Comments from East Eaton Wash Neighborhood
Association on the
City of Pasadena draft Initial Study and Mitigated Negative Declaration
for the project titled "Pasadena Ice Rink Facility", dated February
East Eaton Wash Neighborhood Association is a neighborhood
association recognized by the City of Pasadena and its Neighborhood
Connections office. The association area covers the quiet
single-family residential neighborhood immediately east of the
described Project site, from Foothill Blvd. on the south to Orange
Grove Blvd. on the north, from the SCE land on the west to Sierra Madre
Villa on the east. Houses along Avocado Ave and Avocado Ln and
near their intersections with Alameda, Del Vina, and Las Lunas streets
will be most directly affected by the project. All residents will
be affected by traffic problems on Foothill Blvd as well as any
increase in through traffic or parking on neighborhood streets.
Also, all residents are taxpayers and most are homeowners and want to
be sure both city and personal resources are carefully and thoughtfully
spent and protected.
There are many places in the document where the Project site location
as an "urban" setting. This seems misleading. Suburban
would more adequately reflect this area. Further, while it may be
surrounded by developed city, the area of the project has always served
as an undeveloped buffer zone. By and large quiet, locked up, and
The following comments are arranged somewhat in order of severity of
Item 16d, page 30
Question – "Police Protection" (marked with no impact)
Response – "The proposed site is in an area that has reported
low crime rates according to Police Department burglary statistics. The project will not increase the need for
police protection and the project can be served by existing police
personnel. However, the effect on police
service is not
significant, since the change is within the police department’s scope
The answer is non-responsive.
The first sentence is true, it has been a low crime area, and therefore
the police have not needed to have much presence. The response
does not speak to the changes brought by the project. Just
because the "change is within the police department's scope of
responsibility" does not mean they won't need more resources to
effectively serve that responsibility.
It doesn't address the fact that the facility
will be drawing significant additional (possibly rowdy) people to a
fairly quiet and remote suburban area that has been fenced off for
decades and has required very few police resources. While it may
be true, the response gives no basis for the statement that it
will not increase the need for police protection and can be served by
the existing personnel.
1. What research has been done on the
experiences of other ice rink facilities, particularly in suburban
2. What steps will the facility operator be required (via management
agreement?) to take with
regard to security for the building and grounds? Including both
during hours of operation and after hours? Are there increased
requirements for those larger events?
The existing ice rink downtown is surrounded by a busy business
district on three sides. It really is in an urban setting and has
a lot more police presence and general activity in its vicinity.
It is also not nearly as big as the proposed project.
3. Will the parking areas be locked up after hours, or will they be
open at all times? If they aren't locked, what are the provisions
for monitoring them?
4. We have been told in a meeting that the "small eating area" will not
serve any alcohol. That is good. Will
participants/spectators be permitted to bring and consume their own?
5. The separate fire protection item speaks to a review and process
ascertain needs and insure they are met. Perhaps that is what
this response needs. What project review/permitting process will
insure that the police protection needs will be met?
Much of the document seems to be based on the "project site" not
including the SCE land to the east of the building. For example,
on page 7 in response to question 3d about light and glare, it
specifically says that the "SCE-owned property to the east provides a
buffer between the new Ice Rink Facility and the nearest adjacent
But on page 2, it cites a "potential License Agreement with SCE to
locate additional parking on SCE-owned land."
It seems there may be a recognition of the reality that the 143
required spaces will be insufficient for those events with 400-500
spectators and participants, but an unwillingness to commit to build or
make arrangements for extra parking.
1. What is the city's intent with respect to the "extra
parking"? To have extra or not?
2. If the project does end up using the SCE property for
additional parking, will this document be revisited and updated for
the larger project site area and any potential additional impacts and
mitigation needs? Use of the SCE land for parking will impact the
neighborhood to the east, whether that parking is developed by the city
or by PCC.
3. Is there an intent to work out a share parking agreement with
PCC-CEC, at least for major events?
4. There is no mention as to whether the parking will be free or
require payment. We were previously told free (which from our
neighborhood perspective is good).
5a. If ice rink parking is free, how will you keep it from being
used by PCC students since they have to pay to use PCC parking?
(The fee being major reason why students and college visitors park on
our neighborhood streets instead of
using the lot.)
5b. Is there any chance of getting PCC to stop requiring payment for
its parking, thus alleviating the traffic and parking problems on our
6. If the ice rink parking is not free, or is not sufficient in
number, what is the plan to protect our neighborhood from the ice rink
patrons parking in it (just like the PCC students do)?
1. Will the existing PCC driveway to Foothill Blvd be
2. Will there be special traffic enforcement for the big
events? If so, who will pay for it?
3. Item 18a, cites a traffic study done last summer for the
project. It says to "see Exhibit x", but there is no evidence of
any exhibits in our copy of the document. Is "Exhibit x" the
4. a. Was the traffic study done in the middle of the summer, or
that just when the report was made?
b. Were PCC and PCC-CEC (and other schools) in
session when the study was done?
c. Was it studied during the evening weekday
d. Was the traffic studied at a time when
was a big event at PCC-CEC?
5. The response to item 18d brings in putting in the new
signal at the PCC driveway/Foothill intersection in order to mitigate
the special hazards there.
a. Does the traffic study
show that doing this will clear up the congestion that occurs now?
b. What is the referene in
the 18d response to being "coordinated with the future signal at the
Titley Avenue and Foothill Blvd intersection"? Is this saying
that there will be the signal at Santa Paula, another at the PCC
driveway, and yet another at Titley Avenue?
c. Would really like to see a
drawing of Foothill with where the signals would be and an explanation
of how they would work. Is that in the traffic study?
Item 18e, page 33, emergency access
Within Response - "An additional emergency access entrance is
located at Alameda Street and through the parking area of the proposed
Eaton Wash Park"
1. How will these emergency access entrances be managed?
2. Are they required to be locked all the time except during
3. Who has the ability to unlock them?
4. Would just the existence of a large event be able to constitute an
"emergency" leading to opening those gates and traffic being directed
through our neighborhood?
5. If the city does not lease the SCE land for extra parking,
wouldn't it still have to make an agreement to have an access corridor
to Alameda/Avocado for the emergency gate on that fencing, and also an
access corridor over to the gate for Eaton Wash park? This
alternate possiblity to parking doesn't seem to be accounted for in the
wording on page 2.
Item 14a, page 28
Question - "Exposure of person to or generation of
levels in excess of standards established in the local general plan or
ordinance, or applicable standards of other agencies?"
(Marked with no impact)
Response - "The project itself will not lead to significant
increase in ambient noise. Noise generated by construction activities
a short-term impact and noise from air conditioning and heating systems
increase the existing level of ambient noise after construction. The
from construction noise will be short term and limited to normal
(7am to 7pm Monday – Friday
and 8am to 5pm on Saturday). " ...
"According to the Noise Restrictions Ordinance, the
noise level is 50 dbA during the day (6 a.m. - 11 p.m.) and 40 dBA at
night (11 p.m. to 6 a.m.). Noise generated by construction
shall be 85 dbA or less within a 100 foot radius of the
Construction hours are limited to between the hours of 7:00 a.m. and 9:00 p.m. Monday
The hours given for construction in the
different paragraphs are in conflict with one another. Which is
Item 14c, page 28
Question - "A substantial permanent increase in ambient noise levels in
the Poject vicinity above levels existing without the Project?" (marked
as no impact)
Response - "See response to 14.a. The Noise Restrictions
(Pasadena Municipal Code Chapter 9.36) sets the allowed ambient noise
level. The Project will
not increase ambient noise levels
at the subject site. The site is currently vacant and within a
developed urban area, and the proposed use of an Ice Rink Facility will
not increase the ambient noise levels at the subject site."
These flat statements that it won't increase the noise level are
ridiculous. Of course it will increase the noise levels over
a quiet vacant site or one filled with potted plants with a few workers
only during daylight hours. You may be able to make a case that
the noise will
increase above the allowed level, or that the increase won't be
"significant", but not that it won't increase at all.
It may be within a "developed urban area" in a very broad sense, but
the fact is that it has been an undeveloped quiet buffer area in what
really is a suburb.
1. What research has been done to ascertain what noises are produced by
an ice rink facility and how well that noise is contained?
The response to 14 a and c. appears to presume that the only
operational noise impact would be from air conditioning and heating
1. What about noise from parking lot traffic? Engines, mufflers,
tires, horns, overblown stereo systems. And this will go well
into the night and on weekends whereas the plant nursury vehicles were
only active weekdays.
2. What about noise from garbage collection, delivery trucks,
maintenance of the parking lot, etc.?
3. What about noise from within the facility? Such things as
loudspeaker systems making announcements or playing loud music, and of
course crowd noise. A well designed and run facility should
these inside noise sources, but it has to be designed to do it.
Hydrology and Water Quality
Item 11 b.
Within response: "Any irrigation may incrementally add water to the
Ground water basin. Therefore, there will be no direct additions
or withdrawals from the ground waters."
This ignores that the vast majority of rain and irrigation waters have
been sinking in and replenishing the aquifer, but with this project
it'll all be paved over so it'll go into the storm drain instead.
Item 11 c.
Within response: "Storm and other water runoff will therefore
decrease. Increased paving or building footprint will reduce
water percolating into the soil to replenish the water table and will
increase storm and irrigation water flowing into the storm drain
The second sentence makes sense but is in direct contradiction to the
first sentence. Currently there is significant runoff onto our
streets and eventually the storm drains only when it rains very
a short amount of time (and historically, there were times when nursery
irrigation water was allowed to runoff into our streets). But the
majority of the rain and irrigation sinks in and thus replenishes the
aquifer. After it is almost all paved over, most of that water
will go into the storm drains, not sink in.
Item 11.d. vs.
11.g. and 11.i.
11.d's response correctly says that "water is not usually" stored behind the
dam. But 11.g and 11.i. flatly state that "water is not" stored
behind the dam. Water is sometimes held back by the dam.
This winter for example.
Within response: "surface Projection of the rupture area may be less
than 0.1 miles from the site."
That is awfully close. In which direction?
Within response: ..."This Project will not increase the potential
occurrence of earthquakes."...
Our favorite obvious statement!
9.a.iii says the study claims that the "historic high groundwater
level for the site is more than 100 feet below the surface of the
But then in 9b's response it states it "has a high water
table", and then notes in parentheses that this in conflict with the
Which is it?
Section I - Project Information
Item 9, page 1
"The site is comprised of dedicated parkland located in a fully
developed urban area, just north of Alameda Street"
1. We object to the description as a "fully developed urban
area". It is and always has been either vacant land or land with
plants on it within an area that certainly does not feel "urban".
Except for immediately along Foothill Blvd to the south, the
surrounding area is single family residential and quiet.
2. Alameda street does not extend beyond Avocado street and the
description as being "north of" Alameda street is confusing. A
better description would be "just north of a line extended west from
Item 9, page 2
"property to the north and south of the Project site and the SCE-owned
property to the east have been used for the storage of boxed trees by a
nursery for the past several
Don't know about the city owned property, but the SCE owned property
was occupied by the tree nursury continually from at least the early
1960s. Over four decades is hardly "several" years. That
property usage has provided an important green buffer reducing sound,
light, and air pollution, as well as protecting the neighborhood from
through traffic. It became even more important once the freeway
was built in the early 1970s, and increasingly important as the freeway
has become increasingly noisy and polluting.
Item 6.a, page 10
Within response: "The construction of the concrete flood control
channel and settling basins in 1941 left the Project site
vitually denuded of vegetation."
According to several long time residents, the concrete flood
control channel was not constructed until sometime in the 1950s, around
the same time that Orange Grove Blvd was cut through. There may
have been plans in 1941, and construction may have occurred somewhere
else along the wash, but not at this location.
Item 6.d, page 11
Once again the "developed urban area" statement is not accurate,
as is "will not involve the dispersal of wildlife".
The project area has never been developed and has always had a lot of
wildlife moving through and/or living in it. The existing lousy
fences have not impeded movement very much. To our knowledge,
none of it is endangered or scarce wildlife, just coyotes, raccoons,
skunks, possums, mice, lizards, etc have been known to inhabit and
continually move through that area. They will be dispersed.
Doesn't rate as a "significant" impact on their larger populations, but
the response should not claim they don't exist.
Utilities and Service Systems
Item 19.c., bottom of page 35
Appears to be a conflict between sentences "The project does meet a standard for
review..." and "If the
Project meets a standard for review..."
Eaton Wash Neighborhood Association contact info:
Officers of the association may be contacted via e-mail at: