APPEAL APPLICATION
GENERAL INFORMATION: (Please print)
Appellant: The Maryland HOA
Date: October 6, 2025
Mailing Address: 80 N Euclid Ave.
City: PasadenaState: CA.Zip: 91101
Phone #: (day) 818-550-1800
Contact Person: SilvioNardoni
, (evening) 323-791-8837Fax #: 818-550-1850
Phone #: 818-550-1800
E-mail Address of Contact Person: [email protected] Applicant (if different from appellant): All Saints Church/Erica Tamblyn
APPEAL APPLICATION
ZENT2025-00039
Application # ^\C\JPJ^\8__Da{e of Decision 09/25/2025.Appeal Deadline 10/06/2025 Property Address: 202 N Euclid Ave, Pasadena, CA
I hereby appeal the decision of the: Board of Zoning Appeals The decision maker failed to comply with the provisions of the zoning ordinance in the following manner:
See attached statement of grounds for appeal.
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Date Received:
Appeal Hearing Date
Received by:
City Clerk • City of Pasadena *ioo North Garfield Avem, Room S228 • Pasadena, California 91109 • 626-744-4124 * 626-744-3921 (fax) Appeal application
10/2/25
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Attached to Request for Appeal ofMCUP #7318
October 6,2025
The Honorable City Council
of the City of Pasadena
Pasadena City Hall
IGON.GarfieldAve.
Pasadena, California 91101
Re: Appeal of Board of Zoning Appeals' decision on MCUP #7318, proposed Safe Parking use at the parking lot at 202 N. Euclid Ave.
Honorable Members of the City Council:
The Maryland Homeowners Association ("The Maryland") submits this letter as additional information attached to The Maryland's Request for Appeal of the Board of Zoning Appeals (the "BZA's") September 25, 2025 decision granting, with modifications, the application of Erica Tamblyn on behalf of All Saints Church for a Minor Conditional Use Permit ("MCUP") to allow a proposed Safe Parking operation on the parking lot at 202 N. Euclid Avenue, located at the southeast comer of Euclid and Walnut (the proposed "Safe Parking site").
The MCUP would allow up to 25 vehicles of homeless individuals to park between the hours of 7 p.m. and 7 a.m. on the Safe Parking site. The MCUP would not cap the number of individuals in those vehicles. All Saints proposes the Safe Parking operation be operated by Shower of Hope, which the City of Los Angeles recently de-funded.1 The proposed Safe Parking operation is not limited to or even ' See the video of the BZA's Sept. 25, 2025, hearing at time-stamp 2:03:20 (acknowledging the de- funding) available here: https://pasadena.granicus.com/player/clip/8114?view_id=35&redirect:=tme.
Pasadena City Council
Appeal of MCUP #7318
required to favor homeless individuals from Pasadena. So, while the staff report to the BZA may be correct that the proposed Safe Parking operation may mean "fewer individual will be parking or sleeping in residential areas or on public sidewalks or streets," these may well not be Pasadena's residential areas, public sidewalks, and streets. All of the Safe Parking participants could drive in from Los Angeles.
Goodness knows the City of Los Angeles needs all the help it can get. But that help should not come at the expense of the jeopardizing the safety of a Pasadena neighborhood and its residents. This Council's charge is, of course, to protect Pasadena's residents. At the hearings before the Hearing Officer and the BZA, every person who lives in the neighborhood of the Safe Parking site opposed the proposed operation. Everyone (other than All Saints staff and parishioners) who works near the Safe Parking site opposed to it. The people who spoke in favor of the proposed operation were overwhelmingly All Saints staff and parishioners, none of whom live in the neighborhood, and none of whom will have to deal with the negative effects of the proposed Safe Parking operation.
Turning to the legal bases of The Maryland's appeal, the BZA's findings and decision were in error for three reasons:
• First, the proposed Safe Parking site is not a religious facility site, and therefore the Zoning Code does not allow the proposed operation there.
• Second, the proposed Safe Parking use is not an exempt project under the California Environmental Quality Act (CEQA) as involving "negligible or no expansion" of existing use because the proposed Safe Parking operation is a change of use, and the intensity of activity will expand significantly, causing a negative environmental impact. • Third, the proposed Safe Parking operation would negatively affect the safety of the neighborhood, as the evidence, below, and which was presented to the BZA, demonstrates.
1. The Zoninp Code does not allow Safe Parking on the proposed parkins lot because it is not a religious facility site.
The City's zoning code allows Safe parking operations in the PS (Public and Semi-Public) zoning district, where All Saints Church and the proposed Safe Parking site are located, as long as additional conditions are met. One additional 80 North Euclid Avenue, Pasadena, California 91101
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Pasadena City Council
Appeal of MCUP #7318
condition is that the Safe Parking operation must be located on one of several specified types of sites. The type relevant here is a "religious facility" site. (Zoning Code section 17.24.030 Table 2-5; section 17.50.265.)
Pasadena Zoning Code section 17.80.20 defines a "religious facility" as a facility "in which the primary use is religious worship." While the Code notes that a religious facility "may include related accessory activities," including the sorts of charitable and pastoral activities that commonly occur inside church buildings, such as "religious education, ministry, clothing and food distribution, counseling, employment assistance, referral services, and support groups," the Code explicitly excludes "[o]ther uses (e.g., private schools and child day-care centers) that are located on the site of a religious assembly." For-profit commercial parking is surely an excluded "other use."
The Code does not define "facility." Merriam-Webster Dictionary defines it as "something (such as a hospital) that is built, installed, or established to serve a particular purpose." (See https://www.merriam-webster.com/dictionary/facility.) The American Heritage Dictionary defines it as a "building, room, array of equipment, or a number of such things, designed to serve a particular function:
hospitals and other health care facilities." (See https://ahdictionary.com/word/ search.html?q=facility.)
The Code defines a primary use as the "main purpose for which a site is developed and occupied, including the activities that are conducted on the site a majority of the hours during which activities occur." (Zoning Code section
17.80.020.)
A religious facility under the Zoning Code is thus a structure or assembly location and related equipment whose main purpose is religious worship. In short, and relevant to the current dispute, it's a church and its appointments. The Code thus excludes from being a religious facility site any site whose main use is for- profit commercial activity—such as for-profit commercial parking—since a site's primary use cannot be both for-profit commercial activity and religious worship.
The BZA legally erred in identifying the location of All Saints' "religious facility site." The alleged location of All Saints' church site as depicted, in a presentation staff made to the BZA and upon which the BZA rendered its decision, is shown within a thick yellow line:
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Pasadena City Council
Appeal of MCUP #7318
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The yellow line surrounds almost the entire western half of the block from Walnut Stret on the north to the edge of Plaza Las Fuentes on the south. The staff presentation indicates in red where the proposed Safe Parking operation will occur.
To understand why this yellow line misidentifies All Saints' "religious facility" site, it's essential to understand that the yellow line surrounds three distinct parcels, shown below with the last three digits of the parcels' associated Assessor's Parcel Numbers (APNs).
2 Trinity Church provides a useful contrast. Its safe parking program is sited on its non-commercial parking lot that primarily services and is on the same parcel as the church. Trinity's parking lot is thus on a religious facility site and qualifies to host a Safe Parking program under the City's Zoning Code. 80 North Euclid Avenue, Pasadena, California 91101
Pasadena City Council
Appeal of MCUP #7318
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The southernmost and largest parcel ("Parcel 03 9") has APN 5723-017-039 and the Church's address of 132 N. Euclid Avenue:
80 North Euclid Avenue, Pasadena, California 91101
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Appeal of MCUP #7318
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As you can see from the aerial photograph and All Saints' campus map, below, Parcel 039 contains all of All Saints' facilities for religious worship and related accessory activities —the sanctuary, chapel, guild room, rector's office, etc. (As discussed later. Parcel 039 contains several lots.)
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Appeal of MCUP #7318
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The middle parcel ("Parcel 040") has APN 5723-017-040 and no listed separate address:
80 North Euclid Avenue, Pasadena, California 91101
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Pasadena City Council
Appeal of MCUP #7318
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Parcel 040 is a parking lot, part of which is for-profit commercial. This parking lot contains 55 parking spaces, of which 30 are reserved for All Saints' exclusive use.
The remaining 25 spaces are commercially rented on a daily basis, primarily to people parking at the courthouse located across Euclid Ave. All Saints uses some of the 25 spaces outside of business hours for attendees of church activities, especially on Sunday mornings. Except when All Saints has a choir rehearsal or other evening program, the lot has few cars parked on it during the evening. The lot is nearly empty between 10 p.m. and 7 a.m. the next morning, when court- parkers start arriving on Mondays through Fridasy, or when parishioners start arriving on Sunday mornings or religious holidays. The lot is only lightly used on Saturdays.
The northernmost parcel ("Parcel 012")—the parking lot on which All Saints proposes to operate the Safe Parking program—has APN 5723-017-012 and no listed separate address:
80 North Euclid Avenue, Pasadena, California 91101
Pasadena City Council
Appeal of MCUP #7318
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Parcel 012 is entirely a for-profit commercial parkmg lot, except for one small storage structure at the comer of Euclid and Walnut which occupies (as one can see above) around one-tenth of the parcel. This parcel was a for-profit commercial parking lot when All Saints purchased it in 1992 and has remained so ever since. The parking lot contains 50 spaces, all of which are available for commercial use from 7 a.m. until 5 p.m. on weekdays, and used priinarily by people parking to go to the courthouse located across Euclid Ave. Consistent with primarily servicing court-attendees, the parking lot has minimal tum-over during the course of the day. None of the spaces are reserved for All Saints' exclusive use, though All Saints uses some of the spaces outside ofbusiness-hours for attendees of church activities, especially on Sunday mornings. Except when All Saints has a choir rehearsal or other program, the lot has few cars parked on it during the evening. The lot is usually empty between 10 p.m. and 7 a.m. the next morning, 80 North Euclid Avenue, Pasadena, California 91101
Pasadena City Council
Appeal of MCUP #7318
when court attendees or parishioners start arriving. The lot is mostly empty on Saturdays.
During the June 18 hearing before the Hearing Officer, the Hearing Officer asked "when is the church building and parking being used for church services?"3 An All Saints' representative responded "practically 24/7," listing near-constant activities: children's choir rehearsals, safe haven programs, 12-step groups, committee meetings, and so on. But these are all activities that occur inside the church buildings and the lawn and playground on Parcel 039. They are not activities on the commercial parking lot on Parcel 012. Uncontested testimony by a speaker, Mr. Nardoni, was that the Safe Parking site is definitely not used "24/7."4 As stated, most of the use of Parcel 012 consists of commercial parking during court-hours. The Maryland intends to supplement this appeal by providing photographic evidence that the usage of Parcel 012 falls far below the claimed "24/7."
Parcel 012's primary use is, thus, for-pmfit commercial parking, not religious worship or accessory activities consonant with a "religious facility." The lot is developed and occupied as a parking lot, as it has been since All Saints purchased it in 1992. Most of the vehicles most of the time are parked on Parcel 012 by paying customers, not church-attendees. By any reasonable interpretation of the term, Parcel 012 is, therefore, not a religious facility site. Accordingly, the location is not eligible for a Safe Parking use, and the applicant does not qualify for an MCUP under Zoning Code section 17.24.030 Table 2-5.
To avoid this conclusion, the BZA relied on staffs assertion that all three parcels are part of a single religious facility site based on the definition of "site" at Zoning Code section 17.80.020 (Definitions):
Site.
A lot or group of contiguous lots not divided by any alley, street, other right-of-way or city limit that is proposed for development in accord with the provisions of this Zoning Code, and is in a single ownership or has multiple owners, all of whom join in an application for development.
3 See Hearing Officer's June 18,2025, hearing video at time-stamp 31:25 here:
https://www.cityofpasadena.neVcommissions/audio-video-recordings/. 4 Hearing Officer hearing at time-stamp 55:30.
80 North Euclid Avenue, Pasadena, California 91101
Pasadena City Council
Appeal of MCUP #7318
This definition contemplates a group of contiguous lots constituting a single site when a single proposed development spans the lots. While All Saints owns all three parcels and their constituent lots (Parcel 039 contains six lots), the group of lots is not proposed for development. The development is proposed only for the lot constituting Parcel 012, not any of Parcel 039, which is composed of the lots containing the church and structures for religious accessory activities.
Three final points support The Maryland's position. First, there appear to be no cases (The Maryland could find none) in which a "site" was identified as constituting multiple lots even though the proposed development would occur only one lot. The Maryland did find cases to the contrary. For example, in the staff report before the Hearing Officer for the May 15, 2024 hearing on CUP #7139, staff identified the "site" as the specific area where Caltech proposed to develop its Ginsburg Center for Quantum Precision Measurement. The "site" did not include Caltech contiguous acreage. (The Caltech campus encompasses approximately 124 acres.) Nor did the site include all of the approximately 28 acres of the parcel on which the approximately 1.6 acre development would occur.
Second, the title reports for the three parcels confirm the primary uses The Maryland has ascribed to them. See Exhibit A, attached, which contains the first, "Property Basics" pages of the title reports for the three parcels, showing the primary uses of each parcel:
• Parcel 5723-017-039 / Type: Miscellaneous (Religious) • Parcel 5723-017-040 / Type: Commercial (Parking Lot, Parking Stmcture)
Parcel 5723-017-012 / Type: Commercial (Parking Lot, Parking Stmcture)
•
Third and finally, the plat map for the three parcels shows that Parcel 039, which contains all of the religious facilities and structures for religious accessory activities is distinct from Parcel 012 where the Safe Parking is proposed. Here is the plat:
80 North Euclid Avenue, Pasadena, California 91101
Pasadena City Council
Appeal of MCUP #7318
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Parcel 039 (indicated by the "39" in a circle) consists (going north to south) of Lots 6, 7, 8, 9, 10, and 15. These lots are all lot-tied, as indicated by the Z-shape on the lines separating them. Parcel 040 (indicated by the "40" in a circle) consists of one lot that is also called Lot 7. That Lot 7 was lot-split along the dash-line mnning between "San" and "Pasqual" on the plat. Parcel 039's Lot 6 is, as the Z- shape indicates, lot-tied to the southern part (below the dashed line) of Parcel 040's Lot 7. The parking lot on Parcel 040 is the portion of the Lot 6 north of the dashed line. That parking lot is not lot-tied to the religious facilities on the lot south of it.
And the parking lot on the Lot comprising the whole of Parcel 012 is not lot-tied to any of Parcel 040. In other words, the commercial parking lots on Parcel 040 and Parcel 012 are not legally joined to the All Saints' church facilities. We are dealing 80 North Euclid Avenue, Pasadena, California 91101
Pasadena City Council
Appeal of MCUP #7318
with three distinct sites—only one of which, the parking lot on Parcel 012, is proposed for development in the application for MCUP #731 8 The inescapable conclusion is that the parking lot on Parcel 012 on which All Saints is proposing a Safe Parking operation is not a religious facility and may not, therefore, legally host a Safe Parking operation. The Maryland's appeal of the BZA's determination must granted, the BZA's decision overturned, and All Saints' application for MCUP #7318 denied.
2. The BZA's CEOA determination is improper because the proposed Safe Parking use is not exempt from environmental review.
Staffs recommendation for approval of the permit application rests on two acts of semantic legerdemain. As discussed above, Staff first argues that the Safe Parking program constitutes a development, because it establishes a land use, namely parking. But that is already the primary use of the only Parcel on which the purported development will occur. Staff employs a similar tactic in its analysis of why the development qualifies for exemption from environmental review. It argues, as it must, that the new land use requires a permit to comply with the Zoning Code, and then asserts that the new use is a minor or negligible expansion of the former use.
The BZA adopted the Staff Report's proposed environmental determination that the project is exempt from environmental review pursuant to 14 CCR § 15301 Class 1 and in the absence of any unusual circumstances. This Class 1 exemption applies to the operation of facilities "involving negligible or no expansion of existing or former use." That determination is in error because:
• Granting the MCUP would increase the hours of operation of the Safe Parking site operates by 120%.5
5 The hours of operation would increase from 7 a.m. to 5 p.m. to include 7 p.m. to 7 am, an increase from 10 to 22 hours. If one includes as part of the CEQA baseline the hours during which a substantial number cars are on the parking lot (which includes when All Saints' attendees park on the lot outside of business hours on Monday to Friday), then the hours would increase from 7 a.m. to 10 p.m. to include 10 p.m. to 7 a.m.—a 60% increase.
80 North Euclid Avenue, Pasadena, California 91101
Pasadena City Council
Appeal of MCUP #7318
• Granting the MCUP would increase the number of cars authorized to park in the proposed Safe Parking site (Parcel 012) weekday by approximately 50%.6
• Granting the JS4CUP would be a change of use because the parking lot would be used for shelter 12 hours each day. That this is a change of use is evidenced by All Saints' requiring a new use pennit. Staff acknowledged that the Safe Parking operation is a new, not an existing, use/
These increases cannot be "negligible or no expansion" of use. IVIerriam- Webster Dictionary defines "negligible" as "so small or unimportant or of so little consequence as to warrant little or no attention." (See https://www.merriam- webster.com/dictionary/negligible.) The American Heritage Dictionary similarly defines it as "[n]ot significant or important enough to be worth considering; trifling." (See https://ahdictionary.com/word/search.html? q:=negligible.) The Safe Parking operation's expansion and/or change of use will have significant negative enviromnental effects warranting robust attention and consideration. A significant effect on the environment is statutorily defined as "a substantial, or potentially substantial, adverse change in the enviromnent" including air and noise. (Public Resources Code sections 21068 and 21060.5.) Chief among the significant negative effects will be air pollution from participants idling their vehicles (parked with engines miming). See Sunflower All. v. Dep't of Conservation (2024) 105 Cal. App. 5th 771, 784-85 (CEQA recognizes cars harm air quality).) Safe Parking participants will inevitably idle their cars while waiting to drive into the lot when it opens each evening. (See Recording of Hearing Officer hearing at 1 :00:43 (participants "will not go very far away because they want to get back and get their prime parking spot")). Participants will also t
6 The proposed Safe Parking site would increase from approximately 50 daily cars to include an additional 25 cars each evening, an increase of 50%. (Because oftlie court-oriented function of the parking lot, there is little tum-over during the day. So, the number of parking spaces is a reasonable proxy for the number of vehicles.) If one added the parking spaces on Parcel 040 (including those for the exclusive use of All Saints) to Parcel's 012's spaces as part of the CEQA baseline, then the total would increase from approximately 90 cars to include an additional 25 cars—a 27% increase. 7 In answering the BZA's question whether the Safe Parking operation is a development under the City's Zoning Code, staff said it is because it is the "establishment of a land use." See September 25, 2025 BZA hearing video at time-stamp 2:l9:00-:20.
80 North Euclid Avenue, Pasadena, California 91101
Pasadena City Council
Appeal of MCUP #7318
inevitably idle their cars while on the Safe Parking site to mn their air-conditioning or heaters when the weather is hot or cold.
An idling engine produces 20 times more pollution than a car travelling at 32 m.p.h.8 Idling fuel usage varies from 0.2 to 0.5 gallons per hour for passenger vehicles across a range of sizes, and increases with idling speed.9 Thus, we have the commonly cited estimate that allowing your car to idle for two minutes is equivalent of driving one mile. Using this metric, 25 vehicles each idling for 60 minutes is equivalent of driving 750 miles. All of the pollution from these 750- miles-driving-equivalent will, of course, not be spread out over 750 miles but will all be discharged on and in the neighborhood of the Safe Parking site. The Euclid Avenue block between Walnut and Union is 0.16 mile. Thus, the 750-miles- driving-equivalent is equal to 4,687 cars driving down this block each day. This more than doubles the current level of traffic on this section of Euclid.10 The proposed Safe Parking operation will also potentially substantially increase the noise in a neighborhood with residences and a hotel. The MCUP requires participants comply with the City's Noise Ordinance, but that is aspirational. In reality, 25 vehicles with an indeterminate number of participants (which can include infants and children) and an indeterminate number of pets is going to make a lot of noise. The Westin hotel is immediately adjacent to the Safe Parking site. The Euclid Square apartments at 249 N. Euclid Avenue is 286 feet from the closest Safe Parking's parking space (260 feet if measured parcel-line to parcel-line). The Maryland is on the other side of the church from the Safe Parking site.
Because of these far-from-negligible expansions of use and changes of use, the proposed Safe Parking project does not fall within the Class 1 CEQA exemption. (See 14 CCR 15301 [the CEQA exemption's "key consideration is whether the project involves negligible or no expansion of an existing use"].) The expansion in use will have significant negative environmental effects. An environmental analysis is therefore required. (See Protect Niles v. City ofFremont (2018) 25 Cal. App. 5th 1129, 1138-39 [citing CEQA Guidelines that if there is 8 Utah Department of Environmental Quality, "Some Common Myths: Be Idle Free" available here:
https://deq.utah.gov/air-quality/some-common-myths-be-idle-fi'ee. 9 U.S. Dept. Energy, "Which Is Greener: Idle, or Stop and Restart?" available here:
https://afdc.energy.gov/files/u/publication/which_is_greener.pdf 10See, Exhibit C, showing current traffic volume on the relevant portion of Euclid. 80 North Euclid Avenue, Pasadena, California 91101
Pasadena City Council
Appeal of MCUP #7318
"substantial evidence" in the whole record supporting a fair argument that a project may have a significant effect on the environment, the lead agency shall prepare an EIR, even though it may also be presented with other substantial evidence that the project will not have a significant effect, and noting that "may" means a reasonable possibility].)
The City may not approve the MCUP application at least until the City conducts an environmental review. (See, e.g., Save Tara v. City of W. Hollywood (2008) 45 Cal. 4th 116, 122 (2013) [environmental review must precede project approval]; 14 CCR 15004 ["Before granting any approval of a project subject to CEQA, every lead agency or responsible agency shall consider a final EIR or negative declaration or another document authorized by these guidelines to be used in the place of an EIR or negative declaration."].) The Maryland's appeal of the BZA's determination must granted, the BZA's decision overturned, and All Saints' application for MCUP #7318 denied.
3. The Safe Parking operation would make the neiehborhood less safe.
The City's Zoning Code requires, and the BZA found, that the proposed use will not be detrimental to the "health, safety, or general welfare of persons residing or working in the neighborhood." (Zoning Code section 17.61.050(H)(4); BZA Decision Attachment A, Finding 4.) That finding was in error.
A. All Saints should not be entrusted 'with this Safe Parking operation.
While All Saints' goal of sheltering the homeless is admirable. All Saints has knowingly violated conditions of approval for a similar permit, and thus should not be tmsted to abide by the conditions imposed on this MCUP. All Saints in 2021 was granted CUP #6898 to operate its Safe Haven Bridge to Housing program. One of the conditions of approval is that "[a]t least one security guard shall patrol the subject property from 7:00 p.m. to 7:00 a.m., daily." (See September 1, 2021, staff report to the Hearing Officer at page 12, condition 12.
The Hearing Officer adopted the staff report.) Prompted by then-rector Kinman, the current applicant. Erica Tamblyn, publicly stated on recorded video that All Saints is violating this condition.11 Applicant Tamblyn states that "we [All Saints] have reduced the security" and now rely on security guards stationed at City Hall " See "03.08.24 - All-Saints Pasadena Safe Haven Bridge to Housing Ministry" attime-stamp 1:00:20 here: https://www.youtube.com/watch?v=h5M3_NLeijI&t=2987s. 80 North Euclid Avenue, Pasadena, California 91101
Pasadena City Council
Appeal of MCUP #7318
who "come over a couple of times per night" except for "two nights a week that are like 'hot' nights—Friday night and Saturday night—when we have an officer there throughout the night." This violates the condition of All Saints' CUP. This admission by All Saints undermines any assumption that All Saints will abide by the condition of this MCUP to have a security guard on-site during all hours of operation of its Safe Parking program?12
Additionally, All Saints is already an attractive nuisance that cannot control what occurs on its property. Since 2020, All Saints has had over 450 calls for service from the Police Department, basically averaging a call every 4 days for 5.5 years. (See the Pasadena Police Department's Call for Service Reports attached as Exhibit B.) If All Saints were treated like any other permit-holder or business, it would have been classified as a gross nuisance and closed down by the City years ago. Like a magnet attracting iron filings, the All Saints campus has drawn to it an agglomeration of troublemakers. This history belies All Saints' claim that it can maintain a Safe Parking operation on its parking lot for twelve hours every day without degrading the safety of the neighborhood for our residents and workers, as well as for the customers who come to patronize the neighborhood's businesses.
B. The future will resemble the past.
At a Maryland meeting to discuss the proposed Safe Parking operation, every member of The Maryland in attendance opposed the operation because it would make the neighborhood unsafe for residents and workers. Maryland residents base their opinion on past experience. Five years ago, All Saints permitted as many as 10 or more homeless individuals to camp under a tree south of its sanctuary. While the encampment was in place the following happened:
• Dmg dealers loitered in the area to sell dmgs to the homeless and to anyone else nearby. A Maryland resident on two occasions walked to the nearby courthouse for business. On both occasions he was solicited to buy dmgs.
12 All Saints applicant Tamblyn stated at tiie BZA hearing that All Saints did not realize it was violating its Safe Haven CUP, and that it now has a security guard present each night as is required. (See September 25, 2025 BZA hearing video starting at time-stamp 1:00:50.) Everyone can look at the earlier- cited video with Rector Kinman and Ms. Tamblyn aiid judge for themselves whether All Saints understood it was violating its permit. If you think they did understand, then All Saints appears to be coming into compliance with its Safe Haven CUP in order to receive its Safe Parking MCUP. 80 North Euclid Avenue, Pasadena, California 91101
Pasadena City Council
Appeal of MCUP #7318
• On multiple occasions, members of the encampment and/or others drawn to the encampment shot up dmgs on part of The Maryland's property adjoining Plaza Las Fuentes.
• On multiple occasions, members of the encampment and/or others drawn to the encampment shot up dmgs and passed out on The Maryland's front steps.
• On multiple occasions, members of the encampment and/or others drawn to the encampment lit fires to do dmgs on the green-space at the comer of Euclid and Union. The Maryland is worried that the trees there will catch fire and spread to The Maryland. • On multiple occasions, we had to clean up human feces from Maryland property.
• The amount of trash in the area, especially food containers and beer and liquor bottles greatly increased.
The Maryland's experience is not unique. At the hearing before the Hearing Officer, a representative of the office tower at 301 E Colorado Blvd., across from City Hall, described similar problems:
• Homeless individuals lurk in his building's garage, which has made his security guards afraid to go at night into the lower levels of the tower's garage. (June 18, 2025 Hearing Officer hearing at time-stamp 1:04:18.)
• The tower also had to install a fence around the generator serving the Montana condominiums, located on the office tower's property, because of homeless people defecating behind it.
The problems Maryland residents and other residents and workers in the neighborhood experienced before will return.
At The Maryland homeowners' meeting at which the MCUP was discussed, residents stated that they do not walk during the evening near the old YWCA or YMCA because it is unsafe because of the presence of unstable individuals. Does the City really want to make the area more unsafe by concentrating more unstable homeless individuals into the Civic Center? The answer, we hope, is No.
C. A single security guard will not suffice.
The Maryland rejects—as should the Council—the BZA's determination that a single security guard will suffice to ensure that Safe Parking participants stay on-property and are not solicited by non-participants. The proposed Safe Parking 80 North Euclid Avenue, Pasadena, California 91101
Pasadena City Council
Appeal of MCUP #7318
location is inherently insecure. There are multiple entry points for vehicles, and the northern boundary of Parcel 12 has a low cinder block wall.
A single security guard (or even two, though the proposed permit calls for only one) will not be able to secure 25 vehicles and an indeterminate number of individuals on a parking lot open to the public space on three sides. A representative of the Montana, a residential building at 345 E. Colorado Blvd., agreed that a single security office would be inadequate and that the proposed program is "a disaster waiting to happen." (June 18, 2025 Hearing Officer hearing at time-stamp 49:55-50:55.)
D. Drug-use and -solicitation will increase in the neighborhood before and after Safe Parking hours.
Even if the Safe Parking location were somehow secured during the night, dmg dealers and users will be loitering in the area before and after the program hours. As a Maryland resident who is a licensed psychologist who has worked with homeless individuals testified at the June 18 Hearing Officer hearing, many homeless individuals, including those living in their cars, are dmg-users with schizo-affective disorders. Realistically, here is what will happen: Before they drive onto the parking lot in the evening, some of the Safe Parking participants will park on Euclid or elsewhere in the vicinity to purchase and use dmgs. After driving off of the parking lot in the morning, some of the Safe Parking participants will park on Euclid or elsewhere in the vicinity to purchase and use dmgs. Other users who are not participants in the Safe Parking program will be attracted to the area because of the concentration of available dmgs.
Because the proposed Safe Parking operation will make the neighborhood less safe, the Maryland's appeal of the BZA's determination must granted, the BZA's decision overturned, and All Saints' application for MCUP #7318 denied.
We appreciate the City Council's attention to this matter and anticipate that the Council will deny the application for a minor conditional use permit as sought inMCUP#7318.
Respectfully,
The Maryland Homeowners Association
Silvio Nardoni
Corporate Secretary
80 North Euclid Avenue, Pasadena, California 91101
132 N Euclid Ave, Pasadena, CA 91101
Report Date; 10.01.20251
^SS^stewart
Property Basics
OWNERSHIP
Primary Owner:
Mailing Address:
Vesting:
Legal Description:
Rector Wardens & Vestry Of All
132 N Euclid Ave
Pasadena, CA 91101
LAND DESC AS PAR 1 IN DOC 1849462, 901101
Secondary Owner:Saints Church Of Pasadena
SALE & LOAN
Sale Amount:
Lender:
Document
$0Sale Date:
Loan ype:
Not Available
ASSESSMENTS TAX
Value (Structure); $4,836,187
Tax Amount: $6,486
Exemption: No
Value (Total); $5,719,844
Value (Land):
Tax Area:
Percent Improved:
$883,657
07-456
85 PROPERY CHARACTERISTICS
Type:
Sqft (Structure):
Rooms:
Beds:
Garage:
Number of Units:
M'-.cellaneous. (Religious)
52,434
Year
Sqft (Lot):
Stories:
Baths:
Fireplace:
1923
85,397
1 LAND RECORDS
Parcel/APN:
Zoning;
Map Ref:
5723-017-039
PSC-
County:Los Angeles
461902
• 2025 Stewart Title,
EXHIBIT A
SOO-STEWART Stewai-tNow.coiri
0000,, CA 00000
Report Date: 10-01.2025 I
Afl^stewart
Property Basics
OWNERSHIP
Primary Owner:
Mailing Address:
Vesting:
Legal Description:
All Saints Church Of Pasadena
132 N Euclid Ave
Pasadena, CA 91101
Secondary OwnerRector Wardens & Vestry Of
SAN PASCUAL TRACT LAND DESC AS PAR 2 IN DOC 2111922,901224 FOR OF LOT 7 BLK C
SALE & LOAN
Sale Amount:
Lender:
Document:
$0Sale Date:
Loan Type:
Not Available
ASSESSMENT & TAX
Value (Structure): $15,896
Tax Amount: $8,657
Exemption: No
Value (Total): $1,890,372
Value (Land):
Tax Area:
Percent Improved:
$1,874,476
07-456
1 PROPERY CHARACTERISTICS
Type:
Sqft (Structure);
Rooms:
Beds:
Garage:
Number of Units:
Commercial -'Parking Lot, Psrklng
St!'UCtL"-C;
21,312
Year Built:
Sqft (Lot):
Stories:
Baths:
Pool:
Fireplace:
1980
22,226
1 LAND RECORDS
Parcel/APN:
Zoning;
Map Ref:
5723-017--40
PSC-
County:
Tract:
Los Angeles
2025 Stewart Title,
EXHIBIT A
StewartNow.com
202 N Euclid Ave, Pasadena, CA 91101
Report Date; 10.01.2025'
Afl^stewart
Property Basics
OWNERSHIP
Primary Owner;
Mailing Address:
Vesting:
Legal Description;
All Saints Church Of Pasadena
132 N Euclid Ave
Pasadena, CA 91101
Secondary Owner:Rector Wardens & Vestry Of
SAN PASQUAL TRACT LOT COM W 192.5 FT AND N 240 FT FROM NE COR OF LOT 5 WM CONVERSE SUB TH NTO A PT S 55 FT FROM S LINE OF WALNUT ST TH W 67.5 FTTH NTO SD S LINE TH W THEREON AND S ON E LINE LINE TO BEG PART OF LOT 7 BLK C
SALE & LOAN
Sale Amount:
Document:
$3,992,000
Ssnwa Bank California
1990.2111922
Sale
I nAn Type^
12/17/1990
CONVENTIONAL
ASSESSMENT & TAX
Value (Structure): $17,663
Tax Amount: $20,217
No
Value (Total): $1,874,453
Value (Land):
Tax Area:
Percent Improved:
$1,856,790
07-456
1 PROPERY CHARACTERISTICS
Sqft (Structure):
Rooms:
Beds:
Garage:
of Units:
cmrTiercial (Parking Lot, Parking
;.t.ucture)
21,455
Year
Sqft (Lot):
Stories:
Baths:
Pool:
Fireplace:
1947
21,101
1 LAND RECORDS
Map Ref:
5723-017-012 4
PSC-
CountyLos Angeles
463601
"•)
EXHIBIT A
)
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1,'
Pasadena Police Department
Calls For Service Report
m
v
Generated by 6076 on 6/17/2025
Search Criteria: City: PA | Time Range: 01/01/21 00:01 - 05/31/22 23:59 | Agency: F,P | Address: 132 N EUCLID AV Incident
1PA0000873
1PA0002351
1PA0004117
1PA0004147
1PA0004421
1PA0004782
1PA0006089
1PA0007124
1PA0007409
1PA0009901
1PA0009931
1PA0010164
1PA001Q373
1PA0010402
1PA0010890
1PA0011158
1PA0011159
1PA0011169
|A| Date
P 01/04/21
P 01/09/21
P 01/16/21
P 01/16/21
P 01/17/21
P 01/18/21
P 01/23/21
P 01/27/21
P 01/28/21
P 02/06/21
P 02/06/21
P 02/07/21
P 02/08/21
P 02/08/21
P 02/10/21
P 02/11/21
P 02/11/21
P 02/11/21
Time
11:21:43
17:54:35
00:46:38
09:09:33
05:52:48
12:47:31
00:36:14
07:08:27
00:24:55
07:25:24
10:45:58
03:19:10
00:31:23
07:33:15
01:42:38
00:39:34
00:40:56
02:05:45
1PA0011258 P 02/11/21 11:21:28
1PA0011358
1PA0011387
1PA0011443
1PA0012043
1PA0012058
1PA0013011
1PA0013210
1PA0014704
1PA0015020
1PA0015347
1PA0016897
1PA0017393
1PA0018551
1PA0018802
1PA0018810
1PA0019793
1PA0019964
P 02/11/21
P 02/11/21
P 02/12/21
P 02/14/21
P 02/14/21
P 02/17/21
p
p
p
p
p
p
p
p
p
p
p
02/18/21
02/23/21
02/24/21
02/25/21
03/01/21
03/03/21
03/06/21
03/07/21
03/07/21
03/10/21
03/11/21
17:53:16
19:03:09
01:28:30
00:22:54
03:58:15
15:33:06
03:05:42
02:52:56
00:39:20
01:07:46
20:47:43
13:43:49
20:11:15
17:15:30
18:04:22
17:27:11
09:42:36
Type
459RA
459RA
TRST
FB
TRST
243A
415M
TRST
TRST
484A
FNDPR
p
TRST
TRST
TRST
TRST
602
602
314
HSVIO
L
166-4
TRST
TRST
TRST
925A
HSVIO
L
TRST
459RA
TRST
TRST
459RA
TRST
TRST
TRST
415M
459RA
N01 | Unit
BURGLARY ALARM 1L12
BURGLARY ALARM 2D5
TRANSIENT 3A22
FOOTBEAT HP3
TRANSIENT
BATTERY 2L55
TRST 3A31
TRANSIENT 1L51
TRANSIENT 3L51
PETTr'THEFT 1L51
FOUND PROPERTY 1L52
TRANSIENT 3L51
TRANSIENT 3L52
TRANSIENT
TRANSIENT 3L31
TRESPASS
TRESPASS 3L21
INDECENT 3L21
EXPOSUR
CITE OUT P63
VIOL COURT ORDER HP3
TRANSIENT 2L55
TRANSIENT 3L51
TRANSIENT 3L12
SUSP PERSON/VEH 3L51
HEALTH & SAFETY 2A55
TRANSIENT 3L11
BURGLARY ALARM 3L51
TRANSIENT 3L52
TRANSIENT 3L52
BURGLARY ALARM 3L51
HP1
TRANSIENT 3L11
TRANSIENT 2A55
TRANSIENT 2A55
415MISC
BURGLARY ALARM
Dispo I Location
FALSE 132 N. EUCLID AV
CAN 132 N. EUCLID AV
RES 132 N. EUCLID AV
RES 132 N. EUCLID AV
CAN 132 N. EUCLID AV
RES 132 N. EUCLID AV
RESH 132 N. EUCLID AV
RES 132 N. EUCLID AV
RES 132 N. EUCLID AV
RES 132 N. EUCLID AV
RPT 132 N. EUCLID AV
RES 132 N. EUCLID AV
RES 132 N. EUCLID AV
CAN 132 N. EUCLID AV
RES 132 N. EUCLID AV
DUP 132 N. EUCLID AV
RES 132 N. EUCLID AV
RES 132 N. EUCLID AV
RPT 132 N. EUCLID AV
UNF 132 N. EUCLID AV
RES 132 N. EUCLID AV
RES 132 N. EUCLID AV
RES 132 N. EUCLID AV
RES 132 N. EUCLID AV
UTL 132 N. EUCLID AV
GOA 132 N. EUCLID AV
FALSE 132 N. EUCLID AV
RES 132 N. EUCLID AV
RES 132 N. EUCLID AV
FALSE 132 N. EUCLID AV
RES 132 N. EUCLID AV
RES 132 N. EUCLID AV
GOA 132 N. EUCLID AV
GOA 132 N. EUCLID AV
CAN 132 N. EUCLID AV
CAN 132 N. EUCLID AV
EXHIBIT B
i's^
Pasadena Police Department
Calls For Service Report
Generated by 6076 on 6/17/2025
Search Criteria: City: PA | Time Range: 01/01/21 00:01 - 05/31/22 23:59 | Agency: F,P | Address: 132 N EUCLID AV 1PA0019967 P 03/11/21 09:54:54 459RA BURGLARY ALARM 1L21 CAN 1PA0020636 P 03/13/21 04:46:04 602 TRESPASS 3L52 RES
1PA0021318 P 03/15/21 15:35:15 TRST TRANSIENT 2A55 RES
1PA0021441 P 03/16/21 00:11:48 TRST TRANSIENT 3L51 RES
1PA0021971 P 03/17/21 16:05:02 415M 415MISC 1L52 RES
1PA0022183 P 03/18/21 04:53:22 TRST TRANSIENT 3L11 GOA
1PA0022531 P 03/19/21 03:32:12 602 TRESPASS 3L51 RES
1PA0022978 P 03/20/21 14:20:48 TRST TRANSIENT 1L51 GOA
1PA0023566 P 03/22/21 10:59:35 415M 415MISC 1L51 RES
1PA0024101 P 03/23/21 22:33:04 415M 415 MISC 3L52 RES
1PA0024151 P 03/24/21 04:04:15 415M 415MISC 3A41 RPT
1PA0024152 P 03/24/21 04:16:28 SUPV SUPERVISOR RQST 3S3 RES 1PA0025572 P 03/28/21 05:39:54 TRST TRANSIENT CAN
1PA0026443 P 03/31/21 00:19:33 TRST TRANSIENT 3L51 RES
1PA0029869 P 04/10/21 05:16:46 FNDPR FOUND PROPERTY CAN p
1PA0031689 P 04/16/21 00:48:50 TRST TRANSIENT 3L51 GOA
1PA0033286 P 04/21/21 06:19:24 TRST TRANSIENT 1L52 RES
1PA0033871 P 04/23/21 00:10:32 415M TRST RES
1PA0034239 P 04/24/21 02:20:24 415M 415MISC 3L51 RES
1PA0035203 P 04/27/21 07:33:54 TRST TRANSIENT 1L52 RES
1PA0035209 P 04/27/21 07:53:36 TRST TRANSIENT 1L52 RES
1PA0035247 P 04/27/21 10:30:34 TRST TRANSIENT 1L52 RES
1PA0036514 P 05/01/21 00:39:58 415M 415MISC 3L52 RES
1PA0036515 P 05/01/21 00:40:55 TRST TRANSIENT 3L11 RES
1PA0037084 P 05/03/21 00:04:35 TRST TRANSIENT 3L52 RES
1PA0037089 P 05/03/21 00:44:03 TRST TRANSIENT 3L52 RES
1PA0037112 P 05/03/21 04:56:43 TRST TRANSIENT 1L52 RES
1PA0037959 P 05/05/21 17:57:14 925 SUSP PERSON 2L55 RES 1PA0038088 P 05/06/21 06:52:38 TRST TRANSIENT 1L51 GOA
1PA0039292 P 05/10/21 03:29:33 TRST TRANSIENT 3A11 GOA
1PA0040491 P 05/14/21 01:24:57 TRST TRANSIENT 3L52 RES
1PA0041168 P 05/16/21 03:40:28 TRST TRANSIENT 3L11 RES
1PA0041170 P 05/16/21 04:02:18 TRST TF(ANSIENT 3L11 RES 1PA0043129 P 05/22/21 00:54:37 TRST TRANSIENT 3L52 RES
1PA0043183 P 05/22/21 08:23:57 243A BATTERY 1L51 RES
1PA0044030 P 05/24/21 19:27:06 459RA BURGLARY ALARM 3L51 FALSE 1PA0044123 P 05/25/21 06:37:14 TRST TRANSIENT 1L12 RES
1PA0044124 P 05/25/21 06:48:16 TRST TRANSIENT 1L32 RES
1PA0044414 P 05/26/21 07:45:57 TRST TRANSIENT 1L52 RES
132 N. EUCLID AV
132 N. EUCLID AV
132 N. EUCLID AV
132 N. EUCLID AV
132 N. EUCLID AV
132 N. EUCLID AV
132 N. EUCLID AV
132 N. EUCLID AV
132 N. EUCLID AV
132 N. EUCLID AV
132 N. EUCLID AV
132 N. EUCLID AV
132 N. EUCLID AV
132 N. EUCLID AV
132 N. EUCLID AV
132N.EUCLIDAV
132 N. EUCLID AV
132 N. EUCLID AV
132 N. EUCLID AV
132 N. EUCLID AV
132 N. EUCLID AV
132 N. EUCLID AV
132 N. EUCLID AV
132 N. EUCLID AV
132 N. EUCLID AV
132 N. EUCLID AV
132 N. EUCLID AV
132 N. EUCLID AV
132 N. EUCLID AV
132 N. EUCLID AV
132 N. EUCLID AV
132 N. EUCLID AV
132 N. EUCLID AV
132 N. EUCLID AV
132 N. EUCLID AV
132 N. EUCLID AV
132 N. EUCLID AV
132 N. EUCLID AV
132 N. EUCLID AV
EXHIBIT B
^
<».;
Pasadena Police Department
Calls For Service Report
Generated by 6076 on 6/17/2025
Search Criteria: City: PA | Time Range: 01/01/21 00:01 - 05/31/22 23:59 | Agency: F,P | Address; 132 N EUCLID AV 1PA0044680
1PA0045827
1PA0046091
1PA0050082
1PA0050603
1PA0052213
1PA0052236
1PA0054814
1PA0056846
1PA0056857
1PA0074227
1PA0075184
1PA0078821
1PA0081689
1PA0083845
1PA0086991
1PA0087221
1PA0087459
1PA0088498
1PA0092343
1PA0093653
1PA0106568
1PA0111406
2PA0002746
2PA0005156
2PA0007037
2PA0014050
2PA0014612
2PA0015487
2PA0016355
2PA0020432
2PA0021511
2PA0025298
2PA0026640
2PA0027058
2PA0032522
p
p
p
p
p
06/15/21
06/20/21
06/20/21
06/28/21
07/04/21
P 05/26/21 23:16:44 TRST TRANSIENT
P 05/30/21 15:13:04 TRST TRANSIENT
P 05/31/21 18:05:50 CHKW CHECK WELFARE
EL
P 06/12/21 23:15:14 TRST TRANSIENT
00:31:53 415FYT 415 FIGHT
07:16:03 TRST TRANSIENT
10:46:07 •7'-°
08:29:42 TRST
00:37:24 459RA
P 07/04/21 01:01:49 TRST
P 08/23/21 12:31:33 PMC
P 08/26/21 11:32:03 459RA
P 09/06/21 07:47:30 459RA
P 09/15/21 17:31:20 FNDPR
p
P 09/22/21 15:20:55 TRST
P 10/03/21 00:31:59 602
P 10/03/21 22:40:33 TRST
P 10/04/21 19:04:30 415M
P 10/08/21 13:27:41 415M
P 10/21/21 09:46:56 FB
P 10/25/21 09:32:16 TRST
P 12/05/21 08:54:01 TRST
P 12/21/21 10:41:15 CHKW
EL
P 01/11/22 09:54:11 EXSER
P 01/19/22 17:49:26 459SA
P 01/25/22 11:22:56 FB
P 02/16/22 16:53:38 487-1
P 02/18/22 13:26:33 602
P 02/21/22 11:32:24 484A
P 02/24/22 10:17:20 602
P 03/08/22 10:27:05 FB
P 03/11/22 16:59:36 FNDPR
p
P 03/23/22 16:02:22 415M
P 03/27/22 19:04:50 PUBAS
T
P 03/29/22 11:53:09 484A PETTC THEFT
P 04/15/22 17:43:14 •"°
TRANSIENT
BURGLARY ALARM
TRANSIENT
HU1L51
BURGLARY ALARM
BURGLARY ALARM
FOUND PROPERTl'
POSS 484A/
TRESPASS
TRANSIENT
415 MISC
415MISC
FOOTBEAT
TRANSIENT
TRANSIENT
CHECK WELFARE
EXTRA SERVICE
SIL BURG ALARM
FOOTBEAT
GRAND THEFT
TRESPASS
PETTf THEFT
415MISC
FOOTBEAT
415 MISC
PUBLIC ASSIST
3L52 RESH 132 N. EUCLID AV
1L51 RES 132 N. EUCLID AV
2L55 UTL 132 N. EUCLID AV
3L51 RES 132 N. EUCLID AV
3L51 RES 132 N. EUCLID AV
1L51 RES 132 N. EUCLID AV
1A21 RES 132 N. EUCLID AV
1L12 RES 132 N. EUCLID AV
3L11 CAN 132 N. EUCLID AV
3A22 RES 132 N. EUCLID AV
1L51 UTL 132 N. EUCLID AV
1L52 RES 132 N. EUCLID AV
1L52 FALSE 132 N. EUCLID AV
2A55 UTL 132 N. EUCLID AV
1L51 GOA 132 N. EUCLID AV
3L51 RES 132 N. EUCLID AV
CAN 132 N. EUCLID AV
3L12 CAN 132 N. EUCLID AV
1L51 RES 132 N. EUCLID AV
HP2 RES 132 N. EUCLID AV
1L52 RES 132 N. EUCLID AV
1L52 GOA 132 N. EUCLID AV
HP2 UTL 132 N. EUCLID AV
HP2 RES 132 N. EUCLID AV
2L55 FALSE 132 N. EUCLID AV
HP2 RES 132 N. EUCLID AV
2L55 RES 132 N. EUCLID AV
1L52 RES 132 N. EUCLID AV
1L51 UTL 132 N. EUCLID AV
1L52 RES 132 N. EUCLID AV
HP2 RES 132 N. EUCLID AV
3L51 RES 132 N. EUCLID AV
2L55 RES 132 N. EUCLID AV
3L52 RES 132 N. EUCLID AV
RPT 132 N. EUCLID AV
2L15 RPT 132 N. EUCLID AV
EXHIBIT B
€.
m^
Pasadena Police Department
Calls For Service Report
:K*Generated by 6076 on 6/17/2025
Search Criteria: City: PA | Time Range: 01/01/21 00:01 - 05/31/22 23:59 | Agency: F,P | Address: 132 N EUCLID AV 2PA0033749 P 04/19/22 14:37:34 459RA BURGLARY ALARM 1L52 FALSE 2PA0033757 P 04/19/22 14:58:41 459RA BURGLARY ALARM 2D1 CAN 2PA0033763 P 04/19/22 15:19:00 459RA BURGLARY ALARM CAN 2PA0033769 P 04/19/22 15:33:01 459RA HU 1L52 1A21 FALSE 2PA0042214 P 05/16/22 08:03:18 PFDAS FIRE DEPT ASSIST CAN T
132 N. EUCLID AV
132 N. EUCLID AV
132 N. EUCLID AV
132 N. EUCLID AV
132 N. EUCLID AV
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