Agenda packet — South Pasadena City Council, May 30, 2023 (part 7 of 12)

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City of South Pasadena
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Environmental Assessment
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3.13 PUBLIC SERVICES AND RECREATION

3.13.1 METHODOLOGY
This section discusses the existing public services in the City of South Pasadena and addresses potential impacts associated with the proposed 2021–2029 Housing Element and the nonresidential development capacity envisioned in the General Plan and Downtown Specific Plan (DTSP) Update (Project) to the following services:
 Fire protection and emergency medical services (South Pasadena Fire Department);  Police protection services (South Pasadena Police Department);  School services (South Pasadena Unified School District);  Library services (South Pasadena Public Library); and  Parks and recreation services (City of South Pasadena).

The public service providers were consulted for information regarding current services and to determine if the proposed Project would significantly impact the respective providers abilities to provide services such that new or physically altered facilities would be required, whose construction could result in an environmental impact. Other information presented in this section was derived from the City’s website and the adopted General Plan.

3.13.2 EXISTING CONDITIONS
Fire Protection and Emergency Medical Services
Fire protection and emergency medical services in the City are provided by the South Pasadena Fire Department (SPFD). The SPFD is a full-service fire department that provides fire/rescue services, paramedics, safety education, inspections, plan reviews, and emergency management.

The SPFD is also an all risk emergency services agency, as SPFD personnel are trained to handle responses such as structure, wildland and vehicle fires, hazardous materials releases, rescues and service calls, and provide advanced life support and medical transport. The SPFD includes the following divisions: Administrative Management, Operations (e.g., fire and emergency medical response), Fire Prevention Bureau (e.g., plan checks, public education, brush clearance program), and Emergency Management Program (e.g., disaster preparedness and response).

There is one fire station in the City, located at 817 Mound Avenue, that houses an engine company (Engine 81), a rescue ambulance, and a light and air unit. The SPFD currently has 21 sworn personnel as well as support personnel. The SPFD operates on a 48/96 schedule1 with in-house daily staffing consisting of 7 personnel as follows: 1 Division Chief, 1 Captain, 2 Engineers, and 3 Firefighter/Paramedics. Battalion Chief coverage is provided by a contract agreement for management between the cities of South Pasadena and San Marino. In 2017 (the most recent data online) there were more than 2,300 responses by the SPFD. Of these, about 1,500 were for incidents within the City borders. The balance of the responses (about 800) were with adjoining agencies. Within the City, the most frequent dispatches are for minor falls and fire alarms.
1 A 48/96 schedule uses 3 teams and 3 shifts to provide 24/7 coverage. It consists of a 6-day cycle where each team works 2 consecutive 24-hour shifts, followed by 4 consecutive days off duty. 3 - 980
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R:\Projects\SPA\3SPA010100\Environmental Documentation\Settlement Agreement\EA\3.13_Public_Serv_Rec-050923.docx 3.13-2 Public Services and Recreation A mutual aid agreement is an agreement in which participating agencies guarantee the provision of available resources to a requesting agency in the event of an emergency. An automatic aid agreement provides services without regard for service boundaries but based on earliest response. The SPFD has automatic aid agreements with the twelve other agencies2 affiliated with the Verdugo Fire Communications Center (VFCC), all of whom operate under the Unified Response agreement. The SPFD also participates in the State of California Master Mutual Aid program, which is used when all available local resources have been depleted or committed to an incident, allowing the State to coordinate resources available from neighboring counties, as necessary.

Police Protection Services
Police protection and law enforcement services in the City are provided by the South Pasadena Police Department (SPPD) from its station at 1422 Mission Street. The SPPD’s mission statement is “…to provide our community with the safest possible environmental using interactive crime prevention methods, public education programs, and the equitable and professional application of the law”. The SPPD includes the following divisions, Field Services and Support Services, each described below.

The Field Services Division provides the front line police services to the community and includes the following: Patrol Officers, Reserves, Traffic Unit, K9 Team, Bicycle Unit, Detective Bureau including Police Assistants, Records, Cadets, and Parking Enforcement, Foothill Air Support Program (FAST), Evidence/Property, Area C Mutual Aid, and Emergency Management. The SPPD has participated in the FAST for the past five years. FAST provides a regional law enforcement helicopter air support program to enhance public safety services in the San Gabriel Valley. FAST also assists with Homeland Security checks at major sporting events in the San Gabriel Valley. Currently, FAST is a partnership between the cities of Alhambra, Arcadia, Covina, Glendora, Monrovia, Pasadena, Pomona, San Marino, Sierra Madre, and South Pasadena. The Support Services Division including Crime Analysis, Crime Prevention, and a School Resource Officer; Office of Professional Standards; Communications; Emergency Operations; and Volunteers. The Support Services Division also oversees department purchases, vehicle and station maintenance, and budget and grant management.

As of 2021, the South Pasadena Police Department consists of 33 sworn officers, 16 non-sworn (i.e., civilian) full-time employees, 4 part-time non-sworn employees, and 2 volunteers; and the SPPD is also augmented with 4 Reserve Officers (SPPD 2022). The SPPD has divided the City into four sections designated as service areas 1 through 4; the dividing lines between the service areas are Meridian Avenue (north-south) and Monterey Road (east-west). In the case of an emergency call for service, officers can respond anywhere in the City, not just the assigned service area. In 2021, SPPD received 54,312 calls for service, including 27,339 calls for dispatched service and 5,909 emergency (i.e., 911) calls. Table 3.13-1, South Pasadena Part One Crime Statistics – Years 2020 and 2021, summarizes the calls for service for Part One Crimes. As shown, Part One Crimes decreased by 20.2 percent from 2020 to 2021 (SPPD 2022). 2 The VFCC currently includes the cities of Alhambra, Arcadia, Burbank, Glendale, Monrovia, Montebello, Monterey Park, Pasadena, San Gabriel, San Marino, Sierra Madre, South Pasadena, and the Bob Hope Airport Fire Department.
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SOUTH PASADENA PART ONE CRIME STATISTICS – YEARS
2020 AND 2021
Crime 2020 2021
Homicide 1 0
Rape 4 2
Robbery 17 10
Assault 66 63
Burglary (Residential) 44 42
Burglary (Commercial) 65 43
Larceny-Theft 429 349
Auto Theft 92 65
Arson 4 2
Total 722 576
Source: SPPD 2022.

School Services
The South Pasadena Unified School District (SPUSD) provides educational services to the City, through three elementary schools, one middle school, and one high school. The SPUSD schools and their enrollment for the 2021–2022 school year are summarized in Table 3.13-2, SPUSD Schools and Enrollment for 2021-2022 School Year.

TABLE 3.13-2
SPUSD SCHOOLS AND ENROLLMENT FOR 2021-2022 SCHOOL YEAR
School Name Address Enrollment (2020–21)
SPUSD High School (Grades 9–12)
South Pasadena High School 1401 Fremont Avenue 1,450 students SPUSD Middle School (Grades 6–8)
South Pasadena Middle School 1500 Fair Oaks Avenue 1,146 students SPUSD Elementary Schools (Grades K–5)
Arroyo Vista Elementary School 335 El Centro Street 683 students Marengo Elementary School 1400 Marengo Avenue 761 students Monterey Hills Elementary 1624 Via Del Rey 584 students Total 4,649 students
Source: CDE 2022.

Library Services
The South Pasadena Public Library (SPPL), located at 1100 Oxley Street, provides library services to the City and is a community resource for literacy, lifelong learning, recreation, and professional development. The SPPL was founded in 1895, with the first dedicated library built in 1907 on the southeast corner of Diamond Avenue and El Centro Street with funding from the Carnegie Corporation. In 1917 the building was significantly expanded, and in 1930 portions of the original building were moved to the current location in the center of Library Park. In 1982, the library underwent a major renovation that included all new construction for reading rooms, 3 - 982
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R:\Projects\SPA\3SPA010100\Environmental Documentation\Settlement Agreement\EA\3.13_Public_Serv_Rec-050923.docx 3.13-4 Public Services and Recreation children’s room, staff areas, conference rooms, and stacks. A portion of the original historic structure was retained as a 3,000-square-foot community room that hosts library and City events and is available to the community as a rental space. The 24,500-square-foot facility offers free high-speed Wi-Fi, Internet connected computers, a conference room, dedicated space for teens and children, and seating for more than 130 people. In the 2020-2021 fiscal year, library collections included 114,300 physical items in print and audiovisual formats, 35,144 e-books and e-audiobooks, 27,403 downloadable video materials, and a wide variety of online resources (e.g., homework help language learning, tools for researchers and job seekers). In 2019, prior to the pandemic, more than 23,000 people attended library programs, including concerts, author talks, storytimes, hands-on crafting activities, book discussions, summer reading program performances and workshops, and other community-focused programs. Except for ongoing operational changes due to the COVID-19 pandemic, the SPPL is open 7 days a week for a total of 57 hours per week, or more than 2,679 public service hours in Fiscal Year 2018–2019. There were 3,270 new library cards issued, more than 260,000 visits, 11,000 reference interactions, approximately 323,000 items checked out, and over 22,000 internet computer sessions (CSL 2019, 2022).

Parks and Recreation Services
City Recreational Facilities
The City of South Pasadena has approximately 118.34 acres of parkland, recreation facilities, and open space areas. The City currently provides approximately 4.6 acres of parkland per 1,000 residents. Table 3.13-3, South Pasadena Parks and Recreational Facilities, summarizes the recreation amenities within the City.

TABLE 3.13-3

SOUTH PASADENA PARKS AND RECREATIONAL FACILITIES
Name/Location Size (acres) Facilities
Neighborhood Public Parks and Other Facilities
Arroyo Seco Park
613 Stoney Drive

73.9 Lighted athletic fields, playground equipment, picnic area, golf course/driving range/miniature golf, racquet center, San Pascual Stables, skate park, batting cages, Arroyo Woodland and Wildlife Park
Garfield Park
1750 Mission Street

7.0 Playground equipment, 2 tennis courts (lighted), picnic areas, walking path, open lawn, fire ring, Youth House, Healing Garden
Eddie Park
2017 Edgewood Drive

1.5 Open lawn, playground equipment/swings, historic Eddie House, group barbecue area
Library Park
1102 Oxley Street

2.0 Benches, open lawn, walkways surrounding library building Orange Grove Park
815 Mission Street

2.5 Softball and soccer fields (lighted), 2 tennis courts (lighted), recreation room, and daycare
Legion Park 2.0 Memorial garden War Memorial building with multi-purpose room for up to 200 people
South Paws-adena Dog Park
650 Stoney Avenue

0.75 Opened in November 2016; off-leash dog park, with separate small and special needs dog, and large dog areas
Arroyo Seco-South Pasadena
Woodland and Wildlife Park
100 Pasadena Avenue

3.0 Trails and seating areas among native California flora and fauna
Total Acres 92.7
Source: South Pasadena 1998
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R:\Projects\SPA\3SPA010100\Environmental Documentation\Settlement Agreement\EA\3.13_Public_Serv_Rec-050923.docx 3.13-5 Public Services and Recreation There are gazebos and/or fields available for reservation by the public at Garfield Park, Orange Grove Park, Arroyo Park, and Eddie Park. There are indoor facilities available for reservation by the public at the War Memorial Building, South Pasadena Senior Center, Eddie Park House, Orange Grove Mid-Level Meeting Room, and Garfield Park Youth House. Garfield Park is also the first zero-emission American Green Zone Alliance Green Zone municipal park in the United States.

Park development, renovation, and maintenance, as well as leisure classes and recreational programs are provided by the South Pasadena Community Services Department. The Community Services Department also oversees the City-leased and -managed properties, including the Arroyo Seco Golf Course, Arroyo Seco Racquet Club, San Pasqual Stables, All-Star Baseball School Batting Cages, and South Pasadena Historical Museum; manages the South Pasadena Senior Center and related services, including Dial-A-Ride; and provides a variety of youth services and events, including after-school programs and middle school summer camp (South Pasadena Community Services Department 2022).

Regional Recreational Facilities
The Angeles National Forest is located at the San Gabriel Mountains approximately five miles north of the City. This National Forest has a natural environment, offering scenic views, with developed campgrounds, picnic areas, and opportunities for swimming, fishing, and skiing.

Walking and hiking trails wind throughout the forest for use by hikers, equestrians, mountain bikers, and off-highway vehicle enthusiasts.

There are a variety of recreation opportunities within the Arroyo Seco where it extends several miles northward from the City of South Pasadena. The Lower Arroyo Seco is the area south of the Colorado Street Bridge; the Central Arroyo Seco is the area between the bridge and Devil’s Gate Dam; and the Upper Arroyo, or Hahamongna Watershed Park, is a large park that extends from the dam into the Angeles National Forest. The Lower Arroyo Seco includes features such as a casting pond, archery range, bird sanctuary, memorial grove, and the historic La Casita del Arroyo; the Central Arroyo Seco includes features such as the 3.3-mile paved recreation loop around the Rose Bowl, Rose Bowl Stadium, Rose Bowl Aquatic Center, Kidspace Children’s Museum, Brookside Park, and Brookside Golf Course; and the Hahamongna Watershed Park includes features such as Oak Grove multipurpose field, Flint Wash Bridge, Oak Grove Disc Golf Course, spreading basins and Devil’s Gate Dam (a County of Los Angeles Department of Public Works facility). There are hiking, biking, and/or equestrian trails throughout the Arroyo Seco, including trails that connect the City of South Pasadena north to the Hahamongna Watershed Park (Pasadena 2010).

The Ernest E. Debs Regional Park, located at 4235 Monterey Road in the Montecito Heights neighborhood of central-northeast Los Angeles less than one mile from South Pasadena at the nearest point, is a large open space nature reserve and park operated and maintained by the City of Los Angeles Department of Recreation and Parks (Los Angeles 2018).

Griffith Park, also operated by the City of Los Angeles, is located at 2800 East Observatory Road approximately 5.5 miles west-northwest of South Pasadena. Griffith Park is one of the largest municipal park in North America and is the largest historic landmark in the City of Los Angeles, now covering 4,511 acres. In addition to providing over 70 miles of hiking and equestrian trails, Griffith Park houses the Griffith Observatory, Autry Museum of the American West, Greek Theatre, Los Angeles Zoo, Travel Town Transportation Museum, Los Angeles Live Steamers Railroad Museum, Shane’s Inspiration universally-accessible playground, a ranger station, two 3 - 984
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R:\Projects\SPA\3SPA010100\Environmental Documentation\Settlement Agreement\EA\3.13_Public_Serv_Rec-050923.docx 3.13-6 Public Services and Recreation 180 hole golf courses, three tennis complexes, and “The Plunge” swimming pool (Los Angeles 2016).

There are other public recreation spaces of various sizes and amenities within approximately 10 miles of the City, maintained by the County or other city municipalities. The above-described facilities are the largest and/or nearest major regional facilities that City of South Pasadena residents can access with ease.

3.13.3 RELEVANT PROGRAMS AND REGULATIONS
State
California Fire Plan
In a collaborative effort between the State Board of Forestry and the California Department of Forestry and Fire Protection (CDF), the 2018 Strategic Fire Plan for California (Fire Plan) was prepared to address the protection of lives and property from California wildfires while recognizing that wildfires are a natural phenomenon and can have beneficial effects, particularly on ecosystem health. The Fire Plan is a comprehensive update to the 2010 Strategic Fire Plan for California.

California Disaster and Civil Defense Master Mutual Aid Agreement The California Disaster and Civil Defense Master Mutual Aid Agreement is an agreement between the State of California, its various departments and agencies, and the various political subdivisions, municipal corporations, and other public agencies of the State of California. The agreement allows for the use of all the resources and facilities of the participating agencies in preventing and combating the effect of disasters, such as flood, fire, earthquake, pestilence, war, sabotage, and riot. It commits the participating agencies to voluntarily aid and assist each other in the event of a disaster, through the interchange of services and facilities, including fire, police, medical and health, communication, and transportation services and facilities, as necessary to provide rescue, relief, evacuation, rehabilitation, and reconstruction.

Assembly Bill 2926
The State has traditionally been responsible for funding local public schools. To assist in providing facilities to serve students generated by new development projects, the State passed Assembly Bill (AB) 2926 in 1986. This bill allows school districts to collect impact fees from developers of new residential and commercial/industrial building space to fund school construction and reconstruction. AB 2926 also established maximum fees (adjusted for inflation) which can be collected under this and any other school fee authorization.

Senate Bill 50
Senate Bill (SB) 50 (or “Leroy Greene School Facilities Act”) and Proposition 1A (both of which passed in 1998) provide a comprehensive school facility financing and reform program by, among 3 - 985
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R:\Projects\SPA\3SPA010100\Environmental Documentation\Settlement Agreement\EA\3.13_Public_Serv_Rec-050923.docx 3.13-7 Public Services and Recreation other methods, authorizing both a $9.2 billion school facilities bond issue and school construction cost containment provisions. Specifically, the bond funds are to provide for new construction and for reconstruction/modernization needs. The provisions of SB 50 (1) prohibit local agencies from denying either legislative or adjudicative land use approvals on the basis that school facilities are inadequate and (2) reinstate the school facility fee cap for legislative actions (e.g., general plan amendments, specific plan adoption, zoning plan amendments). According to Section 65996 of the California Government Code, the development fees authorized by SB 50 are deemed to be “full and complete school facilities mitigation”.

SB 50 establishes three levels of developer fees that may be imposed upon new development by a school district’s governing board. Beginning in 2000, the maximum allowable amount of Level 1 developer fees is adjusted every two years based on the change in the statewide cost index for class B construction per Section 65995(b)(3) of the Government Code (OPSC 2023). These fee levels depend upon certain conditions within a district. For year 2022, these three levels currently include the following:

Level 1: Level 1 fees are the base statutory fees. Level 1 fees are $4.79 per square foot (sf) for new residential development and $0.78 per sf of chargeable, covered, and enclosed floor space for new commercial/industrial development. These amounts represent the maximum that can currently be legally imposed upon new development projects by a school district unless the district qualifies for a higher level of funding. Payment of this fee is deemed to constitute full, complete, and adequate mitigation of a project’s impacts on school facilities (OPSC 2023).

Level 2: Level 2 fees allow a school district to impose developer fees above the statutory levels up to 50 percent of school construction costs under designated circumstances. The State provides grant amounts for new school construction if funds are available.

Level 3: Level 3 fees apply if the State runs out of bond funds, allowing a school district to impose 100 percent of the cost of the school facility or mitigation on the developer minus any local dedicated school monies. However, Senate Bill 1016 (Chapter 38, Statutes of 2012) suspended the ability of school districts to levy Level III fees.

To accommodate students from new development projects, school districts may alternatively finance new schools through special school construction funding resolutions and/or agreements between developers, the affected school districts and, occasionally, other local governmental agencies. These special resolutions and agreements often allow school districts to realize school mitigation funds in excess of the developer fees allowed under SB 50. As discussed further below, SPUSD adopted Level 1 Developer Fees that were effective December 12, 2022.

Quimby Act
California allows a City or County to pass an ordinance that requires, as a condition of approval of a subdivision, either the dedication of land, the payment of a fee in lieu of dedication, or a combination of both for park or recreational purposes (California Government Code, Section 66477). This legislation, commonly called the “Quimby Act,” establishes a standard of 3 acres of parkland per 1,000 residents for new subdivision development unless the municipality has already established a higher rate. This is the case with the City of South Pasadena, which has set a standard of 4 acres per 1,000 population.
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R:\Projects\SPA\3SPA010100\Environmental Documentation\Settlement Agreement\EA\3.13_Public_Serv_Rec-050923.docx 3.13-8 Public Services and Recreation In February 2008, the City established a Park Impact Fee of $5.89 per sf with an exemption for the first 250 square feet for renovations/remodels. In June 2016, the City Council increased the fee to $7.65 per sf of new or remodeled residential, with fees for senior housing projects at $2.95 per sf, and exemptions for the first 250 sf of the project that increases the habitable living space.

These capital fees remain in place as of the City’s Master Fee Schedule effective July 1, 2022 (South Pasadena 2022).

Assembly Bill 602
AB 602 imposes additional standards and procedures for agencies adopting impact fees. It requires agencies to identify an existing level of services for public facilities and information supporting the agency's actions in increasing fees and requires agencies to impose fees on a housing development proportionately to the square footage of the development or make findings for a different methodology. Agencies must adopt studies at a public hearing with at least 30 days’ notice, notify any member of the public who requests notice of an impact fee nexus study, and consider any evidence submitted by any member of the public that the agency's determinations or findings are insufficient. Large jurisdictions are required to adopt a capital improvement plan as part of the nexus study. Agencies must update nexus fee studies at least every eight years from the period beginning on January 1, 2022. Agencies must also post the current impact fee schedule and update at least twice a year. Finally, the law directs the California Department of Housing and Community Development (HCD) to create an impact fee nexus study template. The modification or establishment of development impact fees in the City, that would apply to new development or redevelopment pursuant to the Project, would be developed in compliance with AB 602.

City
Municipal Code
Chapter 16A, Growth Requirement Capital Fee
Pursuant to Chapter 16A of the South Pasadena Municipal Code (SPMC), the City assesses a growth requirement capital fee (capital fee) upon new residential and commercial development within City boundaries to support the associated need for additional public facilities and services.

The fees collected from residential development are used for all capital improvements, which include government, police, and fire facilities; essential infrastructure and related facilities; and cultural and recreational facilities. Residential developments also pay a park facilities impact fee in addition to the capital fee, which contributes to the City’s funding for park facilities. The capital fees collected from commercial and industrial development are only used for capital improvements but not park facilities.

The capital fee is based on a formula designed to ensure that individual developers pay their fair share for public facilities needed to serve the city’s growing population. The rates upon which the fees are based shall be adjusted as of July 1st of each year to reflect changes in building costs as determined by the Construction Cost Index for Los Angeles. The public improvements are identified by category in the city’s capital improvement program, which is updated annually.

Effective July 1, 2022, the capital fees are $1.64 per sf for residential and $1.07 per sf for commercial (South Pasadena 2022).
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R:\Projects\SPA\3SPA010100\Environmental Documentation\Settlement Agreement\EA\3.13_Public_Serv_Rec-050923.docx 3.13-9 Public Services and Recreation South Pasadena Unified School District and SB 50
Per SB 50, SPUSD requires developers to pay fees for new residential, commercial, and industrial development; residential construction which increases assessable space by greater than 500 sf; and location, installation, or occupancy of manufactured and mobile homes. The current fees, which went into effect on December 12, 2022, are as follows: No fee for Additions to Existing Residences under 500 sf; $4.79 per sf for Additions to Existing Residences over 500 sf or New Residential; and $0.78 per sf for Commercial/Industrial (SPUSD 2023).

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

Threshold 3.13a: 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:
a) Fire protection.
b) Police protection.
c) Schools.
d) Parks.
e) Other public facilities.

Threshold 3.13b: 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; and/or
Threshold 3.13c: Include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment.

3.13.5 PROPOSED HOUSING ELEMENT GOALS AND POLICIES
There are no Housing Element goals or policies related to public services and recreation.

3.13.6 ENVIRONMENTAL IMPACTS
Threshold 3.13a: 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:
a) Fire protection?
b) Police protection?
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R:\Projects\SPA\3SPA010100\Environmental Documentation\Settlement Agreement\EA\3.13_Public_Serv_Rec-050923.docx 3.13-10 Public Services and Recreation c) Schools?
e) Other public facilities?
Fire Protection and Emergency Medical Services
Future development pursuant to the Project would increase the number of residents, employees, businesses, and structures in the City, including patrons and visitors, thereby increasing the demand for fire protection services. This development is anticipated to create the typical range of fire service calls that other similar uses existing in the City generate. Assuming buildout of the Project, the City is anticipated to increase by up to 2,775 dwelling units (DUs) and 430,000 sf of retail/office land uses, which would generate an estimated 6,882 residents and 1,978 jobs. It is noted the proposed increase in non-residential uses is focused on office and retail development, and no industrial/manufacturing land uses that would more likely handle hazardous materials and/or have increased fire risk are envisioned. The SPFD has indicated the existing facilities and staffing could support the buildout of land uses, and associated increase in resident and daytime population, under the proposed Project.

Individual development projects would be reviewed by the SPFD as part of the City’s project review process and would be required to comply with all fire code standards in effect at the time the building permit is issued, pursuant to Section 14.4 et. seq. of the SPMC, which includes requirements for building construction, fire flows and pressures, hydrant placement, and other requirements that would reduce the creation of fire hazards and facilitate emergency response.

Additionally, the area located south of Monterey Road and west of Meridian Avenue is defined as a “High risk fire area” pursuant to Section 14.1 of the SPMC. In addition to City fire code standards, development of any parcels in this area would be required to have Class A roof assemblies, which are effective against severe fire test exposures.

The SPFD has determined the construction of new or expanded facilities would not be required to serve the projected growth in the City; therefore, there would be no physical impacts associated with the construction of new facilities as a result of the General Plan Update. Additionally, future funding for maintenance of SPFD resources and services (i.e., fire inspectors or fire companies) would be provided through the City’s capital fee program collected on new development (Chapter 16A of the SPMC) as well as through the collection of taxes from existing taxes. If it is determined at a later date that additional fire protection facilities are required, such a development would be subject to project-specific environmental review pursuant to the California Environmental Quality Act (CEQA). Construction-related impacts that would be anticipated from new development would be similar to those addressed for buildout of the Project, as discussed in Sections 3.1 through

3.16 of this Environmental Assessment (EA), and specifically Section 3.2, Air Quality; Section 3.11, Noise; and Section 3.14, Transportation.

Therefore, with implementation of the Projectwould result in less than significant impacts to fire protection services and no mitigation is required.

Police Protection Services
Future development pursuant to the Project would increase the number of residents, employees, businesses, and structures in the City, including patrons and visitors, thereby increasing the demand for police protection services. Increase in vehicle trips on City roadways could also increase the potential for traffic accidents and violations. These factors would lead to increases in the demand for police protection and law enforcement services from the SPPD. 3 - 989
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R:\Projects\SPA\3SPA010100\Environmental Documentation\Settlement Agreement\EA\3.13_Public_Serv_Rec-050923.docx 3.13-11 Public Services and Recreation The SPPD has indicated that while the existing facilities could support the buildout of land uses under the Project, it is recommended that two additional sworn police officers are added to the existing staff. This increase in staff would also entail an additional administrative cost to support the increase in calls for service, public requests, special events, community activities, and ancillary support. The small increase in sworn and non-sworn support staff to provide police protection services to future land uses and populations is solely a cost-based issue. The funding for new officer positions and resources needed to maintain acceptable Citywide police protection service levels comes from the growth requirement capital fee assessed on all new residential and commercial development (Chapter 16A of the SPMC) and the City’s General Fund. Property taxes and other fees assessed on property owners within the City contribute to the General Fund revenues.

However, the SPPD has determined that construction of new or expanded facilities is not required to support implementation of the General Plan and DTSP Update& 2021–2019 Housing Element.

If it is determined at a later date that additional police protection facilities are required, they would be subject to project-specific environmental review pursuant to CEQA. Construction-related impacts that would be anticipated from new development would be similar to those addressed for buildout of the Project, as discussed in Sections 3.1 through 3.16 of this EA, and specifically Section 3.2, Air Quality; Section 3.11, Noise; and Section 3.14, Transportation/Traffic.

Therefore, the proposed Projectwould result in less than significant impacts to police protection services, and no mitigation is required.

School Services
Future development pursuant to the Project would increase the number of homes in the City through 2040, thereby increasing the demand for school services. For purposes of this analysis, all student generation in the City is assumed to be served by the SPUSD.

Long term enrollment projections are predicated primarily on birth rates, property and rental values, family migration patterns and unknown changes in the California Education Code by the Governor and State Legislature. Therefore, current facilities for elementary, middle, and high school students may need to be expanded. Specifically, the SPUSD envisions the need for expansion of permanent (non-modular) facilities on existing campuses and/or reopening the Oneonta School, located at 1955 Fremont Avenue, as an SPUSD elementary school and/or reconfiguring the grade level composition at its elementary and middle schools. The Oneonta School property is owned by the SPUSD, and the facility is leased by the Institute for the Redesign of Learning Almansor Academy, a special education non-public day school. The latter option would require extensive remodeling and modernization to accommodate the planned use.

When and if it is determined that expanded and/or renovated school facilities are required, they would be subject to project-specific environmental review pursuant to CEQA and would also be required to comply with State standards for school siting. This would include consideration of any indirect effects to the Almansor Academy and its relocation. However, at this time, there is not enough data to determine the precise scenario for expanding permanent elementary school services that would ultimately be determined preferable by the SPUSD. As such, the environmental effects of such expansion are not reasonably captured in this EA.

Construction-related impacts that would be anticipated from new development would be similar to those addressed for buildout of the Project, as discussed in Sections 3.1 through 3.16 of this EA, and specifically Section 3.2, Air Quality; Section 3.11, Noise; and Section 3.14, Transportation/Traffic.
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R:\Projects\SPA\3SPA010100\Environmental Documentation\Settlement Agreement\EA\3.13_Public_Serv_Rec-050923.docx 3.13-12 Public Services and Recreation As allowed under the SB 50, school districts serving the City can assess school impact fees based on the floor area of new dwelling units and non-residential developments. These fees are used to fund school services and facilities needed to provide the necessary school services. Future development would need to pay school impact fees prior to issuance of building permits. These fees are subject to changes on an annual basis, as deemed appropriate by the SPUSD, and will be determined at the time individual projects are processed/reviewed. As noted above, SPUSD’s current fees are as follows: $4.79 per sf for Residential and $0.78 per sf for Commercial (SPUSD 2023). As part of this fee program, information on individual development projects would have to be submitted to the school districts that would serve each development to determine applicable school impact fees and to allow the school districts to analyze potential demand for school services and the facility needs of the development. In addition to SB 50 fees, State and local bond measures have been passed, and may be passed in the future, to fund additional school facilities.

As provided under California Education Code Section 17620 and California Government Code Section 65970, the payment of statutory school fees is presumed to fully mitigate a project’s impacts on schools. California Government Code Section 65995(h) states that payment of fees is “full and complete mitigation of the impacts”. The California Education Code and California Government Code do not require the dedication of land or payment of fees in excess of statutorily established school fees. Thus, impacts on school services from future residential development would be less than significant with payment of required SB 50 fees, and no mitigation is required.

Library Services
For purposes of this EA, other public services refer to library services.

Future development pursuant to the Project would increase the number of residents in the City, thereby increasing the demand for library services. The American Library Association and the Public Library Association do not publish service ratio standards for public libraries since needs vary across diverse communities; however, there are a variety of professional resources available (e.g., The National Institute of Building Sciences3) that provide a standard framework for calculating public library facility and equipment needs based on population. These guidelines address collection space, user seating space, staff workspace, meeting space, and special use space.

Based on current cardholder data, the SPPL assumes that approximately 55 percent of future residents would carry and use a library card, or approximately 17,854 total residents (55 percent of the projected 2040 population of 32,462). SPPL residents make up 53 percent of the total number of active cardholders. While the popularity of the library’s e-books and e-audiobooks that are available remotely continues to increase, lending of physical materials remains robust and the demand for in-person services at the library is undiminished. The SPPL states that the library is the most visited public building in the City, and it is expected that the demand for in-library services, including computers, Wi-Fi, space to work and study, librarian assistance, and programs and special events, would increase as the population increases. The existing library facility and equipment is not always adequate to meet current demand.

The SPPL was last expanded and renovated in 1982 and as early as 2020 the Library Board of Trustees recognized that the library needed to be upgraded and expanded to meet the community’s needs for a 21st century library. The City and the SPPL have considered expanding library services into the existing Senior Center if and when a new Community Center is 3 https://www.wbdg.org/building-types/libraries/public-library 3 - 991
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R:\Projects\SPA\3SPA010100\Environmental Documentation\Settlement Agreement\EA\3.13_Public_Serv_Rec-050923.docx 3.13-13 Public Services and Recreation constructed. However, a new Community Center remains in the planning stages, and the location and timing of this facility is unknown.

The SPPL would continue to evaluate library space with regard to adequacy of levels of service as the City grows in the future. The City’s growth requirement capital fee assessed on all new residential and commercial development (Chapter 16A of the SPMC) is intended in part to support library services. When and if it is determined that additional library facilities are required, they would be subject to project-specific environmental review. Like the discussion of schools above, a likely path to provide expanded library services has already been identified and would also involve reuse of an existing space; however, at this time, there is not enough data to determine the precise scenario for expanding library services that would ultimately be implemented by the City. As such, the environmental effects of such expansion are not reasonably captured in this EA and would be analyzed as a separate project in the future, if implemented. Constructionrelated impacts that would be anticipated from new development would be similar to those addressed for buildout of the Project, as discussed in Sections 3.1 through 3.16 of this EA, and specifically Section 3.2, Air Quality; Section 3.11, Noise; and Section 3.14, Transportation/Traffic.

Therefore, the proposed Projectwould result in less than significant impacts to library services, and no mitigation is required.

Threshold 3.13a: 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:
d) Parks?
Future development pursuant to the Project would increase the number of residents in the City, thereby increasing the demand for recreational services. Non-residential development is not likely to create a direct demand for parks and recreational facilities. As discussed above, the City has approximately 118 acres of parks, equating to approximately 4.6 acres of parkland per 1,000 residents. The City’s parks standard of 5 acres of parkland per 1,000 residents is slightly higher than the State standard at 4 acres of parkland per 1,000 residents.

To meet this standard for the existing population (25,580 persons), an estimated 9.5 acres of additional, or 128 acres total, of parks, recreation facilities, and open space areas would be needed. To meet this standard for future growth, the estimated 6,882 residents generated with buildout of the Project (assuming no residential vacancies) would require approximately

34.4 acres of parks and other recreation facilities. When considering both existing and future growth, an estimated 44.0 acres of additional, or approximately 162 acres total, of parks and other recreation acres would be needed.

In Spring 2017, the City has acquired the deeds to two parcels previously owned by Caltrans, located at 2006 Berkshire Avenue and 1107 Grevelia Street, for the development of pocket parks.

The City Council has approved the hiring of a landscape architecture firm to compile the results of the ongoing public outreach effort and complete a conceptual design for each park, for use in seeking grant funding for the construction of each site. On May 10, 2021, the City reinitiated this effort with a community meeting. On June 14, 2021, the Parks and Recreation Commission provided a recommendation to City Council to move forward with the concept designs and 3 - 992
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R:\Projects\SPA\3SPA010100\Environmental Documentation\Settlement Agreement\EA\3.13_Public_Serv_Rec-050923.docx 3.13-14 Public Services and Recreation construction documents for the two pocket parks. In August 2021, City Council approved the concept designs and associated budgets for construction of the pocket parks.

The City would strive to meet and maintain acceptable parkland standards. The City recognizes that providing adequate, or abundant, parks and other open spaces has substantial benefits both to its residents and to the environment. Site-specific improvement plans would be evaluated at the time the development is proposed. Construction-related impacts that would be anticipated from new development would be similar to those addressed for buildout of the Project, as discussed in Sections 3.1 through 3.16 of this EA, and specifically Section 3.2, Air Quality; Section 3.11, Noise; and Section 3.14, Transportation/Traffic.

Therefore, the Project would result in less than significant impacts to parks services, and no mitigation is required.

Threshold 3.13b: 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? The additional residents in the City pursuant to the Project would be likely to use both existing and future parks and recreational facilities in the City, as well as facilities in the surrounding area.

These include City parks, County parks and recreational facilities, private recreational facilities, and recreational areas at the Angeles National Forest.

As discussed above, to meet the proposed standard of 5 acres of parks per 1,000 residents for future growth, the estimated 6,882 residents generated with buildout of the Project would require approximately 44.0 acres of parks and other recreation facilities. The City currently provides approximately 4.6 acres of parks per 1,000 residents, which exceeds the State/Quimby Act standard of 3 acres per 1,000 residents. Under this standard, the City’s approximately 118 acres of parks and recreation facilities would meet the State standard even when considering the projected growth under the Project, which would equate to approximately 97 acres. Therefore, the need to add parkland to meet the City’s standard is solely a function of the high standard for recreation being sought. However, when considering that the State standard would be met (for what is considered adequate parkland in combination with the likely expansion of parks in the City, the addition of an estimated 6,882 residents (assuming no residential vacancies) would not 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.

Therefore, the Project would result in less than significant impacts to park conditions, and no mitigation is required.

Threshold 3.13c: Would the Project include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment?
There are no individual parks or recreational facilities that would be constructed through adoption of the Project. New parks or park expansions that would be constructed by the City or are part of individual development projects are expected to occur within the developed areas of the City, including infill vacant lots. As discussed above, many of the methods that may be used to create additional parkland involve the strategic and creative use of existing lands in the City, such as the Southern California Edison easement and vacant lots, as the City is largely built out. The development of new parks and recreational facilities would be a beneficial impact in the City by meeting existing and future demands. New parks and recreational facilities would result in 3 - 993
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R:\Projects\SPA\3SPA010100\Environmental Documentation\Settlement Agreement\EA\3.13_Public_Serv_Rec-050923.docx 3.13-15 Public Services and Recreation environmental impacts as discussed under the various sections of this EA, including but not limited to short-term construction-related impacts (e.g., air quality, noise, and water quality) as well as long-term operational impacts (e.g., light/glare, noise, traffic). There are several policies and actions pertaining to recreation facilities that focus on the sustainable long-term operation and maintenance of these facilities, both environmentally and financially. Individual park projects would be subject to separate environmental review once specific development plans are identified.

Therefore, the proposed Project would result in less than significant impacts to park construction, and no mitigation is required.

3.13.7 CUMULATIVE IMPACTS
Future growth and development within the San Gabriel Valley would generate increased demand for public services from various service agencies. While increases in demand would occur on other public service agencies that do not serve the City, future development pursuant to the Project would not add to the service demands on those agencies that do not serve the City. Thus, the cumulative analysis for public services considers the service area of the respective providers and adjacent service agencies, as they may be affected by services provided in the City. As identified in this section, the proposed Project would not result in cumulatively considerable impacts related to public services, and no mitigation is required.

Fire Protection and Emergency Medical Services
For fire protection services, the SPFD provides automatic aid to the cities of Alhambra, Arcadia, Burbank, Glendale, Monrovia, Montebello, Monterey Park, Pasadena, San Gabriel, San Marino, and Sierra Madre and the Bob Hope Airport Fire Department as part of the VFCC. The SPFD also participates in the State of California Master Mutual Aid program, which is used when all available local resources have been depleted or committed to an incident, allowing the State to coordinate resources available from neighboring counties, as necessary. Thus, future development in the City of South Pasadena and the VFCC participating agencies would increase the population and introduce structures that would create a demand for fire protection and emergency services. This cumulative demand for fire protection services would require additional personnel and resources at individual agencies to provide the same level of service and maintain existing response times.

Conversely, the purpose of the VFCC is to provide a localized dispatch center with a borderless system among the participating agencies whereby the nearest available responder to the event, regardless of jurisdictional boundary, would provide the needed fire or emergency services.

Essentially, each participating agency has the resources of all other participating agencies available for emergency response.

Individual developments are required to comply with pertinent provisions of the California Fire Code to prevent the creation of fire hazards, to promote fire safety, and to facilitate emergency response. The individual fire agencies, including the SPFD, also regularly review their services and the needed increases in staffing, fire stations, and equipment, as necessary, to keep response times acceptable and to adequately serve their service areas. Plan reviews of proposed development projects by the individual fire departments would accomplish the following:
(1) prevent the creation of fire safety hazards by development; (2) require fire prevention measures to be incorporated into individual projects; and (3) facilitate fire emergency response by providing adequate access and fire alarm systems. Compliance with these existing regulations by the participating VFCC agencies would avoid potential significant cumulative impacts on fire protection service levels, and no mitigation is required. 3 - 994
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R:\Projects\SPA\3SPA010100\Environmental Documentation\Settlement Agreement\EA\3.13_Public_Serv_Rec-050923.docx 3.13-16 Public Services and Recreation Police Protection Services
For police protection services, the geographic area for consideration of cumulative impacts is the City, as this is the SPPD service area. As discussed, the SPPD participates in FAST Program, which provides a regional law enforcement helicopter air support program. The SPPD also participates in a mutual aid program similar to the fire department. As determined in the analysis above, implementation of the Project would result in less than significant impact related to police protection services. Therefore, there would not be a significant cumulative impact, and no mitigation is required.

School Services
For school services, the geographic area for consideration of cumulative impacts is the City, as this is the SPUSD service area. As determined in the analysis above, implementation of the Project would result in less than significant impact related to school services. Therefore, there would not be a significant cumulative impact, and no mitigation is required.

Library Services
For library services, the geographic area for consideration of cumulative impacts is the City, as this is the SPPL service area. As determined in the analysis above, implementation of the Project would result in less than significant impact related to library services. Therefore, there would not be a significant cumulative impact, and no mitigation is required.

Parks and Recreation Services
Future residential development pursuant to the proposed Project and development projects in areas surrounding the City would contribute to the cumulative need for more parks and recreation within the City. The analysis of cumulative impacts to parks and recreation considers buildout of the City and growth and development in the San Gabriel Valley through year 2040.

Typically, parkland requirements are a function of expected demand and are related to the number of residential dwelling units created by projects. Pursuant to Section 66477 of the California Government Code (or Quimby Act), many nearby cities (e.g., Arcadia, Pasadena, Sierra Madre, Temple City, and El Monte and the County of Los Angeles) have adopted Quimby Act ordinances that require the payment of fees or the dedication of parkland to meet the demand for parks and recreational facilities generated by each residential development. Consistent with these regulations, developers of individual projects would pay park fees, dedicate open space lands for park and recreation development, and/or provide on-site recreational facilities to meet the demand for parks and recreational facilities generated by each development. Thus, residential developments in and around the City of South Pasadena would provide parks and recreational facilities to meet their demands. Based on the small increment of park demand (approximately seven acres) required for the Project and the adoption of Quimby Act requirements by several surrounding cities and the County, no significant cumulative impacts would result related to park demand from regional population growth.

The development of new parks and recreational facilities to meet the demand of future growth and development in the San Gabriel Valley would result in cumulative environmental impacts.

Since the Valley is largely built out, these projects are not expected to represent a significant amount of new development and construction in the Valley. These projects would be subject to separate environmental review once specific development plans are identified. Since new parks 3 - 995
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R:\Projects\SPA\3SPA010100\Environmental Documentation\Settlement Agreement\EA\3.13_Public_Serv_Rec-050923.docx 3.13-17 Public Services and Recreation developed under the Project would have less than significant impacts, the Project’s cumulative contribution to impacts related to parks and recreation is also considered less than significant.

The increase in San Gabriel Valley population through 2040 would result in the increased use of existing neighborhood and regional parks or other recreational facilities. However, the surrounding cities, County of Los Angeles, and National Forest Service have policies and programs to maintain and/or develop recreation facilities to meet increased demand. It is not expected that there would be regional growth, without some parallel growth of recreation facilities, such that the existing facilities would experience substantial physical deterioration. There would be no significant cumulative impacts related to deterioration of existing facilities from regional population growth, and no mitigation is required.

3.13.8 MITIGATION MEASURES
No significant adverse impacts related to public services and recreation have been identified with implementation of relevant policies and actions . Therefore, no mitigation is required.

3.13.9 LEVEL OF SIGNIFICANCE AFTER MITIGATION
Less than significant.

3.13.10 REFERENCES
California Department of Education (CDE). 2023 (April 27, access date). DataQuest Home:

Enrollment Report: 2021-22 Enrollment by Grade: South Pasadena Unified School District (19-65029). Sacramento, CA: CDE.
https://dq.cde.ca.gov/dataquest/SearchName.asp?rbTimeFrame=oneyear&rYear=2022- 23&cName=south+pasadena&Topic=Enrollment&Level=District&submit1=Submit.

California Department of Forestry and Fire Protection (CAL FIRE) and State Board of Forestry and Fire Protection. 2018 (August 22). 2018 Strategic Fire Plan for California.

Sacramento, CA: CDF. THE 2009 STRATEGIC FIRE PLAN (ca.gov).

California State Library (CSL). 2023 (April 27, access date). California Library Statistics: All Data:

FY21-22: Excel file. Sacramento, CA: CSL. https://library.ca.gov/wpcontent/uploads/librarystats/All-DataFY20-21.xlsx.

Los Angeles, City of, Department of Recreation and Parks. 2018 (April 2, access date). Ernest E.

Debs Regional Park. Los Angeles, CA: the City. https://www.laparks.org/park/ernest-edebs-regional. ———. 2016. Griffith Park Map & Guide. Los Angeles, CA: the City. https://www.laparks.org/sites/default/files/griffith/pdf/GriffithParkInfo.pdf.

Office of Public School Construction (OPSC). 2023, April 27 (access date). Annual Adjustment to SFP Grants and Developer Fee History. https://www.dgs.ca.gov/OPSC/Resources/PageContent/Office-of-Public-School-Construction-Resources-List-Folder/Annual-Adjustmentto-SFP-Grants-and-Developer-Fee-History.

Pasadena, City of. 2010 (Revised). Explore the Arroyo Seco. Pasadena, CA: the City. https://ww5.cityofpasadena.net/wp-content/uploads/sites/52/2016/10/Aroyo-Seco-TrailGuide-Infosheet.pdf. 3 - 996
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R:\Projects\SPA\3SPA010100\Environmental Documentation\Settlement Agreement\EA\3.13_Public_Serv_Rec-050923.docx 3.13-18 Public Services and Recreation South Pasadena, City of. 2022 (July 1, effective date). Master Fee Schedule. South Pasadena, CA: the City.
https://www.southpasadenaca.gov/government/departments/finance/master-feeschedule.

South Pasadena, City of, Community Services Department. 2022 (July 20, access date).

Recreation and Youth Services. South Pasadena, CA: the City. Recreation & Youth Services | South Pasadena, CA (southpasadenaca.gov).
———. 1998. City of South Pasadena General Plan, Open Space & Resource Conservation Element. South Pasadena, the City. http://www.ci.southpasadena.ca.us/modules/showdocument.aspx?documentid=214.

South Pasadena Police Department (SPPD). 2022. South Pasadena 2020-2021 Biennial Report.

South Pasadena, CA: SPPD. 637842390702230000 (southpasadenaca.gov) South Pasadena Unified School District (SPUSD). 2022 (October 11, adopted). Developer Fee Information. South Pasadena, CA: SPUSD.
https://www.spusd.net/apps/pages/index.jsp?uREC_ID=756718&type=d&pREC_ID=117 7025.
———. 2016 (January). Mission Place Project Draft Environmental Impact Report. South Pasadena, CA: SPUSD.
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R:\Projects\SPA\3SPA010100\Environmental Documentation\Settlement Agreement\EA\3.14_Transportation-050923.docx 3.14-1 Transportation/Traffic

3.14 TRANSPORTATION

3.14.1 METHODOLOGY
This section evaluates the potential for implementation of the proposed 2021–2029 Housing Element and the non-residential development capacity envisioned in the General Plan and Downtown Specific Plan (DTSP) Update (Project)s to result in transportation and traffic impacts in the City of South Pasadena (City). This section describes the existing transportation conditions in the City, including the roadway network, bicycle and pedestrian network, transit network, and current intersection and roadway segment operations.

On May 20, 2020, the City adopted California Environmental Quality Act (CEQA) transportation analysis thresholds (Resolution No. 7656) pursuant to Senate Bill (SB) 743. SB 743 was passed in September 2013 and incorporated into updated State CEQA Guidelines adopted by the Natural Resources Agency in December 2018. The updates included changes to the CEQA Environmental Checklist presented in Appendix G of the State CEQA Guidelines, including a finding that auto delay and roadway volume to capacity measures are no longer applicable metrics to evaluate transportation impacts under CEQA. For the purposes of a CEQA-compliant transportation analysis, the City utilizes measures of vehicle miles traveled (VMT) per capita, per employee, and per service population (i.e., residents plus employees). However, the City will continue to maintain the use of local traffic operations analysis (i.e., Level of Service [LOS] analysis) outside of the CEQA process to ensure adequacy of public roadway facilities.

3.14.2 EXISTING CONDITIONS
South Pasadena’s transportation system includes roadways, public transportation, and bicycle and pedestrian infrastructure.

Existing Roadway Network
The City classifies its streets into three major categories based on the functional classification system and includes arterials, collectors, and local residential streets.

Arterial streets are generally the commercial arteries. They carry most of the traffic within the City.

A major arterial would contain either four or six lanes of through traffic, plus left-turn lanes at key intersections. Minor arterials serve the same function as major arterials but have four lanes of through traffic and may or may not have separate left-turn lanes. Recommended design volumes on arterials are generally greater than 25,000 vehicles per day for major arterials and between 4,000 and 30,000 vehicles per day for minor arterials, depending on number of lanes and left-turn movements. Arterials serve two primary functions: (1) to move vehicles within the City and (2) to serve adjacent commercial land uses. Driveways and other curb cuts along arterials are generally limited to minimizing disruption to traffic flow. Major arterials in the City include Huntington Drive and Fair Oaks Avenue. Minor arterials in the City include Freemont Avenue, Garfield Avenue, Grevilia Street, Monterey Road, Orange Grove Avenue, Mission Street, and Pasadena Avenue.

Collector streets are intended to carry traffic between residential neighborhoods and the arterial street network. They are generally two and four-lane roadways that have a mixture of residential and commercial land uses along them. Traffic volumes on collector streets are generally between 7,000 and 20,000 vehicles per day. Higher density residential land uses, or side yards of singlefamily homes may be located adjacent to collector streets. Higher traffic volumes may be acceptable on certain collector streets such as those fronting commercial uses. 3 - 998
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R:\Projects\SPA\3SPA010100\Environmental Documentation\Settlement Agreement\EA\3.14_Transportation-050923.docx 3.14-2 Transportation/Traffic Local residential streets are designed to serve adjacent residential land uses only. They allow access to residential driveways and often provide parking for the neighborhood. They are not intended to serve through traffic. Traffic volumes on a residential street can carry up to 6,000 vehicles per day. The maximum residential traffic volume that is acceptable to persons living along a street may vary from one street to another, depending upon roadway width, type of dwelling units (i.e., high density apartments versus single-family homes), presence of schools, and other factors.

Truck Routes
Streets declared by the City as truck routes are for the movement of commercial vehicles exceeding a maximum gross weight of 6,000 pounds, laden or unladen, include the following:
 Fair Oaks Avenue between Huntington Drive and the northerly City limits;  Huntington Drive between the westerly City limits and the easterly City limits;  Pasadena Avenue between Mission Street and the westerly City limits;  Mission Street between Pasadena Avenue and Fair Oaks Avenue; and  Fremont Avenue between Alhambra Drive and the south drive of Huntington Drive.

Baseline Traffic Conditions
The VMT analysis was prepared in conformance with the City of South Pasadena’s transportation analysis guidelines. VMT is defined as the total miles traveled by vehicles (within a transportation network). Daily VMT values for the City were generated using the Southern California Association of Governments’ (SCAG’s) regional travel demand model. SCAG’s regional model analyzes modes of travel—local and express bus transit, urban rail, commuter rail, toll roads, carpools, and truck traffic—as well as non-motorized trips based on changes in land use types, household characteristics, transportation infrastructure, and travel costs such as transit fares, parking costs, tolls, and auto operating costs.

The baseline VMT was developed through utilizing the SCAG regional travel demand model’s most recent existing conditions socioeconomic data and transportation network at the time of preparation of the transportation analysis (designated as Year 2018 in the SCAG regional travel demand model). Table 3.14-1 presents the City’s VMT baseline scenario. Two metrics for VMT are shown: (1) home-based VMT per population (VMT per Capita) and (2) total VMT per service population (VMT per Service Population), which is population plus employment. As shown in Table 3.14-1, under baseline conditions the City’s VMT per Capita is 14.5 miles per day and the VMT per Service Population is 24.4 miles per day.

TABLE 3.14-1

CITY OF SOUTH PASADENA BASELINE DAILY VMT
Scenario
HomeBased
VMT Population
VMT/
Capita Total VMT
Service
Population
VMT/Service
Population
Baseline 375,456 25,932 14.5 869,167 35,646 24.4
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R:\Projects\SPA\3SPA010100\Environmental Documentation\Settlement Agreement\EA\3.14_Transportation-050923.docx 3.14-3 Transportation/Traffic Public Transportation System
The Los Angeles County Metropolitan Transportation Authority (Metro) provides transit services in the City of South Pasadena and is the leading transit provider in the County of Los Angeles (County), offering a wide range of rail and fixed-route bus service. The Metro L Line Station near the intersection of Mission Street and Meridian Avenue provides light rail service between East Los Angeles and the City of Azusa via downtown Los Angeles.

Metro also provides transit services through its Access service for people who have a disability.

Access service will pick up and drop off disabled riders within ¾-mile or less from Metro routes.

Access services are consistent with all federal Title V requirements. The City is located in the Eastern Access Service Region.

The City also provides Dial-A-Ride services for City residents who are over 55 years of age, and/or residents with disability. Registration is required and all rides are by appointment only.

Transportation is provided to and from any location within the City limits. Services is also provided to some surrounding medical offices in the cities of Pasadena, San Marino, Arcadia, and Alhambra.

Bikeway Network
Bicycling is encouraged throughout the City of South Pasadena, and the City continues to make fiscal commitments to substantively expand the existing network of bikeways in the community.

The existing bicycle facilities serving the community include the following:

Bicycle Path
 The Arroyo Seco Bike Path from Arroyo Seco Park to the Montecito Recreation Center in the City of Los Angeles.

Class II Bicycle Lanes
 Marengo Avenue from Alhambra Road to Mission Street;
 Mission Street from Brent Avenue to east of Garfield Avenue;  Raymondale Drive from State Street to Amberwood Drive;  El Centro Street from Orange Grove Park to Pasadena Avenue;  Pasadena Avenue from Mission Street to Hawthorne Street;  Pasadena Avenue from Arroyo Drive to Arroyo Verde Drive; and  Marmion Way from east of Arroyo Verde Road to west of Arroyo Verde Street.

Class III Bicycle Routes
 Oxley Street from Fremont Avenue to Fair Oaks Avenue.  El Centro Street from Meridian Avenue to Orange Grove Park. 3 - 1000
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R:\Projects\SPA\3SPA010100\Environmental Documentation\Settlement Agreement\EA\3.14_Transportation-050923.docx 3.14-4 Transportation/Traffic Pedestrian Network
Metro L Line station access is a major focus of the Project. Several streets lead to the station from the north, south, east, and west (i.e., Meridian Street, Mission Avenue, El Centro Street, and Glendon Way). These have been identified as path arterials. There are also several streets that connect to and extend for a considerable distance from these streets and provide important connections. These include, but are not limited to, Grand Avenue, Orange Grove Avenue, Prospect Avenue, Fremont Avenue, Grevelia Street, and Monterey Road. Some of these streets are existing or planned bicycle routes providing important connections beyond the half-mile radius to the larger bikeshed. For example, Mission Street and El Centro Street connect to the Pasadena Avenue bike lanes at their western ends.

The walkshed around the L Line station is a well-connected network of streets with relatively small blocks, enabling direct pedestrian and bicycle paths. However, a few obstacles are noted. These include physical barriers—State Route (SR) 110, the rail line itself, the four lanes on Mission Street, lack of traffic calming on Fremont Avenue, and high-speed intersection turns at El Centro Street and Orange Grove Avenue—as well as widely spaced or missing crosswalks, substandard or missing sidewalks on El Centro Street, Monterey Road, and Mission Street, and gaps between bike lanes on Mission Street.

3.14.3 RELEVANT PROGRAMS AND REGULATIONS
State
California Transportation Commission
The California Transportation Commission (CTC) administers the public decision-making process that sets priorities and funds projects envisioned in long-range transportation plans. The CTC’s programming includes the State Transportation Improvement Program, a multi-year capital improvement program of transportation projects on and off the State highway system, funded with revenues from the State Highway Account and other funding sources. The California Department of Transportation (Caltrans) manages the operation of State highways.

California Department of Transportation
Caltrans is the primary State agency responsible for transportation issues. One of its duties is the construction and maintenance of the State highway system. Caltrans approves the planning, design, and construction of improvements for all State-controlled facilities, including the Arroyo Seco Parkway (SR 110) and the associated interchanges. Caltrans has standards for roadway traffic flow and has developed procedures to determine if State-controlled facilities require improvements.

For projects that may physically affect facilities under its administration, Caltrans requires encroachment permits before any construction work may be undertaken. Caltrans also prepares comprehensive planning documents, including corridor system management plans and transportation concept reports, which are long-range planning documents that establish a planning concept for State facilities.
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City of South Pasadena
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Environmental Assessment
R:\Projects\SPA\3SPA010100\Environmental Documentation\Settlement Agreement\EA\3.14_Transportation-050923.docx 3.14-5 Transportation/Traffic California Manual of Uniform Traffic Control Devices
The California Manual on Uniform Traffic Control Devices (California MUTCD) is published by the State and is issued to adopt uniform standards and specifications for all official traffic control devices in California, in accordance with Section 21400 of the California Vehicle Code. Effective March 10, 2023, Caltrans has made edits, referred to as Revision 7, to the 2014 California MUTCD.

Senate Bill 743
On September 27, 2013, SB 743 was signed into law. A key element of this law is the elimination of or deemphasizing auto delay, LOS, and other similar measures of vehicular capacity or traffic congestion as a basis for determining significant environmental impacts in many parts of the State. According to the legislative intent of SB 743, these changes to current practice were necessary to balance the needs of congestion management with Statewide goals related to infill development, promotion of public health through active transportation, and reduction of greenhouse gas (GHG) emissions.

The California Legislature found that with adoption of the Sustainable Communities and Climate Protection Act of 2008 (SB 375), discussed further below, the State had signaled its commitment to encourage land use and transportation planning decisions and investments that reduce VMT and thereby contribute to the reduction of GHG emissions, as required by the California Global Warming Solutions Act of 2006, Assembly Bill (AB) 32. Additionally, AB 1358, described further below, requires local governments to plan for a balanced, multimodal transportation network that meets the needs of all users.

SB 743 started a process that fundamentally changes transportation impact analysis as part of CEQA compliance. These changes include the elimination of auto delay and similar measures of vehicular capacity or traffic congestion (commonly referred to as LOS analysis) as the basis for determining significant transportation impacts. As part of the updated State CEQA Guidelines, the new criteria were designed to promote the reduction of GHG emissions, the development of multimodal transportation networks, and a diversity of land uses. The Office of Planning and Research (OPR) developed alternative metrics and thresholds based on VMT. The updated State CEQA Guidelines reflecting SB 743 were certified by the Secretary of the Natural Resources Agency in December 2018. These updates require that automobile delay, as described solely by LOS or similar measures of vehicular capacity or traffic congestion, shall not be considered a significant impact on the environment. Individual agencies (cities and counties) had until July 1, 2020, to adopt new VMT-based criteria.

The City developed and adopted new CEQA transportation impact analysis methodology consistent with SB 743 on May 20, 2020 (Resolution No. 7656), to evaluate the transportation impacts of projects in the City’s jurisdiction.

SB 375: Sustainable Communities and Climate Protection Act On December 11, 2008, the California Air Resources Board (CARB) adopted its proposed Scoping Plan for AB 32, the Global Warming Act. This scoping plan included the approval of SB 375 as the means for achieving regional transportation-related GHG emissions targets. SB 375 provides guidance on how curbing emissions from cars and light trucks can help the State comply with AB 32. There are five major components to SB 375. 3 - 1002
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R:\Projects\SPA\3SPA010100\Environmental Documentation\Settlement Agreement\EA\3.14_Transportation-050923.docx 3.14-6 Transportation/Traffic First, SB 375 addresses regional GHG emissions targets. CARB’s Regional Targets Advisory Committee guides the adoption of targets to be met by 2020 and 2035 for each metropolitan planning organization (MPO) in the State. These targets, which MPOs may propose themselves, are updated every eight years in conjunction with the revision schedule of housing and transportation elements.

Second, MPOs are required to create a Sustainable Communities Strategy (SCS) that provides a plan for meeting regional GHG emissions targets. The SCS and the Regional Transportation Plan (RTP) must be consistent with each other, including action items and financing decisions. If the SCS does not meet the regional target, the MPO must produce an Alternative Planning Strategy that details an alternative plan to meet the target.

Third, SB 375 requires that regional housing elements and transportation plans be synchronized on eight-year schedules. In addition, Regional Housing Needs Assessment (RHNA) allocation numbers must conform to the SCS. If local jurisdictions are required to rezone land because of changes in the housing element, rezoning must take place within three years.

Fourth, SB 375 provides CEQA streamlining incentives for preferred development types.

Residential or mixed-use projects qualify if they conform to the SCS. Transit-oriented developments also qualify if they: (1) are at least 50 percent residential, (2) meet density requirements, and (3) are within one-half mile of a transit stop. The degree of CEQA streamlining is based on the degree of compliance with these development preferences.

Fifth, and finally, MPOs must use transportation and air emission modeling techniques consistent with guidelines prepared by the CTC. Regional transportation planning agencies, cities, and counties are encouraged but not required to use travel demand models consistent with the CTC guidelines.

AB 1358: California Complete Streets Act of 2008
The California Complete Streets Act of 2008 was signed into law on September 30, 2008.

Beginning January 1, 2011, AB 1358 required circulation elements to address the transportation system from a multimodal perspective. The bill states that streets, roads, and highways must “meet the needs of all users…in a manner suitable to the rural, suburban, or urban context of the general plan.” Essentially, this bill requires a circulation element to plan for all modes of transportation where appropriate—including walking, biking, car travel, and transit.

The Complete Streets Act also requires circulation elements to consider the multiple users of the transportation system, including children, adults, seniors, and the disabled. For further clarity, AB 1358 tasked OPR to release guidelines for compliance, which were released in December 2010.

California Fire Code
The 2019 California Fire Code sets requirements pertaining to fire safety and life safety, including for building materials and methods, fire protection systems in buildings, emergency access to buildings, and handling and storage of hazardous materials (Title 24 Part 9 of the California Code of Regulations).
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R:\Projects\SPA\3SPA010100\Environmental Documentation\Settlement Agreement\EA\3.14_Transportation-050923.docx 3.14-7 Transportation/Traffic Regional
Regional Transportation Plan/Sustainable Communities Strategies SCAG is the MPO for six counties: San Bernardino, Orange, Riverside, Los Angeles, Ventura, and Imperial, which encompasses an area of more than 38,000 square miles with a population exceeding 19 million persons. As the designated MPO, the federal government mandates that SCAG research and prepare plans for transportation, growth management, hazardous waste management, and air quality. SCAG has developed several plans to achieve these regional objectives, including the 2020–2045 Regional Transportation Plan/Sustainable Communities Strategies (RTP/SCS).

The RTP/SCS is a long-range plan that provides a vision for transportation investments throughout the southern California region. The RTP/SCS integrates land use and transportation strategies that will achieve CARB emissions reduction targets. The RTP/SCS is supported by a combination of transportation and land use strategies that help the region achieve State GHG emissions reduction goals and federal Clean Air Act requirements, preserve open space areas, improve public health and roadway safety, support the vital goods movement industry, and utilize resources more efficiently. SCAG utilizes a regional travel demand model to analyze the air quality and transportation impacts of the RTP/SCS transportation and land use strategies. The SCAG travel demand model was used to inform the transportation impact analysis for the Project.

High-Quality Transit Areas
With adoption of the former 2012 RTP/SCS, the areas formerly known as 2% Strategy Opportunity Areas were replaced with what are now referred to as High-Quality Transit Areas (HQTAs).

HQTAs are areas within one-half mile of a fixed guideway transit stop or a bus transit corridor where buses pick up passengers at a frequency of every 15 minutes or less during peak commuting hours (SCAG 2020). The one-half mile radius around Metro’s L Line Station at the Mission Street and Meridian Avenue intersection and along much of Fair Oaks Avenue are identified as HQTAs.

Federal Transportation Improvement Program (SCAG Region) The Federal Transportation Improvement Program (FTIP) is the implementation tool for the RTP/SCS and includes a listing of highway improvements, transit, rail and bus facilities, high occupancy vehicle lanes, signal synchronization, intersection improvements, freeway ramps, and other transportation projects that have been proposed by cities and local agencies in the SCAG region. The 2023 FTIP lists federally funded projects and regionally significant projects developed in compliance with State and federal requirements. The 2023 FTIP has been reviewed and adopted by SCAG. It has also been given an air quality conformity determination by the Federal Highway Administration (FHWA)/Federal Transit Administration (FTA).

South Coast Air Quality Management District, Air Quality Management Plan The South Coast Air Quality Management District (SCAQMD) is the federally mandated agency that is assigned the responsibility for promulgating and enforcing regulations to achieve compliance with national and State air quality standards. SCAQMD’s central mandate is reflected in its 2022 Air Quality Management Plan (AQMP), which is the region’s blueprint for achieving air quality standards in the South Coast Air Basin, which includes the City. Because of the importance of motor vehicles—the primary source of air pollution—substantial emphasis is placed on reducing motor vehicle travel and increasing transit ridership. The 2022 AQMP relies on 3 - 1004
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R:\Projects\SPA\3SPA010100\Environmental Documentation\Settlement Agreement\EA\3.14_Transportation-050923.docx 3.14-8 Transportation/Traffic regulatory and incentive-based approaches to reducing pollution while eliminating reliance on future uncertain technologies.

County
Metro Long Range Transportation Plan
The Metro 2020 Long Range Transportation Plan (LRTP) is Metro’s roadmap for how Metro will plan, build, operate, maintain, and partner for improved mobility in the next 30 years. The LRTP guides funding plans and policies needed to move Los Angeles County forward for a more mobile, resilient, accessible, and sustainable future. The vision of this program is to enhance the public transit program by investing in bus system while expanding the rail system. The plan is also delivering highway improvements such as new carpool lanes and projects that are easing freeway bottlenecks for both auto and truck traffic. Additionally, the LRTP invests in many other programs, including transit operations, highway maintenance, local street improvements, bicycle and pedestrian connections, and transit services for the disabled. The LRTP was adopted by the Metro Board of Directors on September 24, 2020.

Los Angeles County Measures R and M
Measure R is a half-cent sales tax for the County to finance new transportation projects and programs and accelerate those already in the pipeline. This measure took effect in July 2009. The Measure R Expenditure Plan devotes its funds to seven transportation categories as follows: 35 percent to new rail and bus rapid transit projects; 3 percent to Metrolink projects; 2 percent to Metro Rail system improvement projects; 20 percent to carpool lanes, highways and other highway-related improvements; 5 percent to rail operations; 20 percent to bus operations; and 15 percent for local city sponsored improvements. All Measure R funds will be spent in accordance with the plan approved by voters. There will be an annual independent audit and report to taxpayers and ongoing monitoring and review of spending by an independent taxpayer oversight committee.

Measure M, a half-cent sales tax ballot measure, was approved in 2016. Measure M was developed to address new transit and highway projects, enhanced bus and rail operations, and several other transportation improvements in the County. Metro’s Program Management Plan serves as a strategic framework for Measure M Capital Project. The Program Management Plan summarizes program scope, schedule, and budget; provides organizational information for control systems, processes, responsibilities, and authority; describes agency policies, procedures, and interrelationships; establishes mechanisms for managing technical and financial risks; and demonstrates stakeholder accountability and transparency. Measure M is expected to fund 40 major highway and transit projects in the first 40 years. The goals of Measure M include easing traffic congestion; improving freeway traffic flow; expanding rail and rapid transit systems and improving system connectivity; repaving local streets, repairing potholes, and synchronizing signals; making public transportation more accessible, convenient and affordable for seniors, students, and the disabled; earthquake retrofitting bridges and keeping the transit and highway system safe and in good working condition; embracing technology and innovation; creating jobs, reducing pollution and generating local economic benefits; and providing accountability and transparency by protecting and monitoring the public’s investment. 3 - 1005
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South Pasadena Climate Action Plan
The City of South Pasadena adopted the City’s first Climate Action Plan (CAP) on December 16, 2020, a strategy for reducing its GHG emissions in accordance with Statewide targets. The CAP set a baseline for past and current GHG emissions. The CAP also intends to facilitate the reduction of GHG emissions throughout the City through the implementation of SCAG’s 2016– 2040 RTP/SCS, the current RTP/SCS at the time of CAP adoption, in a way that is practical, efficient, and beneficial to the community and enhances the City’s desirable characteristics and qualities.

The foundation for developing GHG emissions reduction and climate adaptation measures is based on the City’s existing work as detailed in the extensive plans and programs comprising the City’s sustainability goals and vulnerability analysis. In the long term, the CAP will also help achieve multiple community goals such as lowering energy costs, reducing air pollution, supporting local economic development, and improving public health and quality of life.

SB 743 Transportation Impact Analysis Guidelines
The City adopted CEQA transportation analysis guidelines on May 20, 2020 (Resolution No. 7656), pursuant to SB 743, discussed above. The guidelines outline screening criteria and significance thresholds for land use plans, land development projects, and transportation projects.

For land use plans that would change population and/or employment, the SCAG model will be used to forecast the change in VMT. The model parameters will be determined by the City’s Director of Public Works prior to each analysis.

The total VMT of the land use plan area will be divided by population (per capita) and service population (population plus employees). The comparison will use the same model year for both scenarios (i.e., a land use plan with a buildout of 2040 would be compared to a baseline year 2040 no project scenario). The baseline model scenario VMT per population and service population will also be reported in the analysis but will not be used to determine potential significant environmental impacts. A significant impact would occur if the VMT per capita or service population for the land use plan exceeds the VMT per population or service population of the baseline. A cumulative significant impact would be the same as the project-level impact since the analysis includes all regional land use and transportation cumulative conditions.

South Pasadena Bicycle Master Plan Update
On August 17, 2011, the City Council approved an update to the City's Bicycle Master Plan.

Utilizing the existing bicycle plan, the updated plan recommends programs and infrastructure improvements that upon implementation will lead to the development of a safe, inviting, and viable mobility choice for bicycle riders of all levels while reinforcing the small-town atmosphere commonly associated with the City.

South Pasadena Complete Streets Policy
On January 18, 2017, the City Council approved the City’s Complete Streets Policy (Resolution No. 7497) to consider the needs of all users when evaluating available treatments for a project and can lead to the development of superior project designs that facilitate a multi-modal network for walking, biking, and driving.
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R:\Projects\SPA\3SPA010100\Environmental Documentation\Settlement Agreement\EA\3.14_Transportation-050923.docx 3.14-10 Transportation/Traffic Public Works Department
The City has historically focused on stopping the northern extension of the SR-710. The City’s Public Works Department also works on regional and local policy issues related to improving mobility choices while reinforcing a small-town quality of life in South Pasadena that is connected to the larger Los Angeles region. This department also prepares local policy and planning documents. On a regional level, staff participates in the development of regional transportation plans such as Metro’s LRTP and SCAG’s RTP/SCS. Staff also represents the City at various stakeholder groups such as regional boards, working groups, technical advisory groups, and councils of governments.

In addition, the Public Works Department oversee transportation issues not related to policy, such as street paving, stop lights, signs, and traffic-calming. Other departments also oversee transportation issues not related to policy, such as the Dial-A-Ride program (Community Services Department); and parking (Police Department). Metro oversees all issues related to mass transit; the City is served by both the Metro L Line and Metro Bus systems.

It is noted that the Public Works Department has proposed several transportation improvement concepts to be included in, and thereby receive funding for, Metro’s SR-710 Early Action Projects.

This is happening concurrent with the General Plan and DTSP Update process, and in coordination with the adjacent municipalities (e.g., Alhambra, Pasadena). It is not known if funding will be received for some or all of the proposed concepts, and as such implementation of these concepts is not considered reasonably foreseeable for purposes of CEQA.

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

Threshold 3.14a: Conflict with a program plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities; Threshold 3.14b: Conflict or be inconsistent with CEQA Guidelines section 15064.3, subdivision (b);
Threshold 3.14c: Substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment); and/or
Threshold 3.14d: Result in inadequate emergency access.

3.14.5 PROPOSED HOUSING PLAN GOALS AND POLICIES
There are no Housing Element goals or policies related to transportation. 3 - 1007
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3.14.6 ENVIRONMENTAL IMPACTS
Threshold 3.14a: Would the Project conflict with a program plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities?
The Project is consistent with the planning goals of the 2020–2045 RTP/SCS and Metro’s LRTP.

Additionally, under the Complete Streets Act, general plans are required to include planning for complete streets—that is, streets that meet the needs of all users of the roadway, including pedestrians, bicyclists, users of public transit, motorists, children, the elderly, and the disabled.

The Project is consistent with the Complete Streets Act by supporting the City’s Complete Streets Policy. The City considers roadways, complete streets, transit, and bicyclist and pedestrian travel as key components of the overall land use plan and planning program for the City into the future.

Transit
Policies and actions related to supporting transit facilities in the City include prioritizing multimodal systems, supporting first/last mile connectivity to transit, implementing additional complete streets improvements when it fits the context of the community, and supporting the improvement of transit opportunity corridors.

Bicyclist Travel
Future bicycle facilities are a mixture of bicycle routes, bicycle lanes, and bicycle paths.

Bicycle travel in the City is supported by prioritizing multimodal systems, maintaining a network of complete streets to provide mobility opportunities for all users, implementing additional complete streets improvements when it fits the context of the community, developing and maintaining local and regional bicycle networks, and promoting bicycle safety when infrastructure improvements are made. Pedestrian Travel The Project promotes the development of mixed-use, pedestrian-friendly areas clustered around activity centers; encourages community interaction through the development and enhancement of plazas, open space, public places, and pedestrian connections with the public realm; and enhances streets to facilitate safe walking through community participatory design.

Conclusion
In summary, implementation of the Project would support improved public transit, bicycle, and pedestrian facilities as well as roadway circulation. There are no potential inconsistencies or conflicts with policies, plans, or programs regarding public transit, bicycle, or pedestrian facilities or the performance or safety of those facilities. There would be no impact, and no mitigation is required.

Threshold 3.14b: Would the project conflict or be inconsistent with CEQA Guidelines section 15064.3, subdivision (b)?
A significant impact would occur if the VMT per capita or service population for the land use plan exceeds the VMT per capita or service population of the baseline. A cumulative significant impact would be the same as the Project-level impact since the analysis includes all regional land use and transportation cumulative conditions. Whereas the Project would result in additional employment and population growth, it does not identify the precise locations of the growth. The City provided locations for office and retail, and employment-generating development would be 3 - 1008
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R:\Projects\SPA\3SPA010100\Environmental Documentation\Settlement Agreement\EA\3.14_Transportation-050923.docx 3.14-12 Transportation/Traffic focused primarily within the Ostrich Farm District and as part of infill development in Downtown and along other arterial roadways. The Ostrich Farm District is already home to creative offices and is therefore a natural area for expansion. New infill office development on Mission Street, Fair Oaks Avenue, and Huntington Drive can leverage the City’s transit connectivity and provide a daytime shopping population to support surrounding retail businesses and restaurants. Detailed housing distribution is based on the availability of sites for housing in the City’s 2021–2029 Housing Element to meet the requirements of the RHNA and HCD.

Also, accessory dwelling units (ADUs) are allowed in all City zones that allow for single-family and multifamily residential units.

The real-life distribution of land uses that would generate VMT will vary. Individual projects would be built incrementally over time and, where necessary, circulation improvements would be implemented by Public Works.

The Project promotes a land use pattern with increasing density, a mix of housing types and land uses and places the highest density proximate to local and regional multi-modal transportation systems. This would reduce the VMT per capita and VMT per service population compared to the existing condition. Therefore, the Project would not conflict or be inconsistent with Section 15064.3(b) of the State CEQA Guidelines. There would be less than significant transportation impact, and, and no mitigation is required.

Threshold 3.14c: 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)?
The Project supports circulation network improvements that would be subject to review and future consideration by the City’s Public Works engineering staff. Transportation improvements to the existing roadway network would be implemented with the goal of safer and more efficient traffic movement, for all modes of travel. An evaluation of the roadway alignments, intersection geometrics, and traffic control features would be needed. Roadway improvements would be made in accordance with the City’s design standards and meet design guidelines of the California MUTCD.

Roadway and other transportation improvements that may be implemented in the future would involve only existing streets, ramps, driveways, and sidewalks. In some instances, addition of new streets may be necessary to break up the large-scale super-blocks into pedestrian-oriented blocks, or complete a block with missing buildings, open space, or infrastructure. No new major streets or other substantial alterations to the existing roadway network could be accommodated as the City is essentially built out. The proposed growth that could be implemented under the Project involves the same land uses already developed within the City, and as part of the City’s transportation pattern. Therefore, these land uses would not be considered incompatible. The Project would result in no impacts related to substantially increasing a hazard due to a design feature or incompatible uses, and no mitigation is required.

Threshold 3.14d: Would the Project result in inadequate emergency access? Evacuation routes include major roadways in the City, with SR-110 and Interstate 210 freeways serving as primary regional exit routes. No major change to the existing roadway system serving the City is proposed. Any transportation improvements contemplated by the City would be implemented with the goal of safer and more efficient traffic movement. This would include traffic 3 - 1009
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R:\Projects\SPA\3SPA010100\Environmental Documentation\Settlement Agreement\EA\3.14_Transportation-050923.docx 3.14-13 Transportation/Traffic during an emergency or evacuation. There would be no impact related to operation of future transportation improvements, and no mitigation is required.

Access to individual development sites would be made available through existing or planned on-site roadways/driveways, as required under Section 36.310.090 “Driveways and Site Access” of the South Pasadena Municipal Code (SPMC). Section 36.310.090 of the SPMC defines requirements for all access from public streets to private properties that ensure adequate and safe access by vehicular and other traffic. The plan check and building permit process by the South Pasadena Fire Department includes review of access for emergency vehicles in accordance with the California Fire Code, as adopted by reference by the City (Chapter 14 of the SPMC). Compliance with the requirements for emergency lane width, vertical clearance, and distance would provide adequate emergency access to all development implemented pursuant to the Projects. There would be no impact related to operation of future land uses, and no mitigation is required.

Construction activities on public rights-of-way may temporarily block traffic and access near the construction zones. As discussed above, compliance with Section 36.310.090 of the SPMC in the design and construction of future projects would always maintain emergency access to individual parcels. Impacts on traffic flows for emergency response or evacuation would be less than significant during construction activities, and no mitigation is required.

3.14.7 CUMULATIVE IMPACTS
Future development pursuant to the Project, and future growth and development throughout the San Gabriel Valley, and in the rest of the region would increase the number of vehicle trips to, from, and through the City. Traffic congestion is expected to increase on freeways and major roadways if no changes to the existing transportation network are made. Some vehicle trips would be confined to the City (short trips), while other trips would travel outside the City to surrounding cities and urban centers and would affect the regional transportation system. Based on regional traffic forecasts, SCAG has identified regional transportation improvements to meet the transportation and circulation needs of the region in its RTP/SCS and FTIP. Additional freeway travel lanes, expanded transit services, rapid bus transit expansion, high-speed rail service, dedicated truck lanes, and other projects are planned and accounted for in the travel forecasts.

As discussed above, the Project would be consistent with regional plans and policies for the circulation system, reflecting all modes of travel. Therefore, there would be a less than significant cumulative impact related to conflict with circulation system plans, ordinances, or policies.

Traffic issues are generally regional in nature, with drivers and travelers commuting throughout the Southern California region to places of employment and residence. Based on the analysis presented above, there would be less than significant cumulative impacts related to transportation consistent with the methodology presented in Section 15064.3(b) of the State CEQA Guidelines.

As discussed above, the Project would result in no impacts related to traffic hazards, incompatible uses, or emergency access. Therefore, the Project would not contribute to cumulatively considerable impact related to these issues. As discussed, the Project would result in less than significant impacts related to emergency access during construction activities associated with future projects; this impact would be temporary and intermittent. This would not be considered a cumulatively considerable impact to emergency access.
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3.14.8 MITIGATION MEASURES
No significant adverse impacts related to transportation have been identified with implementation of the Project. Therefore, no mitigation is required.

3.14.9 LEVEL OF SIGNIFICANCE AFTER MITIGATION
Less than significant.
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R:\Projects\SPA\3SPA010100\Environmental Documentation\Settlement Agreement\EA\3.15 Utilities-050923.docx 3.15-1 Utilities and Service Systems

3.15 UTILITIES AND SERVICE SYSTEMS

3.15.1 METHODOLOGY
This section addresses utilities and service systems that would be used with implementation of the proposed 2021–2029 Housing Element and the non-residential development capacity envisioned in the General Plan and Downtown Specific Plan (DTSP) Update (Project)and analyzes potential impacts on the availability and capacity of the local providers for the following utilities and service systems (the service provider is noted parenthetically):
 Water supply and distribution (City of South Pasadena);  Wastewater facilities (City of South Pasadena [sewage conveyance] and County Sanitation Districts of Los Angeles County [sewage treatment]);  Solid waste disposal (Athens Services [waste collection] and County Sanitation Districts of Los Angeles County [landfill disposal]); and
 Dry utilities (Southern California Edison and Clean Power Alliance [electric], Southern California Gas Company [natural gas], and various telecommunications companies).

Storm drainage facilities are addressed in Section 3.8, Hydrology and Water Quality. Information presented in this section was derived from the City’s and the respective utilities’ websites, the existing General Plan, interim drafts of the 2020 Urban Water Management Plan (UWMP) and Integrated Water and Wastewater Resources Management Plan (IWWRMP) being prepared by the City, information from the City Public Works Department staff, and the Recirculated Notice of Preparation comment letter from the County Sanitation Districts of Los Angeles County regarding wastewater.

3.15.2 EXISTING CONDITIONS
Water
Water Supply Sources
The City of South Pasadena supplies water to approximately 24,650 residents1 through approximately 6,200 active connections. The City’s water supply sources include groundwater from the Main San Gabriel Groundwater Basin (Basin), treated imported water from the Metropolitan Water District (MWD) Upper San Gabriel Area 2 (USG-2), and purchased water from the City of Pasadena (South Pasadena 2021). Each of these water sources is discussed further below.

Main San Gabriel Basin
The total fresh water storage capacity of the Basin is estimated to be approximately 8.7 million acre feet (af). Of that storage, about one million af is historically considered to have been actively managed for local public water supply. The Court adjudication of the Basin in 1973 provided for groundwater management that allows operation of basin storage to meet water demands and provide a mechanism to fund the purchase and replenishment of untreated imported water to supplement recharge of local water. The management of Basin storage and the use of 1 Estimated number of current residents receiving potable water from the City is different from the estimated 2021 City population used throughout the rest of this EA because they are derived using different methodologies and used for different purposes.
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R:\Projects\SPA\3SPA010100\Environmental Documentation\Settlement Agreement\EA\3.15 Utilities-050923.docx 3.15-2 Utilities and Service Systems supplemental imported water for recharge expand and increase the reliability of the available Basin groundwater supply (South Pasadena 2021).

Although there is no limit on the quantity of groundwater that may be extracted by Parties to the Basin adjudication, including the City, groundwater production in addition to a pumper’s proportional share of the Operating Safe Yield, requires the pumper to bear the cost of imported Replacement Water to recharge the Basin. The City’s share is currently 1.80520 percent of the Operating Safe Yield. Untreated imported water for replacement/recharge purposes is purchased from one of three municipal water districts overlying or partially overlying the Basin that provide imported water for groundwater replacement/recharge or for direct use. The three municipal water districts are Upper District, San Gabriel Valley Municipal Water District (SGVMWD) and TVMWD.

The City is located within Upper District’s service area. The management of the Basin and the large volume of groundwater in storage allow groundwater producers, including the City, to produce groundwater even when replacement water is not available. Any requirement to purchase untreated imported water for replacement/recharge purposes can be met when such water is available in the future. Also, there is the cyclic storage provision allowing producers, like the City, to store supplemental water within the Main San Gabriel Basin for the purpose of supplying a future replacement water requirement. For example, the City and other producers have added/deducted from cyclic storage accounts and as a result, have a total balance of approximately 60,044 af in cyclic storage accounts as of April 2021 illustrating the effectiveness of this water resource program in meeting the replacement water requirements of water producers.

The Operating Safe Yield in the Basin has averaged about 150,000 acre-feet per year (afy) over the past five years (fiscal years 2015-2016 through 2019-2020) plus the surface water rights are fixed at about 10,500 af for a total of about 160,500 af of water rights. Over the past five years, the average water production from the Main San Gabriel Groundwater Basin has been approximately 194,462 afy, and the average replacement water requirements and cyclic storage deductions (total Basin over production) has been approximately 33,512 afy. These, however, are averages. As noted above, producers in the Basin currently have a positive balance in cyclic storage accounts.

The City has four wells located within the Main Basin: Graves Well No. 2, Wilson Well No. 2, Wilson Well No. 3 and Wilson Well No. 4 with approximate pumping capacities of 705 gallons per minute (gpm), 750 gpm, 1,960 gpm and 1,100 gpm, respectively. The City installed a volatile organic compound (VOC) treatment system (Granular Activated Carbon and Ion Exchange) at Graves Well No. 2 in 2020. Wilson Well No. 2 is inactive as of June 2018, but City staff indicated there are plans to rehabilitate its Wilson Well No. 2 by 2025. The City installed a VOC treatment system (Granular Activated Carbon treatment) at Wilson Wells No. 3 and No. 4 in December 2018. The current collective well capacity from Graves Well No. 2, Wilson Wells No. 3 and No. 4 is about 4,960 gpm or about 7.1 million gallons per day (mgd). By 2045, the collective capacity from Graves Well No. 2, Wilson Wells No. 2, No. 3 and No. 4 is anticipated to be about 4,500 gpm or about 6.5 mgd. Assuming the City wells were limited to 75 percent of capacity during calendar years 2020 through 2045, the available pumping capacity would be about 5.3 mgd (about 5,900 af) in 2021 and about 4.9 mgd (5,500 af) in 2045. Over the past 20 years, the City’s groundwater production has ranged from approximately 1,950 afy to approximately 5,264 afy, with an average production of approximately 4,026 afy (Watermaster 2020). 3 - 1013
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The City can receive direct deliveries of treated imported water through its MWD connection through Upper District (USG-2), which has a capacity of 4,500 gpm or 6.5 mgd. Historically, treated import water accounted for less than five percent of the City’s total water demands. In addition, the City purchases water from the City of Pasadena through any of three interconnections to serve a small portion of the City’s service area. The three interconnections have a total capacity of approximately 2,000 gpm. The City regularly uses one of the three interconnections located at the northeasterly corner of the City’s distribution system and receives an average of 17 afy from the City of Pasadena as a source of the City’s supply, which is less than one percent of the City’s total water demands (South Pasadena 2021).

Water Storage and Distribution
The groundwater well sites identified have associated booster stations and storage reservoirs to provide contact time for disinfection. These include the Wilson Reservoir, with a capacity of

1.3 MG, and the Graves Reservoir, with a storage capacity of 1.0 MG. The City has four different pressure zones: Pasadena, Raymond, Bilicke, and Central. The City has the following additional storage reservoirs: Garfield Reservoir (6.5 MG), Grand Reservoir (2.4 MG), and Westside Reservoir (2.0 MG) located in the Central zone; and Bilicke (0.15 MG) and Raymond (0.15 MG) elevated tanks located in the Bilicke and Raymond zones, respectively. The City of Pasadena connection that supplies water to the Pasadena zone on a continuous basis. There are four distribution booster stations located within City limits that provide water to the different pressure zones. Therefore, the total water storage capacity of the City is 13.5 MG. The City distributes potable water via 6,200 water meters that are connected by 67.7 miles of water pipes located throughout the City (South Pasadena 2017a).

Wastewater
Wastewater Conveyance
The City operates and maintains a sanitary sewer collection system, which consists of approximately 53 miles of gravity sewer lines which ultimately flow into larger trunk lines owned and operated by the County Sanitation Districts of Los Angeles County (LACSD). This 24-inch diameter trunk sewer line has a peak capacity of 8.4 million gallons per day (mgd) and conveyed a peak flow of 3.2 mgd (37 percent of capacity) when last measured in 1993.

The City’s sewer system operates under Los Angeles Regional Water Quality Control Board (LARWQCB) Permit Number 4SS010436 and the City is responsible to ensure compliance with Order 2006-003-DWQ. This LARWQCB order requires the City to take a proactive approach to ensure a Citywide operation, maintenance, and management plan is in place to reduce the number and frequency of Sanitary Sewer Overflows (SSO) within the City. In January 2012, the City entered into a consent judgment with the State Regional Water Quality Control Board (SWQCB) as a result of a number of SSO experienced in the City’s sanitary sewer system. The consent judgment requires the City to repair certain deficiencies identified through the City’s sewer video inspection program within a specified period of time. Phase 1 of the sewer repairs started in 2014 and was completed in year 2015. Phase 1 addressed 233 pipe segments totaling approximately 64,000 lineal feet of sewer lines. In March 2017, the City Council awarded a construction for Phase 2 of the sewer repair project. The project consisted of a comprehensive multi-year capital improvement sewer program to satisfy the terms of the consent judgment on a 3 - 1014
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R:\Projects\SPA\3SPA010100\Environmental Documentation\Settlement Agreement\EA\3.15 Utilities-050923.docx 3.15-4 Utilities and Service Systems broader scale. The project addressed all of the remaining deficiencies of the consent judgment and consisted of approximately 107,100 linear feet of sewer mains and modification of 143 existing flush tanks. This project was completed in December 2017, improving approximately 60 percent of the City’s sanitary sewer lines through sewer lining or full pipe replacement.

Wastewater Treatment
Wastewater from the City is treated at either the LACSD’s Whittier Narrows Water Reclamation Plant (WRP) located near the City of El Monte or at the Los Coyotes WRP located in the City of Cerritos depending on LACSD’s operations and/or diversion settings. The Whittier Narrows WRP, located near the City of El Monte, has a design capacity of 15 million gallons per day (mgd) and currently processes an average flow of 9.9 mgd (approximately 66 percent of capacity). The Los Coyotes WRP, located in the City of Cerritos, has a design capacity of 37.5 mgd and currently processes an average flow of 21.3 mgd (approximately 57 percent of capacity)(South Pasadena 2017a, LACSD 2021).

Solid Waste
The City of South Pasadena contracts with Athens Services (Athens) as its residential and commercial solid waste and recycling hauler. Athens has two large volume transfer/processing facilities–also called materials recycling facilities (MRF)–one in City of Industry with a permitted throughput of 5,000 tons per day (tpd) and one in the community of Sun Valley with a permitted throughput of 1,500 tpd (CalRecycle 2021a, 2021b).

According to CalRecycle records for 2021 (the most recent year data is available), the City of South Pasadena has a per resident disposal rate target of 4.4 pounds per day (PPD) and the per employee disposal rate target of 15.8 PPD. The City achieved disposal rates of 3.6 PPD per capita and 14.2 PPD per employee (CalRecycle 2023a). Regarding waste disposal, in 2019 (the most recent year data is available) the City of South Pasadena disposed of approximately 21,482 tons of waste, which included 99 tons transformed to energy and 3,263 tons used as alternative daily cover (CalRecycle 2023c).

3.15.3 RELEVANT PROGRAMS AND REGULATIONS
Federal
Clean Water Act
The Clean Water Act is discussed in Section 4.8, Hydrology and Water Quality, of this EIR.

Safe Drinking Water Act
The Safe Drinking Water Act (SDWA), Health and Safety Code, Sections 116350–116405) was passed in 1974 and is intended to protect public health by regulating the nation’s public drinking water supply. The Federal SDWA authorizes the U.S. Environmental Protection Agency (USEPA) to set national standards for drinking water to protect against contaminants. Amendments in 1996 expanded the focus of the SDWA from primarily water treatment to enhanced source water protection, operator training, funding for water system improvements, and public information as important components of protecting drinking water supplies. The SWDA applies to every public water system in the United States and sets the enforceable maximum contaminant levels (MCLs) for drinking water supplies.
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Safe Drinking Water Act
California enacted its own Safe Drinking Water Act, with the California Department of Health Services (DHS) granted primary enforcement responsibility. Title 22 of the California Code of Regulations (CCR) (Division 4, Chapter 15, “Domestic Water Quality and Monitoring Regulations”) established DHS authority and provides drinking water quality and monitoring requirements, which are equal to or more stringent than federal standards.

Senate Bill 610 and Senate Bill 221
Senate Bill (SB) 610 amended State law2 to improve the link between information on water supply availability and certain land use decisions made by cities and counties. Specifically, it requires land use planning entities (in this case, the City of South Pasadena), when evaluating certain large development projects, to request a water supply availability assessment from the water supply entity that would provide water to the project. A water supply assessment (WSA) must be prepared in conjunction with the land use approval process associated with a project, and it must include an evaluation of the sufficiency of the water supplies available to the water supplier to meet existing and anticipated future demands (including the demand associated with the project in question) over a 20-year horizon that includes normal, single-dry, and multiple dry-years. An SB 610 WSA is required for any “project” that is subject to CEQA and that proposes, among other things, residential development of more than 500 dwelling units.

In addition, SB 221 requires land use planning agencies, such as the City, to include (as a condition in any tentative map that includes a subdivision involving more than 500 dwelling units) a requirement to obtain written verification that sufficient water supplies are available for the subdivision from the applicable public water system, or, where there is no existing water supplier, from a consultant directed by the City. SB 221 also addresses the issue of land use and water supply, but at a different point in the planning process than does SB 610. SB 221 requires a city or county to deny approval of a tentative or parcel map if the city or county finds that the project does not have a sufficient, reliable water supply as defined in the bill.

A General Plan Update is not subject to either SB 610 or SB 221 because a General Plan, in itself, does not grant entitlements. However, these requirements may be applicable to future projects in the City.

Urban Water Management Planning Act
The Urban Water Management Planning Act (UWMP Act) (California Water Code, Division 6, Part

2.6, Section 10610 et seq.) was enacted in 1983. The UWMP Act applies to municipal water suppliers that serve more than 3,000 customers or provide more than 3,000 afy of water. The UWMP Act requires these suppliers to update their Urban Water Management Plan (UWMP) every five years to demonstrate an appropriate level of reliability in supplying anticipated shortterm and long-term water demands during normal, dry, and multiple dry years. 2 SB 610 amended section 21151.9 of the California Public Resources Code, and amended sections 10631, 10656, 10910, 10911, 10912, and 10915 of, repealed section 10913 of, and added and amended section 10657 of, the California Water Code.
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R:\Projects\SPA\3SPA010100\Environmental Documentation\Settlement Agreement\EA\3.15 Utilities-050923.docx 3.15-6 Utilities and Service Systems Water Conservation in Landscaping Act
The Water Conservation in Landscaping Act of 2006 (Assembly Bill 1881) requires cities and counties, including charter cities and charter counties, to adopt landscape water conservation ordinances by January 1, 2010. The Department of Water Resources (DWR) prepared an updated Model Water Efficient Landscape Ordinance (MWELO), as contained in California Code of Regulations Title 23, Division 2, Chapter 2.7. Cities and counties have the option to adopt DWR’s ordinance or to develop their own. DWR’s ordinance identifies the landscape documentation that needs to be submitted to the local agency, including a completed Water Efficient Landscape Worksheet that estimates total water use and compares it to the Maximum Applied Water Allowance (MAWA) based on the annual reference evapotranspiration value for the project area. The MAWA is considered the water budget and should not be exceeded by the estimated water use. Standards for soil management, landscape design, irrigation design and efficiency, grading design, irrigation scheduling, maintenance, audit and survey of water use, recycled water, storm water management, public education, and wastewater prevention are provided to reduce irrigation water demand.

Senate Bill 7
Senate Bill 7 (SBX7_7) was approved in November 2009 and requires urban water retail suppliers in California, which includes the City of South Pasadena, to reduce per capita water use by at least 10 percent on or before December 31, 2015 and achieve a 20 percent reduction by December 31, 2020. An urban retail water supplier must have included in its urban water management plan for the 2010 update, the baseline daily per capita water use, urban water use target, interim urban water use target, and compliance daily per capita water use, along with the bases for determining those estimates, including references to supporting data. Urban wholesale water suppliers shall include an assessment of their present and proposed future measures, programs, and policies to help achieve the water use reductions required by this bill.

Urban retail water suppliers and agricultural water suppliers would not be eligible for State water grants or loans for surface water or groundwater storage, recycling, desalination, water conservation, water supply reliability, and water supply augmentation unless they comply with the water conservation requirements established by this bill.

Title 24 Green Building Standards
The 2022 California Green Building Standards Code (24 CCR, Part 11), also known as the CALGreen code, contains mandatory requirements for new residential and nonresidential buildings (including buildings for retail, office, public schools and hospitals) throughout California.

The development of the CALGreen Code is intended to (1) cause a reduction in greenhouse gas (GHG) emissions from buildings; (2) promote environmentally responsible, cost effective, healthier places to live and work; (3) reduce energy and water consumption; and (4) respond to the directives by the Governor. The CALGreen Code contains requirements for construction site selection, storm water control during construction, construction waste reduction, indoor water use reduction, material selection, natural resource conservation, site irrigation conservation, and more. The code provides for design options allowing the designer to determine how best to achieve compliance for a given site or building condition. The code also requires building commissioning, which is a process for the verification that all building systems, such as heating and cooling equipment and lighting systems, are functioning at their maximum efficiency. 3 - 1017
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R:\Projects\SPA\3SPA010100\Environmental Documentation\Settlement Agreement\EA\3.15 Utilities-050923.docx 3.15-7 Utilities and Service Systems AB 939 and California Solid Waste Reuse and Recycling Access Act of 1991 In 1989, the California legislature passed a bill (Assembly Bill [AB] 939), which requires jurisdictions to reduce the amount of solid waste disposed of in landfills by 50 percent by the year 2000 and thereafter. The purpose of AB 939 is to “reduce, recycle, and reuse solid wastes generated in the State to the maximum extent feasible” (State of California 2013).

Subsequent to AB 939, additional legislation was passed to assist local jurisdictions in accomplishing the required waste reduction goals. The California Solid Waste Reuse and Recycling Access Act of 1991 directs CalRecycle to draft a “model ordinance” relating to adequate areas for collecting and loading recyclable materials in development projects.

Solid Waste Disposal Measurement Act of 2008 (Senate Bill 1016) The purpose of the Solid Waste Disposal Measurement Act of 2008 (Senate Bill [SB] 1016) is to make the process of goal measurement (as established by AB 939) simpler, timelier, and more accurate. SB 1016 builds on AB 939 compliance requirements by implementing a simplified measure of jurisdictions’ performance. SB 1016 accomplishes this by changing to a disposalbased indicator—the per capita disposal rate—which uses only two factors: (1) a jurisdiction’s population (or in some cases employment) and (2) its disposal as reported by disposal facilities.

Each year CalRecycle will calculate each jurisdiction’s per capita (per resident or per employee) disposal rates; the per capita disposal rate will be used for most jurisdictions. Each year’s disposal rate will be compared that jurisdiction’s 50 percent per capita disposal target. As such, jurisdictions will not be compared to other jurisdictions or the statewide average, but they will only be compared to their own 50 percent per capita disposal target. Among other benefits, per capita disposal is an indicator that allows for jurisdiction growth because as residents or employees increase, report-year disposal tons can increase and still be consistent with the 50 percent per capita disposal target. A comparison of the reported annual per capita disposal rate to the 50 percent per capita disposal target will be useful for indicating progress, or other changes, over time.
75 Percent Initiative
In 2011, Governor Brown signed AB 341, which sets a goal of 75 percent recycling, composting, or source reduction of solid wastes by 2020. It also mandates commercial recycling by 2012. The 75 percent goal will shift the focus from local diversion to a Statewide approach that would decrease reliance on landfills. CalRecycle has been holding workshops with stakeholders since May 2012 to identify existing programs and new ways to reduce the waste streams. A number of programs will be implemented under this initiative, including continued local jurisdiction diversion; commercial recycling; mattress recovery; greenhouse gas reduction grant and loan program; commercial organics recycling; potential packaging reduction activities; and other new programs that are under development.

Mandatory Commercial Organics Recycling Bill (AB 1826)
In 2014, Governor Brown signed AB 1826, requiring businesses to recycle their organic waste on and after April 1, 2016, depending on the amount of waste they generate per week. This law also requires that on and after January 1, 2016, local jurisdictions across the State to implement an organic waste recycling program to divert organic waste generated by businesses, including multifamily residential dwellings that consist of five or more units. Organic waste means food waste, green waste, landscape and pruning waste, nonhazardous wood waste, and food-soiled paper 3 - 1018
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R:\Projects\SPA\3SPA010100\Environmental Documentation\Settlement Agreement\EA\3.15 Utilities-050923.docx 3.15-8 Utilities and Service Systems waste that is mixed in with food waste. The minimum threshold of organic waste generation by businesses decreases over time, which means an increasingly greater proportion of the commercial sector will be required to comply.

California Plumbing Code
Part 5 of the California Building Code (Title 24 of the Code of Regulations) is the California Plumbing Code, which provides standards for the design and construction of water and sewer systems, storm drains, and recycled water systems in buildings. It prohibits connection to a septic tank in areas served by a public sewer system and requires the proper abandonment of septic tanks, cesspools, and seepage pits.

Regional
Sanitation Districts of Los Angeles County Wastewater Ordinance In 1972, the Sanitation Districts of Los Angeles County (LACSD) adopted a Wastewater Ordinance, which was most recently amended in 1998, for the operation and financing of the LACSD’s wastewater conveyance, treatment, and disposal facilities. The Wastewater Ordinance applies to all direct and indirect discharges of wastewater to any part of the sewerage system and regulates industrial wastewater discharges to protect the public sewerage system. The LACSD also charges Connection Fees and Surcharges. The Surcharge program requires all industrial companies discharging to the LACSD’s sewerage system to pay their fair share of the wastewater treatment and disposal costs. The Connection Fee program requires all new users of the LACSD’s sewerage system, as well as existing users that significantly increase the quantity or strength of their wastewater discharge, to pay their fair share of the costs for providing additional conveyance, treatment, and disposal facilities. The LACSD uses the fees for the expansion and improvement of their facilities, as needed, to serve existing and anticipated developments.
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Urban Water Management Plan
The 2020 Urban Water Management Plan (UWMP) for the City of South Pasadena was prepared to meet the mandates of the California Urban Water Management Planning Act (South Pasadena 2021). The UWMP identifies historic and projected water supplies available to the City of South Pasadena; existing and projected water demand; available water rights; and programs to meet demand during an average year, single-dry year, and a five consecutive year drought. The UWMP is the foundational document for compliance with both the California Water Code and SB 610 and SB 221 documentation for applicable development projects in the City.

Municipal Code
Water Efficient Landscape
Sections 35.50 through 35.76 of the South Pasadena Municipal Code (SPMC) describes the City’s landscape water conservation ordinance consistent with the requirements of DWR’s Water Conservation in Landscaping Act of 2006, discussed above. The City’s ordinance pertains to the planning, designing, installing, maintaining, and managing water efficient landscapes in new construction and rehabilitated projects. These requirements apply to new construction projects with an aggregate landscape area equal to or greater than 500 square feet requiring a building or landscape permit, plan check or design review; rehabilitated landscape projects with an aggregate landscape area equal to or greater than 2,500 square feet requiring a building or landscape permit, plan check, or design review; existing landscapes limited to those defined in Section 35.70 through 35.72 of the SPMC; and cemeteries (Section 35.51[a][4] of the SPMC).

Water and Sewer Impact Fee
Section 16B et. seq. of the SPMC defines water and sewer impact fees. The purpose of this impact fee is to mitigate unfavorable impacts on the City’s water and sanitary sewer systems attributed to new development. This fee is to be applied toward the costs of new or expanded public water and sewer facilities. It is based on a formula designed to ensure that individual developers pay their fair share for public facilities needed to serve the increased population which results from new development. All new development is required to pay this fee except for the following development: alterations that do not increase floor area; single-family residential additions that do not add habitable space; single-family residential units that are upsizing their meter, but not changing their use; and development exempt due to applicable State or federal laws. Water and sewer impact fees collected are directed into the Water and Sewer Impact Fee Fund; these funds are used only for water and sewer facilities improvements.

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

Threshold 3.15a: 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; 3 - 1020
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R:\Projects\SPA\3SPA010100\Environmental Documentation\Settlement Agreement\EA\3.15 Utilities-050923.docx 3.15-10 Utilities and Service Systems Threshold 3.15b: Have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years; Threshold 3.15c: 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;
Threshold 3.15d: 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; and/or
Threshold 3.15e: Comply with federal, State, and local management and reduction statutes and regulations related to solid waste.

3.15.5 PROPOSED HOUSING ELEMENT GOALS AND POLICIES
There are no Housing Element goals or policies related to utilities and service systems.

3.15.6 ENVIRONMENTAL IMPACTS
Threshold 3.15a: 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 facilities, the construction or relocation of which could cause significant environmental effects?
Threshold 3.15c: Would the Project result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments?
Water Treatment Facilities
A comprehensive analysis of the overall system previously conducted identified a series of system-wide modifications required to improve the operation of the distribution system. As discussed above, in recent years the City has invested heavily in and embarked on an aggressive capital improvement and aging infrastructure replacement program. Improvements include the Grand, Wilson, and Garfield reservoirs reconstructions, water line replacements, and creation of a hydraulic modeling system of the entire water system to identify and address deficiencies on an ongoing basis. Replacement of the Graves Reservoir and pump station improvements has been completed, and replacement of the Westside Reservoir and pump station improvements is an upcoming capital improvement project.

However, even with the modifications implemented to date, water pressure within the downtown area averages about 45 pounds per square inch (psi) during peak use hours, with lower pressures occurring in the eastern portion. Water pressure of 50 to 70 psi is desirable. These pressures are low but unavoidable given the current water distribution system equipment and configuration. The City anticipates that future development may encounter problems associated with low water pressures that can only be remedied on a system-wide basis. Some of the possible pressure and flow rate remedies identified include modifications to the lines entering and leaving the Grand and Garfield reservoirs; enlarging, replacing, or adding water lines, adding pumping stations, and 3 - 1021
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R:\Projects\SPA\3SPA010100\Environmental Documentation\Settlement Agreement\EA\3.15 Utilities-050923.docx 3.15-11 Utilities and Service Systems increase usage of MWD water. Also, after implementation of some of the recommended systemwide improvements, all new development may require on-site pumps for two- or three-story buildings. The City’s IWWRMP, which is under development, will identify other water distribution system issues including low pressure areas and provide recommendations for resolution.

Water infrastructure improvements would be directly related to the pace of development. Also, consistent with Section 16B of the SPMC, this chapter includes an action to require Applicants/Developers of future development projects to pay fair share Water and Sewer Impact Fees for improvements to the water distribution and sanitary sewer systems. The purpose of this fee is to mitigate unfavorable impacts on the City’s water and sewer systems attributed to new development, and the fees collected are applied toward the costs of new or expanded public water and sewer facilities.

As part of the City’s plan review process, the Public Works Department conducts a review of wet utility (i.e., water and wastewater) infrastructure needs. The South Pasadena Fire Department also reviews development plans to determine fire safety requirements are met, including provision of fire flows and pressures. The Applicant/Developer of future development projects would be responsible for installing all new or replacement water-related infrastructure on the property and within the proposed structure(s) deemed required by the City and remitting the water impact fee calculated by the City for that project. The City would be responsible for continuing to manage the Water and Sewer Impact Fee Fund and implement the necessary improvements to the water distribution system.

In summary, new or expanded water infrastructure may be necessary to serve future development projects. The need for, and environmental impacts of, additional water distribution infrastructure would be addressed in the required project-level California Environmental Quality Act (CEQA) review. If significant impacts associated with installation of the necessary infrastructure are identified, mitigation measures would be required. Through compliance with the City’s plan review processes; application of the Water and Sewer Impact Fee (Section 16B of the SPMC); implementation of applicable General Plan Update policies and actions; and identification of and, if necessary, mitigation for, environmental impacts associated with new or expanded water distribution infrastructure, there would be a less than significant impact and no mitigation is required.

Wastewater Treatment Facilities
All sewage treatment/wastewater reclamation plants are subject to the water quality discharge requirements of the applicable National Pollution Discharge Elimination System (NPDES) permit.

The City is within the jurisdiction of the Los Angeles Regional Water Quality Control Board (LARWQCB) and is subject to the waste discharge requirements of the Los Angeles County MS4 Permit (Order No. R4-2012-0175). Future development pursuant to the General Plan Update would increase wastewater flows on City sewer lines, on LACSD trunk sewer lines, and at the WRPs. Any sewer discharges that would cause a receiving WRP to exceed applicable NPDES requirements for discharges into MS4 facilities would result in a potentially significant impact.

Residential wastewater does not require levels of treatment that would exceed LARWQCB NPDES treatment requirements; however, some industrial, manufacturing, and/or commercial uses may generate wastewater requiring additional treatment. In compliance with the LACSD’s Wastewater Ordinance, all wastewater discharges into LACSD facilities shall be required to comply with the discharges standards set forth to protect the public sewerage system. The LACSD Surcharge program requires all industrial companies discharging to the LACSD sewerage system to pay their fair share of the wastewater treatment and disposal costs, and the Connection 3 - 1022
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R:\Projects\SPA\3SPA010100\Environmental Documentation\Settlement Agreement\EA\3.15 Utilities-050923.docx 3.15-12 Utilities and Service Systems Fee program requires all new users of the LACSD sewerage system, as well as existing users that significantly increase the quantity or strength of their wastewater discharge, to pay their fair share of the costs for providing additional conveyance, treatment, and disposal facilities.

Therefore, compliance with LACSD’s Wastewater Ordinance by all Applicants/Developments of future development projects would ensure potential impacts related to wastewater treatment requirements would be less than significant.

Based on the wastewater loadings published by the LACSD and provided with their RNOP comment letter, it can conservatively be estimated that buildout of the Project could generate approximately 662,329 gpd, or 0.66 mgd. This volume of additional wastewater generation could be fully accommodated by either the Whittier Narrows or Los Coyotes WRPs. Specifically, this wastewater generation would represent approximately 13.0 percent of the Whittier Narrows WRP’s remaining capacity of 5.1 mgd, and approximately .14 percent of the Los Coyotes WRP’s remaining capacity of 16.2 mgd (based on LACSD’s RNOP comment letter). Therefore, implementation of the proposed Project would not result in the need for new or expanded wastewater treatment facilities or a determination by the LACSD that there would be inadequate capacity in addition to existing commitments. Also, consistent with the Connection Fee program of LACSD’s Wastewater Ordinance, all new users of the LACSD sewerage system must pay their fair share of the costs for providing additional conveyance, treatment, and disposal facilities.

Regarding the City’s sewer system, similar to the analysis of the water distribution system above, the City has recently completed a large sewer system improvement program. Any additional improvements to the sewer system would be directly related to the pace of development.

The Our Planned Community chapter requires the City to create a long-term plan to update infrastructure to not only accommodate growing population/businesses, but also the effects of climate change. This General Plan Update chapter also requires the City to adopt zero net water building codes, which would also reduce wastewater generation. Finally, consistent with Section 16B of the SPMC, this chapter includes an action to require Applicants/Developers of future development projects to pay fair share Water and Sewer Impact Fees for improvements to the water distribution and sanitary sewer systems. The purpose of this fee is to mitigate unfavorable impacts on the City’s water and sewer systems attributed to new development, and the fees collected are applied toward the costs of new or expanded public water and sewer facilities.

As part of the City’s plan review process, the Public Works Department conducts a review of wet utility (i.e., water and wastewater) infrastructure needs. The Applicant/Developer of future development projects would be responsible for installing all new or replacement sewer-related infrastructure on the property and within the proposed structure(s) deemed required by the City and remitting the sewer impact fee calculated by the City for that project. The City would be responsible for continuing to manage the Water and Sewer Impact Fee Fund and implement the necessary improvements to the sanitary sewer system.

In summary, new or expanded wastewater infrastructure may be necessary to serve future development projects. The need for, and environmental impacts of, additional wastewater infrastructure would be addressed in the required project-level CEQA review. If significant impacts associated with installation of the necessary infrastructure are identified, mitigation measures would be required. Through compliance with the City’s plan review processes; application of the Water and Sewer Impact Fee (Section 16B of the SPMC); implementation of applicable General Plan Update policies and actions; and identification of and, if necessary, mitigation for, environmental impacts associated with new or expanded wastewater infrastructure, there would be a less than significant impact and no mitigation is required. 3 - 1023
City of South Pasadena
2021–2029 Housing Element
Environmental Assessment
R:\Projects\SPA\3SPA010100\Environmental Documentation\Settlement Agreement\EA\3.15 Utilities-050923.docx 3.15-13 Utilities and Service Systems Stormwater Drainage Facilities
Changes in drainage patterns would be confined to individual development sites and would not affect major underground storm drain lines and concrete-lined drainages in the City. Most development sites pursuant to the proposed Project would be redevelopment of existing, fully developed sites, the change in drainage patterns on these sites would be nominal. All development must be conducted in compliance with applicable State and local regulations, which prevent substantial alteration of site drainage patterns by controlling the volume and direction of runoff. Since drainages in the City are concrete-lined, no alteration in the alignment of these channels would occur from future development. Impacts would be less than significant, and no mitigation is required.

Dry Utilities (Electrical, Natural Gas, and Telecommunications) Southern California Edison (SCE) provides electrical services and Southern California Gas (The Gas Company) provides natural gas services in the City. South Pasadena uses the Clean Power Alliance (CPA) for electricity generation at the 100 percent renewable level, wherein the City purchases electricity from the CPA but uses the physical plant and billing processes of SCE.

Telecommunications (i.e., telephone, television, and/or internet) services are provided by several companies, including, but not limited to, Spectrum, AT&T, and EarthLink. There is a backbone of dry utility infrastructure throughout the City. Electric and natural gas services are regulated by the California Public Utilities Commission (CPUC), which requires that these utilities provide services as required by the public. Telecommunications services are provided on demand in a free market system. The need for new, expanded, and/or relocation dry utilities would be determined as part of future individual projects and dependent on the conditions at each project site. The environmental impacts (e.g., air quality and noise) of constructing these facilities is within the range of assumptions applied to the analysis in this Environmental Assessment (EA).

Threshold 3.15b: Have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years?
Future development pursuant to the Project would generate a demand for water that will require increased pumping of groundwater resources and imported water use. The following water supply analysis is based on the City’s 2020 UWMP and input from the City Public Works Department staff.

Based on the 2020 water demand factor of 124 gallons per capita per day (gpcd) from the City’s 2020 UWMP, the total estimated water demand for the additional population (assuming no residential vacancies) is calculated to be 2.62 af (0.85 mgd). The actual water demand in fiscal year 2019-2020 was 3,546 af; therefore, the additional population of the Project would result in a total average day water demand of about 3,549 af. It is anticipated the City will be able to meet its average day demand in 2045 with its total water supply of 4,163 af (South Pasadena 2021).

While the Project would accommodate non-residential growth and additional landscaping, residential growth would be the source of most additional water demand and therefore is used for analysis purposes only to determine whether projected growth could reasonably be expected to have adequate water supplies. Water supply sufficiency would be assessed on a project-byproject basis based on State and other regulations in place at that time and the City’s current UWMP. The City has historically met all its water demands with groundwater production, treated imported water from MWD, and purchased water from the City of Pasadena. Even with the City’s historically reliable water supply, the City included a Water Conservation and Supply Shortage Plans and Enforcement (Ordinance No. 2268) in its 2020 UWMP identifying actions to be taken 3 - 1024
City of South Pasadena
2021–2029 Housing Element
Environmental Assessment
R:\Projects\SPA\3SPA010100\Environmental Documentation\Settlement Agreement\EA\3.15 Utilities-050923.docx 3.15-14 Utilities and Service Systems to respond to a severe or extended water shortage. If water supplies are temporarily insufficient to meet customer demand, the City may implement its Water Conservation and Supply Shortage Plans and Enforcement (Ordinance No. 2268) (South Pasadena 2021).

It is noted the City can increase production from the Basin in accordance with the Main San Gabriel Basin Judgment, even during periods of drought to meet its demands. Groundwater pumping limitations have never been applied to groundwater producers with rights in the Main San Gabriel Basin. This is because in addition to the City’s groundwater extraction from the Main San Gabriel Basin, the City has the ability to obtain supplemental water supplies from its Main San Gabriel Basin cyclic storage account. Under the Main San Gabriel Basin, cyclic storage provisions allow producers, including the City, to store supplemental water within the Main San Gabriel Basin for the purpose of supplying replacement water. As discussed previously, the City and other producers have a total balance of approximately 60,044 af in cyclic storage accounts as of April 2021.

Active and effective groundwater management enables water producers in the Basin to historically meet water demands, including during single and multiple dry years. Based on the demonstrated reliability of water resources available to the City, including the City’s access to the Basin water supplies, including imported replacement water and the City’s access to treated imported water from MWD and purchased water from the City of Pasadena, the City has sufficient and reliable water supplies to meet its future demands from 2020 to 2045, including during single and five consecutive year droughts (South Pasadena 2021). There would be adequate water supplies to support buildout of the Project from existing entitlements and resources. There would be a less than significant impact, and no mitigation is required.

Threshold 3.15d: 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? Threshold 3.15e: Would the Project comply with federal, State, and local management and reduction statutes and regulations related to solid waste? As the City is served by a private waste hauler, the City’s waste can be disposed, after sorting and recycling at one of Athens MRFs, at any landfill with capacity that can accept the municipal waste. Review of CalRecycle documents show that in 2019 (the most recent data available) Citygenerated municipal waste of approximately 21,482 tons was disposed at landfills, transformation facilities, and used for alternative daily cover (CalRecycle 2023c).

Based on the 2021 reporting year disposal rate targets (4.4 PPD per capita and 15.8 PPD per employee)(CalRecycle 2023a), at buildout of the Project the estimated 6,882 residents would generate approximately 30,281 PPD of solid waste, or approximately 5,526 tons per year3. The estimated 1,978 employees would generate approximately 31,252 PPD of solid waste, or approximately 5,704 tons per year4. This equates to approximately 11,230 tons per year (approximately 30.8 tons per day) of additional solid waste requiring disposal in 2040, assuming full buildout of the Project. Compared to the 2019 solid waste disposal after application of source reduction and recycling efforts, this would represent an approximate 52 percent increase municipal solid waste generation requiring disposal. It is noted that these figures are for analysis purposes only, as they assume no additional source reduction programs would be enacted by the City or that additional sorting and/or transformation technologies would not be developed to 3 (30,281 PPD * 365 days)/2,000 pounds per ton = 5,526 tons per year 4 (31,252 PPD * 365 days)/2,000 pounds per ton = 5,704 tons per year 3 - 1025
City of South Pasadena
2021–2029 Housing Element
Environmental Assessment
R:\Projects\SPA\3SPA010100\Environmental Documentation\Settlement Agreement\EA\3.15 Utilities-050923.docx 3.15-15 Utilities and Service Systems further reduce the waste stream, which is unlikely. It is also noted that these figures assume population growth with no residential vacancies, which is unlikely.

As of December 2020, (the most data available), the County’s 10 municipal landfills have a permitted daily capacity of 27,765 tons and an estimated remaining permitted capacity of 142.67 million tons, with remaining life estimates of between 9 and 35 years (LACPW 2021). The City’s estimated daily solid waste increase requiring disposal (approximately 30.8 tons) represents approximately 0.11 percent of the County landfill’s daily capacity and the annual solid waste increase (approximately 11,230 tons) approximately 0.01 percent of the remaining permitted capacity. As such, it is not anticipated that the City’s additional waste stream would exceed the capacity of these landfills. Also, in addition to in-County landfills, Athens can dispose of any available landfill at the time of disposal, including those out-of-County.

The City is currently exceeding its CalRecycle-defined per capita and per employee disposal rates. The City will continue to implement a variety of solid waste reduction, recycling, and re-use measures to continue to meet its obligation under AB 939, and to meet upcoming obligations under AB 341 and AB 1826. Therefore, there would be less than significant impacts related to landfill capacity and solid waste regulations, and no mitigation is required.

3.15.7 CUMULATIVE IMPACTS
Growth and development within the San Gabriel Valley would generate increased demand for utility services from various service agencies. While increases in utility demands would occur on agencies that do not serve the City, future development pursuant to the proposed Project would not add to the service demands of these outside agencies. At the same time, cumulative impacts on regional utility providers would account for growth and development within the larger region, rather than just the San Gabriel Valley. Thus, the cumulative analysis for impacts on utility services considers the service area of the respective providers and adjacent service agencies, as they may be affected by services to be provided within the City.

Water Supply
As discussed above, water services in the City are provided by the City. The primary water supply source now and through 2045 is the Main San Gabriel Groundwater Basin. The City’s 2020 UWMP considered the reliability of the Basin and imported water supplies, based on anticipated growth in entitlements and/or demands on these resources, during average, single dry, and five consecutive year droughts. The 2020 UWMP concluded the Basin and other water sources would reliably provide water demand under all conditions with Project build-out.

Water and Wastewater Infrastructure
The cumulative service area for both water distribution and wastewater conveyance infrastructure is the City of South Pasadena. As such, the analysis presented above is also the cumulative impact analysis. As discussed, future development projects would be required to evaluate the effects on the City’s infrastructure system, as well as identify environmental impacts of and mitigation measures for installation of any necessary infrastructure. As discussed above, through compliance with the City’s plan review processes, application of the Water and Sewer Impact Fee (Section 16B of the SPMC), and project-level CEQA analyses, there would be a less than significant impacts related to the need for new or expanded water distribution and wastewater conveyance infrastructure, and no mitigation is required. Accordingly, there would not be a cumulative impact related to water and wastewater infrastructure. 3 - 1026
City of South Pasadena
2021–2029 Housing Element
Environmental Assessment
R:\Projects\SPA\3SPA010100\Environmental Documentation\Settlement Agreement\EA\3.15 Utilities-050923.docx 3.15-16 Utilities and Service Systems Wastewater Treatment
Cumulative impacts on trunk sewer lines and wastewater treatment would occur within the service area of the LACSD. Future growth and development in the region would generate additional wastewater that would require conveyance and treatment at the WRPs of the LACSD, including the Whittier Narrows and Los Coyotes WRPs. Based on information provided by LACSD, these two WRPs have a combined remaining capacity of 21.3 mgd. Of this, the conservative, hypothetical wastewater generation estimated for the City’s buildout represents approximately

13.0 percent of the Whittier Narrows WRP’s remaining capacity and approximately .14 percent of the Los Coyotes WRP’s remaining capacity, as discussed previously. Also, all future development projects in the LACSD’s service area would be subject to the LACSD’s Wastewater Ordinance, which includes the Connection Fee program. The Connection Fee program requires all new users of the LACSD’s sewerage system, as well as existing users that significantly increase the quantity or strength of their wastewater discharge, to pay their fair share of the costs for providing additional conveyance, treatment, and disposal facilities. The LACSD uses the fees for the expansion and improvement of their facilities, as needed, to serve existing and anticipated developments. Based on continued implementation of the LACSD Wastewater Ordinance and the nominal contribution of additional wastewater flows to the LACSD system, the proposed Project would not contribute to a cumulatively considerable impact to LACSD facilities.

Solid Waste
Solid waste collection services are provided on demand by private haulers, and cumulative impacts on their services from future development pursuant to the General Plan and DTSP Update, public and infrastructure projects in the City, and growth and development within the San Gabriel Valley are not expected to result in adverse impacts on solid waste collection services.

Available landfill capacity is expected to decrease over time with future growth and development in the San Gabriel Valley. Waste reduction and recycling programs and regulations are expected to reduce this demand and extend the life of existing landfills. Also, CalRecycle is responsible for administering and monitoring State solid waste reduction initiatives, and individual jurisdiction’s ability to meet these requirements. It is assumed that CalRecycle’s role would continue in the future. Based on the available capacity of landfills in the region and the nominal contribution of additional solid waste requiring disposal, approximately 0.11 percent of the County landfill’s remaining daily permitted capacity, the proposed Project would not contribute to a cumulatively considerable impact to landfill capacity or solid waste regulations.

Dry Utilities
Natural gas is provided on demand from CPUC-regulated utilities (i.e., The Gas Company) and from free-market providers (e.g., AT&T and Spectrum). The CPA, discussed further above, is a community choice aggregate utility is also not regulated by the CPUC. The respective service areas for these utility providers are large and all cover at least substantial portions of California.

Because these utilities are provided on demand, including CPUC-regulated and community choice aggregate utilities, the expansion of services based on regional growth is part of each providers business strategy. Therefore, growth and development within the San Gabriel Valley are not expected to result in adverse impacts on dry utilities. The proposed Project would not contribute to a cumulatively considerable impact related to the need for new or expanded dry utilities.
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2021–2029 Housing Element
Environmental Assessment
R:\Projects\SPA\3SPA010100\Environmental Documentation\Settlement Agreement\EA\3.15 Utilities-050923.docx 3.15-17 Utilities and Service Systems

3.15.8 MITIGATION MEASURES
No significant impacts related to utilities and service systems have been identified with implementation of the Project. Therefore, no mitigation is required.

3.15.9 LEVEL OF SIGNIFICANCE AFTER MITIGATION
Less than significant.

3.15.10 REFERENCES
California Department of Resources Recycling and Recovery (CalRecycle). 2023a (April 28, access date). Jurisdiction Diversion/Disposal Rate Summary (2007 – Current): South Pasadena: 2021 Reporting Year. Sacramento, CA: CalRecycle. Jurisdiction Diversion/Disposal Rate Detail (ca.gov).
———. 2023b (April 28, access date). Jurisdiction Disposal and Alternative Daily Cover (ADC) Tons by Facility: South Pasadena: 2019 Reporting Year: Los Angeles – South Pasadena.

Sacramento, CA: CalRecycle.
https://www2.calrecycle.ca.gov/LGCentral/DisposalReporting/Destination/DisposalByFac ility.
———. 2023c (April 28, access date). Multi-year Countywide Origin Summary: Los Angeles.

Sacramento, CA: CalRecycle.
https://www2.calrecycle.ca.gov/LGCentral/DisposalReporting/Origin/CountywideSummar y.
———. 2021a (May 14, access date). Solid Waste Information System (SWIS) Facility/Site Activity Details: Athens Service (19-AA-0863). Sacramento, CA: CalRecycle. SWIS Facility/Site Activity Details (ca.gov).
———. 2021b (May 14, access date). Solid Waste Information System (SWIS) Facility/Site Activity Details: Athens Sun Valley Mat. Rec. & TS (19-AR-5581). Sacramento, CA:

CalRecycle. SWIS Facility/Site Activity Details (ca.gov).

County of Los Angeles Public Works (LACPW). 2021 (October). County of Los Angeles Countywide Integrated Waste Management Plan 2020 Annual Report. Alhambra, CA:

LACDPW.
https://dpw.lacounty.gov/epd/swims/ShowDoc.aspx?id=16231&hp=yes&type=PDF.

Main San Gabriel Basin Watermaster (Watermaster). 2020. 2019-2020 Annual Report. Azusa, CA: Watermaster. https://955084b9-ee64-4728-a939-
5db8ad0ab8ae.filesusr.com/ugd/af1ff8_2aa678901b0445899691a07ce3f92b61.pdf.

Sanitation Districts of Los Angeles County (LACSD). 2021 (May 11). RNOP Response for the South Pasadena General Plan and Downtown Specific Plan Update and 2021-2029 Housing Element. Whittier, CA: LACSD. Appendix A-2.

South Pasadena, City of. 2021 (October). City of South Pasadena Final 2020 Urban Water Management Plan. South Pasadena, CA: the
Cityhttps://www.southpasadenaca.gov/home/showpublisheddocument/27639/63773889 7658270000s.
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2021–2029 Housing Element
Environmental Assessment
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City of South Pasadena
2021–2029 Housing Element
Environmental Assessment
R:\Projects\SPA\3SPA010100\Environmental Documentation\Settlement Agreement\EA\3.16_Wildfire-050923.docx 3.16-1 Wildfire

3.16 WILDFIRE

3.16.1 METHODOLOGY
This section describes the existing wildfire hazards in the City of South Pasadena (City) and the potential to exacerbate wildfire risks with future development projects under the proposed 2021–2029 Housing Element and the non-residential development capacity envisioned in the General Plan and Downtown Specific Plan (DTSP) Update (Project).

3.16.2 EXISTING CONDITIONS
Wildfire Hazards in the City of South Pasadena
Wildfires can potentially occur where developments are adjacent to open space or proximate to wildland fuels such as grass, leaf litter, trees, or shrubs that can ignite when exposed to a natural occurrence (i.e., lightning) or by an unplanned, unauthorized, and/or accidental human-caused activity. Wildfires may originate in undeveloped areas and spread to developed or urban areas where landscape and structures are not designed and maintained to be fire-resistant.

High Risk Areas (South Pasadena Municipal Code)
Section 14.1 et. seq. of the City of South Pasadena Municipal Code (SPMC) designates as a High Risk Fire Area “as those properties located south of Monterey Road, extending to the city border, and west of Meridian Avenue, extending to the city border.” The requirements for construction in this area are described below in Section 3.16.3, Relevant Programs and Regulations.

Fire Hazard Severity Zones (California Department of Forestry and Fire Protection) The California Department of Forestry and Fire Protection (CAL FIRE) is mandated by Section 4201-4204 of the Public Resources Code and Section 51175-51189 of the Government Code to identify Fire Hazard Severity Zones in the State. These are areas of significant fire hazard based on fuels, terrain, weather, and other relevant factors where the State has financial responsibility for wildland fire protection. These areas are also known as State Responsibility Areas (SRAs).

Areas where local fire protection agencies are responsible for wildfire protection are classified as Local Responsibility Areas (LRAs). These classifications influence where development occurs and how a city will respond to future wildfire emergencies.

CAL FIRE has not designated any lands within the City of South Pasadena as High Fire Hazard Severity Zones. However, lands abutting the western and southwestern boundaries of the City are identified as within a Very High Fire Hazard Severity Zone (VHFHSZ) (CAL FIRE 2023). Most of these lands are in the City of Los Angeles, and a small portion is in the City of Pasadena (see Exhibit 3.16-1). Those VHFHSZs are in LRA; thus, the cities of Los Angeles and Pasadena are responsible for the costs of wildfire suppression in those areas.

Historic Wildfires in the City
Based on the most recent data, CAL FIRE reports one historic wildfire is mapped as within the City, a 1974 fire in the Monterey Hills area that burned 4.4 acres. Additionally, the edge of a 1957 wildfire that burned 170 acres in the City of Los Angeles immediately to the west-southwest, slightly encroached on the City’s lands near what is now Oak Hill Place (CAL FIRE 2021). The City has experienced small brush fires that are managed by local agencies as well, but these are not tracked as wildfires by CAL FIRE.
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City of South Pasadena
2021–2029 Housing Element
Environmental Assessment
R:\Projects\SPA\3SPA010100\Environmental Documentation\Settlement Agreement\EA\3.16_Wildfire-050923.docx 3.16-2 Wildfire Firefighting Resources
As discussed further in Section 3.13, Public Services and Recreation, the South Pasadena Fire Department (SPFD) provides fire protection and emergency medical services in the City. The SPFD is a full-service fire department that provides fire/rescue services, paramedics, safety education, inspections, plan reviews, and emergency management. The SPFD is also an all risk emergency services agency, as SPFD personnel are trained to handle responses such as structure, wildland and vehicle fires, hazardous materials releases, rescues and service calls, and provide advanced life support and medical transport. There is one fire station in the City, located at 817 Mound Avenue, that houses an engine company (Engine 81), a rescue ambulance, and a light and air unit.

A mutual aid agreement is an agreement in which participating agencies guarantee the provision of available resources to a requesting agency in the event of an emergency. An automatic aid agreement provides services without regard for service boundaries but based on earliest response. The SPFD has automatic aid agreements with the twelve other agencies1 affiliated with the Verdugo Fire Communications Center (VFCC), all of whom operate under the Unified Response agreement. The SPFD also participates in the State of California Master Mutual Aid program, which is used when all available local resources have been depleted or committed to an incident, allowing the State to coordinate resources available from neighboring counties, as necessary.

3.16.3 RELEVANT PROGRAMS AND REGULATIONS
State

CAL FIRE
CAL FIRE’s Fire Prevention Program consists of various activities including wildland pre-fire engineering, vegetation management, fire planning, education, and law enforcement. Common projects include fire break construction and other fire fuel reduction activities that lessen the risk of wildfire to communities. These activities include brush clearance around communities, along roadways and evacuation routes. Other important activities include defensible space inspections, emergency evacuation planning, fire prevention education, fire hazard severity mapping (discussed above), preparation and implementation of the State’s fire plan, fire-related law enforcement activities such as investigations to determine fire cause and origin as well as arson cases, and support for local government fire safe planning in the SRA.

California Fire Plan
In a collaborative effort between the State Board of Forestry and the California Department of Forestry and Fire Protection, the 2018 Strategic Fire Plan for California (Fire Plan) was prepared to address the protection of lives and property from California wildfires while recognizing that wildfires are a natural phenomenon and can have beneficial effects, particularly on ecosystem health. The Fire Plan is a comprehensive update to the 2010 Strategic Fire Plan for California.

The overarching vision of the Fire Plan is to have “A vision for a natural environment that is more fire resilient; buildings and infrastructure that are more fire resistant; and a society that is more aware of and responsive to the benefits and threats of wildland fire; all achieved through local, state, federal, tribal, and private partnerships”. This vision is supported by eight goals and related 1 The VFCC currently includes the cities of Alhambra, Arcadia, Burbank, Glendale, Monrovia, Montebello, Monterey Park, Pasadena, San Gabriel, San Marino, Sierra Madre, South Pasadena, and the Bob Hope Airport Fire Department.
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City of South Pasadena
2021–2029 Housing Element
Environmental Assessment
R:\Projects\SPA\3SPA010100\Environmental Documentation\Settlement Agreement\EA\3.16_Wildfire-050923.docx 3.16-3 Wildfire objectives, and the application of adaptive management as a fundamental strategy of Fire Plan implementation to provide flexibility and allow for changing internal and external conditions (CAL FIRE 2018).

Fire Hazard Severity Zone Mapping
CAL FIRE prepares Fire Hazard Severity Zone maps for SRA and LRA considering many factors such as fire history, existing and potential fuel (natural vegetation), flame length, blowing embers, terrain, and typical weather for the area. The CAL FIRE Director evaluates fire hazard severity in LRA and makes a recommendation to the local jurisdiction where VHFHSZs exist. The Government Code then provides direction for the local jurisdiction to take appropriate action.

Section 4291 of the Public Resources Code
In January 2005, a new State law became effective that extended the defensible space clearance around homes and structures from 30 feet to 100 feet. Proper clearance to 100 feet dramatically increases the chance of a house surviving a wildfire. This defensible space also provides for firefighter safety when protecting homes during a wildland fire. This State law is promulgated in Section 4291 et. seq. of the Public Resources Code, which CAL FIRE is responsible for enforcing.

Section 4291(a)(1) of the Public Resources Code states that “A person who owns, leases, controls, operates, or maintains a building or structure in, upon, or adjoining a mountainous area, forest-covered lands, brush-covered lands, grass-covered lands, or land that is covered with flammable material, shall at all times do all of the following:
(A) Maintain defensible space of 100 feet from each side and from the front and rear of the structure, but not beyond the property line, except as provided in subparagraph (B). The amount of fuel modification necessary shall consider the flammability of the structure as affected by building material, building standards, location, and type of vegetation. Fuels shall be maintained in a condition so that a wildfire burning under average weather conditions would be unlikely to ignite the structure. This subparagraph does not apply to single specimens of trees or other vegetation that are well-pruned and maintained so as to effectively manage fuels and not form a means of rapidly transmitting fire from other nearby vegetation to a structure or from a structure to other nearby vegetation. The intensity of fuels management may vary within the 100-foot perimeter of the structure, with more intense fuel reductions being utilized between 5 and 30 feet around the structure, and an ember-resistant zone being required within 5 feet of the structure, based on regulations promulgated by the board, in consultation with the department, to consider the elimination of materials in the ember-resistant zone that would likely be ignited by embers. The promulgation of these regulations by the board is contingent upon an appropriation by the Legislature in the annual Budget Act or another statute for this purpose. Consistent with fuels management objectives, steps should be taken to minimize erosion. For the purposes of this subparagraph, “fuel” means any combustible material, including petroleum-based products and wildland fuels.”
(B) A greater distance than that required under subparagraph (A) may be required by state law, local ordinance, rule, or regulation. Clearance beyond the property line may only be required if the state law, local ordinance, rule, or regulation includes findings that the clearing is necessary to significantly reduce the risk of transmission of flame or heat sufficient to ignite the structure, and there is no other 3 - 1032
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Environmental Assessment
R:\Projects\SPA\3SPA010100\Environmental Documentation\Settlement Agreement\EA\3.16_Wildfire-050923.docx 3.16-4 Wildfire feasible mitigation measure possible to reduce the risk of ignition or spread of wildfire to the structure. Clearance on adjacent property shall only be conducted following written consent by the adjacent landowner.
(C) An insurance company that insures an occupied dwelling or occupied structure may require a greater distance than that required under subparagraph (A) if a fire expert, designated by the director, provides findings that the clearing is necessary to significantly reduce the risk of transmission of flame or heat sufficient to ignite the structure, and there is no other feasible mitigation measure possible to reduce the risk of ignition or spread of wildfire to the structure. The greater distance may not be beyond the property line unless allowed by state law, local ordinance, rule, or regulation.

California Disaster and Civil Defense Master Mutual Aid Agreement The California Disaster and Civil Defense Master Mutual Aid Agreement is an agreement between the State of California, its various departments and agencies, and the various political subdivisions, municipal corporations, and other public agencies of the State of California. The agreement allows for the use of all the resources and facilities of the participating agencies in preventing and combating the effect of disasters, such as flood, fire, earthquake, pestilence, war, sabotage, and riot. It commits the participating agencies to voluntarily aid and assist each other in the event of a disaster, through the interchange of services and facilities, including fire, police, medical and health, communication, and transportation services and facilities, as necessary, to provide rescue, relief, evacuation, rehabilitation, and reconstruction.

California Fire Code
The 2022 California Fire Code (Title 24, Part 9 of the California Code of Regulations), effective January 1, 2023, is based on the 2021 International Fire Code. Typical fire safety requirements of the California Fire Code include requirements for the installation of fire sprinkler; building materials and particular types of construction; and the clearance of debris and vegetation within a prescribed distance from occupied structures within wildfire hazard areas. In addition, the California Fire Code addresses fire flow requirements, fire hydrant spacing, and access road specifications. Specific California Fire Code fire safety regulations have been incorporated by reference in both the County of Los Angeles Code and the SPMC with local amendments.

Chapter 7A of the California Building Code (CBC) focuses primarily on preventing ember penetration into homes, a leading cause of structure loss from wildfires. These codes have been developed through decades of fire structure “save” and “loss” evaluations to determine what causes buildings to ignite or how to avoid ignition during wildfires. The resulting fire codes now focus on mitigating former structural vulnerabilities through construction techniques and materials so that the buildings are resistant to ignitions from direct flames, heat, and embers.

Senate Bill 969
Senate Bill 969, signed into law in 2018, applies to all new garage doors and garage door opener installations. The law states that when a new garage door is installed or when an existing garage door opener is replaced, the homeowner must install a battery backup garage door opener.

Widespread power outages are often associated with wildfires. Without electricity, homeowners/occupants are unable to open their garage doors using the garage door opener.

While garage doors do have an emergency cord, which disconnects the garage door from the 3 - 1033
City of South Pasadena
2021–2029 Housing Element
Environmental Assessment
R:\Projects\SPA\3SPA010100\Environmental Documentation\Settlement Agreement\EA\3.16_Wildfire-050923.docx 3.16-5 Wildfire garage door opener, some people have difficulty engaging the emergency release and/or manually opening the garage door.

City
Municipal Code
As stated above, the City has a self-defined High Risk Fire Area pursuant to Section 14.1 et. seq. of the SPMC. The location of this area and the requirements for construction in this area related to fire prevention and protection are as follows:

14.1 High risk fire area and special provisions related to roof types.

1. High Risk Fire Area. “High risk fire area” is defined as those properties located south of Monterey Road, extending to the city border, and west of Meridian Avenue, extending to the city border.

2. Special Provisions Related to Roof Types. Except as permitted below, roof covering assemblies shall be Class A.

The following exceptions shall only apply to structures not located within the high risk fire area as defined in subsection (1) of this section:

Exceptions:
a. Replacements within any 12-month period of time that are not more than 25 percent of the total roof area of any individual structure shall be not less than Class C;
b. Replacements within any 12-month period of time that are not more than 50 percent of the total roof area of any individual structure shall be not less than Class B;
c. Entirely noncombustible roof assemblies of masonry or concrete construction;
d. Clay or concrete roof tile installed on an entirely noncombustible substructure;
e. Roof assemblies of ferrous or copper shingles or sheets installed on an entirely noncombustible substructure;
f. Where the fire chief makes a written finding that a less fire resistive roof covering is permissible based on existing conditions.

In no case shall any roof covering be less fire resistive than required by Chapter 15 of the current South Pasadena building code or Chapter 9 of the current South Pasadena residential code.

It is noted that the requirement for Class A roof assemblies, and the exceptions cited above, are consistent with Section R902.1, Roof Covering Materials, of the California Residential Code (Title 24, Part 2.5 of the California Code of Regulations). 3 - 1034
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Environmental Assessment
R:\Projects\SPA\3SPA010100\Environmental Documentation\Settlement Agreement\EA\3.16_Wildfire-050923.docx 3.16-6 Wildfire Emergency Operations Plan
The City of South Pasadena and the South Pasadena Unified School District Joint Emergency Operations Plan (EOP) address the City’s planned response to emergency/disaster situations associated with natural disasters, human-made emergencies, and national security emergencies.

The EOP does not address day-to-day emergencies or the well-established and routine procedures used in coping with such emergencies. Instead, the operational concepts reflected in the EOP focus on large-scale events and was developed with a multi-hazard perspective to make it applicable to the emergency operations for the widest range of emergencies and disasters, both natural and human caused, of the City and the South Pasadena Unified School District. This plan was a preparedness document—designed to be read, understood, and exercised prior to an emergency/disaster. The EOP was prepared in compliance with California Standardized Emergency Management System and National Incident Management System, and also incorporates the concepts and principles of the and the Incident Command System (South Pasadena 2012).

Draft Local Hazard Mitigation Plan
The Draft Local Hazard Mitigation Plan (HMP) assists the City in reducing vulnerability to disasters by identifying critical facilities, resources, information, and strategies for risk reduction, while helping to guide and coordinate mitigation actions. The HMP provides a set of strategies intended to do the following: reduce risk from natural hazards through education and outreach programs, foster the development of partnerships, and implement risk reduction activities. Hazard mitigation ensures that post-disaster repairs and reconstruction result in a true reduction in future hazard vulnerability (South Pasadena 2018).

Additionally, the federal Disaster Mitigation Act of 2000 requires that local governments, as a condition of receiving federal disaster mitigation funds, have a mitigation plan that describes the process for identifying hazards, risks and vulnerabilities, identifies and prioritizes mitigation actions, encourages the development of local mitigation, and provides technical support for those efforts. The City’s HMP serves to meet these requirements and therefore enables the receipt of federal disaster funds, when applicable.

3.16.4 THRESHOLDS OF SIGNIFICANCE
The following significance criteria are derived from Appendix G of the State CEQA Guidelines. If located in or near State responsibility areas or lands classified as VHFHSZ, a project would result in a significant adverse wildfire impact if it would:

Threshold 3.16a: Substantially impair an adopted emergency response plan or emergency evacuation plan;
Threshold 3.16b: Due to slope, prevailing winds, and other factors, exacerbate wildfire risks, and thereby expose project occupants to, pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire;
Threshold 3.16c: Require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment; and/or
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R:\Projects\SPA\3SPA010100\Environmental Documentation\Settlement Agreement\EA\3.16_Wildfire-050923.docx 3.16-7 Wildfire Threshold 3.16d: Expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes.

3.16.5 PROPOSED HOUSING ELEMENT GOALS AND POLICIES
There are no Housing Element goals or policies related to wildfire.

3.16.6 ENVIRONMENTAL IMPACTS
Threshold 3.16a: If located in or near State responsibility areas or lands classified as VHFHSZ, would the Project substantially impair an adopted emergency response plan or emergency evacuation plan?
As noted above, while no part of the City of South Pasadena is classified as a VHFHSZ, there are lands immediately to the west and southwest that are identified by CAL FIRE as VHFHSZ.

Additionally, the City has defined the southwest corner of South Pasadena as a High Risk Fire Area. For purposes of this analysis, the City-defined High Risk Fire Area is treated the same as a VHFHSZ.

Construction activities on public rights-of-way may temporarily block traffic and access near the construction zone. As discussed above, compliance with Section 36.310.090 of the SPMC in the design and construction of future projects would always maintain emergency access to individual parcels. Impacts on traffic flows for emergency response or evacuation would be less than significant during construction activities, and no mitigation is required.

The City has a developed roadway network that provides emergency access and evacuation routes to existing development. Evacuation routes include major roadways in the City, with the State Route 110 and Interstate 210 freeways serving as primary regional exit routes. These freeways provide area-wide evacuation routes, with major north-south and east-west roadways in the City connecting to the freeways and adjacent cities. No major change to the existing roadway system serving the City is proposed. Access to individual development sites would be available through existing or planned on-site roadways/driveways, as required under Section

36.310.090 “Driveways and Site Access” of the SPMC. Section 36.310.090 of the SPMC defines requirements for all access from public streets to private property to ensure adequate and safe access by vehicular and other traffic. The plan check and building permit process by the SPFD includes review of access for emergency vehicles in accordance with the California Fire Code, as adopted by reference by the City (Chapter 14 of the SPMC). Compliance with the requirements for emergency lane width, vertical clearance, and distance would provide adequate emergency access to all new development pursuant to the Project. Continued implementation of State and City emergency access requirements would provide future development with adequate access for emergency response or evacuation.

The proposed General Plan Update includes actions to update the City’s Hazard Mitigation Plan to address disaster recovery in the business community, explore the development of a Business Disaster Assistance Center, develop a rapid response team to support safe evacuation in the hillside areas, and periodically review and update the City’s post-disaster recovery plan. Also, the City has an Emergency Management Program, which includes all elements necessary to respond quickly and effectively to major emergencies. These elements include the following: Emergency Operations Plan, Emergency Operations Center, Emergency Response Program, and Public Education Program.
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R:\Projects\SPA\3SPA010100\Environmental Documentation\Settlement Agreement\EA\3.16_Wildfire-050923.docx 3.16-8 Wildfire With implementation of the policies and actions identified above and continued implementation of the City’s emergency response programs, impacts related to emergency response and evacuation would be less than significant, and no mitigation is required.

Threshold 3.16b: If located in or near State responsibility areas or lands classified as VHFHSZ, would the Project, due to slope, prevailing winds, and other factors, exacerbate wildfire risks, and expose project occupants to, pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire?
There are parcels identified for potential housing in the Suitable Sites Inventory, which is a required part of housing element preparation, within the City’s designated High Risk Fire Area covering properties south of Monterey Road and west of Meridian Drive. Some of these parcels are situated on or near existing slopes. However, individual development projects would be reviewed by the SPFD as part of the City’s project review process and would be required to comply with all State CBC and City fire code standards in effect at the time the building permit is issued, pursuant to Chapter 14, Fire Prevention, of the SPMC. Section 14.4 of the SPMC includes requirements for building construction, fire flows and pressures, hydrant placement, and other requirements that would reduce the creation of fire hazards and facilitate emergency response.

In addition to City-wide fire code standards, Section 14.1 of the SPMC requires that development of any parcels in the High Risk Fire Area would be required to have Class A roof assemblies, which are effective against severe fire test exposures, with exceptions including, but not limited to, installation of an entirely non-combustible roof assembly, clay or concrete tile or ferrous or copper shingles or sheets on an entirely non-combustible substructure, and timing and amount of roof replacements. Therefore, new development pursuant to the Project would not exacerbate wildfire risks due to slope, prevailing winds, and other factors, and thereby expose residents or other persons to pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire.

There would be less than significant impacts, and no mitigation is required.

Threshold 3.16c: If located in or near State responsibility areas or lands classified as VHFHSZ, would the Project require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment?
Since the City of South Pasadena is largely built out, the roadway and utility infrastructure systems are in place. Improvements to roads and other infrastructure may be implemented either to alleviate existing issues or in support of anticipated future growth. The need for and installation of new infrastructure would be determined during the City’s discretionary review process for new development and redevelopment. Extension of utilities or roadway improvements would serve only the existing and proposed uses and would most likely be installed in existing public rights-of-way and/or private property (e.g., water and sewer laterals, gas line connections). Also, new or replacement infrastructure would not extend into wildlands or otherwise substantively beyond the existing urban land uses. As such, while implementation of the Project may result in the installation and maintenance of infrastructure, the locations of this infrastructure would not exacerbate fire risk or result in temporary or ongoing impacts to the environment. There would be a less than significant impact, and no mitigation is required. 3 - 1037
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R:\Projects\SPA\3SPA010100\Environmental Documentation\Settlement Agreement\EA\3.16_Wildfire-050923.docx 3.16-9 Wildfire Threshold 3.16d: Would the Project expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes? The designated High Risk Fire Area is located in the hilly portion of the City. Accordingly, any development or redevelopment in this area would be subject to Section 36.340 et. seq. of the SPMC. This section defines additional requirements, beyond the City Building Code, for development on sites with an average slope of 20 percent or greater, except parcels within the Altos de Monterey (AM) overlay zone situated along Via Del Rey and adjoining streets in the south-central portion of the City. These sites are instead subject to the AM Overlay District (Section 36.250.030 of the SPMC). Procedures for Hillside Development Permits are established in Section 36.410.065 of the City Municipal Code.

Future development or redevelopment within the areas subject to a Hillside Development Permit, largely in the southwest portion of the City, would also be required to prepare site-specific geotechnical investigations that include analysis of slope stability and erosion as it pertains to the site’s unique topography and provide appropriate construction recommendations, as necessary.

The General Plan Update includes policies and actions related to development in the City and in the hillside areas to ensure that regulations related to grading are adopted and maintained, and that development in areas subject to the hillside ordinance are fully investigated. As such, while implementation of the Project may result in development or redevelopment in hillside areas, through compliance with State and City requirements structures would not be exposed to significant downslope or downstream risks as a result of runoff, post-fire slope instability, or drainage changes. There would be a less than significant impact, and no mitigation is required.

3.16.7 CUMULATIVE IMPACTS
The geographic context for cumulative wildfire impacts is generally the City of South Pasadena and those areas within the cities of Los Angeles and Pasadena that are within VHFHSZs abutting the City of South Pasadena (refer to Exhibit 3.16-1). Compliance with State and local regulations pertaining to development in VHFHSZs and/or on hillsides in the cities of Los Angeles and Pasadena would be required of all development in the cumulative area for wildfires. Individual projects would be designed and built in accordance with applicable standards in the CBC and the city’s respective municipal codes as well as all requirements pertaining to emergency access and evacuation. Site-specific geotechnical hazards related to slope and/or landslide risk would be addressed by the geotechnical investigations required by individual cities and the County for each development proposal. Compliance with applicable State and local regulations would prevent significant adverse impacts associated with wildfire hazards, and impacts associated with the Project would not be cumulatively considerable, and no mitigation is required.

3.16.8 MITIGATION MEASURES
No significant adverse impacts related to wildfire have been identified with implementation of the Project. Therefore, no mitigation is required.

3.16.9 LEVEL OF SIGNIFICANCE AFTER MITIGATION
Less than significant.
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3.16.10 REFERENCES
California Department of Forestry and Fire Protection (CAL FIRE). 2023a. (April 25, access date) FHSZ Viewer. Sacramento, CA: CAL FIRE. FHSZ Viewer (ca.gov). ———. 2021 (June 12, last accessed). Maps: Data Basin: Fire Perimeters (firep18_1): GIS Database. Sacramento: CA: CA: Fire Perimeters (ca.gov). ———. 2018 (August 22). 2018 Strategic Fire Plan for California. http://cdfdata.fire.ca.gov/pub/fireplan/fpupload/fpppdf1614.pdf.

South Pasadena, City of. 2018 (July). Draft Local Hazard Mitigation Plan. South Pasadena, CA:
the City. Draft (V1) (southpasadenaca.gov).
———. 2012 (February 14). City of South Pasadena and the South Pasadena Unified School District Joint Emergency Operations Plan. South Pasadena, CA: the City. 636721709083330000 (southpasadenaca.gov).
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R:\Projects\SPA\3SPA010100\Environmental Documentation\Settlement Agreement\EA\4.0_Alternatives-050923.docx 4-1 Alternatives to the Proposed Project SECTION 4.0 ALTERNATIVES TO THE PROPOSED PROJECT

4.1 INTRODUCTION
Section 15126.6 of the California Environmental Quality Act (CEQA) Guidelines addresses the discussion of alternatives in an Environmental Impact Report (EIR). Key provisions of the State CEQA Guidelines are identified throughout this section to explain the basis for the alternatives evaluation in this Environmental Assessment (EA). Section 15126.6(a) states:

An EIR shall describe a range of reasonable alternatives to the project, or to the location of the project, which would feasibly attain most of the basic objectives of the project but would avoid or substantially lessen any of the significant effects of the project, and evaluate the comparative merits of the alternatives. An EIR need not consider every conceivable alternative to a project. Rather, it must consider a reasonable range of potentially feasible alternatives that will foster informed decision-making and public participation. An EIR is not required to consider alternatives that are infeasible. The lead agency is responsible for selecting a range of project alternatives for examination and must publicly disclose its reasoning for selecting those alternatives. There is no ironclad rule governing the nature or scope of the alternatives to be discussed other than the rule of reason.

4.1.1 PROJECT SUMMARY
Pursuant to State law, the City of South Pasadena (City) has an approved General Plan. The South Pasadena General Plan was last updated and adopted by the City in 1998. Similarly, the City has an approved Specific Plan for a portion of the downtown area. The Mission Street Specific Plan (MSSP; now expanded to include a segment of Fair Oaks Avenue and referred to as the Downtown Specific Plan [DTSP]) was adopted in 1996. State law does not require a General Plan to be updated in regularly scheduled intervals, except for the Housing Element, which must be updated every five to eight years. However, a general plan needs to be updated if it is to reflect community values and priorities as they change over time. The City’s current General Plan, including the Housing Element, does not align with the City’s vision for its future nor with the need to provide housing in compliance with State law.

Accordingly, the comprehensive General Plan and Downtown Specific Plan (DTSP) Update is being undertaken by the City at this time to strengthen its commitment to protecting the characteristics that make South Pasadena a desirable place to live; reflect an understanding of current community goals; address continued growth pressures in the San Gabriel Valley and the demand for more diverse mobility and housing choices; and respond to evolving regional and environmental issues. The General Plan and DTSP Update serve as long-term (through 2040) policy guides for decision-making regarding the physical development, resource conservation, and character of the City and establishes a non-residential development capacity for the City.

The housing element is one of the State-mandated elements of a General Plan. It identifies the City’s housing conditions, needs, and opportunities and establishes the goals, policies, and actions (programs) that are the foundation of the City’s housing strategy. However, unlike all other General Plan elements, State law requires each municipality to update its housing element on a prescribed schedule (most commonly every eight years). Housing needs are determined by the California Housing and Community Development Department (HCD), which allocates numerical housing targets to the Metropolitan Planning Organizations (MPOs), including the Southern California Association of Governments (SCAG), which includes the City of South Pasadena.

SCAG finalized its Regional Housing Needs Assessment (RHNA), on March 9, 2021 and has 3 - 1040
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R:\Projects\SPA\3SPA010100\Environmental Documentation\Settlement Agreement\EA\4.0_Alternatives-050923.docx 4-2 Alternatives to the Proposed Project allocated 2,067 dwelling units (DUs) to the City of South Pasadena. Additionally, HCD has required the 2021–2029 Housing Element to demonstrate capacity for a surplus of units beyond the RHNA allocation. The Court Order1 requires that the City bring its Housing Element into compliance with State Planning Law. The changes in the draft 2021–2029 Housing Element is reflected in both the General Plan and DTSP Update, being prepared contemporaneously. This EA is based on environmental analysis of both the residential development capacity identified in the 2021–2029 Housing Element and the non-residential development capacity identified in the General Plan and DTSP Update still in progress (referred to as the Project herein). The central strategy of the Project is to preserve and enhance the distinctive neighborhoods and direct calibrated growth primarily to five focus areas including the Downtown area (i.e., DTSP), Ostrich Farm District, and three Neighborhood Centers on Huntington Drive while providing an enhanced variety of housing opportunities.

The Project would accommodate a total of 2,775 residential DUs and 430,000 square feet (sf) of non-residential uses, comprised of retail and office development, in addition to both the existing land uses (see Table 2-4 in Section 2.0 of this EA). The full buildout of the Project, for purposes of this EA, would generate up to an additional 6,882 residents (assuming no residential vacancies) and 1,978 jobs in the City through 2040 compared to existing conditions.

It is important to note that the Project would not authorize any specific development project or other form of land use approval, including public facilities or capital facilities expenditures or improvements. New development would continue to be subject to the City’s development review process. The General Plan and DTSP Update serve as a long-term policy guide for decisionmaking regarding the physical development, resource conservation, and character of the City and establishes a non-residential development capacity for the City. The proposed 2021–2029 Housing Element serves as the policy guide for decision-making regarding residential development and demonstrates how the City intends to comply with State housing legislation and regional (i.e., SCAG) requirements.

4.1.2 PROJECT OBJECTIVES
Section 15124 of the State CEQA Guidelines requires an EIR to include a statement of the proposed project’s objectives. The proposed Project seeks to achieve the following key objectives:

1. Provide sufficient capacity for housing development in compliance with State policy mandates. Address the shortage of housing for lower-income households and promote an inclusive residential environment that welcomes all people into the community.

2. Preserve natural areas, enhance parks and open spaces to provide enriching recreational opportunities and ensure access to those spaces for people of all ages and abilities.

3. Direct new growth to the downtown area along Mission Street and Fair Oaks Avenue, as well as opportunity sites such as the Ostrich Farm District, while ensuring the continued character of existing residential areas.

4. Develop clear and precise standards that offer predictable outcomes and processes.

5. Encourage pedestrian-oriented mixed-use development, while providing new and enhancing existing public spaces and gathering places, creating vibrant cultural hubs that weave creative expression into everyday life.
1 Stipulated Judgment (Californians For Homeownership V. City of South Pasadena, LASC Case Nos. 22STCP01388 & 22STCP01161)
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6. Create environments that encourage safe and healthy lifestyles and maximize the opportunities for physical activity. Design the public and semi-public realm to foster social interaction and develop good programming to draw people out of their homes and into the community.

4.1.3 SIGNIFICANT AND UNAVOIDABLE IMPACTS
As previously mentioned, an EIR should consider a range of feasible alternatives that would attain most of the project objectives listed above, while reducing or eliminating one or more of the significant and unavoidable impacts of the proposed Project, which include:
 Air Quality (Air Quality Management Plan Consistency, Air Quality Standards Violation, and Cumulative Air Quality Impacts);
 Greenhouse Gas Emissions (GHG Emissions, Plan Consistency);  Noise (Direct and Cumulative Construction and Exterior Traffic Noise Standard Violation); and
 Population and Housing (Population Growth).

4.1.4 ALTERNATIVES TO THE PROPOSED PROJECT
In accordance with the Section 15126.6(a) of the State CEQA Guidelines, this section summarizes the range of alternatives considered in the EA.

The following alternative has been considered and eliminated from detailed consideration for the reasons identified in Section 4.2, below:
 Alternative Site, and
 No Project/No Development.

Alternatives that are considered in detail in this EA include:
 Alternative 1: No Project/Existing General Plan; and
 Alternative 2: Reduced Development Capacity.

4.2 ALTERNATIVES ELIMINATED FROM DETAILED CONSIDERATION Section 15126.6(c) of the CEQA Guidelines specifies that an EIR should (1) identify alternatives that were considered by the lead agency but were eliminated from detailed consideration because they were determined to be infeasible during the scoping process and (2) briefly explain the reasons underlying the lead agency’s determination. Among the factors that may be used to eliminate alternatives from detailed consideration in an EIR are (1) failure to meet most of the basic project objectives; (2) infeasibility; or (3) inability to avoid significant environmental impacts.

4.2.1 ALTERNATIVE SITE
Section 15126.6(f)(2)(A) of the State CEQA Guidelines indicates that, in determining the consideration of an alternative location, “The key question and first step in analysis is whether any of the significant effects of the project would be avoided or substantially lessened by putting the project in another location. Only locations that would avoid or substantially lessen any of the 3 - 1042
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R:\Projects\SPA\3SPA010100\Environmental Documentation\Settlement Agreement\EA\4.0_Alternatives-050923.docx 4-4 Alternatives to the Proposed Project significant effects of the project need be considered for inclusion in the EIR”. Section 15126.6(f)(3) of the State CEQA Guidelines further states “an EIR need not consider an alternative whose effect cannot be reasonably ascertained and whose implementation is remote and speculative”.

Because the Project encompasses the entirety of the City of South Pasadena, an alternative site where the City has no jurisdiction is not feasible. Therefore, further analysis of an alternative site in this EA is not required.

4.2.2 NO PROJECT/NO DEVELOPMENT
Section 15126.6(e) of the State CEQA Guidelines requires than an EIR evaluate a “no project” alternative to allow decision makers to compare the impacts of approving a proposed project with the impacts of not approving that project. Section 15126.6(e)(3) of the State CEQA Guidelines describes the two general types of no project alternative: (1) when the project is the revision of an existing land use or regulatory plan, policy or ongoing operation, the no project alternative would be the continuation of that plan and (2) when the project is not a land use/regulatory plan, such as a specific development on an identifiable property, the no project alternative is the circumstance under which that project is not processed (i.e., no development occurs). In addition, Section 15126.6(e)(2) of the State CEQA Guidelines specifies that the “No Project analysis shall discuss the existing conditions at the time the Notice of Preparation is published, as well as what would be reasonably expected to occur in the foreseeable future if the project were not approved, based on current plans and consistent with available infrastructure and community services”..

No project option 1 above is analyzed below as the No Project/Existing General Plan Alternative.

No project option 2, No Project/No Development Alternative, has been eliminated from detailed consideration because assuming no development would occur in the City of South Pasadena in the future is neither reasonable nor feasible. Therefore, further analysis of the No Project/No Development Alternative in this EA is not required.

4.3 ALTERNATIVES CARRIED FORWARD FOR DETAILED CONSIDERATION The analysis of each of the project alternatives identified below includes the following:
 A description of the alternative.
 An analysis of environmental impacts and a comparison to the possible impacts of the proposed project. Pursuant to the State CEQA Guidelines, if an alternative would cause one or more significant effects in addition to those that would be caused by the project as proposed, the significant effects of the alternative shall be discussed, but in less detail than the significant effects of the project as proposed.  An assessment of the alternative’s ability to meet the project objectives (previously identified in Section 4.1.2).

The comparison of impacts between each alternative and the proposed Project assumes that the general nature and types of (1) existing regulations; (2) proposed General Plan Update goals, policies, and actions; and (3) the Mitigation Measures (MMs) identified in Section 3.0, Environmental Analysis, of this EA would also be applicable to each of the alternatives, where appropriate.
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4.3.1 ALTERNATIVE 1: NO PROJECT/EXISTING GENERAL PLAN
Description of the Alternative
The proposed Project is the revision of an existing land use plan, accordingly, pursuant to Section 15126.6(e)(3)(A) and the State CEQA Guidelines, this No Project/Existing General Plan Alternative considers the comparative environmental impacts of the continued implementation of the existing General Plan, based on the existing conditions in and around January 2018 through the planning horizon of the Project (2040).

This alternative assumes the 1998 General Plan and 2014–2021 Housing Element would remain as the adopted long-range planning policy document for the City of South Pasadena, with future development occurring pursuant to the City’s current General Plan goals and policies and Land Use Map. The current Land Use Map is provided in Exhibit 2 in Section 2.0, Environmental Setting and Project Description, of this EA. It is noted that retention of the 2014–2021 Housing Element would violate State law as well as the Court Order; however, continuation of the existing (1998) General Plan is allowable. Further, as discussed above, the State CEQA Guidelines require a “no project” alternative be addressed. Therefore, this Alternative 1 has been given detailed consideration solely for purposes of comparing and contrasting the environmental impacts of the Project, as proposed, with the reduced development scale of Alternative 1. However, this is a purely hypothetical exercise and cannot be an actionable alternative.

Buildout under this alternative is estimated at 265 DUs in the City over the next approximately 20 years (through 2040), or approximately 13 percent of the Project’s residential units. This estimate is derived from the assumption that the average of 13.25 DUs permitted per year, over the past 8 years, would continue over the next 20 years. Buildout under this alternative also estimates approximately 66,124 sf of non-residential (commercial/office) development, or approximately 15 percent of the Project’s non-residential space. This estimate assumes that the floor area ratio (FAR) of 0.30 in the existing (1998) General Plan is applied to a total of 5.09 acres from select sites with development potential across a total of 12 parcels.

This development would generate approximately 657 residents2 (assuming no residential vacancy) and 304 jobs3. Compared to the proposed Project, this development capacity would result in 2,510 fewer DUs, 63,876 less sf of commercial/office, 6,225 fewer residents, and 1,674 fewer jobs. While this Alternative does not reflect the five focus areas of the Project, based on current and recent land use patterns, this Alternative assumes that the most of this development would occur along Fair Oaks Avenue, Mission Street, within the Ostrich Farm, and more sparsely along other major arterials. Because this alternative assumes continuation of the existing General Plan, including 2014-2021 Housing Element, and MSSP, the policies and actions of the Project documents and the DTSP’s form-based code are assumed not to be implemented under Alternative 1.

Comparative Analysis of Environmental Impacts
Aesthetics
Alternative 1 would result in a reduced level of visual change compared to the proposed Project, commensurate with the reduced geographic scope (i.e., extent of ground disturbance) and amount (i.e., number of DUs and total sf of non-residential) of potential development and 2 Based on a rate of 2.48 persons per household derived from the California Department of Finance demographic data for the City (2022).
3 Based on a rate of 1 employee per 200 sf with an 8 percent vacancy as per the Market Analysis (HR&A 2017). 3 - 1044
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R:\Projects\SPA\3SPA010100\Environmental Documentation\Settlement Agreement\EA\4.0_Alternatives-050923.docx 4-6 Alternatives to the Proposed Project redevelopment. Future development under this Alternative would result in similar types and proportions of land uses as currently exist; the same City height limits; and be subject to the same design standards and processes as the Project, with the exception of the form-based code in the DTSP Update. Any new light sources installed under Alternative 1 would be required to comply with the SPMC standards (Section 36.300.090) for exterior lighting. Accordingly, a lighting plan would be submitted to the City and requiring that lighting fixtures shall be appropriate in scale, intensity, and height to the use they are serving. Like the Project, Alternative 1 would not adversely affect a scenic vista, substantially degrade scenic resources within a scenic highway, substantially degrade the City’s visual quality and character, or result in a substantial increase in light and glare. Because Alternative 1 assumes only 265 DUs, the number of developments including structures exceeding the City’s 45-foot building height limit due to application of certain parts of the State Density Bonus Law would be lower than the Project. However, the City must adopt a 2021–2029 Housing Element or be in violation of State law as well as implement requirements of the Court Order, including is to seeking, through voter approval by December 31, 2024, the repeal of the City’s 45-foot height limit for residential or mixed-use residential projects on sites (i.e., not Citywide) where the base density calls for greater than 50 DUs per acre (DU/acre).

Air Quality
Alternative 1 would generate reduced criteria pollutant emissions from construction and operation commensurate with the reduced amount of potential development compared to the Project. As discussed in Section 3.2, Air Quality, construction-related emissions are speculative and cannot be accurately determined at this stage of the planning process. Similarly, consistent with SCAQMD guidance, an LST analysis can only be conducted at a project level, and quantification of LSTs is not applicable for this program-level analysis. Even with incorporation of MM AQ-1 requiring a project-level air quality analysis for future development projects, construction of development projects would have the potential to result in significant and unavoidable impacts with respect to construction activity. Although construction-related emissions would be reduced, for the same reasons as the proposed Project, Alternative 1 would result in significant and unavoidable direct and cumulative impacts during construction activity with implementation of MM AQ-1.

The Project would exceed the SCAQMD threshold for regional volatile organic compounds (VOC) emissions by over 60 percent. VOCs are an ozone (O3) precursor. The primary source of VOC emissions would be consumer products. MM AQ-1 requires that future projects would provide a project-specific air quality analysis that includes mitigation measures, as needed, to reduce the any significant impacts to the maximum extent feasible. While air quality emissions do not increase or decrease in a strictly linear fashion with increases or decreases in development capacity, based on the development capacity of Alternative 1 being, on average, about 14 percent of the Project (i.e., 13 percent of housing units and 15 percent on non-residential) it is possible Alternative 1 would not result in significant operational emissions of VOC. As discussed for the Project, because the effects of MM AQ-1 cannot be quantified at this time, operational emissions would be considered directly and cumulatively significant and unavoidable for Alternative 1.

Regarding 2022 Air Quality Management Plan (AQMP) consistency, buildout of Alternative 1 would be below the 2020–2045 Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS) population forecast for 2040 by 767 persons and would exceed the employment forecast by 2,020 jobs. As discussed further in Section 3.12, Population and Housing, projections of employment in the City are substantively underestimated by SCAG in the 2020–2045 RTP/SCS and this analysis does not directly compare the SCAG projection for employment and the City’s anticipated future employment to reach a significance finding related to demographic growth.

However, the AQMP requires the comparison to the correlating RTP/SCS. Therefore, based on 3 - 1045
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Environmental Assessment
R:\Projects\SPA\3SPA010100\Environmental Documentation\Settlement Agreement\EA\4.0_Alternatives-050923.docx 4-7 Alternatives to the Proposed Project the SCAQMD criteria, this alternative would result in significant and unavoidable direct and cumulative impacts related to inconsistency with the 2022 AQMP, same as the Project.

Although overall emissions would be reduced under this alternative, the focus of growth would remain the focus areas, in particular the DTSP and Ostrich Farm areas. As such, because the northernmost segment of the DTSP area is within 500 feet of SR-110, this area presents a risk of exposure to diesel particulate matter (DPM, a toxic air contaminant [TAC]). Like the proposed Project, Alternative 1 would result in a less than significant impacts related to exposure to TACs with MM AQ-2, which requires preparation of a Health Risk Assessment (HRA) for development projects that would include sensitive land uses within the area proximate to SR-110.

Biological Resources
Alternative 1 would result in reduced impacts to biological resources compared to the proposed Project, commensurate with the reduced geographic scope of potential development and redevelopment. Like the proposed Project, Alternative 1’s potential impacts to biological resources would be reduced to a less than significant level with implementation of MMs BIO-1 through BIO-5.

Cultural and Tribal Cultural Resources
Alternative 1 is anticipated to result in reduced impacts to cultural and tribal cultural resources compared to the proposed Project, commensurate with the reduced geographic scope of potential development and redevelopment. As such, Alternative 1 is expected to involve demolition or substantial alteration of fewer built environment resources compared to the proposed Project.

Similarly, Alternative 1 would also involve less disturbance of ground on undeveloped land and less ground disturbance on developed land to greater depth or extent than past ground disturbance that could contain unknown buried historical or archaeological resources or human remains. However, development under this Alternative would be subject to the same policies and procedures related to historic preservation in the City and regulatory requirements related to encounter of remains. Like the proposed Project, Alternative 1’s potential impacts to cultural and tribal cultural resources would be reduced to a less than significant level with implementation of MM CUL-1.

Energy
Alternative 1 would result in less construction-related energy use and long-term stationary (i.e., not transportation/mobile) energy demand than the proposed Project, commensurate with the reduced geographic scope and amount of potential development and redevelopment. However, when taking into consideration that Alternative 1 would result in a less dense and less mixed land use pattern than the proposed Project, both fuel efficiency and total VMT (i.e., energy demand from operation) would be higher under this alternative. On balance, it is anticipated that Alternative 1 would result is less than significant impacts related to the wasteful, inefficient, or unnecessary consumption of energy, or conflicts with plans for renewable energy or energy efficiency, like the Project.

Geology and Soils
Geologic and soils conditions, particularly seismic shaking and secondary seismic risks are essentially the same throughout most of the City. The hilly areas in the northeast and southwest may experience additional or slightly different conditions related to slope and/or underlying geologic units. Like the proposed Project, the design and construction of structures for human 3 - 1046
City of South Pasadena
2021–2029 Housing Element
Environmental Assessment
R:\Projects\SPA\3SPA010100\Environmental Documentation\Settlement Agreement\EA\4.0_Alternatives-050923.docx 4-8 Alternatives to the Proposed Project occupancy under Alternative 1 would require preparation of a geotechnical report and be subject to the same State, County, and City codes and requirements.

Alternative 1 would involve less construction that could generate pollutants contaminating storm water runoff than the proposed Project. However, all construction projects under Alternative 1 would be subject to the same State or City stormwater quality requirements as the proposed Project.

Alternative 1 would involve less ground disturbance that could impact unknown paleontological resources than the proposed Project. Like the proposed Project, impacts to paleontological resources would be less than significant after implementation of MM CUL-1.

Greenhouse Gas Emissions
Alternative 1 would generate reduced total greenhouse gas (GHG) emissions from construction and operation of the reduced development capacity compared to the Project. However, as discussed below for Land Use and Planning, this alternative would result in higher vehicle miles traveled (VMT) for the City as a whole compared to the proposed Project. A higher VMT reflects greater relative contribution of the City per capita and per service population to GHG emissions.

Therefore, while this Alternative would reduce development capacity to an average of 14 percent of the Project, at the program level, GHG emissions would potentially result in a significant impact on the environment. MM GHG-1 requires project-level GHG analysis and appropriate mitigation actions shall be implemented. Because the effects of MM GHG-1 cannot be quantified at this time, impacts would remain significant and unavoidable under Alternative 1, same as the Project.

Hazards and Hazardous Materials
Alternative 1 would result in reduced impacts related to hazards and hazardous materials as the proposed Project, because it involves less disturbance of soil that could be contaminated; and would involve less construction effort and thus less use of hazardous materials by construction projects. While the proposed Project would permit development of more residential units than Alternative 1 would, operation of residences generally involves use of only small amounts of hazardous materials for cleaning and maintenance purposes, and operational hazardous materials impacts would be generally similar for Alternative 1 compared to the proposed Project.

Hazardous materials would be used in accordance with existing regulations. Fewer residents and construction workers would be potentially exposed to hazardous materials under Alternative 1 than under the proposed Project. Like the proposed Project, potential impacts related to hazards and hazardous materials would be less than significant with implementation of MMs HAZ-1 and HAZ-2.

Hydrology and Water Quality
Alternative 1 would involve less construction that could generate pollutants contaminating storm water runoff than the proposed Project. Construction projects in each scenario would comply with 3 - 1047
City of South Pasadena
2021–2029 Housing Element
Environmental Assessment
R:\Projects\SPA\3SPA010100\Environmental Documentation\Settlement Agreement\EA\4.0_Alternatives-050923.docx 4-9 Alternatives to the Proposed Project State or City stormwater quality requirements, as applicable. Operational impacts to operational water quality standards and waste discharge requirements would be reduced, due to lower development intensity, compared to the proposed Project. However, like the proposed Project, there would be less than significant impacts related to hydrology and water quality, including drainage patterns, through compliance with State and local regulations.

Developable vacant land in the City comprises less than one percent of the City’s land area; thus, Alternative 1 and the proposed Project would each cause only minor increases in impermeable surfaces in the City. Alternative 1 would generate a lower increase in water demands compared to the proposed Project, commensurate with the reduced amount of potential development and redevelopment. The Main San Gabriel Groundwater Basin (basin), from which the City provides most of its water supply, is controlled by the Main San Gabriel Basin Watermaster. Regardless of the amount of potable water demand by the City, the Watermaster is responsible for monitoring groundwater levels and water quality, including the operating safe yields of the basin and extraction limits and amounts. Therefore, impacts on groundwater recharge and supply from Alternative 1 would be similar to those of the proposed Project.

Land Use and Planning
Alternative 1 would result in a new significant and unavoidable impact related to land use and planning because this alternative would not demonstrate to the State that the City can meet its mandated RHNA allocation. As such, this alternative would conflict with State planning law.

Alternative 1 would be less consistent with SCAG’s 2020-2045 RTP/SCS, as the reduced amount of development and redevelopment would reflect a land use pattern that contribute less towards the GHG emissions reduction targets compared to the proposed Project. This alternative would provide less residential, commercial/office, and mixed-use development near transit and other existing infrastructure (e.g., roads, utilities, services) and generally build at a lower density in selected portions of the City. Therefore, Alternative 1 would result in a higher VMT per capita and per service population for the City as a whole compared to the proposed Project. A higher VMT reflects greater relative contribution of the City to GHG emissions. Like the proposed Project, Alternative 1 would conserve established residential neighborhoods, would not substantially change the development pattern of the City, and would not divide established communities.

Noise
Alternative 1 would result in reduced noise impacts from construction and operation of the reduced development capacity compared to the Project. Buildout under Alternative 1 would result in reduced vehicle trips. Alternative 1 would involve an 90 percent reduction in residential development and an 85 percent reduction in non-residential development. However, as shown in Table 3.11-9 in Section 3.11, Noise, of this EA, the contribution of the proposed Project’s traffic noise would be less than three dBA, which is considered barely perceptible to human hearing.

Therefore, the future exterior noise levels at residential uses after implementation of MM NOI-1 may remain above 65 dBA CNEL at some locations because this is a result of existing conditions and not buildout of the Project. Therefore, this impact would be reduced but remain significant and unavoidable. Interior noise levels and stationary source noise levels for future development projects, residential and non-residential, would remain less than significant with implementation of MMs NOI-2 and NOI-3, respectively.

With reduced development capacity, there would likely be reduced construction activity over the planning horizon. As such, the significant and unavoidable construction noise impact at receiver locations within 200 feet, after implementation of MMs NOI-4 through NOI-7, would affect fewer 3 - 1048
City of South Pasadena
2021–2029 Housing Element
Environmental Assessment
R:\Projects\SPA\3SPA010100\Environmental Documentation\Settlement Agreement\EA\4.0_Alternatives-050923.docx 4-10 Alternatives to the Proposed Project existing receptors. Like the proposed Project, vibration generated during construction would be less than significant with implementation of MMs NOI-4 and NOI-5; and within 50 feet of the Metro L Rail Line with implementation of MM NOI-6.

Alternative 1 would not subject people in South Pasadena to excessive airport-related noise; the nearest airport to the City is the San Gabriel Valley Airport approximately six miles away.

Population and Housing
As discussed above, Alternative 1 assumes development of up to 265 DUs and 66,124 sf of nonresidential (commercial/office) development in the City over the next 20 years (through 2040).

Table 4-1, Comparison of SCAG Projections and Alternative 1 Buildout, provides a comparison of the 2040 SCAG growth projections and the Alternative 1 buildout projections.

TABLE 4-1
COMPARISON OF SCAG PROJECTIONS AND ALTERNATIVE 1 BUILDOUT Existing
Conditions
Alternative 1 Buildout
(2040)
SCAG
Projections
(2040) Difference
Households 10,623a 10,873 (250 DUs)a 11,109c -236 DUs / -2.1% Housing Units 11,156a 11,421 (265 DUs) 11,822a N/A
Population 25,580a 26,200 (620 persons)a 27,004c -804 persons / -3.0% Employment 13,700b 14,004 (304 jobs) 11,984c +2020 jobs / 16.9% Jobs-Housing Ratio 1.23 1.23 1.01 N/A
DU: dwelling units; N/A not applicable
Note: Housing units estimated based on number of households and a vacancy rate of 5.5 percent for South Pasadena.

Population based on 2.48 persons per household for the number of housing units at this vacancy rate.

Sources:
a DOF 2022 b EDD 2022 c SCAG 2020, Aguilar 2021
As shown in Table 4-1, buildout of Alternative 1 would result in approximately 236 fewer households (2.1 percent) and 804 fewer residents (3.0 percent) (assuming a 5.5 percent vacancy rate) than SCAG’s 2040 projections. This would not represent substantial unplanned population growth. Regarding employment, Alternative 1 would result in approximately 2,020 more employees than the SCAG’s projections. As discussed for the Project, projections of employment in the City are substantively underestimated by SCAG and this analysis does not directly compare the SCAG projection for employment and the City’s anticipated future employment to reach a significance finding. For comparison, Alternative 1’s projected employment of 14,004 represents an increase of about 2.2 percent or 0.1 percent per year from EDD’s 2022 estimate of 13,700 jobs in the City.

As shown, Alternative 1 would result in the same jobs-housing ratio as the existing conditions in the City and would be more jobs-rich than projected by SCAG. Again, this is due to the disparity between SCAG’s and EDD’s data. Regardless, an area with a ratio between 1.0 and 1.29 is considered to be “balanced” (SCAG 2001).

Therefore, Alternative 1 would avoid the significant and unavoidable impact related to demographic growth resulting from the inconsistency between SCAG’s growth projections prepared as part of the 2020-2045 RTP/SCS and SCAG’s 6th Cycle RHNA allocation. However, 3 - 1049
City of South Pasadena
2021–2029 Housing Element
Environmental Assessment
R:\Projects\SPA\3SPA010100\Environmental Documentation\Settlement Agreement\EA\4.0_Alternatives-050923.docx 4-11 Alternatives to the Proposed Project the Alternative 1 land use plan is less consistent than the Project with SCAG policies to encourage higher-density and mixed-use development, particularly near transit centers and arterial roadways such as the Mission L Line Station and the Metro bus lines along Fair Oaks Avenue and Huntington Drive.

Like the proposed Project, Alternative 1 could cause some displacement of existing residential units and residents. Projects displacing residents would be mandated to comply with City requirements for tenant notification and relocation assistance programs. Conversion of residences due to projects undertaken by a public entity would be required to comply with the California Relocation Assistance Act. Any residential displacement under Alternative 1 would not require construction of replacement housing, as Alternative 1 would permit construction of up to 265 residential units. Like the Project, there would be no impacts related to displacement of housing or people that necessitates construction of housing elsewhere.

Public Services and Recreation
Alternative 1 would result in reduced demand for fire protection, police protection, school services, library services, and recreation facilities than the proposed Project, commensurate with the reduced amount of potential development and redevelopment. Therefore, like the proposed Project, Alternative 1’s potential impacts to public services would be less than significant level.

Transportation
Alternative 1 would result in reduced total VMT compared to the proposed Project, commensurate with the reduced amount of development or redevelopment and resultant density. However, this alternative would result in relatively higher VMT per capita and VMT per service population compared to the Project, which is the metric used to determine the significance of transportation impacts. Increasing density of land uses, especially when near transit and/or mixed with employment and services, reduces VMT. The proposed Project’s land use plan provides a mix and density of land uses that contributes to reducing vehicle trips through improved alternative transportation options and proximity of housing to employment and services than in the existing condition. Also, unlike the Project, this alternative would not include the extensive transportationrelated policies and actions that support reducing VMT, separate from the land use plan.

However, without extensive modeling, it is unknown the actual VMT per capita or VMT service population that would result. Like the proposed Project, Alternative 1 would not cause substantial hazards due to a geometric design feature or incompatible roadway uses, and future projects developed under Alternative 1 must comply with City requirements to ensure adequate emergency access.

Utilities and Service Systems
Alternative 1 would generate reduced demands for utilities and service services, including water supply, water and wastewater infrastructure, wastewater treatment, dry utilities (i.e., electricity, natural gas, telecommunications), and solid waste generation, commensurate with the reduced amount of development or redevelopment. However, through compliance with applicable regulations and proposed policies and actions, the Project would result in less than significant impacts related to these utilities and service systems. Therefore, with reduced demands, Alternative 1 would also result in less than significant impacts to water supply, water and wastewater infrastructure, wastewater treatment, solid waste, and dry utilities. 3 - 1050
City of South Pasadena
2021–2029 Housing Element
Environmental Assessment
R:\Projects\SPA\3SPA010100\Environmental Documentation\Settlement Agreement\EA\4.0_Alternatives-050923.docx 4-12 Alternatives to the Proposed Project Wildfire
Like the proposed Project, it is possible that parcels in the City’s High Risk Fire Area could be developed or redeveloped under Alternative 1, although the likelihood and extent of this activity would be lower. Also like the proposed Project, implementation of development under Alternative 1 would be required to comply with State and local codes and other regulations related to emergency access and building in wildfire hazard areas and on hillsides. Accordingly, Alternative 1 would not substantially impact emergency response or evaluation, exacerbate wildfire risks, including due to installation or maintenance of infrastructure, and expose persons to pollutant concentrations from wildfire; or expose people or structures to significant risks subsequent to wildfire such as flooding or landslides. Wildfire impacts of Alternative 1 would be less than significant.

Ability to Meet Project Objectives
Alternative 1 would not meet objective 1 to provide sufficient and inclusive housing capacity to meet State mandates. This alternative would be in violation of State law and would open the City to penalties.

Alternative 1 would meet five of the six Project objectives, as the objectives are more closely aligned with providing a high-quality environment rather than a certain amount of development.

Specifically, objectives 2, 4, 5, and 6 can be attained through policy implementation by the City unrelated to the location or extent of development. Similarly, objective 3 would be met because Alternative 1 would still direct growth primarily towards the downtown and Ostrich Farm areas, which is also a policy decision.

Conclusion
Alternative 1 would avoid the significant and unavoidable impact related to visual character.

However, the City must adopt a 2021–2029 Housing Element or be in violation of State law as well as implement requirements of the Court Order, including placement of a ballot measure proposing the repeal of the City’s 45-foot height limit for sites that meet specific characteristics.

Alternative 1 would reduce criteria pollutant emissions and GHG emissions; however, the reduction would not eliminate the significant and unavoidable impacts associated with AQMP consistency, VOC emissions, GHG emissions, or GHG plan inconsistency because the effects of MMs AQ-1 and GHG-1, requiring project-level analysis and mitigation measures, cannot be quantified at this time. Exterior traffic noise levels would be reduced but a significant and unavoidable impact would remain, because this is a result of existing conditions and not buildout of the Project. This Alternative would expose fewer receptors to construction noise that may exceed the standard, but the potential impact on exposed receptors would remain significant and unavoidable. Alternative 1 would result in a new significant and unavoidable impact related to land use and planning as the number of dwelling units would be far below the 6th Cycle RHNA allocation for the City, which would violate State law, opening the City to penalties; and the Court Order to which the City is now subject, opening the City to Court-ordered sanctions.

For all other topics, impacts would be similar or reduced compared to the proposed Project.

Although a lower level of development capacity may be preferable to some, this increment of reduction would not alleviate the total significant and unavoidable impacts of the Project, by eliminating one impact (population and housing) and adding one (land use and planning). From an environmental standpoint, perhaps most importantly, this alternative would not be as 3 - 1051
City of South Pasadena
2021–2029 Housing Element
Environmental Assessment
R:\Projects\SPA\3SPA010100\Environmental Documentation\Settlement Agreement\EA\4.0_Alternatives-050923.docx 4-13 Alternatives to the Proposed Project consistent with regional (SCAG) planning programs and policies related to reducing GHG emissions consistent with SB 375.

4.3.2 ALTERNATIVE 2: REDUCED DEVELOPMENT CAPACITY
Description of the Alternative
During preparation of the EA for the General Plan and DTSP Update, the City chose to combine the proposed housing element update into the proposed Project. The proposed 2021–2029 Housing Element Update incorporates the 6th Cycle RHNA issued by the SCAG, which requires the City to provide 2,067 DUs plus the HCD-required surplus of 708 DUs between 2021 and 2029.

The City chose to retain the environmental analysis in the Administrative Draft EA that has already been prepared for the former project without the Housing Element in condensed form as an alternative to the Project.

Therefore, Alternative 2 assumes a net increase in development capacity of 589 DUs (or approximately 28 percent of the Project’s residential units) and 430,000 sf of non-residential (commercial/office) building area, same as the Project. As shown below in Table 4-2, Alternative 2 Development Capacity (2040), the total 500 DUs previously proposed and all of the net increase of 430,000 sf of non-residential uses would be permitted in the five focus areas, and 89 DUs in lots outside the focus areas, through the Project horizon year of 2040. Additionally, Alternative 2 assumes that proposed policies and goals and the DTSP’s form-based code would be implemented.

TABLE 4-2
ALTERNATIVE 2 DEVELOPMENT CAPACITY (2040)
Proposed Development Capacity
Size
(acres)
Residential
(DUs)
Non-Residential (sf)
Commercial Office Population
Corridorsa
Downtown Specific Plan Area 80.0 300 100,000 125,000 738 Districtsa
Ostrich Farm 13.4 75 5,000 100,000 185
Neighborhood Centersa
Huntington Drive & Garfield Avenue 4.5 75 10,000 50,000 185 Huntington Drive & Fletcher Avenue 1.6 0 5,000 0 0
Huntington Drive & Fremont Avenue 7.4 50 10,000 25,000 123 Remainder of Cityb
Vacant Lots Outside Focus Areas N/A 89 0 0 219
Totals ̶ 589 130,000 300,000 1,449
du: dwelling units; sf: square feet; N/A: not available Sources:
a South Pasadena 2017a b Inloes 2018 c HR&A 2017
3 - 1052
City of South Pasadena
2021–2029 Housing Element
Environmental Assessment
R:\Projects\SPA\3SPA010100\Environmental Documentation\Settlement Agreement\EA\4.0_Alternatives-050923.docx 4-14 Alternatives to the Proposed Project Comparative Analysis of Environmental Impacts
Aesthetics
Alternative 2 would result in a reduced level of visual change compared to the proposed Project, commensurate with the reduced geographic scope (i.e., extent of ground disturbance) and amount of potential development and redevelopment. Future development under this Alternative would result in similar types and proportions of land uses as currently exist; the same height limits (including possible increased heights via the State Density Bonus Law and Court Order to which the City is now subject); and be subject to the same design standards and processes as the Project, including the form-based code in the DTSP Update. Any new light sources installed under Alternative 2 would be required to comply with the SPMC standards (Section 36.300.090) for exterior lighting. Accordingly, a lighting plan would be submitted to the City requiring lighting fixtures shall be appropriate in scale, intensity, and height to the use they are serving. Like the Project, Alternative 2 would not adversely affect a scenic vista, substantially degrade scenic resources within a scenic highway, substantially degrade the City’s visual quality and character, or result in a substantial increase in light and glare.

Air Quality
Criteria pollutant emissions were quantified for the development of 589 DUs and 430,000 sf of non-residential growth as part of EA preparation prior to the inclusion of the 2021–2029 Housing Element. However, in June 2021, the latest version of the California Emissions Estimator Model™ (CalEEMod), which is used to model air quality and GHG emissions, was released. This EA uses the current CalEEMod version for analysis of the proposed Project. While modeling results are generally similar between versions, they do not represent an apples-to-applies comparison.

For purposes of comparison, the air quality modeling for the growth under Alternative 2 concluded there would be a significant and unavoidable impact related to operational nitrous oxides (NOx), whose primary source is combustion engines. Emissions of VOCs were below the SCAQMD significance threshold. Like the proposed Project, mitigation was required to perform a projectspecific analysis. Similar to the Project, it was concluded that because the effects of MM AQ-1 cannot be quantified at this time, operational emissions would be considered directly and cumulatively significant and unavoidable for Alternative 2.

All other aspects of the air quality analysis performed for the growth under Alternative 2 were the same as the Project. Alternative 2 would generate reduced criteria pollutant emissions from construction. As discussed in Section 3.2, Air Quality, construction-related emissions are speculative and cannot be accurately determined at this stage of the planning process. Similarly, consistent with SCAQMD guidance, an LST analysis can only be conducted at a project level, and quantification of LSTs is not applicable for this program-level analysis. Even with incorporation of MM AQ-1 requiring a project-level air quality analysis for future development projects, construction of development projects would have the potential to result in significant and unavoidable impacts with respect to construction activity. Although construction-related emissions would be reduced, Alternative 2 would result in significant and unavoidable direct and cumulative impacts during construction activity with implementation of MM AQ-1.

Regarding 2022 AQMP consistency, buildout of Alternative 2 would exceed the 2020–2045 RTP/SCS population forecast for 2040 by 25 persons and would exceed the employment forecast by 3,394 jobs. As discussed further in Section 3.12, Population and Housing, projections of employment in the City are substantively underestimated by SCAG and this analysis does not directly compare the SCAG projection for employment and the City’s anticipated future 3 - 1053
City of South Pasadena
2021–2029 Housing Element
Environmental Assessment
R:\Projects\SPA\3SPA010100\Environmental Documentation\Settlement Agreement\EA\4.0_Alternatives-050923.docx 4-15 Alternatives to the Proposed Project employment to reach a significance finding related to demographic growth. However, the AQMP requires the comparison to the correlating RTP/SCS. Therefore, based on the SCAQMD criteria, this alternative would result in significant and unavoidable direct and cumulative impacts related to inconsistency with the 2022 AQMP, same as the Project.

Although overall emissions would be reduced under this alternative, because there are properties within 500 feet of SR-110 that may be developed/redeveloped, this area presents a risk of exposure to diesel particulate matter (DPM, a toxic air contaminant [TAC]). Like the proposed Project, Alternative 2 would result in a less than significant impacts related to exposure to TACs with MM AQ-2, which requires preparation of a Health Risk Assessment (HRA) for development projects that would include sensitive land uses within the area proximate to SR-110.

Biological Resources
Alternative 2 would result in reduced impacts to biological resources compared to the proposed Project, commensurate with the reduced geographic scope of potential residential development and redevelopment. Like the proposed Project, Alternative 2’s potential impacts to biological resources would be reduced to a less than significant level with implementation of MMs BIO-1 through BIO-5.

Cultural and Tribal Cultural Resources
Alternative 2 is anticipated to result in reduced impacts to cultural and tribal cultural resources compared to the proposed Project, commensurate with the reduced geographic scope of potential residential development and redevelopment. As such, Alternative 2 is expected to involve demolition or substantial alteration of fewer built environment resources compared to the proposed Project. Similarly, Alternative 2 would also involve less disturbance of ground on undeveloped land and less ground disturbance on developed land to greater depth or extent than past ground disturbance that could contain unknown buried historical or archaeological resources or human remains. However, development under this Alternative would be subject to the same policies and procedures related to historic preservation in the City and regulatory requirements related to encounter of remains. Like the proposed Project, Alternative 2’s potential impacts to cultural and tribal cultural resources would be reduced to a less than significant level with implementation of MM CUL-1.

Energy
Alternative 2 would result in less construction-related energy use and long-term stationary (i.e., not transportation/mobile) energy demand than the proposed Project, commensurate with the reduced geographic scope and amount of potential development and redevelopment. However, when taking into consideration that Alternative would result in a slightly less dense and less mixed land use pattern than the proposed Project, both fuel efficiency and total VMT (i.e., energy demand from operation) would be higher under this Alternative. On balance, it is anticipated that Alternative 2 would result is less than significant impacts related to the wasteful, inefficient, or unnecessary consumption of energy, or conflicts with plans for renewable energy or energy efficiency, like the Project.

Geology and Soils
Geologic and soils conditions, particularly seismic shaking and secondary seismic risks are essentially the same throughout most of the City. The hilly areas in the northeast and southwest may experience additional or slightly different conditions related to slope and/or underlying 3 - 1054
City of South Pasadena
2021–2029 Housing Element
Environmental Assessment
R:\Projects\SPA\3SPA010100\Environmental Documentation\Settlement Agreement\EA\4.0_Alternatives-050923.docx 4-16 Alternatives to the Proposed Project geologic units. Like the proposed Project, the design and construction of structures for human occupancy under Alternative 2 would require preparation of a geotechnical report and be subject to the same State, County, and City codes and requirements.

Alternative 2 would involve less construction that could generate pollutants contaminating storm water runoff than the proposed Project. However, all construction projects in Alternative 2 would be subject to the same State or City stormwater quality requirements as the proposed Project.

Alternative 2 would involve less ground disturbance that could impact unknown paleontological resources than the proposed Project. Like the proposed Project, impacts to paleontological resources would be less than significant after implementation of MM CUL-1.

Greenhouse Gas Emissions
As discussed for the air quality analysis of Alternative 2 above, GHG emissions were quantified for the development of 589 DUs and 430,000 sf of non-residential growth as part of EA preparation prior to the inclusion of the 2021–2029 Housing Element. However, in June 2021, the latest version of CalEEMod was released. This EA uses the current CalEEMod version for analysis of the proposed Project. While modeling results are generally similar between versions, they do not represent an apples-to-apples comparison.

For purposes of comparison, the GHG emission modeling for the growth under Alternative 2 concluded there would be an exceedance of the SCAQMD threshold of annual GHG emissions per service population. MM GHG-1 developed of part of the Administrative Draft for the formerly defined project required adoption of a Climate Action Plan (CAP) within 24 months of the General Plan and DTSP Update’s adoption. The required CAP would have ensured that GHG emissions from buildout of the proposed Project were minimized. However, it was also concluded that the CAP may not feasibly obtain the AB 32 targets and that additional Statewide measures would be necessary to reduce GHG emissions to meet legislative goals. Because additional Statewide measures were not currently available, some of which would involve unforeseen advances in technology, GHG impacts were considered significant and unavoidable for development of 589 DUs and 430,000 sf of growth through 2040.

Alternative 2 would generate reduced greenhouse gas (GHG) emissions from construction and operation of the reduced development capacity compared to the Project. However, as discussed below for Land Use and Planning, this alternative would result in higher vehicle miles traveled (VMT) for the City as a whole compared to the proposed Project. A higher VMT reflects greater relative contribution of the City per capita and per service population to GHG emissions. Like the proposed Project, MM GHG-1 in this Draft EA requires project-level GHG analysis, and appropriate mitigation actions shall be implemented. Because the effects of MM GHG-1 cannot be quantified at this time, impacts would remain significant and unavoidable under Alternative 2, same as the Project.

As discussed further in Section 3.7, Greenhouse Gas Emissions, the City adopted its first CAP on December 16, 2020. The proposed Project was demonstrated to be consistent with the City’s CAP, and the CAP is, in turn, consistent with State plans, policies, and regulations, AB 32, the AB 32 scoping plan and updates, EO B-30-15, SB32, and EO B-55-18, and there would be a less than significant impact. The actions in the CAP would apply City-wide regardless of the amount of development. Therefore, Alternative 2 would also be consistent with the CAP and there would be a less than significant impact, same as the proposed Project. 3 - 1055
City of South Pasadena
2021–2029 Housing Element
Environmental Assessment
R:\Projects\SPA\3SPA010100\Environmental Documentation\Settlement Agreement\EA\4.0_Alternatives-050923.docx 4-17 Alternatives to the Proposed Project Hazards and Hazardous Materials
Alternative 2 would result in reduced impacts related to hazards and hazardous materials as the proposed Project, because it involves less disturbance of soil that could be contaminated; and would involve less construction effort and thus less use of hazardous materials by construction projects. While the proposed Project would permit development of more residential units than Alternative 2 would, operation of residences generally involves use of only small amounts of hazardous materials for cleaning and maintenance purposes, and operational hazardous materials impacts would be generally similar for Alternative 2 compared to the proposed Project.

Hazardous materials would be used in accordance with existing regulations. Fewer residents and construction workers would be potentially exposed to hazardous materials under Alternative 2 than under the proposed Project. Like the proposed Project, potential impacts related to hazards and hazardous materials would be less than significant with implementation of MMs HAZ-1 and HAZ-2.

Hydrology and Water Quality
Alternative 2 would involve less construction that could generate pollutants contaminating storm water runoff than the proposed Project. Construction projects in each scenario would comply with State or City stormwater quality requirements, as applicable. Operational impacts to operational water quality standards and waste discharge requirements would be reduced, due to lower development intensity, compared to the proposed Project. However, like the proposed Project, there would be less than significant impacts related to hydrology and water quality, including drainage patterns, through compliance with State and local regulations.

Developable vacant land in the City comprises less than one percent of the City’s land area; thus, Alternative 2 and the proposed Project would each cause only minor increases in impermeable surfaces in the City. Alternative 2 would generate a lower increase in water demands compared to the proposed Project, commensurate with the reduced amount of potential residential development and redevelopment. The Main San Gabriel Groundwater Basin (basin), from which the City provides most of its water supply, is controlled by the Main San Gabriel Basin Watermaster. Regardless of the amount of potable water demand by the City, the Watermaster is responsible for monitoring groundwater levels and water quality, including the operating safe yields of the basin and extraction limits and amounts. Therefore, impacts on groundwater recharge and supply from Alternative 2 would be similar to those of the proposed Project.

Land Use and Planning
Alternative 2 would result in a new significant and unavoidable impact related to land use and planning because this alternative would not demonstrate to the State that the City can meet its mandated RHNA allocation. As such, this alternative would conflict with State planning law.

Alternative 2 would be less consistent with SCAG’s 2020-2045 RTP/SCS, as the reduced amount of residential development and redevelopment would reflect a land use pattern that contributes less towards the GHG emissions reduction targets compared to the proposed Project. This alternative would provide less residential and mixed-use development near transit and other existing infrastructure (e.g., roads, utilities, services) and generally build at a lower density in selected portions of the City. Therefore, Alternative 2 would result in a higher VMT per capita and VMT per service population for the City as a whole compared to the proposed Project. A higher VMT reflects greater relative contribution of the City to GHG emissions. Like the proposed Project, Alternative 2 would conserve established residential neighborhoods, would not substantially change the development pattern of the City, and would not divide established communities. 3 - 1056
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R:\Projects\SPA\3SPA010100\Environmental Documentation\Settlement Agreement\EA\4.0_Alternatives-050923.docx 4-18 Alternatives to the Proposed Project Noise
Alternative 2 would result in reduced noise impacts from construction and operation of the reduced development capacity compared to the Project. Buildout under Alternative 2 would result in reduced vehicle trips. Alternative 1 would involve a 72 percent reduction in residential development and no reduction in non-residential development. However, as shown in Table 3.11-9 in Section 3.11, Noise, of this EA, the contribution of the proposed Project’s traffic noise would less than three dBA, which is considered barely perceptible to human hearing.

Therefore, the future exterior noise levels at residential uses after implementation of MM NOI-1 may remain above 65 dBA CNEL at some locations because this is a result of existing conditions.

Therefore, this impact would be reduced but remain significant and unavoidable. Interior noise levels and stationary source noise levels for future development projects, residential and nonresidential, would remain less than significant with implementation of MMs NOI-2 and NOI-3, respectively.

With reduced development capacity, there would likely be reduced construction activity over the planning horizon. As such, the significant and unavoidable construction noise impact at receiver locations within 200 feet, after implementation of MMs NOI-4 through NOI-7, would affect fewer existing receptors. Like the proposed Project, vibration generated during construction would be less than significant with implementation of MMs NOI-4 and NOI-5; and within 50 feet of the Metro L Rail Line with implementation of MM NOI-6. Alternative 2 would not subject people in South Pasadena to excessive airport-related noise; the nearest airport to the City is the San Gabriel Valley Airport approximately six miles away.

Population and Housing
As discussed above, Alternative 2 assumes development of up to 589 DUs and 430,000 sf of non-residential development and in the City through 2040. Table 4-3, Comparison of SCAG Projections and Alternative 2 Buildout, provides a comparison of the 2040 SCAG growth projections and the Alternative 2 buildout projections.

TABLE 4-3
COMPARISON OF SCAG PROJECTIONS AND ALTERNATIVE 1 BUILDOUT Existing
Conditions
Alternative 2 Buildout
(2040)
SCAG
Projections
(2040) Difference
Households 10,623a 11,180 (557 DUs)a 11,109c -71 DUs / -0.6% Housing Units 11,156a 11,745 (589 DUs) 11,822a N/A
Population 25,580a 26,961 (1,381 persons)a 27,004c -43 persons / -0.1% Employment 13,700b 15,678 (1,978 jobs) 11,984c + 3,694 jobs / +30.8% Jobs-Housing Ratio 1.23 1.33 1.01 N/A
DU: dwelling units; N/A not applicable
Note: Housing units estimated based on number of households and a vacancy rate of 5.5 percent for South Pasadena.

Population based on 2.48 persons per household for the number of housing units at this vacancy rate.

Sources:
a DOF 2022 b EDD 2022 c SCAG 2020, Aguilar 2021
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R:\Projects\SPA\3SPA010100\Environmental Documentation\Settlement Agreement\EA\4.0_Alternatives-050923.docx 4-19 Alternatives to the Proposed Project As shown in Table 4-3, buildout of Alternative 2 would result in essentially the same number of households and population growth as the SCAG projections. This would not represent substantial unplanned population growth. This is because, as discussed in Section 3.12, Population and Housing, of this EA, SCAG’s projections in the RTP/SCS are based in part on coordination between the City and SCAG during preparation of the RTP/SCS and reflects the anticipated growth in the City prior to release of the unexpectedly high 6th Cycle RHNA. At that time, the City would have provided to SCAG demographic projections based on the proposed 589 DUs and 430,000 sf of non-residential formerly envisioned for the City.

Regarding employment, Alternative 2 would result in the same number of jobs as the Project. As discussed in Section 3.12, the projected employment of 15,678 jobs represents an increase of 1,978 jobs (or about a 14.4 percent increase or 0.72 percent per year) from EDD’s 2022 estimate of 13,700 jobs. As shown, however, Alternative 2 would result in a higher jobs-housing ratio than both the existing conditions in the City (based on EDD data) and would be more jobs-rich than projected by SCAG. Again, this is due to the disparity between SCAG’s and EDD’s data. An area with a ratio between 1.0 and 1.29 is considered to be “balanced” (SCAG 2001). As such, development of Alternative 2 would lead to a potential jobs-housing ratio that is unbalanced through provision of relatively more employment than housing.

Therefore, Alternative 2 would avoid the significant and unavoidable impact related to demographic growth resulting from the inconsistency between SCAG’s growth projections prepared as part of the 2020-2045 RTP/SCS and SCAG’s 6th Cycle RHNA allocation. However, the Alternative 2 land use plan is less consistent than the Project with SCAG policies to encourage higher-density and mixed-use development, particularly near transit centers such as the Mission L Line Station and the Metro bus lines along Fair Oaks Avenue and Huntington Drive.

Like the proposed Project, Alternative 2 could cause some displacement of existing residential units and residents. Projects displacing residents would be mandated to comply with City requirements for tenant notification and relocation assistance programs. Conversion of residences due to projects undertaken by a public entity would be required to comply with the California Relocation Assistance Act. Any residential displacement under Alternative 2 would not require construction of replacement housing, as Alternative 2 would permit construction of up to 589 residential units. Like the Project, there would be no impacts related to displacement of housing or people that necessitates construction of housing elsewhere.

Public Services and Recreation
Alternative 2 would result in reduced demand for fire protection, police protection, school services, library services, and recreation facilities than the proposed Project, commensurate with the reduced amount of potential residential development and redevelopment. Therefore, like the proposed Project, Alternative 2’s potential impacts to public services would be less than significant level.

Transportation and Traffic
Alternative 2 would result in reduced total VMT compared to the proposed Project, commensurate with the reduced amount of residential development or redevelopment and resultant density.

However, this alternative would result in relatively higher VMT per capita and VMT per service population compared to the Project, which is the metric used to determine the significance of transportation impacts. It is noted that, compared to Alternative 1, Alternative 2 would result in relatively higher total VMT but improved VMT per capita and VMT per service population.

Increasing density of land uses, especially when near transit and/or mixed with employment and 3 - 1058
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R:\Projects\SPA\3SPA010100\Environmental Documentation\Settlement Agreement\EA\4.0_Alternatives-050923.docx 4-20 Alternatives to the Proposed Project services, reduces VMT. The proposed Project’s land use plan provides a mix and density of land uses that contributes to reducing vehicle trips through improved alternative transportation options and proximity of housing to employment and services than in the existing condition. Like the Project, this alternative would include the extensive transportation-related policies and actions that support reducing VMT. However, without extensive modeling, it is unknown the actual VMT per capita or service population that would result. Like the proposed Project, Alternative 2 would not cause substantial hazards due to a geometric design feature or incompatible roadway uses, and future projects developed under Alternative 2 must comply with City requirements to ensure adequate emergency access.

Utilities and Service Systems
Alternative 2 would generate reduced demands for utilities and service services, including water supply, water and wastewater infrastructure, wastewater treatment, dry utilities (i.e., electricity, natural gas, telecommunications), and solid waste generation, commensurate with the reduced amount of residential development or redevelopment. However, through compliance with applicable regulations and proposed policies and actions, the Project would result in less than significant impacts related to these utilities and service systems. Therefore, with reduced demands, Alternative 2 would also result in less than significant impacts to water supply, water and wastewater infrastructure, wastewater treatment, solid waste, and dry utilities.

Wildfire
Approximately the southwest quadrant of the City is designated a High Risk Fire Area by the City of South Pasadena Municipal Code (SPMC). No fire hazard severity zones are designated by the California Department of Forestry and Fire Protection (CAL FIRE) within the City. Like the proposed Project, it is possible that parcels in the High Risk Fire Area could be developed or redeveloped under Alternative 2, although the likelihood and extent of this activity would be lower.

Also like the proposed Project, implementation of development under Alternative 2 would be required to comply with State and local codes and other regulations related to emergency access and building in wildfire hazard areas and on hillsides. Accordingly, Alternative 2 would not substantially impact emergency response or evaluation, exacerbate wildfire risks, including due to installation or maintenance of infrastructure, and expose persons to pollutant concentrations from wildfire; or expose people or structures to significant risks subsequent to wildfire such as flooding or landslides. Wildfire impacts of Alternative 2 would be less than significant.

Ability to Meet Project Objectives
Alternative 2 would not meet objective 1 to provide sufficient and inclusive housing capacity to meet State mandates. This alternative would be in violation of State law, opening the City to penalties, and the Court Order to which the City is now subject, opening the City to Court-ordered sanctions.

Alternative 2 would meet five of the six Project objectives, as the objectives are more closely aligned with providing a high-quality environment rather than a certain amount of development.

Specifically, objectives 2, 4, 5, and 6 can be attained through policy implementation by the City unrelated to the location or extent of development. Similarly, objective 3 would be met because Alternative 2 would still direct growth primarily towards the downtown and Ostrich Farm areas, which is also a policy decision.

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R:\Projects\SPA\3SPA010100\Environmental Documentation\Settlement Agreement\EA\4.0_Alternatives-050923.docx 4-21 Alternatives to the Proposed Project Conclusion
Alternative 2 would reduce criteria pollutant emissions and GHG emissions; however, the reduction would not eliminate the significant and unavoidable impacts associated with AQMP consistency, VOC emissions, GHG emissions, or GHG plan inconsistency because the effects of MMs AQ-1 and GHG-1, requiring project-level analysis and mitigation measures, cannot be quantified at this time. Exterior traffic noise levels would be reduced but a significant and unavoidable impact would remain, because this is a result of existing conditions and not buildout of the Project. This Alternative would expose fewer receptors to construction noise that may exceed the standard, but the potential impact on exposed receptors would remain significant and unavoidable. However, Alternative 2 would result in a new significant and unavoidable impact related to land use and planning as the number of dwelling units would be far below the 6th Cycle RHNA allocation for the City, which would violate State law and the Court Order to which the City is now subject.

For all other topics, impacts would be similar or reduced compared to the proposed Project.

4.4 ENVIRONMENTALLY SUPERIOR ALTERNATIVE
CEQA requires the identification of an environmentally superior alternative. Section 15126.6(e)(2) of the State CEQA Guidelines states that, if the No Project Alternative is the environmentally superior alternative, then the EIR shall also identify an environmentally superior alternative among the other alternatives. Table 4-4, Comparison of Impacts for Project Alternatives, on the following page, provides a summary comparison of impacts resulting from both alternatives to the Project.

As shown in Table 4-4, both alternatives would eliminate the significant and unavoidable impact related to population resulting from the inconsistency between SCAG’s growth projections prepared as part of the 2020-2045 RTP/SCS and SCAG’s 6th Cycle RHNA allocation, because of the reduced residential development proposed in Alternatives 1 and 2. However, because of the reduced residential development, both Alternatives 1 and 2 would result in a new significant and unavoidable impact related to land use and planning. Specifically, these alternatives would not accommodate the City’s RHNA allocation and therefore would be in violation of State law as well as the Court Order to which the City is now subject.

For all other topics, the Alternatives’ final impact finding is the same although the degree of impact varies compared to the Project. For instance, both alternatives would have a reduced impacts to public services as there would be less additional land use development; however, under Alternative 1 this comparative reduction would be greater than under Alternative 2 as it proposes the least amount of both residential and non-residential development. From an environmental standpoint, perhaps most importantly, Alternative 2 would not be as consistent with regional (SCAG) planning programs and policies related to reducing GHG emissions pursuant to SB 375 and other State legislation.

Alternatives 1 and 2 would have the same consistency with most Project objectives. 3 - 1060
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R:\Projects\SPA\3SPA010100\Environmental Documentation\Settlement Agreement\EA\4.0_Alternatives-050923.docx 4-22 Alternatives to the Proposed Project Therefore, Alternative 2 is concluded to be the environmentally superior alternative because of its greater amount of development capacity compared to Alternative 1, which results in greater consistency with both the 6th Cycle RHNA allocation, Court Order, and regional plans to reduce GHG emissions.

TABLE 4-4

COMPARISON OF IMPACTS FOR PROJECT ALTERNATIVES
Environmental Issue and EA Section
Alternative 1
(No Project/
Existing General Plan)
Comparison to the Project
Alternative 2
(Reduced Development Capacity)
Comparison to the Project

3.1 Aesthetics Similar Impacts Similar Impacts

3.2 Air Quality Reduced Impacts (Remains
Significant and Unavoidable)
Reduced Impacts (Remains
Significant and Unavoidable)

3.3 Biological Resources Reduced Impacts Reduced Impacts

3.4 Cultural and Tribal Cultural Resources Reduced Impacts Reduced Impacts

3.5 Energy Similar Impacts Similar Impacts

3.6 Geology and Soils
Similar Impacts (Geology);
Reduced Impacts
(Paleontology)
Similar Impacts (Geology); Reduced
Impacts (Paleontology)

3.7 Greenhouse Gas Emissions Reduced Impacts (Remains
Significant and Unavoidable)
Reduced Impacts (Remains
Significant and Unavoidable)

3.8 Hazards and Hazardous Materials Reduced Impacts Reduced Impacts

3.9 Hydrology and Water Quality Reduced Impacts Reduced Impacts

3.10 Land Use and Planning New Significant and
Unavoidable Impact
New Significant and Unavoidable
Impact

3.11 Noise Reduced Impacts (Remains
Significant and Unavoidable)
Reduced Impacts (Remains
Significant and Unavoidable)

3.12 Population and Housing Elimination of Significant and Unavoidable Impact
Elimination of Significant and
Unavoidable Impact

3.13 Public Services and Recreation Reduced Impacts Reduced Impacts

3.14 Transportation Unknown Unknown

3.15 Utilities and Service Systems Reduced Impacts Reduced Impacts

3.15 Wildfire Similar Impacts Similar Impacts

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R:\Projects\SPA\3SPA010100\Environmental Documentation\Settlement Agreement\EA\4.0_Alternatives-050923.docx 4-23 Alternatives to the Proposed Project

4.5 REFERENCES
Aguilar, M. 2021 (June 10). Personal Communication. E-mail correspondence between M. Aguilar (Clerk of the Board, Southern California Association of Governments) and J. Neary (Project Manager, Psomas) regarding 2040 demographic projections pursuant to the 2020-2045 Regional Transportation Plan/Sustainable Communities Strategy.

California Department of Finance (DOF). 2022 (January). Report E-5 Population and Housing Estimates for Cities, Counties, and the State, January 2021-2022, with 2020 Benchmark.

Sacramento, CA: DOF. E-5 Population and Housing Estimates for Cities, Counties, and the State, January 2021-2022, with 2020 Benchmark. (E-5 Population and Housing Estimates for Cities, Counties, and the State, 2020-2022 | Department of Finance (ca.gov).

California Employment Development Department, Labor Market Information Division (EDD). 2022 (July). Unemployment Rates and Labor Force: Cities and Census Designated Places by Individual County: Los Angeles. Sacramento, CA: EDD.
https://www.labormarketinfo.edd.ca.gov/file/lfmonth/lasub.xls.

Southern California Association of Governments (SCAG). 2020 (September 3). 2020-2045 Regional Transportation Plan/Sustainable Communities Strategy. Los Angeles, CA:

SCAG. Read the Plan Adopted Final Plan - Southern California Association of Governments.

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R:\Projects\SPA\3SPA010100\Environmental Documentation\Settlement Agreement\EA\5.0_Other CEQA-050823.docx 5-1 Other CEQA Required Considerations SECTION 5.0 OTHER CALIFORNIA ENVIRONMENTAL QUALITY ACT

REQUIRED CONSIDERATIONS
Section 15126 of the State California Environmental Quality Act (CEQA) Guidelines requires that all aspects of a project be considered when evaluating its impact on the environment, including planning, acquisition, development, and operation. The following must be identified for the project being analyzed; the location of the required information in this Environmental Assessment (EA) is presented in parentheses:
a) Significant environmental effects of the proposed Project (see Table ES-1 and Sections 3.1 through 3.16);
b) Significant environmental effects which cannot be avoided if the proposed Project is implemented (see Table ES-1, Sections 3.1 through 3.16, and Section 4.0); c) Significant irreversible environmental changes which would be involved in the proposed Project should it be implemented (see Section 5.1);
d) Growth-inducing impacts of the proposed Project (see Section 5.2); e) The mitigation measures proposed to minimize significant effects (see Table ES-1 and Sections 3.1 through 3.16); and
f) Alternatives to the proposed Project (see Section 4.0).

5.1 SIGNIFICANT IRREVERSIBLE ENVIRONMENTAL CHANGES
Section 15126.2(c) of the State CEQA Guidelines requires a discussion of any significant irreversible environmental changes that would be caused by the Project. Section 15126.2(c) states:
“Uses of nonrenewable resources during the initial and continued phases of the project may be irreversible, since a large commitment of such resources makes removal or nonuse thereafter unlikely. Primary impact and, particularly, secondary impacts (e.g., highway improvement which provides access to a previously inaccessible area) generally commit future generations to similar uses. Also, irreversible damage can result from environmental accidents associated with the project. Irretrievable commitments of resources should be evaluated to assure that such current compensation is justified.”
As such, a project would generally result in significant irreversible environmental changes if:
 The proposed consumption of resources is not justified (e.g., the project involved the wasteful or inefficient use of energy) (refer to Section 3.5, Energy);  The project would involve a large commitment of nonrenewable resources; or  The project would involve uses in which irreversible damage could result from any potential environmental accidents associated with the project.

Potential future development associated with implementation of the proposed 2021–2029 Housing Element and the non-residential development capacity envisioned in the General Plan and Downtown Specific Plan (DTSP) Update (Project) would consume limited, slowly renewable, and non-renewable resources. Over the long term, new development would require the commitment and reduction of nonrenewable and slowly renewable resources, including petroleum 3 - 1064
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R:\Projects\SPA\3SPA010100\Environmental Documentation\Settlement Agreement\EA\5.0_Other CEQA-050823.docx 5-2 Other CEQA Required Considerations fuels and natural gas (for vehicle emissions, construction, lighting, heating, and cooling of structures) and lumber, sand/gravel, steel, copper, lead, and other metals (for use in building construction, roadways, and infrastructure). Other resources that are slow to renew and/or recover from environmental stressors would also be impacted by long-term implementation of the Project (e.g., air quality through the combustion of fossil fuels and production of greenhouse gases, and water supply through the increased potable water demands for drinking, cooking, cleaning, landscaping, and general maintenance needs).

Future construction activities related to implementation of the Project would result in the irretrievable commitment of nonrenewable energy resources, primarily in the form of fossil fuels (including fuel oil), natural gas, and gasoline for automobiles and construction equipment.

However, the Project would not be creating a need for jobs or housing. The proposed growth would fulfill an existing and anticipated future need that is based on estimates of local and regional population growth. Therefore, the non-renewable resources used in construction of future development projects pursuant to the Project would be expected to be consumed by housing and employment-generating land uses that are anticipated, and are unfulfilled, in the San Gabriel Valley and the wider region. Additionally, the land uses proposed are not unusually wasteful or excessive in terms of construction materials and fossil fuel use.

Implementation of the Project would result in the continuation of long-term resource commitments to potential future development. The resources that would be committed during development would be similar to those currently consumed within the City. These would include energy resources such as electricity and natural gas, petroleum-based fuels required for vehicle trips, and water. Fossil fuels would represent the primary energy source associated with potential future development within the City, and the existing, finite supplies of these natural resources would be incrementally reduced. Any future development would occur in accordance with Title 24, Part 6 of the California Building Code in effect at that time, which sets forth conservation practices that would limit the amount of energy consumed by future development.

The majority of future growth under the Project would consist of infill development and redevelopment, and much of this would be located in proximity to transit (light rail or bus) and/or walking distance to retail and services. The location and type of future growth in the focus areas is intended to reduce vehicle miles traveled (VMT) compared to land uses not located near transit and/or not near a mix of uses and services. Because the future growth in the City would be on or near sites of existing development and would provide a portion of the needed housing stock in the region, the Project would not be considered wasteful or inefficient in its use of fossil fuels, including energy resources.

Similarly, most of the future land uses would not include lawns or other large-scale landscaped areas, and landscaped areas proposed would be required to meet the requirements of Article III, Water Efficient Landscape, of the South Pasadena Municipal Code. As such, the Project would not be considered wasteful or inefficient in its use of water. Although minimal compared to the existing energy use of the City, because of the relatively small increment of growth and types and land uses, the fossil fuel and water requirements associated with implementation of the Project would, nonetheless, represent a long-term commitment of essentially non-renewable resources.

The State CEQA Guidelines also require a discussion of the potential for irreversible damage caused by environmental accidents associated with a project. While implementation of the Project would result in the use, transport, storage, and disposal of hazardous materials and/or wastes typical of urban areas, such as associated with dry cleaners, restaurant and office cleaning/maintenance, and landscape maintenance, as described in Section 3.8, Hazards and Hazardous Materials, all activities would comply with applicable State and federal laws related to 3 - 1065
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R:\Projects\SPA\3SPA010100\Environmental Documentation\Settlement Agreement\EA\5.0_Other CEQA-050823.docx 5-3 Other CEQA Required Considerations hazardous materials transport, use, and storage, which significantly reduces the likelihood and severity of accidents that could result in irreversible environmental damage, and such an accident causing irreversible damage is not considered reasonably foreseeable.

In summary, potential future development associated with the Project would result in the irretrievable commitment of limited, slowly renewable, and nonrenewable resources, which would limit the availability of these particular resource quantities for future generations or for other uses through the year 2040. However, the use of such resources is anticipated and accounted for in the State, regional, and local regulations, which generally prohibit wasteful practices and require environmentally conservative actions, as summarized in the “Relevant Programs and Regulations” discussion within Sections 3.1 through 3.16 of this EA. Similarly, as discussed in Section 3.9, Land Use and Planning, the proposed Project is entirely consistent with the goals adopted in the 2020–2045 Regional Transportation Plan/Sustainable Communities Strategy, which is intended to reduce VMT, contribute to improved air quality, and greenhouse gas emissions, among other objectives. Therefore, although irreversible changes would result from implementation of the Project, such changes would not be considered significant, and no mitigation is required.

5.2 GROWTH-INDUCING IMPACTS
Pursuant to Section 15126.2(d) of the State CEQA Guidelines, this analysis examines ways in which the Project could foster economic or population growth or the construction of additional development, either directly or indirectly, in the surrounding environment.

Also, this section discusses whether the Project could encourage and facilitate other activities that could significantly affect the environment, either individually or cumulatively. Growth can be induced in several ways, such as through the elimination of obstacles to growth, through the stimulation of economic activity within the region, and/or through the establishment of policies or other precedents that directly or indirectly encourage additional growth. Although growth inducement itself is not considered an environmental impact, it could potentially lead to environmental effects.

Accordingly, a project may foster spatial, economic, or population growth in a geographic area if it meets one or more of the following criteria:

1. Removal of an obstacle to growth (e.g., construction or extension of major infrastructure, providing new access to an area);

2. Foster population growth (e.g., construction of additional housing), either directly or indirectly;

3. Foster economic effects that could result in other activities that could significantly affect the environment (e.g., changes in revenue base, employment expansion);

4. Establish a precedent-setting action that could result in other activities that could significantly affect the environment (e.g., an innovation, a change in zoning, general plan amendment); and/or

5. Development of or encroachment on an isolated or adjacent area of open space (being distinct from an in-fill project).

The potential growth-inducing impacts associated with the Project are evaluated below against these criteria. It should be noted that growth-inducing effects are not necessarily beneficial, 3 - 1066
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R:\Projects\SPA\3SPA010100\Environmental Documentation\Settlement Agreement\EA\5.0_Other CEQA-050823.docx 5-4 Other CEQA Required Considerations detrimental, or of little significance to the environment (Section 15126.2[d] of the State CEQA Guidelines).

The impacts associated with the future development of vacant lots and the redevelopment/infill of existing properties to higher intensity or different land uses is analyzed in Sections 3.1 through

3.16 of this EA. As summarized in the Executive Summary of this EA, significant adverse impacts would be avoided or reduced to less than significant levels through compliance with the policies and actions in the proposed Project; compliance with existing regulations; and required mitigation measures (MMs). Significant unavoidable adverse impacts would remain related to Air Quality (Section 3.2), Greenhouse Gas Emissions (Section 3.7), Noise (Section 3.11), and Population and Housing (Section 3.12).

As described in Section 2.0, Environmental Setting and Project Description, a general plan guides the development of a city or county and consists of policies actions and/or programs that would achieve the community’s vision for its future. Accordingly, the Project is premised on a certain amount of growth taking place. As discussed in Section 2.0, the proposed Project presents an opportunity to re-evaluate the City’s values; address broader issues; and respond to changing economic, environmental, legal, social, and regulatory settings. City of South Pasadena decision makers will use the Project to provide direction when making land use and public service decisions.

Since the City of South Pasadena is largely built out, the roadway and utility infrastructure systems are in place. Improvements to roads and other infrastructure would be implemented either to alleviate existing issues or in support of anticipated future growth. Extension of water and sewer lines (i.e., laterals), if needed, would be part of individual future projects and provide services to those developments. However, extensions or replacements of wet utilities (water and sewer infrastructure), dry utilities (i.e., electric, natural gas, telecommunications), or roadway improvements that would serve only the existing and proposed uses and would not serve other nearby areas may be an inducement to further (i.e., unplanned) development either within or near the City. It is also noted that because the City is almost entirely built out and the existing open space areas are not proposed for development, implementation of the Project would not result in development of or encroachment on an isolated or adjacent area of open space.

Implementation of the Project would induce population growth within the City by facilitating directed growth. This analysis assumes the buildout of up to 2,775 additional dwelling units and 430,000 square feet of non-residential uses, comprised of retail and office development. This is estimated to generate up to an additional 6,882 residents and 1,978 jobs. Potential growth inducement impacts of adoption and implementation of the Project are addressed in Section 3.12, Population and Housing, of this EA. Implementation of the Project, which is by definition growthinducing regardless of the significance finding for the Project in Section 3.12, would result in significant environmental impacts after mitigation, as presented in Sections 3.1 through 3.16 of this EA. This is considered a significant and unavoidable growth-inducing impact.

If the Project is adopted, the City will subsequently need to review and update, as needed, its Zoning Code to make sure it is consistent with policies in other planning documents. The environmental impacts of the update to the Zoning Code consistent with State law (Section 65860 of the Government Code). Similar to the discussion of growth inducement above, adoption of a General Plan, Specific Plan, and/or Housing Element and an update to the Zoning Code are, by definition, precedent setting actions, as these documents/codes set the path for future development in the City and would result in significant environmental impacts after mitigation, as presented in Sections 3.1 through 3.16 of this EA. This is considered a significant and unavoidable growth-inducing impact.
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APPENDIX A-1

CULTURAL RESOURCES RECORD SEARCH

3 - 1068
Report List
Report No. Other IDs Year Author(s) Title Affiliation Resources LA-00112 1974 Impact on Archaeological Resources of
Proposed Upgrading Ramps on the
Pasadena Freeway
University of California, Los
Angeles Archaeological
Survey
D'Altroy, Terence N.

LA-00115 1974 Evaluation of the Archaeological Resources and Potential Impact of Proposed Extension
of the Long Beach Freeway (rt. 7) North From
Valley Blvd. to Rt. 210 (colorado Freeway)
University of California, Los
Angeles Archaeological
Survey
Clewlow, William C. Jr.

LA-01319 1983 Archaeological Survey Report for Two
Proposed Disposal Sites 07-la 7 Routes 10 to
210 07-204-020090
Romani, John F. Caltrans

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South Pasadena City CouncilMay 30, 2023

South Pasadena City Council
May 30, 2023