workers and others may be exposed to hazardous materials and that more site investigation is required. As stated in Response 2 -6 above, the commenter’s concerns are thoroughly addressed through the required implementation of MM- HAZ-1. The Hazardous Material Contingency Plan (HMCP), required by MM -HAZ-1, is designed to identify, delineate, report and address contaminated soils and soil vapor (if found), for which the potential to encounter such soils and soil vapor was appropriately identified and described in the Desktop Environmental Review and Document Review, Phase I Environmental Site Assessment, and Vapor Intrusion Risk Assessment (Appendix E-1, Appendix E-2, and Appendix E-3) for the IS/MND. As required by MM-HAZ-1, the HMCP includes management and disposal of contaminated soils, if found, in accordance local and state regulations, and includes health and safety measures appropriate for the potential hazards. Air monitoring will be conducted in accordance with applicable health and safety requirements.
The HMCP also states the environmental monitor will be in charge of disposal and reporting requirements, which must be conducted in accordance with local and state regulations (e.g. , City of Pasadena Best Management Practices for soil stockpiles, Draft Regional Water Board Fill Material Definitions, Department of Toxic Substances Control Voluntary Cleanup Program, and/or Regional Water Quality Control Board’s Leaking Underground Storage Tank program, as applicable). As stated in the HMCP, the contractor must be properly licensed to manage contaminated soils, including a Hazardous Substance Removal Certification to their 740-790 East Green Street Mixed-Use Project / Responses to Comments on the IS/MND & MMRP
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contractor’s license. Therefore, MM-HAZ-1 comprehensively addresses the safety of workers and others that may be nearby construction activities at the Project site in the event that soil contamination is encountered , and this comment does not provide evidence of any new impacts that were not previously analyzed in the IS/MND. 2-8 This comment claims the greenhouse gas analysis in the IS/MND is based on unsupported assumptions. The comment raises concern for the CalEEMod default values and methodology.4 The information presented in the IS/MND has been revised to clarify minor facts. These revisions do not result in any new significant impacts or a substantial increase in the severity of any environmental impacts . See Attachment A to this Final MND for revisions to Section 2.8, Greenhouse Gas Emissions, pages 64 and 65.
Furthermore, the additional reference has now been cited in the IS/MND. Therefore, see Attachment A to this Final MND for revisions to Section 3.1, References Cited, page 133. 2-9 This comment claims the IS/MND does not have supporting evidence to determine the effectiveness of MM-TRA-1 to reduce transportation impacts to a less -than-significant level, and claims that MM -TRA-1 constitutes deferral of mitigation. This comment is incorrect, as MM-TRA-1 provided clearly delineated performance standards that ensure the Project would not create significant impacts related to transportation. As stated, MM -TRA-1 required three mandatory actions to occur, which must be met in order for the Project to proceed. The inclusion of a performance standard in a mitigation measure is supported by relevant case law. The rule for proper deferral of the specifics of mitigation was established in Sacramento Old City Assoc. v. City Council of Sacramento (1991) 229 Cal. App. 3d 1011 . In summary, mitigation must meet one of the following conditions:
• The Lead Agency must commit itself to the mitigation by identifying and adopting one or more mitigation measures for the identified significant effect. The mitigation measure must also set out clear performance standards for what the future mitigation must achieve.
• Alternatively, the agency must provide a menu of feasible mitigation options from which the applicant or agency staffs can choose in order to achieve the stated performance standards.
MM-TRA-1 required development of the Transportation Demand Management Plan that must articulate achievement of a 27% reduction in vehicle trips per capita. This quantifiable performance standard is absolute and was determined by the City of Pasadena’s Department of Transportation to adequately reduce transportation impacts. As such, contrary to the commenter’s assertion, the City has not delegated its responsibility to the Applicant, but rather is the author of the methodology for analysis, thresholds for significance, and methods for mitigation.
4 As further described in Section 2.0, Overview of Changes to the Draft IS/MND, of this Final MND, changes to the proposed Project description since publication of the Draft IS/MND do not result in any new significant impacts or a substantial increase in the severity of any environmental impacts.
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MM-TRA-1 allowed for this quantified performance standard to be manifested in different ways and did not arbitrarily limit the methods by which the Applicant could ensure compliance with the vehicle trip reductions. The City determined that the performance standard set forth in MM- TRA-1 is feasible and achievable. For instance, achievement of the 27% reductio n could be accomplished by converting the commercial component to office or reducing some combination of the unit count and/or square footage of commercial use areas, and/or proscribing particular uses within the commercial use areas that achieve the vehicle reductions. Such options would have no impact on the analyses included in the IS/MND and could potentially reduce environmental impacts if reductions in units or square footage was required.
Subsequent to this analysis, the Applicant chose to revise the proposed Project by removing the Planned Development request and instead conform to the site’s existing CD -4 zoning district and applicable development standards. The Project would continue to include 263 residential units (including 41 affordable housing units). The Project has been revised to include 14,346 square feet of office uses rather than the originally proposed 16,481 square feet of commercial uses. This change in the Project Description accomplishes the intent of MM-TRA-1, and no additional mitigation related to transportation is required. See revisions included in Section 2.17 , Transportation of Attachment A as well as Attachment B, Transportation Impact Analysis. Such revisions do not result in any new significant impacts or a substantial increase in the severity of any environmental impacts. See Section 2.0 of this Final MND for more details. Therefore, this comment does not provide evidence of any new impacts that were not previously analyzed in the IS/MND. 2-10 This comment states that MM -TRA-1 would not result in a reduction of vehicle trips. This comment is incorrect because the City, as Lead Agency under CEQA, has developed the methodology for assessing impacts to transportation and vehicle miles traveled and has determined the potential means by which such impacts could be mitigated in order to achieve less than significant impacts. This methodology is universally applied to Projects within the City and constitutes adequate substantial evidence to conclude that compliance with the City’s General Plan Mobility Element objectives and policies. The Project analysis is based on the City’s Transportation Impact Analysis Guidelines using the City’s calibrated travel demand forecasting model built on Southern California Association of Government’s regional model.
Further, as discussed in Response 2 -9 above, subsequent to the publication of t he IS/MND for public review, the Applicant chose to revise the proposed Project , which has proven the feasibility of MM -TRA-1. Moreover, MM-TRA-1 has been revised to ensure the mix of land uses would accomplish the intent of the mitigation measure. See revisions included in Section
2.17, Transportation of Attachment A for more details and in Attachment B, Transportation Impact Analysis to this Final MND.
2-11 This comment concludes the letter and states the City must prepare an EIR for the proposed Project. All comments have been addressed and do not warrant the preparation of an EIR.
Please see Responses to Comments 2-1 through 2-12.
2-12 This comment is identified as Exhibit A of Comment Letter 2, which is the Indoor Air Quality technical study by Francis J. Offermann, PE, CIH, of Indoor Environmental Engineering. This comment also references, an appendix, and Curriculum Vitae of Mr. Offermann. Please see Responses to Comments 2-4 through 2-6, above.
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Response to Comment Letter No. 3
ActiveSGV
David Diaz, MPH, Executive Director
December 16, 2020
3-1 This comment provides an introduction of the organization and its mission in support of all - electric, mixed-use, infill developments in Pasadena. The commenter cites a 2019 indoor air quality study which determined homes with gas appliances result in worse air pollution consisting of particulate matter less than or equal to 2.5 microns in diameter (PM2.5) and nitrogen dioxide (NO2) as compared to air quality from outdoor air quality conditions.
Discussion of impacts on indoor air quality is not specified or required by the State CEQA Guidelines or California’s air district guidelines. California air districts base their thresholds of significance for CEQA purposes on the levels that scientific and factual data demonstrate that the air basin can accommodate without affecting the attainment date for the state and federal ambient air quality standards (AAQS). The AAQS are based on maximum pollutant levels in outdoor air that would not harm the public’s health. Furthermore, building materials are required to reduce exposure to toxic substances through compliance with the U.S.
Environmental Protection Agency and the California Air Resources Board (CARB) regulations, such as 40 CFR Part 770, Formaldehyde Emission Standards for Composite Wood Products.
The regulations typically apply to manufacturers, distributors, importers, fabricators, and retailers of the products. All building materials used for the Project would be required to comply with the applicable federal and state standards. Therefore, this comment does not provide evidence of any new impacts that were not previously analyzed in the IS/MND, and no revisions to the analysis within the IS/MND is required. 3-2 This comment further describes health concerns associated with indoor air quality. The comment cites studies which state gas stoves and furnaces produce a range of pollutants, including particulate matter, NO2, carbon monoxide, and formaldehyde. The comment highlights a number of health-related concerns for indoor air pollution caused by changing environmental conditions and building conditions. As stated in Response to Comment 2 -4, indoor building materials will not be known until the building permit stage; however, these materials will be required to comply with the CARB and the 2019 CalGreen building code. As such, building materials are required to reduce exposure to toxic substances through compliance with the U.S. Environmental Protection Agency and CARB regulations, such as 40 CFR Part 770, Formaldehyde Emission Standards for Composite Wood Products. The regulations typically apply to manufacturers, distributors, importers, fabricators, and retailers of the products. All building materials used for the Project would be requir ed to comply with the applicable federal and state standards. Lastly, the Project would be built in accordance with CARB’s Air Toxic Control Measures, 2019 CalGreen building code, and Leadership in Energy and Environmental Design (LEED) certification requirements. Discussion of impacts on indoor air quality is not specified or required by the City’s Environmental Policy Guidelines, State CEQA Guidelines, or California’s air district guidelines, as further addressed in Responses to Comments 2-4 and 2-5. Therefore, this comment does not provide evidence of any new impacts that were not previously analyzed in the IS/MND, and no revisions to the analysis within the IS/MND is required.
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3-3 This comment cites support for an all -electric building code for new construction to provide benefits to the climate, air quality, public health, public safety, and housing affordability . This commenter’s suggestion will be provided to the Project applicant and to City decision makers for their review and consideration as part of this Final MND. However, this comment does not contain any specific concerns related to the adequacy of the environmental analysis in the IS/MND. Furthermore, the Project would be built in accordance with the 2019 CalGreen building code and LEED certification requirements. Therefore, this comment does not provide evidence of any new impacts that were not previously analyzed in the IS/MND, and no revisions to the analysis within the IS/MND is required. 3-4 This comment describes the City’s Climate Action Plan (adopted in March 2018 ) which identifies strategies to reduce reliance on gas and fossil fuels. The comment encourages the Project applicant to voluntarily reduce the use of gas in its design. This comm enter’s suggestion will be provided to the Project applicant and to City decision makers for their review and consideration as part of this Final MND. However, this comment does not contain any specific concerns related to the adequacy of the environmental analysis in the IS/MND.
Furthermore, the Project would be built in accordance with the 2019 CalGreen building code and LEED certification requirements. Therefore, this comment does not provide evidence of any new impacts that were not previously analyzed in the IS/MND, and no revisions to the analysis within the IS/MND is required.
3-5 This comment provides a suggestion to the Project applicant to adopt mass timber construction techniques to reduce climate impacts. The comment describes mass timber construction as a carbon-removal and sequestration technique and cites potential cost, aesthetic, value, and safety benefits to utilizing these techniques. The commenter’s suggestion will be provided to the Project applicant and to City decision makers for their review and consideration as part of this Final MND. However, this comment does not contain any specific concerns related to the adequacy of the environmental analysis in the IS/MND. Therefore, this comment does not provide evidence of any new impacts that were not previously analyzed in the IS/MND, and no revisions to the analysis within the IS/MND is required. 3-6 This comment provides a summary of the comment letter and encourages the Project team to embrace new techniques and best practices suggested for sustainable design. This commenter’s suggestion will be provided to the Project applicant and to City decision makers for their review and consideration as part of this Final MND. This comment does not contain any specific concerns related to the adequacy of the environmental analysis in the IS/MND.
Therefore, this comment does not provide evidence of any new impacts that were not previously analyzed in the IS/MND, and no revisions to the analysis within the IS/MND is required. 3-7 This comment outlines communities within the State of California that have adopted building codes to reduce reliance on gas, also known as “REACH Codes.” This comment supports the discussion outlined in Comment 3-3 for reference. Please see Response to Comment 3-3. No further response is required.
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Response to Comment Letter No. 4
Carlson & Nicholas, LLP
Richard A. McDonald, Esq.
December 10, 2020
4-1 This comment identifies the commenter as the legal representation for Stanford Pasadena, LLC, the owner of 770 East Green Street (the Project Applicant). The comment provides a summary of the previous project descriptio n. The comment incorrectly states the Project’s proposed ground floor would consist of 16,234 square feet of commercial space , where the proposed ground floor commercial space totals 16,232 square feet . As shown in Figure 4, Level One Floor Plan, of the IS/MND, the proposed Project includes the commercial uses on the ground floor. However, subsequent to the publication of the IS/MND for public review, the Project Applicant changed select components of the proposed Project. For example, the Project would continue to include 263 residential units (including 41 affordable housing units).
In addition, the Project has been revised to include 14,346 square feet of office uses rather than the originally proposed 16,232 square feet of commercial uses. Such revisions do not result in any new significant impacts or a substantial increase in the severity of any environmental impacts. See Section 2.0 of this Final MND for more details. This comment does not provide evidence of any new impacts that were not previously analyze d in the IS/MND, and no revisions to the analysis within the IS/MND is required. 4-2 This comment states the intent of the letter is to explain the Project’s application ahead of the City Planning Commission’s study session on the proposed Project. The comment states the proposed Project is utilizing both the State’s Density Bonus Law and the City’s Concessions Menu and explains the applicability to the Project’s proposal.
The comment notes the Project site is located on two different sub -districts under the City’s Zoning Code. As such, the proposed Project requested a Planned Development zone change.
The comment correctly identifies components of the proposed Project and requested approvals.
However, subsequent to the publication of the IS/MND for public review, the Project Applicant has withdrawn the Planned Development application and continues to include a Density Bonus component. See changes to the project description and other applicable sections in Section 2.0 of this Final MND. This comment does not contain any specific concerns related to the adequacy of the environmental analysis in the IS/MND. However, the comment will be provided to the City’s decision makers for their review and consideration as part of this Final MND. This comment does not provide evidence of any new impacts that were not previously analyzed in the IS/MND, and no revisions to the analysis within the IS/MND is required. 4-3 This comment notes an MND was prepared to address any potential significant environmental impacts as a result of the proposed Project and mitigation was incorporated to reduce impacts.
The comment further states the Project site does not contain resources with historical significance and the Project would not result in a substantial adverse impact. The comment correctly states the IS/MND’s less-than-significant determination for the Project’s impact on historical resources. Additionally, where the IS/MND has identified potentially significant impacts, mitigation was incorporated to reduce potential impacts to a less -than-significant effect. Mitigation reduced potentially significant impacts to a less-than-significant level for topic 740-790 East Green Street Mixed-Use Project / Responses to Comments on the IS/MND & MMRP
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areas under Section 2.5, Cultural Resources (archaeological resources); Section 2.7, Geology and Soils; Section 2.9, Hazards and Hazardous Materials; Section 2.13, Noise; Section 2.16, Recreation; Section 2.17, Transportation; Section 2.18, Tribal Cultural Resources; and Section 2.21, Mandatory Findings of Significance. Additionally, the commenter notes any objection to the findings for the CEQA determination m ust be based upon substantial evidence. This comment does not contain any specific concerns related to the adequacy of the environmental analysis in the IS/MND. However, the comment will be provided to the City’s decision makers for their review and consid eration as part of this Final MND. This comment does not provide evidence of any new impacts that were not previously analyzed in the IS/MND, and no revisions to the analysis within the IS/MND is required. 4-4 This comment states the proposed Project meets the definitions outlined in the Housing Accountability Act (Government Code Section 65589.5; also known as Senate Bill 330 ). The comment also cites provisions from the Housing Accountability Act in which a city cannot deny a “housing development project” or reduce the proposed density if it complies with planning and land use regulations in effect at the time of a project application is deemed complete unless the proposed project would have a “specific, adverse impact upon the public health or safety.” The comment continues to state the Project’s applicability to the provisions of Senate Bill 330, including limits to the City from holding more than five hearings and imposing any new zoning, fees, and a determination of the Project site as a historic site. Furthermore, the comment states Senate Bill 330 limits the imposition or enforcement of non -objective design standards established after January 1, 2020. This comment does not contain any specific concerns related to the adequacy of the environmental analysis in the IS/MND. However, the comment will be provided to the City’s decision makers for their review and consideration as part of this Final MND. This comment does not provide evidence of any new impacts that were not previously analyzed in the IS/MND, and no revisions to the analysis within the IS/MND is required.
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Response to Comment Letter No. 5
Pasadena Heritage
Andrew Salimian, Preservation Director
December 17, 2020
5-1 This comment provide s a letter which was previously submitted to the City’s Design Commission and expresses support for the Design Commission’s recommendations for the proposed Project . The commenter requests design changes to the Project. The comment does not contain any specific concerns related to the adequacy of the environmental analysis in the IS/MND. However, this comment will be provided to the City’s decision makers for their review and consideration as part of this Final MND. This comment does not provide evidence of any new impacts that were not previously analyzed in the IS/MND, and no revisions to th e analysis within the IS/MND is required.
5-2 This comment asks about the traffic study prepared for the IS/MND. Specifically, the comment asks whether that the vehicle trips /capita threshold of significance is outdated since the Pasadena City Council took action to adopt lower thresholds in December 2020.
City Council Resolution No. 9820 states that the new CEQA thresholds shall apply to any new project applications deemed complete 90 days after November 16, 2020, the date of adoption of the resolution. Significant time and resources were spent by City staff on the project prior to adoption. Since this Project application was deemed complete prior to adoption of the resolution, the amendment does not apply. Furthermore, the revised project description (as demonstrated in Attachment B of this Final MND ) does not exceed any CEQA thresholds related to Transportation and no mitigation is required . See Attachment A to this Final MND for revisions to Section 2.17, Transportation.
5-3 This comment is an attached letter addressed to the City’s Design Commission and dated December 7, 2020. The comment cite s support for the changes to the Project that were included in the latest design . Additionally, the comment includes another attachment, which are included as Responses to Comments 5-4 through 5-6 below.
The comment er requests a design change to include a subterranean setback for the underground parking structure in order to reduce a potential impact to the root system of the ficus trees. As stated in the IS/MND and as shown in Figure 12, Tree Inventory, the proposed Project would be constructed such that the mature trees along East Green Street would be preserved in place. It is anticipated that tree-trimming would be required to accommodate the demolition and/or construction equipment to the trees lining East Green Street. Any tree trimming would be carried out according to City standards to protect the health of the trees.
Moreover, the City conducted a Protected Tree Report prepared by a certified arborist on February 4, 2022 (included as Attachment C to this Final MND) which confirmed Project implementation would not significantly impact the existing f icus trees on East Green Street and made recommendations in compliance with the City’s Municipal Code. The commenter’s request for using the Planning Department’s previously implemented root protection setback will be provided to the Project applicant and the City’s decision makers for their review and consideration as part of this Final MND.
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Lastly, the comment asks to see a design concept for the proposed pocket park and courtyard spaces. Please see Figure 10c, Interior Courtyard Elevations and Figure 11, Open Space Areas of Attachment A to this Final MND . The proposed Project is subject to review and approval by the City’s Design Commission through the City’s Design Review Process. 5-4 This comment is comp osed of feedback from a Pasadena Heritage Advocacy Committee Meeting, which occurred on Thursday, May 2, 2019. The feedback addressed concern for the Project’s size, height, and scale. The comment raises concern for a maximum height of 85 feet.
As described in the IS/MND, the Project’s design proposes a maximum height of 47 feet for the 4-story building fronting Green Street, a maximum of 31 feet on Green Street at Oak Knoll Avenue, a maximum of 35 feet on Green Street at Hudson Avenue, and a maximum height of 62 feet, located in the interior of the Project site. See Figures 10A through 10C of Attachment A to this Final MND for more details of the Project’s elevation. Furthermore, the comment asks if parking would be fully subterranean. The IS/MND states the Project’s proposed parking would consist of two levels of subterranean parking. As such, the proposed Project would not have a maximum height of 85 feet. However, the comment’s request to lower the subterranean parking to reduce building height will be provided to the Project applicant and the City’s decision makers for their review and consideration as part of this Final MND.
The comment also requests the Project’s massing to be reduced and for the applicant to provide street renderings from each corner at the pedestrian level. As noted above, this portion of the comment letter was addressed in Response to Comment 5 -3. See IS/MND Figures 10A through 10C of Attachment A to this Final MND for more details of the Project’s elevation and renderings.
5-5 This comment request s the existing trees along the Project site be protected through an increased setback greater than 5 feet as proposed to not risk the ficus trees along Oak Knoll Avenue and Green Street. Please refer to Response to Comment 5-3 above. 5-6 This comment reques ts the incorporation of high -quality materials for the proposed Project.
Additionally, the comment requests a window depth of 6 inches, a reorientation of the upper floors, as well as the incorporation of overhanging roofs. These requests are aimed to enhance shadow lines, redesign the Project for mountain views, and increase energy efficiency. As discussed in the IS/MND the proposed Project is contemporary in style; however, the buildings incorporate some design elements of historic Spanish Revival buildings in Pasadena, including a base-middle-top visual order, roof articulation, upper floor step backs, and a paired windows pattern. As shown in the elevations illustrated in Figures 10a through 10c of Attachment A to this Final MND , architectural materials contemplated to be incorporated into Project design include white and accent plaster, accent ceramic tile, metal railing, vinyl window frames and door frames, and glass guard railing. Materials and colors are subject to review and approval by the City’s Design Commission through the City’s Design Review Process. The commenter’s suggestions do not contain any specific concerns related to the adequacy of the environmental analysis in the IS/MND. However, this comment will be provided to the Project applicant and the City’s decision makers for their review and consideration as part of this Final MND.
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Response to Comment Letter No. 6-PC
Pasadena Heritage
Andrew Salimian, Preservation Director
December 17, 2020
6-1 This comment is from the City’s Planning Commission meeting on December 17, 2020. The comment notes a letter was submitted via email as well (see Response to Comment Letter 5).
The comment asks if the Project needs to comply with new CEQA vehicle miles traveled/vehicle trips thresholds as amended by the City Council. The comment notes the Transportation Impact Analysis prepared for the IS/MND used 2013 baseline metrics.
City Council Resolution No. 9820 states that the new CEQA thresholds shall apply to any new project applications deemed complete 90 days after November 16, 2020, the date of adoption of the resolution. Significant time and resources were spent by City staff on the Project prior to adoption of the reso lution. Since this Project application was deemed complete prior to adoption, the amendment does not apply. Therefore, the transportation methodologies and analyses used to support the IS/MND are appropriate as presented.
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Response to Comment Letter No. 7
Barry Brenner
January 4, 2021
7-1 This comment represents an email response to the City of Pasadena (City) regarding clarification on the public review period. The commenter requests the following comments (included as Responses to Comments 7 -2 through 7 -5) be submitted to the Planning Commission for consideration. This comment will be provided to the City’s decision makers for their review and consideration as part of this Final MND. 7-2 This commenter notes the potential timeframe that construction and demolition activities could occur per the City’s Noise Ordinance (Section 9.36.070 of the Municipal Code). However, the commenter’s estimation for the Project’s construction duration does not accurately reflect the anticipated number of hours for construction and demolition ac tivities. Although the City’s Noise Ordinance allows for construction activities to occur during the specified hours on specified days, the IS/MND does not anticipate the proposed Project’s construction activities to occur throughout the entire duration of the allowable timeframe. IS/MND Table 1 -3, Estimated Construction Activities, details the potential number of hours, the type and quantity of equipment needed, and each construction phase ’s schedule . The number of hours anticipated within Table 1 -3 is sig nificantly less than the commenter’s calculation.
Furthermore, IS/MND Table 2.13-2 estimates the maximum noise level generated at 50 feet for each construction equipment and Table 2.13-4 estimates the construction noise level at noise-sensitive uses (i.e., multi-family residences to the east of the Project site). As stated in the IS/MND, although construction noise may be annoying because levels would be generally well above typical existing ambient noise levels, construction noise would be temporary, and restricting construction activities to the daytime period would avoid disruption of evening relaxation and overnight sleep periods (per the City’s Noise Ordinance) . Moreover, the IS/MND states construction noise levels would be below the standards establish ed in the City’s Noise Ordinance; thus, construction noise impacts would be less than significant (see Attachment A, Revised IS/MND, Section 2.13, Noise, pages 90–94).
Additionally, the commenter raises concern about the methodology for taking the noise measurements. T he four locations of noise measurements , the durations, the choice of locations, and the procedures used to assess the baseline conditions in the IS/MND represent the standard of the practi ce for community noise studies. Because construction activities would be conducted during daytime hours, these measurements represent typical daytime noise levels in the Project area and appropriately represent the baseline condition from which to assess the Project’s noise impacts. Therefore, this comment does not provide evidence of any new impacts that were not previously analyzed in the IS/MND. 7-3 This comment expresses concern for construction noise and the potential for construction workers and equipment to arrive at within the vicinity of the Project site prior to the designated construction hours . The IS/MND analyzed potential noise impacts to off -site sensitive receptors, including multi-family residences east of the Project site (including the commenter’s home). Although the commenter’s concern for noise prior to designated construction hours may be annoying, construction noise would be temporary and Project activities would be 740-790 East Green Street Mixed-Use Project / Responses to Comments on the IS/MND & MMRP
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required to comply with the City’s Noise Ordinance. Fu rthermore, construction noise levels would be below the standards established by the City and less than significant as shown in IS/MND Table 2.13 -4, Construction Noise Levels at Noise -Sensitive Uses. Therefore, this comment does not provide evidence of any new impacts that were not previously analyzed in the IS/MND. For additional information related to nuisance noise, the City’s Code Compliance Division includes a complaint tracking system for all complaints filed with the Planning and Community Developmen t Department. Each complaint is forwarded to the proper City Department for investigation and resolution. The Pasadena Citizen Service Center allows for online submittal of a request for investigation, including Code compliance concerns (call 626- 744-7311 or see https://www.cityofpasadena.net/citizen-service-center/submit-a-request/). 7-4 This comment requests the construction schedule be revised to only Monday through Friday, 9 a.m. to 5 p.m. in order to reduce general concern for construction noise impacts. As previously discussed above in Response to Comment 7 -3, proposed Project would comply with the City’s Noise Ordinance and construction noise levels would be below the standards established by the Ci ty and less than significant as shown in IS/MND Table 2.13 -4. This comment does not contain any specific concerns related to the adequacy of the environmental analysis in the IS/MND. However, this comment will be provided to the City’s decision makers for their review and consideration as part of this Final MND.
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Response to Comment Letter No. 8
Nina Chomsky
January 17, 2021
8-1 This comment claims the analysis within the IS/MND is inadequate and fails to identify and mitigate potentially significant environmental impacts. The particular comment is not specific in the reasons for the IS/MND’s alleged inadequacy. Please see Responses to Comments 8-2 through 8-9, below.
8-2 This comment raises concern for the definition of “community open space” used in the IS/MND.
The comment further states the proposed balconies should be removed from the total community open space square footage and asserts balconies are not “private open space.” As stated in the IS/MND, the Project includes 27,180 square feet of outdoor community open space (i.e. 4,110 square feet of publicly available pocket park, breezeways, swimming pool courtyard, roof terraces), 600 square feet of indoor community open space, and 11,703 square feet of private open space (i.e. balconies), for a total of 39,483 square feet of community open space. The comment correctly identifies the total square footage of community open space.
However, subsequent to the publication of the IS/MND for public review, the Project Applicant changed select components of the proposed Project. See Section 2.0 of this Final MND and Attachment A, Revised IS/MND for details. Additionally, per the City’s Municipal Code (Section
17.50.160), “community open space” is a defined term which includes all open space provided as part of mixed-use projects such as the proposed Project. “Private open space” is another term defined by the City’s Municipal Code, which identifies balconies as an example of such use.
Section 17.50.160(H)(1) of the City’s Municipal Code determines “c ommunity space requirements”, which include both indoor/interior space and outdoor open space. Community space can be in the form of private open space (e.g., balconies) or common open space (e.g., pool or side or rear setback areas). Further, an indoor recreational room of up to 600 square feet may be credited toward fulfilling this community space requirement.
Section 17.50.160(H )(4) of the City’s Municipal Code defines “p rivate open space ” as not exceeding 30 percent of the total requirement for community space. Section 17.50.160(H)(5) of the City’s Municipal Code states “community open space” shall have at least one minimum dimension of 15 feet and the other dimensions shall be at least six feet, except for private open space (e.g., balconies or patios).
The comment suggests the Project Description in the IS/MND requires revisions to reflect the latest site plan. The Project Description included within Section 1.0, Project Information, of the IS/MND accurately reflected the Project as proposed at the time of the public review of the IS/MND. Subsequent to the public review of the IS/MND, the Applicant chose to revise the proposed Project by removing the Planned Development request and instead conform to the site’s existing CD-4 zoning district and applicable development standards. The Project would continue to include 263 residential units (including 41 affordable housing units). The Project has been revised to include 14,346 square feet of office uses rather than the originally proposed 16,481 square feet of commercial uses. Such revisions do not result in any new 740-790 East Green Street Mixed-Use Project / Responses to Comments on the IS/MND & MMRP
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significant impacts or a substantial increase in the severity of any environmental impacts. See Section 2.0 of this Final MND for more details. Therefore, this comment does not provide evidence of any new impacts that were not previously analyzed in the IS/MND. 8-3 This comment states the Project would result in a significant aesthetic impact by conflicting with applicable zoning and other regulations governing scenic quality. The Project site is located within a n urbanized area as defined by California Public Resources Code Section 21071, which states an “urbanized area” is “(a) an incorporated city that meets either of the following criteria: (1) Has a population of at least 100,000 persons, or (2) Has a population of less than 100,000 persons if the population of that city and not more than two contiguous incorporated cities combined equals at least 100,000 persons.” The City of Pasadena has a population of 138,699 residents.5 As such, the Project site is located within an urbanized area with a population over 100,000 persons. Therefore, a s detailed in IS/MND Section 2.1, Aesthetics, Threshold c), analysis was prepared to determine the proposed Project’s consistency with applicable zoning and other regulations governing sce nic quality. The analysis includes a description of the Project site and surrounding area , discussion on the proposed Project’s components, citations to figures prepared for the IS/MND, and a consistency table (Table 2.1 -1) analyzing the Project’s consiste ncy with the City’s General Plan and Municipal Code. As shown in Table 2.1-1, General Plan Policy/Programs, Specific Plan, and Municipal Code Consistency Analysis, the proposed Project would be consistent with the City’s General Plan policies, Municipal Co de sections, and Specific Plan concepts that pertain to the preservation of the scenic quality of the City (see Attachment A, Revised IS/MND, Section 2.1, Aesthetics, page 26). Given the consistency outlined in Table 2.1 -1, conflict with applicable zoning and other regulations governing scenic quality would not occur.
The comment also states the Environmental Setting fails to describe the existing setting of Green Street, inclu ding the mature ficus trees along Green Street. As described under the IS/MND’s Environmental Setting (Section 1, Project Information), off-site Project components, including the mature ficus trees on Green Street, were adequately identified. IS/MND Figure 12, Tree Inventory, was prepared to illustrate that the mature ficus trees along East Green Street would be preserved in place, whereas those existing street trees along South Hudson Avenue and South Oak Knoll Avenue that are in poor condition woul d be removed and replaced with new trees. All street/public trees proposed for removal would be removed per the City’s Municipal Code Section 8.52.010. It is anticipated that tree -trimming would be required to accommodate the demolition and/or construction equipment to the trees lining East Green Street. Any tree trimming would be carried out according to City standards to protect the health of the trees. Moreover, the City conducted a Protected Tree Report prepared by a certified arborist on February 4, 20 22 (included as Attachment C to this Final MND) which confirmed Project implementation would not significantly impact the existing ficus trees on East Green Street and made recommendations in compliance with the City’s Municipal Code.
The commenter’s concern with the existing tree canopy along Green Street is addressed through the Project’s compliance with the City’s Municipal Code on setbacks (i.e., 5 feet on
5 United States Census Bureau. 2022. QuickFacts: Pasadena city, California. Accessed August 2022. https://www.census.gov/quickfacts/pasadenacitycalifornia. 740-790 East Green Street Mixed-Use Project / Responses to Comments on the IS/MND & MMRP
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Green Street, see IS/MND Table 1-2, Project Development Standards), as well a s the City’s Municipal Code requirements related to trees (see Chapter 8.52, City Trees and Tree Protection Ordinance). The City’s tree ordinance sets forth robust and detailed requirements for activities related to public trees and prohibits any injury or removal of a mature tree without a permit. As stated in Section 8.52.085(J), “To do or commit any unpermitted act that is injurious to a protected tree, including, but not limited to, causing root damage, damage to the trunk, scarring, or any other unpermitted alteration of a protected tree” is prohibited. As noted in the IS/MND, the proposed Project would preserve the mature ficus trees along Green Street and would be prohibited from causing any injury to the tree. Furthermore, as shown in Figure 10b, North and South Elevations, of Attachment A to this Final MND, the massing of the buildings would be setback from Green Street and the existing mature ficus trees along Green Street would be preserved (see Attachment A, Revised IS/MND, Section 2.1, Aesthetics, page 18).
In conclusion, t he IS/MND determined the Project’s potential impacts would be less than significant and no mitigation would be required. Therefore, this comment does not provide evidence of any new impacts that were not previously analyzed in the IS/MND, and no revisions to the IS/MND are required.
8-4 This comment states the proposed Project would significantly transform a major portion of Green Street and thereby impact the existing character and scale of the surrounding area.
As detailed in IS/MND Section 2.1, Aesthetics, Threshold c), “the Project site and surrounding area are generally characterized by disparate commercial and multi -family residential land uses that are inconsistent in size, style, and, as such, lack visual cohesion and uniformity.
Vegetation on the Project site is limited to 12 on-site trees and two sparse planter beds, which would be removed under the proposed Project. The only distinct visual element on the project site and/or in the vicinity are the mature ficus trees along Green Street” (Attachment A, Section
2.1, Aesthetics, page 18). Moreover, as described in Response to Comment 8-3, the IS/MND determined impacts related to consistency with applicable zoning and other regulations governing scenic quality would be less than significant.
Regarding the p roposed buildings’ mass and scale, the Project originally proposed a zone change that would be accompanied by the adoption of development standards for allowed and conditionally allowed uses (i.e., a Planned Development [PD] Plan). The Project previously requested a zone change from CD-4 to the establishment of Planned Development No. 37 (PD 37). However, subsequent to the publication of the IS/MND for public review, the Project Applicant has withdrawn the Planned Development application . Furthermore, the Project would be utilizing the City’s Affordable Housing Concession Menu and the State’s Density Bonus Law, which would allow for an increase in the maximum allowable density, height, and floor-to-area ratio (FAR). As described in Section 2.0 of this Final MND, the withdrawal of the Planned Development application would not change the significance determination related to land use and planning. Instead, the proposed Project would conform to the site’s existing CD -4 zoning district and comply wi th all applicable development standards for implementation. Overall, the proposed Project would still be subject to Design Review approval. These changes to discretionary actions would not result in new, avoidable significant effects on the environment.
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Moreover, the Project has accounted for design considerations to reduce potential aesthetic impacts. As described under Threshold 2.1(c) and in Table 2.1 -1 of the IS/MND, the Project would include height and setback variations to allow for visual dispersal of the Project’s density by utilizing step -down massing between floors and by increasing the setback at Oak Knoll Avenue from 5 feet to 10 feet. In addition, the aesthetic design goal of the proposed Project is to provide a form, proportion, and articulation that relates to similar architectural approaches throughout the urban areas of Pasadena and maintains a clean and streamlined composition conveyed in a contemporary manner. Thus, the Project’s deviation from such general property and design standards wou ld not result in significant impacts to visual quality. The Project would comply with all of the City’s development standards, including but not limited to, the City’s outdoor lighting ordinance, walls and fences guidelines, and public art requirements (as set forth in Chapter 17.40 of the Municipal Code). Furthermore, the proposed Project would be subject to the City’s design review and approval process with the City’s Design Commission. Therefore, this comment does not provide evidence of any new impacts that were not previously analyzed in the IS/MND, and no revisions to the IS/MND are required.
Lastly, the commenter requests detailed and enforceable mitigation to protect the ficus tre es on Green Street . The comment cites further discussion in the comment letter, below, and included as Comment 8-7. Please see Response to Comment 8-7 for more discussion. 8-5 This comment requests the proposed Project be redesigned without the proposed elevated pedestrian walkways along Floors 2, 3, and 4 because the commenter states the design feature would not be consistent with the character or scale of Green Street’s surrounding uses. The IS/MND analyzed Project consistency with applicable zoning and other regulations governing scenic quality in Section 2.1, Aesthetics. In Table 2.1 -1, General Plan Policy 28.4, Design Integration, states that the City “[r]equires residential and nonresidential portions of mixed-use buildings and sites to be integrated through architectural design, development of pedestrian walkways and landscaping”. As such, the IS/MND determined the Project was consistent with the City’s General Plan relative to pedestrian walkways as it “includes 39,980 sf of pedestrian amenities and open space, including a 4,033 sf pocket park, pool lounge and private outdoor space, all of which would provide landscaped pedestrian amenities and enhance walkability. Additionally, the proposed Project is located 500 feet south of Colorado Boulevard and the downtown Pasadena amenities, which would further encourage walkability” (Attachment A, Section 2.1, Aesthetics, page 23).
However, since the publication of the IS/MND, the Project Applicant has changed select components of the proposed Project, including the removal of the aforementioned pedestrian walkways. See Section 2.0 of this Final MND for more details. 8-6 This comment states the proposed Project would not be co nsistent with the City’s General Plan policy/programs and Municipal Code provisions. The comment suggests the Project is not consistent with General Plan Policies 4.10, 4.11, 4.12, 6.1, 7.3, and 28.2. The comment 740-790 East Green Street Mixed-Use Project / Responses to Comments on the IS/MND & MMRP
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is not specific on the reasons why there is inadequacy in the IS/MND’s analysis. The policies mentioned are listed, below:
• General Plan Policy 4.10: Architecture that Enhances . Locate and design buildings to relate to and frame major public streets, open spaces, and cityscape. New development at intersections should consider any number of corner treatments, and should balance safety and accessibility concerns with the vision of the area and the need for buildings to engage the street and create a distinct urban edge.
• General Plan Policy 4.11: Development that is Compatible . Require that development demonstrates a contextual relationship with neighboring structures and sites addressing such elements as building scale, massing, orientation, setbacks, buffering, the arrangement of shared and private open spaces, visibility, priv acy, automobile and truck access, impacts of noise and lighting, landscape quality, infrastructure, and aesthetics. • General Plan Policy 4.12: Transitions in Scale . Require that the scale and massing of new development in higher density centers and corridor s provide appropriate transitions in building height and bulk and are sensitive to the physical and visual character of adjoining lower-density neighborhoods.
• General Plan Policy 6.1: Sense of Place and History . Require new development and changes to exist ing development to be located and designed to respect the defining elements of Pasadena’s character and history such as its grid street pattern, block scale, public realm, neighborhoods and districts, building massing and heights, significant architecture, and relationship to the mountains and Arroyo Seco. • General Plan Policy 7.3: Compatibility. Require that new and adaptively re -used buildings are designed to respect and complement the defining built form, massing, scale, modulation, and architectural detailing of their contextual setting. • General Plan Policy 28.2: Development Scale . Establish standards to assure that an adequate scale and footprint of any single use is achieved in mixed-use areas to establish a cohesive environment that minimizes impacts a ttributable to the adjacency of different uses. This may define minimum parcel and building size, number of housing units, and/or nonresidential square footage, as well as relationships and setbacks.
Each policy mentioned is related to Citywide design goal s that would be reviewed for consistency during the design review process and are not policies adopted for the purposes of avoiding or mitigating an environmental effect. The analysis prepared within Table 2.1-1 of the IS/MND is adequate and has determined the proposed Project would be consistent with these policies.
The commenter asserts that the Project will significantly alter the aesthetic character of Green Street related to the introduction of “massive new buildings” on Green Street. However, as described on page 10 of the IS/MND, the Project area currently contains numerous tall buildings within the immediate viewshed of the proposed Project, including the 5 - to 6-story 740-790 East Green Street Mixed-Use Project / Responses to Comments on the IS/MND & MMRP
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mixed-use/parking garage structures on the north corner of Green Street and Hudson Avenue, which are adjacent to two 9 -story towers on Hudson Avenue and Colorado Boulevard.
Additionally, Hudson Avenue contains two 4 -story mixed use buildings in proximity to the Project site. As such, the introduction of a 4 - to 5-story mixed-use development would be consistent with existing nearby developments. Additionally, the proposed Project would not require a General Plan Amendment. Furthermore, with the approval of the Project, including Design Review, the proposed Project would comply with the City’s zoning designations and would have a less than significant impact on any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect. No mitigation is required (see Attachment A , Revised IS/MN D, Section 2.11, Land Use and Planning, page 86).
However, subsequent to the publication of the IS/MND for public review, the Project Applicant has withdrawn the Planned Development application. See changes to the project description and other applicable sections in Attachment A, Revised IS/MND. As described, the withdrawal of the Planned Development application would not c hange the significance determination related to land use and planning. Instead, the proposed Project would conform to the site’s existing CD -4 zoning district and comply with all applicable development standards for implementation. In addition , the propose d Project would still be subject to Design Review approval. These changes to discretionary actions would not result in new, avoidable significant effects on the environment. Therefore, this comment does not provide evidence of any new impacts that were not previously analyzed in the IS/MND, and no revisions to the IS/MND are required.
Moreover, the comment notes more discussion is outlined further in the comment letter, included as Comment 8-7. Please see Response to Comment 8-7, below. 8-7 This comment suggests the proposed Project would result in a significant impact related to land use and planning based on the Project applicant’s request to u se both the City’s Inclusionary Housing Ordinance and the State’s Density Bonus law.
Section 2.11, Land Use a nd Planning, of the IS/MND determined that the proposed Project would have a less than significant impact related to consistency with a land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect. The comment correctly outlines the IS/MND’s discussion related to the requested zone change and the utilization of both the State’s Density Bonus law as well as the City’s Inclusionary Housing Ordinance, which would increase the Project’s density, height, and FAR. The comment further states the City’s intent for the creation of the Inclusionary Housing Concessions Menu was to avoid the State’s Density Bonus law, respond to public criticism of proposed projects’ density and scale, and provide a process to reduce time and cost for the production of affordable housing. As such, the commenter concludes the proposed Project cannot utilize both the State’s Density Bonus and the City’s Inclusionary Housing Ordinance.
Moreover, the commenter suggests mitigation should b e incorporated to clarify which entitlement request.
The Project’s proposed State Density Bonus component would allow for a 30% density bonus from the 87 dwelling units per acre currently allowed in the CD-4 zone. In addition, the Project would utilize two On-Menu concessions (0.5 FAR increase and a 12-foot height increase) from 740-790 East Green Street Mixed-Use Project / Responses to Comments on the IS/MND & MMRP
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the City’s Inclusionary Housing Ordinance. No Affordable Housing Concession Permit is required, and no Off-Menu concessions are requested. The Project is permitted to u se the same a ffordable units for the City’s Inclusionary Housing Ordinance as for State D ensity Bonus law. As such, the Project’s requested approvals are not over and above what is permitted and allowed.
It should be noted that s ince publication of the IS/MND, the Project Applicant has withdrawn the Planned Development application. As describe d, the withdrawal of the Planned Development application would not change the significance determination related to land use and planning.
8-8 This comment suggests the proposed Project would conflict with the City’s tree preservation policy and could result in impacts to the mature ficus trees along Green Street . Please refer to Response to Comment 8 -3. Further, Section 2.4, Biological Resources, evaluated the Project’s potential to conflict with local policies or ordinances such as Municipal Code Section
8.52.010, which is designed to protect and maintain mature and healthy trees and requires all street/public trees proposed for removal to be replaced. As such, the proposed Project would be constructed such that the mature trees along East Green Street would be preserved in place, whereas some existing street trees along South Hudson Avenue and South Oak Knoll Avenue that are in poor health would be removed and replaced with new trees. Please see Figure 12, Tree Inventory, for more details. As stated in the IS/MND, with adherence to the City’s Municipal Code, the pr oposed Project would not conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance.
Moreover, the City conducted a Protected Tree Report prepared by a certified arborist on February 4, 2 022 (included as Attachment C to this Final MND) which confirmed Project implementation would not significantly impact the existing ficus trees on East Green Street and made recommendations in compliance with the City’s Municipal Code. Therefore, this comment does not provide evidence of any new impacts that were not previously analyzed in the IS/MND, and no revisions to the IS/MND are required.
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Response to Comment Letter No. 9-PC
Nina Chomsky
December 17, 2020
9-1 This comment is from the City of Pasadena ’s Planning Commission meeting on December 17, 2020. The comment raises concern for the public review period provided for the IS/MND during the end of the year holiday season. The comment requests an extension to the comment period by 2 weeks. The IS/MND was circulated for public review from December 3, 2020 t hrough January 4, 2021 , and in accordance with the statutory requirements of CEQA. Of note, all comment letters received by the City have been included in this document. This comment will be provided to the City’s decision makers for their review and consideration as part of this Final MND.
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Response to Comment Letter No. 10
Christine Fedukowski
January 18, 2021
10-1 This comment states the IS/MND is not adequate and an Environmental Impact Report should be prepared for the proposed Project. This particular comment does not indicate reasons why the IS/MND is inadequate. The comment letter further details concerns, below. Please see Responses to Comments 10-2 through 10-6 for more discussion. 10-2 This comment asserts that the proposed Project is inconsistent with General Plan Policy 4.2 and that the commercial uses proposed on site are for the “operational aspects of the apartment building” (e.g., leasing office and resident business center ) and should not be considered as commercial uses . As such, the comment believes Project implementation would result in a net loss of commercial uses.
The comment incorrectly states the Project would include 0.065% of nonresidential uses. As shown in Figure 4, Level One Floor Plan, of the public review draft IS/MND, the proposed Project included the following commercial uses: 2,031 square feet of restaur ant/café uses, a 5,222-square-foot commercial/retail space, and 5,483 square feet of commercial/retail space on the western half of the first floor and a second 3,496-square-foot café space on the eastern half. As such, the total square footage of commercial uses proposed on the first floor would be 16,232 square feet. This represents approximately 6.4% of the Project’s total square footage and excludes the proposed leasing office and resident business center. Furthermore, IS/MND Table 2.1 -1, General Plan Policy/Programs, Specific Plan, and Municipal Code Consistency Analysis, describes the Project as consistent with General Plan Policy 4.2.
Moreover, subsequent to the publication of the IS/MND for public review, the Project Applicant changed select components of the proposed Project, including conversion of commercial uses to office uses and the removal of project design features like the pedestrian walkways. Such revisions do not result in any new significant impacts or a substantial increase in the severity of any environmental impacts. See Section 2.0 of this Final MND for more details.
Therefore, the IS/MND’s consistency determination is valid. This comment does not provide evidence of any new impacts that were not previously analyzed in the IS/MND, and no revisions to the IS/MND are required.
10-3 This comment questions the IS/MND’s definition of outdoor community space and states only the pocket park is publicly accessible open space. In addition, the commenter raises concern for the proposed breezeway s and asserts this design feature is not allowed within the City.
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features like the pedestr ian walkways . For determining compliance with the required community open space, per Zoning Code Section 17.50.160(H), rooftop terraces and common area courtyards are permitted so long as they meet the minimum dimensions (6 feet by 15 feet) and provide some form of recreational function. Breezeways/hallways connecting units aren’t included in this calculation unless they truly are providing an amenity, and again meet the minimum dimensions. Furthermore, t he Zoning Code Section 17.80.020(O) defines Useable Open Space as “[o]utdoor space that serves a recreational function or provides visual relief from the building mass, the minimum dimension of which shall be six feet excluding required front yards not used for balconies or patios. For more details, see Figure 11, Open Space Areas, of Attachment A to this Final MND.
The IS/MND states the City’s Master Plan identifies the Central District (i.e. where the proposed Project is located) as a unique urban core that is denser than other parts of the City and where large, traditional parks are more difficult to establish due to high land costs, intense existing urban development, and a general lack of available land for conversion to parkland and recreational open space (City of Pasadena 2007 ). Furthermore, the Master Plan states that, “Given the built -out condition of the City, it is very unlikely that even a fraction of this amount of acreage could be converted to parkland. A more likely scenario is that small urban open space areas might be created that could provide some of the desired amenities” (City of Pasadena 2007). As stated in Attachment A, Revised IS/MND, the proposed Project would include a 4,033-square-foot publicly accessible pocket park, which would, in part, provide public parkland and recreational open space near downtown Pasadena, including within the Specific Plan area. Thus, the proposed Project would provide a pocket park in an area in the City where traditional parks are more difficult to establish. Additionally, given the pocket park would be located in a unique urban core that is denser than other parts of the City, the pocket park provided by the Project would increase access for residents in this portion of the City to access park spaces.
Lastly, the comment asserts the Project is not consistent with General Plan Policy 4.2 due to a lack of diversity of uses and open space. As described above, the Project is consistent with open space requirement s. Moreover, the comment incorrectly assumes individual project consistency is measured by a diversity of uses on each site. Instead, the overarching goal for this particular policy, Goal 4, states a diversity of uses and forms is intended city -wide. As such, the Project’s components would be consistent with Policy 4.2 as proposed.
Therefore, this comment does not provide evidence of any new impacts that were not previously analyzed in the IS/MND, and no revisions to the IS/MND are required. 10-4 This comment expresses the importance of the mature tree canopy along Green Street and states the Project is not consistent with General Plan Policy 6.1. The comment states that the proposed Project poses a threat to the tree s where underground parking is proposed and building mass may conflict.
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The IS/MND concludes the Project is consistent with General Plan Policy 6.1 with the following analysis (see Attachment A, Revised IS/MND, Section 2.1, Aesthetics, page 19):
The height and setback variations proposed for the mixed -use buildings would allow for the visual dispersal of the Project’s density by utilizing step-down massing between floors.
The proposed mixed -use Project would be contemporary in style; however, the building would incorporate design elements found in many of the historic Spanish Revival buildings that contribute to Pasadena’s architecture. The aesthetic design goal of the proposed Project is to provide a form, proportion, and articulation that relates to similar architectural approaches throughout the urban areas of Pasadena and maintains a clean and streamlined composition conveyed in a contemporary manner. The proposed Project would include a pocket park on Oak Knoll Avenue, which would serve to comp liment the proposed Project’s step -down architectural design and integrate the Project density into the neighborhood.
The commenter’s concern with the existing tree canopy along Green Street is addressed through the Project’s compliance with the City’s Mu nicipal Code on setbacks (i.e., 5 feet on Green Street, see IS/MND Table 1-2, Project Development Standards), as well as the City’s Municipal Code requirements related to trees (see Chapter 8.52, City Trees and Tree Protection Ordinance). The City’s tree ordinance sets forth robust and detailed requirements for activities related to public trees and prohibits any injury or removal of a mature tree without a permit. As stated in Section 8.52.085(J), “To do or commit any unpermitted act that is injurious to a protected tree, including, but not limited to, causing root damage, damage to the trunk, scarring, or any other unpermitted alteration of a protected tree” is prohibited. As noted in the IS/MND, the proposed Project would preserve the mature ficus trees along Green Street and would be prohibited from causing any injury to the tree. Furthermore, as shown in Figure 10b, North and South Elevations, the massing of the buildings would be setback from Green Street and the existing mature ficus trees along Green Street would be preserved ( see Attachment A, Revised IS/MND Section 2.1, Aesthetics, page 18 ). Moreover, the City conducted a Protected Tree Report prepared by a certified arborist on February 4, 2022 (included as Attachment C to this Final MND) which confirmed Project implementation would not significantly impact the existing ficus trees on East Green Street and made recommendations in compliance with the City’s Municipal Code . Therefore, this comment does not provide evidence of any new impacts that were not previously analyzed in the IS/MND, and no revisions to the IS/MND are required.
10-5 This comment asserts that the Project applicant cannot use the City’s Inclusionary Housing Ordinance Concessions as well as the State Density Bonus regulations to support the proposed Project. In addition, the comment questions the calculations for the floor-to-area ratio (FAR) and number of units. Furthermore, the comment notes the Project proposes more studios than one-bedrooms, which is inconsistent with the State’s affordable housing priorities suitable for families (i.e. 2- to 3-bedroom units).
The Project’s proposed State Density Bonus component would allow for a 30% density bonus from the 87 dwelling units per acre currently allowed in the CD-4 zone. In addition, the Project would utilize two On-Menu concessions (0.5 FAR increase and a 12-foot height increase) from 740-790 East Green Street Mixed-Use Project / Responses to Comments on the IS/MND & MMRP
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the City’s Inclusionary Housing Ordinance . The Project site’s General Plan designation of Medium Mixed-Use allows for a FAR of 0 to 2.25. The site’s existing zoning of CD-4 requires an FAR standard of 2. Per the City’s Zoning Code Section 17.43.055, On -Menu Density Bonus, a 0.5 increase in FAR is permitted by designating 41 units as affordable housing on - site. As such, compliance with the City’s Inclusionary Housing Ordinance would allow the Project to utilize the City’s concessions to increase the Project’s floor area ratio from 2.0 to
2.5. In addition, n o Affordable Housing Concession Permit is required an d no Off-Menu concessions are requested. The Project is permitted to utilize the same affordable units for the City’s Inclusionary Housing Ordinance as for State D ensity Bonus law. As such, the Project’s requested approvals are not over and above what is permitted and allowed.
Lastly, the proposed Project would result in 263 for-rent units (including 41 units designated as affordable housing). This would consist of 86 studio units, 126 one-bedroom units, and 51 two- bedroom units. The commenter was not specific on the referenced State affordable housing priority. State and regional housing goals (i.e., the Southern California Association of Government’s Regional Housing Needs Assessment) are based on unit count and not unit type.
The Project would contribute to the City’s regional housing goals (i.e., Regional Housing Needs Assessment). Therefore, this comment does not provide evidence of any new impacts that were not previously analyzed in the IS/MND, and no revisions to the IS/MND are required. 10-6 This comment claims the IS/MND does not have supporting evidence to determine the effectiveness of MM-TRA-1 to reduce transportation impacts to a less -than-significant level, and states that the Metro passes are not proved to be adequate mitigation. This comment is incorrect, as the Ci ty has determined that the performance standard to achieve a 27% reduction in vehicle trips set forth in MM-TRA-1 is feasible and achievable. As set forth in MM- TRA-1, the Metro passes were only one of the requirements in order to achieve the performance standard.
The City of Pasadena, as Lead Agency under CEQA, has developed the methodology for assessing impacts to transportation and vehicle miles traveled and has determined the potential means by which such impacts could be mitigated in order to achieve less-than- significant impacts. This methodology is universally applied to Projects within the City and constitutes adequate substantial evidence to conclude that compliance with the City’s General Plan Mobility Element objectives and policies. The Project analysis is based on the City’s Transportation Impact Analysis Guidelines using the City’s calibrated travel demand forecasting model built on Southern California Association of Government’s regional model.
The City’s use of Metro passes as a condition is to encourage the use of transit and reduce car dependence to and from the Project site. Reduction of vehicular trips can be accomplished by providing individuals with efficient alternative modes of travel and incentivizing use of alternative modes. Providing transit passes provides an alternative mode choice for people to reduce vehicular trips and eliminates one obstacle or disincentive to using transit by addressing the financial cost.
Nevertheless, subsequent to the publication of the IS/MND for public review, the Applicant revised the Project to conform to the requirements of the CD -4 zone and the proposed revisions to the project description (as shown in Section 2.0 of this Final MND), which results 740-790 East Green Street Mixed-Use Project / Responses to Comments on the IS/MND & MMRP
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in a condition that would not exceed any CEQA significance thresholds related to Transportation, as demonstrated in Attachment B of this Final MND. Therefore, the changes in the Project Description accomplish the intent of MM-TRA-1, and no additional mitigation related to transportation is required . See Attachment A , Revised IS/MND for revisions to Section 2.17, Transportation, page 112. Therefore, this comment does not provide evidence of any new impacts that were not previously analyzed in the IS/MND.
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Response to Comment Letter No. 11
Erika Foy
January 15, 2021
11-1 This comment states the IS/MND is inadequate related to projected vehicle trip metrics and states that the proposed mitigation would not guarantee a reduction in the proposed Project’s vehicle trips. This commenter’s statement regarding the effectiveness of MM-TRA-1 is incorrect, as the City has determined that the performance standard to achieve a 27% reduction in vehicle trips set forth in MM-TRA-1 is feasible and achievable, and the Applicant must determine the means of compliance via the preparation of the Transportation Demand Management Plan, while conforming with the City’s Trip Reduction Ordinance. The Metro passes are but one requirement in order to achieve the performance standard. For instance, achievement of the 27% reduction could be accomplished by converting the commercial component to office (as shown in Attachment B of this Final MND) or reducing some combination of the unit count and/or square footage of commercial use areas, and/or prescribing particular uses within the commercial use areas that achieve the vehicle reductions. Such options would have no impact on the analysis included in the IS/MND and could potentially reduce environmental impacts if reductions in units or square footage was required.
The Ci ty, as Lead Agency under CEQA, has developed the methodology for assessing impacts to transportation and vehicle miles traveled (VMT) and has determined the potential means by which such impacts could be mitigated in order to achieve less than significant impacts. This methodology is universally applied to Projects within the City and constitutes adequate substantial evidence to conclude that compliance with the City’s General Plan Mobility Element objectives and policies. The Project analysis is based on t he City’s Transportation Impact Analysis Guidelines using the City’s calibrated Travel Demand Forecasting (TDF) model built on Southern California Association of Government’s regional model. Since the publication of the IS/MND, the City drafted a Transportation Impact Analysis, included as Attachment B to this Final MND on February 24, 2022, for a revised scenario assuming 263 residential units and 16,229 square feet of office. As demonstrated in Attachment A to this Final MND, the Project’s impacts related to CEQA Guidelines section 15064.3 would be less than significant. Therefore, the inclusion of MM -TRA-1 has been proven feasible and no additional mitigation is related to transportation is required . See revisions included in Section 2.17 of Attachment A for more details. In addition, since the publication of the IS/MND, the Project Applicant has changed components of the proposed Project. For example, the Project would continue to include 263 residential units (including 41 affordable housing units). However, the Project has been revised to include 14,346 square feet of office instead of 16,481 square feet of commercial. Such revisions do not result in any new significant impacts or a substantial increase in the severity of any environmental impacts.
See Section 2.0 of this Final MND for more details. Therefore, this comment does not provide evidence of any new impacts that were not previously analyzed in the IS/MND. 11-2 This comment questions the Project’s proposed daily trip generation, notes the existing vacancy in surrounding properties, and questions the assumption made in the analysis. If the Project site’s existing uses were not accounted for and operating at the time the City began the transportation analysis, the Project-related impacts would be overstated. If this and other credits 740-790 East Green Street Mixed-Use Project / Responses to Comments on the IS/MND & MMRP
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were not taken into consideration, the Project’s associated trips would be added to background intersection and segment traffic conditions that would be eliminated by the new development.
Moreover, the comment’s concern for the Outside CEQA analysis is not relevant to the adequacy of this IS/MND given that the Cit y’s CEQA significance thresholds related to transportation are based on VMT and not level of service (LOS) (i.e., a methodology derived from vehicle trip generation and distribution).
11-3 This comment questions the VMT threshold for the City and if the Project’s population generated were calculated at 537 (based on the commenter’s calculations) or 310 (from the IS/MND).
The commenter is conflating the incremental population increase of 537 to be from the Project only. The 537 value is not specific to the occupancy of the Project alone. The City of Pasadena’s TDF model uses information from the Southern California Associat ion of Government’s Planning Model, the National Household Travel Survey, Census data, street network information, travel characteristics, traffic counts, parcel level land use data, and other data sources to develop over 300 traffic analysis zones in the 2013 TDF model to forecast parcel interactions, travel patterns, and demand. The incremental scenario results population calculation of 537 reflects the Citywide incremental change. The calculated incremental 537 population increase does not trigger a VMT/ cap impact. Therefore, this comment does not provide evidence of any new impacts that were not previously analyzed in the IS/MND. 11-4 This comment questions the City’s methodology due to COVID in early/mid-April 2020 during stay-at-home orders within the City. An Outside CEQA analysis was completed on April 6, 2022and determined none of the study intersections exceeded the LOS cap. Similar to Comment 11-2, above, the comment’s concern for the Outside CEQA analysis is not relevant to the adequacy of this IS/MND given that the City’s CEQA significance thresholds related to transportation are based on VMT and not level of service (LOS) (i.e., a methodology derived from vehicle trip generation and distribution).
11-5 This comment notes previous action by the Pasadena City Council on November 16, 2020 , which changed the thresholds of significance for transportation impacts. The comment notes the amendment did not include a “grandfather” exception.
City Council Resolution No. 9820 states that the new CEQA thresholds shall apply to any new project applications deemed complete 90 days after November 16, 2020, the date of adoption of the resolution. Significant time and resources were spent by City staff on the project prior to adoption. Since this project application was deemed complete prior to adoption, the amendment does not apply. This comment does not provide evidence of any new impacts that were not previously analyzed in the IS/MND, and no revisions to the analysis within the IS/MND is required.
11-6 This comment states a group of residents hired PRISM Engineering to assist the group in understanding traffic reports within the City. The comment notes a traffic study was prepared in January 2020 to provide more analysis on existing conditions. 740-790 East Green Street Mixed-Use Project / Responses to Comments on the IS/MND & MMRP
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An Outside CEQA analysis was completed on April 6, 2022. Traffic count data was collected in 2022. The latest Synchro 11 software was used in the updated analysis. Furthermore, default values were not used for saturation flow rates and peak-hour factors in the calculations. This comment does not provide evidence of any new impacts that were not previously analyzed in the IS/MND, and no revisions to the analysis within the IS/MND is required. 11-7 This comment raises concern for the City’s use of outdated Synchro software to determine the methodology and evaluation of transportation impacts. The comment notes concern for the “Peak Hour Factor” and the “Ideal Flow” calculated by the City’s D epartment of Transportation. As such, the comment believes the LOS calculations are inadequate. The comment also asks if the proposed Project would result in significant traffic impacts to Lake Street and South Los Robles. Similar to Comment 11-2, above, the comment’s concern for the Outside CEQA analysis is not relevant to the adequacy of this IS/MND given that the City’s CEQA significance thresholds related to transportation are based on VMT and not level of service (LOS) (i.e., a methodology derived from vehicle trip generation and distribution). 11-8 This comment summarizes the letter by asking for transparency and for the City to use current technology. The comment expresses the opinions of the commenter and does not raise any issues regarding the adequacy of the environmental analysis in the IS/MND. No response is required. However, the comment will be forwarded to the decision makers for consideration as part of the Project record.
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Response to Comment Letter No. 12
Erika Foy
December 17, 2020
12-1 This comment describes existing concern for the City of Pasadena’s traffic conditions and cites potential impacts from related projects onto Lake Street and South Los Robles Avenue. This comment does not express specific environmental comments or concerns with the adequacy of the IS/MND. However, as detailed in Section 2.17, Transportation, of the IS/MND, all transportation impacts were determined to be less than significant. In addition, since the publication of the IS/MND, the City drafted a Transportation Impact Analysis, included as Attachment B to this Final MND on February 24, 2022, for a revised sc enario assuming 263 residential units and 16,229 square feet of office. As demonstrated in Attachment A to this Final MND, the Project’s impacts related to CEQA Guidelines section 15064.3 would be less than significant. Therefore, MM-TRA-1 has been proven feasible and has been revised to ensure the mix of land uses would accomplish the intent of the mitigation measure. See revisions included in Section 2.17, Transportation of Attachment A, Revised IS/MND for more details. 12-2 This comment states concern for traffic under existing conditions and the Project’s potential impacts on Lake Street and South Los Robles Avenue as well as surrounding residential neighborhoods, and states the mitigation is not sufficient.
As previously mentioned, IS/MND Section 2.17, Transportation, concludes all transportation impacts would be less than significant or less than significant with mitigation incorporated. This commenter’s statement regarding the effectiveness of MM-TRA-1 is incorrect, as the City has determined that the performance standard to achieve a 27% reduction in vehicle trips set forth in MM-TRA-1 is feasible and achievable. The Metro passes are but one requirement in order to achieve the performance standard. For instance, achievement of the 27% reduction could be accomplished by converting the commercial component to office (as shown in Attachment B to this Final MND ) or reducing some combination of the unit count and/or square footage of commercial use areas, and/or proscribing particular uses within the commercial use areas that achieve the vehicle reductions. Such options would have no impact on the analysis included in the IS/MND and could potentially reduce environmental impacts if reductions in units or square footage was required.
The City, as Lead Agency under CEQA, has developed the methodology for assessing impacts to transportation and vehicle miles traveled and has determined the potential means by which such impacts could be mitigated in order to achieve less than significant impacts.
This methodology is universally applied to projects within the City and constitutes adequate substantial evidence to conclude t hat compliance with the City’s General Plan Mobility Element objectives and policies. The Project analysis is based on the City’s Transportation Impact Analysis Guidelines using the City’s calibrated Travel Demand Forecasting model built on Southern California Association of Government’s regional model. Since the publication of the IS/MND, the City drafted a Transportation Impact Analysis, included as Attachment B to this Final MND on February 24, 2022, for a revised scenario assuming 263 residential units and 16,229 square feet of office. As demonstrated in Attachment A to this Final MND, the Project’s impacts related to CEQA Guidelines Section 15064.3 would be less than significant. 740-790 East Green Street Mixed-Use Project / Responses to Comments on the IS/MND & MMRP
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As such, MM-TRA-1 has been proven feasible and revised to ensure the mix of land uses would accomplish the intent of the mitigation measure . In addition, subsequent to the publication of the IS/MND, the Project Applicant has changed select components of the proposed Project. For example, the Project would continue to include 263 residential units (including 41 affordable housing units). However, the Project has been revised to include 14,346 square feet of office rather than the originally proposed 16,481 square feet of commercial. Such revisions do not result in any new sig nificant impacts or a substantial increase in the severity of any environmental impacts. See Section 2.0 of this Final MND for more details. Therefore, this comment does not provide evidence of any new impacts that were not previously analyzed in the IS/MND.
12-3 This comment states the importance of transparency when the City considers analysis related to traffic and new development. In addition, the comment requests for more time to respond to the IS/MND’s analysis. The commenter cites the end of the year holiday break and the on- going pandemic as reasons for delay. The IS/MND was circulated for public review from December 3, 2020 to January 4, 2021 , and in accordance with the statutory requirements of CEQA. This co mment will be provided to the City’s decision makers for their review and consideration as part of this Final MND.
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Response to Comment Letter No. 13-PC
Mic Hansen
December 17, 2020
13-1 This comment is from the City of Pasadena’s Planning Commission meeting on December 17, 2020. This comment requests for the public comment period for the IS/MND be extended 15 to 30 days to allow the community to respond due to the ongoing pandemic and end of the year holiday season. The IS/MND was circulated for public review from December 3, 2020 to January 4, 2021, and in accordance with the statutory requirements of CEQA. This comment will be provided to the City’s decision makers for their review and consideration as part of this Final MND.
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Response to Comment Letter No. 14
Joseph F. Paggi, Jr.
December 9, 2020
14-1 This comment expresses support for the proposed Project and cites design changes and accommodations made by the Project applicant to address community concern. This comment will be provided to the decision makers for their review and consideration as part of this Final MND. Additionally, this comment does not express any environmental comments or concerns; no further response is required.
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Response to Comment Letter No. 15
Gail B. Price, Esq.
December 22, 2020
15-1 This comment expresses opposition to the removal of ficus trees on Green Street and cites shade and community character and requests reports prepared by an arborist for the proposed Project be provided for public review. As described in Section 2.4, Biological Resources, of the IS/MND, the proposed Project would be constructed such that the mature trees along East Green Street would be preserved in place, whereas some existing street trees along South Hudson Avenue and South Oak Knoll Avenue that are in poor health would be removed and replaced with new trees. All street/public trees proposed for removal would be removed per the City’s Municipal Code Section 8.52.010.
The commenter’s concern with preserving the existing tree canopy for shade and character/beauty along Green Street is a ddressed through the Project’s compliance with the City of Pasadena ’s Municipal Code on setbacks (i.e., 5 feet on Green Street, see IS/MND Table 1 -2, Project Development Standards), as well as the City’s Municipal Code requirements related to trees (see Chapter 8.52, City Trees and Tree Protection Ordinance).
The City’s tree ordinance sets forth robust and detailed requirements for activities related to public trees and prohibits any injury or removal of a mature tree without a permit. As stated in Section 8.52.085(J), “To do or commit any unpermitted act that is injurious to a protected tree, including, but not limited to, causing root damage, damage to the trunk, scarring, or any other unpermitted alteration of a protected tree” is prohibited. As noted in the IS/MND, the proposed Project would preserve the mature ficus trees along Green Street and would be prohibited from causing any injury to the tree. Furthermore, as shown in Figure 10b, North and South Elevations, the massing of the buildings would be se tback from Green Street and the existing mature ficus trees along Green Street would be preserved (Attachment A, Revised IS/MND, Section 2.1, Aesthetics, page 18 ). Moreover, the City conducted a Protected Tree Report prepared by a certified arborist on Feb ruary 4, 2022 (included as Attachment C to this Final MND) which confirmed Project implementation would not significantly impact the existing ficus trees on East Green Street and made recommendations in compliance with the City’s Municipal Code . 15-2 This comment asks if the proposed Project would include low- to middle-income housing. As described in the IS/MND, the Project includes 263 for-rent units, which includes 41 affordable housing units . Based on the latest submittal, the Project Applicant proposes six very -low- income units, six low-income units, and 29 moderate-income units.
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2 OVERVIEW OF CHANGES TO THE IS/MND
The comments received by the City during the public review period for the IS/MND included information that has resulted in minor revisions to the text of the IS/MND. Text has been added is shown as bold underlined (i.e., underline). Text that has been removed is shown in strikeout (i.e., strikeout).
In addition, the Project Applicant has since changed components of the proposed Project, including, but not limited to the following:
• Change in Discretionary Actions: The Project Applicant is no longer requesting the establishment of a Planned Development No. 37 (PD 37) zoning district via a Zone Change for the Project site. As such, the site’s existing CD-4 Zoning District development standards apply to the proposed Project.
The Project Applicant proposes the use of the State Density Bonus through California Government Code Section 65915 as well as the City’s Affordable Housing Concession Menu. Therefore, the proposed Project would be subject to Design Review approval. • Change in Land Use and Square Footage: The proposed Project would result in a 253,917254,152- sf mixed-use structure including 263 residential units (including 41 affordable housing units) and 16,48114,346 sf of commercial office uses. In addition, the proposed Project includes 27,18027,795 sf of outdoor community open space (i.e. 4,1104,033-sf publicly available pocket park, breezeways, swimming pool courtyard, roof terraces), 600 sf of indoor community open space, and 11,70311,585 sf of private open space (i.e. balconies), for a total of 39,48339,980 sf of community open space.
Given the changes outlined above, this Final MND includes a copy of the public review draft IS/MND with text additions and text removed , as Attachment A. These errata do not create an issue with regard to a stable and finite project description, nor do they constitute “substantial revisions” requiring recirculation of the IS/MND, as set forth in State CEQA Guidelines Section 15073.5. The CEQA process does not have to freeze the ultimate project proposal, especially where the changes could reduce impacts and provided that the description is stable enough to allow for intelligent public participation, as is the case here. A substantial revision is identified as follows: (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 significant and new measures or revisions must be required.
The withdrawal of the Planned Development application would not change the significance determination related to land use and planning as detailed in the IS/MND. Instead, the proposed Project would conform to the site’s existing CD -4 zoning district and comply with all applicable development standards for implementation. In addition, the Project Applicant would continue to use State Density Bonus regulations and the City’s Affordable Housing Concessions Menu; thus, the Project would be eligible for a 30% density bonus as well as concessions on floor area ratio and height with the inclusion of 41 affordable housing units. Overall, the proposed Project would still be subject to Design Review approval. These changes to discretionary actions would not result in new, avoidable significant effects on the environment.
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Plan and the CD-4 zoning district; thus, the Project would not require a General Plan amendment or zone change. The Medium Mixed -Use General Plan designation is intended to support the development of multi-story buil dings with a variety of compatible commercial (retail and office) and residential uses.
Development is characterized by shared open spaces, extensive landscaping, small to medium separations between buildings, and shared driveways and parking. Sites may be exclusively commercial or exclusively residential, or with buildings vertically integrating housing with non -residential uses.
Typically, office uses are less intensive land uses (e.g., less vehicle trip generation, less utility supply and demand generati ons, etc.) when compared to other commercial uses. For example, as detailed in Response to Comment 1 -3, using the generation factors provided by LACSD, the previously proposed project would have result in approximately 57,509 gallons per day of wastewater6 (without considering the existing uses) and the revised Project is anticipated to result in 43,897 gallons per day.7 As such, the revised Project would generate in less wastewater as compared to the previously proposed project. Given this, the revisions to the proposed Project do not result in any new significant impacts or a substantial increase in the severity of any environmental impacts.
In addition, a new Transportation Impact Analysis was prepared by Pasadena Department of Transportation on Februar y 24, 2022 (included as Attachment B to this Final MND). The analysis assumed a project scenario with 263 residential units and 16,229 square feet of office. These inputs are slightly different than the Project Applicant’s revised design (see Attachment A to this Final MND); however, the City has reviewed and confirmed that the transportation-related impact analysis is accurate and no new modeling beyond what is included in Attachment B is required.
Finally, the proposed Project has been revised to total 254,152 square feet from 253,917 square feet in size. Although this change is an increase from what was previously included in the IS/MND, this change is considered to be negligible given that the proposed office uses represents a decrease and the total number of residential units proposed would not change. As such, the change in square footage is representative of nominal ancillary space due to changes in the overall project design.
Therefore, as demonstrated in the revised Initial Study in Attachment A, avoidable significant effects have been identified, no new mitigation measures were added, and the text of the document has not been substantially revised in a manner requiring recirculation.
6 (263 units x 156 gallons per day) + [16,481 sf x (1000 gallons per day/1000 square feet)] = 57,509 gallons per day 7 (263 units x 156 gallons per day) + [14,346 sf x (200 gallons per day/1000 square feet)] = 43,897 gallons per day 740-790 East Green Street Mixed-Use Project / Responses to Comments on the IS/MND & MMRP 12101
151 June 2023
3 MITIGATION MONITORING AND REPORTING PROGRAM
The State CEQA Guidelines, Section 15074(d), requires that a lead or responsible agency adopt a mitigation monitoring plan when approving or carrying out a project when an IS/MND identifies changes that the lead agency has required in the project or made a condition of approval to mitigate or avoid significant environmental effects. As lead agency for the project, the City is responsible for adoption and implementation of the Mitigation Monitoring and Reporting Program (MMRP).
The MMRP is presented below i n Table 3-1 and will be in place and effective throughout all phases of the Project. The City will be responsible for administering the MMRP and ensuring that all parties comply with its provisions. The City may delegate monitoring activities to staff, con sultants, or contractors. The City will also ensure that monitoring is documented and that deficiencies are promptly corrected.
740-790 East Green Street Mixed-Use Project / Responses to Comments on the IS/MND & MMRP 12101
152 June 2023
INTENTIONALLY LEFT BLANK
740-790 East Green Street Mixed-Use Project / Responses to Comments on the IS/MND & MMRP 12101
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Table 3-1. Mitigation Monitoring and Reporting Program Checklist Mitigation Measure
Method of
Verification Implementing Party
Timing of Verification
Verifying Party
Completed
Comments
Pre-
Construction
During
Construction
Post-
Construction Initials Date
Cultural Resources
MM-CUL-1 Prior to commencement of construction activities at the Project site, the City of Pasadena’s construction contractor and construction personnel shall attend and complete a
Workers Environmental Awareness Program (WEAP) training conducted by a qualified archaeologist. The WEAP training shall provide: (1) the types and characteristics of archaeological materials that may be identified during construction and explain the importance of and legal basis for the protection of significant cultural resources; (2) proper procedures to follow in the event that cultural resources or human remains are
uncovered during ground-disturbing activities, including procedures for work curtailment or redirection; and (3) protocols for the contact of the site supervisor and archaeological monitor upon discovery of a resource. The procedures and protocols shall be included in the construction plans and require that a qualified archaeologist be retained to evaluate cultural resource discoveries as they occur, to determine the significance of the resource and the appropriate approach forward.
Submittal of
documentation of
WEAP training (e.g.,
syllabus, sign-in sheet,
etc.) to City for review
Construction
Contractor/ Qualified
Archaeologist
X City of
Pasadena
MM-CUL-2 If cultural resources are discovered during
construction of the proposed Project in the City of Pasadena that may be eligible for listing in the California Register for Historic Resources, all ground disturbing activities in the immediate vicinity of the find shall be halted until the find is evaluated by a Registered Professional Archaeologist. If testing determines that significance criteria are met, then the Project shall be required to perform data recovery, professional identification, radiocarbon dates as applicable, and other special studies; and provide a comprehensive final report including site record to the City of Pasadena and the South Central Coastal Information Center at California State
University Fullerton. No further grading shall occur in the area of the discovery until Planning Department approves the report.
Submittal letter report
of excavations and
findings to City for
review
Construction
Contractor/ Registered
Professional
Archaeologist
X City of
Pasadena
Geology and Soils
MM-GEO-1 Prior to commencement of any grading activity on- site, the Project Applicant shall retain a qualified paleontologist per the Society of Vertebrate Paleontology (SVP) (2010) guidelines. The paleontologist shall prepare a Paleontological Submittal of PRIMP to
City for review/
Submittal of
construction
Qualified Paleontologist X X City of
Pasadena
740-790 East Green Street Mixed-Use Project / Responses to Comments on the IS/MND & MMRP 12101
154 June 2023
Table 3-1. Mitigation Monitoring and Reporting Program Checklist Mitigation Measure
Method of
Verification Implementing Party
Timing of Verification
Verifying Party
Completed
Comments
Pre-
Construction
During
Construction
Post-
Construction Initials Date
Resources Impact Mitigation Program (PRIMP) for the
proposed Project. The PRIMP shall be consistent with the SVP (2010) guidelines and should outline requirements for
preconstruction meeting attendance and worker environmental awareness training, where monitoring is required within the proposed Project site based on construction plans and/or geotechnical reports, procedures for adequate paleontological monitoring and discoveries treatment, and paleontological methods (including sediment sampling for microvertebrate fossils), reporting, and collections management. The PRIMP shall also address reducing or terminating monitoring when no resources are found pursuant to the SVP (2010) guidelines.
The qualified paleontologist shall attend the preconstruction meeting and a paleontological monitor shall be on-site during all rough grading and other significant ground-disturbing activities beyond a depth of five feet below the existing ground surface or the depth of any artificial fill in previously undisturbed, fine- grained older Quaternary (e.g., Pleistocene age) alluvial fan deposits. In the event that paleontological resources (e.g., fossils) are unearthed during grading, the paleontological monitor will temporarily halt and/or divert grading activity to allow recovery of paleontological resources. The area of discovery will be roped off with a 50-foot radius buffer. Once documentation and collection of the find is completed, the monitor will remove the rope and allow grading to recommence in the area of the find.
monitoring logs to City
for review
Hazards and Hazardous Materials
Prior to commencement of any demolition or construction activities, a Hazardous Materials Contingency Plan (HMCP) shall be developed that addresses potential impacts in soil and the potential presence of USTs associated with the former gasoline service station located on the Project site. The HMCP shall include training procedures for identification of contamination and USTs, including procedures for a
geophysical survey to identify USTs in the area of the former gasoline service station. The HMCP shall describe procedures for assessment, characterization, management, and disposal of contaminated soils; assessment, characterization, and
management of soil vapor;, and notification and
decommissioning procedures for tanks, in accordance with all Submittal of the
HMCP to City for
review
Construction
Contractor/
Environmental Monitor
X City of
Pasadena
740-790 East Green Street Mixed-Use Project / Responses to Comments on the IS/MND & MMRP 12101
155 June 2023
Table 3-1. Mitigation Monitoring and Reporting Program Checklist Mitigation Measure
Method of
Verification Implementing Party
Timing of Verification
Verifying Party
Completed
Comments
Pre-
Construction
During
Construction
Post-
Construction Initials Date
applicable state and local regulations. The HMCP will be an internal document used by the permittee and/or its designee (e.g. environmental monitor). The HMCP will designate an environmental monitor who would determine disposal and
reporting requirements for contaminated soils, and will be present on-site during grading activities in areas where potentially impacted soils may be encountered as outlined in the HMCP. Contaminated soils shall be managed and
disposed of in accordance with local and state regulations (e.g.
City of Pasadena Best Management Practices for soil
stockpiles (City of Pasadena 2018), Draft Regional Water Board Fill Material Definitions (RWQCB 2020), DTSC Voluntary Cleanup Program and/or RWQCB Leaking Underground
Storage Tank program, as applicable). Should soil vapor contamination be identified above applicable regulatory levels, as outlined in the HMCP, soil vapor intrusion
methods will be outlined in the final report based on the findings on site and in accordance with February 2023
DTSC Final Draft Supplemental Guidance for Screening
and Evaluating Vapor Intrusion. Proposed engineering
methods for attenuation of vapor intrusion will be prepared and submitted with building plans and approved by the
permitting agency prior to issuance of construction
permits. The HMCP shall include health and safety measures, which may include but are not limited to periodic work breathing zone monitoring and monitoring for volatile organic compounds using a handheld organic vapor analyzer in the event impacted soils are encountered during excavation activities. Health and safety measures will be based on California and federal Occupational Safety and Health Administration (OSHA)
requirements for worker safety, including permissible exposure limits (PELs). The permittee or its designee shall implement the HMCP during construction activities for the proposed Project.
MM-HAZ-2 Prior to commencement of demolition or
construction activities on the southern portion of the Project site (APNs: 5734-025-027 and 5734-025-029), a hazardous
building materials survey shall be conducted to identify asbestos, lead-based paint, and other potentially hazardous building materials (such as mercury thermometers, lighting and electrical appurtenances). The survey shall be conducted on Submittal of
hazardous building
materials survey to
City for review
Construction
Contractor/ Hazardous
Materials Surveyor
X City of
Pasadena
740-790 East Green Street Mixed-Use Project / Responses to Comments on the IS/MND & MMRP 12101
156 June 2023
Table 3-1. Mitigation Monitoring and Reporting Program Checklist Mitigation Measure
Method of
Verification Implementing Party
Timing of Verification
Verifying Party
Completed
Comments
Pre-
Construction
During
Construction
Post-
Construction Initials Date
the two buildings in the southern portion of the Project site scheduled to be disturbed/demolished. Following results of the hazardous materials survey, demolition or renovation plans and contract specifications shall incorporate abatement procedures for the removal of materials containing asbestos and lead. All abatement work shall be done in accordance with federal, state, and local regulations, including those of the U.S.
Environmental Protection Agency, Occupational Safety and Health Administration, California Occupational Safety and Health Administration, and the South Coast Air Quality
Management District.
Noise
MM-NOI-1 Prior to approval of grading plans and/or prior to issuance of demolition, grading and building permits, the Project applicant shall retain a team to prepare a vibration monitoring plan. The team shall include a professional
structural engineer with experience in structural vibration analysis and monitoring for historic buildings and a historical architect to perform the following tasks:
• Review the Project plans for demolition and
construction;
• Survey the Project site and the property/buildings to the south (i.e., 128 South Oak Knoll Avenue and 133 South
Hudson Avenue);
• Conduct geological testing if determined to be
necessary, and:
• Prepare and submit a report to the Director of Planning and Community Development to include, but not be
limited to, the following:
o The information from the survey identified
above;
o Any modifications to the permissible vibration
level thresholds based on the structural
conditions of the adjacent properties to the
south, soil conditions, and planned demolition
and construction methods to ensure that
vibration levels would remain below the
potential for damage to the adjacent structures
to the south;
Submittal of a
vibration monitoring
plan to City for review
Construction
Contractor/ Vibration
Analysis and Monitoring
Team
X X City of
Pasadena
740-790 East Green Street Mixed-Use Project / Responses to Comments on the IS/MND & MMRP 12101
157 June 2023
Table 3-1. Mitigation Monitoring and Reporting Program Checklist Mitigation Measure
Method of
Verification Implementing Party
Timing of Verification
Verifying Party
Completed
Comments
Pre-
Construction
During
Construction
Post-
Construction Initials Date
o Specific measures (such as requiring the use of
lighter, less-powerful equipment when
applicable – a small bulldozer rather than a
large bulldozer for example - in proximity to the
southern Project boundary) to be taken during
demolition / construction to ensure that vibration
level limits identified by the structural engineer
(or 0.12 ppv in/sec in lieu of such specified
limits) are not exceeded;
o A monitoring plan to be implemented during
demolition and construction that includes post-
construction and post-demolition surveys of the
adjacent properties to the south and
documentation demonstrating that the
measures identified in the report have been
implemented.
Transportation
To reduce the original Project’s VT per capita, the Project Applicant/Developer shall either develop and implement a Transportation Demand Management (TDM) Plan that includes strategies to reduce the Project’s vehicle trips by a minimum of 27% or implement a mix of uses that achieves a minimum
of 27% reduction of VT as the Project described in the
Revised IS/MND does. If the TDM Plan approach is
undertaken as a result of the original Project, then
Programmatic programmatic strategies to reduce VT per
capita shall complement City’s Trip Reduction Ordinance minimum requirements and shall include, but not necessarily be limited to, the following:
• Unbundled parking for the residential use;
• The Project Applicant/Developer shall purchase 121
Metro passes and offer them to interested residents at
50% discount for five consecutive years from the
issuance of Certificate of Occupancy.
• The Project Applicant/Developer shall provide an
Annual TDM Survey beginning one year after the
issuance of Certificate of Occupancy to demonstrate
Submittal of
Transportation
Demand Management
Plan to City for review
and approval prior to
the issuance of a
Certificate of
Occupancy
Project Applicant X X City of
Pasadena
740-790 East Green Street Mixed-Use Project / Responses to Comments on the IS/MND & MMRP 12101
158 June 2023
Table 3-1. Mitigation Monitoring and Reporting Program Checklist Mitigation Measure
Method of
Verification Implementing Party
Timing of Verification
Verifying Party
Completed
Comments
Pre-
Construction
During
Construction
Post-
Construction Initials Date
the minimum 27% reduction of Project vehicular trips
per capita is maintained.
Tribal Cultural Resources
MM-TCR-1 The Project Applicant shall be required to retain and compensate for the services of a tribal monitor/consultant who is both approved by the Gabrieleño Band of Mission
Indians-Kizh Nation Tribal Government and is listed under the Native American Heritage Commission’s (NAHC) Tribal
Contact List for the area of the Project location. This list is provided by the NAHC. The monitor/consultant will only be present on site during the construction phases that involve ground-disturbing activities. Ground-disturbing activities are defined by the Gabrieleño Band of Mission Indians-Kizh Nation as activities that may include, but are not limited to, pavement removal, pot-holing or auguring, grubbing, tree removals, boring, grading, excavation, drilling, and trenching, within the Project area. The tribal monitor/consultant will complete daily monitoring logs that will provide descriptions of the day’s activities, including construction activities, locations, soil, and any cultural materials identified. The on-site monitoring shall end when the Project site grading and excavation activities are completed, or when the tribal representatives and
monitor/consultant have indicated that the site has a low potential for impacting tribal cultural resources.
Submittal of daily
construction
monitoring logs to the
City for review
Tribal Monitor X City of
Pasadena
MM-TCR-2 Upon discovery of any archaeological resources, cease construction activities in the immediate vicinity of the find until the find can be assessed. All archaeological resources unearthed by Project construction activities shall be evaluated by the qualified archaeologist and tribal monitor/consultant approved by the Gabrieleño Band of Mission Indians – Kizh Nation. If the resources are Native American in origin, the Gabrieleño Band of Mission Indians – Kizh Nation shall
coordinate with the landowner regarding treatment and curation of these resources. Typically, the tribe will request reburial or preservation for educational purposes. Work may continue on other parts of the Project while evaluation and, if necessary, mitigation takes place (California Environmental Quality Act [CEQA] Guidelines Section15064.5 [f]). If a resource is determined by the qualified archaeologist to constitute a Submittal of letter
report documenting
periodic monitoring to
the City for review
Construction
Contractor/ Qualified
Archaeologist/
Tribal Monitor
X City of
Pasadena
740-790 East Green Street Mixed-Use Project / Responses to Comments on the IS/MND & MMRP 12101
159 June 2023
Table 3-1. Mitigation Monitoring and Reporting Program Checklist Mitigation Measure
Method of
Verification Implementing Party
Timing of Verification
Verifying Party
Completed
Comments
Pre-
Construction
During
Construction
Post-
Construction Initials Date
“historical resource” or “unique archaeological resource,” time allotment and funding sufficient to allow for implementation of avoidance measures, or appropriate mitigation, must be
available. The treatment plan established for the resources shall be in accordance with CEQA Guidelines Section
15064.5(f) for historical resources and for unique
archaeological resources.
MM-TCR-3 Preservation in place (i.e., avoidance) is the preferred manner of treatment. If preservation in place is not feasible, treatment may include implementation of
archaeological data recovery excavations to remove the
resource along with subsequent laboratory processing and analysis. Any historic archaeological material that is not Native American in origin shall be curated at a public, non-profit institution with a research interest in the materials, such as the Natural History Museum of Los Angeles County or the Fowler Museum, if such an institution agrees to accept the material. If no institution accepts the archaeological material, they shall be offered to a local school or historical society in the area for educational purposes.
Submittal of letter
report documenting
treatment of
archaeological material
to City for review
Construction
Contractor/ Qualified
Archaeologist/
Tribal Monitor
X City of
Pasadena
MM-TCR-4 Native American human remains are defined in
Public Resources Code (PRC) 5097.98 (d)(1) as an inhumation or cremation, and in any state of decomposition or skeletal completeness. Funerary objects, called associated grave goods in PRC 5097.98, are also to be treated according to this statute. Health and Safety Code 7050.5 dictates that any discoveries of human skeletal material shall be immediately reported to the County Coroner and excavation halted until the coroner has determined the nature of the remains. If the coroner recognizes the human remains to be those of a Native American or has reason to believe that they are those of a Native American, he or she shall contact, by telephone within 24 hours, the Native American Heritage Commission, and PRC 5097.98 shall be followed.
Submittal of letter
report documenting
discovery and
treatment of human
remains
Construction
Contractor/ Qualified
Archaeologist/
Tribal Monitor
X City of
Pasadena
MM-TCR-5 Upon discovery of human remains, the tribal and/or archaeological monitor/consultant/consultant will immediately divert work at minimum of 150 feet and place an exclusion zone around the burial. The monitor/consultant(s) will then notify the Submittal of letter
report documenting
discovery and
treatment of human
Construction
Contractor/ Qualified
Archaeologist/
X City of
Pasadena
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Table 3-1. Mitigation Monitoring and Reporting Program Checklist Mitigation Measure
Method of
Verification Implementing Party
Timing of Verification
Verifying Party
Completed
Comments
Pre-
Construction
During
Construction
Post-
Construction Initials Date
tribe, the qualified lead archaeologist, and the construction manager who will call the coroner. Work will continue to be diverted while the coroner determines whether the remains are Native American. The discovery is to be kept confidential and secure to prevent any further disturbance. If the finds are determined to be Native American, the coroner will notify the Native American Heritage Commission as mandated by state law who will then appoint a Most Likely Descendant.
remains to City for
review
Tribal Monitor
MM-TCR-6 If the Gabrieleño Band of Mission Indians – Kizh Nation is designated as the Most Likely Descendant, the following treatment measures shall be implemented. To the tribe, the term “human remains” encompasses more than
human bones. In ancient as well as historic times, tribal traditions included, but were not limited to, the burial of funerary objects with the deceased and the ceremonial burning of human remains. These remains are to be treated in the same manner as bone fragments that remain intact. Associated funerary objects are objects that, as part of the death rite or ceremony of a culture, are reasonably believed to have been placed with individual human remains either at the time of death or later; other items made exclusively for burial purposes or to contain human remains can also be considered as
associated funerary objects.
Submittal of letter
report documenting
discovery and
treatment of human
remains to City for
review
Construction
Contractor/ Qualified
Archaeologist/
Tribal Monitor
X City of
Pasadena
MM-TCR-7 Prior to the continuation of ground-disturbing activities, the land owner shall arrange a designated site location within the footprint of the Project for the respectful reburial of the human remains and/or ceremonial objects. In the case where discovered human remains cannot be fully
documented and recovered on the same day, the remains will be covered with muslin cloth and a steel plate that can be moved by heavy equipment placed over the excavation
opening to protect the remains. If this type of steel plate is not available, a 24-hour guard should be posted outside of working hours. The tribe will make every effort to recommend diverting the project and keeping the remains in situ and protected. If the project cannot be diverted, it may be determined that burials will be removed. The tribe will work closely with the qualified archaeologist to ensure that the excavation is treated carefully, ethically and respectfully. If data recovery is approved by the Submittal of letter
report documenting
discovery and
treatment of human
remains and/or
ceremonial objects to
City for review
Construction
Contractor/ Qualified
Archaeologist/
Tribal Monitor
X City of
Pasadena
740-790 East Green Street Mixed-Use Project / Responses to Comments on the IS/MND & MMRP 12101
161 June 2023
Table 3-1. Mitigation Monitoring and Reporting Program Checklist Mitigation Measure
Method of
Verification Implementing Party
Timing of Verification
Verifying Party
Completed
Comments
Pre-
Construction
During
Construction
Post-
Construction Initials Date
tribe, documentation shall be taken which includes at a minimum detailed descriptive notes and sketches. Additional types of documentation shall be approved by the tribe for data recovery purposes. Cremations will either be removed in bulk or by means as necessary to ensure complete recovery of all material. If the discovery of human remains includes four or more burials, the location is considered a cemetery, and a separate treatment plan shall be created. Once complete, a final report of all activities is to be submitted to the tribe and the Native American Heritage Commission. The tribe does NOT authorize any scientific study or the utilization of any invasive diagnostics on human remains.
Each occurrence of human remains and associated funerary objects will be stored using opaque cloth bags. All human remains, funerary objects, sacred objects, and objects of cultural patrimony will be removed to a secure container on site if possible. These items should be retained and reburied within 6 months of recovery. The site of reburial/repatriation shall be on the Project site but at a location agreed upon between the tribe and the landowner at a site to be protected in perpetuity.
There shall be no publicity regarding any cultural materials recovered.
MM-TCR-8 Professional Standards: Archaeological and Native American monitoring and excavation during construction
projects will be consistent with current professional standards.
All feasible care to avoid any unnecessary disturbance, physical modification, or separation of human remains and associated funerary objects shall be taken. Principal personnel must meet the Secretary of the Interior standards for
archaeology and have a minimum of 10 years of experience as a principal investigator working with Native American
archaeological sites in Southern California. The Qualified Archaeologist shall ensure that all other personnel are appropriately trained and qualified.
Submittal of
qualifications for
Qualified
Archaeologist/
Tribal Monitor to City
for review
Construction
Contractor/ Qualified
Archaeologist/
Tribal Monitor
X City of
Pasadena
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162 June 2023
INTENTIONALLY LEFT BLANK
____________________________________________________________________________ 740-790 East Green Street Mixed-Use Project 12101
Responses to Comment on the IS/MND & MMRP June 2023
Attachment A-1
Revised IS/MND
DRAF T FINAL INITIAL STUDY /MITIGATED
NEGATIVE DECLARATION
740 -790 East Green Street
Mixed -Use Project
Prepared for:
City of Pasadena
175 North Garfield Avenue
Pasadena, California 91101-1704
Prepared by:
38 North Marengo Avenue
Pasadena, California 91101
DECEMBER 2020 JUNE 2023
Printed on 30% post-consumer recycled material.
12101
i December 2020 June 2023
TABLE OF CONTENTS
SECTION PAGE NO.
INITIAL STUDY ................................ ................................ ................................ ................................ ............................ 1 SECTION I. PROJECT INFORMATION................................ ................................ ................................ ................... 1 Project Summary .................................................................................................................................................. 2 Project Location ................................................................................................................................................... 3 Environmental Setting ......................................................................................................................................... 3 Existing Site Conditions .......................................................................................................................... 3 Existing Land Use and Zoning Designations ......................................................................................... 3 Surrounding Land Uses .......................................................................................................................... 4 Project Characteristics ......................................................................................................................................... 4 Project Design ......................................................................................................................................... 4 Circulation, Transportation, and Parking .............................................................................................. 6 Architectural Materials ........................................................................................................................... 7 Open Space and Landscaping ............................................................................................................... 7 Lighting ................................................................................................................................................... 7 Sustainability Features .......................................................................................................................... 8 Off-Site Project Components.................................................................................................................. 8 Short-Term Construction Activities ........................................................................................................ 8 Discretionary Actions .............................................................................................................................. 9 SECTION II. ENVIRONMENTAL CHECKLIST FORM ................................ ................................ ............................. 16
2.1 Aesthetics ............................................................................................................................................ 16
2.2 Agriculture and Forestry Resources ................................................................................................... 27
2.3 Air Quality ............................................................................................................................................. 29
2.4 Biological Resources ........................................................................................................................... 42
2.5 Cultural Resources .............................................................................................................................. 45
2.6 Energy .................................................................................................................................................. 49
2.7 Geology and Soils ................................................................................................................................ 56
2.8 Greenhouse Gas Emissions ................................................................................................................ 61
2.9 Hazards and Hazardous Materials ..................................................................................................... 70
2.10 Hydrology and Water Quality ............................................................................................................... 77
2.11 Land Use and Planning ....................................................................................................................... 84
2.12 Mineral Resources .............................................................................................................................. 85
2.13 Noise .................................................................................................................................................... 86
2.14 Population and Housing ...................................................................................................................... 97
2.15 Public Services .................................................................................................................................. 100
2.16 Recreation .......................................................................................................................................... 103
2.17 Transportation ................................................................................................................................... 107
2.18 Tribal Cultural Resources .................................................................................................................. 114 740-790 EAST GREEN STREET MIXED-USE PROJECT
DRAFT FINAL INITIAL STUDY
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ii December 2020 June 2023
2.19 Utilities and Service Systems ............................................................................................................ 118
2.20 Wildfire ............................................................................................................................................... 126
2.21 Mandatory Findings of Significance ................................................................................................. 129 SECTION III. REFERENCES AND PREPARERS ................................ ................................ ................................ .. 132
3.1 References Cited ............................................................................................................................... 132
3.2 List of Preparers ................................................................................................................................ 138
APPENDICES
A CalEEMod Outputs
B Cultural Resources Technical Report
C Energy Calculations
D Geotechnical Engineering Investigation
E Desktop Environmental Review and Document Review, Phase I Environmental Site Assessment, and Vapor Intrusion Risk Assessment
F Noise Assessment Technical Report
G Transportation Impact Analysis
H Utility Letters
FIGURES
Figure 1 Project Location
Figure 2 Existing Site Conditions
Figure 3 Site Plan
Figure 4 Level One Floor Plan
Figure 5 Level Two and Level Three Floor Plan
Figure 6 Level Three Floor Plan
Figure 6 7 Level Four Floor Plan
Figure 7 8 Level Five Floor Plan
Figure 8 9a Parking Garage: Level 1
Figure 8 9b Parking Garage: Level 2
Figure 9 10a East and West Elevations
Figure 9 10b North and South Elevations
Figure 9 10c Interior Courtyard Elevation
Figure 10 11 Open Space Areas
Figure 11 Open Space Concept
Figure 12 Tree Inventory
TABLES
Table 1-1 Proposed Project Floor Area
740-790 EAST GREEN STREET MIXED-USE PROJECT
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Table 1-2 Project Development Standards
Table 1-3 Estimated Construction Activities
Table 2.1-1 General Plan Policy/Programs, Municipal Code, and Specific Plan Consistency Analysis Table 2.3-1 SCAQMD Air Quality Significance Thresholds
Table 2.3-2 Construction Scenario Assumptions
Table 2.3-3 Estimated Maximum Daily Construction Emissions Table 2.3-4 Estimated Maximum Daily Operational Emissions Table 2.3-5 Construction Localized Significance Thresholds Analysis Table 2.6-1 Construction Equipment Diesel Demand (Off-Road Equipment) Table 2.6-2 Construction Worker Gasoline Demand
Table 2.6-3 Construction Vendor Diesel Demand
Table 2.6-4 Construction Haul Truck Diesel Demand
Table 2.6-5 Annual Operational Petroleum Demand
Table 2.8-1 Estimated Annual Construction GHG Emissions Table 2.8-2 Estimated Annual Operational GHG Emissions
Table 2.8-3 Project Consistency with the Southern California Association of Governments Connect SoCal RTP/SCS Table 2.14-1 City of Pasadena Demographics and Household Growth Forecast Table 2.16-1 Existing Parks and Open Space Areas in the City of Pasadena Table 2.19-1 Projected Water Supply to the PWP through 2040 Table 2.19-2 Normal Year, Single Dry Year, and Multiple Dry Year Supply and Demand Comparisons through 2040
740-790 EAST GREEN STREET MIXED-USE PROJECT
DRAFT FINAL INITIAL STUDY
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CITY OF PASADENA
175 NORTH GARFIELD AVENUE
PASADENA, CA 91101-1704
INITIAL STUDY
In accordance with the Environmental Policy Guidelines of the City of Pasadena, this analysis, the associated “Master Application Form,” and/or Environmental Assessment Form (EAF) and supporting data constitute the Initial Study for the subject project. This Initial Study provides the assessment for a determination whether the project may have a significant effect on the environment.
SECTION I. PROJECT INFORMATION
1. Project Title: 740-790 East Green Street Mixed-Use Project
2. Lead agency name and address: City of Pasadena
175 North Garfield Avenue
Pasadena, CA 91101-1704
3. Contact person and phone number: Stephanie Cisneros, Senior Planner (626) 744-7219
David Sinclair, Senior Planner
(626) 744-6766
Jennifer Driver, Planner
(626) 744-6756
4. Project location: 740-790 East Green Street (between Oak Knoll and Hudson Avenues), City of Pasadena. Project
site includes Assessor Parcel Numbers 5734-
025-024, -014, -026, -030, -029, and -027.
5. Project sponsor’s name and address: Stanford Pasadena, LLC
6. General plan designation: Medium Mixed-Use (0 to 2.25 Floor to Area Ratio [FAR])
7. Zoning: CD-4 (Central District Specific Plan , Pasadena Playhouse)
8. Description of project: See Project information below
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PROJECT SUMMARY
The 740-790 East Green Street Mixed -Use Project (proposed Project) would involve the demolition of five commercial buildings and the construction and operation of a new mixed-use project within the City of Pasadena Playhouse District. The proposed mixed-use structure is comprised of one 4-story mixed- use building on the northern portion and one 5-story residential building on the southern portion, which is connected by an outdoor ground-level breezeway and external pedestrian bridges connection at Level 2, Level 3, and Level 4 . The proposed buildings would be located on top of a two -level subterranean parking garage that encompasses the majority of the 2.33-acre property. Table 1-1 provides a summary of the Project’s total floor area (i.e. 253,917 254,152 square feet [sf]), which is the amount of occupiable floor area on the Project site.
Table 1-1. Proposed Project Floor Area
Level 4-Story Building 5-Story Building Total
1 26,506 25,069 34,100 33,506 60,606 58,575
2 26,390 24,850 34,980 35,222 61,370 60,072
3 26,390 24,850 34,980 35,222 61,370 60,072
4 8,134 11,433 34,980 35,222 43,114 46,655
5 - 266 21,421 21,455 21,421 21,721
P1 - - 4,304 4,589
P2 - - 1,732 2,468
Total 87,420 86,468 160,461 160,627 253,917 254,152
The 253,917 254,152-sf development includes 263 for-rent units (including 41 units designated as affordable housing), 16,481 14,346 sf of commercial office use (e.g., retail, café), lobby area, a leasing office, business center, fitness center, and pool lounge, as well as bicycle parking and mechanical equipment areas within the parking garage. The Project also includes 27,180 27,795 sf of outdoor community open space (i.e. 4,110 4,033-sf publicly available pocket park, breezeways, swimming pool courtyard, roof terraces), 600 sf of indoor community open space, and 11,703 11,585 sf of private open space (i.e. balconies), for a total of 39,483 39,980 sf of community open space.
The proposed Project would require a zone change from CD-4 to Planned Development No. 37 (PD 37).
The Project proposes to use the State Density Bonus legislated by the California Governm ent Code Section 65915 to develop 263 for-rent apartment units (30% above the 87 dwelling units per acre currently allowed in the CD-4 zone). Because the proposed Project would include 20% on-site affordable housing units, the Project would comply with the City’s Inclusionary Housing Ordinance, which would allow the Project to utilize the City’s concessions to increase the Project’s floor area ratio (FAR) from 2.0 to 2.5 and to increase the building height 12 feet above the allowed height limit of 35 fee t along Green Street in the northern portion and 50 feet along Hudson Avenue and Oak Knoll Avenue in the southern portion.
With incorporation of the City’s Affordable Housing Concession Menu, the proposed 4-story building would be built to a maximum height of 47 feet and the proposed 5-story building would be built to a maximum height of 62 feet. In addition, the proposed Project requests Design Review Approval. 740-790 EAST GREEN STREET MIXED-USE PROJECT
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PROJECT LOCATION
As shown in Figure 1, Project Location, the proposed Project site is located in the City of Pasadena (City) approximately 7 miles north of from Downtown Los Angeles. Regional access to the Project site is via Interstate (I) 210, exiting South Lake Avenue. Figure 1 shows the location of the Project site within the County and an aerial view of the immediately surrounding land uses. The Project site is bound by East Green Street to the north, South Hudson Avenue to the east, private property to the south, and South Oak Knoll Avenue to the west. The site is located in the “Central District Transit Oriented Development Area” of the City of Pasadena and within the Playhouse District South/Green Street Precinct. The Project is located at 740-790 East Green Street (between Oak Knoll and Hudson Avenue) and is comprised of six Assessor’s Parcel Numbers (APNs): 5734-025-014 -024, -026, -027, -030, and -029, which total 2.33 acres.
ENVIRONMENTAL SETTING
Existing Site Conditions
As shown on Figure 2, Existing Site Conditions, the Project site is currently developed with 5 commercial buildings, totaling approximately 34,668 sf. The existing buildings and their current uses are described in more detail below.
• Building A is a 5-story building with a 3,998 sf footprint, located on APN 5734 -025-024 on the northwestern portion of the Project site, fronting Green Street. The building is currently utilized as a dance studio and as office space for a certified public accounting agency and a business management consulting firm.
• Building B is a 5-story building with a 723 sf footprint, located on APN 5734-025-014, mid-block on the northern portion of the Project site, fronting Green Street. The building is currently utilized as restaurant space and studio space for a drama school. • Building C is a 2-story office building with a 17,308 sf footprint, located on the northeastern corner of the Project site, fronting Green Street. Building C is located on APN 5734 -025-026 and is currently utilized as office space for a law firm.
• Building D is a 1-story building with a 5,214 sf footprint, located on the southwestern portion of the Project site. Building D is located on APN 5734-025-027 near the southern boundary of the Project site, fronting Oak Knoll Avenue. The building is currently utilized as a family services center. • Building E is a 1-story office building with a 7,425 sf footprint, located on the southeastern portion of the Project site, fronting Hudson Avenue. Building E is located on APN 5734 -025-029. The building is currently utilized as a family services center.
The Project site also contains an existing paved surface parking lot located between Buildings A and D is located on APN 5734-025-030.
Existing Land Use and Zoning Designations
According to the City’s General Plan, the Project site is designated as Medium Mixed-Use (0 to 2.25 Floor to Area Ratio [FAR]) and is located within the CD-4 (Central District, Pasadena Playhouse) zoning district. 740-790 EAST GREEN STREET MIXED-USE PROJECT
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Properties designated as Mixed-Use by the Land Use Diagram may be developed for a singular use or a mix of uses on the same site. The Medium Mixed -Use designation is intended to support the development of multi -story buildings with a variety of compatible commercial (retail and o ffice) and residential uses. Development is characterized by shared open spaces, extensive landscaping, small to medium separations between buildings, and shared driveways and parking. Sites may be exclusively commercial or exclusively residential, or with buildings vertically integrating housing with non-residential uses. Mixed-use development projects containing housing shall incorporate amenities contributing to a quality living environment for residents including courtyards, recreation facilities, and s imilar elements.
Where buildings face the street frontage, they shall be designed to enhance pedestrian activity with transparent facades for retail uses and distinctive entries for housing. Parking shall be located below or to the rear of the street. Projects constructed at Medium Mixed Use densities may be required to develop pedestrian-oriented streetscape amenities along their primary street frontages, consistent with the improvement concepts and plans defined by the City (City of Pasadena 2015b).
The Project site is within the Central District Specific Plan, Pasadena Playhouse, which is an urbanized area within the City. According to the Central District Specific Plan, it is recognized by the City’s residents as “Downtown” and is appropriate for infill and higher density transit-oriented development. The Central District Specific Plan was developed to provide neighborhood -specific design and land use regu lations for notable areas, including City Hall, Pasadena Playhouse, Central Park, Paseo Colorado, and Shops on Lake. The Pasadena Playhouse Sub -district, particularly Playhouse South/Green Street is characterized as a pedestrian -oriented place, featuring appropriately scaled commercial buildings focused on the street. Antique and specialty shops, and restaurants are among the uses, and a consistent street tree canopy adds to the identity of the street. South of Green Street the structures and uses transition to the in-town residential neighborhood (City of Pasadena 2004).
Surrounding Land Uses
Adjacent land uses include single - and multi-family residential and commercial to the west across Oak Knoll Avenue; commercial and parking to the north across Green S treet; multi-family residential and parking to the east across Hudson Avenue; and offices and a church immediately to the south, with multi- family and office uses beyond. The nearest light rail stations are the Lake Metro Gold Line Station located at the I nterstate (I) 210 approximately 0.5 -mile to the north, and the Del Mar Metro Gold Line Station located approximately 0.8-mile to the west near Central Park.
PROJECT CHARACTERISTICS
Project Design
Figure 3, Site Plan, shows the overall layout of the proposed Project site in the context of the surrounding streets and adjacent land uses. The proposed Project includes 253,917 254,152 sf of mixed-use residential and commercial office land uses within one 4-story mixed-use building (87,420 84,469 sf); one 5-story residential building (160,461 160,627 sf); and two levels of subterranean parking with 6,036 7,056 sf of bicycle parking, stairs, and mechanical space. The residential components of the two buildings are connected by an outdoor ground -level breezeway and external pedestrian bridges connection at Level 2, Level 3, and Level 4.
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The proposed 4-story building would front onto Green Street and has a maximum height of 47 feet, with the frontage on Green Street at Oak Knoll Avenue at 31 feet and the frontage on Green Street at Hudson Avenue at 35 feet. The proposed 5-story building would be located at the interior of the Project site and has a maximum height of 62 feet. The proposed uses within each building are described in more detail below. 4-Story Mixed-Use Building
• First Floor. As shown in Figure 4, Level One Floor Plan, the first floor of the mixed-use building would include 16,481 14,346 sf of commercial office uses fronting Green Street, including 2,031 sf of restaurant/café uses and 5,483 6,576 sf of commercial office/retail space on the western half of the first floor separated by a 1,242 1,190-sf central lobby from an additional 5,222 7,770 sf of commercial office/retail space and a second 3,496-sf café space on the eastern half of the first floor. The mixed- use building would also include residential/community uses on the interior -facing portion of the building, including a 3,150 3,378-sf fitness center, a 1,694 1,708-sf business center, a 903 1,083-sf leasing office, an 813 614-sf mail/package room, and a 2,684 2,901-sf pool lounge. The commercial office uses fronting Green Street and the interior-facing residential/community uses on the first floor of the mixed-use building would be accessible from the pedestrian sidewalk on Green Street and from interior stairwells and elevators from the subterranean parking structure. • Second and Third Floor. As shown in Figure 5, Level Two and Level Three Floor Plan, and Figure 6, Level Three Floor Plan , the second and third floors of the mixed -use building would have the same floors plans and would each include 31 28 dwelling units comprising 8 4 studios, 15 one-bedroom, and 8 9 two-bedroom for-rent apartment units. Exterior pedestrian breezeways would connect the second and third floors of the mixed-use building to the second and third floors of the proposed residential building.
• Fourth Floor. As shown in Figure 6, Level Four Floor Plan, the fourth floor of the proposed mixed- use building would include 8 9 one-bedroom and 1 3 two-bedroom apartment units. The remaining area of the fourth floor would comprise the roof of the mixed-use building. An exterior pedestrian breezeway would connect the fourth floor apartment units of the mixed-use building to the fourth floor of the residential building. The roof would be 45 feet at its highest point, per the City’s Municipal Code Section 17.43.055B Inclusionary Housing Ordinance Concession), which allows for an additional 12 feet of building height over the applicable zone’s height limit. 5-Story Residential Building
• First Floor. As shown in Figure 4, Level One Floor Plan, the first floor of the residential building would be separated from the first floor of the mixed -use building by community open space, including the pool and interior courtyard. The first floor of the residential building would comprise two lobbies with street and garage access, one lobby on the western side and one lobby on the eastern side of the building. A total of 41 dwelling units, including 15 18 studios, 19 17 one- bedrooms, and 7 6 two-bedroom apartments would be located on the first floor of the residential building.
• Second, Third, and Fourth Floor. As shown in Figure 5, Level Two and Level Three Floor Plan, and Figure 6, Level Three Floor Plan, the second and third floors of the residential building would have the same floors plans and would each include 42 43 dwelling units comprising 15 17 studios, 19 one-bedroom, and 8 7 two-bedroom for-rent apartment units. Similarly, as shown in Figure 6 7, Level Four Floor Plan, the fourth floor of the proposed residential building would also include 42 43 dwelling 740-790 EAST GREEN STREET MIXED-USE PROJECT
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units comprising 15 17 studios, 19 one-bedroom, and 8 7 two-bedroom for-rent apartment units. The second, third, and fourth floors of the residential building would each comprise two small lobbies, one on the western and one on the eastern side of the building. Exterior pedestrian breezeways would connect the second, third, and fourth floors of the residential building to the second, third, and fourth floors of the mixed-use building.
• Fifth Floor. As shown in Figure 7 8, Level Five Floor Plan, the fifth floor of the proposed residential building would include 25 dwelling units comprising 10 studios, 12 one-bedroom, and 3 two-bedroom apartment units. Additionally, the residential building would include a 2,427 2,116-sf rooftop terrace.
The proposed base density allowed according to CD-4 zone standards is 87 du/acre, which allows for up to 203 units. With the addition of the 41 affordable housing units, and the associated 30% affordable housing density bonus, the proposed Project proposes a total of 263 units, including 86 studio units, 126 one-bedroom units, and 51 two-bedroom units. Table 1-2 compares the development standards for the proposed Project with the existing CD-4 zone and General Plan standards.
Table 1-2. Project Development Standards
Standard Proposed Project CD-4 General Plan
Density1 113 du/acre 60 du/acre 0-87 du/acre
FAR1 2.5 2 0 - 2.25
Height1 47 feet – 62 feet 35 feet to 50 feet N/A
Setbacks:
Green Street
Oak Knoll Avenue
Hudson Avenue
Interior2
0 feet to 5 feet
0 feet to 10 feet
0 feet to 5 feet
10 feet
0 feet to 5 feet
0 feet to 5 feet
0 feet to 5 feet
None Required
N/A
Note: du/acre = dwelling unit per acre; FAR = floor-to-area ratio. 1 Per Zoning Code Section 17.43.055, On-Menu Density Bonus, a 30% increase in the density, a 0.5 increase in FAR and a 12 -foot increase in height is permitted by designating 41 units as affordable housing on-site. 2 Interior refers to the setback from the adjacent lot to the south of the Project site.
Circulation, Transportation, and Parking
Residents would enter the proposed 4-story building via the lobby located off of Green Street and would enter the proposed 5-story building via the lobbies off of Hudson Avenue and Oak Knoll Avenue . The parking garage entrance on Oak Knoll Avenue would be utilized by both residents and patrons of the commercial office uses; however, resident ial parking would be separated from the commercial office parking by a restricted access gate. Both buildings could also be accessed from the pocket park on Oak Knoll Avenue via a pathway that connects to the 5-story building.
As shown in Figure 8 9a, Parking Garage Level 1, and Figure 8 9b, Parking Garage Level 2, the parking garage would provide 443 416 vehicle parking spaces and 49 48 bicycles spaces. The parking garage includes two levels (Level 1 and Level 2), each of which have an 11 -foot height clearance. Level 1 includes 65 33 parking spaces for commercial office uses, including 3 2 American Disabilities Act (ADA) compliant parking spaces. Level 1 also includes 27 24 residential guest parking spaces and 118 resident- only parking spaces, including 6 7 ADA compliant parking spaces and 8 16 resident tandem spaces, and 49 48 bicycle parking spaces. Level 2 includes 233 214 parking spaces for residents only , including 2 ADA compliant parking spaces and 24 resident tandem spaces. In total, the subterranean parking garage 740-790 EAST GREEN STREET MIXED-USE PROJECT
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includes 351 355 resident parking spaces (including 8 7 resident ADA spaces, and 32 16 resident tandem spaces), 27 26 resident guest spaces, and 65 35 parking spaces for commercial office uses (including 3 2 ADA spaces).
Architectural Materials
As shown in Figure 9 10a, East and West Elevations, Figure 9 10b, North and South Elevations, and Figure 9 10c, Interior Courtyard Elevation, the proposed Project is contemporary in style; however, the buildings and incorporates some design elements of historic Spanish Revival buildings in Pasadena, including such as a base-middle-top visual order, roof articulation, upper floor step backs, and a paired windows pattern. As shown in the elevations illustrated in Figures 9 10a through 9 10c, architectural materials contemplated to be incorporated into Project design include white and accent plaster, accent ceramic tile, metal railing, vinyl window frames and door frames, and glass guard railing. Materials and colors are subject to review and approval by the City’s Design Commission through the City ’s Design Review Process.
Open Space and Landscaping
As shown on Figure 10 11, Open Space Areas, the proposed Project includes 27,180 27,795 sf of outdoor community open space (i.e. 4,110 4,033-sf publicly available pocket park, breezeways, swimming pool courtyard, roof terraces), 600 sf of indoor community open space, and 11,703 11,585 sf of private open space (i.e. balconies), for a total of 39,483 39,980 sf of community open space. Figure 11, Open Space Concept, identifies the amenities to be included within each of the open space areas. As shown in Figure 11, the The pocket park would be located in the southeast southwest corner of the Project site, the pool and spa are located in the central-eastern portion of the Project site, and the breezeway would traverse the Project site from east to west with a water feature, overhead structure, with an outdoor kitchen and furnishings, and a fire pit.
As shown on Figure 12, Tree Inventory, there are 12 existing trees within the Project site (Numbers 11B, 12, 16B, 17-24) and 15 14 existing street trees1 within the adjacent public sidewalks (Numbers 1-11 and 13-16). All 12 of the existing on-site trees would be removed under the proposed Project , as would 4 existing street trees that are in poor health. All on-site trees proposed for removal would be removed and replaced per the City’s Municipal Code Section 8.52.010. See Attachment C, Protected Tree Report, of the Final MND for more information.
Lighting
Exterior lighting associated with Project would include pedestrian safety lighting and landscape lighting.
The City’s Municipal Code Section 17.40.080 governs outdoor lighting standards for developments within the City. Specifically, exterior lighting on private property should be energy -efficiency and shielded; no lights shall blink, flash or be of high intensity or brightness; and lighting shall be appropriate in scale, intensity, and height. Additionally, per Section 17.30, Central District Specific Plan, the Project would comply with requirements of 17.40.080. During the plan check process, the City will review a photometric plan to ensure compliance with the City’s Municipal Code.
1 One right-of-way tree (identified as #ST5 in Attachment C of the Final MND) has been removed since an earlier tree inventory by EPT Design, which indicated that ST5 was in poor condition. 740-790 EAST GREEN STREET MIXED-USE PROJECT
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Sustainability Features
The Project must comply with the 2019 California Green Building Standards Code (CalGreen), which is codified in Section 14.04, Building Code and Related Codes of the City’s Municipal Code. In addition, sustainability features proposed as part of the Project include electric vehicle charging stations. In accordance with CalGreen, 25% of the total number of parking spaces on the Project site, provided for all types of parking facilities, are required to be electric vehicle charging spaces (EV spaces) capable of supporting future electric vehicle supply equipment (EVSE) and 5% of the total number of parking spaces on a building site, provided for all types of parking facilities, are required to be electric vehicle charging stations (EVCS).
Off-Site Project Components
The Project site is surrounded to the north, east, and west by sidewalks and street trees. Mature Ficus trees line East Green Street while a mix of other street trees, including Holly Oaks, Camphor trees, and Kurrajong Bottletree, are located in the right s-of-way of South Hudson Avenue and South Oak Knoll Avenue. As shown in Figure 12, Tree Inventory, the proposed Project would be constructed such that the mature trees along East Green Street would preserved in place, whereas some existing street trees along South Hudson Avenue and South Oak Knoll Avenue that are in poor health would be removed and replaced with new trees. All street/public trees proposed for removal would be removed and replaced per the City’s Municipal Code Section 8.52.0 10. It is anticipated that tree -trimming would be required to accommodate the demolition and/or construction equipment to the trees lining East Green Street.
Moreover, the Applicant conducted a Protected Tree Report prepared by a certified arborist on February 4, 2022 (included as Attachment C to the Final MND) which made recommendations in compliance with the City’s Municipal Code.
New driveways and curb/gutter construction would be required to accommodate the driveway on South Oak Knoll Avenue and the driveway and loading/unloading dock on South Hudson Avenue. Trenching would be required to make connections for electrical service, water service, sanitary sewer, storm drain, gas service, and telecommunications.
Short-Term Construction Activities
Project demolition activities would begin in approximately May 2023, and construction activities would end approximately December 2025, approximately 34 months later.2 Construction activities would occur in one phase, with the occupancy of the property expected in the January 2026. Construction activities could take place Monday to Friday between 7:00 a.m. and 7:00 p.m. and Saturday between 8:00 a.m. to 5:00p.m., per the City Noise Ordinance, Section 9.36.070 of the Municipal Code.
Table 1-3, Estimated Construction Activities provides a summary of the Project’s anticipated construction phases, equipment and schedule, which are used in consideration of short-term construction related impacts.
2 The analysis in this IS/MND assumes a construction sta rt date of May 2023 . Upon reevaluation of a realistic schedule, construction is anticipated to begin at a later date. However, using an earlier start date for construction represents a more conservative assessment of construction impacts because equipment and vehicle emission factors for later years would be slightly less due to more stringent standards for in -use off-road equipment and heavy-duty trucks, as well as fleet turnover replacing older equipment and vehicle s in later years. Therefore, no remodeling of Air Quality, Greenhouse Gas, or Energy is required due to a delay in construction. 740-790 EAST GREEN STREET MIXED-USE PROJECT
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Table 1-3. Estimated Construction Activities
Construction
Phase
One-Way Vehicle Trips Equipment Schedule
Average Daily Worker Trips
Average Daily Vendor Truck Trips
Total Haul Truck Trips
Types
Quantity
Usage Hours
Start Date
Finish Date
Demolition 16 0 546 Rubber-Tired Dozers 2 8 06/01/
2023
06/30/
2023 Excavators 3 8
Concrete/Industrial Saws 1 8
Grading 20 0 5,094 Excavators 2 8 07/01/
2023
09/30/
2023 Graders 1 8
Rubber Tired Dozers 1 8
Scrapers 2 8
Tractors/Loaders/Backhoes 2 8
Trenching 4 0 0 Trenchers 1 8 07/01/
2023
12/31/
2024
Building
Construction
288 68 0 Cranes 1 7 10/01/
2023
12/31/
2024 Forklifts 3 8
Generator Sets 1 8
Tractors/Loaders/Backhoes 3 7
Welders 1 8
Paving 16 0 0 Pavers 2 8 09/01/
2025
12/31/
2025 Paving Equipment 2 8
Rollers 2 8
Architectural
Coating
58 0 0 Air Compressors 1 6 01/01/
2025
12/31/
2025
Notes: See Appendix A for details.
Discretionary Actions
The proposed Project site is located in the CD -4 Zoning District of the City of Pasadena . The Project Applicant requests the establishment of a Planned Development No. 37 (PD 37) zoning district (via a Zone Change) for the Project site and adoption of a PD Plan that prescribes the development standards and allowed or conditionally allowed uses in the PD No. 37 Zone. In order to construct up to 2 63 residential units, the Project Applicant proposes to use the State Density Bonus regulations legislated by the California Government Code Section 65915 as well as the City’s Affordable Housing Concession Menu. In the City’s Central District (CD) Zone, a P D Plan may not authorize a greater height than that permitted in the CD. Per the PD Plan, the proposed maximum permitted density for the Project site would be 87 dwelling units per acre (du/acre), or 203 units. However, with With the inclusion of 41 affordable housing units, the Project would be eligible for a 30% density bonus; thus, increasing the maximum allowed density to 263 units. Under the State’s Bonus Density Law , and the City’s Affordable Housing Concession Menu, the Project Applicant is able to r equest two concessions to the City’s development standards established by the City’s Zoning Code. Because the proposed Project would include 20% on- site affordable housing units, the Project would comply with the City’s Inclusionary Housing Ordinance, which would allow the Project to utilize the City’s concessions of FAR increase of 0.5 and a height increase of 12 feet for no more than 60% of the building footprint.
The Project Applicant is requesting the following concessions:
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• The Project Applicant is requesting to increase the Project’s floor area ratio from 2.0 to 2.5. • The Project site is located within an area that establishes a maximum height limit of 35 feet along Green Street in the northern portion and up to 50 feet along Hudson Avenue and Oak Knol l Avenue in the southern portion. The Project Applicant is requesting a height limit increase of 12 feet, in order for the northern portion to be built to a maximum height of 47 feet and the southern portion to be built to a maximum height of 62 feet.
The City’s process for reviewing the PD Plan begins with the Design Commission, which advises the City’s Planning Commission. The Planning Commission reviews the proposal and makes a recommendation to the City Council. The City Council is the decision m aker for the requested entitlements and may make recommendations to approve, revise, or deny the proposed Project. Permits and approvals required from the City of Pasadena for development of the proposed Project are anticipated to include, but are not limited to, the following:
• Planned Development, which includes:
o Zone Map Amendment to change the zoning designation of the site from CD-4 to Planned Development No. 37 (PD 37)
o PD Plan that prescribes allowed and conditionally allowed uses, applicable development standards, and conditions of approval
• Design Review approval
• All other discretionary and ministerial permits needed to implement the Project, such as grading and building permits
9. Surrounding land uses and setting:
As shown in Figure 1, Project Location, the proposed Project site is located in an urbanized area of the City of Pasadena . Land uses surrounding the Project site are disparate and include a wide variety of commercial, office, residential, and mixed-use land uses per the CD-4 and CD-5 zoning.
Land uses to the north of the Project site across Green Street include an office building, retail uses, and a multi-level parking structure. Building heights range from single-story to 5-story structures along Green Street. Land uses located further north include retail, surface parking and a 9-story office building.
Land uses to the east of the Project site across Hudson Avenue include a 4-story mixed-use residential building and surface parking along Hudson Avenue. Land uses located further east include multi -level, mixed-use residential/retail development, surface parking, and office uses.
Land uses to the south of the Project site include medical office and a church. Building heights range from 1-story to 2-story structures just south of the property line. Land uses located further south include multi-level, multi-family residential development, surface parking, and office uses.
Land uses to the west of the Project site across Oak Knoll Avenue include a retail uses and single- and multi-family residential. Building heights range from single -story to 4 -story structures along Oak Knoll Avenue. Land uses located further west include multi -level, multi-family residential development, retail, and surface parking.
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10. Other public agencies whose approval is required:
No discretionary approvals from other public agencies are expected to be required.
11. Have California Native American tribes traditionally and culturally affiliated with the project area requested consultation pursuant to Public Resources Code section 21080.3.1? Yes, see Section 2.18, Tribal Cultural Resources.
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ENVIRONMENTAL FACTORS POTENTIALLY AFFECTED:
The environmental factors checked below would be potentially affected by this project, involving at least one impact that is a “Potentially Significant Impact,” as indicated by the checklist on the following pages.
Aesthetics Agriculture and Forestry
Resources Air Quality
Biological Resources Cultural Resources Energy
Geology and Soils Greenhouse Gas Emissions Hazards and Hazardous Materials
Hydrology and Water Quality Land Use and Planning Mineral Resources Noise Population and Housing Public Services
Recreation Transportation Tribal Cultural Resources Utilities and Service Systems Wildfire Mandatory Findings of Significance
DETERMINATION (To be completed by the Lead Agency)
On the basis of this initial evaluation:
I find that the proposed project COULD NOT have a significant effect on the environment, and a NEGATIVE DECLARATION will be prepared.
I find that although the proposed project could have a significant effect on the environment, there will not be a significant effect in this case because revisions in the project have been made by or agreed to by the project proponent. A MITIGATED NEGATIVE DECLARATION will be prepared.
I find that the proposed project MAY have a significant effect on the environment, and an ENVIRONMENTAL IMPACT REPORT is required.
I find that the proposed project MAY have a “potentially significant impact” or “potentially significant unless mitigated” impact on the environment, but at least one effect (1) has been adequately analyzed in an earlier document pursuant to applic able legal standards, and (2) has been addressed by mitigation measures based on the earlier analysis as described on attached sheets. An ENVIRONMENTAL IMPACT REPORT is required, but it must analyze only the effects that remain to be addressed.
I find that although the proposed project could have a significant effect on the environment, because all potentially significant effects (a) have been analyzed adequately in an earlier ENVIRONMENTAL IMPACT REPORT or NEGATIVE DECLARATION pursuant to applicable standards, and (b) have been avoided or mitigated pursuant to that earlier ENVIRONMENTAL IMPACT REPORT or NEGATIVE DECLARATION, including revisions or mitigation measures that are imposed upon the proposed project, nothing further is required.
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Prepared By Date Reviewed By Date
Printed Name Printed Name
Negative Declaration/Mitigated Negative Declaration adopted on: ____________
Adoption attested to by: ______ ________________ ____________ Signature Date
__ _____________________
Printed name
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Evaluation of Environmental Impacts
1. A brief explanation is required for all answers except “No Impact” answers that are adequately supported by the information sources a lead agency cites in the parentheses following each question. A “No Impact” answer is adequately supported if the referenced information sources show that the impact simply does not apply to projects like the one involved (e.g., the project falls outside a fault rupture zone). A “No Impact” answer should be explained where it is based on project-specific factors as well as general standards (e.g., the project will not expose sensitive receptors to pollutants, based on a project-specific screening analysis).
2. All answers must take account of the whole action involved, including off -site as well as on -site, cumulative as well as project-level, indirect as well as direct, and construction as well as operational impacts.
3. Once the lead agency has determined that a particular physical impact may occur, then the checklist answers must indicate whether the impact is potentially significant, less than significant with mitigation, or less than significant. “Potentially Significant Impact” is appropriate if there is substantial evidence that an effect may be significant. If there are one or more “Potentially Significant Impact” entries when the determination is made, an Environmental Impact Report (EIR) is required.
4. “Negative Declaration: Less Than Significant With Mitigation Incorporated” applies where the incorporation of mitigation measures has reduced an effect from “Potentially Significant Impact” to a “Less Than Significant Impact.” The lead agency must describe the mitigation measures, and briefly explain how they reduce the effect to a less than significant level (mitigation measures from “Earlier Analyses,” as described in (5) below, may be cross-referenced).
5. Earlier analyses may be used where, pursuant to the tiering, program EIR, or other CEQA process, an effect has been adequately analyzed in an earlier EIR or negative declaration. Section 15063(c)(3)(D). In this case, a brief discussion should identify the following:
a. Earlier Analysis Used. Identify and state where they are available for review. b. Impacts Adequately Addressed. Identify which effects from the above checklist were within the scope of and adequately analyzed in an earlier document pursuant to applicable legal standards, and state whether such effects were addressed by mitigation measures based on the earlier analysis. c. Mitigation Measures. For effects that are “Less Than Significant With Mitigation Measures Incorporated,” describe the mitigation measures which were incorporated or refined from the earlier document and the extent to which they address site-specific conditions for the project.
6. Lead agencies are encouraged to incorporate int o the checklist references to information sources for potential impacts (e.g., general plans, zoning ordinances). Reference to a previously prepared or outside document should, where appropriate, include a reference to the page or pages where the statement is substantiated.
7. Supporting Information Sources: A source list should be attached, and other sources used or individuals contacted should be cited in the discussion.
8. This is only a suggested form, and lead agencies are free to use different formats; however, lead agencies should normally address the questions from this checklist that are relevant to a project’s environmental effects in whatever format is selected.
9. The explanation of each issue should identify:
a. The significance criteria or threshold, if any, used to evaluate each question; and b. The mitigation measure identified, if any, to reduce the impact to less than significance . 740-790 EAST GREEN STREET MIXED-USE PROJECT
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SECTION II. ENVIRONMENTAL CHECKLIST FORM
Background
Date checklist submitted: December 3, 2020
Department requiring checklist: Planning and Community Development Department Case Manager: David Sinclair, Jennifer Driver
2.1 AESTHETICS
Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Except as provided in Public Resources Code Section 21099, would the project:
a) Have a substantial adverse effect on a scenic vista? b) Substantially damage scenic resources including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway?
c) In non-urbanized areas, substantially degrade the existing visual character or quality of public views of the site and its surroundings? (Public views are those that are experienced from publicly accessible vantage point). If the project is in an urbanized area, would the project conflict with applicable zoning and other regulations governing scenic quality?
d) Create a new source of substantial light or glare which would adversely affect day or nighttime views in the area?
a) Would the project have a substantial adverse effect on a scenic vista? Less Than Significant Impact. Scenic vistas generally refer to views of expansive open space areas or other natural features, such as mountains, undeveloped hillsides, large natural water bodies, or coastlines. Less commonly, certain urban settings or features, such as a striking or renowned skyline, may also represent a scenic vista. Scenic vistas generally refer to views that are accessible from public vantage points, such as public roadways and parks. According to the City’s General Plan Draft EIR, the City of Pas adena is known for its numerous scenic resources, including historic buildings, pristine residential areas, and natural areas of Arroyo Seco, Eaton Wash, and the San Rafael Hills (City of Pasadena 2015a). Scenic vistas in Pasadena include certain views of the San Gabriel Mountains, the Arroyo Seco Corridor, and Eaton Canyon (City of Pasadena 2015a).
The proposed Project is not within the general vicinity or view corridor of either the Arroyo Seco or Eaton Canyon. Limited views of the San Gabriel Mountains are available from the City’s north–south roadway corridors; however, views are largely obscured by distance and urban development, including buildings, utility infrastructure, and signage. Potential effects of the propose d Project on public views of the San Gabriel Mountains are characterized below.
Oak-Knoll Avenue: Oak Knoll Avenue is a north -south running arterial that borders the Project site’s western perimeter. North-facing views of the San Gabriel Mountains are not readily available from Oak 740-790 EAST GREEN STREET MIXED-USE PROJECT
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Knoll Avenue where it traverses west of the Project site due to prevailing urban development and ornamental vegetation (i.e. mature street trees) , which obstruct views of the San Gabriel Mountains.
Additionally, the proposed Project would not include any infrastructure or building features that would encroach into the Oak Knoll Avenue ROW.
South Hudson Avenue: South Hudson Avenue is a north-south running arterial that borders the Project site’s eastern perimeter. On clear days (i.e. days with high visibility), partial north-facing views of the San Gabriel Mountains are available from Hudson Avenue; however, are obstructed by urban development and ornamental vegetation (i.e. mature street tr ees). The proposed Project would not include any infrastructure or building features that would encroach into the Hudson Avenue ROW and, upon operation, the proposed Project would not result in any changes to the existing views of the mountains from Hudson Avenue.
Cordova Street: Cordova Street is an east-west running arterial that borders the southern perimeter of the block on which the Project site is located. North -facing views of the San Gabriel Mountains are generally obstructed by urban development an d ornamental landscaping from Cordova Street in the vicinity of the Project site. The proposed Project would not be visible from Cordova Street, and, as such, the proposed Project would have no impact on north -facing views of the San Gabriel Mountains from Cordova Street.
In summary, obstructed views of the San Gabriel Mountains are available from one or more public viewpoints, including from public roadways surrounding the Project site. However, these existing views are limited due to obstructions typical of urban development, such as utility poles, street trees, and commercial and residential development. The proposed Project would introduce new development to the Project site, which would reach a maximum height of 62 feet. However, due to its location, the proposed Project would not further obstruct existing views of the San Gabriel Mountains beyond existing conditions from motorists and pedestrians traveling along Oak Knoll Avenue, Hudson Avenue, and Cordova Street.
Additionally, motorists and pedestrians are transient, and their views of the mountains are fleeting (temporary and brief) by nature. Therefore, longer-term views of the mountains for pedestrians and motorists would not be affected. As such, the introduction of a new structure on the Project site would not have a substantial a dverse effect on a scenic vista, including views of the San Gabriel Mountains.
The proposed Project would have a less than significant impact on scenic vistas. No mitigation is required. b) Would the project subs tantially damage scenic resources including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway? No Impact. The proposed Project is not within the immediate vicinity of a state designated scenic highway. The California Department of Transportation (Caltrans) classifies the I-210 as an Eligible State Scenic Highway (not officially designated) where it runs from the I-5 near Tunnel Station to State Route (SR-) 134 (Caltrans 2020). However, the Project site is located 1.2-mile southeast of the I-210 and would not be visible from the highway. The nearest Designated State Scenic Highway is the SR-2 where it traverses the San Gabriel Mountains from La Canada/Flintridge to San Bernardino County (USGS 2019a). However, the Project site is located 6.5 miles southeast of the SR-2 and would not be visible from the highway. As such, the proposed Project would have no impact on any scenic resources including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway. 740-790 EAST GREEN STREET MIXED-USE PROJECT
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c) In non -urbanized areas, would the project substantially degrade the existing visual character or quality of public views of the site and its surroundings? (Public views are those that are experienced from public ly accessible vantage point). If the project is in an urbanized area, would the project conflict with applicable zoning and other regulations governing scenic quality?
Less Than Significant Impact. The Project site and surrounding area are generally charac terized by disparate commercial and multi-family residential land uses that are inconsistent in size, style, and, as such, lack visual cohesion and uniformity. Vegetation on the Project site is limited to 12 on-site trees and two sparse planter beds, which would be removed under the proposed Project . The only distinct visual element on the project site and/or in the vicinity are the mature ficus trees along Green Street.
As shown in Figures 9 10a through 9 10c, the proposed Project would develop mixed-use residential and commercial office buildings consisting of up to 263 rental apartment units, approximately 16,481 14,346 sf of commercial office development (e.g. retail, restaurant) , and a 4,110 4,033 sf publicly accessible pocket park.
As shown in Figure 9 10b, North and South Elevations, the massing of the buildings would be setback from Green Street. Additionally, the existing mature ficus trees along Green Street would be preserved. Figure 9 10b, North and South Elevations, depicts the Project site from the southern boundary of the Project site. As shown, the pocket park would be located adjacent to the existing off-site church on the south side of the Project site in order to transition the land uses and set back the proposed buildings from surrounding land uses.
The height and setback variations proposed for the mixed -use development would allow for the visual dispersal of the Project’s density by utilizing step -down massing between floors. Passive solar shading would occur along the paseo/breezeway while solar gain would occur in the proposed community areas, pool deck, patios, and rooftop decks. The proposed mixed-use Project would be contemporary in style; however, the building would incorporate design elements found in many of the historic Spanish Revival buildings that define Pasadena’s architecture. The aesthetic design goal of t he proposed Project is to provide a form, proportion, and articulation that relates to similar architectural approaches throughout the urban areas of Pasadena and maintains a clean and streamlined composition conveyed in a contemporary manner. As shown in the renderings illustrated in Figures 9 10a through 9 10c, architectural materials incorporated into Project design would include white and accent plaster, accent tile, metal railing, vinyl window frames and door frames, and glass guard railing. The design of the proposed Project is intended to be consistent with the visual character and quality of the project site and surrounding area by incorporating a project that is compatible with Pasadena’s Spanish Revival architectural history and also visually consistent with the style and aesthetic of existing contemporary buildings in Pasadena.
With regard to the distinctive mature ficus trees on Green Street, as shown in Figure 12, Tree Inventory, the proposed Project would be constructed such that the mature trees along East Green Street would preserved in place, whereas those existing street trees along South Hudson Avenue and South Oak Knoll Avenue that are in poor condition would be removed and replaced with new trees. All street/public trees proposed for removal are in poor condition and would be removed per the City’s municipal code Section
8.52.010. It is anticipated that tree -trimming would be required to accommodate the demolition and/or construction equipment to the trees lining East Green Street. Any tree trimming would be carried out according to City standards to protect the health of the trees . Moreover, the Applicant conducted a 740-790 EAST GREEN STREET MIXED-USE PROJECT
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Protected Tree Report prepared by a certified arborist on February 4, 2022 (included as Attachment C to the Final MND ) which made recommendations in compliance with the City’s Municipal Code.
The General Plan policies specific to the aesthetic character and quality of development within the City, as well as the applicable City Municipal Code and Central District Specific Plan requirements that affect aesthetic character are listed and analyzed in Table 2.1-1, General Plan Policy/Programs, Municipal Code, and Specific Plan Consistency Analysis.
Table 2.1-1. General Plan Policy/Programs, Specific Plan, and Municipal Code Consistency Analysis
Applicable Policy/Regulation Consistency Analysis
General Plan, Land Use Element
Policy 3.1 High-Impact Uses. Avoid the
concentration of uses and facilities in any
neighborhood or district where their
intensities, operations, and/or traffic could
adversely impact the character, safety,
health, and quality of life.
Consistent. The proposed Project would not include a high-impact use that would adversely impact the aesthetic character of the Project site or the surrounding area. The design of the proposed Project is intended to be consistent with the visual character and quality of the Project site and surrounding area by incorporating a project that is compatible with Pasadena’s Spanish Revival architectural history and also visually consistent with the style and aesthetic of existing contemporary buildings in Pasadena. See Section 2.1(c) for additional details.
Policy 4.2 A Diversity of Places. Maintain
and enhance the City’s urban form with
distinct, compact, and walkable areas with
a diversity of uses, densities, and
characters. Offer choices for living,
working, shopping, and recreation
consistent with community values, needs,
and demographics.
Consistent. The proposed Project is a mixed-use project that would provide residential, commercial office, and public open space uses.
The proposed Project would include pedestrian paseos and a central breezeway, as well as a public pocket park, all of which would contribute to the walkability of the Project site and adjacent streets.
Policy 4.10 Architecture that Enhances.
Locate and design buildings to relate to
and frame major public streets, open
spaces, and cityscape. New development
at intersections should consider any
number of corner treatments, and should
balance safety and accessibility concerns
with the vision of the area and the need for
buildings to engage the street and create a
distinct urban edge.
Consistent. The height and setback variations proposed for the mixed-use buildings would allow for the visual dispersal of the Project’s density by utilizing step-down massing between floors. The proposed mixed-use Project would be contemporary in style; however, the building would incorporate design elements found in many of the historic Spanish Revival buildings that contribute to Pasadena’s architecture. The aesthetic design goal of the proposed Project is to provide a form, proportion, and articulation that relates to similar architectural approaches throughout the urban areas of Pasadena and maintains a clean and streamlined composition conveyed in a contemporary manner. The proposed Project would include a pocket park on Oak Knoll Avenue, which would serve to compliment the proposed Project’s step-down architectural design and integrate the Project density into the neighborhood.
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Table 2.1-1. General Plan Policy/Programs, Specific Plan, and Municipal Code Consistency Analysis
Applicable Policy/Regulation Consistency Analysis
Policy 4.11 Development that is
Compatible. Require that development
demonstrates a contextual relationship
with neighboring structures and sites
addressing such elements as building
scale, massing, orientation, setbacks,
buffering, the arrangement of shared and
private open spaces, visibility, privacy,
automobile and truck access, impacts of
noise and lighting, landscape quality,
infrastructure, and aesthetics.
Consistent. See response to Policy 4.10. For more information regarding land use impacts, noise impacts, and transportation impacts, see Sections 2.11, 2.13, and 2.17 of this IS/MND, respectively.
Policy 4.12 Transitions in Scale. Require
that the scale and massing of new
development in higher density centers and
corridors provide appropriate transitions in
building height and bulk and are sensitive
to the physical and visual character of
adjoining lower-density neighborhoods.
Consistent. See response to Policy 4.10.
Policy 6.1: Sense of Place and History.
Require new development and changes to
existing development to be located and
designed to respect the defining elements
of Pasadena’s character and history such
as its grid street pattern, block scale, public
realm, neighborhoods and districts,
building massing and heights, significant
architecture, and relationship to the
mountains and Arroyo Seco.
Consistent. See response to Policy 4.10.
Policy 6.4 View sheds. Recognize and
protect significant views of the San Gabriel
Mountains, the Arroyo Seco, and other
open spaces, along with views of
significant structures such as the City Hall,
Central Library and the Civic Auditorium.
Consistent. The proposed Project is not within the viewshed of the Arroyo Seco, City Hall, Central Library, or Civic Auditorium and would have a less than significant impact on significant views, including views of the San Gabriel Mountains. See Section 2.1(a) of this IS/MND for additional details.
Policy 6.5 Public Art. Integrate public art in
private projects and in public spaces,
including streetscapes, parks and civic
spaces.
Consistent. The proposed Project would include a large public art space on the southwest corner of the Project site (on Oak Knoll Avenue), which would include a public art installation determined at a later date. Additionally, the proposed Project would provide a 4,1104,033 sf pocket park located on Oak Knoll Avenue, which would provide landscaped open space and pedestrian amenities in an area of the City that is largely developed and lacking such amenities. 740-790 EAST GREEN STREET MIXED-USE PROJECT
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Table 2.1-1. General Plan Policy/Programs, Specific Plan, and Municipal Code Consistency Analysis
Applicable Policy/Regulation Consistency Analysis
Policy 7.1 Architectural Quality. Design
each building as a high-quality, long term
addition to the City’s urban fabric; exterior
design and buildings material shall exhibit
permanence and quality, minimize
maintenance concerns, and extend the life
of the building.
Consistent. The proposed Project would be designed to high architectural quality, using buildings materials that shall exhibit permanence and quality, minimize maintenance concerns, and extend the life of the building. As shown in the renderings illustrated in Figures 9 10a through 9 10c, architectural materials incorporated into Project design would include white and accent plaster, accent tile, metal railing, vinyl window frames and door frames, and glass guard railing.
The design of the proposed Project is intended to imply long-term commitment to the City’s urban fabric by incorporating elements that are compatible with Pasadena’s Spanish Revival architectural history, visually consistent with the style and aesthetic of existing contemporary buildings in Pasadena, and consistent with the existing design guidelines intended to guide future development.
Policy 7.2: Architectural Diversity &
Creativity. Allow for the development of a
diversity of buildings styles. Support
innovative and creative design solutions to
issues related to context and
environmental sustainability.
Consistent. As shown in the renderings illustrated in Figures 9 10a through 9 10c, architectural materials incorporated into Project design would include white and accent plaster, accent tile, wood texture composite siding, metal railing, vinyl window frames and door frames, and glass guard railing. The design of the proposed Project is intended to be consistent with the visual character and quality of the project site and surrounding area by incorporating a project that is compatible with Pasadena’s Spanish Revival architectural history and also visually consistent with the style and aesthetic of existing contemporary buildings in Pasadena. The Project would comply with the 2019 California Green Building Standards Code (CalGreen), which is codified in Section 14.04, Building Code and Related Codes of the City’s Municipal Code. In addition, sustainability features proposed as part of the Project include electric vehicle charging stations.
Policy 7.3: Compatibility. Require that new
and adaptively re-used buildings are
designed to respect and complement the
defining built form, massing, scale,
modulation, and architectural detailing of
their contextual setting.
Consistent. See response to Policy 4.10.
Policy 7.4 Design Review. Require design
review for new and redeveloped projects to
assure compatibility with community
character, while promoting creativity,
innovation, and design quality.
Consistent. The proposed Project would be subject to the City’s design review process.
Policy 9.2 Urban Beautification. Embrace
public arts as a citywide urban
beautification effort. Build a collection of art
in public places. Facilitate public art and
public art partnerships with City
Departments, private developers, and art
and cultural organizations.
Consistent. See response to Policy 6.5.
Policy 9.4 Arts Contributions to a More
Walkable City. Implement artist-designed
crosswalks, murals, free-standing artworks
and environments in pedestrian-oriented
retail and entertainment districts.
Consistent. See response to Policy 6.5.
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Table 2.1-1. General Plan Policy/Programs, Specific Plan, and Municipal Code Consistency Analysis
Applicable Policy/Regulation Consistency Analysis
Policy 23.1 Character and Design. Design
and modulate buildings to avoid the sense
of “blocky” and undifferentiated building
mass, incorporate well-defined entries, use
building materials, colors, and architectural
details complementing the neighborhood,
while allowing flexibility for distinguished
design solutions.
Consistent. See response to Policy 4.10 and Policy 7.2.
Policy 23.2 Parking Areas and Garages.
Minimize the visibility of parking areas and
garages.
Consistent. The proposed Project would provide a subterranean parking garage comprising two levels, which, with the exception of the entrance-exit, would not be visible from the street level.
Policy 23.3 Landscaped Setbacks and
Walkways. Provide appropriate setbacks,
consistent with the surrounding
neighborhood, along the street frontage
and, where there are setbacks, ensure
adequate landscaping is provided.
Consistent. The proposed Project would provide the appropriate setbacks and sidewalks (per the LADOT requirements and the City’s Municipal Code), and would include 37,666 39,980 sf of open space, which includes the pocket park, paseo/breezeway and courtyards, pool courtyard and indoor recreation space, rooftop terraces, and private decks and patios.
Policy 23.5 Streetscapes. Provide ample
public spaces and tree-lined sidewalks
furnished with pedestrian amenities that
contribute to comfortable and attractive
settings for pedestrian activity.
Consistent. See response to Policy 6.5.
Policy 25.4 Architecture and Site Design.
Require that new development protect
community character by providing
architecture, landscaping and urban
design of equal or greater quality, and by
respecting the architectural character and
scale of adjacent buildings.
Consistent. See response to Policy 4.10 and Policy 7.2.
Policy 25.5 Connectivity to Neighborhoods.
Link commercial areas to adjoining
residential neighborhoods and other
districts by well-designed and attractive
streetscapes with pedestrian sidewalks
and street amenities.
Consistent. See response to Policy 6.5.
Policy 25.7 Buffering Adjoining Residential
Areas. Ensure commercial uses adjoining
residential neighborhoods or mixed
residential and commercial uses are
designed to be compatible with each other.
Consistent. See response to Policy 6.5 and Policy 7.1.
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Table 2.1-1. General Plan Policy/Programs, Specific Plan, and Municipal Code Consistency Analysis
Applicable Policy/Regulation Consistency Analysis
Policy 28.2 Development Scale. Establish
standards to assure that an adequate
scale and footprint of any single use is
achieved in mixed-use areas to establish a
cohesive environment that minimizes
impacts attributable to the adjacency of
different uses. This may define minimum
parcel and building size, number of
housing units, and/or nonresidential square
footage, as well as relationships and
setbacks.
Consistent. With approval of the PD Zone Change and demonstrated compliance with the Affordable Housing Concession Menu, the proposed Project would construct up to 263 residential units through the State Density Bonus regulations legislated by Government Code Section 65916. In order to construct the additional residential units, the Project Applicant is requesting to exceed the maximum FAR of 2.0 by
0.5, resulting in a FAR of 2.5. Additionally, the Project Applicant is requesting to exceed the maximum height limit of 35 feet in the northern portion and the maximum height limit of 50 feet in the southern portion by 12 feet, resulting in a maximum height of 47 feet and 62 feet, respectively, , as shown on Table 1-2. As also shown in Table 1-2, the Project would increase density from the current zoning of 60 du/acre to 113 du/acre. Thus, the Project proposes an increase in development scale compared to the existing conditions. The Project would include height and setback variations to allow for visual dispersal of the Project’s density by utilizing step-down massing between floors and by increasing the setback at Oak Knoll Avenue from 5 feet to 10 feet. In addition, the aesthetic design goal of the proposed Project is to provide a form, proportion, and articulation that relates to similar architectural approaches throughout the urban areas of Pasadena and maintains a clean and streamlined composition conveyed in a contemporary manner. Therefore, upon Project approval, the proposed Project would be within the appropriate development scale as afforded by the Affordable Housing Concession Menu.
Policy 28.4 Design Integration. Require
residential and nonresidential portions of
mixed-use buildings and sites to be
integrated through architectural design,
development of pedestrian walkways and
landscaping.
Consistent. The Project includes 37,666 39,980 sf of pedestrian amenities and open space, including a 4,110 4,033 sf pocket park, pool lounge and private outdoor space, all of which would provide landscaped pedestrian amenities and enhance walkability.
Additionally, the proposed Project is located 500 feet south of Colorado Boulevard and the downtown Pasadena amenities, which would further encourage walkability.
Policy 31.2 Sub-District Identity. Enhance
the distinctive, yet complementary nature
of the Central District’s sub-areas by
recognizing and building on their unique
attributes and features through signage,
streetscape designs, design guidelines
and encouraging new uses and infill
development that fits with the vision of
each sub-area.
Consistent. See response to Policy 4.10 and Policy 7.2.
Policy 31.4 Contextual Development in
Historic Districts. Require new
development within and adjacent to the
historic districts to be compatible with the
scale, density, and urban design features
of existing historic buildings and districts.
Consistent. See response to Policy 4.10 and Policy 7.2. 740-790 EAST GREEN STREET MIXED-USE PROJECT
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Table 2.1-1. General Plan Policy/Programs, Specific Plan, and Municipal Code Consistency Analysis
Applicable Policy/Regulation Consistency Analysis
Policy 37.4 Visual Variety. Allow for a
diversity of architectural design styles and
building types contributing to the distinctive
characteristics of the area’s intended
artistic, cultural, and creative businesses.
Consistent. See response to Policy 4.10 and Policy 7.2.
City of Pasadena Municipal Code
Chapter 2.80: Design Commission Consistent. The proposed Project would be subject to the Design Commissions review and approval.
Chapter 8.52: City Trees and Tree
Protection Ordinance
Consistent. Any trees removed under the proposed Project would be removed according to Chapter 8.52 of the City Municipal Code.
Chapter 17.40: General Property
development and Use Standards
Consistent. With approval of the PD Zone Change and demonstrated compliance with the City’s Affordable Housing Concession Menu, the proposed Project would construct up to 263 residential units through the State Density Bonus regulations legislated by Government Code Section 65915. In order to construct the additional residential units, the Project Applicant is requesting to exceed the maximum FAR of 2.0 by
0.5, resulting in a FAR of 2.5. Additionally, the Project Applicant is requesting to exceed the maximum height limit of 35 feet in the northern portion and the maximum height of 50 feet in the southern portion by 12 feet resulting in a maximum height of 47 feet and 62 feet, respectively, as shown on Table 1-2. As also shown in Table 1-2, the Project would increase density from the current zoning of 60 du/acre to 113 du/acre. Thus, the Project proposes to deviate from existing general property and development standards with regards to height and density. As previously addressed, the Project would include height and setback variations to allow for visual dispersal of the Project’s density by utilizing step-down massing between floors and by increasing the setback at Oak Knoll Avenue from 5 feet to 10 feet. In addition, the aesthetic design goal of the proposed Project is to provide a form, proportion, and articulation that relates to similar architectural approaches throughout the urban areas of Pasadena and maintains a clean and streamlined composition conveyed in a contemporary manner. Thus, the Project’s deviation from such general property and design standards would not result in significant impacts to visual quality. Further, the City’s process for reviewing the PD plan begins with Design Commission to review the Project amongst applicable development standards. Upon approval, the Project would be consistent with the general property and development use standards as determined by the PD zone. The Project would comply with all of the City’s development standards, including but not limited to, the City’s outdoor lighting ordinance, walls and fences guidelines, and public art requirements (as set forth in Chapter 17.40 of the Municipal Code). Furthermore, the proposed Project would be subject to the City’s design review and approval process.
Chapter 17.44: Landscaping Consistent. The proposed Project would adhere to the City’s landscaping requirements and all landscaping plans would be submitted to the City for review and approval prior to implementation of the proposed Project.
Section 17.61.030: Design Review Consistent. The proposed Project would be subject to the City’s design review and approval.
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Table 2.1-1. General Plan Policy/Programs, Specific Plan, and Municipal Code Consistency Analysis
Applicable Policy/Regulation Consistency Analysis
Central District Specific Plan, District-Wide Urban Design Concept Downtown Linkages: It has been noted
that the planning concept for Downtown
emphasizes diverse Sub-districts that are
interconnected and complementary of one
another. This component addresses the
multiple physical and visual linkages that
create a more integrated and accessible
Downtown, especially from a pedestrian
point-of-view.
Consistent. The proposed Project is a mixed-use project that would provide residential, commercial office, and public open space uses.
The proposed Project would include pedestrian paseos and a central breezeway, as well as a public pocket park, all of which would enhance the walkability and connectivity of the Project site and adjacent streets. Additionally, the proposed Project would be located along Green Street and 500 feet south of Colorado Boulevard and, thus, integrated within and accessible to the amenities of downtown Pasadena.
The Public Realm: An engaging public
realm is important to the development of
any great city. Pasadena’s residents also
believe that their quality of life is related to
the provision of accessible outdoor space
that not only serves their recreational
needs, but also finds a balance between
built and natural resources. Building on the
notion of a well-connected Downtown, this
component describes a District-wide
network of key pedestrian streets, public
parks and civic spaces.
Consistent. The proposed Project is a mixed-use project that would provide residential, commercial office, and public open space uses.
The proposed Project would include pedestrian paseos and a central breezeway, as well as a public pocket park, all of which would contribute to the walkability and connectivity of the Project site and adjacent streets. Also see Section 2.16, Recreation.
Public - Private Interface: A vibrant and
economically vital Downtown is best
served by private developments that
positively contribute to the public realm.
This demands close interaction between
Downtown’s buildings and its streets; the
essential treatment of building setbacks,
orientation and use is discussed. Signage
is also addressed.
Consistent. The proposed Project is a mixed-use project that would provide residential, commercial office, and public open space uses.
The proposed Project would include pedestrian paseos and a central breezeway, as well as a public pocket park, all of which would contribute to the walkability and connectivity of the Project site and adjacent streets, while positively contributing to the public realm.
The Private Realm: Although this
component is referred to as “The Private
Realm,” because it establishes limitations
on private development projects, these
concepts have a profound impact on the
quality and livability of the Downtown
environment. Height recommendations
work in concert with the FAR proposal to
describe the basic three-dimensional
character of Downtown. Additional
development standards and design
guidelines further regulate development in
the Downtown.
Consistent. The City’s process for reviewing the PD plan begins with Design Commission to review the Project amongst applicable development standards. The review process for this Project would establish limitations on private development projects. As previously discussed, the Project proposes to deviate from existing development standards with regards to FAR, height and density. The Project would include height and setback variations to allow for visual dispersal of the Project’s density by utilizing step-down massing between floors and by increasing the setback at Oak Knoll Avenue from 5 feet to 10 feet. In addition, the aesthetic design goal of the proposed Project is to provide a form, proportion, and articulation that relates to similar architectural approaches throughout the urban areas of Pasadena and maintains a clean and streamlined composition conveyed in a contemporary manner. Thus, the Project’s deviation from such design standards would not result in significant impacts to visual quality. With approval of the proposed Project’s Zone Change to PD and demonstrated compliance with the City’s Affordable Housing Concession Menu, the proposed Project would be consistent with City’s land use plans and development standards.
Source: City of Pasadena 2004; City of Pasadena 2015b
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As described above in Table 2.1-1, the proposed Project would be consistent with the City’s General Plan policies, Municipal Code Sections, and Specific Plan concepts that pertain to the preservation of the scenic quality of the City. With approval of the Project site’s zone change to PD and demonstrated compliance with the City’s Affordable Housing Concession Menu, the proposed Project would be consistent with the City’s zoning . Furthermore, proposed Project design would add architectural and landscape features that would contribute to the visual quality of the Project site and the Project area.
Given the above, the proposed Project would not conflict with applicable zoning and other regulations governing scenic quality; rather, the proposed Project would develop a new commercial office mixed- use development project that wo uld be designed specifically with Pasadena’s architectural history in mind. Therefore, impacts would be less than significant. No mitigation is required. d) Would the project create a new source of substantial light or glare which would adversely affect day or nighttime views in the area?
Less Than Significant Impact. Lighting is of most concern when it may spill over or trespass from a Project site onto sensitive surrounding land uses, such as residential properties, resulting in nuisance. The proposed Project is located in a commercial segment of the Specific Plan and is approximately 500 feet south of the City’s main downtown thoroughfare, Colorado Boulevard. The Project site is surrounded by commercial and residential land uses. Existing sources of daytime and nighttime light include streetlights, business identification signs, building and landscape accent lights, safety lights, and lit windows.
Any lighting that would be implemented as part of the proposed Project would adhere to the City’s Municipal Code, Section 17.40.080, which establishes the standards for ext erior lighting in the City. In summary, the standards require: that lighting be energy efficient and shielded or recessed so that direct glare and reflections are confined to the maximum extent practicable and directed downward and away from adjoining properties; lights shall not blink, flash, or be of high intensity or brightness; and, lighting be appropriate in scale, intensity, and height.
Similarly, extraneous glare associated with the use of highly reflective build ing materials (glass, steel etc.) cou ld result in nuisance to surrounding land uses. The proposed Project would include some reflective building materials such as glass and steel; however, these materials would be utilized in a manner consistent with Municipal Code, Section 17.40.080, which requires that any proposed land use or activity producing glare be shielded so that glare is not perceptible beyond the property line. As such, compliance with City regulations would ensure that the proposed Project would have a less than significant impact regarding the creation of a new source of substantial light or glare, which would adversely affect day or nighttime views in the area. No mitigation is required. 740-790 EAST GREEN STREET MIXED-USE PROJECT
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2.2 AGRICULTURE AND FORESTRY RESOURCES
Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
In determining whether impacts to agricultural resources are significant environmental effects, lead agencies may refer to the California Agricultural Land Evaluation and Site Assessment Model (1997) prepared by the California Department of Conservation as an optional model to use in assessing impacts on agriculture and farmland. In determining whether impacts to forest resources, including timberland, are significant environmental effects, lead agencies may refer to information compiled by the California Department of Forestry and Fire Protection regarding the state’s inventory of forest land, including the Forest and Range Assessment Project and the Forest Legacy Assessment project; and forest carbon measurement methodology provided in Forest Protocols adopted by the California Air Resources Board.
Would the project:
a) Convert Prime Farmland, Unique Farmland, or
Farmland of Statewide Impo rtance (Farmland),
as shown on the maps prepared pursuant to the
Farmland Mapping and Monitoring Program of
the California Resources Agency, to non -
agricultural use?
b) Conflict with existing zoning for agricultural use, or a Williamson Act contract?
c) Conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code
section 12220(g)), timberland (as defined by Public
Resources Code section 4526), or timberland zoned
Timberland Production (as defined by Government
Code section 51104(g))?
d) Result in the loss of forest land or conversion of
forest land to non-forest use?
e) Involve other changes in the existing environment
which, due to their location or nature, could result in conversion of Farmland, to non-agricultural use or
conversion of forest land to non-forest use?
a) Would the project convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use? No Impact. The City does not contain any Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the FMMP (DOC 2019). As such, there are no designated farmlands on or near the Project site and the proposed Project would not convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance . Additionally, the Project site is located in an urban area on a site that is fully developed with buildings and asphalt paving , which precludes agricultural activities. No impact would occur. 740-790 EAST GREEN STREET MIXED-USE PROJECT
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b) Would the project conflict with existing zoning for agricultural use, or a Williamson Act contract? No Impact. The Project site is located in an urban area on a site that is fully developed with buildings and asphalt paving, which precludes agricultural activities. The Project site is designated CD-4 (Central District), which does not allow for agricultural land u se activities. Similarly, the proposed Zone Change (to PD) associated with the proposed Project would not allow for agricultural activities. There are no agricultural land use zones or lands under Williamson Act contracts on or near the Project site under existing conditions (DOC 2016). Given this, the proposed Project would not conflict with existing zoning for agricultural use or with a Williamson Act contract. c) Would the project conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code section 12220(g)), timberland (as defined by Public Resources Code section 4526), or timberland zoned Timberland Production (as defined by Government Code section 51104(g))?
No Impact. As stated above, the Project site is fully developed under existing conditions, and is located in an urban area of down town Pasadena. The proposed Project would not conflict with existing zoning, proposed zoning, or cause rezoning of, forest land, timberland, or timberland zoned Timberlan d Production. Additionally, the Project site is surrounded by urban development and is not within the general or local vicinity of forest land or timberland. As such, no impact would occur. d) Would the project result in the loss of forest land or conversion of forest land to non-forest use? No Impact. As stated above, the Project site is fully developed under existing conditions, and is located in an urban area of downtown Pasadena. The Project site is zone d, and proposed to be zoned, for commercial office and multi-family uses and would not conflict with existing zoning, proposed zoning, or cause rezoning of, forest land, timberland, or timberland zoned Timberland Production. Additionally, the Project site is surrounded by urban developmen t and is not within the general or local vicinity of forest land or timberland. As such, the proposed Project would not result in the loss of forest land or conversion of forest land to non-forest use. No impact would occur. e) Would the project involve ot her changes in the existing environment which, due to their location or nature, could result in conversion of Farmland, to non -agricultural use or conversion of forest land to non-forest use?
No Impact. As stated above in Section 2.2(c) and (d), the Projec t site is located in an urban area, is surrounded by developed land uses and there is no farmland or forest land on or near the Project site.
The proposed Project would include a mixed-use development with residential and commercial office land uses, and would not entail land uses that involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland, to non -agricultural use or conversion of forest land to non-forest use. No impact would occur. 740-790 EAST GREEN STREET MIXED-USE PROJECT
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2.3 AIR QUALITY
Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Where available, the significance criteria established by the applicable air quality management district or air pollution control district may be relied upon to make the following determinations.
Would the project:
a) Conflict with or obstruct implementation of the
applicable air quality plan?
b) Result in a cumulatively considerable net increase
of any criteria pollutant for which the project region
is non-attainment under an applicable federal or
state ambient air quality standard?
c) Expose sensitive receptors to substantial pollutant
concentrations?
d) Result in other emissions (such as those leading to
odors) adversely affecting a substantial number of
people?
a) Would the project conflict with or obstruct implementation of the applicable air quality plan? Less Than Significant Impact. The proposed Project site is located within the South Coast Air Basin (SCAB), which includes the non-desert portions of Los Angeles, Riverside, and San Bernardino Counties, and all of Orange County, and is within the jurisdictional boundaries of the South Coast Air Quality Management District (SCAQMD).
The SCAQMD administers the Air Quality Management Plan (AQMP) for the SCAB, which is a comprehensive document outlining an air pollution control program for attaining all California Ambient Air Quality Standards (CAAQS) and National Ambient Air Quality Standards (NAAQS). The most recent adopted AQMP is the 2016 AQMP (SCAQMD 2017), which was adopted by the SCAQMD Governing Board in March 2017. The 2016 AQMP focuses on available, proven, and cost -effective alternatives to traditional strategies while seeking to achieve multiple goals in partnership with other entities promoting reductions in greenhouse gases (GHGs) and toxic risk, as well as efficiencies in energy use, transportation, and goods movement (SCAQMD 2017).
The purpose of a consistency finding is to determine if a proposed Project is inconsistent with the assumptions and objectives of the regional air quality plans, and, thus, if it would interfere with the region’s ability to comply with federal and state air quality standards. The SCAQ MD has established criteria for determining consistency with the currently applicable AQMP in Chapter 12, Sections 12.2 and 12.3, in the SCAQMD CEQA Air Quality Handbook. The criteria are as follows (SCAQMD 1993):
• Consistency Criterion No. 1: Whether the project would result in an increase in the frequency or severity of existing air quality violations, cause or contribute to new violations, or delay timely attainment of the ambient air quality standards or interim emission reductions in the AQMP. 740-790 EAST GREEN STREET MIXED-USE PROJECT
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• Consistency Criterion No. 2: Whether the project would exceed the assumptions in the AQMP or increments based on the year of project buildout and phase.
To address the first criterion regarding the proposed Project’s potential to result in an increase in the frequency or severity of existing air quality violations, cause or contribute to new violations, or delay timely attainment of the ambient air quality standards or interim emission reductions in the AQMP, Project - generated criteria air pollutant emissions were estimated and analyzed for significance and are addressed under Section 2.3(b). Detailed results of this analysis are included in Appendix A, CalEMMod Outputs. As presented in Section 2.3(b), construction and operation of the proposed Project would not generate criteria air pollutant emissions that exceed the SCAQMD’s thresholds, and it would therefore be consistent with Criterion No. 1.
The second criterion regarding the Project’s potential to exceed the assumptions in the AQMP or increments based on the y ear of Project buildout and phase is primarily assessed by determining consistency between the project’s land use designations and potential to generate population growth. In general, projects are considered consistent with, and would not conflict with or obstruct implementation of, the AQMP if the growth in socioeconomic factors is consistent with the underlying regional plans used to develop the AQMP (per Consistency Criterion No. 2 of the SCAQMD CEQA Air Quality Handbook).
The SCAQMD primarily uses demographic growth forecasts for various socioeconomic categories (e.g., population, housing, employment by industry) developed by the Southern California Association of Governments (SCAG) for its Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS) (SCAG 2016), which is based on general plans for cities and counties in the SCAB, for the development of the AQMP emissions inventory (SCAQMD 2017). 3 The SCAG 2016 RTP/SCS, and associated Regional Growth Forecast, are generally consistent with the local plans; therefore, the 2016 AQMP is generally consistent with local government plans.
As discussed in the introduction to Section I of this IS/MND, Existing Land Use and Zoning Designations, the General Plan land use designation for the proposed Project site is Medium Mixed-Use, and the zoning designation is CD -4 (Central District, Pasadena Playhouse). The Medium Mixed -Use designation is intended to support the development of multi -story buildings with a variety of compatible commercial (retail and office) and residential uses. The proposed base density allowed according to CD -4 zone standards is 87 dwelling units per acre, which allows for up to 203 units. With the addition of the 41 affordable housing units, and the associated 30% affordable housing density bonus, the Project proposes a total of 263 units, including 87 studio units, 125 one-bedroom units, and 51 two-bedroom units. Based on the unit count and number of bedrooms, a total of 39,450 square feet of open space is required. The Project incorporates 39,483 39,980 square feet of open space, which includes 27,180 27,795 square feet of common open space, 11,703 11,585 square feet of private open space, and 600 square feet of interior common open space. Thus, the Project would not require a land use change.
3 Information necessary to produce the emission inventory for the SCAB is obtained from the SCAQMD and other governmental agencies, including the California Air Resources Board , Caltrans, and SCAG. Each of these agencies is responsible for collecting data (e.g., industry growth factors, socioeconomic projections, travel activity levels, emission factors, emission speciation profile, and emissions) and developing methodologies (e.g., model and demographic forecast improvements) required to generate a comprehensive emissions inventory. SCAG incorporates these data into its Travel Demand Model for estimating/projecting vehicle miles traveled and driving speeds. SCAG’s socioeconomic and transportation activities projections in their 2016 RTP/SCS are integrated in the 2016 AQMP (SCAQMD 2017). 740-790 EAST GREEN STREET MIXED-USE PROJECT
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The Project site is well -located to encourage the use of public transit and ac tive transportation modes.
The Project site is currently served by LA Metro, Foothill Transit, LA Department of Transportation, and Pasadena Transit. Furthermore, the Project would be a mixed-use development, providing a mix of retail, restaurant, and residential uses that could result in a reduction of vehicle miles traveled and associated air emissions from the resident’s trips to work and other activities. A ccordingly, the Project is consistent with the SCAG RTP/SCS forecasts used in the SCAQMD AQMP development.
In summary, based on the considerations presented for the two criteria, impacts relating to the Project’s potential to conflict with or obstruct implementation of the applicable AQMP would be less than significant.
No mitigation is required.
b) Would the project result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard?
Less Than Significant Impact. Air pollution is largely a cumulative impact. The nonattainment status of regional pollutants is a result of past and present development, and the SCAQMD develops and implements plans for future attainment of ambient air quality standards. Based on these considerations, project-level thresholds of significance for criteria pollutants are used in the determination of whether a project’s individual emissions would have a cumulativ ely considerable contribution on air quality. If a project’s emissions would exceed the SCAQMD significance thresholds, it would be considered to have a cumulatively considerable contribution. Conversely, projects that do not exceed the project -specific thresholds are generally not considered to be cumulatively significant (SCAQMD 2003).
A quantitative analysis was conducted to determine whether proposed construction activities would result in a cumulatively considerable net increase in emissions of criteria air pollutants for which the SCAB is designated as nonattainment under the NAAQS or CAAQS. Criteria air pollutants include ozone (O 3), nitrogen dioxide (NO 2), carbon monoxide (CO), sulfur dioxide (SO 2), particulate matter with an aerodynamic diameter less than or equal to 10 microns (PM 10), particulate matter with an aerodynamic diameter less than or equal to 2.5 microns (PM2.5), and lead. Pollutants that are evaluated herein include volatile organic compounds (VOCs) and oxides of nitrogen (NOx), which are important because they are precursors to O3, as well as CO, sulfur oxides (SOx), PM10, and PM2.5.
Regarding NAAQS and CAAQS attainment status,4 the SCAB is designated as a nonattainment area for national and California O3 and PM2.5 standards (CARB 2018; EPA 2018a). The SCAB is designated as a nonattainment area for California PM 10 standards; however, it is designated as an attainment area for national PM10 standards. The SCAB nonattainment status of O 3, PM10, and PM2.5 standards is the result of cumulative emissions from various sources of air pollutants and their precursors within the SCAB, including motor vehicles, off -road equipment, and commercial and industrial facilities. The SCAB is designated as an attainment area for national and California NO2, CO, and SO2 standards. Although the
4 An area is designated as in attainment when it is in compliance with the NAAQS and/or the CA AQS. The NAAQS and CAAQS are set by the Environmental Protection Agency (EPA) and California Air Resources Board (CARB), respectively, for the maximum level of a given air pollutant that can exist in the outdoor air without unacceptable effects on human health or the public welfare. Attainment = meets the standards; attainment/maintenance = achieve the standards after a nonattainment designation; nonattainment = does not meet the standards. 740-790 EAST GREEN STREET MIXED-USE PROJECT
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SCAB has been designated as partial nonattainment (Los Angeles County) for the federal rolling 3-month average lead standard, it is designated attainment for the state lead standard.5 The SCAQMD has established Air Quality Significance Thresholds, as revised in April 2019, which set forth quantitative emissions significance thresholds below which a project would not have a significant impact on ambient air quality (SCAQMD 2019). The quantitative air quality anal ysis provided in this section (Section 2.3) applies the SCAQMD thresholds to determine the potential for the Project to result in a significant impact under CEQA, as presented in Table 2.3-1.
Table 2.3-1. SCAQMD Air Quality Significance Thresholds Criteria Pollutants Mass Daily Thresholds
Pollutant
Construction
(Pounds per Day)
Operation
(Pounds per Day)
VOC 75 55
NOx 100 55
CO 550 550
SOx 150 150
PM10 150 150
PM2.5 55 55
Leada 3 3
Toxic Air Contaminants (TACs) and Odor Thresholds
TACsb (including carcinogens
and noncarcinogens)
Maximum incremental cancer risk 10 in 1 million
Cancer Burden > 0.5 excess cancer cases (in areas > 1 in 1 million) Chronic and Acute Hazard index 1.0 (project increment) Odor Project creates an odor nuisance pursuant to SCAQMD Rule 402 Ambient Air Quality Standards for Criteria Pollutants c
NO2 1-hour average
NO2 annual arithmetic mean
SCAQMD is in attainment; proposed project is significant if it causes or contributes to an exceedance of the following attainment standards:
0.18 ppm (state)
0.030 ppm (state) and 0.0534 ppm (federal)
CO 1-hour average
CO 8-hour average
SCAQMD is in attainment; proposed project is significant if it causes or contributes to an exceedance of the following attainment standards:
20 ppm (state) and 35 ppm (federal)
9.0 ppm (state/federal)
PM10 24-hour average
PM10 annual average
10.4 g/m3 (construction)d
2.5 g/m3 (operation)
1.0 g/m3
PM2.5 24-hour average 10.4 g/m3 (construction)d
2.5 g/m3 (operation)
SO2
1-hour average
24-hour average
0.25 ppm (state) & 0.075 ppm (federal- 99th percentile)
0.04 ppm (state)
Sulfate
24-hour average
25 g/m3 (state)
5 Re-designation of the lead NAAQS designation to attainment for t he Los Angeles County portion of the SCAB is expected based on current monitoring data. The phase out of leaded gasoline started in 1976. Since gasoline no longer contains lead, the project is not anticipated to result in impacts related to lead; therefore, it is not discussed in this analysis. 740-790 EAST GREEN STREET MIXED-USE PROJECT
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Table 2.3-1. SCAQMD Air Quality Significance Thresholds Criteria Pollutants Mass Daily Thresholds
CO
1-hour average
8-hour average
South Coast AQMD is in attainment; project is significant if it causes or contributes to an exceedance of the following attainment standards: ‘ 20 ppm (state) and 35 ppm (federal)
9.0 ppm (state/federal)
Lead
30-day average
Rolling 3-month average
1.5 g/m3 (state)
0.15 g/m3 (federal)
Source: SCAQMD 2019.
SCAQMD = South Coast Air Quality Management District; VOC = volatile organic compound; NOx = oxides of nitrogen; CO = carbon monoxide; SOx = sulfur oxides; PM10 = coarse particulate matter; PM2.5 = fine particulate matter; TAC = toxic air contaminant; NO2 = nitrogen dioxide; ppm = parts per million; g/m3 = micrograms per cubic meter.
a The phase-out of leaded gasoline started in 1976. Since gasoline no longer contains lea d, the proposed Project is not anticipated to result in impacts related to lead; therefore, it is not discussed in this analysis. b TACs include carcinogens and non-carcinogens.
c Ambient air quality standards for criteria pollutants are based on SCAQMD Rule 1303, Table A-2, unless otherwise stated. d Ambient air quality threshold are based on SCAQMD Rule 403.
A project would result in a substantial contribution to an existing air quality violation of the NAAQS or CAAQS for O3, which is a nonattainment pollutant, if the project’s construction or operational emissions would exceed the SCAQMD VOC or NO x thresholds shown in Table 2.3-1. These emission -based thresholds for O3 precursors are intended to serve as a surrogate for an “ozone signifi cance threshold” (i.e., the potential for adverse O3 impacts to occur) because O3 itself is not emitted directly, and the effects of an individual project’s emissions of O3 precursors (VOCs and NOx) on O3 levels in ambient air cannot be determined through air quality models or other quantitative methods.
The following discussion quantitatively evaluates Project-generated emissions and impacts that would result from implementation of the proposed Project.6
Construction Emissions
Proposed construction activities would result in the temporary addition of pollutants to the local airshed caused by on-site sources (i.e., off-road construction equipment, soil disturbance, and VOC off-gassing) and off -site sources (i.e., on -road haul trucks, vend or trucks, and worker vehicle trips). Construction emissions can vary substantially from day to day, depending on the level of activity; the specific type of operation; and, for dust, the prevailing weather conditions. Therefore, an increment of day -to-day variability exists and, as a result, such emission levels can only be approximately estimated.
Emissions from the construction phase of the proposed Project were estimated using the California Emissions Estimator Model (CalEEMod) version 2016.3.2. For emission estimation purposes, demolition and construction is assumed to begin in May 2023 and conclude in December 2025.7 A detailed depiction
6 The analysis in this IS/MND represents a conservative analysis since the revisions to the Project Description, as shown in Section I of this document , include a decrease of approximately 2,000 square feet of office use , which would result in an incremental decrease in operational impacts accordingly. 7 The analysis in this IS/MND assumes a construction start date of May 2023. In practice, construction is anticipated to begin at a later date. However, using an earlier start date for construction represents a conservative scenario for construction impacts, because equipment and vehicle emission factors for later years would be slightly less due to more stringent standards for in -use off-road equipment and heavy -duty trucks, as well as fleet turnover replacing older equipment and vehicles in later years.
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of expected construction schedules —including information regarding phasing, equipment used during each phase, truc ks, and worker vehicles —is provided in Appendix A. The analysis assumes a construction start date of May 2023, which represents the earliest date construction would initiate. In the event construction is started later than May 2023, the analysis performed represents the worst -case scenario for criteria air pollutant emissions because equipment and vehicle emission factors for later years would be slightly less due to more stringent standards for in -use off-road equipment and heavy - duty trucks, as well as fleet turnover replacing older equipment and vehicles in later years.
The construction equipment mix used and estimated hours of operation per day for estimating the construction emissions of the pro posed Project are based on CalEEMod default assumptions a nd are shown in Table 2.3-2. For this analysis, it was assumed that heavy construction equipment would operate 5 days a week during Project construction.
Table 2.3-2. Construction Scenario Assumptions
Construction
Phase
One-Way Vehicle Trips Equipment Schedule
Average Daily
Worker Trips
Average Daily
Vendor Truck
Trips
Total Haul
Truck Trips
Types
Quantity
Usage Hours
Start Date
Finish Date
Demolition 16 0 546 Rubber Tired
Dozers
2 8 06/01/2023 06/30/2023
Excavators 3 8
Concrete/Industrial
Saws
1 8
Grading 20 0 5,094 Excavators 2 8 07/01/2023 09/30/2023 Graders 1 8
Rubber Tired
Dozers
1 8
Scrapers 2 8
Tractors/Loaders/
Backhoes
2 8
Trenching 4 0 0 Trenchers 1 8 07/01/2023 12/31/2024
Building
Construction
288 68 0 Cranes 1 7 10/01/2023 12/31/2024
Forklifts 3 8
Generator Sets 1 8
Tractors/Loaders/
Backhoes
3 7
Welders 1 8
Paving 16 0 0 Pavers 2 8 09/01/2025 12/31/2025
Paving Equipment 2 8
Rollers 2 8
Architectural
Coating
58 0 0 Air Compressors 1 6 01/01/2025 12/31/2025
Notes: See Appendix A for details.
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Demolition of on-site existing buildings and asphalt is anticipated to generate a total of 5,515 tons of demolition debris. Export of demolition material is anticipated to require 273 round haul truck trips (546 one-way trips). It is anticipated that no fi ll material would be imported, and 40,741 cubic yards would be exported during construction. Assuming a haul truck capacity of 16 cubic yards per truck, it is anticipated that 2,547 round haul truck trips (5,094 one-way trips) would be required to export excavated material off site.
The Project would be required to comply with SCAQMD Rule 403 to control dust emissions generated during any dust-generating activities. Standard construction practices that would be employed to reduce fugitive dust emissions include watering of the active dust areas three times per day, with additional watering depending on weather conditions. The Project would involve application of architectural coating (e.g., paint and other finishes). The construction contractor is required to procure architectural coatings from a supplier that complies with the requirements of SCAQMD’s Rule 1113 (Architectural Coatings).
Estimated maximum daily construction criteria air pollutant emissions from all on -site and off -site emission sources is provided in Table 2.3-3, Estimated Maximum Daily Construction Emissions.
Table 2.3-3. Estimated Maximum Daily Construction Emissions Year
VOC NOx CO SOx PM10a PM2.5a
pounds per day
2023b 4.19 50.80 36.05 0.13 5.38 3.21
2024 3.13 21.91 29.48 0.08 3.73 1.59
2025 8.45 9.89 18.58 0.03 1.12 0.62
Maximum Daily Emissions 8.45 50.80 36.05 0.13 5.38 3.21 SCAQMD Threshold 75 100 550 150 150 55
Threshold exceeded? No No No No No No
Source: See Appendix A for detailed results.
Notes: VOC = volatile organic compound; NOx = oxides of nitrogen; CO = carbon monoxide; SOx = sulfur oxides; PM10 = coarse particulate matter; PM2.5 = fine particulate matter; SCAQMD = South Coast Air Quality Management District. a These estimates reflect control of fugitive dust required by SCAQMD Rule 403 (SCAQMD 2005). b The analysis in this IS/MND assumes a construction start date of May 2023. In practice, construction is anticipated to begin at a later date.
However, using an earlier start date for construction represents the worst -case scenario construction impacts, because equipment and vehicle emission facto rs for later years would be slightly less due to more stringent standards for in -use off-road equipment and heavy - duty trucks, as well as fleet turnover replacing older equipment and vehicles in later years.
As shown in Table 2.3-3, daily construction emis sions would not exceed the SCAQMD significance thresholds for VOC, NO x, CO, SO x, PM10, or PM 2.5 during Project construction. Therefore, construction impacts of the proposed Project would be less than significant, and no mitigation is required.
Operational Emissions
Operation of the proposed Project would produce VOC, NO x, CO, SO x, PM 10, and PM 2.5 emissions associated vehicular traffic, area sources (consumer products, architectural coatings, landscaping equipment), and energy sources (natural gas, appliances, and space and water heating). It was assumed that the proposed Project would not include any woodburning or natural gas fireplaces. As such, area source emissions associated with hearths were not included. Operational year 2026 was assumed following completion of Project construction.
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Emissions from the existing office land use were also estimated using CalEEMod to present the net change in criteria air pollutant emissions. The existing buildings were assumed to be general office building for purposes of the transportation analysis to be general office building. Therefore, the same existing use was assumed for air quality for consistency. Operational year 2020 was assumed for existing conditions.
On-road vehicular emissions associated with the proposed Project were modeled using CalEEMod default trip generation rates for retail, residential, and restaurant land uses. Emissions from energy sources include electricity and natural gas combustion for appliances and space and water heating.
CalEEMod defaults were used for area sources landscape maintenance equipment, consumer products, and architectural coatings for maintenance of buildings.
Trip generation rates for the Project and existing scenario were based on the TIA prepared for the Project (Pasadena Department of Transportation 2020). For the Project and the existing scenario, the assumed Saturday and Sunday trip rates were adjusted in proportion to the CalEEMod default weekday, Saturday and Sunday trip rates and the TIA weekday trip rate.
Table 2.3-4, Estimated Maximum Daily Operational Emissions, summarizes the net change in maximum area, energy, and mobile source emissions of criteria pollutants that would be generated by the development of the proposed Project in 2026 and operation of the existing land use in 2020. The values shown are the maximum summer or winter daily emissions (i.e., foreseeable worst case) results from CalEEMod. Details of the emission calculations are provided in Appendix A.8 Table 2.3-4. Estimated Maximum Daily Operational Emissions Emission Source
VOC NOx CO SOx PM10 PM2.5
(pounds per day)
Proposed Project
Area 6.76 0.25 21.72 0.00 0.12 0.12
Energy 0.11 0.96 0.55 0.01 0.08 0.08
Mobile 3.77 16.60 41.33 0.17 14.74 4.03
Total 10.64 17.81 63.60 0.17 14.94 4.22
Existing
Area 1.55 0.00 0.01 0.00 0.00 0.00
Energy 0.02 0.19 0.16 0.00 0.01 0.01
Mobile 1.35 6.62 18.61 0.06 4.69 1.30
Total 2.92 6.82 18.78 0.06 4.71 1.31
Net Change (Proposed
Project minus Existing)
7.72 10.99 44.82 0.11 10.23 2.91
SCAQMD Threshold 55 55 550 150 150 55
Threshold Exceeded? No No No No No No
Source: See Appendix A for detailed results.
Notes: VOC = volatile organic compound; NOx = oxides of nitrogen; CO = carbon monoxide; SOx = sulfur oxides; PM10 = coarse particulate matter; PM2.5 = fine particulate matter.
Area sources = consumer product use, architectural coatings, and landscape maintenance equipment. Energy sources = natural gas. Mobile sources = motor vehicles.
8 The analysis in this IS/MND represents a conservative analysis since the revisions to the Project Description, as shown in Section I of this document , include a decrease of approximately 2,000 square feet of office use, which would result in an incremental decrease in operational impacts accordingly. 740-790 EAST GREEN STREET MIXED-USE PROJECT
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The values shown are the maximum summer or winter daily emissions results from CalEEMod.
As shown in Table 2.3-4, the net change in combined emissions would not exceed the SCAQMD thresholds for VOC, NOx, CO, SOx, PM10, or PM2.5.
If a project’s emissions would exceed SCAQMD’s significance thresholds, it would be considered to have a cumulatively considerable contribution to nonattainment status in the SCAB. If a project does not exceed thresholds and is determi ned to ha ve less-than-significant project-specific impacts, it may still contribute to a significant cumulative impact on air quality. The basis for analyzing the project’s cumulatively considerable contribution is if the project’s contribution accounts for a significant proportion of the cumulative total emissions (i.e., it represents a “cumulatively considerable contribution” to the cumulative air quality impact) and consistency with SCAQMD’s 2016 AQMP, which addresses cumulative emissions in the SCAB.
As previously discussed, the SCAB has been designated as a federal nonattainment area for O 3 and PM2.5, and a state nonattainment area for O3, PM10, and PM2.5.Construction and operational activities of the proposed Project would generate VOC and NOx emissions (precursors to O3) and emissions of PM10 and PM 2.5. However, as indica ted in Tables 2.3-3 and 2.3-4, Project-generated emissions would not exceed the SCAQMD emission -based significance thresholds for VOCs, NOx, PM 10, or PM 2.5, and therefore the proposed Project would not cause a cumulatively significant impact.
Cumulative localized impacts would potentially occur if a project were to occur concurrently with another off- site project. Schedules for potential future projects near the project area are currently unknown; therefore, potential impacts associated with two or more simultaneous projects would be considered speculative. 9 However, future projects would be subject to CEQA and would require air quality analysis and, where necessary, mitigation. Criteria air pollutant emissions associated with construction activity of future projects would be reduced through implementation of control measures required by the SCAQMD. Cumulative PM10 and PM2.5 emissions would be reduced because all future projects would be subject to SCAQMD Rule 403 (Fugitive Dust), which sets forth general and specific requirements for all sites in the SCAQMD.
Therefore, the proposed Project would not result in a cumulatively considerable increase in emissions of nonattainment pollutants, and impacts would be less than significant during construction and operation.
No mitigation is required.
c) Would the project expose sensitive receptors to substantial pollutant concentrations? Sensitive receptors are those individuals more susceptible to the effects of air pollution than the population at large. People most likely to be affected by air pollution include children, the elderly, and people with cardiovascular and chronic respiratory diseases. According to the SCAQMD, places where sensitive receptors congregate include residences, schools, playgrounds, childcare centers, long -term healthcare facilities, rehabilitation centers, conv alescent centers, and retirement homes (SCAQMD 1993). Sensitive receptors near the proposed Project site include the following:
• Single- and multi-family residential land uses adjacent to the proposed Project site.
9 The CEQA Guidelines state that if a particular impact is too speculative for evaluation, the agency should note its conclusion and terminate discussion of the impact (14 CCR 15145).
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• Multi-family residential to the east across Hudson Avenue.
Localized Significance Thresholds
Less Than Significant Impact. The SCAQMD recommends a localized significance threshold (LST) analysis to evaluate localized air quality impacts to sensitive receptors in the immediate vicinity of the Project site as a result of construction activities. The impacts were analyzed using methods consistent with those in the SCAQMD’s Final Localized Significance Threshold Methodology (SCAQMD 2009). The proposed Project is located in Source-Receptor Area (SRA) 8 (West San Gabriel Valley).
The proposed Project area is 2.33 acres; therefore, the maximum daily disturbed acreage was conservatively assumed to be 2 acres. The SCAQMD LST screening thresholds for 2 acres within Source–Receptor Area 8 with a receptor distance of 25 meters (the shortest distance provided by the SCAQMD) were compared to emission s from the proposed Project.
Project construction activities would result in temporary sources of on-site criteria air pollutant emissions associated with construction equipment exhaust and dust -generating activities. Off-site emissions from trucks and worker vehicle trips are not included in the LST analysis because they occur off site . The maximum daily on-site construction emissions generated during construction of the proposed Project is presented in Table 2.3-5, Construction Localized Significance Thresholds Analysis, and compared to the SCAQMD localized significance screening thresholds for SRA 8 to determine whether Project-generated on-site construction emissions would result in potential LST impacts.
Table 2.3-5. Construction Localized Significance Thresholds Analysis Pollutant
Project Construction
Emissions
(Pounds per Day)
LST Screening
Thresholds
(Pounds per Day) Exceeds LST?
NO2 37.75 98 No
CO 30.64 812 No
PM10 4.04 6 No
PM2.5 2.81 4 No
Source: See Appendix A for detailed results.
Notes: NO2 = nitrogen dioxide; CO = carbon monoxide; PM 10 = particulate matter; PM 2.5 = fine particulate matter; SCAQMD = South Coast Air Quality Management District; LST = localized significance threshold.
Localized significance thresholds are shown for a 2-acre project site corresponding to a distance to a sensitive receptor of 25 meters.
These estimates reflect control of fugitive dust required by Rule 403.
The emissions represent worst-case operating scenario during construction.
As shown in Table 2.3-5, proposed construction activities would not generate emissions in excess of location specific LST screening thresholds; therefore, localized P roject construction impacts would be less than significant. No mitigation is required.
CO Hotspots
Less Than Significant Impact. Traffic-congested roadways and intersections have the potential to generate localized high levels of CO. Localized areas where ambient concentrations exceed federal and/or state standards for CO are termed CO “hotspots.” CO transport is extremely limited and disperses rapidly with distance from the source. Under certain extreme meteorological conditions, however, CO concentrations near 740-790 EAST GREEN STREET MIXED-USE PROJECT
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a congested roadway or intersection may reach unhealthy levels, affecting sensitive receptors. Typically, high CO concentrations are associated with severely congested intersections operating at an unacceptable level of service (LOS) (LOS E or worse is unacceptable). Projects contributing to adverse traffic impacts may result in the formation of a CO hotspot. Additional analysis of CO hotspot impacts would be conducted if a project would result in a significant impact or contribute to an adverse traffic impact at a signalized intersection that would potentially subject sensitive receptors to CO hotspots.
The Code of Federal Regulations (CFR) Procedures for Determining Localized CO, PM 10, and PM 2.5 Concentrations (hot-spot analysis), states that “CO, PM10, and PM2.5 hot-spot analyses are not required to consider con struction-related activities, which cause temporary increases in emissions. Each site which is affected by construction -related activities shall be considered separately, using established ‘Guideline’ methods. Temporary increases are defined as those which occur only during the construction phase and last five years or less at any individual site” (40 CFR 93.123(c)(5)). While Project construction would involve on-road vehicle trips from trucks and workers during construction, construction activities are con sidered temporary and less trip -inducing than project operation . As a result, the proposed construction activities would not require a Project-level construction hotspot analysis.
Mobile source impacts occur on two scales of motion. Regionally, P roject-related travel would add to regional trip generation and increase the vehicle miles traveled (VMT) within the local airshed and the SCAB. Locally, Project-generated traffic would be added to the City of Pasadena’s (City’s) roadway system near the Project site. If such traffic occurs during periods of poor atmospheric ventilation, is composed of a large number of vehicles cold-started and operating at pollution-inefficient speeds, and is operating on roadways already crowded with non-Project traffic, there is a potential for the formation of microscale CO hotspots in the area immediately around points of congested traffic. Because of continued improvement in vehicular emissions at a rate faster than the rate of vehicle growth and/or congestion, the potential for CO hotspots in the SCAB is steadily decreasing.
To verify that the Project would not cause or contribute to a violation of the CO standard, a screening evaluation of the potential for CO hotspots was conducted for operation. The potential for CO hotspots was evaluated based on the results of the Traffic Impact Analysis for the Project (Pasadena Department of Transportation 2020), and the California Department of Transportation Institute of Transportation Studies Transportation Project-Level Carbon Monoxide Protocol (CO Protocol; Caltrans 1997) was followed. For projects located within an area designated as attainment or unclassified under the CAAQS or NAAQS, the CO Protocol identifies screening criteria for consideration. The first screening criteria focuses on projects that are likely to worsen air quality, which would occur if (1) the project significantly increases the percentage of vehicles operating in cold-start mode (greater than 2%), (2) the project significantly increases traffic volumes (greater than 5%), and/or (3) the project worsens traffic flow. In addition to consideration of whether the project would worsen air quality, CO hotspots are typically evaluated when (1) the LOS of an intersection or roadway decreases to LOS E or worse, (2) signalization and/or channelization is added to an intersection, and (3) sensitive receptors such as residences, schools, and hospitals are located in the vicinity of the affected intersection or roadway segment. No intersections studies in the Traffic Impact Analysis identified a LOS that would exceed the screening thresholds (Pasadena Department of Transportation 2020) .
Therefore, the project would not cause an intersection to exceed the screening thresholds to necessitate a quantitative CO hotspots analysis.
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Accordingly, the Project would not generate traffic that would contribute to potential adverse traffic impacts that may result in the formation of CO hotspots. In addition, due to continued improvement in vehicular emissions at a rate faster than the rate of vehicle growth and/or congestion, the potential for CO hotspots in the SCAB is steadily decreasing. Based on these considerations, the Project would result in a less-than- significant impact to air quality with regard to potential CO hotspots. No mitigation is required.
Toxic Air Contaminants
Less Than Significant Impact. Toxic air contaminants (TACs) are defined as substances that may cause or contribute to an increase in deaths or in serious illness, or that may pose a present or potential hazard to human health. The nearest sensitive-receptor land use (i.e., a residence) is located approximately 60 feet from the Project site boundary.
Health effects from carcinogenic air toxics are usually described in terms of cancer risk. The SCAQMD recommends an incremental cancer risk threshold of 10 in 1 million. “Incremental cancer risk” is the net increased likelihood that a person continuously exposed to concentrations of TACs resulting from a Project over a 9-, 30-, and 70-year exposure period will contract cancer based on the use of standard Office of Environmental Health Hazard Ass essment (OEHHA) risk-assessment methodology (OEHHA 2015). In addition, some TACs have non -carcinogenic effects. The SCAQMD recommends a Hazard Index of 1 or more for acute (short -term) and chronic (long-term) non-carcinogenic effects.10 TACs that would potentially be emitted during construction activities associated with development of the proposed Project would be diesel particulate matter.
Project construction would result in emissions of diesel particulate matter from heavy construction equipment and trucks accessing the site. Diesel particulate matter is characterized as a TAC by the State of California.
The Office of Environmental Health Hazard Assessment has identified carcinogenic and chronic non - carcinogenic effects from long-term exposure but has not identified health effects due to short-term exposure to diesel exhaust. According to the Office of Environmental Health Hazard Assessment, health risk assessments, which determine the exposure of sensitive receptors to toxic emissions, should be based on a 30-year exposure period for the maximally exposed individual resident; however, such assessments should be limited to the period/duration of activities associated with the Project. Thus, the duration of the proposed construction activities would only constitute a small percentage of the total 30-year exposure period. Due to this relatively short period of exposure (32 months) and minimal particulate emissions on site , TACs generated by the Project would not result in concentrations causing significant health risks. Overall, the Project would not result in substantial TAC exposure to sensitive receptors in the vicinity of the proposed Project, and impacts would be less than significant.
Following completion of on-site construction activities, the proposed Project would not involve operational activities that would generate TAC emissions. For th e reasons described above, the P roject would not result in substantial TAC exposure to sensitive receptors in the vicinity of the proposed Project, and impacts would be less than significant. No mitigation is required.
10 Non-cancer adverse health risks are measured against a hazard index, which is defined as the ratio of the predicted incremental exposure concentrations of the various non-carcinogens from the project to published reference exposure levels that can cause adverse health effects.
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Health Effects of Criteria Air Pollutants
Less Than Significant Impact. Construction of the proposed Project would generate criteria air pollutant emissions; however, the project would not exceed the SCAQMD mass-emission thresholds.
Health effects associated with O 3 include respiratory symptoms, worsening of lung disease leading to premature death, and damage to lung tissue (CARB 2019). VOCs and NOx are precursors to O 3, for which the SCAB is designated as nonattainment with respect to the NAAQS and CAAQS. Thus, existing O3 levels in the SCAB are at unhealthy levels during certain periods. Because the proposed Project would not involve construction or operational activities th at would result in O 3 precursor emissions (VOC or NOx) in excess of the SCAQMD thresholds, the proposed Project is not anticipated to substantially contribute to regional O3 concentrations or the associated health impacts.
Exposure to NO2 and NOx can irrit ate the lungs, cause bronchitis and pneumonia, lower resistance to respiratory infections, and enhance allergic responses (CARB 2019). Project construction and operation would not exceed the SCAQMD NOx threshold, and existing ambient NO2 concentrations are below the NAAQS and CAAQS. Thus, implementation of the proposed Project is not expected to exceed the NO2 standards or contribute to associated health effects.
Health effects associated with CO include chest pain in patients with heart disease, headache, light- headedness, and reduced mental alertness (CARB 2019). CO tends to be a localized impact associated with congested intersections. CO hotspots were discussed previously as a less than significant impact. Thus, the proposed Project’s CO emissions would not contribute to the health effects associated with this pollutant.
Particulate matter exposure has been linked to a variety of problems, including premature death in people with heart or lung disease, nonfatal heart attacks, irregular heartbeat, aggrav ated asthma, decreased lung function, and increased respiratory symptoms such as irritation of the airways, coughing, or difficulty breathing (EPA 2016b). The SCAB is designated as nonattainment for PM10 under the CAAQS and nonattainment for PM2.5 under the NAAQS and CAAQS. Implementation of the proposed Project would not generate emissions of PM10 or PM2.5 that would exceed the SCAQMD’s thresholds. Accordingly, the proposed Project’s PM10 and PM2.5 emissions are not expected to cause any increase in relate d regional health effects for these pollutants.
In summary, the proposed Project would not result in a potentially significant contribution to regional concentrations of non -attainment pollutants and would not result in a significant contribution to the adverse health effects associated with those pollutants. Impacts would be less than significant. No mitigation is required.
d) Would the project result in other emissions (such as those leading to odors) adversely affecting a substantial number of people?
Less Than Significant Impact . The occurrence and severity of potential odor impacts depend on numerous factors. The nature, frequency, and intensity of the source; wind speed and direction; and the sensitivity of receiving location each contribute to the int ensity of the impact. Although offensive odors seldom cause physical harm, they can be annoying, cause distress among the public, and generate citizen complaints.
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During Project construction, exhaust from equipment may produce discernible odors typical of most construction sites. Potential odors produced during construction would be attributable to concentrations of unburned hydrocarbons from tailpipes of construction equipment. However, such odors would disperse rapidly from the Project site and generally occur at magnitudes that would not affect substantial numbers of people. Accordingly, impacts associated with odors during construction would be less than significant.
SCAQMD provides a list of land uses associated with odor concerns, which include agricultural uses, wastewater treatment plants, food -processing plants, chemical plants, composting, refineries, landfills, dairies, and fiberglass molding (SCAQMD 1993). The proposed Project includes operation of residences, retail, and restaurant spaces, which are not anticipated to generate odors and do not result in operation of the types of land uses listed in SCAQMD’s screening criteria. For the reasons described above, odor impacts from Project construction and operation would be less than significant. No mitigation is required.
2.4 BIOLOGICAL RESOURCES
Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Would the project:
a) Have a substantial adverse effect, either directly
or through habitat modifications, on any species
identified as a candidate, sensitive, or special
status species in local or regional plans, policies,
or regulations, or by the California Department of
Fish and Game or U.S. Fish and Wildlife
Service?
b) Have a substantial adverse effect on any
riparian habitat or other sensitive natural
community identified in local or regional plans,
policies, regulations, or by the California
Department of Fish and Game or U.S. Fish and
Wildlife Service?
c) Have a substantial adverse effect on state or
federally protected wetlands (including, but
not limited to, marsh, vernal pool, coastal,
etc.) through direct removal, filling,
hydrological interruption, or other means?
d) Interfere substantially with the movement of any
native resident or migratory fish or wildlife
species or with established native resident or
migratory wildlife corridors, or impede the use of
native wildlife nursery sites?
e) Conflict with any local policies or ordinances
protecting biological resources, such as a tree
preservation policy or ordinance?
f) Conflict with the provisions of an adopted
Habitat Conservation Plan, Natural Community
Conservation Plan, or other approved local,
regional, or state habitat conservation plan?
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a) Would the project have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Game or U.S. Fish and Wildlife Service?
No Impact. As shown in Figure 1, the Project site is entirely paved and surrounded by urban development under existing conditions. Vegetation on the Project site is limited to 12 on -site trees and two sparse planter beds, which would be removed under the proposed Project. Given this, the Project site does not support any naturally vegetated areas or green spaces that could contribute to habitat or habitat linkages for candidate, sensitive, or special -status species. Th e nearest protected open space which provides support for a number of native plant and wildlife communities is the Arroyo Seco, located approximately
1.8 miles west of the Project site (City of Pasadena 2015a). However, the Arroyo Seco is separated from the Project site by land uses that are urban in nature and as such, preclude the movement of wildlife in the direction of the Project site. For these reasons, no special -status species are expected to occur in the Project area, and development of the propose d Project would not either directly or through habitat modifications, result in a substantial adverse effect on any species identified as a candidate, sensitive, or special status in local or regional plans, policies, or regulations, or by the California Department of Fish and Game or U.S. Fish and Wildlife Service, and no mitigation is required. b) Would the project have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies , regulations, or by the California Department of Fish and Game or U.S. Fish and Wildlife Service? No Impact. There are no riparian habitat communities or other sensitive natural communities located on the Project site, which is fully developed with urban uses, with vegetation limited to ornamental landscaping under existing conditions. According to the United States Fish and Wildlife Service’s (FWS) National Wetlands Inventory (NWI), the nearest sensitive natural community is the Arroyo Seco, parts of which are considered Freshwater Forested/Shrub Wetland s with associated Forested/Shrub Riparian habitat (NWI 2019). As stated above, the Arroyo Seco is located approximately 1. 8 miles west o f the Project site, and is separated from the Project site by prevailing urban development. As such, demolition and construction activities at the Project site would have no impact on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations, or by the California Department of Fish and Game or U.S. Fish and Wildlife Service. c) Would the project have a substantial adverse effect on state or federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means? No Impact. As stated above in Section 2.4(b), there are no state or federally protected wetlands on or within the general vicinity of the Project site (NWI 2019). As such, Project implementation would not have a substantial adverse effect on state or federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological inte rruption, or other means . No impact would occur.
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d) Would the project interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites? Less Than Significant Impact with Mitigation Incorporated. As stated in Section 2.4(a), the Project site is located in a fully developed, urban area surrounded by urban land uses. The existing ornamental landscaping on the Project site does not provide substantial habitat for wildlife, nor could it serve as a native wildlife nursery site.
As stated in the General Plan EIR, the City is predominantly developed with urban land uses and sensitive biological resources are limited to the Arroyo Seco Watershed (1.8 miles west of the Project site) , the foothills of the San Gabriel Mountains (four miles north of the Project site) , the San Rafael Hills in the western part of the City (four miles northwest of the Project site), and the Eaton Wash (3.2 miles northeast of the Project site; City of Pasadena 2015). As such, wildlife movement is already greatly restricted within the City due to existing urban development. The Project site is separated from the undeveloped areas within and adjacent to the City by dense urban development, the presence of which restricts native wildlife movement in the direction of the Project site. As such, the proposed Project would not interfere substantially with the movement o f any native resident or migratory wildlife species or with established native resident or migratory wildlife corridors or impede the use of native wildlife nursery sites.
As stated in Section 2.4(b) and 2.4(c), there are no state or federal wetlands within proximity of the Project site (NWI 2019). The Arroyo Seco Watershed, located approximately 1. 8 miles west, is the closest riparian habitat to the Project site. As such, the proposed Project would not interfere substantially with the movement of any native resident or migratory fish.
However, the existing ornamental trees and around on the Project site could be utilized by migratory bird species for nesting during the breeding season. Migratory birds are protected under the Migratory Bird Treaty Act ( MBTA) and the California Fish and Game Code (CFGC). Construction -related activities, including the removal of some of these trees (see Figure 12) and construction noise, could disturb nesting birds protected u nder the MBTA. Compliance with MBTA would protect migratory birds, and further, compliance with Sections 3503, 3503.5, and 3513 – Native Bird Protection of the CFGC would avoid impacts to nesting birds. As such, the Project’s compliance with the MBTA and the CFGC would result in a less than significant impact on the movement of native resident or migratory fish or wildlife species and established native resident or migratory wildlife corridors, and the Project would not impede the use of native wildlife nursery sites.
e) Would the project conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance? Less Than Significant Impact. The Project site is surrounded to the north, east, and west by sidewalks and street trees. Mature ficus trees line East Green Street while a mix of other street trees, including Holly Oaks, Camphor trees, and Kurrajong Bottletree, are located in the ROW of South Hudson Avenue and South Oa k Knoll Avenue. As shown in Figure 12, Tree Inventory, the proposed Project would be constructed such that the mature trees along East Green Street would be preserved in place, whereas some existing street trees along South Hudson Avenue and South Oak Knoll Avenue that are in poor health would be removed and replaced with new trees. All street/public trees proposed for removal would be removed per the City’s municipal code Section 8.52.010. Moreover, the Applicant conducted a 740-790 EAST GREEN STREET MIXED-USE PROJECT
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Protected Tree Report prepared by a certified ar borist on February 4, 2022 (included as Attachment C to the Final MND) which made recommendations in compliance with the City’s Municipal Code. The Protected Tree Report was reviewed by the City’s Urban Forestry staff, which concurred with its conclusions that the Project would not require the removal of any of the existing ficus trees on Green Street. With adherence to the City’s Municipal Code, the proposed Project would not conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance. Impacts would be less than significant. No mitigation is required. f) Would the project conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan?
No Impact. The proposed Project would not be located within the planning area of any h abitat conservation plans or natural community conservation plans, or other approved local, regional, or state habitat conservation plan (CDFW 2019). As such, Project implementation would not conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan. No impacts would occur.
2.5 CULTURAL RESOURCES
Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
Would the project:
a) Cause a substantial adverse change in the
significance of a historical resource pursuant to
§15064.5?
b) Cause a substantial adverse change in the significance of an archaeological resource pursuant to §15064.5?
c) Disturb any human remains, including those interred
outside of dedicated cemeteries?
a) Would the project cause a substantial adverse change in the significance of a historical resource pursuant to §15064.5?
Less Than Significant Impact. Historic-age structures are those that are built more than 45 years ago and, therefore, have the potential to be considered historical resources pursuant to Section 15064.5 of the CEQA Guidelines. While some historical resources are also considered archaeo logical resources, such resources are addressed in Section 2.5(b), as part of the discussion of archaeological resources.
The five commercial structures proposed for demolition , located at 740 -750 East Green Street (constructed 1963), 770-784 East Green Street (constructed 1956), 790 East Green Street (constructed 1967), 111 South Hudson Avenue (constructed 1950), and 118 South Oak Knoll Avenue (constructed 1951), are of historic-age.
The cultural resources assessment for the proposed Project (Appendix B, Cultural Resources Technical Report) includes a description of the historic-age structures that could be affected by the proposed Project 740-790 EAST GREEN STREET MIXED-USE PROJECT
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and an evaluation as to whether the proposed Project would cause a substantial adverse change in the significance of a historical resource. As such, these buildings would be directly affected by the proposed Project and, therefore, were evaluated for their historical significance in consideration of National Register of Historic Places, California Register of Historical Resources, and City of Pasadena Historical Resources criteria and integrity requirements.
No cultural resources were identified within the Project site as a result of the California Historical Resources Information System (CHRIS) at the South Central Coast Information Center (SCCIC), Sacred Lands File (SLF) search, extensive archival research, field survey, and property significance evaluations.
The evaluation of the properties located at 740-750 East Green Street, 770-784 East Green Street, 790 East Green Street, 111 South Hudson Avenue, and 118 South Oak Knoll Avenue found that they do not appear eligible for NRHP, CRHR, or City designation due to a lack of significant historical associations , architectural merit, and integrity in all case s (Appendix B). Therefore, these five commercial buildings (740-750 East Green Street, 770 -784 East Green Street, 790 East Green Street, 111 South Hudson Avenue, and 118 South Oak Knoll Avenue ) are not considered historical resources for the purposes of CEQA. As such, removal of these buildings as part of the proposed Project would not cause a substantial adverse change in the significance of a historical resource.
Additionally, the cultural resources assessment for the proposed Project analyzed the results of the CHRIS records search, SLF search, California Historic Resource Inventory database with a focus on Pasadena properties, and extensive archival research. No additional cultural resources were identified adjacent to the Project site which might be indirectly affected by the proposed Project resulted from this analysis. As such, the proposed Project would not indirectly affect any adjacent historic -age structures.
For these reasons, impacts would be less than significant. b) Would the project cause a substantial adverse change in the significance of an archaeological resource pursuant to §15064.5?
Less Than Significant Impact with Mitigation Incorporated. A records search of the CHRIS at the SCCIC was conducted on April 16, 2019. The CHRIS records search did not identify any previously recorded archaeological resources mapped within the Project site or within 0.5-mile of the Project site.
The records search identified 18 previously conducted cultural resources technical investigations within the records search area, two of which are adjacent to Project’s northern boundary. None of these studies identified any cultural resource issues warranting additional study. Historic maps and aerial images were reviewed and demonstrated that structures did exist at least as early as 1927 with gradual development up to the 1950s. Given that the extant buildings within the Project site were constructed in the early to mid-twentieth century, there is potential for important older historic fe atures or artifact concentrations to exist subsurface.
Additionally, Dudek contacted the Native American Heritage Commission (NAHC) on August 13, 2019, and requested a review of the SLF. The NAHC replied via email on September 13, 2019, stating that the results of the SLF search were positive, though specific information pertaining to the location of these resources within the Project site was not provided by the NAHC. No additional tribal outreach was conducted by Dudek; however, in compliance with Assembly Bill (AB) 52, the City has contacted all NAHC -listed traditionally geographically affiliated tribal representatives that have requested Project notification. AB 52 consultation efforts conducted by the City are discussed in Section 2.18, Tribal Cultural Resources. 740-790 EAST GREEN STREET MIXED-USE PROJECT
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No newly or previously recorded archaeological resources were identified within the Project site or 0.5- mile records search buffer as a result of the CHRIS records search and NAHC SLF search. However, it is possible that previously undiscovered intact archaeological deposits are present at subsurface levels and could be uncovered during ground -disturbing activities. If such unanticipated discoveries were encountered, impacts to encountered re sources could be potentially significant. In order to ensure that all Project personnel are aware of the potential for encountering unknown archaeological resources within the Project site, a worker’s environmental awareness program (WEAP) training will be required to be implemented under MM-CUL-1 to ensure early identification and response to inadvertent discovery of unknown archaeological resources. In the event of an inadvertent discovery of an archaeological resource, a resource -specific management plan will be appropriately developed and implemented to ensure any potential adverse change to this resource is appropriately addressed under CEQA as defined under MM-CUL-2. Therefore, impacts to archaeological resources would be less than significant with MM-CUL-1 and MM-CUL-2 incorporated.
MM-CUL-1 Prior to commencement of construction activities at the Project site, the City’s construction contractor and construction personnel shall attend and complete a Workers Environmental Awareness Program (WEAP) training conducted by a qualified archaeologist. The WEAP training shall provide: (1) the types and characteristics of archaeological materials that may be identified during construction and explain the importance of and legal basis for the protection of signific ant cultural resources; (2) proper procedures to follow in the event that cultural resources or human remains are uncovered during ground -disturbing activities, including procedures for work curtailment or redirection; and (3) protocols for the contact of the site supervisor and archaeological monitor upon discovery of a resource.
The procedures and protocols shall be included in the construction plans and require that a qualified archaeologist be retained to evaluate cultural resource discoveries as they occur, to determine the significance of the resource and the appropriate approach forward.
MM-CUL-2 If cultural resources are discovered during construction of the proposed Project in the City of Pasadena that may be eligible for listing in the California Register for Historic Resources, all ground disturbing activities in the immediate vicinity of the find shall be halted until the find is evaluated by a Registered Professional Archaeologist. If testing determines that significance criteria are met, then the Project shall be required to perform data recovery, professional identification, radiocarbon dates as applicable, and other special studies; and provide a comprehensive final report including site record to the City and the South Central Coastal Information Center at California State University Fullerton.
No further grading shall occur in the area of the discovery until Planning Department approves the report.
c) Would the project disturb any human remains, including those interred outside of dedicated cemeteries?
Less Than Significant Impact. No prehistoric or historic burials were identified within the Project site based on the results of the CHRIS records search. Therefore, the likelihood of encountering human remains within the proposed Pr oject site is low. In the event human remains are inadvertently encountered during construction activities, the discovery would require handling in accordance with California Public Resources Code 5097.98, which requires the County Coroner to be immediately notified 740-790 EAST GREEN STREET MIXED-USE PROJECT
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if human remains are discovered. No further excavation or disturbance of the Project site or any nearby area reasonably suspected to overlie adjacent remains shall occur until the County Coroner has determined, within two working days of notification of the discovery, the appropriate treatment and disposition of the human remains. If the County Coroner determines that the remains are, or are believed to be, Native American, he or she shall notify the NAHC in Sacramento within 24 hours. In accordance with California Public Resources Code, Section 5097.98, the NAHC must immediately notify those persons it believes to be the most likely descendant from the deceased Native American. The most likely descendant shall complete their inspection within 48 hours of being granted access to the site. The designated Native American representative would then determine, in consultation with the property owner, the disposition of the human remains. Compliance with regulations would ensure that potential disturbance of any human remains, including those interred outside of dedicated cemeteries, would be less than significant.
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2.6 ENERGY
Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Would the project:
a) Result in potentially significant environmental
impact due to wasteful, inefficient, or
unnecessary consumption of energy resources,
during project construction or operation?
b) Conflict with or obstruct a state or local plan for
renewable energy or energy efficiency?
a) Would the project result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation?
Less Than Significant Impact. The construction and operation of the proposed Project would require the consumption of energy resources in several forms at the proposed Project site and within the proposed Project site area. In general, the aggregated-temporary (approximate 32 months) construction energy consumption would be less than energy consumed during the long-term operation of the facility.
To facilitate the discussion of whether the Project would result in environmental impacts due to wasteful, inefficient, or unnecessary consumption of energy, the construction and operational energy consumption is evaluated in detail below.11
Construction
Electricity
Temporary electric power for as-necessary lighting and electronic equipment (such as computers inside temporary construction trailers) would be provided by Pasadena Water and Power (PWP). The electricity used for such activities would be temporary and be s ubstantially less than that required for P roject operation, and would have a negligible contribution to the Project’s overall energy consumption.
Natural Gas
Natural gas is not anticipated to be required during construction of the proposed Project. Fuels used for construction would primarily consist of diesel and gasoline, which are discussed below under “Petroleum.” Any minor amounts of natural gas that may be consumed as a result of Project construction would be substantially less than that required for Project operation and would have a negligible contribution to the Project’s overall energy consumption.
11 The analysis in this IS/MND represents a conservative analysis since the revisio ns to the Project Description, as shown in Section I of this document , include a decrease of approximately 2,000 square feet of office use, which would result in an incremental decrease in operational impacts accordingly. 740-790 EAST GREEN STREET MIXED-USE PROJECT
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Petroleum
Heavy-duty construction equipment associated with demolition and construction activities would rely on diesel fuel, as would vendor trucks involved in delivery of materials to the Project site. Construction workers would travel to and from the Project site throughout the duration of construction. It is assumed in this analysis that construction workers would travel in gasoline-powered light-duty vehicles.
Heavy-duty construction equipment of various types would be used during each phase of Project construction.
Appendix C, Energy Calculations lists the assumed equipment usage for each phase of construction. The Project’s construction equipment is estimated to operate a total combined 37,610 hours.
Fuel consumption from construction equipment was estimated b y converting the total carbon dioxide (CO2) emissions from each construction phase to gallons using the conversion factors for CO2 to gallons of gasoline or diesel. The conversion factor for gasoline is 8.78 kilograms per metric ton of CO2 per 1 gallon of gasoline, and the conversion factor for diesel is 10.21 kilograms per metric ton of CO2 per 1 gallon of diesel (The Climate Registry 2020). The estimated diesel fuel usage from construction equipment is provided in Table 2.6-1.
Table 2.6-1. Construction Equipment Diesel Demand (Off-Road Equipment) Phase
Pieces of
Equipment
Equipment
CO2 (MT) kg/CO2/Gallon Gallons
Demolition 6 37.39 10.21 3,662.21
Grading 8 177.24 10.21 17,359.37
Trenching 1 58.46 10.21 5,726.24
Building Construction 9 379.06 10.21 37,126.20
Architectural Coating 1 33.32 10.21 3,263.46
Paving 6 88.08 10.21 8,627.29
Total 75,764.77
Sources: Pieces of equipment and equipment CO2 (Appendix C); kg/CO2/Gallon (The Climate Registry 2020).
Notes: CO2 = carbon dioxide; MT = metric ton; kg = kilogram.
Fuel consumption from worker, vendor, and haul truck trips are estimated by converting the total CO 2 emissions from each construction phase to gallons using the conversion factors for CO 2 to gallons of gasoline or diesel. Worker vehicles are assumed to be gasoline, and vendor/hauling vehicles are assumed to be diesel. Calculations for total worker, vendor, and haul truck fuel consumption are provided in Table 2.6-2, Table 2.6-3, and Table 2.6-4.
Table 2.6-2. Construction Worker Gasoline Demand
Phase Trips
Vehicle
MT CO2 kg/CO2/Gallon Gallons
Demolition 352 1.62 8.78 184.27
Grading 1,300 5.98 8.78 680.54
Trenching 352 7.06 8.78 803.82
Building Construction 112,896 422.10 8.78 48,074.98
Architectural Coating 5,232 64.81 8.78 7,381.48
Paving 15,138 6.03 8.78 686.56
Total 57,811.64
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Sources: Trips and vehicle CO2 (Appendix C); kg/CO2/Gallon (The Climate Registry 2020).
Notes: MT = metric ton; CO2 = carbon dioxide; kg = kilogram.
Table 2.6-3. Construction Vendor Diesel Demand
Phase Trips
Vehicle
MT CO2 kg/CO2/Gallon Gallons
Demolition 0 0.00 10.21 0.00
Grading 0 0.00 10.21 0.00
Trenching 0 0.00 10.21 0.00
Building Construction 22,236 256.13 10.21 25,085.92
Architectural Coating 0 0.00 10.21 0.00
Paving 0 0.00 10.21 0.00
Total 25,085.92
Sources: Trips and vehicle CO2 (Appendix C); kg/CO2/Gallon (The Climate Registry 2020).
Notes: MT = metric ton; CO2 = carbon dioxide; kg = kilogram.
Table 2.6-4. Construction Haul Truck Diesel Demand
Phase Trips
Vehicle
MT CO2 kg/CO2/Gallon Gallons
Demolition 546 19.71 10.21 1,930.15
Grading 5,094 183.86 10.21 18,007.64
Trenching 0 0.00 10.21 0.00
Building Construction 0 0.00 10.21 0.00
Architectural Coating 0 0.00 10.21 0.00
Paving 0 0.00 10.21 0.00
Total 19,937.79
Sources: Trips and vehicle CO2 (Appendix C); kg/CO2/Gallon (The Climate Registry 2020).
Notes: MT = metric ton; CO2 = carbon dioxide; kg = kilogram.
In summary, construction of the Project is conservatively anticipated to consume 57,812 gallons of gasoline and 120,788 gallons of diesel over approximately 32 months. By comparison, California’s consumption of petroleum is approximately 74.8 million gallons per day. Based on these assumptions, approximately 53 billion gallons of petroleum would be consumed in California over the course of the construction period (EIA 2017). Within Los Angeles County, approximately 24 billion gallons of petroleum (gasoline and diesel) would be consumed over the course of the construction period (CARB 2019). Thus, the Project’s construction fuel demand represents 0.0001% and 0.0002% of the fuel consumption for the State and County, respectively. Further, the Project would be required to comply with CARB’s Airborne Toxics Control Measure, which restricts heavy-duty diesel vehicle idling time to 5 minutes, which would minimize fuel consumption. While construction activities would consume petroleum -based fuels, consumption of such resources would be temporary and would cease upon the completion of construction. Further, the petroleum consumed related to Project construction would be typical of construction projects of similar types and sizes and would not necessitate new petroleum resources beyond what are typically consumed in California. In addition, the Project site is well served by public transportation services and more construction workers would be anticipated to use public transportation to access the Project site during construction as compared to other sites that have fewer public transportation opportunities. Therefore, construction worker trips and associated petroleum consumption would be expected to be reduced compared to similar construction projects in rural locations. 740-790 EAST GREEN STREET MIXED-USE PROJECT
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Use of electricity, natural gas, and petroleum during Project construction would be required for the Project. Electricity and natural gas use would have a negligible contribution to the Project’s overall energy consumption. Petroleum would be used in a manner that is typical for construction (i.e. construction equipment, worker, vendor, and haul truck trips) and would not result in a wasteful, inefficient, and unnecessary use of energy. Therefore, impacts associated during construction would be less than significant. No mitigation is required.
Operation12
Electricity
Operation of the Project upon buildout would require electricity for multiple purposes, including cooling, lighting, appliances, and various equipment. Additionally, the supply, conveyance, treatment, and distribution of water and wastewater would indirectly result in electricity usage. Electrici ty consumption associated with Project operation is based on CalEEMod outputs presented in Appendix C.
CalEEMod default values for energy consumption for each land use were applied for the Project analysis.
The Project involves both residential and nonresidential uses. Fo r residential energy use, CalEEMod uses data collected during the Residential Appliance Saturation Survey to develop energy intensity values (electricity and natural gas per square foot per year). The energy use from nonresidential land uses is calculated in CalEEMod based on the California Commercial End -Use Survey database . For parking lots, CalEEMod includes calculation of energy use from lighting, ventilation, and elevators in parking lots and structures. Energy use in buildings (both natural gas and el ectricity) is divided by the program into end use categories subject to California Building Standards Code (Title 24) requirements (end uses associated with the building envelope, such as the HVAC system, water heating system, and integrated lighting) and those not subject to California Building Standards Code requirements (such as appliances, electronics, and miscellaneous “plug-in” uses).
The California Building Standards Code serves to enhance and regulate California’s building standards.
The Building Energy Efficiency Standards are part of the California Building Standards Code (specifically, Part 6 of Title 24). The most recent version of the Building Energy Efficiency Standards is referred to as the “2019 Building Energy Efficiency Standards” and went into effect in January 2020. As a result, the proposed Project would consume approximately 2,302,663 kilowatt-hours (kWh) per year during operation. The electricity consumption at the Project site under existing conditions was also calculated using CalEEMod and is estimated to be 1,146,795 kWh per year. As such, upon Project implementation, electricity demand at the Project site would increase by 1,155,868 kBTU per year as a result of the proposed increased development density on the site, and the associated: increased supply, conveyance, treatment, and distribution of water and wastewater; increased electricity use from the elevator in the parking structure; and increas ed electricity for lighting, appliances, and cooling from the multi-family residential buildings and retail buildings . For comparison, in 2018 the total residential and nonresidential electricity use in Pasadena Water and Power’s service area was 1,040,640,000 kilowatt- hours (CEC 2020). The Project’s electricity consumption would represent a 0.13% of the Pasadena Water and Power’s existing demand (2018) . The Project does not include a use that would result in a
12 The analysis in this IS/MND represents a conservative analysis since the revisions to the Project Description, as shown in Section I of this document , include a decrease of approximately 2,000 square feet of office use, which would result in an incremental decrease in operational impacts accordingly. 740-790 EAST GREEN STREET MIXED-USE PROJECT
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wasteful, inefficient, and unnecessary use of electrical energy. Furthermore, the project would comply with current Title 24 Standards and the California Green Building Standards. Therefore, the project’s electricity consumption would not be wasteful, inefficient, or unnecessary and would have a less-than- significant impact to electrical energy resources.
Natural Gas
Project operation would require natural gas for various purposes, including water heating and natural gas appliances. Natural gas consumption associated with operation is based on the Cal EEMod outputs (see Appendix C).
CalEEMod default values for energy consumption for each land use were applied for the Project analysis.
For residential energy use, CalEEMod uses data collected during the Residential Appliance Saturation Survey to develop energy intensity values (electricity and natural gas per square foot per year). The energy use from nonresidential land uses is calculated in CalEEMod based on the California Commercial End-Use Survey database. Energy use in buildings (both natural gas and electricity) is divided by the program into end use categories subject to California Building Standards Code requirements (end uses associated with the building envelope, such as the HVAC system, water heating system, and integrated lighting) and those not subject to California Building Standards Code requirements (such as appliances, electronics, and miscellaneous “plug- in” uses). Based on CalEEMod estimations, the proposed Project would consume approximately 3,734,981 kilo-British Thermal Units (kBTU) per year. Under existing conditions, it is estimated that 722,891 kBTU per year is used by the existing uses. As such, upon Project implementation, natural gas demand at the Project site would increase by 3,012,090 kBTU per year, which would equate to 3,013 therms. Natural gas is supplied to the Project site by SoCalGas. As of 2018, approximately 5,156 million therms of natural gas were used in SoCalGas’ service area per year (CEC 2020). Thus, the expected increase in use represents approximately
0.00007% of SoCalGas’ existing 2018 demand. The project would comply with current Title 24 Standards and the California Green Building Standards. Therefore, due to the inherent increase in efficiency of building code regulations, the proposed Project would not result in a wasteful, inefficient, or unnecessary use of natural gas. Impacts related to operational natural gas use would be less than significant.
Petroleum
During operations, the majority of fuel consumption resulting from the Project would involve the use of motor vehicles traveling to and from the Project site including residents, employees, and customers.
Petroleum fuel consumption associated with motor v ehicles traveling to and from the Project site is a function of the VMT as a result of Project operation. The annual VMT attributable to the proposed Project is expected to be 6,391,132 VMT. Under existing conditions at the Project site, the land uses to be demolished are estimated to result in 1,655,415 VMT per year (Appendix C). Similar to the construction worker and vendor trips, fuel consumption from operational trips are estimated by converting the total CO2 emissions from operation of the Project to gallons using the conversion factors for CO2 to gallons of gasoline or diesel.
Calculations for annual mobile source fuel consumption (gasoline and diesel) are provided in Table 2.6-5. 740-790 EAST GREEN STREET MIXED-USE PROJECT
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Table 2.6-5. Annual Operational Petroleum Demand
Scenario
Vehicle
MT CO2
Kg CO2/
Gallon Gallons
Proposed Project
Gasoline 2,317.83 8.78 263,990.22
Diesel 187.52 10.21 18,366.59
Total Project Petroleum Use 282,356.82
Existing
Gasoline 687.03 8.78 78,249.83
Diesel 53.45 10.21 5,234.68
Total Existing Petroleum Use 83,484.50
Net Increase in Petroleum Demand (Project minus Existing) 198,872.31 Sources: Trips and vehicle CO2 (Appendix C); kg/CO2/Gallon (The Climate Registry 2020).
Notes: MT = metric ton; CO2 = carbon dioxide; kg = kilogram As depicted in Table 2.6-5, the Project would consume approximately 282,357 gallons of petroleum per year and the existing scenario would consume approximately 83,485 gallons of petroleum per year, for an annual net increase of 198,872 gallons of petroleum. By comparison, California as a whole consumes approximately 28.7 billion gallons of petroleum per year. The anticipated increase in consumpti on associated with one year of P roject operation is 0.0008% of the statewide use. The Project is a mixed- use development located near transit stops. The nearest light rail stations are the Lake Metro Gold Line Station located at the Interstate 210 approximately 0.5 miles to the north, and the Del Mar Metro Gold Line Station located approximately 0.8 miles to the west near Central Park. As such, the proposed Project would provide residence and employment opportunities within proximity to transit services. The nature of the Project’s land use mix and site location would reduce VMT and associated petroleum use by being in proximity to complimentary land uses and employment centers, which could encourage use of alternative transportation methods such as transit, walking, or biking, or would result in shorter vehicle trips. In addition, the project would install four electric vehicle charging stations.
Over the lifetime of the Pr oject, the fuel e fficiency of vehicles used by residents, employees, and customers, as well as vehicles used for deliveries to the Project site, is expected to increase. As such, the amount of petroleum consumed as a result of v ehicular trips to and from the P roject site d uring operation would decrease over time. There are numerous regulations in place that require and encourage increased fuel efficiency. For example, CARB has adopted an approach to passenger vehicles by combining the control of smog-causing pollutants and GHG emissions into a single, coordinated package of standards. The approach also includes efforts to support and accelerate the number of plug-in hybrids and zero-emissions vehicles in California (CARB 2013). Additionally, in response to Senate Bill 375, CARB adopted the goal of reducing per -capita GHG emissions from 2005 levels by 8% by 2020, and 18% by 2035 for light -duty passenger vehicles in the SCAG planning area. As such, operation of the Project is expected to use decreasing amounts of petroleum over time due to advances in fuel economy.
In summary, the proposed Project would create additional electricity and natural gas demand. However, the Project would be subject to the 2019 Building Energy Efficiency Standards , which apply to new construction and regulate energy consumed for heating, cooling, ventilation, water heating, and lighting.
Compliance with the 2019 Building Energy Efficiency Standards would ensure that the energy efficiency of the proposed buildings is maximized to the extent feasible. F urthermore, the proposed Project would install 25 EV charging stations. For these reasons, the proposed Project would not result in wasteful, 740-790 EAST GREEN STREET MIXED-USE PROJECT
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inefficient, or unnecessary consumption of energy. I mpacts would be less than significant , and no mitigation is required.
b) Would the project conflict with or obstruct a state or local plan for renewable energy or energy efficiency?
Less Than Significant Impact. The proposed Project would be subject to state regulations for energy efficiency, namely, California’s Building Energy Efficiency Standards and CALGreen, both of which are set forth in the California Code of Regulations, Title 24. California’s Building Energy Efficiency Standards were established in 1978 and serve to enhance and regulate California’s building standards. These standards include regulations for residential and nonresidential buildings constructed in California to reduce energy demand and consumption. The Building Energy Efficiency Standards are updated periodically (every 3 years) to incorporate and consider new energy efficiency technologies and methodologies. CALGreen institutes mandatory minimum environmental performance standards for all ground -up, new construction of commercial, low-rise residential, and state-owned buildings, as well as schools and hospitals. The 2016 CALGreen standards became effective on January 1, 2017. The new 2019 standard become effective on January 1, 2020. The proposed Project would meet Building Energy Efficiency Standards and CALGreen standards to reduce energy demand and increase energy efficiency. In addition, the proposed Project would be consistent with the City’s Climate Action Plan (see Section 2.8).
At a regional level, the proposed Project would be subject to the policies set forth in SCAG’s Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS) The most recently adopted RTP/SCS 2040-2045 Connect SoCal is a long -range visioning plan that builds upon and expands land use and transportation strategies established over several planning cycles to increase mobility options and achieve a more sustainable growth pattern. It charts a path toward a more mobile, sustainable and prosperous region by making connections between transportation networks, between planning strategies and between the people whose collaboration can improve the quality of life for Southern Californians.
With regard to individual developments, such as the Project, the strategies and policies set forth in Connect SoCal include increased mobility options and achieve a more sustainable growth pattern.
The 2016 RTP/SCS is a regional growth -management strategy that targets per -capita GHG reduction from passenger vehicles and light -duty trucks in t he Southern California region pursuant to Senate Bill (SB) 375. In addition to demonstrating the region’s ability to attain and exceed the GHG emission - reduction targets set forth by CARB, the 2016 RTP/SCS outlines a series of actions and strategies for integrating the transportation network with an overall land use pattern that responds to projected growth, housing needs, changing demographics, and transportation demands. Thus, successful implementation of the 2016 RTP/SCS would result in more complete com munities with a variety of transportation and housing choices, while reducing automobile use. With regard to individual developments, such as the Project, the strategies and policies set forth in the 2016 RTP/SCS include improved energy efficiency.
The 2016 RTP/SCS goal is to actively encourage and create incentives for energy efficiency, where possible. As discussed previously, the Project would comply with the 2019 CALGreen standards.
As discussed above, and in Section 2.8 b), the Project would be not conflict with the measures within Connect SoCal by constructing a mixed-use development located near transit stops. As such, the Project would be designed to encourage pedestrian activity and would provide residence and employment opportunities within proximity to transit services. In addition, in accordance with CalGreen, 25% of the total number of parking spaces on the Project site, are required to be electric vehicle charging spaces 740-790 EAST GREEN STREET MIXED-USE PROJECT
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and 5% of the total number of parking spaces on a building site, are req uired to be electric vehicle charging stations. For these reasons , the proposed Project would be consistent with the SCAG 2016 RTP/SCS and Connect SoCal.
The proposed Project would follow applicable energy standards and regulations during construction. In addition, the proposed Project would be built and operated in accordance with all existing, applicable regulations at the time of construction. As such, t he proposed Project would not conflict with existing energy standards , regulations, or plans ; therefo re, impacts during construction and operation of the proposed Project would be less than significant, and no mitigation is required.
2.7 GEOLOGY AND SOILS
Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Would the project:
a) Directly or indirectly cause potential substantial
adverse effects, including the risk of loss, injury, or death involving:
i) Rupture of a known earthquake fault, as
delineated on the most recent Alquist-Priolo
Earthquake Fault Zoning Map issued by the
State Geologist for the area or based on other
substantial evidence of a known fault? Refer to
Division of Mines and Geology Special
Publication 42.
ii) Strong seismic ground shaking?
iii) Seismic-related ground failure, including
liquefaction?
iv) Landslides?
b) Result in substantial soil erosion or the loss
of topsoil?
c) Be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the
project, and potentially result in on- or off-site
landslide, lateral spreading, subsidence,
liquefaction or collapse?
d) Be located on expansive soil, as defined in Table
18-1-B of the Uniform Building Code (1994),
creating substantial direct or indirect risks to life or property?
e) Have soils incapable of adequately supporting the
use of septic tanks or alternative waste water
disposal systems where sewers are not available
for the disposal of waste water?
f) Directly or indirectly destroy a unique
paleontological resource or site or unique geologic
feature?
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a) Would the project directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving:
i) Rupture of a known earthquake fault, as delineated on the most recent Alquist - Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault? Refer to Division of Mines and Geology Special Publication 42.
Less Than Significant Impact. According to the General Plan Safety Element, the City is located at the boundary between two of Southern California’s geomorphic provinces, in an area that is being compressed by the geologic forces associated with the movement of the Pacific and North American plates (City of Pasadena 2002). In the Pasadena area, the main faults include the Sierra Madre fault, a reverse fault that extends across the City’s northern boundary, and the left -lateral strike-slip Raymond fault that locally extends into Pasadena’s southern and eastern boundaries (City of Pasadena 2002). Like all of Southern California, the proposed Project site is subject to potential moderate to strong seismic ground shaking as a result of movement along major regional faults. However, there are no faul ts underlying the proposed Project site. The proposed Project site is not located within Alquist -Priolo Earthquake Fault Zone (CGS 2019). Therefore, the risk of fault rupture in the immediate vicinity of the proposed Project site is low. The proposed Proje ct would not directly or indirectly cause or exacerbate the risk of fault rupture. As such, the proposed Project would not directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving rupture of a known earthquake fault, as delineated on the most recent Alquist -Priolo Earthquake Fault Zoning Map.
Therefore, impacts would be less than significant, and no mitigation is required. ii) Strong seismic ground shaking?
Less Than Significant Impact. Like most of southern California, the City is located in a seismically active area. Movement along major faults in proximity to the City, as well as along buried blind thrust faults, can occur across the greater Los Angeles Area. These faults, as well as numerous other regional faults, are capable of producing moderate to large earthquakes that could affect the Cit y. However, the proposed Project would be constructed in accordance with state and City building standards , as well as with the recommendations outlined in the Geotechnical Report prepared for the Project (Appendix D, Geotechnical Engineering Investigation). As with all development within the City, the proposed Project is required to comply with Title 24 of the California Building Code (CBC) and the Pasadena Building Code as legislated by Title 14 of the City’s Municipal Code. Proper engineering and compliance with Title 24 of the CBC, the Pasadena Building Code, and the recommendations established in the Geotechnical Report (Appendix D) would ensure the maximum feasible protection of the buildings and occupants. Additionally, implementation of the pr oposed Project would not exacerbate the potential for strong seismic ground shaking to occur. As such, the proposed Project would not directly or indirectly cause or exacerbate adverse effects involving seismic ground shaking. Impacts would be less than si gnificant, and no mitigation is required.
iii) Seismic-related ground failure, including liquefaction? Less Than Significant Impact. Liquefaction typically occurs in loose, saturated soils that lose their internal cohesion due to the associated pressure ch anges in the soil during seismic events. When liquefaction occurs, soils typically behave ‘liquid -like’, resulting in significant damage (i.e. collapse, 740-790 EAST GREEN STREET MIXED-USE PROJECT
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irreparable structural damage etc.) to structures and infrastructure built on them. According to the Geotechnical Report prepared for the Project, the soils underlying the proposed Project site are native alluvial soils comprising silty sands and sands, while the historically highest groundwater level beneath the proposed Project site was recorded at 90 feet below grade ( Appendix D). As such, the proposed Project site would not be prone to liquefaction and associated lateral spreading during the ground motion expected during a major seismic event (Appendix D). Additionally, the California Geological Surve y (CGS) has determined that the proposed Project site is not located in a liquefaction zone (CGS 2019).
Furthermore, as with all development within the City, the proposed Project is required to comply with the CBC, the Pasadena Building Code , and the recom mendations provided in the Geotechnical Report (Appendix D). As such, the proposed Project would not directly or indirectly cause or exacerbate adverse effects involving seismic -related ground failure, such as liquefaction. Impacts would be less than significant and no mitigation is required.
iv) Landslides?
Less Than Significant Impact. The proposed Project site is located on relatively flat terrain in downtown Pasadena. Both the California Geological Survey (201 9) as well as the Geotechnical Report (Appendix D) prepared for the proposed Project have determined that the proposed Project site is not located within a region susceptible to landslides. The closest earthquake -induced landslide zone is located approximately 1. 6 miles to the west of the proposed Project site (CGS 201 9). Furthermore, implementation of the proposed Project would not exacerbate the potential for landslides to occur. As such, impacts would be less than significant, and no mitigation is required. b) Would the project result in substantial soil erosion or the loss of topsoil? Less Than Significant Impact. The proposed Project site is not located in a hillside development area or agricultural zone that could be susceptible to eroding soils or the loss of topsoil due to site development. The proposed Project site is fully developed and paved, with negligible amounts of soil exposed in areas of ornamental landscaping. However, during construction -related activities , soils exposed during grading and excavation would have increased potential for erosion as a result of exposure to the elements (e.g. wind and water runoff) and human activity (e.g. movement of construction workers and equipment).
Given that the proposed Project would disturb more than one acre of soil, the proposed Project would be required to obtain coverage under the National Pollutant Discharge Elimination System (NPDES) General Permit for Storm Water Discharges Associated with the Construction and Lan d Disturbance Activities (Order No 2009 -009-DWQ as amended by 2010 -0014-DWQ and 2012 -0006-DWQ, NPDES No.
CAS000002) or the latest approved general permit. The General permit would include e rosion-control measures as part of the Storm Water Pollution Prevention Plan (SWPPP) for the proposed Project. The required SWPPP will mandate the implementation of Best Management Practices (BMPs) to reduce or eliminate construction-related pollutants in the runoff, including sediment. Implementation of the erosion control BMPs in the SWPPP would reduce construction-related soil erosion and there would be no loss of topsoil associated with proposed Project implementation. Impacts would be less than significant, and no mitigation is required.
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c) Would the project be locate d on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction or collapse? Less Than Significant Impact. According to the State of California Seismic Hazard Zones map for the Los Angeles Quadrangle, the site is not located in an area potentially susceptible to earthquake induced landslides, lateral spreading, or liquefaction (CGS 201 9). Based on the relatively flat topo graphy, proposed Project construction would not initiate a landslide or increase the potential for landslides to occur. Additionally, liquefaction is unlikely as the proposed Project site is not located within a liquefaction zone (CGS 2019) . According to t he Geotechnical Report prepared for the proposed Project site, the underlying alluvial soils are relatively uniform and are not expected to result in excessive differential soil settlements during a seismic event (Appendix D). Given the above, the potential impacts associated with landslides, lateral spreading, liquefaction, collapse and subsidence would be less than significant and no mitigation is required.
d) Would the project be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code (1994), creating substantial direct or indirect risks to life or property? Less Than Significant Impact. Expansive soils are clay-rich soils that shrink when dry and swell when wet.
This change in volume can exert substantial pressure on foundations, resulting in structural distress and/or damage. The proposed Project’s underlining soil consists of native alluvial soils comprising uniform silty sands and sands (Appendix D). These soils typically contain very little clay material and are usually not subject to expansion. Proposed Project construction would not increase or exacerbate the potential for expansive soils to create substantial direct or indirect risks to life or property. Additionally, the proposed Project would be constructed according to the mandatory seismic and structural design guidelines established in the CBC, the Pasadena Building Code, and in the Geotechnical Report prepared for the Project (Appendix D). As such, impacts would be less than significant. No mitigation is required. e) Would the project have soils incapable of adequately supporting the use of septic tanks or alternative waste water disposal systems where sewers are not available for the disposal of waste water?
No Impact. The proposed Project site is currently served by sewer infrastructure. No septic tanks or alternative wastewater disposal is proposed; therefore, the proposed Proj ect would have no impacts related to soils supporting the use of septic tanks or alternative waste water disposal systems. f) Would the project directly or indirectly destroy a unique paleontological resource or site or unique geologic feature?
Less Than Significant Impact with Mitigation Incorporated. The Project site is located south of the San Gabriel Mountains and southwest of the San Bernardino Mountains within Los Angeles County (Dibblee and Ehrenspeck, 1989). The Project site is underlain by Quaternary gravel and sand (map unit Qof; 2.58 million to 11,700 years old), derived as alluvial fan deposits from the San Gabriel Mountains to the north according to surficial geological mapping by Dibblee and Ehrenspeck (1989) at a 1:24,000 scale. These Pleistocene (or “Ice Age”), older alluvial fan deposits may be encountered at the surface or at an unknown depth beneath fill (Dibblee and Ehrenspeck, 1989). 740-790 EAST GREEN STREET MIXED-USE PROJECT
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Although no fossils are recorded from within the Project site itself, they are documented in the region from similar sedimentary deposits as those underlying the Project area. According to the records search results received from the Natural History Museum of Los Angeles County (LACM) on October 31, 2019, a fossil specimen of mastodon (Mammut) was recovered from locality LACM 2027 in the City, northeast of the Project site and south of the intersection between Washington Boulevard and Allen Avenue, near the western end of Brigden Road (McLeod, 2019). Another fossil locality, located west-southwest of the Project area, in Eagle Rock, east of the Glendale Freeway (Highway 2) and Eagle Rock Boulevard, south of York Boulevard produced fossil specimens from older Quaternary deposits. This lo cality LACM (CIT) 342 yielded fossil specimens of turkey ( Parapavo californicus) and mammoth (Mammuthus) at a depth of 14 feet below the ground surface (McLeod, 2019). Both specimens were documented in scientific publications (Miller, 1942; Roth, 1984). Given the proximity of past fossil discoveries in the surrounding area and potential for underlying, Pleistocene-age older alluvial fan deposits, these sedimentary deposits within the Project site are considered to be highly sensitive for supporting paleonto logical resources.
Younger, Holocene age alluvial fan deposits and artificial fill, if encountered within the proposed Project site, have low potential to yield paleontological resources.
No paleontological resources were identified within the Project site as a result of the institutional records search or desktop geological review. As such, the Project site is not anticipated to be underlain by unique geologic features. If intact paleontological resources are located on -site, ground -disturbing activities associated with construction of the proposed Project, such as grading during site preparation, have the potential to destroy a unique paleontological resource or site. As such, the p roposed Project site is considered to be potentially sensitive for paleontological resources and without mitigation, the potential damage to paleontological resources during construction associated with the p roposed Project is considered a potentially significant impact. Upon implementation of MM -GEO-1, impacts would be reduced to below a level of significance.
MM-GEO-1 Prior to commencement of any grading activity on-site, the Project Applicant shall retain a qualified paleontologist per the Society of Vertebrate Paleont ology (SVP) (2010) guidelines. The paleontologist shall prepare a Paleontological Resources Impact Mitigation Program (PRIMP) for the proposed Project. The PRIMP shall be consistent with the SVP (2010) guidelines and should outline requirements for precons truction meeting attendance and worker environmental awareness training, where monitoring is required within the proposed Project site based on construction plans and/or geotechnical reports, procedures for adequate paleontological monitoring and discoveri es treatment, and paleontological methods (including sediment sampling for microvertebrate fossils), reporting, and collections management. The PRIMP shall also address reducing or terminating monitoring when no resources are found pursuant to the SVP (201 0) guidelines. The qualified paleontologist shall attend the preconstruction meeting and a paleontological monitor shall be on -site during all rough grading and other significant ground-disturbing activities beyond a depth of five feet below the existing ground surface or the depth of any artificial fill in previously undisturbed, fine -grained older Quaternary (e.g., Pleistocene age) alluvial fan deposits . In the event that paleontological resources (e.g., fossils) are unearthed during grading, the paleonto logical monitor will temporarily halt and/or divert grading activity to allow recovery of paleontological resources. The area of discovery will be roped off with a 50 -foot radius buffer. Once documentation and collection of the find is completed, the monit or will remove the rope and allow grading to recommence in the area of the find.
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2.8 GREENHOUSE GAS EMISSIONS
Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Would the project:
a) Generate greenhouse gas emissions, either
directly or indirectly, that may have a significant
impact on the environment?
b) Conflict with an applicable plan, policy or
regulation adopted for the purpose of reducing the
emissions of greenhouse gases?
a) Would the project generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment?
Less Than Significant Impact. Climate change refers to any significant change in measures of climate, such as temperature, precipitation, or wind patterns, lasting for an extended period of time (decades or longer). The Earth’s temperature dep ends on the balance between energy entering and leaving the planet’s system, and many factors (natural and human) can cause changes in Earth’s energy balance.
The greenhouse effect is the trapping and build -up of heat in the atmosphere near the Earth’s sur face (the troposphere). The greenhouse effect is a natural process that contributes to regulating the Earth’s temperature, and it creates a livable environment on Earth. Human activities that emit additional greenhouse gases (GHGs) to the atmosphere increa se the amount of infrared radiation that gets absorbed before escaping into space, thus enhancing the greenhouse effect and causing the Earth’s surface temperature to rise. Global climate change is a cumulative impact; a project contributes to this impact through its incremental contribution combined with the cumulative increase of all other sources of GHGs. Thus, GHG impacts are recognized exclusively as cumulative impacts (CAPCOA 2008).
A GHG is any gas that absorbs infrared radiation in the atmosphere; in other words, GHGs trap heat in the atmosphere. As defined in California Health and Safety Code Section 38505(g) for purposes of administering many of the state’s primary GHG emissions reduction programs, GHGs include carbon dioxide (CO 2), methane (CH 4), nitrous oxide (N 2O), hydrofluorocarbons, perfluorocarbons, sulfur hexafluoride, and nitrogen trifluoride (see also CEQA Guidelines Section 15364.5). 13 The three GHGs evaluated herein are CO 2, CH4, and N2O because these gases would be emitted during Project construction and/or operations.
The Intergovernmental Panel on Climate Change developed the global warming potential (GWP) concept to compare the ability of each GHG to trap heat in the atmosphere relative to another gas. The reference gas used is CO 2; therefore, GWP -weighted emissions are measured in metric tons (MT) of CO 2 equivalent (CO2e). Consistent with CalEEMod Version 2016.3.2, this GHG emissions analysis assumed the GWP for CH4 is 25 (i.e., emissions of 1 MT of CH4 are equivalent to emissions of 25 MT of CO2), and
13 Climate-forcing substances include GHGs and other substances such as black carbon and aerosols . This discussion focuses on the seven GHGs identified in the California Health and Safety Code Section 38505; impacts associated with other climate-forcing substances are not evaluated herein. 740-790 EAST GREEN STREET MIXED-USE PROJECT
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the GWP for N2O is 298, based on the Intergovernmental Panel on Climate Change Fourth Assessment Report (IPCC 2007).
The City adopted the Climate Action Plan (CAP) on March 5, 2018. The CAP is a strategic framework for measuring, planning, and reducing the City’s share of GHG emissions and goals for reducing emissions.
The CAP sets a goal to reduce community -wide GHG emissions 27% below 2009 levels by 2020, 49% below 2009 levels by 2030, 59% below 2009 levels by 2035, and 83% below 2009 levels by 2050. The CAP serves as a qualified GHG reduction plan consistent with CEQA Guidelines Section 15183.5. The CAP extends through the year of 2035, consistent with the horizon year of the City’s 2015 General Plan Land Use Element. The City uses the CAP Consistency Checklist for discretionary projects subject to CEQA. The checklist is a tool for new development projects to demonstrate consis tency with the CAP and to demonstrate a less-than-significant contribution to cumulative GHG emissions. Projects subject to CEQA review have three options to demonstrate consistency with the CAP: Option A, incorporate mandatory and selective sustainable development actions that will become conditions of the entitlement; Option B, quantify the project’s GHG emission levels and demonstrate that the project is below Pasadena’s service person efficiency threshold; and Option C, quantify the project’s GHG emission levels and demonstrate that the project would not result in a net increase in GHG emissions (City of Pasadena 2018a). The City’s CAP Option B GHG efficiency metric is used for this analysis. Under Option B, based on the Project’s first operational year 2026, the City’s GHG efficiency metric of 3.57 MT CO2e per service person would be used. According to Section 2.14, Population and Housing, the Project would add 853 (815 residents and 38 full time employees) persons to the Project site.
Construction Emissions
Construction of the proposed Project would result in GHG emissions primarily associated with the use of off-road construction equipment, on-road trucks, and worker vehicles. A depiction of expected demolition and construction schedul es (including information regarding phasing, equipment used during each phase, truck trips, and worker vehicle trips) assumed for the purposes of emissions estimation is provided in Table 2.3-2, Construction Scenario Assumptions, and in Appendix A. On -site sources of GHG emissions include off-road equipment, and off-site sources include trucks and worker vehicles. Table 2.8- 1, Estimated Annual Construction GHG Emissions, presents construction GHG emissions for the proposed Project from on-site and off-site emissions sources. The analysis assumes a construction start date of May 2023, which represents the earliest date construction would initiate. In the event construction is started later than May 2023, the analysis preformed represents the worst -case scenario for GHG emissions because equipment and vehicle emission factors for later years would be slightly less due to more stringent standards for in-use off-road equipment and heavy-duty trucks, as well as fleet turnover replacing older equipment and vehicles in later years.
The calculation methodology and default values provided in CalEEMod (CAPCOA 2017) were used to calculate potential CO 2 emissions associated with the one -time change in carbon sequestration capacity of a ve getation land use type. The calculation of the one -time loss of sequestered carbon is the product of the converted acreage value and the carbon content value for each land use type (vegetation community). CalEEMod calculates GHG emissions resulting from la nd conversion, and uses six general IPCC land use classifications for assigning default carbon content values (in units of MT CO 2 per acre). CalEEMod default carbon content values were assumed to estimate the loss of sequestered carbon (release of CO 2) from the removal of the scrub (14.3 MT CO 2 per acre), trees (111 740-790 EAST GREEN STREET MIXED-USE PROJECT
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MT CO2 per acre), and grassland (4.31 MT CO 2 per acre) vegetation categories, which are based on data and formulas pro vided in the IPCC reports. The P roject would permanently disturb a total of 0.21 acres of trees. Table 2.8-1 presents construction GHG emissions for the Project from on-site and off - site emission sources.
Table 2.8-1. Estimated Annual Construction GHG Emissions Year
CO2 CH4 N2O CO2e
Metric Tons per Year
2023 659.71 0.11 0.00 662.49
2024 887.34 0.10 889.94 895.92
2025 192.24 0.03 0.00 193.04
Total 1,739.30 0.25 889.94 1,751.45
Vegetation Removal 23.31
Total 1,774.46
Amortized Over 30 Years 59.16
Source: See Appendix A for complete results.
Notes: GHG = greenhouse gas; CO2 = carbon dioxide; CH4 = methane; N2O = nitrous oxide; CO2e = carbon dioxide equivalent.
As shown in T able 2.8-1, the estimated total GHG emissions in 2023 through 2025 would be approximately 1,751 MT CO2e. Amortized over 30 years (SCAQMD 2008), construction and carbon loss from vegetation removal GHG emissions would be approximately 59 MT CO 2e per year. In addition, as with Project-generated construction criteria air pollutant emissions, GHG emissions generated during proposed construction activities would be short term, lasting only for the duration of the construction period, and would not represent a long-term source of GHG emissions.
Because there is no separate GHG threshold for construction, the evaluation of significance is discussed in the operational emissions analysis in the following text.
Operational Emissions
Operation of the proposed Project would generate GHG emissions through motor vehicle trips to and from the P roject site; landscape maintenance equi pment operation; energy use (natural gas and generation of electricity consumed by the Project); solid waste disposal; and generation of electricity associated with water supply, treatment, and distribution and wastewater treatment. CalEEMod was used to calculate the annual GHG emissions .14 GHG emission estimates were based on the mobile source, area source, and energy (natural gas) operational assumptions described in Section 2.3(b), within the air quality analysis. CalEEMod default values were used to estimate GHG emissions associated with energy (electricity) consumption, solid waste, and water and wastewater.
CalEEMod default values were conservatively utilized for energy consumption , which assume compliance with the 2016 Title 24 Building Energy Efficiency Standards. However, since the publication of this IS/MND, the Project would be required to comply with the more stringent 2022 Title 24 Building Energy Efficiency Standards that became ef fective January 1, 202 3. However, since the Project would be required to comply with the more stringent The 2019 Title 24 Building Energy
14 The analysis in this IS/MND represents a conservative analysis since the revisions to the Project Description, as shown in Section I of this document , include a decrease of approximately 2,000 square feet of office use, which would result in an incremental decrease in operational impacts accordingly. 740-790 EAST GREEN STREET MIXED-USE PROJECT
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Efficiency Standards would result in a 30% reduction based on the California Energy Commission’s estimate that compared to the 2016 standards, “nonresidential buildings [built to 2019 standards] will use about 30% less energy due mainly to lighting upgrades” (CEC 2018). Further, the 2022 standards build on 2016 and 2019 standards by encouraging electric heat pump technology and use, establish electric-ready requirements when natural gas is installed, expending solar photovoltaic sy stem and battery storage requirements and strengthening ventilation standards to improve indoor air quality (CEC 2021). Based on the age of the existing buildings to be demolished, the historical energy use (i.e., pre-2005 standards) option was selected in CalEEMod as the existing buildings were built in compliance with less stringent building energy efficiency codes.
The calculation methodology and default values provided in CalEEMod were also used to estimate the one- time carbon-stock change from planting new trees. Trees sequester CO2 while they are actively growing and the amount of CO2 sequestered depends on the type of tree. Thereafter, the accumulation of carbon in biomass slows with age and is assumed to be offset by losses from clipping, pruning, and occasional death. Active growing periods are subject to, among other things, species, climate regime, and planting density; however, for modeling purposes, CalEEMod assumes the IPCC active growing period of 20 years (CAPCOA 2017).
CalEEMod calculates GHG sequestration that results from planting of new trees and has default carbon content values (in units of MT CO2 per tree per year) for 10 different general tree species and a miscellaneous tree category.15 As the types of tree species that would be planted within the Project site are currently unknown, the CO2 sequestration rate of 0.0354 MT CO2 per tree per year for the miscellaneous tree species category was assumed in this analysis. It is assumed that all 20 trees would grow for a minimum of 20 years.
The estimated operational (2026) Project-generated and existing (2020) GHG emissions and net change in GHG emissions from area sources, energy usage, motor vehicles, solid waste generation, and water usage and wastewater generation are shown in Table 2.8-2, Estimated Annual Operational GHG Emissions. In the event operation is started later than these projections, the analysis preformed represents the worst-case scenario for GHG emissions because equipment and vehicle emission factors for later years would be slightly less due to more stringent standards for in -use off-road equipment and heavy-duty trucks, as well as fleet turnover replacing older equipment and vehicles in later years.
Table 2.8-2. Estimated Annual Operational GHG Emissions Emission Source
CO2 CH4 N2O CO2e
metric tons per year
Proposed Project
Area 4.44 0.00 0.00 4.55
Energy 695.15 0.03 0.01 698.90
Mobile 2,505.36 0.12 0.00 2,508.33
Solid waste 20.05 1.19 0.00 49.68
Water supply and wastewater 74.58 0.52 0.01 91.33
Total 3,299.59 1.86 0.02 3,352.79
Existing
Area <0.01 0.00 0.00 <0.01
Energy 237.67 0.01 <0.01 238.92
Mobile 740.48 0.04 0.00 741.52
Solid waste 13.11 0.77 0.00 32.48
15 Species included aspen, soft maple, mixed hardwood, hardwood maple, juniper, cedar/larch, Douglas fir, true fir/hemlock, pine, spruce, and miscellaneous.
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Table 2.8-2. Estimated Annual Operational GHG Emissions Emission Source
CO2 CH4 N2O CO2e
metric tons per year
Water supply and wastewater 57.93 0.41 0.01 71.10
Total 1,049.19 1.23 0.01 1,084.02
Net Change (Proposed Project minus Existing) 2,250.40 0.62 0.01 2,268.78 Amortized Construction Emissions 59.16
Amortized Gain from Sequestered Carbon (0.47)
Total Net Operation + Amortized Construction Total 2,327.47 Notes: CO2 = carbon dioxide; CH4 = methane; N2O = nitrous oxide; CO 2e = carbon dioxide equivalent; <0.01 = value reported is less than 0.01; values in parenthesis represent negative values.
See Appendix A for detailed results.
These emissions reflect proposed Project operational year 2026 and existing operational year 2020.
As shown in Table 2.8-2, the estimated net annual operational GHG emissions would be approximately 2,327 MT CO2e, including amortized construction and loss and gain of carbon sequestration emissions.
Based on the Project’s service population of 853, the Project’s GHG efficiency metric would be 2.73 MT CO2e per service person starting in 2026, which does not exceed the City’s CAP GHG efficiency threshold of 3.57 MT CO 2e per service person. The Project has demonstrated consistency with the City’s CAP.
Therefore, operational impacts associated with directly o r indirectly generating a significant quantity of GHG emissions would be less than significant. No mitigation is required. b) Would the project generate conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases? Less Than Significant Impact. The City adopted the CAP on March 5, 2018. The CAP is a strategic framework for measuring, planning, and reducing the City’s share of GHG emissions and goals for reducing emissions. Other local policy documents include the Green City Action Plan, which was adopted in 2006, provides a list of environmental initiatives intended to guide the City towards sustainability and accelerate its environm ental commitment. Furthermore, P roject consistency with the SCA G 2016 RTP/SCS, CARB’s California’s 2017 Climate Change Scoping Plan (Scoping Plan), and statewide GHG reduction goals for 2030 or 2050 identified in Executive Order (EO) S -3-05 and SB 32, is discussed below.
Project Consistency with the City’s Climate Action Plan The City uses the CAP Consistency Checklist for discretionary Projects subject to CEQA. The checklist is a tool for new development projects to demonstrate consistency with the CAP and to demonstrate a less-than-significant contribution to cumulative GHG emissions. As discussed in Section 2.8(b), under the City’s CAP Option B, the Project’s GHG efficiency metric would be 2.73 MT CO2e per service person starting in 2026, which does not exceed the City’s CAP GHG efficiency threshold of 3.57 MT CO 2e per service person. Thus, the Project has demonstrated consistency with the City’s CAP.
Project Consistency with SCAG’s 2016 RTP/SCS and SCAG’s 2020–2045 RTP/SCS SCAG’s 2016 RTP/SCS is a regional growth-management strategy that targets per capita GHG reduction from passenger vehicles and light-duty trucks in the Southern California region pursuant to SB 375. In addition to demonstrating the region’s ability to attain and exceed the GHG emission-reduction targets set forth by 740-790 EAST GREEN STREET MIXED-USE PROJECT
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CARB, the 2016 RTP/SCS outlines a series of actions and strategies for integrating the transportation network with an overall land use pattern that responds to projected growth, housing needs, changing demographics, and transportation demands. Thus, successful implementation of the 2016 RTP/SCS would result in more complete communities with a variety of transportation and housing choices, while reducing automobile use.
With regard to individual developments, such as the Project, the strategies and policies set forth in the 2016 RTP/SCS can be grouped into the following three categories: (1) reduction of vehicle trips and VMT; (2) increased use of alternative fuel vehicles; and (3) improved energy efficiency. The proposed Project’s consistency with these three strategy categories is presented below.
1. Consistency with VMT Reduction Strategies and Policies The proposed Project’s consistency with this aspect of the 2016 RTP/SCS is demonstrated via the Project’s land use characteristics and features that would reduce vehicular trips and VMT, as well as the Project’s consistency with the regional growth forecast as sumed in the 2016 RTP/SCS for the City. Regarding VMT reduction characteristics, the Project is a mixed -use development located near transit stops. The nearest light rail stations are the Lake Metro Gold Line Station located at the Interstate 210 approximately
0.5 miles to the north, and the Del Mar Metro Gold Line Station located approximately 0.8 miles to the west near Central Park. As such, the proposed Project would provide residence and employment opportunities within proximity to transit services. The nature of the Project’s land use mix and site location would reduce VMT and associated GHG emissions by being in proximity to complimentary land uses and employment centers, which could encourage use of alternative transportation methods such as transit, walking, or biking, or would result in shorter vehicle trips.
2. Increased Use of Alternative Fueled Vehicles Policy Initiative The second goal of the 2016 RTP/SCS, with regard to individual development projects such as the proposed Project, is to increase alternative fueled vehicles to reduce per capita GHG emissions. This 2016 RTP/SCS policy initiative focuses on accelerating fleet conversion to electric or other near zero - emission technologies. The project would support this goal through the installation of four electric vehicle charging stations.
3. Energy Efficiency Strategies and Policies
The third important focus within the 2016 RTP/SCS, for individual developments such as the proposed Project, involves improving energy efficiency (e.g., reducing energy consumption) to reduce GHG emissions. The 2016 RTP/SCS goal is to actively encourage and create incentives for energy efficiency, where possible. The project would comply with the current Title 24 Standards CALGreen at the time of construction. Based on the previous analysis, the Project would be consistent with the SCAG 2016 RTP/SCS.
While striving to achieve the NAAQS for O3 and PM2.5 and the CAAQS for O3, PM10, and PM2.5 through a variety of air quality control measures, the SCAQMD 2016 AQMP also acco mmodates planned growth in the SCAB. Projects are considered consistent with, and would not conflict with or obstruct implementation of, the AQMP if the growth in socioeconomic factors (e.g., population, employment) is consistent with the underlying regional plans used to develop the AQMP (per Consistency Criterion No. 2 of the SCAQMD CEQA Air Quality Handbook). The demographic growth forecasts for various socioeconomic categories (e.g., population, housing, employment by industry) developed by SCAG for their 2016–2040 RTP/SCS, which are based on general plans for cities and counties in the SCAB, were 740-790 EAST GREEN STREET MIXED-USE PROJECT
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used to estimate future emissions in the 2016 AQMP (SCAQMD 2017). Accordingly, the 2016 AQMP is generally consistent with local government plans. The Project does not require a land use change and, including the affordable housing density bonus, would not exceed the allowed population based density, and thus would not conflict with the growth projections within the 2016 AQMP. Therefore, the P roject would be consistent with the goals of the 2016 AQMP.
On May 7, 2020, SCAG’s Regional Council adopted Connect SoCal (2020-2045 Regional Transportation Plan/Sustainable Communities Strategy) for federal transportation conformity purposes only. On September 3, 2020, the Regional Council approved of Connect SoCal in its entirety and for all other purposes. Connect SoCal is a long-range visioning plan that builds upon and expands land use and transportation strategies established over several planning cycles to increase mobility options and achieve a more sustainable growth pattern. It charts a path toward a more mobile, sustainable and prosperous region by making connections between transportation networks, between planning strategies and between the people whose collaboration can improve the quality of life for Southern Californians. Because the Project is not growth inducing, this type of consistency analysis does not apply. Nonetheless, the major goals of the Connect SoCal are outlined in Table 2.8-3, Project Consistency with the Southern California Association of Governments Connect SoCal RTP/SCS, along with the Project’s consistency with them.
Table 2.8-3. Project Consistency with the Southern California Association of Governments Connect SoCal RTP/SCS
RTP/SCS Goal Project Consistency
Goal 1. Encourage regional economic
prosperity and global competitiveness.
Not applicable. The Project would not inhibit SCAG from encouraging regional economic prosperity and global
competitiveness.
Goal 2. Improve mobility, accessibility,
reliability, and travel safety for people and
goods.
Not applicable. The Project would not inhibit SCAG from strengthening the regional transportation network for goods movement.
Goal 3. Enhance the preservation, security,
and resilience of the regional transportation
system.
Not applicable. The Project would not inhibit SCAG from enhancing the resilience of the regional transportation system.
Goal 4. Increase person and goods movement
and travel choices within the transportation
system.
Not applicable. The Project would not inhibit SCAG from increasing person and goods movement and travel choices within the transportation system.
Goal 5. Reduce greenhouse gas emissions
and improve air quality.
No conflict. The Project would result in criteria air pollutant and GHG emissions during construction and operation. The net change in GHG emissions between the Project and existing land use would not exceed the City’s CAP GHG efficiency threshold presented in Section 2.8(a). In addition, as presented in Section
2.3, the Project would not exceed the SCAQMD mass daily significance thresholds for all pollutants during construction and operation.
Goal 6. Support healthy and equitable
communities.
No conflict. The Project would include the construction of a mixed- use development located near transit stops. The Project would be designed to encourage pedestrian activity and characteristics and features that would reduce vehicular trips and vehicle miles traveled. In addition, the Project would install four electric vehicle charging stations.
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Table 2.8-3. Project Consistency with the Southern California Association of Governments Connect SoCal RTP/SCS
RTP/SCS Goal Project Consistency
Goal 7. Adapt to a changing climate and
support an integrated regional development
pattern and transportation network.
No conflict. the Project is a mixed-use development located near transit stops. The nearest light rail stations are the Lake Metro Gold Line Station located at the Interstate 210 approximately 0.5 miles to the north, and the Del Mar Metro Gold Line Station located approximately 0.8 miles to the west near Central Park. As such, the proposed Project would provide residence and
employment opportunities within proximity to transit services. In addition, in accordance with CalGreen, 25% of the total number of parking spaces on the Project site, are required to be electric vehicle charging spaces and 5% of the total number of parking spaces on a building site, are required to be electric vehicle charging stations.
Goal 8. Leverage new transportation
technologies and data-driven solutions that
result in more efficient travel.
Not applicable. The Project would not inhibit SCAG from leveraging technology for the transportation system.
Goal 9. Encourage development of diverse
housing types in areas that are supported by
multiple transportation options.
No conflict. The Project would develop multi-family housing, including affordable housing, near transit stops. In addition, the Project would not inhibit SCAG from encouraging development of diverse housing types.
Goal 10. Promote conservation of natural and
agricultural lands and restoration of habitats.
No conflict. The Project would not impact natural lands during construction or operation.
Source: SCAG 2020.
Notes: SCAG = Southern California Association of Governments; GHG = greenhouse gas; SCAQMD = Southern California Air Quality Management District; City = City of Pasadena.
As shown in Table 2.8-3, the Project would not conflict with the SCAG Connect SoCal RTP/SCS.
Project Consistency with the CARB Scoping Plan, SB 32, and EO S-3-05 The CARB Scoping Plan, approved by CARB in 2008 and updated in 2014 and 2017, provides a framework for actions to reduce California’s GHG emissions and requires CARB and other state agencies to adopt regulations and other initiatives to reduce GHGs. The Scoping Plan is not directly applicable to specific projects, nor is it intended to be used for Project-level evaluations.16 Under the Scoping Plan, however, there are several state regulatory measures aimed at the identification and reduction of GHG emissions. CARB and other state agencies have adopted many of the measures identified in the Scoping Plan. Most of these measures focus on area source emissions (e.g., energy usage, high-GWP GHGs in consumer products) and changes to the vehicle fleet (i.e., hybrid, electric, and more fuel -efficient vehicles) and associated fuels (e.g., Low Carbon Fuel Standard), among others.
The proposed Project would not impede the attainment of the GHG reduction goals for 2030 or 2050 identified in EO S-3-05 and SB 32. EO S-3-05 establishes the following goals: GHG emissions should be reduced to 2000 levels by 2010, to 1990 levels by 2020, and to 80% below 1990 levels by 2050. SB 32 establishes a statewide GHG emissions reduction target whereby CARB, in adopting rules and regulations
16 The Final Statement of Reasons for the amendments to the CEQA Guidelines reiterates the statement in the Initial Statement of Reasons that “[t]he Scoping Plan may not be appropriate for use in determining the significance of individual projects because it is conceptual at this stage and relies on the future development of regulations to implement the strategies identified in the Scoping Plan” (CNRA 2009).
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to achieve the maximum technologically feasible and cost -effective GHG emissions reduct ions, shall ensure that statewide GHG emissions are reduced to at least 40% below 1990 levels by December 31, 2030. While there are no established protocols or thresholds of significance for that future year analysis; CARB forecasts that compliance with the current Scoping Plan puts the state on a trajectory of meeting these long-term GHG goals, although the specific path to compliance is unknown (CARB 2014).
CARB has expressed optimism with regard to both the 2030 and 2050 goals. It states in the First Update to the Climate Change Scoping Plan that “California is on track to meet the near -term 2020 GHG emissions limit and is well positioned to maintain and continue reductions beyond 2020 as required by AB 32” (CARB 2014). With regard to the 2050 target for reducing GHG emissions to 80% below 1990 levels, the First Update to the Climate Change Scoping Plan states that the level of reduction is achievable in California (CARB 2014). CARB believes that the state is on a trajectory to meet the 2030 and 2050 GHG reduction targets set forth in AB 32, SB 32, and EO S -3-05. This is confirmed in the Second Update, which states (CARB 2017):
The Proposed Plan builds upon the successful framework established by the Initial Scoping Plan and First Update, while also identi fying new, technologically feasibility and cost-effective strategies to ensure that California meets its GHG reduction targets in a way that promotes and rewards innovation, continues to foster economic growth, and delivers improvements to the environment and public health, including in disadvantaged communities. The Proposed Plan is developed to be consistent with requirements set forth in AB 32, SB 32, and AB 197.
The Project would not interfere with implementation of any of the previously described GHG r eduction goals for 2030 or 2050 because the Project would not exceed the City’s CAP Option B GHG efficiency threshold of 3.57 MT CO2e per service persons starting in year 2026. Because the Project would not exceed the threshold, this analysis provides support for the conclusion that the Project would not impede the state’s trajectory toward the previously described statewide GHG reduction goals for 2030 or 2050.
As discussed previously, the Project is consistent with the GHG emission reduction measures in the Scoping Plan and would not conflict with the state’s trajectory toward future GHG reductions. In addition, since the specific path to compliance for the state in regard to the long -term goals will likely require development of technology or other changes that are not currently known or available, specific additional mitigation measures for the P roject would be speculative and cannot b e identified at this time. The Project’s consistency would assist in meeting the City’s contribution to GHG emission reduction targets in California. With respect to future GHG targets under SB 32 and EO S -03-05, CARB has also made clear its legal interpretation is that it has the requisite authority to adopt whatever regulations are necessary, beyond the AB 32 horizon year of 2020, to meet SB 32’s 40% reduction target by 2030 and EO S-03-05’s 80% reduction target by 2050; this legal interpretation by an expert agency provides evidence that future regulations w ill be adopted to continue the state on its trajectory toward meeting these future GHG targets. Based on the considerations previously outlined, the Project would not conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of GHGs, and no mitigation is required. Therefore, impacts would be less than significant. No mitigation is required.
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2.9 HAZARDS AND HAZARDOUS MATERIALS
Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Would the project:
a) Create a significant hazard to the public or the
environment through the routine transport, use, or
disposal of hazardous materials?
b) Create a significant hazard to the public or the
environment through reasonably foreseeable
upset and accident conditions involving the
release of hazardous materials into the
environment?
c) Emit hazardous emissions or handle hazardous
or acutely hazardous materials, substances, or
waste within one-quarter mile of an existing or
proposed school?
d) Be located on a site that is included on a list of
hazardous materials sites compiled pursuant to
Government Code Section 65962.5 and, as a
result, would it create a significant hazard to the
public or the environment?
e) For a project located within an airport land use
plan or, where such a plan has not been adopted,
within two miles of a public airport or public use
airport, would the project result in a safety hazard
or excessive noise for people residing or working
in the project area?
f) Impair implementation of or physically interfere
with an adopted emergency response plan or
emergency evacuation plan?
g) Expose people or structures, either directly or
indirectly, to a significant risk of loss, injury or
death involving wildland fires?
a) Would the project create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials? The Los Angeles County Fire Department Health Hazardous Materials Division is the certified unified program agency ( CUPA) for the City . The CUPA is design ated to protect public health and the environment from accidental relea ses and improper handling, storage, transportation, or disposal of hazardous materials and waste (County of Los Angeles Fire Department 2020) . The Pasadena Fire Department is responsible for ensuring that the transportation, use, and disposal of hazardous materials is conducted safely throughout the City (Pasadena Fire Department 2020). 740-790 EAST GREEN STREET MIXED-USE PROJECT
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Construction
Less Than Significant Impact. Construction of the proposed Project would involve demolition of five commercial buildings to construct a new 253,917 254,152 sf mixed-use development. Construction would require the use of heavy machinery and equipment. Potentially hazardous materials used during routine construction activities may include gasoline, diesel fuel, lubricating oil, grease, adhesive materials, solvents, paints, and other materials that potentially contain hazardous substances. The materials used would not be in such quantities or stored in such a manner as to pose a significant safety or environmental hazard. Should materials that are stored onsite exceed reporting thresholds, their use would be documented and reported in a Hazardous Material Business Plan (HMBP) and submitted to the local CUPA via the California Environmental Reporting System (CERS). Project construction workers would be trained in safe handling and hazardous materials use, as required by their company health and safety plans and/or HMBP. Activities at the Project site, including those conducted by a contractor, would comply with existing federal, state, and local regulations regarding hazardous material use, storage, disposal, and transport to prevent Project-related risks to public health and safety. All on-site generated waste that meets hazardous criteria would be stored, manifested, transported, and disposed of in accordance with federal, state, and local requirements. On -site generated contaminated waste would be stored, transported, and disposed of as required by federal, state, and local re quirements, and would be either treated or disposed of offsite at an authorized and permitted facility, as required. Any routine handling, transport, use, or disposal of hazardous materials would comply with the CUPA regulations. Impacts would be less than significant.
Operation
Less Than Significant Impact. The proposed Project includes residential, commercial office use (e.g., retail, restaurant), a parking garage, and open space. Potentially hazardous materials associated with operation of the proposed Project would include those materials typically associated with cleaning and maintenance activities. Although these materials would vary, they wou ld generally include household cleaning products, solvents, paints, fertilizers, and herbicides and pesticides. Many of these materials are considered household hazardous wastes, common wastes, and universal wastes, which are types of wastes common to businesses and households and to pose a lower risk to people and the environment than other hazardous wastes when properly handled, transported, used, and disposed of (DTSC 2020).
Federal, state, and local regulations typically allow these types of wastes to be handled and disposed of under less-stringent standards than other hazardous wastes, and many of these wastes do not need to be managed as hazardous waste.
Additionally, any potentially hazardous material handled on the Project site would be limited in qu antity and concentration, consistent with other similar residential and commercial office uses located in the City, and any handling, transport, use, and disposal of such material would comply with applicable federal, state, and local agencies and regulati ons. Additionally, as mandated by the Hazard Communication Standard (29 CFR 1910.1200(g)), chemical manufacturer, distributor, or importer are required to provide Safety Data Sheets for each hazardous chemical to describe the proper handling, transportatio n, cleanup, and protective measures. Use of these products would be in accordance with requirements and recommendations in the Safety Data Sheet and would be managed in accordance with federal, state, and local laws and regulations. Therefore, long-term impacts associated with the routine use, transport, and disposal of hazardous materials would be less than significant. 740-790 EAST GREEN STREET MIXED-USE PROJECT
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b) Would the project create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment?
Construction
Less Than Significant Impact with Mitigation Incorporated . As previously described, potentially hazardous materials used during routine construction activit ies may include gasoline, diesel fuel, lubricating oil, grease, adhesive materials, solvents, paints, and other materials that potential ly contain hazardous substances.
Should quantities of materials stored onsite be greater than reporting thresholds, the se hazardous materials would be documented and reported to the CUPA via CERS in accordance with State and local requirements, which require spill response and contingency plans to address potential releases. If quantities onsite are below reporting thresho lds, a significant release would not likely occur. Therefore, use of these hazardous materials for their intended purpose would not create a significant hazard to the public or the environment through foreseeable upset or accident condition.
A Desktop Environmental Review and Document Review and Phase I Environmental Site Assessment (ESA documents; Appendix E-1 and Appendix E-2) was performed to assess the potential presence of recognized environmental conditions (RECs) that could potentially impact the proposed Project. The ESA identified the following RECs:
• The east portion of the Project site located on APN 5734 -025-026 was formerly utilized as a gasoline service station from sometime prior to 1931 until at least 1952. Car and battery repair and greasing also took place onsite. There has been no regulatory agency documentation of tank removal or soil sampling and analysis. As the site was improved with a new commercial building in 1964, it is likely, however not confirmed as yet, that any tanks were removed during demolition and grading of the site.
• The adjacent properties to the north of the Project site have been historically used for auto repair purposes since 1932. Based on the close proximity (within 100 -feet) and long-term utilization of the property for auto repair purposes, the north adjacent property poses a potential vapor encroachment concern.
To evaluate whether the historical land uses on and surrounding the Project site have significantly impacted soil vapor conditions in the subsurface soil, a Vapor Intrusion Risk Assessment (Appendix E- 3) was performed. A total of seven soil vapor probes were a dvanced to a depth of 5 feet below ground surface throughout the northern portion of the Project site and analyzed for volatile organic compounds (VOCs). VOCs were not detected in any of the seven soil vapor samples. Based on the Vapor Intrusion Risk Assessment, a threat to human health was not identified as a result of the former gasoline and auto repair operations at the Project site and at the north adjacent property . Therefore, potential risks associated with the vapor encroachment REC are less than significant. There are still potential impacts associated with the presence of the former gasoline service station, including potential underground storage tanks and impacts to subsurface soils. Potential contaminants of concern associated with former automotive and gasoline service station activities include, but are not limited to, petroleum hydrocarbons (gasoline, diesel, heavy oil), and volatile organic compounds (VOCs). Should construction occur in an 740-790 EAST GREEN STREET MIXED-USE PROJECT
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area where a UST was/is located or contaminated soils are found, this could result in an upset or accident resulting in a release of hazardous materials. As described in the ESA documents (Appendix E-1 and E2), groundwater is at a depth of approximately 14 5 feet below ground surface, and is not expected to be encountered during construction activities.
MM-HAZ-1 Prior to commencement of any demolition or construction activities, a Hazardous Materials Contingency Plan (HMCP) shall be developed that addresses potential impacts in soil and the potential presence of USTs associated with the former gasoline service station located on the Project site. The HMCP shall include training procedures for identification of contamination and USTs, including procedures for a geophysical survey to identify USTs in the area of the former gasoline service station. The HMCP shall describe procedures for assessment, characterization, management, an d disposal of contaminated soils ; assessment, characterization, and management of soil vapor; , and notification and decommissioning procedures for tanks, in accordance with all applicable state and local regulations. The HMCP will be an internal document used by the permittee and/or its designee (e.g. environmental monitor). The HMCP will designate an environmental monitor who would determine disposal and reporting requirements for contaminated soils, and will be present on -site during grading activities in areas where potentially impacted soils may be encountered as outlined in the HMCP. Contaminated soils shall be managed and disposed of in accordance with local and state regulations (e.g. City of Pasadena Best Management Practices for soil stockpiles (City of Pasadena 2018), Draft Regional Water Board Fill Material Definitions (RWQCB 2020), DTSC Voluntary Cleanup Program and/or RWQCB Leaking Underground Storage Tank progra m, as applicable) .
Should soil vapor contamination be identified above applicable regulatory levels, as outlined in the HMCP, soil vapor intrusion methods will be outlined in the final report based on the findings on site and in accordance with February 2023 DTSC Final Draft Supplemental Guidance for Screening and Evaluating Vapor Intrusion.
Proposed engineering methods for attenuation of vapor intrusion will be prepared and submitted with building plans and approved by the permitting agency prior to issuance of construction permits. The HMCP shall include health and safety measures, which may include but are not limited to periodic work breathing zone monitoring and monitoring for volatile organic compounds using a handheld organic vapor analyzer in the event impacted soils are encountered during excavation activities. Health and safety measures will be based on California and federal Occupational Safety and Health Administration (OSHA) requirements for worker safety, including permissible exposure limits (PELs). The permittee or its designee shall implement the HMCP during construction activities for the proposed Project.
Given the age of the existing on -site buildings on the southern portion of the Project site (APNs: 5734 - 025-027 and 5734-025-029), there is potential for asbestos-containing building materials (ACM) and lead- based paint (LBP) to be encountered during demolition activities. Demolition of these structures without proper abatement of hazardous building materials could result in an upset or accident condition releasing hazardous materials to the environment. The proposed Project would be required to comply with SCAQMD Rule 1403, Asbestos Emissions from Demolition/Renovation Activities, which addresses asbestos emissions from demolition and renovation activities and requires the safe handling of known or suspected ACM (SCAQMD 1989). The purpose of SCAQMD Rule 1403 is to specify work practice 740-790 EAST GREEN STREET MIXED-USE PROJECT
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requirements to limit asbestos emissions from building demolition and renovation activities, including the removal and associated disturbance of ACM. The requirements for de molition and renovation activities include asbestos surveying; notification; ACM removal procedures and time schedules; ACM -handling and clean-up procedures; and storage, disposal, and landfilling requirements for asbestos -containing waste materials. All operators are required to maintain records, including waste shipment records, and to use appropriate warning labels, signs, and markings (SCAQMD 1989). The California Department of Public Health enforces lead laws and regulations related to the prevention of lead poisoning, accreditation and training for construction-related activities, lead exposure and screening, disclosures, and limitations on the amount of lead in products. Accredited specialists are required to find and abate lead hazards in a construction project and to perform lead -related construction work in an effective and safe manner.
Additionally, construction debris may require screening for hazardous levels of leachable lead.
Nonetheless, demolition and disposal of these materials without proper abatement could cause an upset or accident condition. Proper identification, delineation, and abatement of potentially hazardous materials would prevent potential exposure of hazardous materials to the public or the environment during transportation and disposal of potentially contaminated media. Impacts related to ACM and LBP are potentially significant. With implementation of MM -HAZ-1 and MM -HAZ-2, construction impacts associated with potential upset and accident conditions would be less than significant.
MM-HAZ-2 Prior to commencement of demolition or construction activities on the southern portion of the Project site (APNs: 5734-025-027 and 5734-025-029), a hazardous building materials survey shall be conducted to identify asbestos, lead -based paint, and other potentially hazardous building materials (such as mercury thermometers, lighting and electrical appurtenances). The survey shall be conducted on the two buildings in the southern portion of the Project site scheduled to be disturbed/demolished. Following results of the hazardous materials survey, demolition or renovation plans and contract specifications shall incorporate abatement procedures for the removal of materials containing asbestos and lead. All abatement work shall be done in accordance with federal, state, and local regulations, including those of the U.S. Environmental Protection Agency, Occupational Safety and Health Administration, California Occupational Safety and Health Administration, and the South Coast Air Quality Management District.
Operation
Once operational, onsite hazardous materials would generally include household cleaning products, solvents, paints, fertilizers, and herbicides and pesticides. As discussed in impact analysis (a), these common household hazardous materials would be stored in small quantities and used in accordance with federal, state, and local regulations, as well as in accordance with manufacturer’s instructions. Therefore, impacts would be less than significant.
c) Would the project emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school? Less Than Significant Impact with Mitigation Incorporated. Futures Academy – Pasadena, is located approximately 0.17-mile north of the Project site at 35 N Lake Avenue. Hazardous materials required for construction and operation would be transported, handled, stored, and disposed of in accordanc e with federal, state, and local laws and regulations, as described in the previous analysis sections. Hazardous 740-790 EAST GREEN STREET MIXED-USE PROJECT
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materials used during construction of the proposed Project would be stored within proposed Project boundaries. Hazardous materials associated with potentially contaminated soils and/or USTs would be managed by a HMCP as described in MM-HAZ-1. Hazardous materials associated with potential ACM, LBP, and/or other hazardous building materials would be identified and abated as described in MM-HAZ-
2. Therefore, impacts related to emissions or handling of hazardous materials near schools would be less than significant with mitigation incorporated.
Land uses and activities typically associated with hazardous emissions or handling of hazardous or acutely hazardous materials, substances, or waste include heavy commercial, manufacturing, research, and industrial uses. The proposed Project does not include any such uses or activities. Once operational, onsite hazardous materials would generally include household cleaning products, solvents, paints, fertilizers, and herbicides and pesticides. As discussed in impact analysis (a), these common household hazardous materials would be stored in small quantities and used in accordance with federal, state, and local regulations, as well as in accordance with manufacturer’s instructions. d) Would the project be located on a site that is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment?
Less Than Significant Impact with Mitigation Incorporated. The Hazardous Waste and Substances Sites (Cortese) List is a planning document used by the state, local agencies, and developers to comply with the CEQA requirements of providing information about the locations of hazardous materials release sites. Califor nia Government Code Section 65962.5 requires the California EPA to develop, at least annually, an updated Cortese List. However, the Cortese List is no longer updated as a single list; the information is contained in multiple regulatory databases. DTSC and the State Water Resources Control Board maintain multiple lists that meet the requirements of California Government Code Section 65962.5.
As part of the Phase I ESA conducted for the Project site (Appendix E-1 and E-2), a regulatory agency record review (EDR database search) was conducted for the Project site and surrounding properties.
The EDR database search listed the Project site and surrounding properties in various databases indicating the use and storage of hazardous materials and/or petroleum prod ucts, and generation of hazardous waste. This database search includes Cortese List databases. While the Project site and adjoining sites were not identified on Cortese List databases, they were listed in other databases that identify hazardous material usage and/or potential hazardous material contamination. The Project site is listed as the Penn Oil & Supply Co. / Kirks Texaco Service (790 East Green Street) on the EDR Historical Auto Station (EDR US Hist Auto Stat) database. According to the listing, gas stations Penn Oil & Supply Co. and Kirks Texaco Service operated on the property during at least 1932 through 1942 and in 1951, respectively. In addition, several adjoining and immediately surrounding properties were identified as former auto service shops and one former dry cleaner (see Appendix E-2).
As discussed in previous impact sections, a Vapor Intrusion Risk Assessment (Appendix E-3) was conducted on the northern portion of the Project site in the area surrounding the former gasoline service station and adjacent potentially contaminated sites. The results of the Risk Assessment confirmed there were no detected VOCs in soil vapor at 5 feet below ground surface and, as such, no potential risk from contaminated soil vapors. However, as also discussed above, there is a potential for contaminated soils and USTs to be present on the Project site due to the presence of the former gasoline service station.
Implementation of a HMCP would be required in accordance with MM -HAZ-1; therefore, any 740-790 EAST GREEN STREET MIXED-USE PROJECT
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contaminated soils and/or USTs onsite would be identified and properly managed in accordance with federal, state, and local laws and regulations. Thus, i mpacts associated with hazardous material sites would be less than significant with mitigation incorporated. e) For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard or excessive noise for people residing or working in the project area? No Impact. The San Gabriel Airport, which is located approximately 6.8-miles southeast of the Project site in El Monte , is the closest public use airport . The Project site is more than 2 miles from the San Gabriel Airport and is not within an airport land use plan. As such, the proposed Project would not involve placing people or structures in proximity to air craft operations. Therefore, no impacts associated with public airport hazards would occur.
f) Would the project impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan?
Less Than Significant I mpact. According to the General Plan EIR, the City has incorporated two emergency preparedness plans, namely, the Los Angeles County Operational Area Emergency Response Plan and the City’s Emergency Operations Plan (EOP; City of Pasadena 2015a). Both plans provide the framework for emergency preparedness and response , although the EOP specifically provides a plan for the residents of Pasadena to respond to major emergencies or disasters. Additionally, the Pasadena Fire Department provides emergency response services, including hazardous materials emergency response (City of Pasadena 2015a).
According to the LADPW, Colorado Boulevard, which runs in an east -west direction approximately 500 feet south of the Project site, is an emergency disaster route and the I-210, which runs in an east -west direction approximately 0.5 mile north of the Project site, is a freeway disaster route (County of Los Angeles Department of Public Works 2008).
In the event of a major disaster or emergency, the Los Angeles County Operat ional Area Emergency Response Plan and the City’s EOP would improve the efficiency of the City’s disaster response. The proposed Project would not include the construction of any buildings or infrastructure that would preclude the City’s or County’s ability to implement an adopted emergency response plan or emergency evacuation plan. During construction of the proposed Project, it is anticipated that some of the construction activities may require short-term partial or full road closures of travel lanes along Oak Knoll Avenue or Hudson Avenue. As further deta iled in Section 2.17, Transportation, the Project applicant would submit a Construction Staging and Traffic Management Plan (CSTMP) to the Pasadena Department of Public Works (DPW) that shall show the impact of various construction stages on the public rig ht-of-way (Appendix H-1). The CSTMP would require coordination with agencies and City departments to obtain necessary occupancy permits in the event of road closures to identify any detour or alternate routes. With implementation of the CSTMP , impacts to e mergency access during construction of the Project would be less than significant . Upon operation of the proposed Project, emergency access would be provided via Green Street, Oak Knoll Avenue, and Hudson Avenue . As such, the proposed Project would not sub stantially impair an adopted emergency response plan or emergency evacuation plan and impacts would be less than significant. No mitigation is required. 740-790 EAST GREEN STREET MIXED-USE PROJECT
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g) Would the project expose people or structures, either directly or indirectly, to a significant risk of loss, injury, or death involving wildland fires? No Impact. The Project site is located within an urban setting and is surrounded by developed land uses, which are predominantly commercial and residential in nature. According to the CALFIRE Very High Fire Hazard Severity Zone (VHFHSZ) Map, the Project site is not located within a VHFHSZ (CAL FIRE 2011).
The nearest fire hazard areas are the undeveloped, wildland areas of the Arroyo Seco , approximately
1.8 miles west of the Project site. Therefore, no impacts associated with wildland fires would occur.
2.10 HYDROLOGY AND WATER QUALITY
Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Would the project:
a) Violate any water quality standards or waste
discharge requirements or otherwise substantially
degrade surface or ground water quality?
b) Substantially decrease groundwater supplies or
interfere substantially with groundwater recharge
such that the project may impede sustainable
groundwater management of the basin?
c) Substantially alter the existing drainage pattern of the site or area, including through the alteration of
the course of a stream or river or through the
addition of impervious surfaces, in a manner which
would:
i) result in substantial erosion or siltation on or
off site;
ii) substantially increase the rate or amount of
surface runoff in a manner which would result
in flooding on or off site;
iii) create or contribute runoff water which would
exceed the capacity of existing or planned
stormwater drainage systems or provide
substantial additional sources of polluted
runoff; or
iv) impede or redirect flood flows?
d) In flood hazard, tsunami, or seiche zones, risk
release of pollutants due to project inundation?
e) Conflict with or obstruct implementation of a water
quality control plan or sustainable groundwater
management plan?
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a) Would the project violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality? Less Than Significant Impact. A significant impact would occur if the proposed Project would discharge water that did not meet the water quality standards established by the State Water Resources Control Board (SWRCB) NPDES and waste discharge requirement (WDR) permit programs, and the Los Angeles Regional Water Quality Control Board’s ( LARWQCB) Los Angeles Region Basin Plan for the Coastal Watersheds of Los Angeles and Ventura Counties (Basin Plan; LARWQCB 2019). The proposed Project is not anticipated to violate any water quality standard or waste discharge requirement during construction and operation, for the reasons described below.
Construction
Construction General Permit. Th e demolition of the existing buildings on -site would disturb the entire Project site. As described in Secti on 2.7, Geology and Soils, gr ading and excavation activities would result in soil disturbance, which could potentially increase sediment loads in stormwater runoff by eroding soils newly loosened by construction activities. Additionally, as described in Se ction 2.9, Hazards and Hazardous Materials, the proposed Project could adversely affect water quality through the accidental spills and leaks of construction-related pollutants such as petroleum products from construction vehicles.
However, the proposed Project would comply with the provisions of the NPDES General Permit for Storm Water Associated with Construction Activities (Order No 2009-009-DWQ as amended by 2010-0014-DWQ and 2012- 0006-DWQ, NPDES No. CAS000002). Because the proposed Project is greater than one acre in size, the Applicant would be required to submit a Notice of Intent to the LARWQCB in order to obtain approval to complete construction activities under the Construction General Permit. This permit would include a number of design, management, and monitoring requirements for the protection of water quality and the reduction of construction phase impacts related to stormwater (and some non-stormwater) discharges. Permit requirements would include the preparation of a SWPPP, implementation and monitoring of BMPs, implementation of best available technology for toxic and non-conventional pollutants, implementation of best conventional technology for conventional pollutants, and periodic submittal of performance summaries and reports to the LARWQCB. The SWPPP would apply to the Project as a whole and would include reference to the major construction areas, materials staging areas, and haul roads.
Typical BMPs that could be incorporated into the SWPPP include, but are not limited to, the following:
• Diverting off-site runoff away from the construction site • Vegetating landscaped/vegetated swale areas as soon as feasible following grading activities • Placing perimeter straw wattles to prevent off-site transport of sediment • Using drop inlet protection (filters and sand bags or straw wattles), with sandbag check dams within paved areas
• Regular watering of exposed soils to control dust during demolition and construction • Implementing specifications for demolition/construction waste handling and disposal • Using contained equipment wash-out and vehicle maintenance areas • Maintaining erosion and sedimentation control measures throughout the construction period 740-790 EAST GREEN STREET MIXED-USE PROJECT
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• Stabilizing construction entrances to avoid trucks from imprinting soil and debris onto City roadways • Training, including for subcontractors, on general site housekeeping Additionally, the proposed Project would comply with the City’s Municipal Code, Section 8.70.010 et seq., which legislates stormwater management and discharge control during construction -related activities.
Additionally, the proposed Project would be required to comply with the latest County of Los Angeles Department of Public Works L ow Impact Development (LID) Standards Manual. The LID Standards Manual complies with the requirements of the NPDES Municipal Separate Storm Sewer System (MS4) Permit for stormwater and non-stormwater discharges from the MS4 within the coastal watersheds of Los Angeles County (CAS004001, Order No. R4-2012-0175), referred to as the 2012 MS4 Permit. The LID Standards Manual provides guidance for the implementation of stormwater quality control measures in new development and redevelopment projects with the intention of improving water quality and mitigating potential water quality impacts from stormwater and non -stormwater discharges (LADPW 2014). Given the above, the proposed Project would have a less than significant impact on water quality standards and waste discharge requirements and would not otherwise substantially degrade surface or ground water quality during construction, and no mitigation is required.
Operations
Operation of the proposed Project would have a less than significant impact to water quality through implementation of the following:
• Stormwater Management and Discharge Control. The purpose of the City’s Municipal Code, Section 8.70.010 et seq. is to ensure the future health, safety, and general welfare of the residents of the City of Pasadena who recreate in and consume from the waters of the United States, and to protect marine habitats and ecosystems existing therein by: a) Regulating non-stormwater discharges to the municipal stormwater system; b) Providing for the control of spillage, dumping or disposal of materials into the municipal storm-water system; and, c) Reducing pollutants in stormwater and urban runoff to the maximum extent practicable. The proposed Project would adhere to the City’s stormwater management and discharge control regulations and, as such, is not anticipated to violate any water quality standard or waste discharge requirement during operation. • LID Features. In the City of Pasadena, all development and redevelopment projects must comply with the latest County of L os Angeles Department of Public Works LID Standards Manual. The LID Standards Manual complies with the requirements of the NPDES MS4 Permit for stormwater and non -stormwater discharges from the MS4 within the coastal watersheds of Los Angeles County (CAS004001, Order No. R4 -2012-0175), referred to as the 2012 MS4 Permit. The LID Standards Manual provides guidance for the implementation of stormwater quality control measures in new development and redevelopment projects with the intention of improving water quality and mitigating potential water quality impacts from stormwater and non -stormwater discharges (City of Pasadena 2019).
Project design, construction, and operation would be completed in accordance with the LID Standards Manual, with the goal of redu cing the amount of pollutants in stormwater and urban runoff. The Project would be required to comply with the LID ordinance and LID Standards Manual, which mandates completion of a LID Plan. This plan would include permanent control measures to reduce the long-term impacts of the Project on water quality and the tributary waterways. The LID Plan would use site design 740-790 EAST GREEN STREET MIXED-USE PROJECT
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and stormwater management in order to maintain the site’s pre -development runoff rates and volumes.
The goal of the LID Plan would be to mimi c the site’s pre -development hydrology by using design techniques that filter, store, evaporate, and detain runoff close to the source of rainfall. Some examples of these LID measures that would be incorporated into the Project include, but are not limited to:
• Minimizing impervious surfaces that are directly connected to the storm drain system, by routing runoff to landscaped areas;
• Using landscaping as a drainage feature;
• Using roofed trash enclosures;
• Connecting areas used for washing equipment to the sanitary sewer; • Marking storm drain inlets with a “No Dumping” message; • Street and parking lot sweeping;
• Regular inspection and cleaning of storm drain inlets; and • Engineering source control treatment measures.
Per the LID Manual, the Project must retain the stormwater quality design volume (SWQDv) on -site through infiltration, evapotranspiration, stormwater runoff harvest and reuse, or a combination thereof, unless it is demonstrated that it is technically infeasible to do so. The SWQDv is defined as the greater of the 0.75-inch, 24-hour rain event, or the 85th percentile, 24 -hour rain event, as determined from the Los Angeles County 85th percentile precipitation isohyetal map.
Compliance with SWPPP and LID features would ensure that the Project wo uld not violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality. As such, Project impacts would be less than significant, and no mitigation is required. b) Would the project substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin?
Less Than Significant Impact. According to the City’s 2015 Urban Water Management Plan (UWMP), local water supplies include local water from the Raymond Basin ( approximately 40%) and purchased imported water (approximately 60%) from the Metropolitan Water District (MWD) of Southern California, which sources water from the Sta te Water Project (SWP) and the Colorado River Aqueduct (UWMP 2015). The UWMP projects adequate water supply from the Raymond Basin in normal, single dry year, and multiple dry year conditions through the planning horizon of 2040 (UWMP 2015).
The proposed Project would not include the introduction of any infrastructure, including wells, which would decrease groundwater supplies. Rather, the proposed Project would tie -in to the existing water utility and, as such, would receive water supply from PWP, some of which would be sourced from groundwater supplies. Withdraw from the Raymond Basin is controlled by the Raymond Basin Management Board and, thus, the volume of water PWP withdraws from the Basin is not dependent on the City’s water demand. With regard to groundwater recharge, the proposed Project site is entirely developed and paved under existing conditions, which precludes water infiltration and any associated groundwater recharge at the Project site. Upon Project operation, the Project site would be predominantly 740-790 EAST GREEN STREET MIXED-USE PROJECT
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paved, with the exception of a 4,110 4,033-sf pocket park and other small open space areas . As such, the Project site would remain largely impermeable upon Project operation, and the existing on -site drainage patterns and groundwater recharge trends would prevail. Therefore, the proposed Project would not substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the Project may impede sustainable groundwater management of the basin when compared to existing conditions. Impacts would be less than significant. No mitigation is required. c) Would the project substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would:
i) result in substantial erosion or siltation on or off site; Less Than Significant Impact. As stated above in Section 2.10(b), the proposed Project site would remain largely impermeable upon Project operation, and the existing on -site drainage patterns would prevail. Therefore, the proposed Project would not substantially alter drainage patter ns through the addition of impervious surfaces. Additionally, the Project site is not located within the general vicinity of a stream or river and, as such, would not alter the course of a stream or river. However, during construction-related activities, soils exposed during grading and excavation would have increased potential for erosion as a result of exposure to the elements (e.g. water runoff).
Given that the proposed Project would disturb more than one acre of soil, the Project would be required to obtain coverage under the NPDES General Permit for Storm Water Discharges Associated with the Construction and Land Disturbance Activities (Order No 2009 -009-DWQ as amended by 2010 -0014- DWQ and 2012 -0006-DWQ, NPDES No. CAS000002) or the latest approved general p ermit. The General permit would include e rosion-control measures as part of the SWPPP for the Project. The required SWPPP would mandate the implementation of BMPs to reduce or eliminate construction-related pollutants in the runoff, including sediment that could result in siltation . Implementation of the erosion control BMPs in the SWPPP would reduce construction-related soil erosion and siltation associated with Project implementation. Impacts would be less than significant, and no mitigation is required. ii) substantially increase the rate or amount of surface runoff in a manner which would result in flooding on or off site;
Less Than Significant Impact. As stated above in Section 2.10(b), the proposed Project site would remain largely impermeable upon Pro ject operation, and the existing on -site drainage patterns would prevail. The Project site is not located within the general vicinity of a stream or river, and, as such, would not alter the course of a stream or river. Additionally, as stated above in Sect ion 2.10(a), the proposed Project would implement LID features intended to mimic the site’s pre -development hydrology by using design techniques that filter, store, evaporate, and detain runoff close to the source of rainfall. LID features should, as much as feasibl y possible, minimize impervio us surfaces, use landscape as a drainage feature, and improve drainage facilities to decrease the potential of flooding on and off site. With these features implemented, the development of the proposed Project would not result in a substantial increase in the rate or amount of surface runoff in a manner that would result in flooding. Impacts would be less than significant. No mitigation is required.
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iii) create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff; or
Less Than Significant Impact. As stated above in Section 2.10(b), the proposed Project site would remain largely impermeable upon Project operation, and the existing on -site drainage patterns would prevail. The Project site is not located within the general vicinity of a stream or river, and as such, would not alter the course of a stream or river.
As previously discussed, during construction, erosion -control measures would be im plemented as part of the SWPPP for the Project, consistent with the requirements of the NPDES General Permit for Storm Water Discharges Associated with the Construction and Land Disturbance Activities ( Order No 2009 - 009-DWQ as amended by 2010-0014-DWQ and 2012-0006-DWQ, NPDES No. CAS000002) or the latest approved general permit. The site -specific SWPPP would ensure that runoff during construction would not exceed the capacity of existing or planned storm water infrastructure. In addition, the development of LID features would minimize post -construction sources of polluted runoff by mimicking the site’s pre - development hydrology and filtering, storing, evaporating, and detaining water. With these features, the proposed 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.
Project impacts would be less than significant, and no mitigation is required. iv) impede or redirect flood flows?
No Impact. As stated above in Section 2.10(b), the proposed Project site would remain largely impermeable upon Project operation, and the existing on -site drainage patterns would prevail. The Project site is not located within the general vicinity of a stream or river, and, as such, would not alter the course of a stream or river. There are no drainages, creeks, or streams on the Project site and no flows would be diverted, impeded, or redi rected due to the proposed Project. According to the Federal Emergency Management Agency (FEMA), the Project is located within Zone X, which is an area of Minimal Flood Hazard (FEMA 2008). Therefore, the Project site is not located within an area that woul d be subject to flooding or flood flows. No impact would occur. d) In flood hazard, tsunami, or seiche zones, would the project risk release of pollutants due to project inundation?
No Impact. The Project site is not located within an area at risk from floods, tsunamis, or seiches (CGS 2015). According to FEMA, the Project is located within Zone X, which is an area of Minimal Flood Hazard (FEMA 2008). Therefore, the Project site is not located within an area that would be subject to flooding.
The nearest inundation zone to the Project site is associated with the Arroyo Seco Watershed, approximately 1. 8 miles west of the Project site. The prevailing distance between the Arroyo Seco channel and the Project site precludes the risk of Project inundation. Given the above, the risk of release of pollutants due to Project inundation as a result of dam failure, flood hazard, tsunami, or seiche is low.
No impact would occur.
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e) Would the project conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan?
Less Than Significant Impact. The Basin Plan for the Coastal Watersheds of Los Angeles and Ventura Counties is the Water Quality Control Plan (WQMP) for the Los Angeles Region, which includes the City of Pasadena. The Basin Plan: (i) identifies beneficial uses for surface and ground waters, (ii) includes the narrative and numerical water quality objectives that must be attained or maintained to protect the designated beneficial uses and conform to the State's anti -degradation policy, and (iii) describes implementation programs and other actions that are necessary to achieve the water quality objectives established in the Basin Plan (LARWQCB 2019).
With compliance with applicable regulations, the proposed Project would not include any facilities or land uses that could generate pollutants that could result in substantial water quality impacts. As discussed in Threshold 2.10(a), compliance the City’s requirements would protect surface water quality in a manner pursuant to the NPDES Construction General Permit . Additionally, compliance with the General Permit issued by the SWRCB would require implementation of BMPs during construction to address the potential for pollutants from entering downstream waters. The Project’s potential to violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality would be less than significant and no mitigation is required.
California Department of Water Resources (DWR) is required to prioritize and update California’s groundwater basin prioritization in accordance with the requirements of Sustainable Groundwater Management Act (SGMA) and related laws. SGMA requires that groundwater resources be managed sustainably for long-term reliability and multiple benefits for current and future beneficial uses and also allows the SWRCB to intervene if local agencies will not or do not meet the SGMA requirements. SGMA applies to all California groundwater basins and requires the DWR to prioritize California’s 517 groundwater basins and subbasins as either high, medium, low, or very low (DWR 2019). The Raymond Basin, which underlies the City of Pasadena, was determined by DWR to be “Very Low” priority and is a fully adjudicated basin; therefore, the Raymond Basin is not subject to the requirements to form a GSA or to develop a Groundwater Sustainability Plan (DWR 2019).
As previously discussed, the SWPPP and LID features would reduce the Project’s impact on water quality in accordance with all applicable federal, state, and local requirements. Additionally, the Project would be consistent with the assumptions set forth in the City’s UWMP discussed in section 2.10(b). As a result, the Project would not conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan. Therefore, the Project’s impact would be less than significant , and no mitigation is required.
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2.11 LAND USE AND PLANNING
Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Would the project:
a) Physically divide an established community?
b) Cause a significant environmental impact due to
a conflict with any land use plan, policy, or
regulation adopted for the purpose of avoiding or
mitigating an environmental effect?
a) Would the project physically divide an established community? Less Than Significant Impact. The proposed Project would be located on a site that is fully developed with commercial land uses under existing conditions. Adjacent land uses include single- and multi-family residential and commercial to the west across Oak Knoll Avenue; commercial and parking to the north across Green Street; multi-family residential and parking to the east across Hudson Avenue; and offices and a church immediately to the south, with multi-family and office uses beyond.
The proposed Project would include the construction of a mixed-use development, comprising 236 rental apartment units, approximately 16,481 14,346 sf of commercial office development (e.g. retail, restaurant), and 37,666 39,980 sf of open space and amenities, including a 4,110 4,033 sf publicly accessible pocket park. As such, the proposed Project would be consistent with the land use patterns in the surrounding area.
Moreover, the proposed Project would be developed on a single site and would not include the construction of any infrastructure or features that would encroach into adjacent ROWs, thereby physically dividing an established neighborhood. The site currently consists of commercial land uses, and the proposed Project would construct new residential and commercial office uses. Thus, the proposed Project would not physically divide an existing community, but rather, would facilitate the development of community within the area. Further, the proposed Project does not involve the displacement of existing residences or the construction of barriers through the developed residential areas of the City. Therefore, the proposed Project would not physically divide an established community. Impacts would be less than significant. No mitigation is required.
b) Would the Project cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adop ted for the purpose of avoiding or mit igating an environmental effect?
Less Than Significant Impact. Land use plans and policies applicable to the proposed Project are set forth in the City’s General Plan and Zoning Ordinance. The City’s General Plan provi des the planning framework through which development in the City is organized and carried out. The Project site is located within the CD-4 (Central District, Pasadena Playhouse) zoning district.
The proposed Project would establish a Planned Development (PD) zoning district (via a Zone Change) for the site and requires adoption of a PD Plan that prescribes the development standards and allowed or conditionally allowed uses in the PD. The Project proposes to use the State Density Bonus regulations 740-790 EAST GREEN STREET MIXED-USE PROJECT
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legislated by the California Government Code Section 65915 as well as the City’s Affordable Housing Concession Menu to develop 2 63 units, which would be allowed after applying a 3 0% density bonus based on the inclusion of 41 affordable housing units on-site. Because the proposed Project would include 20% on -site affordable housing units, the Project would comply with the City’s Inclusionary Housing Ordinance, which would allow the Project to utilize the City’s concessions of a FAR increase of
0.5 and a height increase of 12 feet for no more than 60% of the building footprint. The project would also require Design Review approval.
No General Plan Amendment is being sought by the proposed Project. With approval of the zone change from CD-4 to PD 37 and approval of the Project, including Design review, the proposed Project would be compatible with the City’s zoning designations and would have a less than significant impact on any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect.
No mitigation is required.
2.12 MINERAL RESOURCES
Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Would the project:
a) Result in the loss of availability of a known
mineral resource that would be of value to the
region and the residents of the state?
b) Result in the loss of availability of a locally-
important mineral resource recovery site
delineated on a local general plan, specific plan,
or other land use plan?
a) Would the project result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the state? No Impact. According to the Department of Conservation’s State Mining and Geology Board , the proposed Project site is located in Mineral Resource Zone 3 (MRZ -3) for aggregate resources such as sand, gravel etc .; MRZ-3 is defined as an area containing mineral deposits , the significance of which cannot be evaluated from available data (DOC 1982). There are not active mining operations in the City and mining is not an allowed use in any of the City’s zones . As such, the proposed Project would not result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the state.
The DOC’s Division of Oil, Gas, and Geothermal Resources (DOGGR) does not list any wells on , or in the general vicinity of, the Project site (DOGGR 2019). The nearest well is located 3.98 miles south of the Project site and has been plugged (non-operable) since 1964 (DOGGR 2005). As such, the proposed Project would not result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the state. No impacts would occur. No mitigation is required. 740-790 EAST GREEN STREET MIXED-USE PROJECT
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b) Would the project result in the loss of availability of a locally important mineral resource recovery site delineated on a local general plan, specific plan, or other land use plan? No Impact. The General Plan EIR found that the projected buildout of the City would have no impact to mineral resources as well as oil, gas, and geothermal resources (City of Pasadena 2015a). There are no locally important mineral resource recovery site s in Pasadena that are identified in the City’s General Plan, Specific Plans, or other land use plans. No impact would occur. No mitigation is required.
2.13 NOISE
Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Would the project result in:
a) Generation of a substantial temporary or
permanent increase in ambient noise levels in the
vicinity of the project in excess of standards
established in the local general plan or noise
ordinance, or applicable standards of other
agencies?
b) Generation of excessive groundborne vibration or
groundborne noise levels?
c) For a project located within the vicinity of a
private airstrip or an airport land use plan or,
where such a plan has not been adopted,
within two miles of a public airport or public
use airport, would the project expose people
residing or working in the project area to
excessive noise levels?
Noise Characteristics
Sound may be described in terms of level or amplitude (measured in decibels (dB)), frequency or pitch (measured in hertz (Hz) or cycles per second), and duration (measured in seconds or minutes). The standard unit of measurement of the amplitude of sound is the decibel. Because the human ear is not equally sensitive to sound at all frequencies, a special frequency-dependent rating scale is used to relate noise to human sensitivity. The A -weighted decibel scale (dBA) performs this compensation by discriminating against low and very high frequencies in a manner approximating the sensitivity of the human ear. Several descriptors of noise (noise metrics) exist to help predict average community reactions to the adverse effects of environmental noise, including traffic-generated noise, on a community. These descriptors include the equivalent noise level over a given period (Leq), the statistical sound level (Ln), the day–night average noise level (L dn), and the community noise equivalent level (CNEL). Each of these descriptors uses units of dBA. In terms of changes in environmental or community noise levels, a 3 dBA increase or decrease is generally recognized as the threshold for an average person to notice a change has occurred.
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Leq is a sound energy level averaged over a specified time period (typically no less than 15 minutes for environmental studies). Leq is a single numerical value that represents the amount of variable sound energy received by a receptor during a time interval. For example, a 1-hour Leq measurement would represent the average amount of energy contained in all the noise that occurred i n that hour. L eq is an effective noise descriptor because of its ability to assess the total time-varying effects of noise on sensitive receptors. Lmax is the greatest sound level measured during a designated time interval or event.
Unlike the Leq metrics, Ldn and CNEL metrics always represent 24-hour periods, usually on an annualized basis. L dn and CNEL also differ from L eq because they apply a time -weighted factor designed to emphasize noise events that occur during the evening and nighttime hours (when speech and sleep disturbance is of more concern). “Time weighted” refers to the fact that Ldn and CNEL penalize noise that occurs during certain sensitive periods. In the case of CNEL, noise occurring during the daytime (7:00 a.m.–7:00 p.m.) receives no pe nalty. Noise during the evening (7:00 p.m. –10:00 p.m.) is penalized by adding 5 dB, while nighttime (10:00 p.m.–7:00 a.m.) noise is penalized by adding 10 dB. Ldn differs from CNEL in that the daytime period is defined as 7:00 a.m.–10:00 p.m., thus eliminating the evening period.
Ldn and CNEL are the predominant criteria used to measure roadway noise affecting residential receptors.
These two metrics generally differ from one another by no more than 0.5 to 1 dB.
Existing Noise Conditions
The Project site is located at 740 -790 East Green Street. The Project site is bounded by East Green Street to the north, South Hudson Avenue to the east, private property to the south, and South Oak Knoll Avenue to the west. Single- and multi-family residential uses are located to the west of the Project site, across South Oak Knoll Avenue. Multi -family residential uses are located to the east across Hudson Avenue. A church is located immediately to the south, and multi-family residential uses are located to the south of an office building.
A sound-level survey was conducted on September 17, 2019, to evaluate existing sound levels and assess potential Project noise impacts on the surrounding area. Short -term (1 hour or less) attended sound-level measurements were taken with a SoftdB Piccolo sound -level meter. This instrument is categorized as type 2, general use. The sound-measuring instrument used for the survey was set to the “slow” time response and the A -weighting scale for all noise measurements. To ensure accuracy, the calibration of the instrument was field checked before the measurements using a portable acoustical calibrator. The microphone height was 5 feet above the ground on a tripod, and the microphone was equipped with a windscreen.
Short-term sound levels were m easured at four locations in the Project vicinity (Refer to Appendix F , Noise Assessment Technical Report, for further detail ). During the field measurements, physical observations of the predominant noise sources were noted. The major noise source in the Project area was vehicle traffic. Other secondary noise sounds included distant conversations, birds, distant construction noise, and other community noises. Appendix A includes field data sheets from the measurements conducted in the site vicinity. Table 2.13-1 provides the measured noise levels and concurrent traffic volumes for the pertinent roadway facilities. As shown in Table 2.13-1, measured noise levels varied from 65 dBA Leq at ST2 to 71 dBA Leq at ST4. 740-790 EAST GREEN STREET MIXED-USE PROJECT
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Table 2.13-1. Measured Average Traffic Sound Level and Manual Traffic Count Results Site
Primary Noise
Source Date Time Leq Cars MT2 HT3
ST1; 101 South Oak
Knoll Avenue
Traffic on South Oak
Knoll Avenue
9/17/19 9:49 to 10:04
a.m.
66 dBA 52 1 0
ST2; 128 South Oak
Knoll Avenue
Traffic on South Oak
Knoll Avenue
10:07 to
10:22 a.m.
65 dBA 44 1 0
ST3; 139-141 South
Hudson Avenue
Traffic on South
Hudson Avenue
10:32 to
10:47 a.m.
67 dBA 62 1 0
ST4; 820 East
Green Street
Traffic on South
Hudson Avenue
10:51 to
11:06 a.m.
71 dBA 61 1 0
Source: Appendix F
Notes:
1 Equivalent Continuous Sound Level (Time-Average Sound Level) 2 Medium Trucks
3 Heavy Trucks
Sensitive Receptors
Noise- and vibration-sensitive land uses are locations where people reside or where the presence of unwanted sound could adversely affect the use of the land. Residences, schools, hospitals, guest lodging, libraries, and recreation area s would be considered noise - and vibration -sensitive and may warrant unique measures for protection from intruding noise. Sensitive receptors near the pro ject site include residences to the east and west of the Project site (across Hudson Avenue and Oak Knoll Avenue, respectively). Additionally, a church is located immediately south of the Project site, and residences are also located to the south, south of an office building. In evaluating construction noise impacts, including impacts on these noise -sensitive land uses in the immediate proximity of the Project site, the City measures construction noise impacts at 100 feet from the source (i.e., equipment) to compare construction noise levels to the corresponding 85-dBA limitation in the City’s Noise Ordinance exemption.
The above sensitive receptors represent the nearest land uses with the potential to be impacted by construction and operation of the proposed development. Additional sensitive receptors are located farther from the Project site in the surrounding community and would be less impacted by noise and vibration levels from the Project.
a) Would the project result in generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies? Short-Term Construction Impacts
Less Than Significant Impact. Construction noise and vibration are temporary occurrences. Construction noise and vibration levels vary from hour-to-hour and day-to-day, depending on the equipment in use, the operations being performed, and the distance between the source and receptor. Construction of the proposed Project would generate noise that could expose nearby receptors to elevated noise levels that may disrupt communication and routine activities. The magnitude of the impact would depend on the type of construction activity, equipment, duration of construction, distance between the noise source and receiver, and intervening structures. Noise impacts resulting from construction noise levels were calculated (refer to Appendix F for further details) at nearby sensitive receptors (i.e., residences). 740-790 EAST GREEN STREET MIXED-USE PROJECT
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Construction – Equipment Data and Description
Equipment operates in alternating cycles of full power and low power, producing noise levels less than the maximum level. The typical noise levels for various pieces of construction equipment at a distance of 50 feet are presented in Table 2.13-2.
Table 2.13-2. Typical Construction Equipment Noise Emission Levels and Usage Factors Equipment Description
Impact
Device?
Acoustical
Use Factor
(%)
Lmax @ 50 Feet
(dBA, Slow)
All other equipment > 5 horsepower No 50 85
Auger drill rig No 20 85
Backhoe No 40 80
Bar bender No 20 80
Compressor (air) No 40 80
Concrete pump truck No 20 82
Crane No 16 85
Dozer No 40 85
Dump truck No 40 84
Excavator No 40 85
Flatbed truck No 40 84
Front-end loader No 40 80
Generator No 50 82
Generator (<25 kilovolt-amps) No 50 70
Hydra break ram Yes 10 90
Man lift No 20 85
Pickup truck No 40 55
Pneumatic tools No 50 85
Pumps No 50 77
Roller No 20 85
Sand blasting (single nozzle) No 20 85
Scraper No 40 85
Tractor No 40 84
Welder/torch No 40 73
Source: Appendix F
As shown in Table 2.13-2, a backhoe has a maximum sound level of 80 dBA at a distance of 50 feet; with outdoor attenuation rates, this level would be reduced to 74 dBA at 100 feet, and 68 dBA at 200 feet.
On-Site Construction Noise Assessment
With the assumed construction equipment noise sources identified in Table 2.13-3, a noise analysis of on-site construction noise was performed using the Roadway Construction Noise Model (RCNM) , developed by the Federal Highway Administration (FHWA 2008). Input variables for RCNM consist of the receiver/land use types, the equipment type (e.g., backhoe, crane, truck), the number of equipment pieces, the duty cycle for each piece of equipment (i.e., percentage of each hour or reference period that the equipment typically works), and the distance from the equipment to the receiver. Refer to Appendix F for the inputs used in the RCNM model and the results. 740-790 EAST GREEN STREET MIXED-USE PROJECT
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Noise-sensitive land uses exist to the south, east and west of the Project site. The closest noise-sensitive receiver consists of a church that is as near as 10 feet from the Project site, located immediately south of the Project site. Multi-family residences exist to the south, west, and east, with the closest being approximately 60 feet from the Project site. Additionally, single-family residences exist to the west, approximately 60 feet from the Project site. These nearby land uses (and the nearest source-receiver distances) were used to assess worst-case construction noise levels. However, the above distanc e assumptions would not be representative of more typical construction noise, because in general the construction activities would not take place either at the nearest or at the farthest portions of the Project site, but somewhere in between. Thus, in order to provide information on typical construction noise levels, the distance from the nearest receivers to the Project’s “acoustic center” was also analyzed. The acoustic center represents the idealized point from which the energy sum of all construction activity noise, near and far, would be centered. The acoustic center is derived by taking the square root of the product of the nearest and the farthest distances. For this Project, the acoustic center for the nearest noise -sensitive land use (the church to the south) was found to be approximately 60 feet. Given the overall size of the Project site, and the relatively equal distribution of proposed development across the property, noise levels derived from the acoustic center of construction activity would provide a better representation of average noise level exposure across the entire construction process for a given off-site receiver, than using the minimum distance worst-case method.
Table 2.13-3. Construction Scenario Assumptions
Construction
Phase
One-Way Vehicle Trips Equipment
Average
Daily
Worker
Trips
Average
Daily
Vendor
Truck
Trips
Average
Daily Haul
Truck
Trips1 Equipment Type Quantity
Usage
Hours
Demolition 16 0 25 Concrete/Industrial Saws 1 8
Excavators 3 8
Rubber Tired Dozers 2 8
Grading 20 0 78 Excavators 2 8
Graders 1 8
Rubber Tired Dozers 1 8
Scrapers 2 8
Tractors/Loaders/Backhoes 2 8
Trenching 4 0 0 Trenchers 1 8
Building construction 288 68 0 Cranes 1 7
Forklifts 3 8
Generator Sets 1 8
Tractors/Loaders/Backhoes 3 8
Welders 1 8
Architectural Coating 16 0 0 Air Compressors 1 6
Paving 58 0 0 Pavers 2 8
Paving Equipment 2 8
Rollers 2 8
Source: Appendix F
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The noise ordinance contains a construction noise restriction which pertains specifically to sound levels at 100 feet from the construction noise sources; according to the Noise Ordinance, construction equipment must not produce noise that exceeds 85 dBA at 100 feet.
The results of the construction noise analysis using RCNM are summarized in Table 2.13-4 (see Appendix F for complete results). As shown, the highest noise levels from construction are predicted to range from approximately 88 dBA L eq (during the architectural coating phase) to 95 dBA L eq (during the demolition phase) at the nearest adjacent noise-sensitive receiver (i.e., church located 10 feet from the closest point of construction). These noise levels would be substantially higher than ambient noise levels in the area, and would be considered annoyin g or disruptive for daily activities at the closest off -site receptor (i.e., nineteen feet from the northern property line).
At the nearest residences, located approximately 60 feet away, the highest noise levels would range from approximately 72 dBA L eq (during architectural coating) to 83 dBA L eq (during demolition and grading).
These noise levels are considered to be a peak exposure, applicable not more than 10-15% of the total construction period, only while the construction activity is taking place at the nearest boundaries of the respective off-site receivers. The typical construction noise levels (for construction taking place at a range of locations on-site and modeled at the acoustical center for analysis purposes) range from approximately 72 dBA L eq (during architectural coating) to approximately 86 dBA L eq (during grading) at the church to the south, and from 64 dBA L eq (during architectural coating) to 78 dBA L eq (during grading) at the residences, and are also shown in Table 2.13-4. These typical construction noise levels would still be considerably greater than ambient noise levels in the Project vicinity, likely resulting in annoyance.
Construction noise levels at 100 feet were also evaluated, and are shown in the bottom row of Table
2.13-4. These values are compared against the City’s 85 dBA at 100 feet criterion for construction equipment noise. As shown in Table 2.13-4, the estimated construction noise level would remain below the 85 dBA criterion, resulting in a less than significant construction noise impact.
Table 2.13-4. Construction Noise Levels at Noise-Sensitive Uses Off-site
Receptor
Location
Noise
Sensitive
Land Use
Existing
Ambient
Noise
Level
Distance from
Construction
Activity to Noise
Receptor (feet)
Estimated Construction Noise
Levels (dBA Leq)
Demolition
Grading
Building
Construction
Paving
Architectural
Coating
Trenching
South of the
Project Site
Church 66 Nearest Construction
Activity /Receiver
Distance (10')
95 94 90 90 88 91
Typical Construction
Activity /Receiver
Distance (60')
84 86 83 80 72 76
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Table 2.13-4. Construction Noise Levels at Noise-Sensitive Uses Off-site
Receptor
Location
Noise
Sensitive
Land Use
Existing
Ambient
Noise
Level
Distance from
Construction
Activity to Noise
Receptor (feet)
Estimated Construction Noise
Levels (dBA Leq)
Demolition
Grading
Building
Construction
Paving
Architectural
Coating
Trenching
West of the
Project Site
Single-family
and multi-family
residences
65 Nearest Construction
Activity /Receiver
Distance (60')
83 83 79 78 72 76
Typical Construction
Activity /Receiver
Distance (150')
76 78 75 72 64 68
South of the
Project Site
Multi-family
residences
67 Nearest Construction
Activity /Receiver
Distance (60')
83 83 79 78 72 76
Typical Construction
Activity /Receiver
Distance (150')
76 78 75 72 64 68
East of the
Project Site
Multi-family
residences
71 Nearest Construction
Activity /Receiver
Distance (60')
83 83 79 78 72 76
Typical Construction
Activity /Receiver
Distance (150')
76 78 75 72 64 68
100-Foot
Reference
Distance
N/A N/A 100' 79 79 76 74 68 71
Source: Appendix F
Note: Noise levels from construction activities do not take into account attenuation provided by intervening structures.
Leq dBA: Energy-averaged noise level
The Project would be required to comply with the City’s Noise Ordinance by adhering to the following construction schedule (City of Pasadena 2008):
Construction activity must comply with City noise ordinance requirements, which limit construction activities to the hours between 7:00 a.m. and 7:00 p.m. on weekdays.
Saturday construction can occur between 8:00 a.m. and 5:00 p.m. Construction on Sundays and holidays is prohibited.
Noise from construction activities may be annoying because levels would generally be well above typical existing ambient noise levels. However, construction noise would be temporary, and restricting construction activities to the daytime period would avoid disruption of evening relaxation and overnight sleep periods. 740-790 EAST GREEN STREET MIXED-USE PROJECT
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Moreover, as construction noise levels would be below the standards established in the City’s Noise Ordinance, construction noise impacts would be less than significant.
Off-Site Construction Noise Assessment
The proposed Project would result in temporary increases in traffic from worker vehicles and project - related truck trips. The increase in vehicles along local arterials would correspond with an incremental increase in traffic noise. Based on the air quality analysis prepared for the Project (refer to Appendix A), the Project would result in as many as 78 daily one -way truck trips (up to 39 round trips) and 288 daily one-way worker trips (144 round trips) during the various construction phases, as shown in Table 2.13-
3. It should be noted that the highest numbers of truck trips and worker trips would not occur during the same construction phases.
In order to assess potential noise impacts from construction-related traffic, the FHWA’s TNM noise model (FHWA 2004) was utilized. Because the nearest City-designated truck routes are Del Mar Boulevard and Lake Avenue, Project -related trucks would likely access the Project site via either (or both) of these streets, then using either Green Street, Oak Knoll Avenue or Hudson Avenue. As a conservative measure, it was assumed that Project-related construction trips (autos and trucks) could use all of these streets. For each of the two phases for which haul truck trips and worker trips would be at their respective peaks (grading and building construction, respectively), Project-related autos and truck trips were added to all of the adjacent modeled roadways. The resulting noise levels and resulting Project -related increases are summarized in Table 2.13-5.
As shown in Table 2.13-5, temporary traffic noise increases would be 2 d ecibels (dB) or less. Although individual truck pass -bys would be audible, the incremental increase in hourly average (and 24 -hour CNEL) vehicle noise would not be an audible change (as detailed in Appendix F, a change in noise level of 3 dB is considered to be barely audible). Therefore, off-site construction noise impacts would be less than significant.
Table 2.13-5. Construction-Related Traffic Noise
Modeled Receptor
Existing Noise Level
(Peak-Hour Leq dBA)
Existing plus Construction
Traffic Noise Level
(Peak-Hour Leq dBA)
Noise Level
Increase
(dB)
Grading Phase
ST1 68 69 1
ST2 68 69 1
ST3 68 69 1
ST4 70 70 0
Building Construction Phase
ST1 68 70 2
ST2 68 70 2
ST3 68 70 2
ST4 70 72 2
Source: Appendix F
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On-Site Long-Term Operational Noise Impacts
Less Than Significant Impact. The implementation of the Project would result in changes to existing noise levels in the Project vicinity by developing new stationary sources of noise. Operational noise sources for the Project include HVAC equipment as the primary anticipated source. Noise from other sources, such as the proposed pocket park, outdoor community open space, and the proposed loading zone, would result in periodic noise; however, these noises would be relatively low because of design and location. Exterior-facing spaces (i.e., the pocket park, the garden courtyard, and the 5th-floor roof terrace) are designed for passive uses– no events or other particularly noisy activities, such as a large gatherings, would occur in these areas.
Additionally, the pocket park, garden courtyard, and 5th floor rood terrace would be shielded (to varying degrees) by the buildings’ structures, which further reduce the ability of sound to travel from the Project site to nearby noise receivers. For example, noise from people gathering on the 5th-floor roof terrace would be shielded at adjacent receivers by the terrace balcony walls. Similarly, the pocket park would be located along the southern side of the Project, not facing the residences to the west, which would limit the potential for on- site noise to disrupt adjacent receptors. The active recreation area is located within the central interior court and would be shielded from adjacent uses by the surrounding 4 to 5-story structure. Additionally, no amplified music systems would be permitted in the outdoor spaces.
Mechanical equipment noise was analyzed based on common residential HVAC units and d istances to the property lines (refer to Appendix F) . Standard acoustic distance calculations were performed to determine the attenuated noise level at the property line location for each cluster of mechanical noise sources. HVAC equipment (i.e., the conde nser units) would be mounted on the rooftops. Exact specifications for the equipment are not yet available, but locations have been specified in the roof plans.
General assumptions regarding the HVAC are used to analyze the potential for operational noise impacts from the HVAC equipment. Based on noise emission data (refer to Appendix F), the sound power levels would range from 68 to 71 dBA (Trane 2013).
The roof plans indicate that 52 HVAC units would be located on the roof of the north building level 3, 20 HVAC units would be located on the roof at the north building level 4, 68 HVAC units would be located on the roof at the south building level 4 roof, and 126 HVAC units would be located on the roof at the south building level 5 roof a total of 26 HVAC units would be placed on the roof of the northwestern wing, 19 HVAC units would be placed on the roof of the northern wing, 76 units would be placed on the roof of the central wing, and 19 units would be placed on the roof of the southern wing .
The elevations of the rooftop HVAC equipment would range from approximately 30 feet to 70 feet above ground level, and the plans indicate 4 -foot high parapets around the roof. The parapets would provide not only visual screening, but would also act as a n oise barrier. Calculations for the HVAC noise at the northern, western, and eastern property lines, where the closest off -site residences are located , are provided in Appendix F. Calculations were also performed at the property lines to the south, adjacent to a church and residences. The results of the HVAC noise calcul ations are summarized in Table 2.13-6.
The maximum noise level for all HVAC units in operation, along the northwestern northeastern side of the Project boundary, was calculated to be 37 39 dBA Leq. Along the southern southwestern side of the Project site, the noise level was calculated to be 30 34 dBA Leq. The measured existing ambient levels are approximately 30 25 dB or more above the calculated noise levels due to the mechanical equipment.
Therefore, operational noise levels from the expected mechanical equipment for the Project would be less than significant.
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Table 2.13-6. Summary of Mechanical Equipment Operational Noise Results Equipment
Noise Level at Property Boundary
Property Line Average Noise Level
(dBA Leq)
HVAC North, West Side 33 36
HVAC North, East Side 37 39
HVAC South, West Side 30 34
HVAC South, East Side 30 32
HVAC East, North Side 30 32
HVAC East, Mid-Block 35 37
HVAC West, North Side 35 38
HVAC West, Mid-Block 33 36
Source: Appendix F
Traffic Noise Impacts
Less Than Significant Impact. The primary potential noise-related effect that most residential mixed-use projects produce is a potential for off-site increases in traffic, which in turn can produce greater traffic noise exposure levels for noise-sensitive land uses located along such roadways. The noise levels associated with roadway traffic were determined based on the Project’s Traffic Impact Analysis (City of Pasadena 2020a) and using the Federal Highway Administration TNM 2.5 Traffic Noise Model version 2.5 (FHWA 2004). TNM 2.5 was employed to compare the existing traffic noise level to the resulting traffic noise level from the addition of Project generated traffic (see Appendix F for complete traffic modelling inputs and results).
The results of the traffic modeling for the existing and existing plus Project scenarios are summarized in Table 2.13-7. As shown, the Project-related traffic would result in a noise level increase of 1 dB CNEL or less along the studied roads in the vicinity of the Project site. Increases would be below the significance threshold of 3 dB , which is the level considered to be bare ly audible. Therefore, traffic related to the proposed Project would not substantially increase the existing noise levels in the Project vicinity, and operational traffic-related noise impacts would be less than significant. No mitigation is required.
Table 2.13-7. Traffic Noise (Existing and Existing-with-Project) Modeled Receptor
Existing Noise Level
(dBA CNEL)
Existing plus Project
Noise Level
(dBA CNEL)
Noise Level Increase
(dB)
ST1 68 69 1
ST2 68 69 1
ST3 68 69 1
ST4 70 70 0
Source: Appendix F
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b) Would the project result in generation of excessive groundborne vibration or groundborne noise levels?
Less Than Significant Impact with Mitigation Incorporated. Operation of the Project does not include any heavy rotating equipment. Thus, significant groundborne vibration is not expected during the operational phase of the Project. However, construction activities that might expose adjacent structures or uses to excessive ground-borne vibration or ground-borne noise could cause a potentially significant impact. Ground-borne vibration information related to construction activities has been collected by the California Department of Transportation (Caltrans 2020). The heavier pieces of construction equipment, such as bulldozers, would have peak particle velocities of approximately 0.089 inches per second PPV or less at a distance of 25 feet. Lighter construction equipment, such as a small bulldozer, would have peak particle velocities of appr oximately 0.003 inches per second PPV at 25 feet (FTA 2018). The Project’s construction activity would not include blasting or pile driving, which are the primary sources of high vibration levels associated with construction.
Ground-borne vibration is typ ically attenuated over short distances. The distance from the nearest buildings (the church to the south of the Project site on the Project’s west side, and an office building to the south of the Project site on the Project’s east side) to where demolition and construction activity would be occurring on the Project site is approximately 10 feet. At a distance of 10 feet, and with the anticipated construction equipment, the PPV vibration level would be approximately 0.352 inches per second PPV.
The major concern with regards to construction vibration is related to building damage, which could occur at vibration levels of 0.2 inches per second or greater for non-engineered timber and masonry buildings, and at vibration levels of 0.12 inches per second or greater for buildings extremely susceptible to vibration damage (FTA 2018). The church located at 128 South Oak Knoll Avenue , immediately south of the Project site on the westerly side, is approximately 100 years old ( City of Pasadena 2020b), and is thus considered “potentially fragile”; the FTA damage threshold of 0.12 inches/sec PPV is therefore applied to this structure. Also, the building at 133 South Hudson Avenue, immediately south of the Project site on the easterly side, is of unknown age and is currently occupied by medical offices (including a dental office); therefore the FTA damage threshold of 0.12 inches/sec PPV is applied to this structure as a conservative measure. As discussed above, the anticipated vibration levels associated with on -site Project construction using heavy construction equipment would be approximately 0.352 inches per second PPV at the nearest structures, which is above the threshold of 0.12 inches per second. Therefore, vibration impacts would be potentially s ignificant without mitigation. With incorporation of MM -NOI-1, potential construction vibration impacts would be reduced to less than significant.
MM-NOI-1 Prior to approval of grading plans and/or prior to issuance of demolition, grading and building permits, the Project applicant shall retain a team to prepare a vibration monitoring plan. The team shall include a professional structural engineer with experience in structural vibration analysis and monitoring for historic buildings and a historical architect to perform the following tasks:
• Review the Project plans for demolition and construction; • Survey the Project site and the property/bui ldings to the sout h (i.e., 128 South Oak Knoll Avenue and 133 South Hudson Avenue);
• Conduct geological testing if determined to be necessary, and:
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• Prepare and submit a report to the Director of Planning and Community Development to include, but not be limited to, the following:
o The information from the survey identified above;
o Any modifications to the permissible vibration level thresholds based on the structural conditions of the adjacent properties to the south , soil conditions, and planned demolition and construction methods to ensure that vibration levels would remain below the potential for damage to the adjacent structures to the south; o Specific measures (such as requiring the use of lighter, less -powerful equipment when applicable – a small bulldozer rather than a large bulldozer for example - in proximity to the southern Project boundary) to be taken during demolition / construction to ensure that vibration level limits identified by the structural engineer (or 0.12 ppv in/sec in lieu of such specified limits) are not exceeded; o A monitoring plan to be implemented during demolition and construction that includes post-construction and post-demolition surveys of the adjacent properties to the south and documentation demonstrating that the measures identified in the report have been implemented.
c) For a project located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people residing or working in the p roject area to excessive noise levels?
No Impact. The Project site is located approximately 6.9 miles northwest of San Gabriel Airport, and approximately 12.8 miles southeast of Hollywood/Burbank Airport. The Project site is not located within the Airport Influence Areas of either of these airports, and thus would not expose people residing or working in the Project area to excessive noise levels from the airports. Similarly, no private airstrips exist in the Project vicinity. No impacts would occur.
2.14 POPULATION AND HOUSING
Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Would the project:
a) Induce substantial unplanned population growth
in an area, either directly (for example, by
proposing new homes and businesses) or
indirectly (for example, through extension of
roads or other infrastructure)?
b) Displace substantial numbers of existing people or
housing, necessitating the construction of
replacement housing elsewhere?
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a) Would the project induce substantial unplanned population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure)?
Less Than Significant Impact. The proposed Project would directly induce population growth in the City by constructing 2 63 for -rent residential units. According to the Southern California Association of Governments (SCAG), the City of Pasadena’s population in 2018 was 144,388 people, with an average of 3.1 people per household (SCAG 2019). Using this factor of 3.1 people per household, the proposed Project could support a residential population of approximately 815 persons.
The City’s General Plan indicates goals and policies related to growth provide for community conservation and strategic growth, preserving existing neighborhoods and targeting new development to infill areas that are vacant or underutilized, and are scaled and designed to complement existing uses. As stated in Policy
1.3, the City seeks to “Regulate building intensity and population density consistently with the designations established by the Land Use Diagram” (City of Pasadena 2015b). As discussed in the introduction to Section I of this IS/MND, Existing Land Use and Zoning Designations, the General Plan land use designation for the proposed Project site is designated as Medium Mixed-Use, and the zoning designation is CD-4 (Central District, Pasadena Playhouse) zoning district. The Project is located within the Central District Specific Plan, which shall not exceed the 4,272 residential units for cumulative new development (City of Pasadena 2015b).
As of November 2020, building permits have been issued for a total of 1,721 dwelling units, with a remaining total of 2,551 dwelling units. Therefore, the Project’s 222 market rate units would be within this allocation.
That there is adequate allocation remaining is required to be confirmed prior to the issuance of building permits for the project. The Medium Mixed-Use designation is intended to support the development of multi-story buildings with a variety of compatible commercial (retail and office) and residential uses. The proposed base density allowed according to CD-4 zone standards is 87 dwelling units per acre, which allows for up to 203 units. With the addition of the 41 affordable housing units, and the associated 30% affordable housing density bonus, the Project proposes a total of 263 units, including 86 studio units, 126 one-bedroom units, and 51 two-bedroom units. Based on the unit count and number of bedrooms, a total of 39,450 square feet of open space is required. The Project incorporates 39,483 39,980 square feet of open space, which includes 27,180 27,795 square feet of common open space, 11,703 11,585 square feet of private open space, and 600 square feet of interior common open space. Thus, the Project would be consistent with the existing land use and zoning designation and, thus, would be consistent with the City’s General Plan goals and policies related to growth.
As shown in Table 2.14-1, the SCAG 2020-2045 Regional Transportation Plan/Sustainable Communities Plan: Appendix, Demographics and Growth Forecast , estimates that the City can expect a population increase of 13,400 people by 2045, as well as a n 8,800 increase in households and a 24,000 increase in employment opportunities by 2040 (SCAG 2019).
Table 2.14-1. City of Pasadena Demographics and Household Growth Forecast Year Population Households Employment
2016 142,100 56,300 116,200
2045 155,500 65,100 140,200
Total Growth 13,400 8,800 24,000
Source: SCAG 2019
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The proposed Project includes the construction of a mixed-use development comprising 263 rental apartment units, approximately 16,481 14,346 sf of commercial office development (e.g. retail, restaurant), 37,666 39,980 sf of open space and amenities, and a 4,110 4,033-sf publicly accessible pocket park. Substantial population growth in any particular area is usually associated with a significant increase in available housing stock and/or employment opportunities. The proposed Project includes 263 rental units, which could result in some localized populati on growth in Pasadena. Although it is highly unlikely that all of the proposed units would be rented by people relocating to Pasadena, for the purpose of conservatively estimating population growth as a result of the proposed Project, this analysis assumes that all people occupying the new units would be new residents to the area. As such, in a “worst-case scenario”, the proposed Project has the potential to add approximately 8 15 people to the local population.17 The Project’s potential 815 new residents represents approximately 6% of the City’s projected growth from 2016 through 2045,18 which is within the population projections currently estimated by SCAG (see Table 2.14-1). As such, the proposed Project would no t induce substantial unplanned population growth in the area. Furthermore, the proposed Project would not include the construction of any roads or other infrastructure, the implementation of which could result in substantial, indirect population growth.
According to SCAG’s Employment Density Report, the average square foot per employee in Los Angeles County is 424 s quare feet per employee for other retail (SCAG 2001). Thus, the proposed Project’s 16,481 14,346 sf of retail would generate approximately 38 persons to the City’s employment pool.
However, the proposed retail would be replacing the 5 commercial buildings, totaling approximately 34,668 sf, which generates approximately 82 persons in the employment pool. Therefore, the proposed Project would result in a potential loss of 44 employment opportunities. The Project would not generate a substantial employment population compared to the existing conditions.
For these reasons, the proposed Project would not result in substantial, unplanned population gr owth.
Given the above, the proposed Project would have a less than significant impact on population growth and no mitigation is required.
b) Would the project displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere? No Impact. The proposed Project would be located on a site that is fully developed with commercial land uses under existing conditions. No housing would be demolished under the proposed Project, and, as such, no people would be displaced. Therefore, no impact would occur. No mitigation is required.
17 263 proposed units * 3.1 average household size = 815.3 new residents. 18 816 people / 6,312 projected population growth = 0.134 * 100 = 13.4% 740-790 EAST GREEN STREET MIXED-USE PROJECT
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2.15 PUBLIC SERVICES
Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for any of the public services:
Fire protection?
Police protection?
Schools?
Parks?
Other public facilities?
a) Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental f acilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for any of the public services:
Fire protection?
Less Than Significant Impact. Fire protection services in the City are provided by the Pasadena Fire Department (PFD). There are four fire stations within a 1-mile radius of the Project site: Station 33 located at 515 N. Lake Avenue, approximately 0.7-mile north of the Project site; Station 34 located at 1360 E .
Del Mar Blvd , approximately 0.7-mile southeast of the Project site; Station 809 located at 285 N . Hill Avenue, approximately 0.9-mile northeast of the Project site and Station 31 located at 135 S. Fair Oaks Avenue, approximately 0.9-mile west of the Project site. Based on proximity to the Project site, the first- in station would be PFD Station 33 and the second-in station would be PFD Station 34.
The need for new or expanded public service facilities (such as fire protection facilities) is typically associated with a population increase. As described in Section 2.14, Project employment and new residential uses would result in approximately 815 residents on the Project site. Conservatively assuming all employees become new residents within the City, the Project would result in a n additional 815 residents. These 815 residents would approximately 6% of the City’s projected growth from 2016 through 2045. Due to the minor nature of the population growth that could result from development of the proposed Project and because this growth falls well within the projected population growth for the City, the population growth that could be caused by the proposed Project is not substantial and has been accounted for in local and regional population projections. As such, it is expected that the population growth associated with the Project would not outpace the existing or future service capacity of the PFD.
Furthermore, the Project site is located in an urbanized area, and is not located in a moderately, highly, or very highly susceptible area to fire (CAL FIRE 2019). Although increased intensities are proposed, the Project site is in an existing urban area with a low fire hazard. As such, implementation of the proposed Project is not likely to expose proposed structures or people to substantial fire risk. In addition, prior to 740-790 EAST GREEN STREET MIXED-USE PROJECT
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construction of the proposed Project , PFD would review the development plans to ensure Fire Code requirements are met, including Section 14.28, Fire Prevention Code, of the City’s Municipal Code . As the proposed Project would not necessitate the construction of new fire facilities or expansion of existing facilities to serve the Project, impacts related to fire protection services would be less than significant.
Police protection?
Less Than Significant Impact. Police protection services in the City are provided by the Pasadena Police Department (PPD). The Project site is served by the PPD Station located at 207 Garfield Avenue, Pasadena, CA 91101. Based on the Pasadena Police Department’s published monthly crime reports for March 2020, there were a total of 317 citywide service calls (Pasadena Police Department 2020). The PPD consists of 366 sworn officers and nonsworn personnel for a population of approximately 144,388 people (as of 2018) ( City of Pasadena 2016a ; SCAG 2019). T his equates to a staffing density of 2.5 officers per 1,000 residents in the City. Considering the increase of approximately 815 new residents, the staffing density would remain 2.5 officers per 1,000 residents in the City. Although implementation of the Project would generate a demand for police protection services, the Project would not change current staffing to resident ratios. Thus , the Project would not result in the new for new or expanded Police facilities. Therefore, impacts related to police protection services would be less than significant.
Schools, Parks, Other Public Facilities?
Schools
Less Than Significant Impact. The City is served by the Pasadena Unified School District (PUSD). The need for new school facilities is typically associated with a population increase that generates an increase in enrollment large enough to cause new schools to be constructed. The Project site would be served by McKinley Elementary School (325 S Oak Knoll Avenue), Blair Middle School (1201 Marengo Avenue), and Blair High School (1201 Marengo Avenue) (PUSD 2020). The proposed Project would involve a net increase of 263 for-rent units in the City. The state has a Student Yield Factor for Unified School Districts, which is 0.7 students per dwelling unit (Office of Public School Construction 2008). Using this generation factor, the proposed project is anticipated to result in approximately 188 new students. The anticipated increase in 188 students would result in an increase in enrollment. Per California Government Code Section 65995, developer fees paid to the PUSD would mitigate all Project-related impacts to schools.
As stated in Government Code Section 65996, payment of school impact fees in accordance with Government Code Section 65995 is deemed to constitute full and complete mitigation for potential impacts to schools caused by development. For these reasons, impacts related to the need for new school facilities as a result of implementing the proposed Project would be less than significant.
Parks
Less Than Significant Impact. As further detailed in Section 2.16, Recreation, according to the City’s Green Space, Recreation, and Parks Master Plan (Master Plan), the City of Pasadena included 23 dedicated parks in 2007 (including 15 Neighborhood Parks, five Community Parks, and three Citywide Parks), totaling 338.2 acres (City of P asadena 2007). As shown in Table 2.16-1 (see Section 2.16, Recreation), the City currently holds approximately 395 acres of dedicated parkland and 502.3 acres of open space (City of Pasadena 2015a).
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According to the General Plan EIR, the City does not hav e an adopted minimum parkland standard for evaluating impacts on parks; rather, parkland needs are assessed under the overarching Policy GSRP
6.3 from the City’s Master Plan, which states that adequate developed parkland must be acquired or developed “in sufficient quantity to meet the community demand for facilities and programs identified in the Master Plan” (City of Pasadena 2015a).
Given the above, it is important to note that the City’s Master Plan identifies the Central District (i.e. where the proposed Project is located) as a unique urban core that is denser than other parts of the City and where large, traditional parks are more difficult to establish due to high land costs, intense existing urban development, and a general lack of available land for conversion to parkland and recreational open space (City of Pasadena 2007).
Furthermore, the Master Plan states that, “Given the built-out condition of the City, it is very unlikely that even a fraction of this amount of acreage could be converted to parkland. A more likely scenario is that small urban open space areas might be created that could provide some of the desired amenities” (City of Pasadena 2007).
As stated in Section I, Project Description, the proposed Project would include a 4,110 4,033-sf publicly accessible pocket park, which would, in part, provide public parkland and recreational open space near downtown Pasadena, including within the Specific Plan area. Thus, the proposed Project would provide a pocket park in an area in the City were traditional parks are more difficult to establish. Additionally, given the pocket park would be located in a unique urban core that is denser than other parts of the City, the pocket park provided by the Project would increase access for residents in this portion of the City to access park spaces. Further, per the Quimby Act, or California Government Code Section 66477, local jurisdictions may require developers to dedicate land and/or pay in-lieu fees towards the conservation of parkland.
It should also be noted that the City is in the process of creating a new Playhouse District Park + Parking Lot to provide additional public parkland and recreational open space near downtown Pasadena. The City is currently collecting feedback from the public and held three community workshops in October 2019, November 2019, and December 2019.
Given that: 1) the City does not utilize a parkland standard (City of Pasadena 2015a); 2) the Master Plan acknowledges that “small urban open space areas might be created that co uld provide some of the desired amenities” (City of Pasadena 2007); and, 3) the developer would be required to supplement for the additional parkland not compensated for by the proposed pocket park through the payment of in-lieu fees, the proposed Project would not create the need for new or expanded park facilities. Impacts would be less than significant. No mitigation is required.
Libraries
Less Than Significant Impact. Other public facilities and services provided within the City include library services and City administrative services. Library services are provided by the Pasadena Public Library system, which includes 10 libraries. The nearest public library to the Project site is the Hill Avenue Branch Library located at 55 S Hill Avenue, approximately 0.7 -mile east of the Project site. The Hill Avenue Branch Library is 4,752 sf, has a collection size of 41,859, 19 meeting room seats, and 11 parking spaces (City of Pasadena 2020c).
The proposed Project would g enerate approximately 38 new employees and 816 new residents. As described above under “fire protection,” the population and employment growth from the P roject would fall well within local and regional growth projections and would also represent a minor fraction of existing and future population and employment in the City. Conservatively assuming the proposed Project has the potential to add approximately 815 people to the local population, the new residents represents 740-790 EAST GREEN STREET MIXED-USE PROJECT
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approximately 6% of the City’s project ed growth from 2016 through 2045. 19 This nominal increase in library patrons is not expected to result in the need for new or expanded library facilities. Further, Section
4.109, Library Special Tax, requires residential swelling units to pay a special tax specifically for maintaining the quality of the Pasadena Public Library system. The Project would contribute to this fund.
Therefore, impacts associated with libraries and other public facilities would be less than significant.
2.16 RECREATION
Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Would the project increase the use of existing
neighborhood and regional parks or other
recreational facilities such that substantial
physical deterioration of the facility would
occur or be accelerated?
b) Does the project include recreational facilities
or require the construction or expansion of
recreational facilities which might have an
adverse physical effect on the environment?
a) Would the project increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated?
Less Than Significant Impact. Substantial physical deterioration of existing neighborhood and regional parks primarily occurs when population growth significantly surpasses the capacity of existing parks and recreational facilities, which deteriorate over time as a result of overuse and insufficient maintenance.
According to the City’s Green Space, Recreation, and Parks Master Plan (Master Plan), the City of Pasadena included 23 dedicated parks in 2007 (including 15 Neighborhood Parks, five Community Parks, and three Citywide Parks), totaling 338.2 acres (City of Pasadena 2007). According to the City’s General Plan EIR, this number has risen to 27 parks totaling 893.5 acres, as shown in Table 2.16-1 below (City of Pasadena 2015a).
The City also considers urban open spaces (such as public plazas, paseos, golf courses, and museums) as significant contributors to the City’s recreational amenities (City of Pasadena 2007).
Table 2.16-1. Existing Parks and Open Space Areas in the City of Pasadena Park Name Address
Total Dedicated
Size (acres) Approximate
Distance from
Project Site (miles) Parks
Open
Space
Citywide Parks:
These parks afford contact with the natural and/or historic environment and possess a unique character or function not found in neighborhood or community parks. They contain facilities that are used by residents throughout the City for activities that cannot be accommodated in other parks.
Brookside Park 360 N. Arroyo Boulevard 61.6 --
19 816 people / 6,312 projected population growth = 0.134 * 100 = 13.4% 740-790 EAST GREEN STREET MIXED-USE PROJECT
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Table 2.16-1. Existing Parks and Open Space Areas in the City of Pasadena Park Name Address
Total Dedicated
Size (acres) Approximate
Distance from
Project Site (miles) Parks
Open
Space
Rose Bowl Area H/
Central Arroyo Seco
747 Seco Street 19 173.2
Hahamongna Watershed
Park
Southeast corner of Oak Grove
Drive and Foothill Boulevard.
95 230 6 miles northwest
Lower Arroyo Park/Lower
Arroyo Seco Open Space
71.1 99.1
Community Parks:
These facilities are approximately 5 to 25 acres in size and are designed primarily for recreational activities of all age groups. They serve and attract users from a wider community than the neighborhood parks. They may be combined with or adjacent to junior high or high school sites.
Central Park 275 South Raymond Avenue. 9.2 -- 1.4 miles southwest Memorial Park 85 E Holly Street. 5.3 -- 1 mile west
Robinson Park 1081 North Fair Oaks Avenue. 9.2 -- 2.3 miles northwest Victory Park 2575 Paloma Street. 26.2 -- 3 miles northwest Villa-Parke 363 East Villa Street. 10.5 -- 1 mile northwest Neighborhood Parks:
These facilities are approximately 1 to 6 acres in size and are designed primarily to provide facilities for preschool and elementary age children. They may be combined with or adjacent to elementary schools. They primarily serve the immediately surrounding residential area.
Allendale Park 1130 South Marengo Avenue. 2.9 -- 2 miles southwest Brenner Park 235 Barthe Drive. 2.7 -- 2.5 miles northwest Defenders Park W Colorado Blvd & N Orange
Grove Blvd.
1.8 -- 3 miles west
Desiderio Park 10 N Arroyo Blvd 3.8 - 1.6-miles west
Eaton-Blanche Park 3100 East Del Mar Boulevard. 5.5 -- 3 miles east Sunnyslope Park N Sunnyslope Avenue & Paloma
Street.
2 -- 3.5 miles northwest
Grant Park 232 S Michigan Avenue. 2.5 -- 0.8-mile southeast Floyd O. Gwinn Park Orange Grove Blvd & N
Sunnyslope Avenue.
2.7 -- 3.5 miles northeast
Hamilton Park 3680 Cartwright Street. 6.4 -- 4.7 miles northeast Jefferson Park 1501 East Villa Street. 4.4 -- 1.6 miles northwest La Pintoresca Park 45 E Washington Blvd. 2.9 -- 2.7 miles northwest McDonald Park 1000 East Mountain Street. 5.1 -- 1.5 miles north San Rafael Park Corner of Colorado Boulevard and
Melrose Avenue.
0.9 -- 3.5 miles southeast
Singer Park Corner of California Boulevard and
Long Beach Freeway.
3.0 -- 2 miles southeast
Vina Vieja Park 3026 E Orange Grove Blvd. 8.6 -- 3.5 miles northwest Washington Park 700 E Washington Blvd. 5.5 -- 2 miles north 740-790 EAST GREEN STREET MIXED-USE PROJECT
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Table 2.16-1. Existing Parks and Open Space Areas in the City of Pasadena Park Name Address
Total Dedicated
Size (acres) Approximate
Distance from
Project Site (miles) Parks
Open
Space
Unclassified Parks:
Annandale Canyon Park 24.3 --
Arlington Gardens 2.6 --
Sid Tyler Park 0.3 --
Total Approximate Acreage* 395 502.3 894 acres
Source: City of Pasadena 2019b
Notes: *2015 acreage estimates rounded, excluding facility building square-footages As shown in Table 2.16-1, the City currently holds approximately 395 acres of dedicated parkland and 502.3 acres of open space (City of Pasadena 2015a).
According to the General Plan EIR, the City does not have an adopted minimum parkland standard; rather, parkland needs are assessed under the overarching Policy GSRP 6.3 from the City’s Master Plan, which states that adequate developed parkland must be acquired or developed “in sufficient quantity to meet the community demand for facilities and programs identified in the Master Plan” (City of Pasadena 2015a).
Given the above, it is important to note that the City’s Master Plan identifies the Central District (i.e. where the proposed Project is located) as a unique urban core that is denser than other parts of the City and where large, traditional parks are more difficult to establish due to high land costs, intense existing urban development, and a general lack of available land for conversion to parkland and recreational open space (City of Pasadena 2007). Furthermore, the Master Plan states that, “Given the built out condition of the City, it is very unlikely that even a fraction of this amount of acreage could be converted to parkland. A more likely scenario is that small urban open space areas might be created that could provide some of the desired amenities” (City of Pasadena 2007). As stated in Section I, Project Description, the proposed Project would include a 4,110 4,033-sf publicly accessible pocket park, which would, in part, alleviate the existing deficiency in public parkland and recreational open space near downtown Pasadena, including within the Specific Plan area. Thus, the proposed Project would provide a pocket park in an ar ea in the City were traditional parks are more difficult to establish. Additionally, given the pocket park would be located in a unique urban core that is denser than other parts of the City, the pocket park provided by the Project would increase access for residents in this portion of the City to access park spaces.
Even with the inclusion of the proposed pocket park, the proposed Project would introduce a maximum of 815 new residents to Pasadena, some of whom would utilize public parks and recreational fa cilities.
As such, the proposed 4,110 4,033-sf pocket park is not expected to significantly alleviate the existing parkland deficiency within the Central District as it would only compensate for a small portion of the expected additional use of City parks and recreational facilities associated with the proposed Project. As such, the proposed Project has the potential to add enough residents to the local population that physical deterioration of other existing parks and recreational facilities may occur.
However, per the Quimby Act, or California Government Code Section 66477, local jurisdictions may require developers to dedicate land and/or pay in-lieu fees towards the conservation of parkland. The Quimby Act was legislated to encourage the pre-emptive mitigation of developments’ impact to parks and open space with the 740-790 EAST GREEN STREET MIXED-USE PROJECT
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overarching goal of achieving a jurisdictional standard of 3.5 acres of parkland per 1,000 residents (California Department of Parks and Recreation 2002). The land dedication and/or fees required under the Quimby Act differ by project and are based upon the residential density, parkland cost, and other factors. Land dedication and fees collected pursuant to the Quimby Act may be used for acquisition, improvement, and expansion of park, playground, and recreational facilities or the development of public school grounds. Additionally, per Assembly Bill 1359 cities and counties may use developer paid Quimby Act fees to provide parks in neighborhoods other than the one in which the developer’s subdivision is located, as long as the legislative body completes a public hearing before utilizing the applicable fees.
Further, it should be noted that the City is in the process of creating a new Playhouse District Park + Parking Lot to further alleviate the existing deficiency in public parkland and recreational open space near downtown Pasadena. The City is currently collecting feedback from the public and held three community workshops in October 2019, November 2019, and December 2019.
Given that: 1) the City does not utilize a parkland standard (City of Pasadena 2015a); 2) the Master Plan acknowledges that “small urban open space areas might be created that could provid e some of the desired amenities” (City of Pasadena 2007); and, 3) the developer would be required to supplement for the additional parkland not compensated for by the proposed pocket park through the payment of in-lieu fees, the proposed Project is not anticipated to increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated. Impacts would be less than significant. No mitigation is required. b) Does the project include recreational facilities or require the construction or expansion of recreational facilities, which might have an adverse physical effect on the environment? Less Than Significant Impact with Mitigation Incorporated. The proposed Project would include the construction of a 4,110 4,033-sf pocket park. However, analysis of the environmental impacts of the proposed pocket park are considered under the proposed Project and, as such, are analyzed throughout this IS/MND. As stated throughout this document, the proposed Project would have a less than significant impact on the environment with mitigation incorporated. Specifically, incorporation of MM-BIO-1, MM- CUL-1 through MM-CUL-3, MM-GEO-1, MM-HAZ-1, MM-HAZ-2, and MM-TCR-1 would reduce impacts to the environment to a less-than-significant level. As such, impacts of constructing the proposed pocket park have been considered and found to be less than significant. 740-790 EAST GREEN STREET MIXED-USE PROJECT
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2.17 TRANSPORTATION
Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Would the project:
a) Conflict with a program, plan, ordinance, or
policy addressing the circulation system,
including transit, roadway, bicycle, and
pedestrian facilities?
b) Conflict or be inconsistent with CEQA
Guidelines section 15064.3, subdivision (b)?
c) Substantially increase hazards due to a
geometric design feature (e.g., sharp
curves or dangerous intersections) or
incompatible uses (e.g., farm
equipment)?
d) Result in inadequate emergency access?
Pasadena Department of Transportation (DOT ) revieweds a proposed project’s transportati on impacts based on project size, consisting of below or equal to communitywide significance thresholds, and above communitywide significance thresholds. Communitywide significance projects are defined as 50,000 square feet of new commercial use, 50 residential units, or any combination of the two. The proposed Project is under Category 2 , which requires analyses of street segment and Level of Service (LOS) outside of CEQA in addition to the CEQA analysis of Vehicle Miles Traveled (VMT) per capita, Vehicle Trips (VT) per capita, Proximity and Quality of the Bicycle Network, Proximity and Quality of the Tra nsit Network, and Pedestrian accessibility . Therefore, the DOT prepared CEQA (Category 2) Evaluation Transportation Impact Analysis and Outside of CEQA (Category 2) Transportation Impact Analysis (TIA) on April 14, 2020February 24, 2022 for the proposed Project (included as Attachment C to the Final MND), which assumes 263 residential units and 16,229 square feet of office.
The CEQA Evaluation TIA analyzed the impact that the proposed Project would potentially have on the City’s transportation system by estimating incremental changes in VMT per capita, VT per capita, service population proximity access to transit and bicycle facilities, and walk accessibility score. The following section summarizes and incorporates by reference the information provided in the CEQA Evaluation TIA, included as Appendix G of this document. The Condition Letter for the CEQA Evaluation dated April 15, 2020 that provides CEQA mitigation measures is also included as Appendix G.
A) Would the project confli ct with a program , plan, ordinance , or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities? Less Than Significant Impact. As shown in the analysis below the Project’s impact to a program, plan, ordinance, or policy addressing the circulation system would be less than significant. 740-790 EAST GREEN STREET MIXED-USE PROJECT
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General Plan Mobility Element, 2015
Pasadena’s General Plan Mobility Element guides the continuing development of the transportation system to support planned growth. The Mobility Element sets forth goals and policies to improve overall transportation in Pasadena. The Mobility Element’s objective is to promote a livable community where people can circulate without cars and non-auto travel modes are emphasized in order to recognize their role in improving the City’s environment and quality of life. Consequently, performance measures related to the per capita length and number of trips associated with changes in land use have been adopted for evaluating the transportation system in lieu of levels of service measures. As discussed above, these new performance measures and CEQA thresholds are consistent with the City’s adopted General Plan.
Pasadena Transportation Impact Analysis Guidelines
On September 27, 2013, Senate Bill (SB) 743 was signed into law, which created a process to change the way that transportation impacts are analyzed under CEQA. SB 743 required the Governor’s Office of Planning and Research (OPR) to amend the CEQA Guidelines to provide an alternative to level of service (LOS) for evaluating transportation impacts. Under the new transportation guidelines, LOS, or vehicle delay, can no longer be considered an environmental impact under CEQA. In response to SB 743, the City of Pasadena adopted the Transportation Impact Analysis Current Practice and Guidelines (City of Pasadena Department of Transportation 2015).
The City’s TIA Guidelines promote an “integrated and multimodal transportation system that provides choices and accessibility for everyone living and working in the City” through public transit services, parking strategies, bicycle facilities, and pedestrian components that are connected with the larger transportation system. The TIA Guidelines identify projects tha t may have transportation impacts and provide instructions for preparing transportation impact analyses for these projects. As described above, the TIA Guidelines differentiates between analyses to be conducted pursuant to CEQA and analyses to be evaluated outside the CEQA process. CEQA and non -CEQA transportation analyses have been prepared for the Project.
Pasadena Municipal Code
Section 10.64.020 of the Pasadena Municipal Code requires that development projects that meet the following criteria incorporate a Transportation Demand Management (TDM) program:
• Multi-family residential developments that are 100 or more units; • Mixed-use developments with 50 more residential units; or 50,000 square feet or more of non - residential development; or
• Nonresidential projects which exceed 75,000 square feet.
The purpose of this chapter of the code is to implement the requirements of Metro’s CMP, in accordance with California Government Code Sections 65089 and 65089.3 and with the provisions of Metro’s model trip reduction ordinance (TRO), and to be consistent with environmental compliance and sustainability efforts. The TDM Program Plans must be approved by the Director of Transportation prior to the issuance of a building permit, and are required to be reviewed and ap proved annually thereafter. In compliance 740-790 EAST GREEN STREET MIXED-USE PROJECT
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with the Pasadena Municipal Code Section 10.64.020, the Project would develop a TDM program meeting the criteria addressed above.
For these reasons, the Project would not conflict with the City’s policies related to circulation b) Would the project conflict or be inconsistent with CEQA Guidelines section 15064.3, subdivision (b)?
Less Than Significant Impact with Mitigation Incorporated . CEQA Guidelines Section 15064.3, subdivision (b), focuses on newly adopted criteria (VMT) adopted pursuant to SB 743 for determining the significance of transportation impacts. On November 3, 2014, the City of Pasadena City Council adopted a resolution to replace the City’s transportation performance measures with five ne w Transportation Performance Measures and new thresholds of significance to determine transportation and traffic impacts under CEQA. The new performance measures and CEQA thresholds are consistent with the City’s adopted General Plan and SB 743, and include VMT per capita, vehicle trips (VT) per capita, proximity and quality of bicycle network, proximity and quality of transit network, and pedestrian accessibility. These performance measures align with the sustainability goals of the General Plan by evaluating the efficiency of projects by analyzing the per capita length and number of trips associated with changes in land use.
With the expanded emphasis on sustainability and a continued focus on livability, the proposed performance measures assist in determining how to balance travel modes as well as understanding the mobility needs of the community. Table 2.17-1 summarizes the City’s thresholds for determining the significance of project-related transportation impacts under CEQA.
Table 2.17-1. Transportation Performance Metrics for CEQA Thresholds of Significance Metric Description CEQA Impact Threshold
1. VMT Per
Capita
Vehicle Miles Traveled (VMT) in the City
of Pasadena per service population
(population + jobs).
An increase over existing Citywide VMT per
Capita of 22.6
2. VT Per Capita Vehicle Trips (VT) in the City of
Pasadena per service population
(population + jobs).
An increase over existing Citywide VMTVT per
Capita of 2.8 VMVT
3. Proximity and
Quality of
Bicycle
Network
Percent of service population (population
+ jobs) within a quarter mile of bicycle
facility types.
31.7%
Any decrease in existing citywide of service
population (population + jobs) within a quarter
mile of levels 1 & 2 bike facilities.
4. Proximity and
Qualityof
Transit
Network
Percent of service population (population
+ jobs) located within a quarter mile of
transit facility types.
66.6%
Any decrease in existing citywide service
population (population + jobs) within a quarter
mile of levels 1 & 2 transit facilities.
5. Pedestrian
Accessibility
The Pedestrian Accessibility Score uses
the mix of destinations, and a network-
based walk shed to evaluate walkability
Any decrease in the Citywide Pedestrian
Accessibility Score
Source: Pasadena Department of Transportation 2015
Notes:
Service population = population + jobs
Level 1 bicycle facility types (advanced facilities) consist of bicycle paths, multipurpose paths, and cycle tracks/protected bicycle lanes Level 2 bicycle facility types (dedicated facilities) consist of buffered bicycle lanes, bicycle lanes, and bicycle boulevards 740-790 EAST GREEN STREET MIXED-USE PROJECT
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In the CEQA Evaluation TIA, the Project’s impacts analyses are based on the City’s calibrated travel demand forecasting model (TDF), which was bui lt on SCAG’s regional model. The City’s TDF model simulates traffic levels and travel patterns for the City. The model consists of input files that summarize the City’s land uses, street network, travel characteristics, and other key factors. Using this da ta, the model performs a series of calculations to determine the number of trips generated, the beginning and ending location of each trip, and the route taken by the trip.
The following analyses are findings of the proposed Project’s impacts on the transportation system using the calibrated TDF model. The results are based on the Project’s vehicular and non-vehicular trip making characteristics, trip length, and its interaction with other surrounding/citywide land uses, and the City’s transportation network using TransCAD software. Moreover, the findings are based on the assumptions presented in Attachment B to the Final MND.
VMT per Capita Analysis
Considering the demolition of the existing commercial office structures on the site and constructing 263 residential units, 16,481 16,229 square feet of commercial office space with a pocket park and subterranean parking, the TDF model calculation results determined that the Project’s population would increase while number of employees would decrease. The TDF model calculations determined the Project’s net capita (population + employment) is 310 332 and the Project’s VMT is 5,711 3,418. As such, the incremental VMT per capita change is 18.5 10.320, which does not exceed the adopted threshold of significance under the VMT per capita of 22.6. Therefore, impacts related to VMT would be less than significant.
VT Analysis
The TDF model calculation results determined that the Project’s net capita is 310 332 (population + employment) and the Project’s VT is 1,187 917. As such, the incremental VT per capita change is 3.8
2.821, which indicates that the Project’s incremental VT per capita change would not exceed the adopted threshold of significance of 2.8 VT per capita. Therefore , impacts related to VT would be potentially significant, before mitigation less than significant.
MM TRA-1 is required designed to reduce the Project’s VT per capita and requires the Project Applicant to develop and implement a TDM Plan that results in a reduction of the project’s vehicle trips by a minimum of 27% or implements a mix of uses that achieves a minimum of 27% reduction of VT as the Project described in the Revised IS/MND does. Implementation of MM-TRA-1, would ensure that the proposed Project would not conflict with the City’s policies related to circulation.
Proximity and Quality of Bicycle Network Analysis
As shown in Table 2.17-2, any decrease in the existing citywide service population percentage of 31.7% within a quarter mile of bicycle facilities would be a significant impact. Currently, a Level 3 bike route along Cordova Street is the only marked bike facility in the vicinity of the Project, as mentioned in description of existing transportation network in the TIA. There is a future cycle track proposed along Union Street and bikes lanes as part of future road diet proposed along Cordova Street. The TDF model
20 VMT per capita is calculated by dividing the Project’s VMT (5,711 3,418) by the Project’s net capita (310 332) 21 VT per capita is calculated by dividing the Project’s VT (1,187 917) by the Project’s net capita (310 332) 740-790 EAST GREEN STREET MIXED-USE PROJECT
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results indicated that the citywide service population with access to Level 1 and 2 bicycle facilities would be 31.7% after implementation of the Project. Therefore, impacts to the existing bicycle network would be less than significant.
Proximity and Quality of Transit Network Analysis
As shown in Table 2.17-2, any decrease in the existing citywide service population percentage of 66.6% within a quarter mile of transit faci lities would indicate a significant impact. With the Metro Gold Line station at Lake Avenue near I-210, and various bus stations (i.e., Metro, Foothill Transit, and Pasadena Transit) in close proximity to the Project site, the TDF model results indicated t hat the citywide service population with access to transit facilities would be 66.8% after implementation of the Project. Therefore, impacts related to the proximity and quality of the transit network would be less than significant.
Pedestrian Accessibility Analysis
The Pedestrian Accessibility Score is a count of the number of land use types accessible to a Pasadena resident or worker in a given Transportation Analysis Zone (TAZ) within a five-minute walk. As shown in Table 2.17-2, any decrease in the calculated citywide Pedestrian Accessibility Score of greater than 3.9 would indicate a significant impact. T he TDF model results indicated that the citywide Pedestrian Accessibility Score would be 3.88 with the addition of the Project. Therefore, impacts related to pedestrian accessibility would be less than significant.
The results of the above analysis are demonstrated in Table 2.17-2.
Table 2.17-2 Transportation Performance Metrics for the Project Metric
Significant
Impact Cap
Incremental change
(Existing +Project)
Significant Impact
Before Mitigation
1. VMT Per Capita >22.6 18.5 10.3 No
2. VT Per Capita >2.8 3.8 2.8 Yes No
3. Proximity and Quality of
Bicycle Network
<31.7% 31.7 No
4. Proximity and Quality of
Transit Network
<66.6% 66.8 No
5. Pedestrian Accessibility <3.9 3.9 No
Source: Appendix G Attachment B of the Final MND
The proposed Project is not expected to exceed the VT per capita CEQA threshold causing a potentially significant impact. Therefore, the following mitigation is proposed required to reduce the Project’s vehicle trips impact to a less than significant level. With the implementation of MM-TRA-1, the Project’s impacts related to CEQA Guidelines section 15064.3, would be less than significant.
MM-TRA-1 To reduce the original Project’s VT per capita, the Project A pplicant/Developer shall either develop and implement a Transportation Demand Management (TDM) Plan that includes strategies to reduce the Project’s vehicle trips by a minimum of 2 7% or implement a mix of uses that achieves a minimum of 27% reduction of VT as the Project describe d in the Revised IS/MND does. If the TDM Plan approach is undertaken as a result of the original Project, then Programmatic programmatic 740-790 EAST GREEN STREET MIXED-USE PROJECT
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strategies to reduce VT per capita shall complement City’s Trip Reduction Ordinance minimum requirements and shall include, but not necessarily be limited to, the following:
• Unbundled parking for the residential use;
• The Project Applicant/Developer shall purchase 121 Metro passes and offer them to interested residents at 50% discount for five consecutive years from the issuance of Certificate of Occupancy.
• The Project Applicant/Developer shall provide an Annual TDM Survey beginning one year after the issuance of Certificate of Occupancy to demonstrate the minimum 27% reduction of Project vehicular trips per capita is maintained. c) Would the project substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)? Less Than Significant Impact. The proposed Project and its impact on vehicle circulation has been evaluated by the City’s Department of Transportation. The proposed Project would involve new driveways and curb/gutter construction to accommodate the driveway on South Oak Knoll Avenue and the driveway and loading/unloading dock on South Hudson Avenue. The new driveways would be used by the residents and patrons of the commercial office/retail uses, and loading/unloading dock users. Without adequate sight distances, the new driveway could pose a hazard to pedestrians walking along the sidewalk in front of the driveway. However, a number of conditions of approval would be imposed on the Project that would minimize safety hazards to the extent feasible. Conditions would include design requirements related to safety along roadways surrounding the Project, such as loading/unloading location requirements, driveway width, minimum distance from driveway to intersection, and/or other measures to ensure that the Project circulation design would not be hazardous to traffic circulation either within the Project site or the Project vicinity. In addition, the Project’s circulation design meets the City’s engineering standards. Therefore, the proposed Project would not increase hazards due to a design feature or incompatible use. The Project’s impact due to increase in hazards due to geometric design feature would be less than significant. d) Would the project result in inadequate emergency access? Less Than Significant Impact. During construction of the proposed Project, it is anticipated that some of the construction activities may require short-term partial or full road closures of travel lanes along Oak Knoll Avenue or Hudson Avenue. As discussed in the Memorandum from the City of Pasadena Department of Public Works (DPW) (Appendix H-1), as part of the Project, the Project applicant would submit a Construction Staging and Traffic Management Plan (CSTMP) to DPW that would show the impact of various construction stages on the public right -of-way, including all street occupations, lane closures, detours, staging areas, and routes of construction vehicles entering and exiting the construction site. An occupancy permit would be obtained from the DPW for the occupation of any traffic lane, parking lane, parkway, or any other public right -of-way. All lane closures would be done in accordance with the Manual of Uniform Traffic Control Devices (MUTCD) and California Supplement and other requirements specified by DPW in the Project’s conditions of approval. With implementation of the CSTMP, impacts to emergency access during construction of the Project would be less than significant.
Once operational, vehicular access to the Project would be via a driveway along Oak Knoll Avenue that would lead to the subterranean parking garage. The driveway would operate as a full -access providing 740-790 EAST GREEN STREET MIXED-USE PROJECT
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entry and exit to the Pr oject. The parking garage entrance, if gated, must be at least 20 feet back from property line to accommodate queuing space for one car length. Project ingress and egress would comply with all building, fire, and safety codes and final plans would be subject to review and approval by the City’s Public Works and Transportation Departments, the Building Division, and the Fire Department. No permanent lane closures or obstructions that could impede emergency response to or from the Project site from surrounding streets would occur as a result of the proposed Project during operation. Impacts to emergency access would be less than significant.
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2.18 TRIBAL CULTURAL RESOURCES
Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Would the project cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is:
a) Listed or eligible for listing in the California
Register of Historical Resources, or in a local
register of historical resources as defined in
Public Resources Code section 5020.1(k), or
b) A resource determined by the lead agency, in its
discretion and supported by substantial
evidence, to be significant pursuant to criteria
set forth in subdivision (c) of Public Resources
Code Section 5024.1. In applying the criteria set
forth in subdivision (c) of Public Resource Code
Section 5024.1, the lead agency shall consider
the significance of the resource to a California
Native American tribe?
a) Would the project cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is:
i) Listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code section 5020.1(k)?
Less Than Significant Impact. No previously recorded arc haeological resources of Native American origin or Tribal Cultural Resources (TCR) listed in the California Register of Historical Resources or a local register were identified within the Project site through searches of the CHRIS records. Although the NAHC’s review of the SLF was positive, no resource -specific information was provided regarding eligibility in the CRHR or local register . Further, no TCRs have been identified by California Native American tribes as part of the City’s AB 52 notification and consultation process. Therefore, the proposed Project would not adversely affect tribal cultural resources that are listed or eligible for listing in the state or local register. Therefore, impacts would be less than significant. 740-790 EAST GREEN STREET MIXED-USE PROJECT
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ii) A resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code Section 5024.1. In applying the criteria set forth in subdivision (c) of Public Resour ce Code Section 5024.1, the lead agency shall consider the significance of the resource to a California Native American tribe? Less Than Significant Impact with Mitigation Incorporated. There are no resources in the Project site that have been determined b y the City to be significant pursuant to the criteria set forth in Public Resources Code Section 5024.1. Further, no specific TCRs were identified in the Project site by the NAHC, by California Native American tribes, or by the City as part of the AB 52 no tification and consultation process. On January 2, 2020 , the City sent notification of the proposed Project to all California Native American tribal representatives that have requested notifications from the City pursuant to AB 52. The Gabrieleno Band of Mission Indians, Kizh Nation, responded on January 7, 2020, affirming the Project lies within their Ancestral Tribal Territory and provided a list of mitigation measures. During subsequent communication, the City and Kizh Nation had scheduled a meeting for consultation on October 15, 2020. On September 4, 2020, the City sent an email to Kizh Nation indicating the Project Applicant would abide by the mitigation measures previously provided on January 7, 2020. The City received email correspondence from Kizh Nation on September 4, 2020 indicating that since the Project Applicant had agreed to abide by the proposed mitigation measures , there would be no need for consultation and AB 52 consultation is considered to be completed.
Due to the absence of previously recorded tribal cultural resources within the Project site and because no specific tribal cultural resources have been identified by California Native American tribes through the AB 52 consultation process, the City has determined that no known tribal cultural resources are present in the Project site. However, the correspondence from Kizh Nation suggests that there is some potential for unknown subsurface tribal cultural resources to be impacted by the project. In the event that unknown subsurface tribal cultural resources are uncovered during construction ground disturbance, and such resources are not identified and avoided or properly treated, a potentially significant impact could result.
As such, along with MM -CR-1 for WEAP training, mitigation measure MM -TCR-1 through MM-TCR-8 have been set forth to protect tribal cultural resources, in the event that any are discovered during Project construction. Upon implementation of MM -TCR-1 through MM -TCR-8, impacts would be less than significant with mitigation incorporated.
MM-TCR-1 The Project Applicant shall be required to retain and compensate for the services of a tribal monitor/consultant who is both approved by the Gabrieleño Band of Mission Indians- Kizh Nation Tribal Government and is listed under the Native American Heritage Commission’s (NAHC’s) Tribal Contact List for the area of the Project location. This list is provided by the NAHC. The monitor/consultant will only be present on site during the construction phases that involve ground-disturbing activities. Ground-disturbing activities are defined by the Gabrieleño Band of Mission Indians-Kizh Nation as activities that may include, but are not limited to, pavement removal, pot -holing or auguring, grubbing, tree removals, boring, grading, excavation, drilling, and trenching, within the Project area. The tribal monitor/consultant will complete daily monitoring logs that will pro vide descriptions of the day’s activities, including construction activities, locations, soil, and any cultural materials identified. The on -site monitoring shall end when the Project site grading and excavation activities are completed, or when the tribal representatives and 740-790 EAST GREEN STREET MIXED-USE PROJECT
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monitor/consultant have indicated that the site has a low potential for impacting tribal cultural resources.
MM-TCR-2 Upon discovery of any archaeological resources, cease construction activities in the immediate vicinity of the find until the find can be assessed. All archaeological resources unearthed by Project construction activities shall be evaluated by the qualified archaeologist and tribal monitor/consultant approved by the Gabrieleño Band of Mission Indians – Kizh Nation. If the resources are Native American in origin, the Gabrieleño Band of Mission Indians – Kizh Nation shall coordinate with the landowner regarding treatment and curation of these resources. Typically, the tribe will request reburial or preservation for educational purposes. Work may continue on other parts of the Project while evaluation and, if necessary, mitigation takes place ( California Environmental Qualit y Act [ CEQA] Guidelines Section15064.5 [f]). If a resource is determined by the qualified archaeologist to constitute a “historical resource” or “ unique archaeological resource,” time allotment and funding sufficient to allow for implementation of avoidance measures, or appropriate mitigation, must be available. The treatment plan established for the resources shall be in accordance with CEQA Guidelines Section 15064.5(f) for historical resource s and for unique archaeological resources.
MM-TCR-3 Preservation in place (i.e., avoidance) is the preferred manner of treatment. If preservation in place is not feasible, treatment may include implementation of archaeological data recovery excavations to remove the resource along with subsequent laboratory processing and analysis. Any historic archaeological material that is not Native American in origin shall be curated at a public, non -profit institution with a research interest in the materials, such as the Natural History Museum of Los Angeles County or the Fowler Museum, if such an institution agrees to accept the material. If no institution accepts the archaeological material, they shall be offered to a local school or historical society in the area for educational purposes.
MM-TCR-4 Native American human remains are defined in Public Resources Code (PRC) 5097.98 (d)(1) as an inhumation or cremation, and in any state of decomposition or skeletal completeness.
Funerary objects, called associated grave goods in PRC 5097.98, are also to be treated according to this statute. Health and Safety Code 7050.5 dictates that any discoveries of human skeletal material shall be immediately reported to the County Coroner and excavation halted until the coroner has determined the nature of the remains. If the coroner recognizes the human remains to be those of a Native American or has reason to believe that they are those of a Native American, he or she shall contact, by telephone within 24 hours, the Native American Heritage Commission, and PRC 5097.98 shall be followed.
MM-TCR-5 Upon discovery of human remains , the tribal and/or archaeological monitor/ consultant/consultant will immediately divert work at minimum of 150 feet and place an exclusion zone around the burial. The monitor/consultant(s) will then notify the tribe, the qualified lead archaeologist, and the construction manager who will call the coroner. Work will continue to be diverted while the coroner determines whether the remains are Native American. The discovery is to be kept confidential and secure to preve nt any further disturbance. If the finds are determined to be Native American, the coroner will notify the 740-790 EAST GREEN STREET MIXED-USE PROJECT
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Native American Heritage Commission as mandated by state law who will then appoint a Most Likely Descendant.
MM-TCR-6 If the Gabrieleño Band of Mission Indians – Kizh Nation is designated as the Most Likely Descendant, the following treatment measures shall be implemented. To the tribe, the term “human remains” encompasses more than human bones. In ancient as well as historic times, tribal traditions i ncluded, but were not limited to, the burial of funerary objects with the deceased and the ceremonial burning of human remains. These remains are to be treated in the same manner as bone fragments that remain intact. Associated funerary objects are objects that, as part of the death rite or ceremony of a culture, are reasonably believed to have been placed with individual human remains either at the time of death or later; other items made exclusively for burial purposes or to contain human remains can also be considered as associated funerary objects.
MM-TCR-7 Prior to the continuation of ground -disturbing activities, the land owner shall arrange a designated site location within the footprint of the Project for the respectful reburial of the human remains and/or ceremonial objects. In the case where discovered human remains cannot be fully documented and recovered on the same day, the remains will be covered with muslin cloth and a steel plate that can be moved by heavy equipment placed over the excavation opening to protect the remains. If this type of steel plate is not available, a 24- hour guard should be posted outside of working hours. The tribe will make every effort to recommend diverting the project and keeping the remains in situ and protected. If t he project cannot be diverted, it may be determined that burials will be removed. The tribe will work closely with the qualified archaeologist to ensure that the excavation is treated carefully, ethically and respectfully. If data recovery is approved by t he tribe, documentation shall be taken which includes at a minimum detailed descriptive notes and sketches. Additional types of documentation shall be approved by the tribe for data recovery purposes. Cremations will either be removed in bulk or by means as necessary to ensure complete recovery of all material. If the discovery of human remains includes four or more burials, the location is considered a cemetery, and a separate treatment plan shall be created. Once complete, a final report of all activities is to be submitted to the tribe and the Native American Heritage Commission. The tribe does NOT authorize any scientific study or the utilization of any invasive diagnostics on human remains.
Each occurrence of human remains and associated funerary objects will be stored using opaque cloth bags. All human remains, funerary objects, sacred objects , and objects of cultural patrimony will be removed to a secure container on site if possible. These items should be retained and reburied within 6 months of recov ery. The site of reburial/repatriation shall be on the Project site but at a location agreed upon between the tribe and the landowner at a site to be protected in perpetuity. There shall be no publicity regarding any cultural materials recovered.
MM-TCR-8 Professional Standards: Archaeological and Native American monitoring and excavation during construction projects will be consistent with current professional standards. All feasible care to avoid any unnecessary disturbance, physical modification, or sepa ration of human remains and associated funerary objects shall be taken. Principal personnel 740-790 EAST GREEN STREET MIXED-USE PROJECT
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must meet the Secretary of the Interior standards for archaeology and have a minimum of 10 years of experience as a principal investigator working with Native Ameri can archaeological sites in Southern California. The Qualified Archaeologist shall ensure that all other personnel are appropriately trained and qualified.
2.19 UTILITIES AND SERVICE SYSTEMS
Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Would the project:
a) Require or result in the relocation or
construction of new or expanded water,
wastewater treatment, or storm water drainage,
electric power, natural gas, or
telecommunications facilities, the construction or
relocation of which could cause significant
environmental effects?
b) Have sufficient water supplies available to serve
the project and reasonably foreseeable future
development during normal, dry, and multiple dry
years?
c) Result in a determination by the wastewater
treatment provider, which serves or may serve the
project that it has adequate capacity to serve the
project’s projected demand in addition to the
provider’s existing commitments?
d) Generate solid waste in excess of State or local
standards, or in excess of the capacity of local
infrastructure, or otherwise impair the attainment of
solid waste reduction goals?
e) Comply with federal, state, and local management
and reduction statutes and regulations related to
solid waste?
a) Would the project require or result in the relocation or construction of new or expanded water, wastewater treatment , or storm water drainage, electric power, natural gas, or telecommunications faci lities, the construction or relocation of which could cause significant environmental effects?
Less Than Significant Impact.
Water. Water in the City is provided by the Pasadena Water and Power (PWP) Department. According to the City’s 2015 UWMP , l ocal wa ter supplies include local water from the Raymond Basin (approximately 40%) and purchased imported water ( approximately 60%) from the Metropolitan Water District (MWD) of Southern California, who sources water from the State Water Project (SWP) and the Colorado River Aqueduct (UWMP 2015).
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The proposed Project would connect to the existing water utility infrastructure, the environmental impacts of which are assessed throughout this IS/MND. Additionally, the proposed Project would be subject to standard connection fees, as legislated by the Pasadena Municipal Code, Section 13.20.080, Water Main Charge. Per Section 13.20.080, the proposed Project would either be charged to tie -in to the existing water mains, or, if/where new water mains are required, would be charged the total cost (either directly or through an in-lieu fee) of installing the required new water mains). PWP has indicated it can serve the Project (Appendix H-2). Additionally, PWP has stated, if it is determined that a water main must be upgraded due to size, age, pressure deficiencies, and/or the integrity of the existing water main; the upgrade will be paid for by the owner/developer. A deposit will be requested for the water main design and a cost estimate will be provided to the Project Applicant for the new water service installations, main design, and main construction (Appendix H-2). With payment of these co nnection fees, water needs of the proposed Project could be met by existing water utility infrastructure and is not anticipated to require or result in the relocation or construction of new or expanded water facilities, the construction or relocation of wh ich could cause significant environmental effects . Impacts would be less than significant. No mitigation is required.
Wastewater. The City’s Sewer System Management Plan serves as the foundational planning document, through which the City manages and oper ates sewer system demand, supply, and associated infrastructure. Sewer lines in the City convey wastewater into trunk lines that are maintained by the Los Angeles County Sanitation District (LACSD), which provides much of the primary sewer trunk line system and treats local wastewater (City of Pasadena 2006). According to the Pasadena Sewer Maps database, the proposed project is served by existing 8-inch, Vitrified Clay Pipe (VCP) sewer lines within the Green Street ROW, as well as an 18 -inch, VCP sewer tru nk line within the Oak Knoll Avenue ROW (City of Pasadena 2019c). Wastewater would then flow to the LACSD Chapel Avenue Trunk Sewer Section 2, located in Los Robles Avenues north of Mission Street (LACSD 2020). The LACSD 15 -inch diameter trunk sewer has a capacity of 8.1 million gallons per day and conveyed a peak flow of
0.2 million gallons per day when last measured in 2015 (LACSD 2020). Therefore, this trunk sewer line has adequate capacity to accommodate the Project’s wastewater flows.
The proposed Project would tie-in to the existing 8-inch and 18-inch VCP sewer lines in Green Street and Oak Knoll Avenue , the environmental impacts of which are assessed throughout this IS/MND . Per Section 4.53, Sewer Facility Charge, of the Pasadena Municipal Code, the Applicant would be required to pay into the ‘Sewer Facility Charge Fund,’ which expends the sewer facility connection charges required by new development towards sewer infrastru ctural improvements. Additionally, per the California Health and Safety Code, LACSD may require the Applicant to pay a connection fee for the use of LACSD’s Sewerage System prior to project approval. With adherence to the Pasadena Municipal Code, Section 4.53, the proposed Project would have paid its fair share contribution towards any necessary sewer infrastructure upgrades, including those required as a result of the proposed Project. Any separate sewer system upgrades undertaken by the City using these fees would be subject to independent environmental review, and, as such, the proposed Project would have a less than significant impact to wastewater infrastructure.
Stormwater. The proposed Project is not expected to generate increased stormwater runoff. As described under Section 2.10, the drainage patterns of the Project site would not substantially change relative to existing conditions. As previously discussed under Section 2.10, all development and redevelopment projects must comply with the latest LI D Standards Manual, which complies with the 740-790 EAST GREEN STREET MIXED-USE PROJECT
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requirements of the NPDES 2012 MS4 Permit. The LID Standards Manual provides guidance for the implementation of stormwater quality control measures in new development and redevelopment projects with the intention of improving water quality and mitigating potential water quality impacts from stormwater and non-stormwater discharges (LADPW 2014). Project design, construction, and operation would be completed in accordance with the LID Standards Manual, which mandates completion of a LID Plan, as does the City of Pasadena . The LID Plan would use site design and stormwater management in order to maintain the site’s pre-development runoff rates and volumes. The goal of the LID Plan would be to mimic the site’s pre-development hydrology by using design techniques that filter, store, evaporate, and detain runoff close to the source of rainfall. Compliance with state and local regulations would reduce the peak volume of stormwater runoff discharged into the City’s storm dra in system and would ensure that stormwater is retained on-site, to the extent feasible. As such, the proposed Project would not require the construction or expansion of off-site storm water drainage facilities, as the project would not contribute a substantial amount of new stormwater runoff relative to existing conditions.
Solid Waste. The California Solid Waste Reuse and Recycling Access Act of 1991 (AB 341) declared that cities and counties must divert 50% of all solid waste by 2000 and aims to reduce 75% of all solid waste by 2020, through source reduction, recycling and composting activities, as well as, provide adequate areas for collecting and loading recyclable materials. Under the California Solid Waste Reuse and Recycling Access Act of 1991, each local agency must adopt an ordinance for collecting and loading recyclable materials.
The City of Pasadena reached a 73% reduction in solid waste as early as 2010 and is moving towards zero waste as implemented by the Zero Waste Strategic Plan, which is anticipated to accomplish a Citywide minimum of 87% solid waste diversion by 2040 (City of Pasadena 2019d). Additionally, the Pasadena Municipal Code requires that 75% of construction and demolition debris be recycled.
Based on the CalEEMod solid waste genera tion rates, the proposed Project would generate approximately 222.76 tons/year (602.86 cubic yards/year22) (Appendix A).23 Solid waste generated by the proposed Project would be collected by and transported to a local or regional landfill. The City primarily disposes of solid waste at four landfills, including Scholl Canyon Landfill, Sunshine Canyon Landfill, El Sobrante Landfill, and Chiquita Canyon Landfill. As of 2015, these landfills had a combined remaining capacity of 297,000,000 cubic yards, of which the proposed Project would represent a nominal contribution (City of Pasadena 2015a). For instance, assuming the Project has a lifespan of 100 years, the solid waste generation would be 60,286, which would represent only 0.02% of the remaining capacity of the four landfills serving the City. Additionally, required compliance with Chapter 8.62 of the Pasadena Municipal Code w ould reduce the project’s solid waste generation during construction and demolition activities. As such, the proposed Project would not require or result in the need for new or expanded solid waste treatment facilities, the construction or relocation of wh ich could cause significant environmental effects.
Electricity and Natural Gas. PWP provides electricity to the City, and operates one power plant, Glenarm Power Plant, within the City’s SOI. Both underground and overhead electrical distribution lines are present within the City streets and yard easements. According to the 2018 Pasadena Water and
22 This assumes landfill waste has a density of 739 pounds. per cubic yard (Waste 360 2020). Using a conversion rate of 2,000 pounds = 1 ton, the 222 tons/ year is equivalent to 444,000445,520 pounds./year. Thus, 445,520 pounds/year ÷ 739 pounds per cubic yard = 602.86 cubic yards per year.
23 The analysis in this IS/MND represents a conservative analysis since the revisions to the Project Description, as shown in Section I of this document , include a decrease of approximately 2,000 square feet of office use, which would result in an incremental decrease in operational impacts accordingly. 740-790 EAST GREEN STREET MIXED-USE PROJECT
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Power Integrated Resource Plan (IRP), PWP delivers about 1.1 million megawatt-hours (MWh) of energy annually to 65,000 retail customers, with an historical peak load of about 320 MW. To serve these customers, over time PWP has assembled a portfolio of generating resources, including gas-fired, large and small hydro, coal, nuclear, solar, wind, geothermal, an d landfill gas (City of Pasadena 2018 b). In addition to the Glenarm Power Plant, the City receives power from numerous other sources, including the Magnolia Power Plant (Burbank, CA), the Intermountain Power Plant (Lynndyl, UT), the Antelope Big Sky Ranch Solar Project (Lancaster, CA), the Summer Solar Project (Lancaster, CA), the Columbia II Solar Project (Mojave, CA), the Kingbird Solar Project (Rosamond, CA), the Windsor Reservoir Solar project (Pasadena, CA), the Milford Wind Corridor (Milford, UT), the Azusa Hydroelectric Plant (Azusa, CA), the Hoover Uprating Hydroelectric Project (Black Canyon, NV), and several landfill gas -to-energy plants (City of Pasadena 2019e). Although the City currently receives electric power from a variety of sources, the IRP establishes the City’s conformance with SB 250, whereby the City aims to acquire 33 percent of its energy for retail loads from renewable resources by 2020, and 50 percent by 2030 (City of Pasadena 2018).
According to the IRP, the City has a total resource of Capacity of 423 MW (i.e. 103 MW remaining; City of Pasadena 2018)). Although some electricity would be needed for construction of the proposed Project, power consumption would be minimal and would be both short -term and tem porary in nature. U pon Project implementation, electricity demand at the P roject site would increase by 1,155,868 kBTU per year. (Appendix A) 24 For comparison, in 2018 the total residential and nonresidential electricity use in Pasadena Water and Power’s service area was 1,040,640,000 kilowatt-hours (CEC 2020). The Project’s electricity consumption would represent a 0.13% of the PWP’s existing demand (2018) and therefore represent a less than significant impact to electrical energy resources. Thus, the Project would not require expansion of existing facilities. PWP has indicated the existing electrical service would need to be demolished prior to construction and would require coordination ( Appendix H-3). However, the impacts associated with the demolition of existing facilities within the Project site have been analyzed throughout this IS/MND and would not result in significant environmental impacts. As such, the proposed Project would not require or result in of the need for new or expanded electric power infrastructure , t he construction or relocation of which could cause significant environmental effects.
Southern California Gas Company (SoCalGas) provides natural gas to the City via distribution lines and laterals within the City streets and easements. Existing gas lines would be protected in place during construction-related activities, and the proposed Project would tie -in to existing natural gas utility . The City’s General Plan EIR estimates that SoCalGas has sufficient planned natural gas supplies to accommodate the buildout of the City’s General Plan, which is expected to add approximately 9.6 million therms of demand on natural gas resources (City of Pasadena 2015a). As such, no off-site improvements for natural gas infrastructure are anticipated with the implementation of the proposed Project, which falls well within the parameters of the General Plan.
Telecommunication Facilities. Services within the City are provided by AT&T, Charter Communications, and satellite television services. The proposed Project would not require new or expanded telecommunication facilities.
24 The analysis in this IS/MND represents a conservative analysis since the revisions to the Project Description, as shown in Section I of this document , include a decrease of approximately 2,000 square feet of office use, which would result in an incremental decrease in operational impacts accordingly. 740-790 EAST GREEN STREET MIXED-USE PROJECT
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In summary, the proposed Project would adhere to state and local legislation pertaining to the payment of impact fees to accommodate the Project’s fair -share contribution to increased demand for utility infrastructure and services. Moreover, the Project would not result in the need for new or expanded water, wastewater treatment, or storm water drainage, electric power, natural gas, or telecommunications facilities. Therefore, impacts in this regard are less than significant and no mitigation is required. b) Would the project have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry, and multiple dry years? Less Than Significant Impact. Water in the City is provided by PWP. According to the City’s 2015 UWMP, l ocal water supplies include local water from the Raymond Basin ( approximately 40%) and purchased imported water (approximately 60%) from the Metropolitan Water District (MWD) of Southern California, who sources water from the State Water Project (SWP) and the Colorado River Aqueduct (UWMP 2015). The 2015 UWMP projects a total available water supply of 38,291 acre -feet per year (AFY) in the planning horizon of 2040 as shown below in Table 2.19-1.
Table 2.19-1. Projected Water Supply to the PWP through 2040 Water Supply Detail
Reasonably Available Volumes
2020 2025 2030 2035 2040
Purchased (Imported
Water)
Available from the MWD 20,934 20,986 21,237 21,529 21,617 Groundwater Decreed groundwater and
spreading credits
12,684 12,684 12,684 12,684 12,684
Recycled Water Groundwater Recharge 0 0 930 930 930
Total Potable Supplies 33,618 33,670 34,851 35,143 35,231 Recycled Water Includes non-potable sources
such as tunnel water
700 1,100 2,280 2,670 3,060
Total Potable and Non-Potable Supplies 34,318 34,770 37,813 37,813 38,291 Source: City of Pasadena 2016b
The 2015 UWMP also considers water supply constraints (i.e. climate change, facility constraints, etc.) that have the potential to impact the volume of water available in normal, single-dry, and multiple-dry year scenarios. Table 2.19-2 below shows the normal year, single-dry year, and multiple-dry year supply and demand comparisons through the planning horizon year of 2040.
Table 2.19-2. Normal Year, Single Dry Year, and Multiple Dry Year Supply and Demand Comparisons through 2040 (AFY)
2020 2025 2030 2035 2040
Normal Year
Groundwater for Pumping 12,684 12,684 12,684 12,684 12,684 Imported Water 20,934 20,986 21,237 21,529 21,617
Recycled Water 700 1,100 3,210 3,600 3,990
Supply Totals 34,318 34,770 37,131 37,813 38,291
Demand Totals 32,586 32,611 32,719 32,891 33,000
Difference (Placed in Storage) 1,732 2,159 4,412 4,922 5,291 Single Dry Year
Groundwater for Pumping 10,964 10,964 10,964 10,964 10,964 740-790 EAST GREEN STREET MIXED-USE PROJECT
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Table 2.19-2. Normal Year, Single Dry Year, and Multiple Dry Year Supply and Demand Comparisons through 2040 (AFY)
2020 2025 2030 2035 2040
Imported Water 20,934 20,986 21,237 21,529 21,617
Recycled Water 700 1,100 3,210 3,600 3,990
Supply Totals 32,598 33,050 35,411 36,093 36,571
Demand Totals 32,586 32,611 32,719 32,891 33,000
Difference (Placed in Storage) 12 439 2,692 3,202 3,571 Multiple Dry Years (Year 1)
Groundwater for Pumping 10,964 10,964 10,964 10,964 10,964 Imported Water 20,934 20,986 21,237 21,529 21,617
Recycled Water 700 1,100 3,210 3,600 3,990
Supply Totals 32,598 33,050 35,411 36,093 36,571
Demand Totals 32,586 32,611 32,719 32,891 33,000
Difference (Placed in Storage) 12 439 2,692 3,202 3,571 740-790 EAST GREEN STREET MIXED-USE PROJECT
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Table 2.19-2. Normal Year, Single Dry Year, and Multiple Dry Year Supply and Demand Comparisons through 2040 (AFY)
2020 2025 2030 2035 2040
Multiple Dry Years (Year 2)
Groundwater for Pumping 10,964 10,964 10,964 10,964 10,964 Imported Water 20,934 20,986 21,237 21,529 21,617
Recycled Water 700 1,100 3,210 3,600 3,990
Supply Totals 32,598 33,050 35,411 36,093 36,571
Demand Totals 32,586 32,611 32,719 32,891 33,000
Difference (Placed in Storage) 12 439 2,692 3,202 3,571 Source: City of Pasadena 2016b
AFY = acre feet per year
As shown in Table 2.19-2, the PWP projects having adequate water supplies to meet projected water demand in the City through the year 2040 (City of Pasadena 2016b). The proposed Project would connect to the existing water utility infrastructure . According to the CalEEMod est imates (see Section 2.3 and Appendix A for details), the proposed P roject is anticipated to use approximately 21.24 million gallons per year, compared to the existing uses onsite which use approximately 12.34 million gallons per year.
The Project would represent an increase in approximate 8.9 million gallons year (27 acre-feet per year).25 As previously described in Table 1 -2, Project construction would be completed in the Year 2025. The UWMP shows that the 2025 excess water supply is 439 acre-feet per year under the single dry year and multiple dry years scenarios, which is larger than the Project’s net increase of 27 acre -feet per year .
Additionally, the proposed Project is within the growth projections assumed in the UWMP; therefore, the forecasted 439 acre-feet per year excess remains after accounting for cumulative growth within the City, including development of the proposed Project. Further, while the proposed Project would result in an increase in water demand from increa sed on-site residential and commercial office use compared to existing conditions, the proposed Project would be required to comply with P asadena Municipal Code water conservation measures which would further reduce water demand associated with the proposed Project. As such, the proposed Project’s water demand can be met by existing water supplies. Impacts would be less than significant. No mitigation is required. c) Would the project result in a determination by the wastewater treatment provider, w hich serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments? Less Than Significant Impact. Sewer lines in the City convey wastewater into trunk lines that are maintained by the LACSD, which provides much of the primary sewer trunk line system and treats local wastewater (City of Pasadena 2006). The sewer system in Pasadena totals approximately 350 miles of sewer pipelines (City of Pasadena 2015a). According to the Pasadena Sewer Maps database, the proposed project is served by existing 8-inch, VCP sewer lines within the Green Street ROW, as well as an 18-inch, VCP sewer trunk line within Oak Knoll Avenue ROW (City of Pasadena 2019c). The majority
25 The analysis in this IS/MND represents a conservative a nalysis since the revisions to the Project Description, as shown in Section I of this document , include a decrease of approximately 2,000 square feet of office use, which would result in an incremental decrease in operational impacts accordingly. 740-790 EAST GREEN STREET MIXED-USE PROJECT
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(99.3%) of the City’s wastewater is treated at three different facilities, namely: proposed Project’s wastewater would be treated at one of the following plants:
• The Whittier Narrows Water Reclamation Plant (WRP), located near the City of South El Monte, with a design cap acity of 15 million gallons per day (mgd) and an average flow of 8.6 mgd , resulting in a remaining capacity of approximately 6.4 mgd (City of Pasadena 2015a). • The San Jose Creek WRP, located adjacent to the City of Industry, with a design capacity of 100 mgd and an average flow of 63 mgd, resulting in a remaining capacity of approximately 37 mgd (City of Pasadena 2015a).
• The Joint Water Pollution Control Plant, located in the City of Carson, with a design capacity of 400 million gallons per day (mgd) and an average flow of 261.1 mgd (LACSD 2020), resulting in a remaining capacity of 138.9 mgd.
• The Los Coyotes WRP, located in the City of Cerritos, with a design capacity of 37.5 mgd and an average flow of 21 mgd (LACSD 2012 2020), resulting in a remaining capacity of approximately
16.5 15.8 mgd (City of Pasadena 2015a).
According to the CalEEMod estimations, the proposed Project would produce approximately 21.24 million gallons per year (0.58 million gallons per day) of wastewater. Based on the remaining capacities of the San Jose Creek WRP, the Whittier Narrows WRP, Joint Water Pollution Control Plant and the Los Coyotes WRP, which total approximately 60 154.7 mgd, the wastewater generated by the proposed Project would represent a nominal ( 0.09 0.022%) percentage of the facilities’ remaining daily capacity.
As such, the proposed Project is not anticipated to exceed current capacities of the wastewater treatment system and would not significantly impact existing wastewater treatment systems such that new facilities would be required. Impacts would be less than significant and no mitigation is required. d) Would the project generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals?
Less Than Significant Impact. The City’s non-residential solid waste is disposed of through contracts with private haulers. These waste management services offer waste and recycling collection, green waste recycling programs, organics waste composting, special waste transportation, and transfer and materials recovery services to the City as well as many other are as in Southern California. As stated above in Section 2.19(a), the City adheres to the State’s Solid Waste Reuse and Recycling Access Act of 1991 (AB 341), which declares that cities and counties must divert 50% of all solid waste by 2000 and 75% of all so lid waste by 2020, through source reduction, recycling and composting. The City of Pasadena reached a 73% reduction in solid waste as early as 2010 and is moving towards zero waste as implemented by the Zero Waste Strategic Plan, which is anticipated to accomplish a Citywide minimum of 87% solid waste diversion by 2040 (City of Pasadena 2019d). Additionally, the Pasadena Municipal Code requires that 75% of construction and demolition debris be recycled. 740-790 EAST GREEN STREET MIXED-USE PROJECT
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Based on the CalEEMod solid waste generation rates, th e proposed Project would generate approximately 222.76 tons/year (602.86 cubic yards/year ) (Appendix A).26 Solid waste generated by the proposed Project would be collected and transported to a local or regional landfill. The City primarily disposes of solid waste at four landfills, including Scholl Canyon Landfill , Sunshine Canyon Landfill, El Sobrante Landfill, and Chiquita Canyon Landfill. With adherence to the abovementioned regulations, the increase in solid waste generation from implementation of the proposed Project would be minimal, and, as of 2015, the above -mentioned landfills had a combined remaining capacity of 297,000,000 cubic yards, of which the proposed Project would represent a nominal contribution (City of Pasadena 2015a).
Additionally, required compliance with Chapter 8.62 of the Pasadena Municipal Code would reduce the project’s solid waste generation during construction and demolition activities. For these reasons, solid waste impacts resulting from the construction and operation of the proposed Project would be considered less than significant. No mitigation is required.
e) Would the project comply with federal, state, and local management and reduction statutes and regulations related to solid waste?
No Impact. As stated above in Section 2.19(a), the City adheres to the states Solid Waste Reuse and Recycling Access Act of 1991 (AB 341), which declares that cities and counties must divert 50% of all solid waste by 2000 and 75% of all solid waste by 2020, through source reduction, recycling and composting. The City of Pasadena reached a 73% reduction in solid waste as early as 2010 and is moving towards zero waste as implemented by the Zero Waste Strategic Plan, which is anticipated to accomplish a Citywide minimum of 87% solid waste diversion by 2040 (City o f Pasadena 2019d). Additionally, the Pasadena Municipal Code requires that 75% of construction and demolition debris be recycled. The proposed Project would comply with federal, state, and local management and reduction statutes and regulations related to solid waste. No impact would occur.