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 2005.

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 is referred to 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 unlit at night.

The following comments are arranged somewhat in order of severity of concern.

Public Services

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 of responsibility."

Comments/Questions:

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 settings?
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.

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?

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 which will 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?


Parking

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 residential property". 
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 residential streets?

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)?


Traffic

1.  Will the existing PCC driveway to Foothill Blvd be widened?

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 study itself?

4.  a. Was the traffic study done in the middle of the summer, or is 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 rush-hours?
     d. Was the traffic studied at a time when there 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?
            

"emergency exit"

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"

Questions:

1. How will these emergency access entrances be managed?

2. Are they required to be locked all the time except during emergencies?

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.



Noise

Item 14a, page 28

Question - "Exposure of person to or generation of noise levels in excess of standards established in the local general plan or noise 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 may have a short-term impact and noise from air conditioning and heating systems may increase the existing level of ambient noise after construction. The impact from construction noise will be short term and limited to normal working hours (7am to 7pm Monday – Friday and 8am to 5pm on Saturday). " ...

    "According to the Noise Restrictions Ordinance, the allowed ambient 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 equipment shall be 85 dbA or less within a 100 foot radius of the equipment.  Construction hours are limited to between the hours of 7:00 a.m. and 9:00 p.m. Monday through Saturday."

Comments/Questions:

The hours given for construction in the different paragraphs are in conflict with one another.  Which is it?


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 Ordinance (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."

Comments/Questions:

These flat statements that it won't increase the noise level are ridiculous.  Of course it will increase the noise levels over those of 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 not 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 possible operational noise impact would be from air conditioning and heating systems. 

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 contain 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 Raymond 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 facilities."

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 hard in 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.


Geology and Soils

Item 9.a.i.

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!

Items 9.a.iii vs.  9.b.
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 site".
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 study.
Which is it? 


Section I - Project Information

Item 9, page 1

Within response:
"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 Alameda street".

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 years."

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.


Biological Resources

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..."

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East Eaton Wash Neighborhood Association contact info:

Officers of the association may be contacted via e-mail at:  [email protected]