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City of Pasadena

Temporary Use of the Rose Bowl Stadium


by the National Football League (NFL)
Final Environmental Impact Report
SCH No. 2012031053

Prepared For:
City of Pasadena
175 N. Garfield Avenue
Pasadena, California 91109

Prepared by:

I M PA C T S C I E N C E S , I N C .
803 Camarillo Springs Road, Suite A
Camarillo, California 93012 November 2012
(805) 437-1900 FAX (805) 437-1901
Temporary Use of The Rose Bowl by the NFL
Final
Environmental Impact Report

SCH No. 2012031053

Prepared for:

City of Pasadena
175 Garfield Avenue
Pasadena, California 91109

Prepared by:

Impact Sciences, Inc.


803 Camarillo Springs Road, Suite C
Camarillo, California 93012

November 2012
TABLE OF CONTENTS
Section Page
1.0 Summary .................................................................................................................................................1.0-1
2.0 Corrections and Additions....................................................................................................................2.0-1
3.0 Responses to Comments........................................................................................................................3.0-1
Topical Responses
Topical Response 1 – Adequacy of Project Description ....................................................................3.0-9
Topical Response 2 – Historic Resources ..........................................................................................3.0-11
State and Local Agencies
Letter No. 1 State of California, Native American Heritage Commission,
August 16, 2012 ........................................................................................................3.0-14
Letter No. 2 South Coast Air Quality Management District, October 10, 2012.....................3.0-20
Letter No. 3 Metropolitan Transportation Authority, October 8, 2012 ..................................3.0-32
Private and Local Organizations
Letter No. 4 Pasadena Chamber of Commerce, September 17, 2012 ......................................3.0-37
Letter No. 5 Pasadena Heritage, September 14, 2012................................................................3.0-40
Letter No. 6 City of Pasadena, Transportation Advisory Commission, October 5, 2012.....3.0-44
Letter No. 7 West Pasadena Residents Association, October 8, 2012 .....................................3.0-56
Letter No. 8 Linda Vista-Annandale Association, October 8, 2012.........................................3.0-69
Letter No. 9 West Pasadena Residents Association, October 1, 2012 ...................................3.0-114
Letter No. 10 San Rafael Neighborhoods Association, October 7, 2012.................................3.0-118
Letter No. 11 Planning Commissioner Vince Farhat, September 23, 2012.............................3.0-125
Letter No. 12 Planning Commission Meeting, Commissioner Comments,
September 19, 2012 ................................................................................................3.0-150
Letter No. 13 Transportation Advisory Commission Meeting - Commissioner
Comments, October 2, 2012 ..................................................................................3.0-158
Letter No. 14 Parks and Recreation Commission Meeting – Commissioner Comments,
October 4, 2012 .......................................................................................................3.0-167
Individuals
Letter No. 15 Planning Commission Meeting – Resident Comments, September 19,
2012 ..........................................................................................................................3.0-176
Letter No. 16 Transportation Advisory Commission Meeting – Public Comments,
September 27, 2012 ................................................................................................3.0-187
Letter No. 17 Parks and Recreation Commission Meeting – Public Comments,
October 2, 2012 .......................................................................................................3.0-199
Letter No. 18 S. Robert Snodgrass, October 8, 2012 ..................................................................3.0-210
Letter No. 19 Mary Alexander, October 8, 2012 ........................................................................3.0-229
Letter No. 20 Eunice Bae, October 4, 2012 ..................................................................................3.0-231
Letter No. 21 Adele Baquet, October 7, 2012..............................................................................3.0-233
Letter No. 22 Kristina Bell-Marinescu, August 13, 2012...........................................................3.0-235
Letter No. 23 Don Bremner, October 8, 2012..............................................................................3.0-237
Letter No. 24 John Boyle, October 3, 2012 ..................................................................................3.0-242
Letter No. 25 Petrea Burchard, October 5, 2012.........................................................................3.0-244
Letter No. 26 Cabreira-Johnson Family, September 24, 2012...................................................3.0-246
Letter No. 27 Samir Das, October 1, 2012 ...................................................................................3.0-248

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Letter No. 28 Michael Duran, September 9, 2012 ......................................................................3.0-250
Letter No. 29 Michael Duran, October 8, 2012...........................................................................3.0-252
Letter No. 30 Eleanor Edwards, October 8, 2012.......................................................................3.0-254
Letter No. 31 Barbara Ellis, October 8, 2012 ...............................................................................3.0-256
Letter No. 32 Gregory Fu, October 8, 2012 .................................................................................3.0-258
Letter No. 33 Loring Guessous, October 2, 2012 .......................................................................3.0-260
Letter No. 34 Gary Hackney, October 7, 2012............................................................................3.0-265
Letter No. 35 Ron Hemingway, August 21, 2012 ......................................................................3.0-271
Letter No. 36 Jenna Kachour, September 13, 2012.....................................................................3.0-273
Letter No. 37 Guido Meindl, August 11, 2012 ...........................................................................3.0-278
Letter No. 38 Gloria Morrison, September 10, 2012 ..................................................................3.0-280
Letter No. 39 Lorig Mushegain, September 13, 2012 ................................................................3.0-282
Letter No. 40 Arundhati Nag, October 1, 2012 ..........................................................................3.0-284
Letter No. 41 Dianne K. Newman, August 15, 2012 .................................................................3.0-286
Letter No. 42 Dianne K. Newman, October 7, 2012 ..................................................................3.0-288
Letter No. 43 Dianne K. Newman, TAC Comments, September 27, 2012 .............................3.0-292
Letter No. 44 JoAnn Newman, August 16, 2012........................................................................3.0-295
Letter No. 45 Steve Onderdonk, September 10, 2012................................................................3.0-297
Letter No. 46 Susann Perry, August 19, 2012.............................................................................3.0-299
Letter No. 47 Jonas Peters, August 15, 2012 ...............................................................................3.0-301
Letter No. 48 Jonas Peters, October 8, 2012 ................................................................................3.0-303
Letter No. 49 Jonas Peters, TAC Comments, September 27, 2012...........................................3.0-324
Letter No. 50 Sylvia Plummer, October 8, 2012 .........................................................................3.0-329
Letter No. 51 Ann Scheid, October 2, 2012.................................................................................3.0-331
Letter No. 52 Joy Selby, September 10, 2012 ..............................................................................3.0-335
Letter No. 53 Leland Sklar and Maureen Gay McGillan-Sklar, October 1, 2012...................3.0-337
Letter No. 54 Bob Snodgrass, September 17, 2012.....................................................................3.0-341
Letter No. 55 Bob Snodgrass, TAC Comments, September 27, 2012 ......................................3.0-344
Letter No. 56 Patrick Theofanis, October 1, 2012.......................................................................3.0-347
Letter No. 57 Andrea Totten, September 27, 2012.....................................................................3.0-349
Letter No. 58 Unknown, August 15, 2012 ..................................................................................3.0-351
Letter No. 59 Susann Walker-Perry, September 10, 2012 .........................................................3.0-353
Letter No. 60 Michele Zack, October 8, 2012..............................................................................3.0-355
Letter No. 61 Christy Zamani, October 8, 2012..........................................................................3.0-357
Letter No. 62 Barbara Zimmerman, October 8, 2012 ................................................................3.0-363
Letter No. 63 Madhu Kumar, October 10, 2012 .........................................................................3.0-365
Letter No. 64 Online Petition from Change.org ........................................................................3.0-367
Letter No. 65 Petition ....................................................................................................................3.0-592
Letter No. 66 Ruben Cruz, October 25, 2012 ..............................................................................3.0-610
4.0 Mitigation Monitoring and Reporting Program ................................................................................4.0-1
Appendices
F3.0 Final EIR Supplemental Documentation
Contemporary Services Corporation Letter
Cultural Resources Consultation
Loop Improvement Survey Memo
NAHC Correspondence
SMMC Grant Agreement

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LIST OF TABLES
Table Page
1.0-1 Summary of Project Impacts, Mitigation Measures, and Residual Impacts...................................1.0-8
4.0-1 Mitigation Monitoring and Reporting Program Matrix....................................................................4.0-2

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1.0 SUMMARY

CEQA REQUIREMENTS

In accordance with the California Environmental Quality Act (CEQA), specifically State CEQA Guidelines
Sections 15088, 15089, and 15132, the City of Pasadena has prepared the Final Environmental Impact
Report (EIR) for the proposed Temporary Use of the Rose Bowl Stadium by the NFL. A Final EIR is
defined by Section 15362(b) of the State CEQA Guidelines as “containing the information contained in the
Draft EIR; comments, either in verbatim or in summary received in the review process; a list of persons
commenting; and the responses of the Lead Agency to the comments received.”

Section 3.0 of this document contains all comments received on the Draft EIR during the document’s
60‐day public review period of August 9, 2012 to October 8, 2012. Responses to comments received by all
interested parties have been prepared and are included in this document. Section 2.0, Corrections and
Additions, includes changes either in the response to comments received on the document, or as initiated
by the Lead Agency (City of Pasadena) on the Draft EIR.

This document, along with the Draft EIR (incorporated by reference), make up the Final EIR as defined in
State CEQA Guidelines, Section 15132, which states that:

The Final EIR shall consist of:

(a) The Draft EIR or a revision of the Draft.

(b) Comments and recommendations received on the Draft EIR either verbatim or in summary.

(c) A list of persons, organizations, and public agencies comment on the Draft EIR.

(d) The responses of the Lead Agency to significant environmental points raised in the review
and consultation process.

(e) Any other information added by the Lead Agency.”

USES OF THE FINAL EIR

The Final EIR allows the public and the decision makers an opportunity to review revisions to the Draft
EIR, the response to comments, and other components of the EIR, such as the Mitigation Monitoring
Program, prior to approval of the project. The Final EIR serves as the environmental document to support
approval of the proposed project, either in whole or in part.

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After completing the Final EIR, and before approving the project, the Lead Agency must make the
following three certifications as required by Section 15090 of the State CEQA Guidelines:

 That the Final EIR has been completed in compliance with CEQA;

 That the Final EIR was presented to the decision‐making body of the Lead Agency, and that
the decision‐making body reviewed and considered the information in the Final EIR prior to
approving the project; and

 That the Final EIR reflects the Lead Agency’s independent judgment and analysis.

Additionally, pursuant to Section 15093(b) of the State CEQA Guidelines, when a Lead Agency approves a
project that would result in significant unavoidable impacts that are disclosed in the Final EIR, the agency
must state its reasons for supporting the approved action in writing. This Statement of Overriding
Considerations is supported by substantial information in the record, which includes the Final EIR. Since
the proposed project would result in significant unavoidable impacts, the decision‐making body (City
Council) would be required to adopt a Statement of Overriding Considerations if it approves the
proposed project.

These certifications, along with the Facts, Findings, and the Statement of Overriding Considerations will
be included in a separate document. Both the Final EIR and the Findings are submitted to the decision-
making body for consideration of the proposed project.

REVISIONS TO THE DRAFT EIR

Text changes are intended to clarify or correct information in the Draft EIR in response to comments
received on the document, or as initiated by Lead Agency (City) staff. Text changes are included in this
Final EIR in Section 2.0 Corrections and Additions.

PROJECT LOCATION AND SETTING

The City of Pasadena is located approximately 10 miles northeast of the City of Los Angeles in the
County of Los Angeles (Draft EIR Figure 2.0-1 Regional Location). Regional access to the City is provided
by State Route 134 (SR 134), Interstate 210 (I-210), Interstate 110 (I-110), and Interstate 710 (I-710). The
Rose Bowl Stadium is located at 1001 Rose Bowl Drive in the City of Pasadena, on the south side of I-210
and west of SR-134. Main access points to the stadium are Rosemont Avenue, Seco Street, Salvia Canyon
Road, West Washington Drive, and Rose Bowl Drive.

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The stadium and associated facilities are located within the Arroyo Seco on the western edge of the City
(Draft EIR Figure 2.0-2, Project Vicinity). The Arroyo Seco is a deeply cut canyon that links the San
Gabriel Mountains and the Los Angeles River and is comprised of three sections, the Upper, Central, and
Lower Arroyos. The Rose Bowl is located in the Central Arroyo, which extends from the Colorado Street
Bridge at the south to I-210 at the north. It is generally bounded by Arroyo Boulevard and Arroyo Terrace
on the east and Linda Vista Avenue on the west. The neighborhoods to the east and west are residential.
The Central Arroyo comprises approximately 470 acres and is the most developed section of the Arroyo
Seco. In 2009, the Central and Lower Arroyo areas were listed on the National Register of Historic Places
as a district. Draft EIR Figure 2.0-3, Arroyo Seco, shows the location of the Upper, Lower and Central
Arroyo Seco.

Land uses surrounding the Rose Bowl include the Brookside Golf Course immediately to the north and
Brookside Park to the south. Single-family residential units are located near the stadium on the slopes of
the Arroyo Seco. The residential neighborhoods surrounding the Central Arroyo are primarily single-
family residential and within a hillside development district. The southeast edge of the Central Arroyo
along Arroyo Terrace contains some small areas zoned for multi-family uses.

Access and Circulation

Currently, the Central Arroyo can accommodate approximately 21,518 vehicles. During major events at
the Rose Bowl, parking is provided on adjacent surface parking lots located to the east, west, and south of
the stadium, on Brookside Golf Course located north of the stadium, and off-site parking provided at the
existing Parsons complex located at 100 West Walnut Street (via an existing shuttle program to/from the
Rose Bowl Stadium). The paved parking lots to the east of the stadium are Lots B and D and the paved
lots to the west are Lots F, K, L, and M. Lot I is also paved and is located south of the stadium just south
of Seco Street (see Figure 2.0-6, in Section 2.0, Project Description, of the Draft EIR). Area H is a turf area
that is used primarily for recreational activities (i.e., soccer, kite flying, etc.) and on special event days,
parking is provided in this area. The fairways of the two 18-hole Brookside Park golf courses north of the
stadium are also divided into areas used for parking for major events. Parking is also provided near
Brookside Park, located just east of Lot I. Based on information provided by the RBOC, approximately
21,518 total parking spaces are made available on both paved and turf areas. For large events like the
Rose Bowl Game, with current attendance well over 80,000 people, the total parking supply can be
increased to approximately 23,310 spaces with multiple stack parking configurations on certain lots.
Parking configurations (i.e., two or three stack configurations) are determined on an event-by-event basis,
based on the type of event and the number of attendees. It should be noted that although multiple stack

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parking results in a significantly higher parking supply, it also results in increased delays and less
convenience for event patrons.

On-Site Recreation

The Rose Bowl Stadium and associated facilities are located at 1001 Rose Bowl Drive and encompass 30 of
470 acres within the Central Arroyo. Recreational resources at the project site include an interchangeable
football and soccer stadium, and open field/park amenities are provided by adjacent, associated facilities.
The Rose Bowl Stadium provides recreational-viewing opportunities to the public, while associated
facilities, such as Brookside Park, provide recreational use opportunities by the general public. The Rose
Bowl Stadium is used throughout the year for concerts and at the 4th of July for a fireworks display.
Draft EIR Figure 2.0-7, Rose Bowl Recreation Facilities, shows the recreational areas surrounding the Rose
Bowl Stadium.

The Rose Bowl Operating Company and Existing Lease Agreements

The Rose Bowl Stadium, golf course, and clubhouse are managed by the Rose Bowl Operating Company
(RBOC), a California non-profit, public benefit corporation, founded in 1995 by an act of the City Council.
Areas it manages include the Rose Bowl Stadium and Brookside Golf Course. Board members are
appointed by the City Council. The purpose of the RBOC is to enhance the economic and civic value of
the Rose Bowl as a world-class stadium and the Brookside Golf Course as a professional-quality course.
The other areas of the Central Arroyo – Area H and Brookside Park - are managed directly by the City of
Pasadena through its Public Works Department.

PROJECT OBJECTIVES

The following are the City’s objectives for the Temporary Use of the Rose Bowl by the NFL project:

 Generate revenue to fund City services and offset the costs associated with the Rose Bowl renovation
project.

 Promote economic development in the project area and greater Pasadena through increased event
activity and tourism.

 Conserve resources and avoid environmental impacts by utilizing existing infrastructure and parking
facilities.

 Utilize the existing parking supply and establish a parking management plan to distribute parking
consistent with arrival and departure directions to efficiently disperse project traffic, facilitate access

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to and from the site, and reduce traffic in the immediate vicinity to minimize potential
pedestrian/vehicular conflicts.

PROJECT CHARACTERISTICS

The Rose Bowl is currently limited by the Arroyo Seco Public Lands Ordinance of the City of Pasadena
Municipal Code to no more than 12 displacement events (attendance exceeding 20,000) per year. Such
events occur primarily on the weekends, although concerts, football championship (BCS) games, and
soccer events are often held during the week. The proposed project would amend the Ordinance to allow
an additional 13 displacement events to occur annually at the Rose Bowl Stadium for a total of
25 displacement events. Approximately seven events would continue to be reserved for UCLA football
games and up to two post-season collegiate games, including the Rose Bowl Game. Up to 13 events
would be reserved for the NFL with up to two games held on weeknights. The Rose Bowl would
continue to host other displacement events such as concerts and international soccer games with the total
number of displacement events not to exceed 25. This amendment would specifically be aimed at
allowing the NFL to use the Rose Bowl for a period of up to five years beginning no sooner than the
2013-2014 season. The use of the Rose Bowl by the NFL would be temporary until a new NFL stadium is
selected and built in the Los Angeles area, or until the completion of a five-year lease term, whichever
comes first.

In addition to displacement events, the monthly swap meet and flea market would continue to be held, as
would soccer and other games held in Lot H outside the stadium. There would be no change in the
number of minor events that could be held. Currently, approximately 30 events (including the monthly
flea market) with attendance between 2,000 and 20,000 are held each year.

The proposed project does not include any physical changes to the Rose Bowl Stadium or any of the
surrounding features. It would not increase or decrease the seating available at the stadium, or associated
parking. It does not include any ground disturbing or excavation activities, any interior or exterior
renovation to the Rose Bowl, or any new structures on the project site.

ALTERNATIVES TO THE PROJECT

CEQA requires that an environmental impact report (EIR) describe a range of reasonable alternatives to a
proposed project that could feasibly avoid or lessen any significant environmental impacts, while
attaining the basic objectives of the project. Comparative analysis of the impacts of these alternatives is
required. In response to the significant impacts associated with the proposed project, the City of
Pasadena developed and considered several alternatives to the project. These alternatives include:

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 Alternative 1 – No Project Alternative

The No Project Alternative assumes that an amendment to the Arroyo Seco Public Lands Ordinance
would not occur and that the number of displacement events allowed annually at the Rose Bowl
Stadium would continue to be 12.

 Alternative 2 – Reduced Attendance Alternative

The Reduced Attendance Alternative would reduce per event attendance by approximately one-
third, thereby allowing a maximum of 50,000 patrons at each event.

 Alternative 3 – Reduced Non-NFL Displacement Event Alternative

The Reduced Non-NFL Displacement Event Alternative would reduce the number of additional
displacement events from 13 to nine for a five-year period and would be restricted to non-NFL
events. These displacement events could be sports related, concerts, or other activities that have a
maximum attendance of 75,000 patrons.

The State CEQA Guidelines require that an environmentally superior alternative be identified from the
alternatives considered in an EIR. Both the Reduced Attendance Alternative (Alternative 2) and the
Reduced Non-NFL Alternative (Alternative 3) would reduce impacts associated with greenhouse gas
emissions and land use. Alternative 2, the Reduced Attendance Alternative, would reduce significant
impacts at intersections and street segments (compared to the proposed project). Alternative 2 would also
reduce particulate matter 10 microns or less in diameter (PM10) impacts associated with the proposed
project. Therefore, Alternative 2 is the environmentally superior alternative.

AREAS OF KNOWN CONTROVERSY

The State CEQA Guidelines require a Draft EIR to identify areas of controversy known to the lead agency,
including issues raised by other agencies and the public. Comments were received from public agencies
and interested parties in response to the circulated Notice of Preparation (NOP). In compliance with State
CEQA Guidelines, the City held two scoping meetings one on April 12, 2012 and a second scoping meeting
on April 14, 2012, at the Rose Bowl to solicit comments and to inform the public of the proposed EIR.
Comments received in response to the published NOP (provided in Appendix 1.0 of the Draft EIR)
identified environmental topics that local and regional agencies and City residents recommended for
analysis in the Draft EIR. These topics include:

 Air Quality  Recreation


 Greenhouse Gases  Noise
 Land Use  Transportation, Circulation and Parking
 Public Services  Cultural Resources

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ISSUES TO BE RESOLVED

The State CEQA Guidelines require an EIR to present issues to be resolved by the lead agency. These issues
include the choice between alternatives and whether or how to mitigate potentially significant impacts.
The major issues to be resolved by the City of Pasadena, as the Lead Agency for the project include the
following:

 Whether the recommended mitigation measures should be adopted or modified;

 Whether additional mitigation measures need to be applied to the project; and

 Whether the project or an alternative should be approved.

SUMMARY OF PROJECT IMPACTS

A summary of the environmental impacts associated with implementation of the proposed project,
mitigation measures included to avoid or lessen the severity of potentially significant impacts, and
residual impacts, is provided in Table 1.0-1, Summary of Project Impacts, Mitigation Measures, and
Residual Impacts, below.

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Table 1.0-1
Summary of Project Impacts, Mitigation Measures, and Residual Impacts

Significance Threshold and Project Impacts Mitigation Measures Residual Impact


None
Although they would not reduce any impacts associated with the MM 2.0-1 : RBOC shall be responsible for removal of all trash and debris Not applicable, no impact
project, the following measures MM 2.0-1 and MM 2.0-2 are associated with NFL events. Clean up shall commence within 24 hours of an was identified and the
proposed. NFL event and shall including all areas where patrons are directed to park measures are not
within the Central Arroyo. Clean up shall be conducted to the satisfaction of the associated with any
Department of Public Works. The RBOC shall provide funding as necessary. impact of the project.
MM 2.0-2 : After each NFL event at the Rose Bowl, RBOC shall be responsible
for visually inspecting parked areas for signs of oil, fluids, or other potentially
harmful substances within 24 hours of an NFL event. In the event such
substances are discovered, the soil shall be removed and disposed of in
accordance with applicable regulations. RBOC shall provide the City of
Pasadena Department of Public Works with a written summary of the visual
inspection and any necessary soil removal.
Air Quality
Impact 3.1-1: The project would not conflict with or obstruct No mitigation is required Less than significant
implementation of the applicable air quality plan
Impact 3.1-2: The project would generate total criteria pollutant MM 3.1-1: Any RFP for vendors to serve NFL events shall specify that the Significant and
emissions during construction or operation (direct and indirect) in vendor must utilize 2010 or later diesel trucks or alternatively fueled delivery unavoidable
excess of the thresholds given in Table 3.1-4, SCAQMD Regional trucks or demonstrate practices that will provide equivalent reduction of air
Emissions Significance Thresholds emissions compared to a typical vendor who does not use such equipment.
MM 3.1-2: Any maintenance vehicles or forklift purchased to serve NFL events
at the Rose Bowl shall be electric or use alternative fuel, provided that electric or
alternative fuel equipment is available.
MM 3.1-3 : Prior to the hosting of an NFL game at the Rose Bowl, the RBOC
shall provide electrical outlets in Lot I or nearby in Brookside Park to allow for
electric barbecues to be used by those who choose to tailgate and use portable
electric barbecues.
MM 3.1-4 : The RBOC shall ensure that cleaning products used to clean the Rose
Bowl and surrounding areas after NFL games are water based or low VOC
cleaning products
See Traffic Mitigation Measure MM 3.7-1 and MM 3.7-2,
Impact 3.1-3: The project would result in a cumulatively See Traffic Mitigation Measure MM 3.7-1 and MM 3.7-2, Significant and
considerable net increase of criteria pollutants for which the project unavoidable
region is non-attainment under an applicable federal or state ambient
air quality standard.

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Significance Threshold and Project Impacts Mitigation Measures Residual Impact


Impact 3.1-4: The project would not expose sensitive receptors to No mitigation is required Less than significant
substantial pollutant concentrations.
Greenhouse Gases
Impact 3.2-1: The proposed project would generate greenhouse gas No mitigation is required Less than significant
emissions as a result of the increased number of events at the Rose
Bowl Stadium but these emissions would not exceed the threshold of
4.8 MTCO2e per SP per year.
Land Use
Impact 3.3.1 The proposed project would not physically divide an No mitigation is required Less than significant
established community.
Impact 3.3.2 The proposed project would not conflict with No mitigation is required Less than significant
applicable land use plans.
Noise
Impact 3.4.1 The proposed project would expose persons to or See Traffic Mitigation Measure MM 3.7-1 and MM 3.7-2, Significant and
generate noise levels in excess of standards established in the local unavoidable
general plan or noise ordinance, or applicable standards of other
agencies.
Impact 3.4.2 The proposed project would not create a substantial No mitigation is required Less than significant
permanent increase in ambient noise levels in the project vicinity
above levels existing without the project.
Impact 3.3-3 The proposed project would create a substantial See Traffic Mitigation Measure MM 3.7-1 and MM 3.7-2, Significant and
temporary or periodic increase in ambient noise levels in the project unavoidable
vicinity that would exceed the City’s standards.
Public Services
Impact 3.5.1-1 The proposed project could increase demand for fire No mitigation is required Less than significant
protection services, but would not require the construction of new or
physically altered governmental facilities to accommodate the
increased demand and maintain acceptable fire flows.
Impact 3.5.2-1 The proposed project could affect police levels on No mitigation is required Less than significant
major event days, but would not require the construction of new or
physically altered police facilities to accommodate increased demand.

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Significance Threshold and Project Impacts Mitigation Measures Residual Impact


Recreation
Impact 3.6-1 The proposed project would not result in the physical MM 3.6-1 The RBOC or its designee shall ensure for the timely repair (repair With implementation of
deterioration of neighborhood or regional parks, or require the shall occur within 24 hours) of damaged Brookside Golf Course turf areas, and MM 3.6-1, impacts would
construction of new parks to accommodate demand. any other grassy areas (such as Lot H), that are damaged as a result of parking be less than significant
during NFL events. The RBOC shall ensure that all turf areas are returned to
playable/usable condition within one day of an NFL event. Prior to
commencement of the use of the Rose Bowl by the NFL, the RBOC shall
approve a plan for maintenance of damaged turf areas. The plan shall be
developed in coordination with the City and local golfers and include a
timetable detailing estimated time of repair and methodology for the repair of
the turf areas. RBOC shall be responsible for the costs of all repairs.
Impact 3.6-2 The proposed project would significantly interfere MM 3.6-2 In accordance with the provisions of the Santa Monica Mountains Passive recreational users
with existing recreational facilities in the Central Arroyo. Conservancy trail agreement dated January 10, 1985 (SMMC Grant), the RBOC and certain active
shall ensure access as required by the agreement. recreation users would
MM 3.6-3 RBOC shall notify residents and neighborhood associations of continue to be displaced
upcoming NFL games. A schedule of games shall be provided to nearby from the Rose Bowl area
residents, neighborhood associations and interested parties prior to the start of on event days. Impacts
each NFL season. associated with disruption
of recreational use within
MM. 3.6-4 The City and the NFL shall ensure, through provisions in the lease the Central Arroyo would
agreement, that the Tournament of Roses and Rose Bowl game activities will be
remain significant and
accommodated in a manner consistent with the traditional operating unavoidable.
circumstances, needs, and locations of Tournament activities.
MM 3.6-5 Prior to any NFL use of the Rose Bowl, the City shall develop a plan
for monitoring park use during event days and develop a strategy for repairing
or improving parks and recreational areas as necessary to address potential
increased usage on event days. The City shall be responsible for funding those
repairs and/or improvements.
Impact 3.6-3 The proposed project would expand recreational use at No mitigation is required Beneficial
the Rose Bowl by adding additional events, including NFL games.

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Significance Threshold and Project Impacts Mitigation Measures Residual Impact


Transportation, Circulation and Parking
Impact 3.7-1 Implementation of the proposed project would result MM 3.7-1 The following 22 significantly impacted intersections are projected Significant and
in significant impacts to intersections during weekday and weekend to operate at LOS C or better during both arrival (prior to event) and departure unavoidable
events. (post-event) under both the weekday or/and weekend Existing With Project and
Future With Project scenarios:
Intersection 1: San Rafael Avenue & SR-134 Freeway EB Ramps
Intersection 4: West Drive and Seco Street
Intersection 5: Rosemont Avenue and Washington Boulevard
Intersection 11: I-210 Freeway EB Ramps & Howard Street
Intersection 12: Lincoln Avenue & I-210 Freeway WB Ramps
Intersection 19: I-210 Freeway WB Ramps & Berkshire Place
Intersection 20: Linda Vista Avenue & Highland Drive
Intersection 21: Linda Vista Avenue & Oak Grove Drive
Intersection 23: North Arroyo Boulevard/Windson Avenue & Woodbury Road
Intersection 24: Arroyo Boulevard & Lower Arroyo Park Entrance
Intersection 25: Arroyo Boulevard & California Boulevard
Intersection 30: St. John Avenue & Colorado Boulevard
Intersection 31: Pasadena Avenue & Union Street
Intersection 32: Pasadena Avenue & Colorado Boulevard
Intersection 39: Lincoln Avenue & Woodbury Road
Intersection 40: Fair Oaks Avenue & Woodbury Road
Intersection 41: Lincoln Avenue & Washington Boulevard
Intersection 45: St. John Avenue/I-210 Eastbound Off-Ramp & Walnut Street
Intersection 46: Pasadena Avenue/I-210 Westbound On-Ramp & Walnut Street
Intersection 50: Arroyo Parkway & Union Street
Intersection 61: St. John Avenue & Del Mar Boulevard
Intersection 62: Pasadena Avenue & Del Mar Boulevard

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Transportation, Circulation and Parking (continued)
MM 3.7-1 (continued)
Proposed Project Feature: Out of the aforementioned 22 intersections, the
following 11 intersections will either be supplemented with a traffic control
officer (TCO) to prioritize event traffic flow through the intersection or will
operate under an optimized traffic signal timing plan to prioritize peak event
traffic flow:
Traffic Control Office Post*
Intersection 1: San Rafael Avenue & SR-134 Freeway EB Ramps
Intersection 4: West Drive and Seco Street
Intersection 5: Rosemont Avenue and Washington Boulevard
Intersection 24: Arroyo Boulevard & Lower Arroyo Park Entrance
Intersection 25: Arroyo Boulevard & California Boulevard
Intersection 41: Lincoln Avenue & Washington Boulevard
Traffic Signal Optimization
Intersection 31: Pasadena Avenue & Union Street
Intersection 32: Pasadena Avenue & Colorado Boulevard
Intersection 41: Lincoln Avenue & Washington Boulevard
Intersection 45: St. John Avenue/I-210 Eastbound Off-Ramp & Walnut Street
Intersection 46: Pasadena Avenue/I-210 Westbound On-Ramp & Walnut Street
*Appendix A of the traffic study includes details of changes in lane configuration at
some of the intersection where a TCO is deployed during arrival or/and departure of
event traffic.

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Transportation, Circulation and Parking (continued)
MM 3.7-1 (continued)
Mitigation Measures for intersections operating at LOS D, E, and F
The following 38 significantly impacted intersections are projected to operate at
LOS D, E or F during either/both arrival (prior to event) and departure (post-
event) under the weekday or/and weekend Existing With Project and Future
With Project scenarios:
Intersection 2: San Rafael Avenue & SR-134 Freeway WB Ramps
Intersection 3: West Drive and Salvia Canyon Road
Intersection 6: Rosemont Avenue and Seco Street
Intersection 7: Orange Grove Boulevard & Holly Street/I-210 Freeway WB Off-
Ramp and EB On-Ramp
Intersection 8: Orange Grove Boulevard & SR-134 Freeway EB Off-Ramp and
WB On-Ramp/Colorado Boulevard
Intersection 9: North Arroyo Boulevard & I-210 Freeway WB Ramps
Intersection 10: North Arroyo Boulevard & I-210 Freeway EB Ramps
Intersection 13: I-210 Freeway EB Ramps & Mountain Street
Intersection 14: I-210 Freeway WB Ramps & Mountain Street
Intersection 18: I-210 Freeway EB Ramps & Berkshire Place
Intersection 26: Orange Grove Boulevard & California Boulevard
Intersection 27: Arroyo Parkway & California Boulevard
Intersection 28: Pasadena Avenue & California Boulevard
Intersection 29: St. John Avenue & California Boulevard
Intersection 34: Fair Oaks Avenue & Walnut Street
Intersection 35: Fair Oaks Avenue & Union Street
Intersection 36: Pasadena Avenue & Colorado Boulevard
Intersection 37: Fair Oaks Avenue & Green Street
Intersection 38: Arroyo Parkway & Colorado Boulevard
Intersection 43: Lincoln Avenue & Mountain Street/Seco Street
Intersection 44: Fair Oaks Avenue & Mountain Street
Intersection 47: Fair Oaks Avenue & Orange Grove Boulevard
Intersection 48: Fair Oaks Avenue & Maple Street/I-210 Westbound Ramps/SR
134 Westbound Ramps

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Transportation, Circulation and Parking (continued)
MM 3.7-1 (continued)
Intersection 49: Fair Oaks Avenue & Corson Street/SR 134 Eastbound Ramps
Intersection 51: Linda Vista Avenue & Holly Street
Intersection 52: Arroyo Parkway & Del Mar Boulevard
Intersection 53: Fair Oaks Avenue & California Boulevard
Intersection 54: Fair Oaks Avenue & Glenarm Street
Intersection 55: Arroyo Parkway & Glenarm Street
Intersection 56: Fair Oaks Avenue & I-110 Southbound On-Ramp/State Street
Intersection 57: Fair Oaks Avenue & I-110 Northbound Off-Ramp/Grevalia
Street
Intersection 58: Orange Grove Avenue & I-110 Southbound Ramps
Intersection 59: Orange Grove Avenue & I-110 Northbound Ramps
Intersection 60: Orange Grove Avenue & Del Mar Boulevard
Intersection 63: Fair Oaks Avenue & Del Mar Boulevard
Intersection 64: Orange Grove Avenue & Columbia Street
Intersection 65: Pasadena Avenue/Fremont Avenue & Columbia
Intersection 66: Fair Oaks Avenue & Columbia Street
Proposed Project Feature: As part of the proposed project traffic operations
plan, out of the aforementioned 38 intersections, the following 23 intersections
will either be deployed with a TCO to prioritize event traffic flow through the
intersection or will operate under an optimized traffic signal timing plan to
prioritize peak event traffic flow:
Traffic Control Office Post*
Intersection 2: San Rafael Avenue & SR-134 Freeway WB Ramps
Intersection 3: West Drive and Salvia Canyon Road
Intersection 6: Rosemont Avenue and Seco Street
Intersection 7: Orange Grove Boulevard & Holly Street/I-210 Freeway WB Off-
Ramp and EB On-Ramp
Intersection 8: Orange Grove Boulevard & SR-134 Freeway EB Off-Ramp and
WB On-Ramp/Colorado Boulevard

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Transportation, Circulation and Parking (continued)
MM 3.7-1 (continued)
Intersection 9: North Arroyo Boulevard & I-210 Freeway WB Ramps
Intersection 10: North Arroyo Boulevard & I-210 Freeway EB Ramps
Intersection 26: Orange Grove Boulevard & California Boulevard
Intersection 43: Lincoln Avenue & Mountain Street/Seco Street
Intersection 51: Linda Vista Avenue & Holly Street
Intersection 53: Fair Oaks Avenue &California Boulevard
Intersection 54: Fair Oaks Avenue & Glenarm Street
Intersection 60: Orange Grove Avenue & Del Mar Boulevard
Intersection 63: Fair Oaks Avenue & Del Mar Boulevard
Intersection 64: Orange Grove Avenue & Columbia Street
Traffic Signal Optimization
Intersection 34: Fair Oaks Avenue & Walnut Street
Intersection 35: Fair Oaks Avenue & Union Street
Intersection 36: Pasadena Avenue & Colorado Boulevard
Intersection 37: Fair Oaks Avenue & Green Street
Intersection 44: Fair Oaks Avenue & Mountain Street
Intersection 47: Fair Oaks Avenue & Orange Grove Boulevard
Intersection 48: Fair Oaks Avenue & Maple Street/I-210 Westbound Ramps/SR
134 Westbound Ramps
Intersection 49: Fair Oaks Avenue & Corson Street/SR 134 Eastbound Ramps
*Appendix A of the traffic study includes details of changes in lane configuration at
some of the intersection where a TCO is deployed during arrival or/and departure of
event traffic.
In addition, it is recommended that traffic management strategies, including a
program of operational improvements be employed as mitigation to help
manage demand and improve traffic operations over and above the changes
currently proposed as part of project’s traffic operations plan.
The operational improvements include priority or additional roadway capacity
for certain traffic movements to or from the Rose Bowl during arrival or
departure of event traffic. To quantitatively account for the benefit of proposed
mitigations, additional capacity has been applied to the prioritized movements
in the V/C and LOS analysis under the “with mitigations” scenarios. Reduced
capacities have been applied to non-prioritized movements, reflecting the
priority that would be transferred to other movements

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Transportation, Circulation and Parking (continued)
MM 3.7-2: Unless on-the-ground conditions (e.g., traffic accidents or other
unanticipated traffic events) require the Pasadena Police Department to deviate
from these specific mitigation measures and implement alternative traffic
control measures, the traffic operations plan shall include, and the City shall
implement, the following intersection-specific mitigation measures:
Intersection #8 Orange Grove Boulevard and SR-134 Freeway EB Off-Ramp
and WB On-Ramp/Colorado Boulevard – As an additional improvement over
and above the aforementioned traffic operations plan, the westbound right
turns from Colorado Boulevard would be allowed to operate as free-flow with
the provision of an additional receiving lane on northbound Orange Grove
Boulevard using traffic cones.
Intersection #9 North Arroyo Boulevard and I-210 Freeway WB Ramps –
During the peak hour for departure traffic after a game, this intersection’s signal
would be placed in flash mode and manually controlled by a TCO to prioritize
the northbound traffic from Rosemont Avenue onto the I-210 freeway
westbound on-ramp. This intersection would be operated using way-finding
signage and traffic cones to allow left turns from both the northbound left-turn
lane and adjacent through lane.
Intersection #10 North Arroyo Boulevard and I-210 Freeway EB Ramps – As
an additional improvement over and above the aforementioned traffic
operations plan, the northbound approach at this location would operate as two
through lanes and an exclusive right-turn lane using traffic cones
Intersection 13# I-210 Freeway EB Ramps and Mountain Street – During the
peak hour for arrival traffic before a game, this intersection would be manually
controlled by a TCO to prioritize westbound traffic on Mountain Street.
During the peak hour for departure traffic after a game, this intersection would
be operated to allow three lanes of eastbound traffic with one free flow right-
turn lane onto the I-210 westbound on-ramp, one shared through/right-turn
lane and one through lane using traffic cones. During egress, pedestrian
movement at the intersection impacts the flow of vehicles. A TCO is
recommended to control pedestrian movement and facilitate the flow of
vehicular traffic.
Intersection #14 I-210 Freeway WB Ramps and Mountain Street – During the
peak hour for arrival traffic before a game and departure traffic after a game,
this intersection would be manually controlled by a TCO to improve traffic flow
and coordinate with operations at adjacent intersection #13 – I-210 Freeway
Eastbound Ramps and Mountain Avenue.

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Transportation, Circulation and Parking (continued)
MM 3.7-2: (continued)
Intersection #34 Fair Oaks Avenue & Walnut Street – In addition to the
traffic signal optimization by the City of Pasadena Traffic Management Center
(TMC) as part of the proposed Project traffic operations plan, eastbound left
turns off the freeway would be allowed from both the left-turn lane and the
adjacent through lane using way-finding signage and traffic cones.
Intersection #49 Fair Oaks Avenue & Corson Street/SR 134 Eastbound
Ramps – The northbound right-turn lane would operate as a free-flow right-
turn lane onto the Corson Street using traffic cones. The eastbound approach
would operate as one left-turn lane, one shared through/left-turn lane, and two
right-turn lanes.
Intersection #53 Fair Oaks Avenue & California Boulevard – This
intersection’s signal would be manually controlled by a TCO to provide
additional green time to northbound traffic during the peak hour for arrival
traffic before a game and southbound traffic during the peak hour for departure
traffic after a game.
Intersection #54 Fair Oaks Avenue & Glenarm Street – This intersection’s
signal would be manually controlled by a TCO to provide additional green time
to northbound traffic during the peak hour for arrival traffic before a game and
southbound traffic during the peak hour for departure traffic after a game.
Intersection #56 Fair Oaks Avenue & I-110 Southbound On-Ramp/State Street
– This intersection’s signal would be manually controlled by a TCO to provide
additional green time to northbound traffic during the peak hour for arrival
traffic before a game and southbound traffic during the peak hour for departure
traffic after a game.
Intersection #57 Fair Oaks Avenue & I-110 Northbound Off-Ramp/Grevalia
Street – During the peak hour for arrival traffic before a game, this intersection's
signal would be placed in flash mode and manually controlled by a TCO. The
northbound off-ramp would operate as one left-turn lane and one shared
left/through/right-turn lane onto Fair Oaks Avenue. No mitigation measure has
been identified for the departure peak hour after a game.

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Transportation, Circulation and Parking (continued)
MM 3.7-2: (continued)
In addition to the operational improvements recommended in Mitigation
Measure 3.7-2, a transportation demand management program might further
reduce impacts to a small and not quantifiable extent by encouraging the use of
transportation other than automobiles, encouraging ride sharing, and increasing
the efficiency by which vehicles could be moved off of streets and into the Rose
Bowl parking lots. Therefore, a transportation demand management program is
recommended as Additional Measure 3.7-2.1. However, as the success of this
program is neither guaranteed nor quantifiable, no credit for reducing impacts
has been calculated as a result of this recommended measure and it is not
considered to be mitigation. Additionally, some flexibility has been provided to
coordinate measures with the future team that would play football at the Rose
Bowl and to be able to adjust programs based on whether any individual
incentive or implementation measure is proving successful.
AM 3.7-2.1: The RBOC, in conjunction with the tenant, shall implement a
transportation demand management program that shall incorporate the
following elements to promote ride sharing, alternative forms of transportation,
and to maximize the efficiency of vehicle travel.
Incentivize Carpooling
Develop and implement incentives for carpools of four or more persons per car,
and incentives for alternative fuel vehicles. Incentives may include, without
limitation, preferential parking, reduced parking costs, or other discounts.
Pre-paid Parking Program
Provide pre-paid parking options. The use of pre-paid parking passes could
increase the throughput for vehicles at the Rose Bowl parking entrances by
eliminating the need to collect parking fees at critical access points to the
stadium from those vehicles with pre-paid parking, thus improving traffic
operations.
Bicycle Valet at Parsons
Provide a bicycle valet parking service at the Parson’s parking lot. Spectators
may valet park their bicycles and ride on the shuttle bus to/from the Rose Bowl.
This would incentivize the use of bicycles as a mode of travel to/from the event
and help reduce the number of vehicular trips.
Charter Bus
Solicit interest in charter bus service from season ticket holders, groups and
other potential users and provide charter bus service from locations such as
downtown and neighboring cities in response to demand. The service will
include the concept of “park-and-ride,” which will encourage event patrons to
leave their vehicles and transfer on to a charter bus for the remainder of the
journey. Rose Bowl will encourage charter bus service by providing drop off for
passengers in preferred areas close to the stadium.

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Transportation, Circulation and Parking (continued)
AM 3.7-2.1: (continued)
Rideshare Program for Employees
The RBOC will implement a Rideshare program for employees.
Temporary Changeable Message Signs
The use of temporary changeable message signs is already employed at
different locations around the Rose Bowl. Expand the use of temporary
changeable message signs to include two changeable message signs along the I-
210 or/and SR-134, depending on traffic demands, to help facilitate
ingress/egress on game days.
Way Finding Signage for Transit Patron
The City of Pasadena and RBOC will work together with Metro to install way-
finding signage to guide patrons to/from the Gold Line Memorial Park Station
and the shuttle bus pick-up/drop-off location.
Use of Social Media
Use social media to communicate current information regarding directions
to/from the Rose Bowl from regional freeways and roadways, preferred routes
to various parking lots, and detailed information regarding potential modes of
travel other than passenger vehicles to/from the Rose Bowl (rail/bus/shuttle
routes, timetables, etc.).
Impact 3.7-2 Implementation of the proposed project would result No feasible mitigation exists to reduce this impact Significant and
in significant impacts to street segments during weekday and unavoidable
weekend events.
Impact 3.7-3 Implementation of the proposed project would not No mitigation is required Less than significant
adversely affect pedestrian and bicycle facilities during events.
Impact 3.7-4 Implementation of the proposed project could MM 3.7-3 To mitigate the potential impact to the regional transit system, it is Significant and
adversely affect transit systems on event days. recommended that Metro increase transit service to meet the demand of both unavoidable
commuter peak hour transit ridership, as well as the demand generated from
the project. Since this mitigation measure is the responsibility of another
jurisdiction, it is recommended that the City of Pasadena provide information to
Metro in order to determine the level of transit service that is adequate to meet
game day demands
Impact 3.7-5 Implementation of the proposed project would result The Traffic Command Center shall coordinate with PPD, PDOT, and Caltrans to Significant and
in significant impacts to CMP intersections. place two changeable message signs along the I210 or/and SR-134 to help unavoidable
facilitate ingress/egress on game days. However, given the volume of traffic
that would utilize the freeways, there is no feasible operational mitigation
measure that could fully mitigate the project’s potential for impacts.

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Transportation, Circulation and Parking (continued)
Impact 3.7-6 Parking demand for weekday events could exceed MM 3.7-5 Parking operators shall monitor parking demand on game days to Less than significant
supply; however impacts can be mitigated. ensure sufficient supply is available to meet parking demand around the Rose
Bowl. If excess parking demand is anticipated, stacked parking will be
implemented as needed in one or more of the following parking lots to ensure
that there is sufficient supply to meet demand:
Lot H, Lot BD 2 & 3, Lot 1 A, Lot 1, Lot 2, Lot 3, Lot 4, Lot 5, Lot 6, Lot 7, Lot 8A,
Lot 9, Lot 10
The use of stacked parking at these lots can increase parking supply by up to
approximately 3,000 spaces.
MM 3.7-6 Parking and traffic management staff for the Rose Bowl will
implement all traffic and parking control plans for NFL game days, as are
implemented for other events at the Rose Bowl to monitor and direct traffic to
minimize spillover parking and other disruptions to residential neighborhoods
adjacent to the Rose Bowl.

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3.0 COMMENT LETTERS AND RESPONSES

INTRODUCTION

According to the California Environmental Quality Act (CEQA) Guidelines, Section 15132), the Final EIR
shall consist of the following items: (1) the Draft EIR or a revision of the Draft, (2) comments and
recommendations received on the Draft EIR, (3) a list of persons, organizations and public agencies
commenting on the Draft EIR, (4) the responses of the Lead Agency to significant environmental points
raised in the review and consultation process, and (5) any other information added by the lead agency.
Item 1 is provided as Section 2.0 Corrections and Additions to the Draft EIR of this document.

The Draft EIR was submitted to the State Clearinghouse Office of Planning and Research and circulated
for public review on August 9, 2012. The 60-day comment period concluded on October 8, 2012.
Comment letters received after this date were also accepted and are included in this Final EIR.

A total of 65 comment letters were received. A list of commenters is shown on the following pages. The
comment letters have been numbered and organized into the following categories:

 Topical Responses

 State and Local Agencies

 Private and Local Organizations

 Individuals

The original bracketed comment letters are provided followed by a numbered response to each bracketed
comment. Individual comments within each letter are numbered and the response is given a matching
number. Where responses result in a change to the Draft EIR, it is noted, and the resulting change is
identified in Section 2.0 Corrections and Additions.

LIST OF PUBLIC AGENCIES AND PRIVATE PARTIES COMMENTING ON THE


DRAFT EIR

Topical Responses
Topical Response 1 – Adequacy of Project Description
Topical Response 2 – Historic Resources

State and Local Agencies


Letter No. 1. State of California, Native American Heritage Commission, August 16, 2012
Letter No. 2. South Coast Air Quality Management District, October 10, 2012
Letter No. 3. Metropolitan Transportation Authority, October 8, 2012

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3.0 Responses to Comments

Private and Local Organizations

Letter No. 4. Pasadena Chamber of Commerce, September 17, 2012


Letter No. 5. Pasadena Heritage, September 14, 2012
Letter No. 6. City of Pasadena, Transportation Advisory Commission, October 5, 2012
Letter No. 7. West Pasadena Residents Association, October 8, 2012
Letter No. 8. Linda Vista-Annandale Association, October 8, 2012
Letter No. 9. West Pasadena Residents Association, October 1, 2012
Letter No. 10. San Rafael Neighborhoods Association, October 7, 2012
Letter No. 11. Planning Commissioner Vince Farhat, September 23, 2012
Letter No. 12. Planning Commission Meeting, Commissioner Comments, September 19, 2012
Letter No. 13. Transportation Advisory Commission Meeting - Commissioner Comments, October 2,
2012
Letter No. 14. Recreation and Parks Commission Meeting – Commissioner Comments, October 4, 2012

Individuals

Letter No. 15. Planning Commission Meeting – Resident Comments, September 19, 2012
Letter No. 16. Transportation Advisory Commission Meeting – Public Comments, September 27, 2012
Letter No. 17. Recreation and Parks Commission Meeting – Public Comments, October 2, 2012
Letter No. 18. S. Robert Snodgrass, October 8, 2012
Letter No. 19. Mary Alexander, October 8, 2012
Letter No. 20. Eunice Bae, October 4, 2012
Letter No. 21. Adele Baquet, October 7, 2012
Letter No. 22. Kristina Bell-Marinescu, August 13, 2012
Letter No. 23. Don Bremner, October 8, 2012
Letter No. 24. John Boyle, October 3, 2012
Letter No. 25. Petrea Burchard, October 5, 2012
Letter No. 26. Cabreira-Johnson Family, September 24, 2012
Letter No. 27. Samir Das, October 1, 2012
Letter No. 28. Michael Duran, September 9, 2012
Letter No. 29. Michael Duran, October 8, 2012
Letter No. 30. Eleanor Edwards, October 8, 2012
Letter No. 31. Barbara Ellis, October 8, 2012
Letter No. 32. Gregory Fu, October 8, 2012
Letter No. 33. Loring Guessous, October 2, 2012
Letter No. 34. Gary Hackney, October 7, 2012
Letter No. 35. Ron Hemingway, August 21, 2012
Letter No. 36. Jenna Kachour, September 13, 2012
Letter No. 37. Guido Meindl, August 11, 2012
Letter No. 38. Gloria Morrison, September 10, 2012
Letter No. 39. Lorig Mushegain, September 13, 2012
Letter No. 40. Arundhati Nag, October 1, 2012
Letter No. 41. Dianne K. Newman, August 15, 2012
Letter No. 42. Dianne K. Newman, October 7, 2012
Letter No. 43. Dianne K. Newman, TAC Comments, September 27, 2012
Letter No. 44. JoAnn Newman, August 16, 2012

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3.0 Responses to Comments

Letter No. 45. Steve Onderdonk, September 10, 2012


Letter No. 46. Susann Perry, August 19, 2012
Letter No. 47. Jonas Peters, August 15, 2012
Letter No. 48. Jonas Peters, October 8, 2012
Letter No. 49. Jonas Peters, TAC Comments, September 27, 2012
Letter No. 50. Sylvia Plummer, October 8, 2012
Letter No. 51. Ann Scheid, October 2, 2012
Letter No. 52. Joy Selby, September 10, 2012
Letter No. 53. Leland Sklar and Maureen Gay McGillan-Sklar, October 1, 2012
Letter No. 54. Bob Snodgrass, September 17, 2012
Letter No. 55. Bob Snodgrass, TAC Comments, September 27, 2012
Letter No. 56. Patrick Theofanis, October 1, 2012
Letter No. 57. Andrea Totten, September 27, 2012
Letter No. 58. Unknown, August 15, 2012
Letter No. 59. Susann Walker-Perry, September 10, 2012
Letter No. 60. Michele Zack, October 8, 2012
Letter No. 61. Christy Zamani, October 8, 2012
Letter No. 62. Barbara Zimmerman, October 8, 2012
Letter No. 63. Madhu Kumar, October 10, 2012
Letter No. 64. Online Petition from Change.org

Jonas C. Peters, Pasadena, CA Sarah Gavit, Pasadena, CA


Adele Baquet, Sierra Madre, CA Sally K Conn, Pasadena, CA
Andre de Salis, Pasadena, CA Eleanor Edwards, Pasadena, CA
Rosalind Oliver, Altadena, CA Tita Hutchison, South Pasadena, CA
Loring Guessous, Pasadena, CA Grant Delgatty, Pasadena, CA
Bernard Goldsen, Pasadena, CA Gail Lovejoy, Pasadena, CA
Maribeth Swegal, Pasadena, CA Amy McReynolds, Carbondale, IL
Porter Harris, Altadena, CA Barbara Ellis, Pasadena, CA
Petrea Sandel, Pasadena, CA James Grimes, Pasadena, CA
Kristen Chew, Pasadena, CA Therese Brummel, Pasadena, CA
Rosemary Stevens, Pasadena, CA Christopher Cunningham, Pasadena, CA
Lisa Tush, Pasadena, CA Joanne Siegel, Pasadena, CA
Douglas Rees, Arcadia, CA Miles Scott, Pasadena, CA
Tamara Brown, Pasadena, CA Mary Fitzgerald, Pasadena, CA
Roarke Horstmeyer, San Marino, CA Susan Campisi, Altadena, CA
Bob Browne II, Burbank, CA Franklin Miller, Reno, NV
Sharon McTigue, Pasadena, CA Sandra Schneider, Moorpark, CA
Elizabeth Garrison, Los Angeles, CA Jane Barger, Glendale, CA
Pietro Perona, Altadena, CA Dharam Damama Khalsa, Los Angeles, CA
Alix Reeves, Pasadena, CA Kathleen Smith-Miller, Reno, NV
Whitney Chandler, Pasadena, CA Helen Segal, Pasadena, CA
Clark Pardee, Studio City, CA Michael Herndo, Quincy, CA
Julie Lee, La Canada, CA Artemis Ailianou, Pasadena, CA
Ann Burke, Pasadena, CA Robert Campbell, Altadena, CA
Gina Samartin, Pasadena, CA Devin Wiley, Pasadena, CA

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3.0 Responses to Comments

William Bogle, Pasadena, CA Andrew Wang, Pasadena, CA


John Perotta, Pasadena CA Tulia Vazquez, Los Angeles, CA
Vanessa Walker-Oakes, Pasadena, CA Mark Harfouche, Pasadena, CA
Evan Miyazono, Pasadena, CA Samuel Adams, Glendale, CA
Zach Tobin, Pasadena, CA Emily Hamecher, Pasadena, CA
Madeleine Kieffer, Pasadena, CA Anupama Thubagere, Pasadena, CA
Cindy Tran, Minneapolis, MN Robert Buchman, Pasadena, CA
Magnus Haw, Altadena, CA Chan Y. Park, Pasadena, CA
Dagny Fleischman, Pasadena, CA Joel Buchman, Pasadena, CA
Kayla Truong, Pomona, CA Yunung Lin, Pasadena, CA
Michael Davis, Pasadena, CA Nicholas Scianmarello, Pasadena, CA
Emily Warren, Pasadena, CA Brian HE, Pasadena, CA
Muhammed Mujeeb-U-Rahman, Pasadena, CA Matthew Kelley, Pasadena, CA
Bassam Helou, Pasadena, CA Michiel Niesen, Monrovia, CA
Nadia Herrera, Pasadena, CA Rachel Miller, Pasadena, CA
Arundhati Nag, Pasadena, CA Sandra Kulli, Pasadena, CA
Kangway Chuang, Pasadena, CA Nancy Neville, Louisville, KY
Marcella Gomez, Pasadena, CA Andrew Nickel, San Marino, CA
Samir Das, Pasadena, CA Bethany Ehlmann, Pasadena, CA
Anna Chen, Pasadena, CA Amanda Verderese, Towanda, PA
Bogdan Soica, Pasadena, CA Grady Youngblood, Fort Lauderdale, FL
Alejandro Lopez Ortega, Pasadena, CA Alyssa Zetzius, Pasadena, CA
Stephanie, Culler, Pasadena, CA Erika Oller, Pasadena, CA
Sushant Sundaresh, Pasadena, CA Susan Clark, Pasadena, CA
Brett Babin, Pasadena, CA Gwen Gordon, Sierra Madre, CA
Brooke Dallas, Pasadena, CA Christina Wallerstein, Pasadena, CA
Glenn Hair, Pasadena, CA Virginia Paca, Pasadena, CA
Jonathan Schwarzkopf, Pasadena, CA Lynda Obershaw, Pasadena, CA
Kevin Shen, Pasadena, CA Jean Blasiar, Pasadena, CA
Kevin Fiedler, Sierra Madre, CA Mei-Lee Ney, Pasadena, CA
Maayan Schwarzkopf, Pasadena, CA Alex Krause, Pasadena, CA
Tal Einav, Pasadena, CA Toni Lee, Los Angeles, CA
Nicole Czakon, Pasadena, CA Pablo Guerrero, Pasadena, CA
Yulia Tolstova, Pasadena, CA John Pineda, Pasadena, CA
Timothy Wannier, Pasadena, CA Nicholas Swisher, Pasadena, CA
Gretchen Aleks, Pasadena, CA Ron Appel, Pasadena, CA
Hemant Bajaj, Chino Hills, CA Rangoli Sharan, Pasadena, CA
Emily Lin, Pasadena, CA Sara Dougherty, Pasadena, CA
Ann Marie Cody, Pasadena, CA Danielle Bower, Pasadena, CA
Baoging Zhou, Goleta, CA Georg Kaltenboeck, Pasadena, CA
Niangjun Chen, Pasadena, CA Leo Singer, Pasadena, CA
Konstantin Batygin, San Gabriel, CA Utkarsh Mital, Pasadena, CA
Jeffrey Holder, Pasadena, CA Bryan Schmidt, Pasadena, CA
Sean Symon, Pasadena, CA Kyle Carlson, Pasadena, CA
BellaDonna Iodice, Rochester, NY Portia Harris, Altadena, CA
Kelly Kim, Pasadena, CA Jomela Meng, Pasadena, CA
Sonja Spasojevic, Houston, TX Betty Wong, Pasadena, CA
David Abrecht, Pasadena, CA Harry Choi, Pasadena, CA

Impact Sciences, Inc. 3.0-4 Temporary Use of the Rose Bowl by the NFL
1136.001 November 2012
3.0 Responses to Comments

Ajay Limaye, Pasadena, CA Jon Gilutin, Los Angeles, CA


Scott Roberts, Pasadena, CA Nigel Taylor, Ventura, CA
Josh Wiensch, Pasadena, CA Mark Stears, Findlay, OH
Emily Kosten, Pasadena, CA Finn Engen, Toensberg, Norway
Amanda Shing, Pasadena, CA Colleen Bates, Pasadena, CA
Victoria Tang, Pasadena, CA Patty Silversher, Glendale, CA
Marcello Gori, Pasadena, CA Luke Clarke, Cutchogue, NY
Jin Park, San Marino, CA Randi Massengill, Hopkins, SC
Janet Chow, Pasadena, CA Melina Root, Pasadena, CA
Michael Bottom, Pasadena, CA Michael Duran, Pasadena, CA
Tina Bao, San Jose, CA Song Ryu Geist, Pasadena, CA
Joe Levine Pasadena, CA Deborah Kusber, Campbell, CA
Alma Gharib, Altadena, CA Joyce Macormac, Azusa, CA
Anna Basaloca Buchman, Pasadena, CA Heather Shadrick, Camelford, UK
Patrick Theofanis, Pasadena, CA Mark E. Miller, Alameda, CA
Prakhar Mehrotra, Pasadena, CA Emily Anderson, Pasadena, CA
Stephan Wu, Arcadia, CA Jean Grinois, Pasadnea, CA
Jonathan Sternberg, Pasadena, CA Emily Bates, Pasadena, CA
Eric Olman, Pasadena, CA Harry Hall, Los Angeles, CA
Mehmet Hanay, Pasadena, CA Tim Salmon, Signal Mountain, TN
Subrahmanyam Duvvuri, Pasadena, CA Sylvia Plummer, Pasadena, CA
Patrick Sanan, Pasadena, CA Cynthia Crosswhite, Pasadena, CA
Manuel Lombardini, Pasadena, CA Melanie Baker, Sierra Madre, CA
Yasha Vilenchik, Pasadena, CA Cathleen Scott, Pasadena, CA
Jennifer Zelaya, South Pasadena, CA Patrick Briggs, Pasadena, CA
Cristofer Flowers, Pasadena, CA Robert Adams, Pasadena, CA
Matanya Horowitz, Pasadena, CA Karen Berger, Montrose, CA
Yoke Peng Leong, Pasadena, CA Helen Tolen, Vallejo, CA
Erik Schomburg, Pasadena, CA Bruce Greenspan, Malibu, CA
Alexis Sklarevski, Los Angeles, CA Robin Cox, Hamburg, NY
Christopher Grener, Syracuse, NY Jochem van Rooijen, Amsterdam, Netherlands
Ronald Presley, Austin, TX Edwin White, Orlando, FL
Dennis Rambo, Bridgeport, PA Alan Steinberger, La Crescenta, CA
Randall Riggs, Pasadena, CA Xavier de la Torre, Whittier, CA
Alice Finch, Mercer Island, WA Kevin Munro, Brechin, Canada
Shirley Gray, Pasadena, CA John P, Hermosa Beach, CA
Robert Lawhorne, Lafayette, IN Christopher Amistadi, Templeton, MA
Kyle Ahlers, Ashland, MA Rick Metz, Lake Oswego, OR
Adam Levine, Paso Robles, CA Brent Brooks, Burbank, CA
Catherine Adde, Pasadena, CA Johan Smeets, Geleen, Netherlands
Agnes Tong, Alhambra, CA Tony Salinas, Bastrop, TX
Shana Goffredi, Pasadena, CA Brian Ill, Pasadena, CA
David Hasty, Calhoun, GA Adam Ross, Australia
J.M.C. Aldenhoven, Maastricht, Netherlands Herve Le Duc, Rennes, France
Todd Schurdell, Embudo, NM Clint Bahr, New York City, NY
Cynthia Vail, Pasadena, CA Mary Gavel-Briggs, Pasadena, CA
David Abrams, Santa Monica, CA Cathy Thornburn, Los Angeles, CA
Steve Elkins, Pasadena, CA Kit Carson, Newport Beach, CA

Impact Sciences, Inc. 3.0-5 Temporary Use of the Rose Bowl by the NFL
1136.001 November 2012
3.0 Responses to Comments

Artie Breslin, Belle Chasse, LA Diane Bercaw, Pasadena, CA


John Axelrad, Glendale, CA Layne Russell, Redding, CA
Cherie Whitaker, Simi Valley, CA Todd Binkley, Nashville, TN
Sarah Taylor, Sherman Oaks, CA David Sosa, North Hills, CA
Greg Fu, Pasadena, CA Carol Nigsarian, Pasadena, CA
Donna Grotzinger, San Marino, CA Steve Bolton, Hemet, CA
Ara Oshagan, Glendale, CA Lou Gonzalez, Henderson, NV
Marie Gauthier, Montreal, Canada Andrea Farber, Los Angeles, CA
Bruce Lieberman, Garden Grove, CA Johnny Clark, La Crescenta, CA
Liana Alexakis, Pasadena, CA Mary Davis, Pasadena, CA
Dawn Rosenquist, Ottawa, CA John Richard Young, East Norriton, PA
Bernhard Jobst, Vienna, Austria Patty Albert-Leis, Ojai, CA
Ken Farley, Pasadena, CA Doerte Lindner, Pasadena, CA
Victoria Orphan, Pasadena, CA Victoria Brennan, Glendora, CA
Robert Levy, New Haven, CT Benjamin Schwarz, South Pasadena, CA
Ed Lucie, Encino, CA TF Bernett, Studio City, CA
Zhen-Gang Wang, La Canada, CA Cat Quill, Culver City, CA
Donna Gerry, Pasadena, CA Jeffrey Vanston, Studio City, CA
Norma Clifford, Pasadena, CA Dianne Newman, Pasadena, CA
Leonard Levenda, Rehoboth, MA Sarah Reisman, San Marino, CA
Gale Kohl, Pasadena, CA Eldon Kottwitz, Platte City, MO
Douglas Gerry, Pasadena, CA Robin Stewart, Mission Hills, CA
Shedy Berrios, Jacksonville, NC Jeanne Hines, Prescott, AZ
Claudia Andrade, Pasadena, CA Mike Combs, Tahlequah, OK
L’Angelo D’Silva, Coto de Caza, CA Karen Brunschwig, Pasadena, CA
Kathleen Goodwin, Pasadena, CA Ernie Ephraim, Rogue River, OR
Ron Haynes, Roanoke, VA Han Gordinou de Gouberville, Almere, Nether.
Paul Gilbert, Southfield, MI Jim Feller, Corydon, IN
Kathleen McCarthy, Pasadena, CA Lora Royster, Orange, CA
Wendy Villasenor, Santa Rosa, CA Susan Brown, Pinole, CA
Manuel Verdugo, Pasadena, CA Kevin Mooney, Arlington Heights, IL
Rosine Sarafian, Glendale, CA Ron Watkins, Glendora, CA
Wendy Villasenor, Santa Rosa, CA Jeff Bova, West Hollywood, CA
Manuel Verdugo, Pasadena, CA Catherine Jurca, Pasadena, CA
Rosine Sarafian, Glendale CA Sossina Haile, Pasadena, CA
Paul Asimow, South Pasadena, CA Pablo Munguia, Beverly Hills, CA
Ryan Hunter, Pasadena, CA Willie Ornelas, Malibu, CA
Helena Lambert, Lakewood, CA Roland Wilhelm, Pasadena, CA
Siddharth Dasgupta, Altadena, CA Blanc Blanc, Ravine des Cabris, Reunion
Harry Gray, Pasadena, CA Ken Barry, Brenwood, TN
Steve Irwin, Louisville, KY Lina Bird, Pasadena, CA
John Bercaw, Pasadena, CA Kirby Binder, Minnetonka, MN
Kristy Nguyen, Pasadena, CA Thomas Lane, Torrance, CA
Lyle Workman, Glendale, CA Frank Wolf, Tarzana, CA
Monica Oller, Los Angeles, CA Steven Roberts, Greenacres, WA
Michele Botts, Burbank, CA Lydia Geissman, Sherman Oaks, CA
John D. Roberts, Pasadena, CA Jon Button, Los Angeles, CA
Charles Hale, Orange, CA Leland Sklar, Pasadena, CA

Impact Sciences, Inc. 3.0-6 Temporary Use of the Rose Bowl by the NFL
1136.001 November 2012
3.0 Responses to Comments

Paul Mills, Las Vegas, NV George Heritier, Oak Park, MI


Suzanne Spillane, Pasadena, CA Trina Smith, Pasadena, CA
Brenda Scott, Novato, CA Henry Savage, Mt. Pleasant, SC
Bruce Crawford, Oceanside, CA Tom Barger, Los Angeles, CA
Lana Sparks, Bella Vista, AK Bobbe Gross, Buffalo, NY
Jay Ruston, Sherman Oaks, CA Gary marsh, Prescott Valley, AZ
Craig Pannell, Greensboro, NC Roberto Dias, Tampa, FL
Drew Maxwell, Silverlake, CA Kirk Powers, Denton, TX
Jamie Collins, Newbury Park, CA Doug Habbena, Drexel, MO
James Aycock, Nashville, TN Arlene Kaminski, Odessa, FL
Marsha Hopkins, Kansas City, MO Bran van Steenbergen, Huntington Beach, CA
Christopher Willcox, Santa Barbara, CA Michael Abate, Jupiter, FL
Timo Bergstrom, Raseborg, Finland Elle Robak, Shelton, CT
Roger Scheerer, Kirchheim, Germany David Rule, New York, NY
John Alden, Huntington Beach, CA Jonathan, Ingoldsby, Los Angeles, CA
Simond Veronique, Ajaccio, France Paul Nelson, Newbury Park, CA
Pall Engilbjartsson, Hverageroi, Iceland Amye Williams, Santa Rosa Valley, CA
Claus Ulrich, Hamburg, Germany Mark Corben, Los Angeles, CA
Mikael Wounsch, Fristad, Sweden Ken Van Wagenen, Pasadena, CA
Chris Paulse, Bellajoh, Denmark Mike Torry, Havre, MT
Carlos Pepin, Coconut Creek, FL Peter Barthe, Pasadena, CA
Jordan Richman, Sherman Oaks, CA Rik Converse, Santa Ana, CA
Michelle Peacock, North Hollywood, CA Pat Howell, Paron, AK
Benj Clarke, Long Beach, CA Elissa Kline, Santa Cruz, CA
Margreet Keijzer, Amsterdam, Netherlands Jon Ostrowski, Santa Ana, CA
Mark Smotroff, San Francisco, CA Sydney Feeney, PRobert Bruns, Diamond Bar, CA
Trevor Song, Torrance, CA James Zeutzius, Pasadena, CA
Adam Endersby, Australia Barbara Holliday, Brattleboro, VT
Jonas Peters, Pasadena, CA Joanne Laurence, Pasadena, CA
Kimberly Johnson, Pasadena, CA Nancy Dionesotes, Cary, IL
William Harman, Pasadena, CA Chazz Ross, Sylmar, CA
Maureen McGillan Sklar, Pasadena, CA Catherine Totten, Sandy, UT
Charles McCrory, Pasadena, CA Oz Barron, Cambria, CA
Gillian Pierce, South Pasadena, CA Peter Doell, Los Angeles, CA
David Lacy, Pasadena, CA Fred Eder, Anthem, AZ
Andrea Totten, Pasadena, CA James Stith, San Dimas, CA
Bruce Brunschwig, Pasadena, CA Gregory, Reeves, Glendale, CA
Niles Pierce, South Pasadena, CA Dewey Armstrong, Miami, FL
JoAnn Newman, Pasadena, CA Wayne Newitt, San Luis Obispo, CA
John Anderson, Pasadena, CA Daniel Suess, Los Angeles, CA
Patricia StJohn, Pasadena, CA Kayla, Maddox, Pasadena, CA
Steven Fink, Pasadena, CA Joanne Laurence, Pasadena, CA
Joe Gorfinkle, Hollywood, CA Katherine Wimmer, Pasadena, CA
Tanya Page, Glendale, CA Jill Nieporte, Pasadena, CA
Chris Pinnick, Chatsworth, CA Allison Schreiner, South Pasadena, CA
Debbie Crawford, Culver City, CA Angelita O’Brien, Pasadena, CA
Carol Sevilla, Berkeley, CA Joan Hearst, Pasadena, CA
Chris Tune, Van Nuys, CA Judith Barker, South Pasadena, CA

Impact Sciences, Inc. 3.0-7 Temporary Use of the Rose Bowl by the NFL
1136.001 November 2012
3.0 Responses to Comments

Parameswaran Ramakrishnan, Pasadena, CA Xiaoze Ou, Pasadena, CA


Jae Moreno, Los Angeles, CA Christin Hong, Pasadena, CA
Joseph Rand, Los Angeles, CA Kelly Rouse, Pasadena, CA

Letter No. 65. Petition

Pamela Aschbacher, Pasadena, CA Paul G. Faghini, Pasadena, CA


M. Aschbacher, Pasadena, CA Hilda Havila, Pomona, CA
Margaret Bruell, Pasadena, CA Yuen Fang, Altadena, CA
Bruce Brunschwig, Pasadena, CA Irene Jung, San Gabriel, CA
Karen Brunschwig, Pasadena, CA Debbie Mitchell, Pasadena, CA
Carla Drew, Pasadena, CA John Aragon, Pasadena, CA
R. W. Edwards, Glendale, CA Laura Gilbert, Pasadena, CA
Lawrence Felix, Pasadena, CA Caraly Higuchi, Pasadena, CA
Cherie Felix, Pasadena, CA Cherie Cates, Pasadena, CA
Pol Forn, Pasadena, CA Laurie Koralenko, Pasadena, CA
Roger Segura, Pasadena, CA Macho Okumura, Pasadena, CA
Gerald Knapton, Pasadena, CA Hyun Jo Pang, Pasadena, CA
Annette Knapton, Pasadena, CA Kevin Pang, Pasadena, CA
Robert Li, Pasadena, CA Tanvi Ratani, Pasadena, CA
Joy Li, Pasadena, CA Melina Root, Pasadena, CA
Cameron Totten, La Canada, CA Michael Steven, Pasadena, CA
Joe Langer, Pasadena, CA

Letter No. 66. Ruben Cruz, October 25, 2012

Impact Sciences, Inc. 3.0-8 Temporary Use of the Rose Bowl by the NFL
1136.001 November 2012
2.0 CORRECTIONS AND ADDITIONS

The following corrections and additions are set forth to update the Temporary Use of the Rose Bowl by
the NFL Draft Environmental Impact Report (Draft EIR) in response to the comments received during
and after the public review period. Changes to the Draft EIR are listed by section and page number and
new text is provided in underline with strikeout of deleted text.

The following additions and corrections have been reviewed in relation to the standards in Section
15088.5(a) and (b) of the California Environmental Quality Act (CEQA) Guidelines on when recirculation of a
Draft EIR is required prior to certification. The additions and corrections to the Revised Draft EIR
document do not constitute new significant information requiring recirculation of the Draft EIR.

Sections 15088.5(a) and (b) of the State CEQA Guidelines state,

(a) A lead agency is required to recirculate an EIR when significant new information is added to
the EIR after public notice is given of the availability of the draft EIR for public review under
Section 15087 but before certification. As used in this section, the term “information” can
include changes in the project or environmental setting as well as additional data or other
information. New information added to an EIR is not “significant” unless the EIR is changed
in a way that deprives the public of a meaningful opportunity to comment upon a substantial
adverse environmental effect of the project or a feasible way to mitigate or avoid such an effect
(including a feasible project alternative) that the project’s proponents have declined to
implement. “Significant new information” requiring recirculation include, for example, a
disclosure showing that:

(1) A new significant environmental impact would result from the project or from a new
mitigation measure proposed to be implemented.

(2) A substantial increase in the severity of an environmental impact would result unless
mitigation measures are adopted that reduce the impact to a level of insignificance.

(3) A feasible project alternative or mitigation measure considerably different from other
previously analyzed would clearly lessen the significant environmental impacts of the
project, but the project’s proponent decline to adopt it.

(4) The draft EIR was so fundamentally and basically inadequate and conclusory in nature
that meaningful public review and comment were precluded.

(b) Recirculation is not required where the new information added to the EIR merely clarifies or
amplifies or makes insignificant modifications in an adequate EIR.

Impact Sciences, Inc. 2.0-1 Temporary Use of the Rose Bowl by the NFL
1136.01 November 2012
2.0 Corrections and Additions

CORRECTIONS AND ADDITIONS

Changes to the Draft EIR are identified below by the corresponding Draft EIR section and subsection, if
applicable, and the page number. Additions are in underline and deletions are shown in strikethrough
format.

Executive Summary

The Executive Summary of the Draft EIR is replaced by Section 1.0 Summary, as contained in the Final
EIR document.

Project Description

The first sentence of the last paragraph on page 2.0-16 has been revised as follows:

Currently, the Central Arroyo can accommodate approximately 20,280 21,518 vehicles.

The fourth sentence of the first paragraph on page 2.0-17 has been revised as follows:

Based on information provided by RBOC, approximately 20,280 21,518 total parking spaces are made
available on both paved and turf areas.

The following text has been added to the bottom of page 2.0-17:

Although they would not reduce any impacts associated with the project, the following measures have
been included to respond to concerns expressed in comments on the Draft EIR:

MM 2.0-1 RBOC shall be responsible for removal of all trash and debris associated with NFL
events. Clean up shall commence within 24 hours of an NFL event and shall including all
areas where patrons are directed to park within the Central Arroyo. Clean up shall be
conducted to the satisfaction of the Department of Public Works. The RBOC shall
provide funding as necessary.

MM 2.0-2 After each NFL event at the Rose Bowl, RBOC shall be responsible for visually inspecting
parked areas for signs of oil, fluids, or other potentially harmful substances within 24
hours of an NFL event. In the event such substances are discovered, the soil shall be
removed and disposed of in accordance with applicable regulations. RBOC shall provide
the City of Pasadena Department of Public Works with a written summary of the visual
inspection and any necessary soil removal.

Impact Sciences, Inc. 2.0-2 Temporary Use of the Rose Bowl by the NFL
1136.01 November 2012
2.0 Corrections and Additions

The second point in the list under Section 3.32.270(A) on page 2.0-18 has been revised as follows:

2. The revenue generating potential form from the additional event justifies its consideration.

Project 7 (300 W Green Street) in Table 2.0-1, Pending and Approved Project in the City of Pasadena on
page 2.0-21 of the Draft EIR has been revised as follows

Residential (39 units) 248 Senior/Life Care Units, 70 condominiums and the remodel/retention of an
existing 46 multi-family residential units

3.1 Air Quality

The following text has been added to page 3.1-21 before the subheading Summary of Emissions:

Emissions from tailgating have also been included as on-site emissions. The figures presented are based
on a total of 24,518 parking spots available on-site.

Table 3.1-6 has been revised as follows:

Table 3.1-6
Estimated Unmitigated Operational Emissions

Emissions in Pounds per Day


Emissions Source VOC NOX CO SOX PM10 PM2.5
Operational (Mobile) Sources 490.31 1,254.26 5,387.56 7.76 885.01 60.40
Natural Gas 0.18 4.00 0.67 0.00 0.01 0.01
Tailgating 1.02 13.20 7.62 1.71 0.51 0.20
Event Emissions Total 491.5190.49 1,271.46 58.26 5,395.85 88.23 9.47 7.66 885.5302 60.6141
SCAQMD Threshold 490.49
55 55 550 150 150 55
Exceeds Threshold? YES YES YES NO YES YES

Source: Impact Sciences, Inc. Emissions calculations are provided in Appendix 3.1.
Totals in table may not appear to add exactly due to rounding in the computer model calculations.

The following text has been added to page 3.1-24 following the first sentence of the second paragraph:

In addition to on-site operations such as food preparation and other services, the proposed project would
allow tailgating by event attendees. Further, since the majority of air pollutant emissions would result
from traffic, vehicle emissions within a quarter mile from the Rose Bowl have been included in the LST
analysis. It should be noted that mobile emissions are not typically included in an LST analysis. However,
as the proposed project is somewhat unusual and mobile emissions represent the primary source of
pollutants for the proposed project, they have been included in the interest of a conservative and
comprehensive analysis.

Impact Sciences, Inc. 2.0-3 Temporary Use of the Rose Bowl by the NFL
1136.01 November 2012
2.0 Corrections and Additions

The following text has been added to page 3.1-22 before the heading “Residual Impacts”

The following mitigation measures are also proposed in response to concerns express in comments on the
Draft EIR, although they will not result in any material reduction in the emissions projected in the draft
EIR:

MM 3.1-1 Any RFP for vendors to serve NFL events shall specify that the vendor must utilize 2010
or later diesel trucks or alternatively fueled delivery trucks or demonstrate practices that
will provide equivalent reduction of air emissions compared to a typical vendor who
does not use such equipment.

MM 3.1-2 Any maintenance vehicles or forklifts purchased to serve NFL events at the Rose Bowl
shall be electric or use alternative fuel, provided that electric or alternative fuel
equipment is available.

MM 3.1-3 Prior to the hosting of an NFL game at the Rose Bowl, the RBOC shall provide electrical
outlets in Lot I or nearby in Brookside Park to allow for electric barbecues to be used by
those who choose to tailgate and use portable electric barbecues.

MM 3.1-4 The RBOC shall ensure that cleaning products used to clean the Rose Bowl and
surrounding areas after NFL games are water based or low VOC cleaning products

Table 3.1-7 on page 3.1-24 has been revised as follows:

Table 3.1-7
Localized Significance Thresholds Analysis

On-Site Maximum Emissions (pounds per day)1


Significance Threshold NOX CO PM10 PM2.5
Operation
Maximum Daily On-site Emissions 4.00 0.76 0.01 0.01
Vehicle Emissions within ¼ Mile 26.13 112.24 18.44 1.26
Tailgating 13.20 7.62 0.51 0.20
Total 43 121 19 1.5
LST Screening Criteria 166 4,119 21 7
Exceeds Threshold? NO NO NO NO

Source: Impact Sciences, Inc. Emission calculations are provided in Appendix 3.1.
1 The NOX thresholds contained in the SCAQMD lookup tables are based on emissions of NO X and assume gradual conversion to NO2

based on the distance from the project site boundary.

Impact Sciences, Inc. 2.0-4 Temporary Use of the Rose Bowl by the NFL
1136.01 November 2012
2.0 Corrections and Additions

3.2 Greenhouse Gases

The third paragraph on page 3.2-1 has been revised as follows:

The proposed project is estimated to emit maximum net emissions of approximately 8,555 6,940.51 metric
tons of carbon dioxide equivalents (MTCO2e) per year, or 2.14 1.7 MTOC2e per service person (SP) per
year, without the implementation of GHG reducing project design features and mitigation measures.

3.3 Land Use

The last sentence of the second paragraph under the heading Hahamongna Watershed Park Master Plan
has been revised as follows:

The HMP does not include an implementation plan for specific projects in the HMP area and therefore
does not include any goals or policies that are relevant to the proposed project.

The following text has been added to the top of page 3.3-12:

Section 3.32.260 addresses general regulations and provides the following:

C. No portion of lands within the Arroyo Seco shall be used for any commercial, industrial, or
institutional purposes other than those which existed at the effective date of the ordinance
codified in this chapter.

Table 3.3-1 Project Consistency with Existing Land Use Plans, on page 3.3-15 has been revised as follows:

Plan Goal/Policy Project Consistency


City of Objective 12 – Fiscal Health – Encourage a Consistent. The proposed project will generate revenue for the
Pasadena business climate that contributes to the City’s City which may be used to pay off the cost of the Rose Bowl
General Plan fiscal well-being. renovation project, a project which is critical to the City’s
Land Use ability to maintain the historic Rose Bowl and continue to be a
Element premier tourist destination.
Policy 12.3 Pay your own way: Ensure that new Consistent. See additional discussion in Section 3.5 Public
development pays its own way rather than Services. The proposed project would not require additional
burdens existing businesses and residents with City services such as police and fire protection.
increased costs for services and infrastructure
needs.
Objective 17 Recreation – Provide adequate Consistent. The project site would continue to be accessible to
recreation opportunities to all residents of the residents. With implementation of the proposed project,
City additional residents could be exposed to the amenities at the
site through game attendance.
Policy 17.1 Accessible neighborhood parks: Consistent. Rose Bowl parks would remain accessible for
preserve, enhance and acquire parks with residents.
adequate recreational facilities in residential
areas, including planning for, and locating parks
within walking distance of multi-family
housing.

Impact Sciences, Inc. 2.0-5 Temporary Use of the Rose Bowl by the NFL
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2.0 Corrections and Additions

Plan Goal/Policy Project Consistency


Policy 17.2 Shared facilities: Promote the shared Consistent. The proposed project would not interfere with the
use of public school recreational land and joint use of facilities.
facilities for City recreational uses and/or
community centers.
Policy 17.4 Urban Open Space: Encourage and Consistent. The proposed project does not include construction
require, where feasible, the incorporation of activity; however, the project site would continue to provide
publically accessible open spaces, including open space amenities.
parks, courtyards, water features, gardens,
passageways, and plazas, into public
improvements and private projects.
Objective 20 – Land Use Transportation Consistent. The proposed project includes off-site parking and
Relationship – promote the relationship of land coordination with Metro for expanded rail services.
use and transportation
Objective 2 – Preservation and Protection of the Consistent. The proposed project will temporarily promote
Arroyo Seco and Adjacent Open Space Areas: Pasadena as a premier destination with an NFL team and more
Recognize the importance to Pasadena of the importantly provide funding to allow for successful
history, cultural resources, and unique character completion of the Rose Bowl renovation project that will
of the Arroyo Seco, and conserve and enhance preserve and maintain the historic resource that is the Rose
these assets. Bowl.
Policy 2.1 – Arroyo Seco Planning: Fully Consistent. The proposed project would not interfere with
implement all master plans and design implementation of the Arroyo Seco Master Plan.
guidelines for the Arroyo. This includes the
Lower Arroyo Master Plan, the Hahamongna
Watershed Park Master Plan, and the Central
Arroyo Master Plan.
Policy 2.4 – Promote multi-faceted use of the Consistent. The proposed project promotes the multi-faceted
Arroyo: Through implementation of the Arroyo use of the Rose Bowl by adding new events and would lead to
Seco Master Plans, continue to maintain and long-term preservation of the Rose Bowl through funding of
enhance the area as a prime resource for quality the renovation project.
of life of Pasadena residents.
Objective 4: Natural Open Space And Passive Consistent. The proposed project would not interfere with the
Recreation Preservation And Acquisition: Use preservation of open space in Pasadena.
traditional and creative strategies to preserve
and acquire open spaces in order to enhance the
quality of life of all Pasadenans.
Policy 4.5 – Open Space Zoning: Provide Consistent. The proposed project will temporarily disrupt
adequate land resources with the City’s OS access to recreational uses at the Rose Bowl during the five-
(Open Space) zone to meet the outdoor year time frame of the project. In addition, the project will
recreation needs of the present and future disrupt recreational access an additional 13 days per year.
residents in the region. Ensure careful planning Nonetheless, the project site will continue to provide open
within the City’s OS zones space to the residents of Pasadena.
Pasadena Objective 10 – Park And Green Space Design: Consistent. The facilities at the Rose Bowl would not be
Green Space, Park and open space projects should be planned modified with implementation of the proposed project and
Recreation, so that recreational facilities reinforce the will continue to reflect Pasadena’s character and heritage and
and Parks historic nature of Pasadena’s parks as well as the project provides funding to complete the renovation
Element and Pasadena’s character, heritage, and project that directly reinforces the historic nature of the Bowl.
Master Plan neighborhoods.
Policy 10.3 – Quality: Pasadena’s green spaces Consistent. The proposed project provides funding to complete
should have a quality appearance that instills the renovation project of the historic Rose Bowl preserving the
pride in the surrounding neighborhood and the quality appearance of the Bowl and the surrounding green
City at large. space.

Impact Sciences, Inc. 2.0-6 Temporary Use of the Rose Bowl by the NFL
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2.0 Corrections and Additions

Plan Goal/Policy Project Consistency


Objective 11 – Balance Special Events With Consistent. The proposed project would increase the number
Local Recreation Needs: It is important to of displacement events at the Rose Bowl per year and would
balance the recreational and open space needs of provide additional opportunities to promote the Rose Bowl
and capacity for Pasadena residents with the Stadium through NFL games. However, this increase would
status of many of the City’s parks as popular achieve a balance between special events and local recreation
venues for local and regional events such as needs by limiting the duration of the increased number of
music festivals, seasonal celebrations, and special events while recognizing that the need for the funding
cultural activities, many of which also serve as that will come from the project is critical, but not permanent.
key promotional activities for the City’s regional
and national image.
Policy 11.1 – Protect Local Recreation Needs at Consistent. The proposed project would promote special
Special Event Facilities: Through careful events at the Rose Bowl, specifically NFL games. Recreational
planning, continue to promote special events users would be displaced for a portion of the day on a
while providing access to recreational activities maximum of 13 additional days per year and for a temporary
at City facilities. Provide adequate land period (five years) balancing the recognition of the fact that the
resources to hold large special events while not need for the funding that will come from the project is critical,
unreasonably displacing recreational areas. but not required indefinitely.
Policy 11.2 – Community Identity: Continue to Consistent. The proposed project would reinforce Pasadena’s
promote special events and celebrations that identity as the host of one of the premier football stadiums in
reinforce Pasadena’s community identity and the world. The funding from the project will also preserve the
provide incentives for organizers to use Rose Bowl and thereby directly reinforce a key component of
Pasadena’s facilities. Pasadena’s community identity.
Arroyo Seco Temporary signage for events with a seasonal Consistent. Signage associated with NFL events will be
Design duration, or New Year’s related events, or events temporary. All signage will be coordinated with the City to
Guidelines lasting more than three days shall: ensure it does not conflict with the Comprehensive Signage
 have a coordinated signage program that is Program.
reviewed by the Parks and Natural
Resources Division and the Recreation and
Parks Commission;
 shall not conflict with the approved
Comprehensive Signage Program.
Open Space Goal: Preserve, Acquire and Create Open Space Consistent. The proposed project would not conflict with the
and  Preserve currently zoned open spaces, preservation or acquisition of open space in Pasadena. The
Conservation natural open spaces, hillsides, proposed project would not direct organized recreation to
Element viewsheds, watersheds and natural open spaces. The City would work with displaced
recreational areas users of Brookside Park to find appropriate space at existing
parks.
 Direct organized recreation to existing
parks, fields, and school facilities and
away from natural open spaces.
Develop Access & Connectivity for Wildlife and Consistent. The proposed project would not conflict with open
People space or wildlife corridors, the restoration of trails in Angeles
 Develop open space and wildlife National Forest, or information on the availability of open
corridors and establish easement and spaces. The proposed project includes the multi-faceted use of
acquisition programs. the Rose Bowl by adding new events.
 Acknowledge, restore, and maintain
Pasadena’s connections with trails in
the Angeles National Forest and
regional trail systems.
 Ensure that all Pasadena residents
have access to information about
where open spaces are located and the
transportation opportunities and
options for getting to them.

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Plan Goal/Policy Project Consistency


Preserve, Restore and Maintain the Eaton Consistent. The proposed project would not conflict with the
Canyon Corridor & the Arroyo Seco preservation, restoration, or maintenance of Eaton Canyon or
 Preserve, restore, and maintain the the Arroyo Seco. The proposed project will temporarily disrupt
natural character of the Eaton Canyon access to recreational uses at the Rose Bowl during the five-
Corridor and the Arroyo Seco as self- year time frame of the project. In addition, the project will
sustaining healthy ecosystems of disrupt recreational access an additional 13 days per year.
plants and animals. Their natural Nonetheless, the project site will continue to provide open
character will continue to inspire space to the residents of Pasadena.
people, as it has throughout time.
 Promote responsible human interfaces
with these unique natural
environments in open space planning.
Welcome and Value the Importance of Citizen Not applicable. This policy relates to open space planning; the
Participation proposed project does not include an open space component.
Therefore, the policy is not applicable to the project.
 Citizen participation shall play a
major role in all phases of open space
planning.
 The City shall provide the public with
timely information regarding open
space planning and decision making

Define and Recognize the Benefits Derived from Consistent. The proposed project will temporarily disrupt
Open Space access to recreational uses at the Rose Bowl during the five-
year time frame of the project. In addition, the project will
 The opportunity to experience open disrupt recreational access an additional 13 days per year.
space is vital to the physical and Nonetheless, the project site will continue to provide open
psychological well-being of
space to the residents of Pasadena.
Pasadena’s residents.
 Account for impacts to “nature’s
services” and associated value when
making decisions about open space.
 Open space is important for the health
of the ecosystem and provides direct
and indirect economic benefit to the
City.
 Preserve, restore, and maintain
Pasadena’s natural amenities and
recreation options which provide
unique value to Pasadena’s character
and desirability as a place to live, visit,
and conduct business.

3.4 Noise

The top of page 3.4-19 has been revised as follows:

Impact 3.34-4

The second sentence of the third paragraph on page 3.4-19 has been revised as follows:

As shown in Table 3.4-5, noise level increases on area roadways would range from 10.4 dB(A) to
169.8 dB(A).

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3.6 Recreation

Mitigation Measure MM 3.6-1 has been revised as follows:

MM 3.6-1 The RBOC or its designee shall ensure for the timely repair (repair shall occur within 24
hours) of be responsible for timely repair (within one day) of damaged Brookside Golf
Course turf areas, and any other grassy areas (such as Lot H), that are damaged as a
result of parking during displacement NFL events. The RBOC shall ensure that all turf
areas are returned to playable/usable condition within one day of an NFL event. Prior to
commencement of the use of the Rose Bowl by the NFL, the RBOC shall approve a plan
for maintenance of damaged turf areas. The plan shall be developed in coordination with
the City and local golfers and include a timetable detailing estimated time of repair and
methodology for the repair of the turf areas. RBOC shall be responsible for the costs of all
repairs.

The fifth sentence of the last paragraph on page 3.6-28 has been revised as follows:

Implementation of Mitigation Measure MM 3.6-2 would ensure access to the existing westerly equestrian
trails loop access is maintained.

Mitigation Measure MM 3.6-2 is revised as follows:

MM 3.6-2 In accordance with the provisions of the Santa Monica Mountains Conservancy trail
agreement dated January 10, 1985 (SMMC Grant), the RBOC shall ensure access as
required by the agreement. maintain access to the loop, trails and other recreational uses
during NFL and other displacement events.

Mitigation Measure 3.6-5 has been added following Mitigation Measure MM 3.6-4 on page 3.6-30 of the
EIR.

MM 3.6-5 Prior to any NFL use of the Rose Bowl, the City shall develop a plan for monitoring park
use during event days and develop a strategy for repairing or improving parks and
recreational areas as necessary to address potential increased usage on event days. The
City shall be responsible for funding those repairs and/or improvements.

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On page 3.6-30, Impact 3.6-3 has been removed from the EIR:

Impact 3.6-3 The proposed project would expand recreational use at the Rose Bowl by
adding additional events, including NFL games.

By increasing to 25 the number of events with 20,000 or more patrons, the Rose Bowl stadium and
associated facilities will be available to additional patrons. The City of Pasadena actively continues to
maintain and enhance park and recreational facilities throughout the City, and the RBOC strives to
promote Pasadena and Los Angeles County as a sports destination for local, regional, state, national, and
international sports events. Therefore, each event that occurs at the stadium will enhance the area’s
image, provide entertainment and participatory opportunities, further one of the City’s guiding
principles of promoting Pasadena as a corporate, entertainment, and educational center of the region, and
contribute to quality of life in the City of Pasadena, and, thus, would constitute a beneficial impact.

Mitigation Measures

No mitigation is required

Residual Impact

This would be a beneficial impact.

3.7 Transportation, Circulation and Parking

The source for Table 3.7-6 on page 3.7-35 has been corrected as follows:

Source: City of Pasadena General Plan, Mobility Element 20041994.

Mitigation Measure AM 3.7-2.1 on page 3.7-88 of the Draft EIR has been revised as follows:

AM 3.7-2.1. The RBOC, in conjunction with the tenant, shall implement a transportation demand
management program that shall incorporate the following elements to promote ride
sharing, alternative forms of transportation, and to maximize the efficiency of vehicle
travel.

Incentivize Carpooling

Develop and implement incentives for carpools of four or more persons per car, and
incentives for alternative fuel vehicles. Incentives may include, without limitation,
preferential parking, reduced parking costs, or other discounts.

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Pre-paid Parking Program

Provide pre-paid parking options. The use of pre-paid parking passes could increase the
throughput for vehicles at the Rose Bowl parking entrances by eliminating the need to
collect parking fees at critical access points to the stadium from those vehicles with pre-
paid parking, thus improving traffic operations.

Bicycle Valet at Parsons

Provide a bicycle valet parking service at the Parson’s parking lot. Spectators may valet
park their bicycles and ride on the shuttle bus to/from the Rose Bowl. This would
incentivize the use of bicycles as a mode of travel to/from the event and help reduce the
number of vehicular trips.

Charter Bus

Solicit interest in charter bus service from season ticket holders, groups and other
potential users and provide charter bus service from locations such as downtown and
neighboring cities in response to demand. The service will include the concept of “park-
and-ride,” which will encourage event patrons to leave their vehicles and transfer on to a
charter bus for the remainder of the journey. Rose Bowl will encourage charter bus
service by providing drop off for passengers in preferred areas close to the stadium.

Rideshare Program for Employees

The RBOC will implement a Rideshare program for employees.

Temporary Changeable Message Signs

The use of temporary changeable message signs is already employed at different


locations around the Rose Bowl. Expand the use of temporary changeable message signs
to include two changeable message signs along the I-210 or/and SR-134, depending on
traffic demands, to help facilitate ingress/egress on game days.

Way Finding Signage for Transit Patron

The City of Pasadena and RBOC will work together with Metro to install way-finding
signage to guide patrons to/from the Gold Line Memorial Park Station and the shuttle
bus pick-up/drop-off location.

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Use of Social Media

Use social media to communicate current information regarding directions to/from the
Rose Bowl from regional freeways and roadways, preferred routes to various parking
lots, and detailed information regarding potential modes of travel other than passenger
vehicles to/from the Rose Bowl (rail/bus/shuttle routes, timetables, etc.).

Mitigation Measure MM 3.7-4 on page 3.7-102 of the Draft EIR has been revised as follows:

MM 3.7-4 The Rose Bowl Traffic Command Center shall coordinate with PPD, PDOT, and Caltrans
to place two changeable message signs along the I210 or/and SR-134 to help facilitate
ingress/egress on game days. However, given the volume of traffic that would utilize the
freeways, there is no feasible operational mitigation measure that could fully mitigate the
project’s potential for impacts.

4.0 Alternatives

The statement of project objectives on page 4.0-2 has been revised as follows:

The alternatives to the proposed project ultimately selected for analysis in this EIR were developed to
avoid or substantially lessen one or more of the significant environmental impacts associated with the
proposed project, while still meeting many of the project’s objectives. The following are objectives for the
proposed project:

 Generate revenue to fund City services and offset the costs associated with the Rose Bowl renovation
project.

 Promote economic development in the project area and greater Pasadena through increased event
activity and tourism.

 Conserve resources and avoid environmental impacts by utilizing existing infrastructure and parking
facilities.

 Utilize the existing parking supply and establish a parking management plan to distribute parking
consistent with arrival and departure directions to efficiently disperse project traffic, facilitate access
to and from the site, and reduce traffic in the immediate vicinity to minimize potential
pedestrian/vehicular conflicts.

 Avoid the need for new infrastructure through a transportation management plan, including
information systems to advise patrons of transportation options and preferred alternatives.

 Provide additional entertainment opportunities to Pasadena residents that are not currently provided
in the community.

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Appendix 1.0

All references to Section 6.0 are corrected to refer to Section 5.0.

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TOPICAL RESPONSES

Topical Response 1 – Adequacy of Project Description

This topical response addresses comments that the Project Description in the Draft EIR was inaccurate,
incomplete, and legally inadequate. The comments suggest that the Project Description, and thereby the
scope of the entire environmental review, cannot be legally adequate because it does not describe the
environmental impacts of a lease or other agreement with the NFL or a specific NFL team.

At this time, there is no draft lease or other agreement between the City and the NFL or an NFL team. As
there is no such draft lease or other agreement, the City is unable to include any details of such a
document in the description of the project.

In order to include an analysis of an NFL agreement in the EIR, the City would need to delay
environmental review of the project until an agreement had been negotiated. However, CEQA
commands that a lead agency undertake environmental review as early as possible in the planning
process. The City should not wait until it has negotiated agreements with the NFL or an NFL team before
undertaking environmental review. Such delay would not comport with the purpose and mandates of
CEQA. When environmental review is conducted earlier in the process, the process is more amenable to
modification to reflect the environmental concerns identified.

Furthermore, in this case, the Project Description set forth in the EIR already provides a general
description of the project that is sufficient for the public to understand the potential environmental
impacts. The Draft EIR describes the project as the temporary use of the Rose Bowl Stadium by the
National Football League, which requires an amendment of the City’s Arroyo Seco Public Lands
Ordinance (the “Ordinance”). Amending the Ordinance would allow for an additional 13 displacement
events per year at the Rose Bowl Stadium for a period of up to five years. Each event would have a
maximum attendance of 75,000 persons. As stated in the Project Description, implementation of the
proposed project requires an amendment to the Ordinance, a possible amendment to the Rose Bowl lease
agreements, and one or more agreements with the NFL or specific NFL teams. At this time, the specific
terms of those agreements are not known to the City.

Some comments also suggest that without knowing the identity and reputation of the specific NFL team
that would use the Rose Bowl, it would be impossible to fully consider the impacts of the project and
determine appropriate mitigation measures. The comments suggest that the project is “speculative” and
that the Project Description “is improperly phased and improperly segmented.”

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The EIR has not included any details regarding impacts caused by specific NFL teams and/or their
requirements because the City is not aware of any evidence suggesting that any particular NFL team
would cause environmental impacts that are more significant than the impacts caused by any other team.
Given that the City does not know which NFL team will be using the Rose Bowl and given that the City is
not aware of any evidence suggesting that any team would cause environmental impacts that are
different than any other team, identification of a specific team that would play in the Rose Bowl is
unnecessary.

Finally, the Project Description is not speculative merely because it is not assured that the City will be
able to successfully negotiate a lease agreement with the NFL or an NFL team. Regardless of whether the
project comes to fruition, the Project Description is finite and stable. The Project Description is neither
phased nor segmented. As mentioned above, the description clearly identifies that the proposed project
involves an agreement to allow an NFL team to play games at the Rose Bowl for a temporary period. The
EIR identifies the potential impacts of that project, including the potential impacts of a lease agreement.
The terms of an agreement with the NFL or an NFL team are not expected to alter the potential
environmental impacts of the project discussed in the EIR. In the unexpected and unlikely event that a
lease or other agreement between the City and the NFL, or a specific NFL team, would result in
significant environmental impacts that are not identified and discussed in the EIR, the City would be
required to conduct additional environmental review prior to entering into such an agreement.

In sum, the Project Description accurately reflects the scope of the project, complies with CEQA’s
mandate that environmental review be conducted as early as possible, and is legally adequate.

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Topical Response 2 – Historic Resources

The Draft EIR addresses the temporary use of the Rose Bowl Stadium by the National Football League
(NFL), which requires an amendment of the Arroyo Seco Public Lands Ordinance to allow an additional
13 annual displacement events at the Rose Bowl Stadium for a period of up to five years.

The Initial Study that was prepared prior to the Draft EIR found the additional events to have No Impact
on the Rose Bowl Stadium or the surrounding area, including the Pasadena Arroyo Parks and Recreation
District and adjacent residential neighborhoods that have been designated as historic districts. The Rose
Bowl Stadium and its environs include a number of historic resources recognized at the national, state,
and local levels. The Rose Bowl Stadium itself is a National Historic Landmark and a contributing
structure to the Pasadena Arroyo Parks and Recreation District, which is listed in the National Register of
Historic Places. The Pasadena Arroyo Parks and Recreation District is roughly bounded by the Foothill
Freeway on the north, the City limits to the south, Arroyo Boulevard to the east and San Rafael Ave on
the west. It contains 27 contributing buildings, structures, sites, and landscape features, including the
Brookside Golf Club, Brookside Park, the Brookside Theater, Jackie Robinson Memorial Field and
Stadium, the Fannie Morrison Horticultural Center, the Holly Street Bridge, the Colorado Street Bridge,
the Mayberry and Parker Bridge, Lower Arroyo Seco Park and the Lower Arroyo Bird Sanctuary.

There are also three residential neighborhoods within the project vicinity that have been listed in the
National Register of Historic Places as historic districts: Prospect Park located east of Brookside Park,
Arroyo Terrace located south of Brookside Park, and the Lower Arroyo Seco located south of the 134
Freeway. Resources listed in the National Register of Historic Places are also listed in the California
Register of Historical Resources. All of the resources mentioned above qualify as historic resources under
CEQA.

CEQA states that a project would normally have a significant impact on historic resources if it would
result in a substantial adverse change in the significance of a historic resource. According to State CEQA
Guidelines, a substantial adverse change in the significance of a historic resource means demolition,
destruction, relocation, or alteration of the resource or its immediate surroundings such that the
significance of a historical resource would be materially impaired.1 The State CEQA Guidelines go on to
state that:

[t]he significance of an historic resource is materially impaired when a project… [d]emolishes or


materially alters in an adverse manner those physical characteristics of an historical resource that
convey its historical significance and that justify its inclusion in, or eligibility for, inclusion in the

1 State CEQA Guidelines, section 15064.5(b) (1).

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California Register of Historical Resources… local register of historic resources… or its


identification in a historic resources survey.2

The temporary NFL project will not cause a substantial adverse change that would threaten the eligibility
for historic designation of the Rose Bowl Stadium, the Pasadena Arroyo Parks and Recreation District, or
the three adjacent residential historic districts, based on the following analysis:

1. Would the Project involve the demolition of a significant resource?

The proposed temporary use of the Rose Bowl by the NFL for a period up to five years would not involve
any demolition either on the Rose Bowl site or within its vicinity. Therefore, the proposed project will not
demolish any historically significant resources, either on the Rose Bowl site or within its vicinity.

2. Would the Project involve relocation that does not maintain the integrity of a significant resource?

The proposed temporary use of the Rose Bowl by the NFL for a period up to five years would not
relocate any historically significant resources, either on the Rose Bowl site or within its vicinity.

3. Would the Project involve conversion, rehabilitation or alteration of a significant resource which does
not conform to the Secretary of the Interior’s Standards for Rehabilitation and Guidelines for
Rehabilitating Historic Buildings?

The proposed temporary use of the Rose Bowl by the NFL for a period up to five years would not
convert, rehabilitate, or alter any historically significant resources, either on the Rose Bowl site or within
its vicinity. The Rose Bowl stadium and its related ancillary buildings are currently being rehabilitated
according to the Secretary of the Interior Standards, and no additional rehabilitation or alteration is
proposed to accommodate the proposed temporary use by the NFL.

The Rose Bowl was constructed specifically to accommodate football games. The general wear and tear
that results from the regular use of a resource is not considered a substantial adverse change under
CEQA. The materials that could be impacted by football games are primarily reinforced concrete, arroyo
stone retaining walls, stucco, and asphaltic concrete. These materials always have and will continue to be
repaired and maintained as needed. An increase in the number of football games each year for a
temporary period will not materially impact any of the significant character-defining features of the
stadium.

Golf Courses 1 and 2 at Brookside Golf Club are currently used to accommodate parking for large events,
including college football games and large-scale entertainment events. Although use of the golf courses as
parking can damage fairways and landscaping, there are systems and procedures in place for

2 State CEQA Guidelines, section 15064.5(b) (2).

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maintaining and repairing the landscaping after such events that would remain in place for any NFL use.
Moreover, the actual tees, bunkers, fairways and landscaping of the golf courses have been altered and
changed numerous times during the Golf Club’s history, and are not considered character-defining.3

4. Would the project involve construction that reduces the integrity or significance of important
resources on the site or in the vicinity?

The proposed temporary use of the Rose Bowl by the NFL for a period up to five years would not include
any new construction. Therefore, the proposed project would not involve any construction that reduces
the integrity or significance of any historically significant resources, either on the Rose Bowl site or within
its vicinity.

In conclusion, temporary use of the Rose Bowl by the NFL will increase the number of times the Rose
Bowl is used as a football stadium per year. The proposed temporary use would result in a maximum of
65 additional events over the life of the stadium. The project will not introduce a new use for the Rose
Bowl but will instead temporarily expand the number of times it is used for its historic purpose. The Rose
Bowl is a reinforced concrete structure specifically designed and constructed as a football stadium. It has
successfully hosted football games and capacity crowds since 1922. Moreover, the Rose Bowl is currently
undergoing rehabilitation according to the Secretary of the Interior’s Standards. There is no evidence to
suggest that use of the Rose Bowl for 13 additional football games for a period of up to five years will
cause any undue stress that might damage character-defining features such that the Rose Bowl would no
longer be eligible for historic designation.

Use of the Rose Bowl by the NFL will not involve the demolition, relocation, conversion, rehabilitation, or
alteration of any historically significant resource. Nor will it involve any construction that reduces the
integrity or significance of any historic resources. Therefore, the proposed project will not result in
significant impacts to historic resources.

3 Pasadena Arroyo Parks and Recreation District National Register of Historic Places Registration Form, prepared by
Teresa Grimes for Pasadena Heritage, July 13, 2007. (7)

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Letter No. 1

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Letter No. 1: Native American Heritage Commission


State of California
Native American Heritage Commission
915 Capitol Map, Room 364
Sacramento, CA 95814
Mr. Dave Singleton, Program Analyst
August 16, 2012

Response 1-1

Based on correspondence received from the California Native American Heritage Commission and
included in Appendix F3.0 of the Final EIR, a Sacred Lands File Search is not necessary for the proposed
project.

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Letter No. 2

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Letter No. 2: South Coast Air Quality District


South Coast Air Quality Management District
21865 Copley Drive
Diamond Bar, CA 91765
Ian MacMillan, Program Supervisor, CEQA Inter-Governmental Review
October 10, 2012

Response 2-1

The comment provides introductory information and a summary of the detailed comments provided in
the attachment to the letter. Refer to Responses 2-2 through 2-7 for responses to these comments.

Response 2-2

The comments on transportation and parking mitigation measures appear to be taken from the Farmer’s
Field EIR or from other projects and do not take into account the constraints of the Rose Bowl stadium,
the manner in which the stadium is served by transit and parking facilities or the mitigation already
recommended by the Draft EIR. The following provides a response to each individual mitigation measure
described in the AQMD letter:

Response to Transportation Mitigation Measures

a) Trip ratios at NFL stadiums vary greatly throughout the nation. The mode split for the proposed
project was based on surveys and review of historical information related to large events held at Rose
Bowl, other large event venues in Southern California and available information on various NFL
venues throughout the nation. This data is summarized in a table under Response 2-7. As show in
the table, the transit mode share ranges from 5 percent to 41 percent and is largely dependent on
access to available and reliable transit service options. For the purpose of traffic analysis, a 5 percent
transit ridership was assumed for weekend games versus weekday games, for which transit ridership
was assumed at 7 percent (in part due to a lack of convenient and direct access to transit to/from the
Rose Bowl). The Gold Line light rail station at Memorial Park Station is located within 2 miles of the
Rose Bowl and a connection via shuttle service is provided on game days. Therefore, through the use
of a TDM program (as described in the EIR) and through coordination with transit service providers,
the project mitigates traffic impacts to the extent feasible by implementing transportation demand
management measures to reduce vehicle trips to the extent possible with a goal of reducing trip
ratios. Any assumption that these measures would be more successful in reducing vehicle trips
would risk underestimating the potential impact of traffic.

b) The comment requests the inclusion of the mitigation measures identified under “Additional
Measure 3.7-2.1” in the Draft EIR be included in the Mitigation, Monitoring, and Reporting Plan. This
measure will be included in the mitigation monitoring plan. With respect to addressing the specific
measures listed in the comment, the following information has been provided:

 Additional Metro and Metrolink Service – As part of the transit mitigation, the EIR
recommends that transit service be increased to help accommodate the demand of the proposed
Project. Please refer to Mitigation Measure 3.7-3. In this measure it is also recommended that the

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City of Pasadena work with Metro in order to determine the level of transit service adequate to
meet game day demands. However, this mitigation measure is within the responsibility and
jurisdiction of Metro and Metrolink.

 Additional Special Metrolink Trains: Please see the above response regarding additional Metro
and Metrolink Service.

 Express Bus Park-and-Ride: The proposed project does offer a shuttle bus park-and-ride at the
Parson’s facility. A total of 4,500 spaces are provided at this facility for event days. Patrons can
park their vehicle and board the exclusive shuttle bus to travel to/from Rose Bowl. The shuttle
travels on a partially exclusive route to/from Rose Bowl.

 Charter Bus Service – The EIR recommends that Rose Bowl explore interest in charter and park
and ride bus services from season ticket holders and other potential users. This type of service
could be provided from locations such as downtown Los Angeles and neighboring cities in
response to demand. Transit cost for patrons will likely be lower than parking costs. Therefore,
further discounting transit will not likely incentivize transit use. Further, the Rose Bowl does not
control ticket prices and cannot discount tickets for those who use transit. The Rose Bowl will
encourage charter bus service by providing drop off for passengers in preferred areas close to the
stadium.

 Encouraging and incentivizing transit (e.g. ticket bundling): An effective way to encourage and
incentivize transit is through a robust information and marketing campaign. The RBOC will
enlist the use of social media, the internet, and other methods to encourage the use of transit to
the events.

 Parking discounts for high occupancy vehicles: – The EIR recommends that Rose Bowl develop
and implement incentives for carpools of four or more persons per car. The Draft EIR already
recommends reduced parking costs as one of the incentives for patrons arriving to the proposed
events in a high occupancy vehicle.

c) As described above under Response 2-2 (a), the Rose Bowl is currently served by the Gold Line LRT
via Memorial Park Station located within 2 miles of Rose Bowl connected via shuttle service provided
on game days.)

d) This mitigation measure is not necessary as there are already a number of publically accessible
electric vehicle charging stations in close proximity to the Parsons site, from which a Rose Bowl
patron can easily walk to the Parsons site to take advantage of the shuttle service. These sites are
located at: 150 E. Holly St., 33 E. Green St., 45 S. De Lacey Ave., and 24 E. Union St.

e) Transit use by employees to/from the Rose Bowl will be encouraged. Generally, given the hours of
games, transit should be available to all employees upon the completion of their work. However, the
availability of rail transit is within the responsibility and jurisdiction of Metro, not the City of
Pasadena.

f) As summarized under AM 3.7-2.1, the Draft EIR recommends that the RBOC incentivize carpooling.
These incentives may include preferential parking, reduced parking costs, or other discounts. With
respect to incentivizing transit and carpooling through stadium discounts, please see
Response 2-2(b).

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g) Please see Response 2-2 (b), and (f) regarding incentives aimed at encouraging transit use.

h) The RBOC will implement a Rideshare program for employees. See Section 2.0 Corrections and
Additions for changes to AM 3.7-2.1

i) The Rose Bowl has a network of bicycle facilities within the general vicinity. However, on event days,
some of the facilities within the immediate vicinity of Rose Bowl may not be available for their
intended use due to the implementation a traffic operations and neighborhood protection plan.
Patrons may need to walk their bicycles when within immediate vicinity of Rose Bowl. The Draft EIR
recommends that the project provide a bicycle valet parking service at the Parsons parking lot.
Spectators may valet park their bicycles and ride on the shuttle bus available for the intended use.

j) The following mitigation measure shall be included in the Final EIR, although it will not result in any
material reduction in the emissions projected in the Draft EIR: “Any RFP for vendors to serve NFL
events shall specify that the vendor must utilize 2010 or later diesel trucks or alternatively fueled
delivery trucks or demonstrate practices that will provide equivalent reduction of air emissions
compared to a typical vendor who does not use such equipment.”

k) This mitigation measure is not necessary to mitigate any environmental impact of the proposed
project. There is currently an electric vehicle charging station at the Rose Bowl which is available to
vendors who use electric vehicles. There is a compressed natural gas refueling station within
approximately 6 miles of the Rose Bowl.

l) The proposed mitigation measure is not necessary to mitigate any environmental impact of the
project and will not mitigate project impacts. The project will not involve construction. Nor will the
project require the purchase of maintenance equipment or forklifts. The vast majority of maintenance
activities and equipment usage at the Rose Bowl will not be altered by the project as the stadium
must currently be maintained to host football games and other events. There may be minor use of
equipment in connection with signage and other game day preparation activities, which would not
have a material impact on air quality. The usage would be sufficiently minor that it would be
speculative to attempt to quantify emissions from such usage. Nevertheless, the following mitigation
measure has been included in the Final EIR: “Any maintenance vehicles or forklift purchased to serve
NFL events at the Rose Bowl shall be electric or use alternative fuel, provided that electric or
alternative fuel equipment is available.”

Response to Parking Mitigation Measures

m) The Rose Bowl has been holding large events of similar attendance for a number of years and has
refined entry/exit to the area in order to minimize vehicular queuing and delay. In addition, the EIR
recommends the use of a pre-paid parking program in order to improve access times into the stadium
area. In terms of signage and communication for parking and bowl access, the general vicinity of
Rose Bowl has adequate signage along established routes to/from the Rose Bowl to regional roadway
and freeway network. The Draft EIR recommends the installation of two changeable message signs
(CMS) along the I-210 and SR-134 Freeways. The Rose Bowl Traffic Command Center will coordinate
with PPD, PDOT, and Caltrans to place these signs on the freeway to help facilitate ingress/egress on
game days. The Draft EIR also recommends the use of social media to communicate current
information regarding directions to/from the Rose Bowl from regional freeways and roadways,

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preferred routes to various parking lots, and detailed information regarding potential modes of travel
other than passenger vehicles to/from the Rose Bowl (rail/bus/shuttle routes, timetables, etc.).

n) The EIR recommends the use of pre-paid parking to increase the throughput for vehicles at the Rose
Bowl parking entrances by eliminating the need to collect parking fees at critical access points to the
stadium, thus improving traffic operations.

o) The EIR identifies preferential parking as one way to incentivizing carpooling. This measure would
cover Vanpools as well as alternative fuel vehicles.

p) Given the location and nature of the Rose Bowl stadium, parking fees are collected upon arrival to the
stadium and this is expected to continue for the proposed NFL displacement events. There is
currently no provision of walkup kiosks or electronic payment. These are usually suitable for parking
facilities where visitors pay for parking on exit and is not suitable for event facilities where parking
fee is paid on arrival. (see Response 2-2 (n), above)

q) The parking for the Rose Bowl is not divided into many structures where some may fill up and divert
patrons to other structures. Therefore, this mitigation measure would be ineffective and would not
reduce any impacts identified in the Draft EIR.

Other Mitigation Measures

r) As with several other measures recommended by this comment, this proposed measure is unlikely to
lead to any material reduction in emissions as it does not address the source of emissions that are
creating the identified impact. Nevertheless, the following mitigation measure has been added to the
final EIR: “Prior to the hosting of an NFL game at the Rose Bowl, the RBOC shall provide electrical
outlets in Lot I or nearby in Brookside Park to allow for electric barbecues to be used by those who
choose to tailgate and use portable electric barbecues.”

s) This mitigation measure is unlikely to predictably reduce any emissions associated with the project.
RBOC staff has indicated that tailgating patrons at the Rose Bowl do not traditionally idle their cars
in order to provide power to tailgating activities. Therefore, providing an alternative to idling engines
will not measurably reduce emissions. Additionally, the proposed measure is not feasible as there is
no open area in the Arroyo that could be set aside for tailgating purposes without displacing other
recreation uses in the Arroyo. Since displacement of recreational users from the Arroyo is a
significant environmental impact of the project, the proposed mitigation would have a greater
environmental impact than benefit.

t) The proposed measure would not mitigate any impacts of the project. The Rose Bowl has two
emergency generators. No additional generators will be purchased or used in connection with the
project. The generators are tested for 15 to 20 hours per year in order to ensure that they are
functioning properly. The emergency generators are not otherwise used. The testing will occur
without regard to whether the project is approved and will not be lengthened if the project is
approved.

u) This proposed mitigation does not mitigate impacts of the project. No additional lawn mowing is
anticipated in connection with the project. With regard to leaf blowers, the Rose Bowl site currently
undergoes regular landscape maintenance and leaf blowers are used for that purpose. If the project is

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approved, some additional minor landscape maintenance may occur up to 13 times per year on NFL
game days; however, quantifying any reduction in emissions from using electric or alternative fuel
leaf blowers for this minor landscape maintenance would be speculative and if quantified, would not
materially reduce project emissions.

v) This proposed mitigation does not mitigate impacts of the project. The Central Arroyo is currently
swept regularly, including after weekends of heavy use for recreation purposes. Thus, sweeping that
will occur after NFL games played on Sundays would often have occurred without regard to the
project. If the project is approved, some additional sweeping may occur after football games on days
that would not have otherwise required sweeping, but this is likely to occur on no more than a few
occasions per year. Any reduction in emissions from using electric or alternative fuel street sweepers
on these few additional occasions of street sweeping would be speculative and such reduction would
not materially reduce project emissions.

w) Although additional cleaning as a result of the project will likely be limited to 13 times per year after
NFL games, and therefore will not materially contribute to air emissions, the following mitigation
measure shall be added to the Final EIR: “The RBOC shall ensure that cleaning products used to clean
the Rose Bowl and surrounding areas after NFL games are water based or low VOC cleaning
products.”

Response 2-3

Air quality impacts from tailgating have been included in the EIR.

Response 2-4

There is currently no plan to allow or include fireworks at the events analyzed in this EIR. Consequently
there would be no air quality impacts.

Response 2-5

As described in Section 2.0 of the Project Description, the amendment to the Arroyo Seco Public Lands
Ordinance would allow 13 additional events for a period of five years beginning in no sooner than the
2013–2014 football season and ending in 2018. At the end of the five-year period the maximum allowable
number of events per year under the Arroyo Seco Public Lands Ordinance would return to 12.

Response 2-6

Localized impacts from vehicle traffic within 0.25 mile of the Rose Bowl have been added to the LST
analysis previously performed for the project. Also included in the LST analysis are emissions from
tailgating, which would also occur on-site. The total of all emissions from these sources are compared to
the applicable LST thresholds, and remain well below the applicable standard. As the LST screening
thresholds are based on dispersion modeling and health impact analysis performed by the SCAQMD it
was assumed that comparison with the LST thresholds would represent a suitable and conservative
analysis of localized health impacts as recommended by the SCAQMD.

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Response 2-7

The trip length used for analysis of air quality impacts was based on an approximately 45 minute trip on
average. This is believed to represent a reasonable average trip length for football fans in the Los Angeles
area. The commenter suggests use of past data to substantiate these assumptions; however, as no NFL
team is located within the Los Angeles area, no comparable local trip length data currently exists.
Further, the air quality impacts from vehicle trips have been found to be significant and unavoidable.
Modifying the trip length to assume a longer average travel time for those who attend NFL games in Los
Angeles would not change the conclusions of the air quality analysis.

Travel mode split for the proposed project was based on surveys and review of historical information
related to large events held at Rose Bowl, other large event venues in Southern California and available
information on various NFL venues throughout the nation. This information is summarized below:

Travel Mode Choice Data

Stadium Source of Information Auto Transit Bike/ Walk

Farmers Field, Convention and Event Center Project EIR, 2012 73% 20% 7%
Downtown Los (Weekday)
Angeles
Convention and Event Center Project EIR, 2012 82% 15% 3.5%
(Weekend)
Qualcomm Farmers Field EIR n/a 18–20% n/a
Stadium, San Diego
CenturyLink Field, Farmers Field EIR n/a 25–30% n/a
Seattle
Candlestick Park, Farmers Field EIR n/a 8% n/a
San Francisco
Petco Park, San Farmers Field EIR n/a 8–15% n/a
Diego
AT&T Park, San Farmers Field EIR n/a 34–41% 5-8%
Francisco Adjacent
Target Field, Farmers Field EIR n/a 30% n/a
Minneapolis
Rose Bowl Rose Bowl Stadium Renovation Project EIR, 2005 n/a 5% n/a
Renovation
Pasadena Rose EIR for the Temporary Use of the Rose Bowl Stadium by 92% 7% 1%
Bowl the NFL (Weekday)
EIR for the Temporary Use of the Rose Bowl Stadium by 94% 5% 1%
the NFL (Weekend)

As shown in the aforementioned table, the transit mode share ranges from 5 percent to 41 percent and is
largely dependent on access to available and reliable transit service options. For the purpose of traffic
analysis, a lower (5 percent) transit ridership was assumed for weekend games versus weekday games,
for which transit ridership was assumed at 7 percent. A lower ridership is expected on the weekends

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because people are more likely to come from their homes in their private automobiles. On weekdays,
some patrons are expected to travel to the game from their place of employment. This will allow them a
greater opportunity to use transit to/from Rose Bowl.

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Letter No. 3

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Letter No. 3: Metro


Metropolitan Transportation Authority
One Gateway Plaza
Los Angeles, CA 90012
Martha Welborne, FAIA, Executive Director, Countywide Planning
October 8, 2012

Response 3-1
(1) The comments are noted and are hereby part of the Final EIR, and will be forwarded to the decision
makers for their consideration prior to taking any action on the Project. Regarding transit mitigation
measure MM 3.7-3, the traffic study recommends that Metro increase transit service to meet the
demand of both commuter peak hour transit ridership, as well as the demand generated from the
project. The study recognizes that the implementation of this mitigation measure is outside the
purview of the City of Pasadena and Rose Bowl and under Metro’s jurisdiction, it is recommended
that City of Pasadena coordinate with Metro in order to determine the level of transit service needed
to meet game day demand.

(2) The Draft EIR also acknowledges that transit ridership will increase as a result of the project. While
service frequencies (and transit capacity as a result) could increase to meet future demand, this is
outside of the control of the City of Pasadena. It is acknowledged that the future rail capacity may be
unable to meet patron demand and this might have to be achieved through increasing bus service
levels.

(3) The Memorial Park and Del Mar Metro Gold line Stations are routinely used to accommodate transit
patrons making their way to similar sized events, such as a UCLA game, at the Rose Bowl with no
safety impacts. Therefore, no safety issues are anticipated with the additional displacement events at
the Rose Bowl.

(4) Event patrons arriving at the Memorial Park Station on the Gold Line will be able to take a shuttle to
Rose Bowl from the northwest corner of the intersection of Fair Oaks Avenue & Holly Street located
approximately 600 feet west of the Station. It is not recommended that shuttle stops be placed at the
Del Mar Station as this would provide a less attractive option for Rose Bowl patrons, and likely result
in additional air quality and traffic impacts.

(5) The City of Pasadena and RBOC will work together with Metro to install way-finding signage to
guide patrons to/from the Gold Line Memorial Park Station and the shuttle bus pick-up/drop-off
location. The Draft EIR also recommends the use of social media to communicate current information
regarding directions to/from the Rose Bowl from regional freeways and roadways, preferred routes
to various parking lots, and detailed information regarding potential modes of travel other than
passenger vehicles to/from the Rose Bowl (rail/bus/shuttle routes, timetables, etc.).

(6) No street closures are planned adjacent to or around the Metro Stations. In the event that there will be
street closures around the Memorial Park and Del Mar stations, the City of Pasadena will coordinate
with Metro.

(7) Funding for traffic control officers and neighborhood protection personnel will be the responsibility
of the City of Pasadena and not Metro.

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(8) As recommended in Mitigation Measure 3.7-3, the City of Pasadena will coordinate transit service
with Foothill Transit and Metrolink.

Response 3-2

The comments are noted and are hereby part of the Final EIR, and will be forwarded to the decision
makers for their consideration prior to taking any action on the Project. Regarding the comment to
include criteria in relation to CMP arterial and highway monitoring stations and associated mitigation
measures per the CMP TIA Guidelines published in the “2010 Congestion Management Program for Los
Angeles County,” Appendix D, section D.9, the traffic impact analysis included the criteria for analysis
and significant impact determination for both arterial and freeway monitoring stations.

Using the aforementioned criteria at arterial and freeway monitoring stations, significant impacts were
identified at one arterial location and 20 freeway-monitoring stations. Mitigation measures were explored
for both arterial and freeway impacted locations.

No feasible physical mitigation measures were determined to be available for significant impact
identified at the Arroyo Parkway and California Boulevard monitoring station and therefore, the impact
will remain and significant and unavoidable.

The traffic study proposed that deployment of two changeable message signs along the I-210 or/and SR-
134 to help facilitate ingress/egress on game days. Rose Bowl will fund the permitting and deployment of
two temporary changeable message signs (CMS) on days of the proposed displacement events. The cost
of renting and deploying two CMS on 13 event days is estimated at $15,000. For a five-year period, this
cost is estimated at $75,000.

The Rose Bowl Traffic Command Center shall coordinate with PPD, PDOT, and Caltrans to place these
changeable message signs. However, given the volume of traffic that would utilize the freeways, there is
no feasible operational mitigation measure that could fully mitigate the project’s impacts.

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Letter No. 4

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Letter No. 4: Pasadena Chamber of Commerce


Pasadena Chamber of Commerce & Civic Association
844 E. Green Street, Suite 208
Pasadena, CA 91101
Paul Little, President and Chief Executive Officer

Response 4-1

The comment includes statements in support of the proposed project. Thank you for your comment. Your
comment will be forwarded to the decision maker prior taking action on the proposed project.

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Letter No. 5

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Letter No. 5: Pasadena Heritage


Pasadena Heritage
651 South Saint John Avenue
Pasadena, CA 91105
Jenna Kachour, Preservation Director
September 14, 2012

Response 5-1

The comment expresses a concern that earlier comments on the Initial Study were not responded to in the
Draft EIR. In response to comments from Pasadena Heritage and other individuals, the Final EIR has
been updated with a discussion of historic resources through Topical Response 2. Please see Topical
Response 2.

Response 5-2

The comment points to typographical errors in the Draft EIR. As stated in the comment, Table 1 in
Appendix 1.0 of the Draft EIR includes an incorrect reference to Section 6.0; the correct reference should
be Section 5.0. This correction has been made in the Final EIR.

Response 5-3

Refer to Topical Response 2 which provides an updated description of historic resources within the
Arroyo Seco.

Response 5-4

Refer to Topical Response 2 which analyzes the project’s potential to result in a significant effect on
historic resources.

Response 5-5

Refer to Topical Response 2 for a discussion of the inclusion of the historical resources analysis in the
Final EIR and associated findings. As requested in the comment, Cultural Resources has been added to
the Areas of Known Controversy on page ES-5 of the Draft EIR.

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Letter No. 6

Jennifer Higginbotham, Chair


Transportation Advisory Commission
City of Pasadena

October 5, 2012

Dear Mr. Sinclair,

Thank you for attending the September 27, 2012 meeting of the Transportation Advisory Commission.
What follows are my written comments related to the draft environmental impact report for the
temporary use of the Rose Bowl Stadium by the NFL.

Page 3.7-35, Table 3.7-6 1


Another relevant Mobility Element policy is de-emphasizing certain streets. Why aren’t de-
emphasized streets, such as South Orange Grove Blvd., identified in the EIR? The EIR should
explain why traffic should be added to a de-emphasized street when the policy clearly states the
City will not intentionally add traffic to de-emphasized streets.

Page 3.7-35

Many residents adjacent to the project say traffic impacts begin long before event start times
and extend well after events conclude. Why are LOS impacts measured only for the peak hour
before and after an event? Is this a fair evaluation of impact of LOS impacts in fact extend far
2
longer than 60 minutes? Also, why are LOS impacts based only on stadium capacity
(ticketholders) and employees? Football events routinely have many ticketless fans who tailgate
and who impact traffic volumes.

Page 3.7-36

The EIR should show a specific statistical comparison between UCLA football event spectators 3
and NFL football event spectators in terms of trips to and from the Rose Bowl. The language in
the EIR is vague.

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Page 3.7-37

Is there sufficient available capacity on the Gold Line to handle NFL crowds? The Gold Line has
been operating at or near capacity during weekday peak hours, so the assumption NFL 4
spectators would be able to use it to access the Rose Bowl may be invalid.

Does the EIR study bicyclist or pedestrian safety? If bike and walk modes are to be encouraged,
then safety should be evaluated in the EIR and, if necessary, possible mitigation should be
detailed. Routes are dark at night, road are narrow and attendees exiting an event are often not 5
cautious drivers.

Does the EIR consider the establishment of special game day transit routes to be used during
NFL events to encourage fewer vehicle trips to the Rose Bowl? 6
In general, I believe the EIR has insufficiently studied alternate transit modes, including mass
transit, bicycling and walking. Assumptions have been made about transit usage that are not
substantiated with facts proving available capacity. And, assumptions have been made about bike 7
riding and walking that do not consider the perception of unsafe routes as a significant deterrent
to using those travel modes.

Page 3.7-41

Are the environmental and transportation impacts of the shuttle trips factored into the traffic
8
study? Should the EIR stipulate that shuttles be low-emission and low-noise vehicles?

Figure 3.7-7

Why doesn’t the study include trips coming from the 710 Freeway, especially since the study 9
says 30% trips are assumed to be coming from the south?

Page 3.7-49

Why are there no future/related projects included in the study?


10
Page 3.7-53

For how many minutes or hours per event day are levels of service adversely affected by the 11
project?

Page 3.7-88
12
The study should have considered pre-paid parking as an additional TDM measure.

Were any studies done to determine if the mitigation measures mentioned will have any positive
impact? Is there any evidence from similar venues of the additional measures mentioned 13
successfully and measurably having a positive impact on reducing vehicle trips?

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Page 3.7-93

Riding a bike at night on streets around the Rose Bowl is dangerous because it is very dark, the
streets are narrow and drivers are often anxious to arrive or depart quickly creating safety
hazards. What is the justification for saying, “no impacts associated with safety hazards due to
14
design features would be expected”?

Page 3.7-95

The EIR should include information from Metro regarding its ability to meet projected demand 15
because without this information, it is impossible to conclude the transit impacts are valid.

Page 3.7-102
16
Were shared parking options considered beyond those listed, the Parsons, public and One
Colorado lots? Shared parking should be studied further given the projected parking deficit.

Page 3.7-103

Since the Parsons property has a new owner who has expressed an intent to redevelop the
property, should the EIR consider any impacts of constructions or loss of existing parking? What
17
happens if the re-development of this site begins during the NFL’s use of the Rose Bowl venue?

Page 4.0-3

Since traffic impacts are a significant concern, the EIR should have considered a reduced on-site
parking alternative instead of the improbably reduced attendance alternative #2. Why wasn’t a 18
reduced on-site parking alternative considered?

Alternative #3 assumes non-NFL attendees behave the same as NFL attendees. I am not sure
this is true. The NFL should demonstrate how they are similar if that is the case. 19

Thank you for taking public comment on this project. I look forward to reading the responses to my
questions and comments.

Sincerely,

Jennifer Higginbotham

Chair, Transportation Advisory Commission

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Letter No. 6: Transportation Advisory Commission


Transportation Advisory Commission
City of Pasadena
Jennifer Higginbotham, Chair
October 5, 2012

Response 6-1

Per City of Pasadena General Plan Mobility Element (2004), Orange Grove Boulevard is designated as a
de-emphasized street. The Mobility Element states that no capital or operational transportation
improvement can be made to increase traffic on de-emphasized streets.

The traffic distribution for the proposed was developed in conjunction with Pasadena Department of
Transportation and based on discussions with Pasadena Police Department (PPD) and Rose Bowl
operations staff regarding key routes to/from Rose Bowl. Since, Orange Grove Boulevard is one of the key
routes and currently advertised as such on the SR-110; project traffic is anticipated to utilize this street to
travel to/from Rose Bowl. However, the project is not proposing any new capital or operational
transportation improvements to increase traffic on Orange Grove Boulevard.

Response 6-2

The scope of work for the traffic analysis was developed in conjunction with Pasadena Department of
Transportation (PDOT) and follows the City of Pasadena’s adopted traffic study guidelines. Per the
guidelines, the analysis focuses on the peak traffic hour prior to an event and the peak traffic hour post-
event. This analysis represents the timeframes when congestion is expected to be at its worst level. Hours
outside of these timeframes are expected to experience less project traffic, and therefore will have fewer
project impacts.

As discussed in the letter provided by CSC and provided in Appendix F3.0 of the Final EIR, a relatively
small number of fans generally arrive at the stadium in hopes of receiving a free ticket or purchasing a
reduced price ticket. While some persons may remain in the parking lots during the game if they are
unsuccessful in obtaining a ticket, in the experience of CSC this has not constituted a significant problem.
In addition, many stadiums, including the Rose Bowl, patrol the parking lots during the game to request
that ticketless patrons leave the premises. For these reasons, it is not anticipated that ticketless fans would
congregate in the parking lots to tailgate during the game or in neighborhoods surrounding the Rose
Bowl merely to be close to the Stadium. As per current RBOC policy, tailgating is required to shut down
after kickoff and thus there is little incentive for ticketless fans to come to the stadium area/vicinity.
Therefore, given the aforementioned disincentives for ticketless patrons to travel to the stadium or/and
stay in the stadium’s vicinity, ticketless tailgaters are expected to be a small number and to conduct a
quantitative analysis for the ticketless patrons is considered speculative.

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Response 6-3

The comment is noted and is hereby part of the Final EIR, and will be forwarded to the decision makers
for their consideration prior to taking any action on the Project. A statistical comparison between UCLA
spectators and NFL spectators would not provide additional information concerning the environmental
impacts of the proposed project.

Response 6-4

During large events at the Rose Bowl, Metro Gold Line runs three-car trains at peak hour headways,
which is every 6 minutes, or 10 trains per hour. Per information obtained from Metro, each car has a
capacity of 144 passengers per car for a total of 4,320 passengers per hour in each direction. Using the
transit ridership factors described above, a total of 5,850 weekday and 4,350 weekend spectators were
estimated to travel by transit. These riders will typically be spread over a span of multiple hours prior to
start of a game or after the game is over. However, since a higher percentage travel to/from the Rose Bowl
during the peak 1 hour prior to the event and post-event, the Draft EIR identifies a significant transit
impact.

Response 6-5

The EIR addresses whether the project would result in significant impacts to the pedestrian/bicyclist
environment. The traffic study acknowledges that a small number of patrons may arrive to the NFL event
on a bicycle or on foot. The traffic operations plan proposed as part of the project includes deployment of
traffic control officers and traffic control equipment (including delineators, signs, etc.), which will
facilitate an orderly flow of vehicular traffic and reduce conflict between vehicles and
bicyclists/pedestrians. On event days, not all bicycle lanes/routes will be open within the immediate
vicinity of the Rose Bowl. Bicyclists will likely have to walk with their bicycles when within the
immediate vicinity or inside the parking lots of the Rose Bowl. Free bicycle parking is available at
Brookside Park across from the Aquatic Center. To incentivize use of bicycles as a mode of travel to the
NFL games, the traffic study recommends providing a bicycle valet at Parsons. This will provide
bicyclists a secure place to park their bicycles and take a shuttle to/from Rose Bowl.

Response 6-6

A majority of transit riders are expected to use the Gold Line to travel to/from the NFL event. The Draft
EIR on Page 3.7-88 recommends that Metro increase transit service to meet the increased demand on
event days. It also recommends that the City of Pasadena provide information to Metro in order to
determine the level of transit service adequate to meet game day demands. The traffic study also
recommends that the Rose Bowl solicit interest in charter bus service from season ticket holders, groups,
and other potential users to provide charter bus service from locations such as downtown and

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neighboring cities in response to demand. Together, the aforementioned recommendations are aimed at
reducing vehicle trips to the area.

Response 6-7

The traffic study analyzes the alternate modes including transit, bicycling and walking per City of
Pasadena traffic study guidelines. Transit usage assumptions were determined based on surveys and
review of historical information related to large events held at Rose Bowl, other large event venues in
Southern California and available information on various NFL venues throughout the nation. This
information is summarized below:

Travel Mode Choice Data

Stadium Source of Information Auto Transit Bike/Walk

Farmers Field, Convention and Event Center Project EIR, 2012 73% 20% 7%
Downtown Los (Weekday)
Angeles
Convention and Event Center Project EIR, 2012 82% 15% 3.5%
(Weekend)
Qualcomm Farmers Field EIR n/a 18–20% n/a
Stadium, San Diego
CenturyLink Field, Farmers Field EIR n/a 25–30% n/a
Seattle
Candlestick Park, Farmers Field EIR n/a 8% n/a
San Francisco
Petco Park, San Farmers Field EIR n/a 8–15% n/a
Diego
AT&T Park, San Farmers Field EIR n/a 34–41% 5-8%
Francisco Adjacent
Target Field, Farmers Field EIR n/a 30% n/a
Minneapolis
Rose Bowl Rose Bowl Stadium Renovation Project EIR, 2005 n/a 5% n/a
Renovation
Pasadena Rose EIR for the Temporary Use of the Rose Bowl Stadium by 92% 7% 1%
Bowl the NFL (Weekday)
EIR for the Temporary Use of the Rose Bowl Stadium by 94% 5% 1%
the NFL (Weekend)

As shown in the aforementioned table, the transit mode share ranges from 5 percent to 41 percent and is
largely dependent on access to available and reliable transit service options. For the purpose of traffic
analysis, a lower (5 percent) transit ridership was assumed for weekend games versus weekday games,
for which transit ridership was assumed at 7 percent. A lower ridership is expected on the weekends
because people are more likely to come from their homes in their private automobiles. On weekdays,
some patrons are expected to travel to the game from their place of employment. This will allow them a
greater opportunity to use transit to/from Rose Bowl.

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In response to comment regarding available capacity on transit, during large events at the Rose Bowl,
Metro Gold Line runs three-car trains at peak hour headways, which is every 6 minutes, or 10 trains per
hour. Per information obtained from Metro, each car has a capacity of 144 passengers per car for a total of
4,320 passengers per hour in each direction. Using the transit ridership factors described above, a total of
5,850 weekday and 4,350 weekend spectators were estimated to travel by transit. These riders will
typically be spread over a span of multiple hours prior to start of a game or after the game is over.
However, since a higher percentage travel to/from the Rose Bowl during the peak 1 hour prior to the
event and post-event, the Draft EIR identifies a significant transit impact.

In response to the comment regarding safe bicycle and pedestrian routes, the traffic operations plan
proposed as part of the project includes deployment of traffic control officers and traffic control
equipment (including delineators, signs, etc.), which will facilitate an orderly flow of vehicular traffic and
reduce conflict between vehicles and bicyclists/pedestrians. On event days, not all bicycle lanes/routes
will be open within immediate vicinity of the Rose Bowl. To incentivize use of bicycles as a mode of
travel to the NFL games, the traffic study recommends providing bicycle valet at Parsons. This will
provide the bicyclist a secure place to park their bicycles and take a shuttle to/from Rose Bowl. Historic
experience with football games at the Rose Bowl has proven that pedestrians are willing to walk to the
Rose Bowl from certain locations.

Response 6-8

As shown in Tables 3.7-11 through 3.7-13 and described on page 3.7-41 of the Draft EIR, shuttle trips were
estimated for the project. The shuttle trips were converted to vehicle trips, assigned to the current route
used for UCLA games and the impacts of the overall increase in traffic was quantified.

Shuttle trips were incorporated into the air analysis in that they had an effect on the number of vehicle
trips used in the air quality and greenhouse gas analysis. Shuttles and buses would tend to reduce air
quality emissions due to the greater efficiency provided. Shuttles do not exacerbate an air quality impact.

The traffic distribution was developed in conjunction with Pasadena Department of Transportation and
based on discussions with Pasadena Police Department (PPD) and Rose Bowl operations staff regarding
key routes to/from Rose Bowl. The traffic study includes project trip distribution from the south traveling
on Freemont Avenue and Fair Oaks Avenue to/from the Rose Bowl. This traffic represents patrons using
the I-710 freeway and taking surface streets to the Rose Bowl. However, the majority of the motorists
traveling on the I-710 Freeway are expected to use other connecting freeways such as the I-5 Freeway to
the SR-110 Freeway to reach the Rose Bowl.

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Response 6-10

As stated on Page 3.7-49 of the Draft EIR, “Future No Project traffic forecasts include the effects of specific
cumulative development projects, also called related projects, expected to be built in the vicinity of the
proposed project site. Figure 3.7-9 of the Draft EIR shows the location of the related projects.” Table 10 of
the Traffic Study shows a detailed list of related projects included as part of the analysis.

Response 6-11

The scope of work for the traffic analysis was developed in conjunction with Pasadena Department of
Transportation (PDOT) and follows the City of Pasadena’s adopted traffic study guidelines. Per the
guidelines, the analysis focuses on the peak traffic hour prior to an event and the peak traffic hour post-
event. This analysis represents the timeframes when congestion is expected to be at its worst level. Hours
outside of these timeframes are expected to experience less project traffic, and therefore will have fewer
project impacts. A project impact is considered significant if the impact exceeds the threshold of
significance during the peak hour.

Response 6-12

As shown on Page 3.7-88 of the Draft EIR, a pre-paid parking program was considered as part of
Additional Measure 3.7-2.1.

Response 6-13

The mitigation measures recommended in the traffic study include: (1) additional operational
improvements over and above the changes currently proposed as part of Project’s traffic operations plan;
(2) Transit mitigation measures; and (3) transportation demand management strategies. Although, all
recommended mitigation measures have the potential of providing benefits such as increased traffic flow
at intersections, higher transit ridership, and reduction in vehicle trips; the EIR traffic analysis did not
assume that transit and transportation demand management measures would be successful. No
mitigation credit was taken for these measures. Only the operational improvements were quantitatively
evaluated and summarized in the traffic study.

Most, if not all, of the recommended mitigation strategies are known to reduce vehicle trips at event
venues. However, the level of benefits from these mitigation strategies will vary from one venue to the
other depending on a number of variables such as access to available and reliable alternative modes of
travel, site location, etc.

Response 6-14

The traffic operations plan proposed as part of the project includes deployment of traffic control officers
and traffic control equipment (including delineators, signs, etc.). The purpose of this plan is to facilitate

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an orderly flow of vehicular traffic and reduce conflict between vehicles and bicyclists/pedestrians. On
event days, not all bicycle lanes/routes will be open within immediate vicinity of the Rose Bowl. Bicyclist
will likely have to walk with their bicycles when within the immediate vicinity or inside the parking lots
of Rose Bowl.

Response 6-15

Currently Metro runs peak period headways (every 6 minutes) during large events at the Rose Bowl. As
stated in Comment 3-1 from the Los Angeles Metropolitan Transportation Authority, “for weekday
events Metro may be unable to increase rail capacity to the level required to meet patron demand and
instead may have to supplement rail service with additional bus service during Metro’s peak operating
periods.” Additionally, “any additional Metro rail/bus service required to accommodate patron demand
would be subject to MTA Board approval as part of MTA’s annual operations budget.”

For these reasons and because transit service is not under the control of the City of Pasadena, transit
impacts as a result of the proposed project are considered significant and unavoidable.

Response 6-16

The parking provided at the Rose Bowl and Parsons campus is sufficient to address the needs of the
project. No other shared parking options were considered as of the parking analysis. Additionally, when
more parking spaces have been required, the RBOC has been able to accommodate the vehicles in various
garages, surface lots, and structures throughout the City. An example, but not exhaustive list, of the
parking supply and location includes: Old Pasadena, Jet Propulsion Laboratory, Elks Club, and Sierra
Madre Villa Gold Line station. While it is acknowledged that the proposed parking will be sufficient to
address the demand of the project, RBOC has consistently and regularly demonstrated the ability to
secure auxiliary parking when needed on an event-by-event basis.

Response 6-17

The Draft EIR adequately analyzed the potential environmental impacts associated with the development
of the Parsons site. As shown in Table 10 of Appendix 3.7 - Traffic Study, the Parsons project was
included as part of the cumulative traffic analysis for the proposed project. The cumulative traffic
assumed to be generated during pre-event peak hour by the Parson’s site upon completion is expected to
be greater than the construction related traffic generated during the construction of the Parson’s project.
Thus, the Draft EIR adequately considered the impacts of the Parsons project by incorporating trips
generated by that project into the cumulative traffic impacts analysis.

With respect to the potential parking impacts that may result from the development of the Parson’s site,
no parking related impacts are expected to occur because the parking demand for the stadium is

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anticipated to be met. As discussed on page 3.7-105 of the Draft EIR, the peak hour parking demand for a
weekday NFL game is anticipated to be 27,689 parking spaces. A lesser number of parking spaces, 25,633,
are anticipated to be needed for weekend NFL games. The difference in weekday versus weekend
parking demand is attributed to the higher Average Vehicle Occupancy on the weekend, as detailed on
page 3.7-105 of the Draft EIR. While the worst-case scenario is a weekday game, this scenario is limited to
no more than two events per year. Moreover, even the parking demand for a weekday game can be met,
as described below.

The Draft EIR notes that with stacked parking, the Rose Bowl can accommodate 24,518 parking spaces
on-site, which is 3,171 spaces less than the maximum anticipated number of parking spaces needed for
weekday games, and 1,115 parking spaces less than the anticipated demand for weekend games. (See
Draft EIR page 3.7-102) The Parsons site has hosted parking for Rose Bowl events (football and
entertainment) for over 20 years and is anticipated to continue this tradition through the duration of the
proposed Project. The Parsons site is currently improved with more than 3,171 parking spaces (non-
tandem) which meets and exceeds the anticipated demand for the project for both weekend and weekday
games. This number includes 2,241 parking spaces located in garages on the Parsons “Annex” site.

The commenter questions whether or not the potential development of the Parsons site would impact the
project beyond that analyzed in the Draft EIR. It is anticipated that parking for Rose Bowl events will
continue for the life of the project and beyond, however, it is acknowledged that a Predevelopment Plan
Review (Concept Plan) has been submitted to the City for development of the site. This Concept Plan
does not involve any changes to the 2,241 parking spaces on the Annex site, which are anticipated to be
available regardless of whether or not the main Parsons site is developed. Thus, even with the possibility
of simultaneous construction, the Annex parking garage can accommodate parking sufficient to cover
weekend games.

With respect to the main site, development is anticipated to be phased. Under the proposed phased
development, approximately 680 spaces would be available even during construction. Moreover, the
development of the Parson’s site could feasibly involve a construction staging plan whereby up to
250 additional parking spaces could be provided in a non-standard and tandem/aisle parking
configuration. Under this scenario, even the projected peak parking demand, which would require
3,171 spaces outside of the Arroyo could be provided on-site at Parsons.

Finally, the concept plans for the Parsons site suggest that a total of 6,378 parking spaces would be
available upon completion of the Parsons project, which is more than currently exist today. Thus, after
construction is completed, the Parsons site would have a far greater number of parking spaces than the
3,171 spaces required by peak parking demand for weekday NFL games.

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Even if the Parsons site, which has served the Rose Bowl for the last 20 years, were to become unavailable
during the construction of the Parsons project, the RBOC has a demonstrated record of accommodating
patron vehicles in various garages, surface lots, and structures throughout the City. An example, but not
exhaustive list, of the parking locations that have been or could potentially be available include: Old
Pasadena (6,000 spaces); JPL (1,000 spaces); Elks Club (200 to 300 spaces); and Sierra Madres Villa Gold
Line station (950 parking spaces). The RBOC has consistently and regularly demonstrated the ability to
secure auxiliary parking when needed on an event-by-event basis for events such as: the U2 concert in
2009 (attendance of approximately 97,000); World Cup Games (June 18-July 17, 1994 – eight events,
average attendance of approximately 90,000 per event); the Rose Bowl game on an annual basis (average
attendance of approximately 93,000 for last five years), the BCS Championship Game in 2010 (attendance
of over 94,000) and the Super Bowl (1977, 1980, 1983, 1987, 1993 – average attendance of approximately
102,000). Therefore, while the Parson’s site is anticipated to continue to be used for parking to
accommodate the project, no parking impact is anticipated to occur if it were to become unavailable
because alternative parking locations would be utilized, as has been historically demonstrated as feasible
for the last 18 years.

While these variations in the specific traffic patterns around parking facilities cannot be fully evaluated
(because the exact parking locations are: (1) not anticipated to be used; and (2) unknown at this time),
there would be no increase in net trips from using parking locations other than Parsons for 3,171 spaces a
maximum of 13 times per year.

Response 6-18

Alternative 2, the Reduced Capacity Alternative analyzes a seating capacity of 50,000. According to State
CEQA Guidelines Section 15126.6, an EIR must describe a “reasonable range” of alternatives that attain
most of the project objectives but avoid or substantially lessen any of the significant impacts of the
project. As described throughout the Draft EIR, many of the impacts (air quality, traffic, noise) are closely
related to the number of vehicle trips. Therefore, an alternative that could lessen impacts would
reasonably include a reduction in the number of vehicle trips. Existing NFL stadium capacities range
from approximately 63,000 (Lucas Oil Stadium, Soldier Field) to 79,000 (FedEx Field), however, in 2012,
several teams had average attendance numbers well below 63,000 including Miami (55,182), St. Louis
(53,941) and Tampa Bay (52,074). As negotiations with the NFL are not underway, the ultimate
attendance for the NFL team is unknown at this time. However, based on information known to the City
at the time of preparation of the EIR, an attendance level of 50,000 appeared to be an appropriate
“bookend” for a low level of attendance that could substantially lessen impacts while still potentially
fulfilling the basic objectives of the proposed project because it did not vary significantly from the
average attendance of several NFL teams.

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A reduced on-site parking alternative, as suggested in the comment, would reduce many of the same
impacts as Alternative 2 by reducing the number of vehicles traveling to the Rose Bowl. To achieve the
reduction in impacts similar to Alternative 2, off-site parking would need to accommodate 9,259 vehicles
(assuming the same 2.7 AVO used in the Draft EIR) for weekday events and 8,333 vehicles (assuming the
same AVO of 3.0 as used in the Draft EIR) for weekend events. The most likely places for park and ride
lots would be Santa Anita Racetrack (15,550 spaces); JPL (1,000 spaces); and Sierra Madres Villa Gold Line
station (950 spaces). Assuming the City could negotiate parking at other lots to accommodate the
remaining vehicles, the reduction in trips traveling to the Rose Bowl could be achieved. However, it is
important to note that although trips to the Rose Bowl would be reduced, the total number of trips would
remain the same as 75,000 patrons would still attend the event. Trips would be redistributed elsewhere in
the region. Some trips lengths may be reduced as patrons would choose a park and ride lot closer to their
home or work. The total number of automobile trips generated by the project would remain the same and
additional bus emissions would be added to the project as shuttles take patrons to and from the park and
ride lots. In some cases, the emissions associated with the shuttles could be more polluting than the
automobile trips. Therefore, although a reduced on-site parking alternative would reduce impacts at local
intersections, it would increase impacts at other intersections depending on the location of parking, and
air quality impacts would likely remain significant and unavoidable. While the suggested alternative
would reduce traffic in the immediate area of the Rose Bowl, it would not appear to offer significant
environmental advantages over the project or Alternative 2.

Response 6-19

Alternative 3 – Reduced Non NFL Displacement Events would increase the number of events per year by
nine and attendance would be 75,000. The Reduced Non NFL Displacement Event Alternative allows for
any type of event, such as international soccer, or concerts. It would be speculative at this time to try to
determine the exact type of event, as the type would likely vary from year to year. For instance one year
there could be two international soccer matches and the next could be five international soccer matches.
Sporting events such as international soccer would be expected to draw patrons who would act similar to
NFL fans, in particular, it is expected that these fans would tailgate in the parking lots and police would
be required for traffic management and crowd control. Festivals and concerts could also result in similar
activities before the event depending on the artist or type of festival both of which are unknown at this
time. Please refer to the letter submitted by CSC which states there are little differences in the behavior of
soccer fans or concert attendees compared to NFL event attendees. The letter is provided in
Appendix F3.0 of the Final EIR.

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Letter No. 7

                               
     

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Letter No. 7: West Pasadena Residents Association


West Pasadena Residents Association
PO Box 50252
Pasadena, CA 91115
Bill Urban, WPRA President and Fred Zepeda, WRPA Board Member
October 8, 2012

Response 7-1

Please see Topical Response 1 regarding the adequacy of the Project Description and the need for public
review of the Statement of Overriding Considerations prior to City Council consideration. Regarding
comment abound incorrect and unclear traffic assumptions, the scope of work for the traffic analysis was
developed in conjunction with Pasadena Department of Transportation (PDOT) and follows the City of
Pasadena’s adopted traffic study guidelines. The traffic study includes a detailed summary of project
traffic generation approach, methodology, assumptions.

Regarding the comment about Metro’s implementation of SR-710 Freeway extension, there are still
several alternatives being considered. There is no record of decision for a locally preferred alternative,
design, or approved schedule for construction of the SR-710 Metro project. An EIR examining several
alternatives is currently scheduled to be prepared and completed in the fall of 2013. As there is currently
no project proposed, no project was included as part of the traffic analysis.

Additionally, at its meeting of October 29, 2012, the City Council of the City of Pasadena considered a
letter from the Planning Commission requesting the Final EIR for the temporary use of the Rose Bowl by
the NFL be returned to them so that they could make a formal recommendation on the document to the
City Council. Given the three public meetings (Planning Commission meeting of September 19, 2012,
Transportation Advisory Commission (September 27, 2012) and the Recreation and Parks Commission
(October 2, 2012) that were held to receive public comment, The City Council directed staff to bring the
Final EIR and the SOC to the City Council on November 19, 2012 without returning the Planning
Commission. In this regard, the SOC will not be available for a 90-day review period. Currently, there is
no NFL lease deal to review, nor is it guaranteed that the NFL will even come to Los Angeles, so there
might not be a proposal before the City. As such, the City Council has yet to direct staff regarding the
process by which a potential NFL lease would be addressed.

Response 7-2

The comment provides a summary of specific comments included in the attachment. Refer to Responses
7-3 through 7-20, below.

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Response 7-3

Refer to Response 7-1.

Response 7-4

Refer to Response 7-1.

Response 7-5

Please see Topical Response 1 regarding the adequacy of the Project Description.

Response 7-6

The comment points to a typographical error in Section 4.0 Alternatives of the Draft EIR. Page 4.0-2
includes a statement of the project objectives, these objectives differ from the project objectives listed
correctly in Section 2.0 Project Description. The project objectives listed in Section 2.0 are correct. The
Final EIR has been revised to correct the typographical error.

Response 7-7

Please see Topical Response 1 regarding the adequacy of the Project Description.

Response 7-8

Pages 2.0-15 and 2.0-16 of the Draft EIR include a description of NFL events and anticipated signage
associated with events. As indicated in the Draft EIR, the proposed project does not include any physical
changes, although additional signage such as banners, balloons, and commercial advertisements would
be anticipated and would be located primarily in “fan fest” areas immediately outside the stadium. NFL
events would also require the use of tents and pavilions and similar temporary structures for pre-game
fan events and promotions. These would be similar to the current use of tents and pavilions for UCLA
and BCS games and as these activities surrounding UCLA and BCS games have had no significant
environmental impact, they are not expected to have a significant environmental impact in conjunction
with NFL games. In addition to the information provided in this section, supplementary clarification on
the time to setup was provided by the Rose Bowl Operating Company (RBOC) and is provided herein.
The set-up of an NFL game (including erection of tents and/or pavilions) would begin at 8:00 AM prior to
the event day.4 However, the set up prior to event day would not interfere with recreational activities,
both organized and non-organized, would continue until the day of the event at which time activity at the
Rose Bowl, including the loop, Kidspace, Aquatic Center and recreational use on the grassy areas would
be restricted. The time of the restriction would be dependent on the time of the NFL game, but could
begin as early as 5:00 on the day of the event and would remain in place until at least 90 minutes after the

4 Charles Thompson, RBOC, personal communication May 24, 2012.

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event concludes. Traffic restrictions would occur on a similar schedule as restriction of recreational
activities. As required by MM 3.6-2, access to the equestrian trail would remain open during NFL events.

Response 7-9

Please see Topical Response 2 for a complete analysis of potential impacts to historic resources.

Response 7-10

The comment states the Draft EIR does not include sufficient information related to the number of users
in the Arroyo. Page 3.6-25 includes a graphic depicting the number of estimated users of the loop. The
counts were taken in 2008. In addition, the City conducted additional counts at the loop on Sunday
October 21, 2012 from 11:15 AM to 12:15 AM to supplement the 2008 counts. These counts were taken at
the entrance to Gate C and are as follows:

 Walk/jog: 232

 Bicycle: 65 (non-Peloton)

 Skate/Scooter: 3

 Motor Vehicle: 234

City staff also conducted surveys of the various users of the Rose Bowl in October and November of 2010.
These surveys were conducted to assess the success of improvements to the loop that occurred in
February 2010. The findings of the survey were presented to the City Council in February 2011 in the
form of a memo. The memo is included in Appendix F3.0 of this Final EIR. The survey results indicated
that approximately half (51 percent) of the users of the loop were Pasadena residents and the majority of
responders (75 percent) used the loop for walking/running.

In addition to information provided regarding the recreational loop, the Draft EIR includes estimates for
each of the facilities at the Rose Bowl in the form of annual estimates. These are stated on pages 3.9-4 and
3.6-5 of the Draft EIR and are as follows:

Brookside Golf Course: 800,000 annual visits

Rose Bowl Loop: 1.5 million visits

Brookside Park: 115,000 individuals

Rose Bowl Aquatic Center: 16,800 swimmers, 250,000 visitors

Kidspace Museum: 200,000 visitors

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The comment further states the estimates of users result in inadequate conclusions and mitigation. The
conclusions and mitigation measures presented in the Draft EIR are not based on an estimate of the total
number of users in the Arroyo Seco and would not change depending on the number of users. The Draft
EIR finds the displacement of users to be a significant and unavoidable impact due to the loss of access to
these recreational resources, this finding is not dependent on a numerical threshold as implied by the
commenter, but on the basis that the project could substantially interfere with or preclude the use of
existing recreational facilities in the Central Arroyo Seco.

Response 7-11

The comment states the recreational loop is closed prior to major events at the Rose Bowl. Mitigation
Measure MM 3.6-2 was included to reduce potential impacts associated with the loss of recreational uses
at the Rose Bowl on event days. However, even with this MM 3.6-2 impacts were found to be significant
and unavoidable. Since publication of the Draft EIR, the City has received comments from the public that
certain portions of this measure are infeasible, as a practical matter and for safety reasons. In particular,
comments state that it is infeasible to maintain access to the loop and other recreational uses during NFL
events. However, equestrian trails must remain accessible in accordance with the City of Pasadena’s
agreement with the Santa Monica Mountains Conservancy. For these reasons MM 3.6-2 has been revised
as follows and the following language will be recommended to the City Council for MM 3.6-2:

MM 3.6-2 In accordance with the provisions of the Santa Monica Mountains Conservancy trail
agreement dated January 10, 1985 (SMMC Grant), the RBOC shall ensure access as
required by the agreement. maintain access to the loop, trails and other recreational uses
during NFL and other displacement events.

Response 7-12

The Draft EIR focuses on the displacement of users in the Central Arroyo, as those users would be
directly displaced. Other areas of the Arroyo, such as the Lower Arroyo and Hahamongna would not be
closed to public use. However, traffic associated with NFL events could dissuade some users from
accessing the Hahamongna and the Lower Arroyo. Additionally, depending on the location of the user,
some users may have better access to these areas than the Central Arroyo on game days and choose to
utilize these areas rather than the Rose Bowl.

Response 7-13

Traffic estimates were not based solely on observations from one football game. The transportation
analysis was developed with input from Pasadena Department of Transportation (PDOT), PPD and the
Rose Bowl operations staff based on their experience with many events at the Rose Bowl, including many
that had attendance in excess of 75,000 persons. Project trip generation assumptions were also based on

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information from large sporting venues within Southern California and other NFL stadiums currently
operating throughout the nation.

Response 7-14

Page 3.7-2 of the Draft EIR correctly refers to the City’s 2004 Mobility Element. The reference in Table 3.7-
6 is a typographical error and has been corrected to say “2004.”

Response 7-15

Please refer to Response 6-1.

Response 7-16

The scope of work for the traffic analysis was developed in conjunction with Pasadena Department of
Transportation (PDOT) and follows the City of Pasadena’s adopted traffic study guidelines. The study
area, including the intersections and street segments, was determined in coordination with Rose Bowl
Operations staff, PPD and PDOT. The agencies provided input based on their vast experience at the Rose
Bowl events over the past 30 years, including ground and aerial observations of traffic during events. In
addition, observations were taken at a UCLA/Cal football game from last season. Comments from the
2005 EIR were also taken into consideration. The study area described in the Draft EIR is considered
sufficient for the determination of project impacts.

Following is a response addressing comments specific to individual intersection and street segments:

Arroyo Boulevard intersections south of California Boulevard

Study intersections were selected in conjunction with PDOT after detailed discussions with the Pasadena
Police Department (PPD) and Rose Bowl Operations staff regarding primary routes to/from the stadium.
The proposed traffic control plan and neighborhood protection plan focuses on keeping event traffic on
streets intended for use during events. The majority of the traffic travelling on Arroyo Boulevard north of
California Boulevard comes from Orange Grove Boulevard. However, it is possible that a small number
of vehicles may use Arroyo Boulevard south of California Boulevard to travel to/from Rose Bowl. Based
on historic traffic patterns for displacement events at the Rose Bowl, this traffic is expected to be minimal
and therefore is not expected to result in a significant impact at an intersection along Arroyo Boulevard
south of California Boulevard. Any assignment of trips to this corridor would be speculative and would
divert trips from their more likely path of travel, reducing impacts at other intersections.

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Arroyo Boulevard and Seco Street (in the Arroyo)

The intersection of Arroyo Boulevard a Seco Street is located between the analyzed intersections of West
Drive & Seco Street and Rosemont Avenue & Seco Street. During displacement events, the intersection of
Arroyo Boulevard & Seco Street functions as an internal access intersection and is significantly
reconfigured by PPD and Rose Bowl Parking staff using barricades and other traffic control equipment to
allow free flow of traffic to/from the parking lots it serves. Therefore, it is not possible to compute a level
of service for the location.

Street segments on South Orange Grove, Fair Oaks, and Arroyo Parkway south of Green Street and
Pasadena Avenue between California and Glenarm.

The street segments in the traffic study are intended to provide adequate representation of major traffic
activity along routes to/from Rose Bowl. As shown on Figure 3.7-4 and listed in Section 3-7 of the Draft
EIR, the traffic study analyzed a total of 27 street segments, of which, 20 were determined to be
significantly impacted on weekday events and 22 were determined to be significantly impacted during
weekend events. A significantly impacted segment is representative of the corridor in which it is
measured, the study does not and need not measure each block as such additional measurements will
provide no additional information concerning the impact to the corridors measured.

The traffic study analyzed the following three segments along the streets questioned by the commenter:

#24 - Arroyo Parkway south of Colorado Boulevard

#25 - Pasadena Avenue south of Glenarm Street

#26 - Orange Grove Boulevard south of Colorado Boulevard

The segments listed above were selected as they represent locations that capture the majority of project
traffic activity along Arroyo Parkway, Pasadena Avenue and Orange Grove Boulevard. Of these three
segments, the segments along Arroyo Parkway and Orange Grove Boulevard were found to be
significantly impacted by the proposed project.

All streets east of Arroyo Parkway such as Marengo and Los Robles

The study intersections were selected in conjunction with PDOT after detailed discussions with the
Pasadena Police Department (PPD) and Rose Bowl Operations staff regarding primary routes to/from the
stadium. The proposed traffic control plan and neighborhood protection plan focuses on keeping event
traffic on streets intended for use during events. However, some event patrons may choose to travel on

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streets located east of Arroyo Parkway. These streets provide parallel north/south and east/west routes to
Rose Bowl, but these patrons will eventually have to traverse through the analyzed intersections and
streets segments to reach the Rose Bowl. Based on historic traffic patterns for displacement events at the
Rose Bowl, project traffic on the streets located east of Arroyo Parkway is expected to be minimal and
would not cause a significant impact. Any assignment of trips to these streets would be speculative and
would divert trips from their more likely path of travel, reducing impacts at other intersections.

Response 7-17

Public transportation “mode splits” were based on surveys and review of historical information related to
large events held at Rose Bowl, other large event venues in Southern California and available information
on various NFL venues throughout the nation. Please refer to Response 6-7 for detailed information on
travel mode shares data from the aforementioned sources.

Response 7-18

Significance thresholds, emissions guidelines, and rules provided by the SCAQMD are designed for the
protection of all residents, with particular attention to sensitive receptors. The presence of even a single
sensitive receptor in the area triggers consideration of such receptors, regardless of their relative density
in the area of the proposed project.

Response 7-19

The Draft EIR includes a discussion of the closure of Fire Station #39 in Section 3.5.1 Fire Protection.
Based on information provided by the Pasadena Fire Department, the Fire Station will reopen in 2013
before the Rose Bowl is in use as a temporary facility for the NFL. Additionally, as discussed in Section
3.5.1 Fire Protection, the Pasadena Fire Department (PFD) has indicated they have adequate facilities to
serve the project. Also, the PFD currently has adequate staff to serve special events such as displacement
events at the Rose Bowl; and thus services would continue to be adequate.

Response 7-20

Please refer to Response 7-1.

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Letter No. 8: Linda Vista Annandale Association


Linda Vista Annandale Association
P.O. Box 94364
Pasadena, CA 91109
Nina Chomsky, President
October 8, 2012

Response 8-1

Refer to Topical Response 1 which relates to the adequacy of the Project Description.

Response 8-2

Page 2.0-16 of the Draft EIR includes a discussion on signage and lighting. This discussion summarizes
the referenced study (ME Engineers of Wheatridge Colorado, 2004) which specifically evaluated the
impacts of lighting on the community surrounding the Rose Bowl and found that event lighting does not
spill outside the bowl during events. Lighting for major events is based on the broadcast networks’ need
to capture such events with slow-motion cameras, and more recently, in High Definition (HD). The
lighting at the Rose Bowl must meet the networks standards for broadcasting major sporting events in
HD. Currently networks broadcast in HD from the Rose Bowl which indicates the current lighting would
be acceptable and no changes to the existing lighting at the Rose Bowl are anticipated. Further, the
International Commission on Illumination (CIE)5 provides guidelines for the luminance levels for
building facades and provides a glare rating specific to outdoor sports lighting to determine the
acceptable level of glare to nearby residences. The CIE indicates field event luminaries should not exceed
a glare rating of more than 55. Existing NFL events are in compliance with this practice6 and therefore it
is reasonable to assume that future NFL events at the Rose Bowl stadium would also meet this
requirement.

Response 8-3

Page 2.0-15 of the Draft EIR includes a description of NFL events. In addition to the information provided
in this section, additional clarification on the time for set up was provided by the RBOC and is included
herein. The setup of an NFL game would begin at 8:00 AM prior to the event day.7 However, recreational
activities, both organized and non-organized, would continue until the day of the event at which time
activity in the Rose Bowl, including the loop, Kidspace, Aquatic Center and recreational use on the grassy
areas would be restricted. The time of the restriction would be dependent on the time of the NFL game,

5 International Commission on Illumination (CIE) 150-2003, Tables 2.1 through 2.6.


6 Convention and Event Center Project EIR, Lighting Technical Report. March 27, 2012
7 Charles Thompson, RBOC, personal communication May 24, 2012.

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but could begin as early as 5:00 AM on the day of the event. RBOC currently manages operations of the
Rose Bowl and is therefore the appropriate source for such information.

As discussed in the Draft EIR, the Tournament of Roses has exclusive use of the Rose Bowl during much
of the month of December for set up of the Tournament of Roses Parade. Section 3.6 Recreation of the
Draft EIR recognizes the potential for conflicts to occur during the month of December and includes
Mitigation Measure MM 3.6-4 to reduce this impact. As discussed in Section 2.0 Project Description,
RBOC has indicated that due to the time required to set up an NFL event, as well as concern over safety
of turf conditions, it is not expected that an NFL game would occur on a day preceded by a UCLA game
due to the desire of the NFL for optimal turf conditions. While unlikely, it is possible that both a UCLA
and an NFL event could occur in the same weekend. However, impacts to the Tournament of Roses
would be minimal due to MM 3.6-4. Impact to UCLA would also be minimal as both UCLA and the NFL
would have adequate advance notice if two events were to occur in the same weekend. In the unlikely
event the Rose Bowl hosted events on both weekend days, RBOC would coordinate with UCLA to ensure
set up of the NFL event does not interfere with the UCLA game.

Response 8-4

As discussed in Response 8-3, above, information related to the set-up for each NFL game, including the
assumption that 35 delivery trucks would be required, was obtained from RBOC. RBOC manages
operation of the Rose Bowl and has provided this information based on past experience preparing for
events at the Rose Bowl.

Response 8-5

As discussed in Section 2.0 Project Description of the Draft EIR, all NFL signage would be temporary and
would remain in place for no more than 24 hours. This assumption is based on current usage of the Rose
Bowl, including UCLA and Rose Bowl/BCS Championship Games. This information was obtained from
conversations with RBOC. Further, NFL events would not be expected to occur on consecutive weekends,
meaning one Sunday would host an NFL event and the following Saturday would host a UCLA event,
and then one week later another NFL event. Therefore, the signage would need to be temporary and
changed out to reflect the needs of each specific event.

Response 8-6

Refer to Response 8-1, above.

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Response 8-7

The comment describes the mitigation measures in the Draft EIR as minimal and ineffective, but does not
suggest clarifications to the measures or additional measures. Please refer to Responses 8-11 through 8-15
regarding specific mitigation measures.

Response 8-8

The comment states that the Draft EIR does not include sufficient information related to the number of
users that would be displaced by the project. Page 3.6-25 includes a graphic depicting the number of
estimated users of the loop. The counts were taken in 2008. In addition, the City conducted additional
counts at the loop on Sunday October 21, 2012 from 11:15 AM to 12:15 AM to supplement the 2008
counts. These counts were taken at the entrance to Gate C and are as follows:

 Walk/jog: 232

 Bicycle: 65 (non-Peloton)

 Skate/Scooter: 3

 Motor Vehicle: 234

City staff also conducted surveys of the various users of the Rose Bowl in October and November of 2010.
These surveys were conducted to assess improvements to the loop that occurred in February 2010.
The findings of the survey were presented to the City Council in February 2011 in the form of a memo.
The memo is included in Appendix F3.0 of this Final EIR. The survey results indicated that
approximately half (51 percent) of the users of the loop were Pasadena residents and the majority of
responders (75 percent) used the loop for walking/running.

In addition to information provided regarding the recreational loop, the Draft EIR includes estimates for
each of the facilities at the Rose Bowl in the form of annual estimates. These are stated on pages 3.9-4 and
3.6-5 of the Draft EIR and are as follows:

 Brookside Golf Course: 800,000 annual visits

 Rose Bowl Loop: 1.5 million visits

 Brookside Park: 115,000 individuals

 Rose Bowl Aquatic Center: 16,800 swimmers, 250,000 visitors

 Kidspace Museum: 200,000 visitors

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These numbers were obtained from the same Urban Land Institute report cited extensively by the
commenter. As the LVAA has suggested the findings of the ULI report are acceptable, the baseline data
provided in the report is therefore an acceptable source of information.

The comment further states the estimates of users result in inadequate conclusions and mitigation. The
conclusions and mitigation measures presented in the Draft EIR are not based on an estimate of the total
number of users in the Arroyo Seco and would not change depending on the number of users. The Draft
EIR finds the displacement of users to be a significant and unavoidable impact due to the loss of access to
these resources, this finding is not dependent on a numerical threshold as implied by the commenter, but
on the basis that the project could substantially interfere with or preclude the use of existing recreational
facilities in the Central Arroyo Seco.

Response 8-9

The comment states that displacement of recreational users would take place throughout the Arroyo. The
Draft EIR focuses on the displacement of users in the Central Arroyo, as those users would be directly
displaced. Other areas of the Arroyo, such as the Lower Arroyo and Hahamongna would not be closed to
public use. However, traffic associated with NFL events could dissuade some users from accessing the
Hahamongna and the Lower Arroyo. Additionally, depending on the location of the user, some users
may have better access to these areas than the Central Arroyo on game days and choose to utilize these
areas rather than the Rose Bowl.

Response 8-10

Refer to Response 8-8, which relates to the need for a baseline study of users or additional analysis of the
number of users of the Arroyo Seco.

Response 8-11

The comment indicates Mitigation Measure MM 3.6-1 should be removed from the project. The Draft
EIR includes this measure to reduce the potential impact of parking on Brookside Golf Course. This
measure was developed in coordination with RBOC. However, in light of comments received the
measure has been further refined as follows:

MM 3.6-1 The RBOC or its designee shall ensure for the timely repair (repair shall occur within 24
hours) of be responsible for timely repair (within one day) of damaged Brookside Golf
Course turf areas, and any other grassy areas (such as Lot H), that are damaged as a
result of parking during displacement NFL events. The RBOC shall ensure that all turf
areas are returned to playable/usable condition within one day of an NFL event. Prior to
commencement of the use of the Rose Bowl by the NFL, the RBOC shall approve a plan

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for maintenance of damaged turf areas. The plan shall be developed in coordination with
the City and local golfers and include a timetable detailing estimated time of repair and
methodology for the repair of the turf areas. RBOC shall be responsible for the costs of all
repairs.

Brookside Golf Course has been in use as parking for Rose Bowl events for more than 20 years and
continues to be a treasured and heavily used Golf Course even with its current use as parking for events.
The addition of 13 days of parking for five years, for a total of 65 occurrences of use would not result in
irreparable damage to the golf course. Information to this effect has been provided by Brookside Golf
Operations staff, who indicate that past use of Brookside Golf Course for parking included two World
Cup events. These events consist of multiple games over several weeks and required parking the golf
course up to three times per week. The golf course was not irreparably damaged during this time frame.
Use of the golf course for parking associated with NFL usage would not require the same intensity of
usage (e.g., parking the golf course three times per week).

Based on information provided by RBOC, the current golf course is cleaned up and returned to playable
condition within one day of displacement events. The addition of NFL events would not increase the
difficulty of repairing the golf course, as the golf course would be returned to playable condition after
each individual event, no matter the condition of the course. With appropriate care and the above
mitigation measures, it is reasonable to conclude the Brookside Golf Course will continue to remain
playable beyond the five years during which the Rose Bowl would host NFL events.

Response 8-12

[The commenter states that rainy days are not adequately considered by the Draft EIR and that the mitigation plan
should include mitigation measures to address rainy day parking limitations.]

In the event that portions of the Brookside Golf Course cannot be fully utilized due to rain and/or concern
for damage to the turf for parking, there is an existing plan in-place to utilize the streets surrounding the
Rose Bowl to “stack” parked cars. These streets are: Seco St. (Rosemont Ave. to Lincoln Ave,.); West Dr.
(just south of Salvia Canyon Rd. to Washington Blvd.); Salvia Canyon Rd. (West Dr. to Linda Vista Ave.);
Washington Blvd. (West Dr. to Rosemont Ave.); Rosemont Ave. (just south of Washington Blvd. to Rose
Bowl Dr.); Rose Bowl Dr. (Rosemont Ave. to Arroyo Blvd.); Washington Blvd. (Arroyo Blvd. to Rosemont
Ave.); and Rosemont Ave. (Washington Blvd. to Arroyo Blvd.).

This plan has been used regularly in the past when portions of the golf course were not available for
parking. The typical parking arrangement is to park two rows of cars on one side with at least one row on
the opposite side, sometimes facing the same direction, sometimes the opposite direction. On wide

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streets, such as Seco St. one side can accommodate up to five rows of cars. In all cases, an emergency
access lane is kept open at all times.

Based on past the experience of the Pasadena Police Department, at no time would Brookside Golf
Course be completely unusable for parked vehicles; due to the undulating terrain and drainage patterns,
portions of all designated parking areas would be available for parking. For example, in the days prior to
the 2010 Rose Bowl Game (attendance 84,790) there was a significant amount of rain. Utilizing most of
Brookside Golf Course and the street-parking plan, all vehicles entering the Arroyo were able to be
accommodated.

Based on this information and the relatively infrequent use of this alternative parking plan, it is expected
that while it may result in a minor inconvenience to the small number of homeowners on a few of these
streets, the result is not a significant impact other than what was analyzed in the Draft Environmental
Impact Report.

Response 8-13

The comment states Mitigation Measure MM 3.6-2 is in error. This mitigation measure was included to
reduce potential impacts associated with the loss of recreational uses at the Rose Bowl on event days.
However, even with MM 3.6-2 impacts were found to be significant and unavoidable. Since publication
of the Draft EIR, the City has received comments from the public that certain portions of this measure are
infeasible, as a practical matter and for safety reasons. In particular, comments state that it is infeasible to
maintain access to the loop and other recreational uses during NFL events. However, equestrian trails
must remain accessible in accordance with the City of Pasadena’s agreement with the Santa Monica
Mountains Conservancy. For these reasons MM 3.6-2 has been revised as provided in Response 7-11 and
will be recommended to the City Council.

Response 8-14

Impact 3.6-3 that describes a beneficial effect of the project due to enhanced recreation has been removed
from the Final EIR.

Response 8-15

Section 3.6 Recreation of the Draft EIR describes the surrounding recreational opportunities including
nearby local and regional parks. Due to the wide diversity of users at the Rose Bowl and the Central
Arroyo, it would be speculative to try to determine where each of the users might go on an NFL event
day. For example, some families may choose to picnic in nearby parks, while hikers may choose Eaton
Canyon, golfers may choose Scholl Canyon or Arroyo Seco Golf Courses, cyclists would choose still a
different location, and so forth. Section 3.6-1 of the Draft EIR analyzes the impact on recreational facilities

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other than the Central Arroyo and concludes that there would not be a significant impact on such
facilities.

The comment includes a suggested mitigation measure to provide for a written Central Arroyo
Recreational Displacement Plan which “fully takes account of all lost recreation, relocation of lost
recreation and…measures required to fully mitigate….impacts.” It is important to note that the proposed
project, the temporary use of the Rose Bowl by the NFL, would displace users of the Rose Bowl no more
than 13 times per year. The suggested mitigation measures would not restore the recreational
opportunities lost due to the increased number of displacement events and would not mitigate any
significant impact identified in the Draft EIR. However, the Final EIR includes Mitigation Measure
MM 3.6-5 which was suggested during the comment period. Although not necessary to mitigate an
environmental impact, this measure requires the City to evaluate the use of City parks and provide
funding for additional maintenance and improvement of facilities as necessary.

MM 3.6-5 Prior to any NFL use of the Rose Bowl, the City shall develop a plan for monitoring park
use during event days and develop a strategy for repairing or improving parks and
recreational areas as necessary to address potential increased usage on event days. The
City shall be responsible for funding those repairs and/or improvements.

Response 8-16

Section 3.6 Recreation, “Off-Site Recreation,” provides a listing of nearby recreational facilities. It is not
the intention of this section of the Draft EIR to indicate that each of the facilities provides all of the
amenities that the Rose Bowl provides; rather, it is the intention of this section to provide the reader with
a comprehensive listing of the many recreational resources in and around the City of Pasadena. It does
not state that these parks or special facilities are comparable or equivalent to the amenities in the Central
Arroyo, but provides context to the reader of the many opportunities available. While not all of these
recreational sites may be suitable for all recreational uses, these parks, and facilities do exist and are
available for a number of recreational opportunities including hiking, softball, tennis, football, soccer and
so forth.

Response 8-17

The comment states the current baseline for the Arroyo includes degraded conditions and references a
report prepared by ULI. The facilities in the Central Arroyo can accommodate the use of the Stadium and
the Central Arroyo for 13 additional displacement events for a maximum of five years will result in
minimal wear and tear on the facilities and the facilities will remain available for the primary recreational
use during and after use by the NFL. See Response 8-11 for further discussion of Brookside golf course.
The Central Arroyo currently hosts 12 major (displacement) events and numerous minor events. As

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discussed in Topical Response 2, above, the proposed project would have no effect on the actual stadium
which is designed to host football games. As acknowledged by the commenter, other portions of the
Central Arroyo are affected during events at the Rose Bowl; these include, but are not limited to,
Brookside Golf Course and the grassy areas around the stadium. These areas are used for parking during
displacement events and for staging/hosting minor events. The ULI report points to several problems
with maintenance of the Central Arroyo, including the fact that the Arroyo is a free resource accessible by
anyone. The ULI report further recommended a “pay to play” program whereby users of the Central
Arroyo would be charged a fee to use the loop, parks and other areas, all of which are currently free and
accessible continuously (with displacement events being the one time these facilities are inaccessible).

The Draft EIR recognizes that 13 additional events will require the use of grassy areas for parking which
would degrade those areas. To mitigate this potential impact, the EIR includes Mitigation Measure
MM 3.6-1 which requires the repair of grassy areas. Therefore, contrary to the commenter’s statement that
use of the Rose Bowl by the NFL would result in decline of the Central Arroyo, the project will require
the maintenance and repair of areas damaged during NFL events. This measure will maintain the quality
of the Central Arroyo without placing a fee on the users as suggested in the ULI report. A mitigation
measure to prepare a comprehensive plan to address the recommendations of the ULI report would not
address the impacts of the proposed project.

Response 8-18

As stated in the Draft EIR, it is the intention of the City to continue to hold the RJ Canning Flea
Market/Swap Meet consistent with its current schedule. Due to the size of the Swap Meet, the Swap Meet
would not be held on the same day as an NFL event. As discussed on page 3.6-27 of the Draft EIR, use of
the facility by the NFL would have priority over all other activities, and other activities, including the
Swap Meet, would need to schedule events around the NFL schedule. With advance scheduling as
discussed in Section 3.6 of the Draft EIR, the Swap Meet would continue to be held at the Rose Bowl.

Response 8-19

As described in Section 3.6 Recreation of the Draft EIR, the NFL would have priority over all activities at
the Rose Bowl with the exception of the Tournament of Roses uses, including Rose Parade and associated
activities. If the City were to enter into an agreement with the NFL, the City may also need to renegotiate
its existing agreement with the Tournament of Roses to determine shared use of the facility. At this time it
would be speculative to predict how the facility will be shared between uses, but it is not uncommon for
NFL teams to share stadiums with other teams and uses, for example the Pittsburgh Steelers share Heinz
field with the Pitt Panthers, the Philadelphia Eagles share Lincoln Financial Field with Temple University
and two NFL teams (the New York Giants and Jets) share MetLife Stadium. Several other stadiums are

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shared between football and baseball teams. Therefore, the concept of sharing the stadium and the
associated challenges related to scheduling would not be an unfamiliar one for the NFL or many NFL
teams. Nonetheless, the specific terms of the agreements between the City and the NFL and the City and
the Tournament of Roses would detail the priority of events at the stadium. Additionally, mitigation
measure MM 3.6-4 would ensure impacts to the Tournament of Roses would be less than significant. As
discussed in Section 3.6 Recreation of the Draft EIR and Response 8-15, above, access to the recreational
uses including Kidspace and the Aquatic Center would be lost up to 13 days per year with the proposed
project. This was identified as a significant and unavoidable impact. It is not anticipated that these
facilities would be lost on other days.

Response 8-20

Refer to Topical Response 2 related to historic resources.

Response 8-21

Section 3.6 Recreation of the Draft EIR includes a discussion of potential displacement of users of the
Central Arroyo on game days. Regarding the physical impacts of displacement, page 3.6-22 states the
following” It is possible that on event days, typical users of the Rose Bowl would choose a different
recreational area within the City resulting in a slight increase in use at nearby parks…” Mitigation
measure MM 3.6-5 described under Response 8-15, above, was suggested during the public comment
period and therefore has been included in the Final EIR. Although impacts to local parks were found to
be less than significant, this measure would ensure funds are appropriately used to maintain the quality
of Pasadena parks and open spaces.

Response 8-22

The Draft EIR includes a discussion of trash associated with NFL games. As stated in Section 2.0, the
RBOC has a standard trash removal plan. The RBOC contracts with the City’s Public Works Department
to collect trash on the stadium grounds (stadium, concourse, parking lots) and the streets (Rosemont,
Seco, Arroyo, Linda Vista, Salvia Canyon, etc.) surrounding the stadium. In addition, the City’s
Neighborhood Services Division’s MASH program is deployed to do another sweep of the area streets
one or two days following a Rose Bowl event. The MASH sweep is designed to cover specific neighboring
streets in the immediate Rose Bowl area (west to Linda Vista Avenue, north to Washington, east to
Lincoln, and south to Holly Street and Arroyo Oaks). Continued implementation of these programs
would ensure impacts would remain less than significant. Although not necessary to mitigate an
environmental impact, Mitigation Measure MM 2.0-1 will be recommended to the City Council for
inclusion into the project. This measure will also ensure plastic pollution associated with NFL events does
not end up in the Lower Arroyo or the Arroyo Stream.

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MM 2.0-1 RBOC shall be responsible for removal of all trash and debris associated with NFL
events. Clean up shall commence within 24 hours of an NFL event and shall including all
areas where patrons are directed to park within the Central Arroyo. Cleanup shall be
conducted to the satisfaction of the Department of Public Works. The RBOC shall
provide funding as necessary.

Response 8-23

Refer to Response 8-22. The Initial Study for the project evaluated the potential for the temporary use of
the Rose Bowl to degrade the visual character of the Central Arroyo and determined impacts would be
less than significant and no further analysis was necessary. The aesthetic effect of trash would not
degrade the visual character of the site. Trash associated with NFL events is removed in accordance with
RBOC’s standard trash removal plan. In addition, Response 8-22 includes MM 2.0-1 which, although not
necessary to mitigate an environmental impact, would ensure trash remaining around the Rose Bowl
after an NFL event would be removed. As trash would be removed according to MM 2.0-1 and the
RBOC’s trash removal plan, visual impacts would remain less than significant.

In response to comments on the Draft EIR concerning potential historical resources impacts, a historical
resources evaluation was completed to reexamine the conclusions of the initial study regarding the
potential of the project to degrade the character of the Arroyo. The findings of this study are presented in
Topical Response 2. As determined by the historical resources study and the initial study, the aesthetic
character of the Rose Bowl and the Central Arroyo would not be degraded by the use of the stadium by
the NFL. No further analysis is necessary.

The use of signage associated with NFL events would be temporary, occurring for a period of less than 24
hours on no more than 13 occasions per calendar year for a period of no more than five years. Changes in
visual character are typically considered significant if they are permanent or would create a contrast with
existing uses. Currently, the Rose Bowl hosts numerous events, nearly all of which include signage,
banners, symbols, and commercial advertising. As indicated in the Draft EIR, additional signage such as
banners, balloons, and commercial advertisements would be anticipated and would be located primarily
in “fan fest” areas immediately outside the stadium. NFL events would also require the use of tents and
pavilions for pre-game fan events and promotions. These would be similar to the current use of tents and
pavilions for UCLA and BCS games which have not created any significant environmental impacts.

Similarly, when the Rose Bowl hosts UCLA, the Rose Bowl game or large concerts, it is not uncommon to
see tailgaters, banners, tourism installations and such, nor are recreational vehicles an uncommon site, as
the Rose Bowl hosts an annual Recreational Vehicle show. Therefore, the aesthetic impacts associated
with the NFL would not be substantially different than existing conditions at the Rose Bowl and, in fact

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many of these occurrences such as signage and banners are an expected and common sight at the Rose
Bowl. Again, past experience with these items has not created any significant environmental impact.

Response 8-24

The Draft EIR includes a description of the adopted plans related to use of the Arroyo Seco, these include
the General Plan land use element, the Green Space, Recreation and Parks Element of the Master Plan, the
Open Space and Conservation Element, the Arroyo Seco Plans, including the Hahamongna Watershed
Park Master Plan, the Central Arroyo Master Plan, the Central Arroyo Master Plan and the Arroyo Seco
Design Guidelines. The Draft EIR also includes Table 3.3-1, which summarizes the project’s consistency
with the General Plan, Green Space Recreation and Parks Element, and Arroyo Seco Design Guidelines.
The discussion in the text on page 3.3-14 of the Draft EIR summarizes the project’s consistency with the
Arroyo Seco Public Lands Ordinance. As indicated in the Draft EIR, additional signage such as banners,
balloons, and commercial advertisements would be anticipated and would be located primarily in “fan
fest” areas immediately outside the stadium. NFL events would also require the use of tents and
pavilions for pre-game fan events and promotions. These would be similar to the current use of tents and
pavilions for UCLA and BCS games. As stated in Response 8-23, the aesthetic impacts associated with the
NFL would not be substantially different than existing conditions at the Rose Bowl and, in fact many of
these occurrences such as signage and banners are an expected and common sight at the Rose Bowl.
Experience has demonstrated that these installations do not created significant environmental impacts.

Response 8-25

The comment provides a suggestion for a mitigation measure in the form of a “Central Arroyo
Management Plan that is transparent and provides a significant role for all stakeholders in the Central
Arroyo, including all the surround Arroyo neighborhoods.” The suggestion of the mitigation measures is
based on the premise that poor management practices have led to decline of the Central Arroyo, resulting
in degraded conditions. Such a mitigation measure is beyond the scope of this EIR, as no impact has been
identified that such a mitigation measure would be necessary to mitigate.

Response 8-26

The Draft EIR includes a discussion of the anticipated demand on police and fire protection services that
would be associated with the proposed project. As discussed in Section 3.5 Public Services of the
Draft EIR, both the police and fire departments have indicated they have sufficient resources to handle
the additional events at the Rose Bowl. Further, as stated on page 3.5.2-9 of the Draft EIR consistent with
current practice, the operator of the project would be required to provide sufficient private security to
offset any increased demand for police protection services as a result of the project. Regarding increased
Public Works, Rose Bowl personnel and City Administration in general, no specific needs for such

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staffing has been identified at this time. Additionally, the need for additional administrative staff is not
an environmental impact of the project. However, were increases in staffing required specifically to
support the NFL events at the Rose Bowl, the City could use funding associated with the project to staff
those temporary positions.

Response 8-27

Please see Topical Response 1 related to the detail required in a project description.

Response 8-28

The scope of work for the traffic analysis was developed in conjunction with Pasadena Department of
Transportation (PDOT) and follows City of Pasadena’s adopted traffic study guidelines to conduct traffic
studies. A complete streets methodology has not been adopted by the City as part of its traffic study
guidelines. Therefore, the traffic study does not use a complete street analysis methodology to analyze
intersections and street segments for significant traffic impacts.

Response 8-29

The scope of work for the traffic analysis was developed in conjunction with Pasadena Department of
Transportation (PDOT) and follows the City of Pasadena’s adopted traffic study guidelines. Per the
guidelines, the analysis focuses on the peak traffic hour prior to an event and the peak traffic hour post-
event. This analysis represents the timeframes when congestion is expected to be at its worst level. Hours
outside of these timeframes are expected to experience less project traffic, and therefore will have fewer
project impacts. A project impact is considered significant if the impact exceeds the threshold of
significance during the peak hour.

Response 8-30

Please refer to Response 6-2.

Response 8-31

Please refer to Response 6-2 regarding ticketless patrons. In addition, requiring patrons to display tickets
before they can enter the Central Arroyo or/and the neighborhood may not be feasible because of the
following reasons:

 Family and friends may need to travel separately and not always have the tickets with them before
they arrive

 Patrons may choose to purchase the tickets at Rose Bowl

 It may result in long traffic delays at the entry points to the Central Arroyo or the local
neighborhoods, resulting in increased traffic congestion

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Response 8-32

Please refer to Response 6-3.

Response 8-33

Table 3.7-12 as shown on page 3.7-42 of the Draft EIR provides detailed estimates of shuttle trips in the
hour before and after the NFL event, including the underlying numbers of passengers and their estimated
times of arrival and departure used to calculate the total number of trips required during the peak hour.
The duration of shuttle trips are variable depending on traffic levels and time of day.

Response 8-34

Refer to Response 6-17.

Response 8-35

The comment assumes that all NFL fans wish to tailgate and therefore will not take public transportation
or shuttles to attend a football game. Please see Response 6-7 which includes a chart indicating that other
venues experience significant transit ridership by fans. At several venues, between 20 percent and
30 percent of fans arrive by transit. For the reasons discussed in Response 6-7, the Draft EIR estimates
lower transit ridership among fans traveling to the Rose Bowl. In order to encourage transit ridership, the
Draft EIR recommends several transportation demand management (TDM) strategies as an Additional
Measure (AM 3.7-2.1). These strategies include ways to incentivize carpooling, the use of alternative
transportation modes, and the use of social media to communicate information regarding potential
modes of travel other than passenger vehicles to/from the Rose Bowl (rail/bus/shuttle routes, timetables,
etc.). The goal of the TDM measures is to reduce automobile trips and parking demand at the Rose Bowl.

On page 3.7-9, the Draft EIR states that ARTS bus service is subject to detour during large events at the
Rose Bowl. Tables 3.7-7 and 3.7-8 provide the “percentage of people traveling on local and regional
transit lines assumed to arrive/depart the event via shuttle.”

Response 8-36

[The commenter questions why “park and ride” from sites outside Pasadena are not considered and studied in the
EIR and states that the Draft EIR should include or provide for a plan to establish and implement a “park and ride”
program to NFL and other displacement events in the Rose Bowl.]

The EIR recommends a transportation demand management program that includes the following
measure: “Solicit interest in charter bus service from season ticket holders, groups, and other potential
users and provide charter bus service from locations such as downtown and neighboring cities in

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response to demand.” The measure will be revised in the Final EIR to make clear that charter bus service
includes the concept of “park and ride.”

Response 8-37

Refer to Response 8-12.

Response 8-38

Section 3.5.2 of the Draft EIR was prepared in coordination with the PPD. Correspondence with the PPD
indicates that, current staffing levels at the Rose Bowl are established to prevent an impact to the City’s
regular patrol services. Further, although the PPD currently has 350 sworn officers on staff, the
department is budgeted for a total of 383 and therefore if additional officers were required funding is
available for that purpose. Private security will be provided to offset PPD’s resource needs as necessary.
The Draft EIR includes a description of the existing tailgating policy that would be in effect for the
proposed project. As with current policy, fans will not be allowed to tailgate in parking areas once the
game has started.

Response 8-39

[The commenter states that the traffic management through the neighborhoods and throughout the Central Arroyo
that is controlled by the Police Department seems to be implemented on an ad hoc and sometimes haphazard basis.
The commenter also states that they are not aware of any publicly available written reference manual of these
policies and practices and that traffic mitigations should include a written, publicly accessible manual of all
applicable Rose Bowl event traffic/parking management policies.]

The traffic mitigation measures set forth in the Draft EIR are written and publicly available. They will also
be included in a publicly available mitigation monitoring program, which will be adopted by the City.
The existing traffic operations plan referenced on pages 3.7-47 and 48 of the Draft EIR is an internal
written document maintained by the Pasadena Police Department and is available to all police command
personnel who may assume charge of Rose Bowl event traffic management.

Response 8-40

Section 3.5.2 of the Draft EIR includes a discussion of the current staffing levels, the types of criminal
incidents associated with events at the Rose Bowl, public safety concerns such as crowd control, traffic
control, emergency and disaster response. This section was prepared in coordination with Pasadena
Police, specifically, the event management personnel who have experience preparing for and staffing
events at the Rose Bowl. Similarly, Section 3.5.1 Fire Protection was prepared in coordination with the
Pasadena Fire Department. Further, as indicated in correspondence from CSC and provided in
Appendix F3.0, there is no substantial difference in the behavior of college football fans and NFL football

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fans that would result in the need for additional police or fire protection services beyond those currently
in place at the Rose Bowl.

Response 8-41

Refer to Response 8-40 regarding coordination with the Pasadena Police Department and topics covered
in the Draft EIR. The Draft EIR includes a discussion of the existing tailgating policy which will continue
to be enforced during NFL events. In addition, CSC has indicated that NFL tailgating does not operate
“on a much larger and more intense level than UCLA tailgating” as suggested by the commenter.
Therefore, the discussion of tailgating and associated demand on police protection services discussed in
the Draft EIR is adequate.

CSC also has provided information related to the NFL’s alcohol policy, which requires alcohol sales cease
during the 3rd quarter of the game. These policies would apply to NFL events held at the Rose Bowl. The
commenter includes a suggested mitigation measure to limit alcohol consumption at the Rose Bowl
during NFL events. Such a measure would not reduce any environmental impact associated with the
project and is therefore not included in the Final EIR.

Response 8-42

The comment addresses general subject areas, which received extensive analysis in the Draft EIR. The
comment does not raise any specific issue regarding that analysis and, therefore, no more specific
response can be provided or is required. However, the comment will be included as part of the record
and made available to the decision makers prior to a final decision on the proposed project. Please see
Response 8-43 regarding police department staffing.

Response 8-43

As discussed in response to comments 8-40 and 8-41 above, Section 3.5.2 of the Draft EIR was prepared in
coordination with the PPD. Correspondence with the PPD indicates that, current staffing levels at the
Rose Bowl are established to prevent an impact to the City’s regular patrol services. Further, although the
PPD currently has 350 sworn officers on staff, the department is budgeted for a total of 383 and therefore
if additional officers were required funding is available for that purpose. PPD also provided a summary
of staffing levels at major Rose Bowl events. These included:

UCLA vs. Texas 2011 (attendance 54,583):

 Traffic Control – 75 total personnel assigned to traffic

 Crowd Control – 50 total personnel assigned to crowd control

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Rose Bowl Game 2012 (attendance 91, 245 - International Soccer would have similar numbers):

 Traffic Control – 80 total personnel assigned to traffic

 Crowd Control – 69 total personnel assigned to crowd control

The cumulative effect of the proposed project in combination with other Pasadena projects is also
discussed on page 3.5.2-9 and determined that if the need for services did arise, it would be temporary.
Further, as discussed above, PPD developed the above staffing levels to ensure existing services are
maintained and services would be supplemented with private security staffing if necessary.

Response 8-44

The Draft EIR describes the PPD approach to crime prevention, as well as the Rose Bowl’s tailgating
policy. As a general matter, NFL fans are not expected to create different impacts than are currently
experienced during displacement events at the Rose Bowl and therefore are not expected to create
significant impacts on public services. Refer to Response 8-41. The comment suggests a mitigation
measure to exclude the Oakland Raiders from use of the Rose Bowl stadium. As part of the NFL’s effort
to educate fans and keep disruptive fan behavior to a minimum, the NFL and all 32 teams have
developed a “NFL Code of Conduct.” Each team communicates its code of conduct during the preseason
to season-ticket holders and fans through mailings, online, and in-stadium signage, and other messages.
The NFL code of conduct states the following:

The National Football League and its teams are committed to creating a safe, comfortable, and
enjoyable experience for all fans, both in the stadium and in the parking lot. We want all fans
attending our games to enjoy the experience in a responsible fashion. When attending a game, you
are required to refrain from the following behaviors:

 Behavior that is unruly, disruptive, or illegal in nature.

 Intoxication or other signs of alcohol impairment that results in irresponsible behavior.

 Foul or abusive language or obscene gestures.

 Interference with the progress of the game (including throwing objects onto the field).

 Failing to follow instructions of stadium personnel.

 Verbal or physical harassment of opposing team fans.

Event patrons are responsible for their conduct as well as the conduct of their guests and/or
persons occupying their seats. Stadium staff will promptly intervene to support an environment
where event patrons, their guests, and other fans can enjoy the event free from the above behavior.
Event patrons and guests who violate these provisions will be subject to ejection without refund
and loss of ticket privileges for future games.

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Teams may add additional provisions to the standard code based on local circumstances or preferences.
Several venues now require fans who have been ejected from NFL games to complete an online fan
conduct class before being allowed to reenter the venue.

The suggested mitigation measure to exclude the Oakland Raiders from the Rose Bowl stadium due to
the perceived impact of bringing more crowd control, crime and alcohol impacts than other NFL teams is
not necessary to mitigate any significant environmental impact.

Response 8-45

This comment questions the adequacy of the City’s current disaster planning efforts and suggests that the
City adopt a mitigation measure to require the City to prepare an LVAA emergency response plan that
would cover all displacement events at the Rose Bowl. The Draft EIR addresses public safety and
emergency access in Section 3.5.1 Fire Protection and 3.5.2 Police Protection, including a discussion of
emergency preparedness and the maintenance of emergency access for public safety vehicles. This
analysis concludes that the proposed project would not have a significant impact on public safety
services. As the project itself is not expected to have a significant impact on public safety services, no
mitigation is required.

Response 8-46

It is standard practice, accepted by the various air districts in California including the SCAQMD, to use
the nearest air quality monitoring station for data on ambient air quality. These stations have been
carefully sited by the air districts to provide quality data for the area in which they are located. They are
also carefully calibrated and maintained, and collect data over long periods of time to provide an accurate
measure of ambient air quality that is largely independent of statistical outliers. Taking ambient air
quality measurements locally and only during displacement events at the Rose Bowl would provide
results that are not a true reflection of ambient air quality. This would also likely result in baseline
pollutant levels much higher than generally experienced in the area, which would be counter to the
conservative analysis typical of a CEQA assessment.

Response 8-47

The relationship between topography, weather, and air pollutant concentrations can be complicated and
difficult to fully analyze. For example, high temperatures in canyon areas often create strong updrafts
along the canyon walls that would tend to quickly flush any air pollutants in the canyon out into the
surrounding areas as opposed to concentrating pollutants within the canyon. However, a quantitative
analysis to this level of detail is not required for this EIR.

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Response 8-48

Greenhouse gas (GHG) emissions have by nature globally cumulative impacts. GHG emissions in
Pasadena have the same impact as emissions in other parts of California or anywhere else. Current state
law requires reductions relative to a California-wide baseline, not a local baseline, so that baseline
emissions in Pasadena are irrelevant to discussion of the GHG emissions or reductions associated with
the Rose Bowl. Similarly, the draft GHG significance thresholds developed by the SCAQMD are based on
compliance with AB 32, which as mentioned requires reductions relative to a state-wide baseline.

Response 8-49

The comment states several projects under consideration in the City of Pasadena were not included in the
cumulative analysis. The cumulative project listing provided on page 2.0-21 and 2.0-22 of the Draft EIR
includes 32 projects within the City of Pasadena including the Marriott Residence Hotel, the sediment
removal project, and the multi-benefit project. The City does not have an application related to the Arts
Center College of Design Master Plan; therefore, there is no project to include in the cumulative projects
list. According to the City of Pasadena, construction of the La Loma Bridge Rehabilitation project is
expected to be complete by fall of 2013. There may be minor overlap between the La Loma bridge project
and the proposed project, but impacts are not expected to be cumulative. Per the Project Description, the
proposed NFL displacement events at Rose Bowl can begin in fall 2013. There may be minor overlap
between the construction project and NFL displacement events; however this is not anticipated to impact
traffic and circulation relating to the project as the La Loma bridge does not serve as a direct route to the
Rose Bowl. Therefore, the discussion of cumulative effects provided in the Draft EIR is adequate.

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Letter No. 9: West Pasadena Residents Association


West Pasadena Residents Association
Fred Zepeda
October 1, 2012

Response 9-1

Refer to Response 7-3.

Response 9-2

Please see Topical Response 1 regarding the adequacy of the Project Description.

Response 9-3

Refer to Response 7-8, above.

Response 9-4

Refer to Response 7-6, above.

Response 9-5

Refer to Topical Response 2 regarding historic resources.

Response 9-6

The Hahamongna Watershed Master Plan includes recommendations for improvements related to the
Hahamongna Watershed and specific projects proposed in the Hahamongna Park, such as stepping
stones, habitat restoration, and park infrastructure. The statement that the HMP does not include policies
relevant to the project is not intended to imply there is no connection between the Hahamongna and the
Central Arroyo rather that the HMP includes an implementation plan and projects rather than general
policies related to the Arroyo. Similarly, the General Plan Open Space and Conservation Element policies
relate more to the acquisition of wilderness areas. Nonetheless, these policies have been added to
Table 3.3-1 Project Consistency with Existing Land Use Plans, has been updated to include policies from
the General Plan Open Space and Conservation Element.

Response 9-7

General Plan policies and objectives present broad concepts for development that are designed to guide
growth within the City. These policies and objectives are general by nature. Objective 17 states “provide
adequate recreation opportunities to all residents of the City” At the broad policy level, the project is
consistent with this policy in that the recreational opportunities as a whole would continue to be
adequate and the Central Arroyo would continue to be accessible to residents for the majority of the year.
The recreational impact identified in Section 3.6 Recreation, is a site-specific impact that occurs. The

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project therefore can be consistent with broad policy objectives while still resulting in a site-specific
impact.

Response 9-8

The commenter is referred to the letter submitted by CSC which provides additional information relating
to the similarities between college and NFL events. The letter is provided in Appendix F3.0 of the Final
EIR.

Response 9-9

Refer to Response 7-10 regarding the need for a baseline study.

Response 9-10

Please refer to Response 7-16, which includes a detailed response on individual intersections and street
segments mentioned in the comment.

Response 9-11

Please refer to Response 7-14.

Response 9-12

The public transportation “mode split” assumptions were determined based on surveys and review of
historical information related to large events held at Rose Bowl, other large event venues in Southern
California and available information on various NFL venues throughout the nation. Please refer to
Response 6-7 for detailed information on travel mode shares data from the aforementioned sources.

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Letter No. 10: San Rafael Neighborhoods Association


San Rafael Neighborhoods Association
PO Box 92617
Pasadena, CA 91109
Ron Paler, President
October 7, 2012

Response 10-1

This comment is an introduction to comments that follow. Refer to Responses 10-2 through 10-4 for
specific responses.

Response 10-2

[The commenter states that the Draft EIR fails to include Avenue 64 as a Principal Arterial, connecting the
Northbound 110 Pasadena Freeway with Colorado Boulevard, and the Avenue 64/Marmion Way off-ramp from the
110 Pasadena Freeway.]

Avenue 64 runs north/south between the SR-110 Freeway in the South and Colorado Boulevard in the
North. The majority of project patrons using Northbound SR-110 to travel to the Rose Bowl on event days
are expected to stay on the freeway until they reach Orange Grove Boulevard or other exits east of
Orange Grove Boulevard since they present a more direct route to Rose Bowl. Based on detailed
discussions with PDOT and PPD regarding past experience during large displacement events held at the
Rose Bowl, it is acknowledged that a small number of patrons may choose to take indirect routes.
However, these routes are not expected to experience substantial increases in traffic. Since there are only
a small number of vehicles expected on potentially many indirect routes, project traffic distribution, and
assignment on these routes would be speculative. Use of Avenue 64 from SR-110 Freeway to reach Rose
Bowl is considered as an indirect route and therefore is not expected to experience a significant impact.
Therefore, assigning any material project traffic to this route is considered speculative and would divert
trips from their more likely path of travel, reducing impacts at other intersections.

Response 10-3

[The commenter states that the Draft EIR fails to address the eastbound exit of the 134 freeway at Figueroa Street.]

Majority of project patrons using SR-134 to travel to Rose Bowl on event days are expected to stay on the
freeway until they reach the Linda Vista exit or continue to the I-210 freeway. Based on detailed
discussions with PDOT and PPD regarding past experience during large displacement event held at the
Rose Bowl, it is acknowledged that a small number of patrons may choose to take indirect routes.
However, these routes are not expected to experience substantial increases in traffic. Since there are only
a small number of vehicles expected on potentially many indirect routes, project traffic distribution, and

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assignment on these routes would be speculative. Taking an exit on to Figueroa Street from the SR-134 to
head towards the Rose Bowl via Colorado Boulevard and available north/south routes such as Linda
Vista Avenue or Orange Grove Boulevard to reach the Rose Bowl is considered an indirect route and
therefore is not expected to experience a significant impact. Therefore, assigning any material project
traffic to this route is considered speculative and would divert trips from their more likely path of travel,
reducing impacts at other intersections.

Regarding the comment on the EB 134 exit at San Rafael, the intersection of SR 134 and San Rafael
Avenue was considered significant and unavoidable after mitigation. The reexamination for the weekday
peak hours of 8:00 to 9:00 AM would not be relevant for this project as it does not coincide with
timeframes of peak traffic generation for an NFL game. Therefore, this scenario was not analyzed in the
EIR.

Response 10-4

According to the City of Pasadena, construction of the La Loma Bridge Rehabilitation project is expected
to be complete by Fall of Year 2013. Per the Project Description, the proposed NFL displacement events at
Rose Bowl can begin as early as in Fall of Year 2013. There may be minor overlap between the renovation
of the La Loma Bridge and NFL displacement events; however traffic shift and diversion as a result of the
La Loma Bridge construction is not anticipated to impact traffic and circulation of the proposed project as
it is not a direct route for Rose Bowl traffic.

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Letter No. 11: Planning Commission


City of Pasadena Planning Commission
Vince Farhat
September 23, 2012

Response 11-1

Refer to Response 7-1.

Response 11-2

Refer to Response 7-1.

Response 11-3

Section 15087 of State CEQA Guidelines requires that public notice of the availability of a Draft EIR be
provided at the same time the Notice of Completion is sent to the State Office of Planning and Research.
This Notice of Availability is required to be mailed to all organizations and individuals who have
requested such notices in writing. In addition, Section 15087 also requires that notice also be given by at
least one of the following methods:

1. Publication in a newspaper of general circulation

2. Posting of notice on and off the site in the area where the project is located

3. Direct mailing to owners and occupants of property contiguous to the parcel where the project is
located

In addition to the state requirements above, the City’s Environmental Policy Guidelines require that the
notice be mailed to all property owners within at least 300 feet of the project site.

For this project the City mailed approximately 90 notices to organizations and individuals who have
asked to be notified of all environmental notices, published the notice in the Pasadena Journal on
August 9, 2012, mailed the notice to all property owners (approximately 600) within 500 feet of the
property on which the Rose Bowl is located, mailed the notice to the designated contacts for all
neighborhood associations in Pasadena (approximately 90) registered within Neighborhood Connections,
and posted the notice on the City’s website.

Response 11-4

Refer to Topical Response 1 regarding the Project Description.

Response 11-5

Refer to Response 8-3, which related to setup and break down of events.

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Response 11-6

Refer to Topical Response 1 regarding the Project Description and Response 7-1 regarding review of the
terms and conditions associated with the project.

Response 11-7

The comment raises issues that do not appear to relate to any physical effect on the environment. The
comment will be included as part of the record and made available to the decision makers prior to a final
decision on the proposed project. However, as proposed, the project will involve a lease agreement that
will have a term of no more than five years. Upon expiration of the term, the tenant will have no further
right to use the stadium.

Response 11-8

The comment suggests reducing the proposed five year term of the lease. Refer to Response 12-5 for
analysis of a reduced timeframe for the project. The comment asks at what point impacts associated with
the project are “irreversible.” The impacts identified in the EIR as significant and unavoidable are
generally event specific. For example, traffic and air quality impacts exceed the thresholds at each
individual event, while recreation impacts occur due to the displacement of users on event days. Impacts
such as traffic, noise, and recreation would be eliminated once the five year term of the NFL lease is up,
however, other effects such as resources committed to the project would be irreversible. These
irreversible effects are discussed in Section 5.0 Other CEQA Considerations.

Response 11-9

This comment asks about the “shelf-life” of the Draft EIR. That is, the commenter asks whether the Draft
EIR would be “stale” if the NFL does not come to the Rose Bowl until 2014, 2015, or 2016. This EIR is
being prepared in conjunction with a proposed amendment to the Arroyo Seco Lands Ordinance, which
would increase the number of displacement events allowed at the Rose Bowl without specific findings by
an additional 13 events annually. In accordance with CEQA, if the NFL does not choose to come to Los
Angeles until 2014, 2015, or 2016, the City would need to evaluate at that time whether conditions have
changed that warrant supplemental environmental analysis in connection with any subsequent
discretionary approvals.

Response 11-10

The comment points to a typographical error in Section 4.0 Alternatives of the Draft EIR. Page 4.0-2
includes a statement of the project objectives, these objectives differ from the project objectives listed
correctly in Section 2.0 Project Description. The project objectives listed in Section 2.0 are correct. The
Final EIR has been revised to correct the typographical error.

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Response 11-11

The commenter inquires whether or not the list of pending and approved projects includes all proposed
developments on the former Ambassador College and proposed expansion plans for Art Center College
of Design or whether any other projects on Fair Oaks should be included.

Table 2.0-1 Pending and Approved Projects included in the Draft EIR provides a list of cumulative
projects that were included in the analysis of the Draft EIR. While there is no pending or approved project
for the Art Center College of Design, there is a project on the former Ambassador College Campus
(Ambassador Project). This project is listed as No. 7 on the list. However, staff notes that the information
contained in the table incorrectly identifies the project as a Residential Project with 39 Dwelling Units and
thanks the commenter for the opportunity to provide clarification. The entire project that was approved
by the City Council includes new construction of 248 Senior/Life Care Units, 70 condominiums and the
remodel/retention of an existing 46 multi-family residential units (the “39 Dwelling Unit” project
represents one portion of the 70 condominiums). See Section 2.0 Corrections and Additions.

CEQA requires that an EIR include a cumulative impact analysis that looks at the impacts of a proposed
project in combination with the impacts of other past, present, and reasonably foreseeable projects
identified within a study area. The Ambassador Project was previously analyzed in a separate EIR which
was certified by the City and all of its environmental impacts have been disclosed. However, for the
purposes of the cumulative analysis, the direct, indirect, and cumulative impacts of the project with the
reconciliation of the cumulative project list would not be materially different from the analysis presented
in the Draft EIR. Staff has analyzed the cumulative project impacts including the corrected Ambassador
Project and determined that traffic impacts within the assigned study area would be no different than
those disclosed in the Draft EIR and no new significant impacts would result.

Regarding air quality, the SCAQMD’s CEQA Handbook identifies possible methods to determine the
cumulative significance of land use projects. These methods differ from the methodology used in other
cumulative impact analyses in which all foreseeable future development within a given service boundary
or geographical area is predicted and its impacts measured. The SCAQMD has not identified thresholds
to which the total emissions of all cumulative development can be compared. Instead, the SCAQMD
methods are based on performance standards and emission reduction targets necessary to attain the
federal and state air quality standards as predicted in the AQMP. In addition, projects that do not exceed
the project-specific SCAQMD thresholds of significance should be considered not cumulatively
considerable unless there is other pertinent information to the contrary. As the proposed project would
exceed the SCAQMD thresholds of significance and would result in a cumulatively considerable air

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quality impacts as disclosed in the Draft EIR. The revision to the cumulative project list would not change
this conclusion.

Regarding greenhouse gas emissions, the vast majority of the emissions associated with the project are
related to vehicle trips to the Rose Bowl on event days. The number of trips associated with the project
would not change as a result of the correction to the cumulative project list. As discussed in Section 3.2
Greenhouse Gases, the project would meet the requirements of AB 32 as project emissions would not
exceed the established threshold. Although the threshold is project specific, due to its use in achieving a
statewide goal, it also serves as a cumulative impact threshold. As the number of trips associated with the
project would not change, the emissions associated with the project would not change, and the project’s
contribution to a cumulative impact would continue to be less than significant.

As discussed in Section 3.4 Noise, there would be no cumulative impact from traffic noise as traffic
associated with cumulative projects would be minimal on event days as drivers avoid the Rose Bowl.
Therefore, the conclusions presented in the Draft EIR would not change as a result of the correction to the
cumulative project list.

The correction to the project list would not affect public service demand, as the project has been approved
by the City and is included in PPD and PFD planning efforts. Therefore, the conclusions presented in the
Draft EIR would not change as a result of the correction to the cumulative project list.

Land use and Recreation impacts were determined to be site specific, and therefore the conclusions
presented in the EIR would not change as a result of the correction to the project list.

Response 11-12

The traffic study prepared for the Draft EIR provides a figure of 4,000 employees at the Rose Bowl for a
displacement event. This figure was provided by RBOC based on their past experience of events at the
Rose Bowl. Since the GHG emissions are compared to an efficiency threshold based on emissions per
service person (SP), SP defined as employees and residents, the effect of reducing the number of SP
would be to increase the level of GHG emissions per SP, with the caveat that reducing the number of SP
would also reduce GHG emissions as well, since SP also produce GHG emissions. However, assuming
that GHG emissions remain constant despite reducing SP, the number of SP would need to be less than
1,445 persons to exceed the draft significance threshold.

Response 11-13

The GHG analysis for the Draft EIR does not include a baseline study specific to this project. The draft
significance thresholds developed by the SCAQMD, like similar thresholds used in other air districts, are

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specifically designed to enable the region to meet the reductions in GHG required by state law,
specifically AB 32. AB 32 includes a state-wide baseline study, so that GHG emissions in the region are
effectively measured against this baseline through use of the significance thresholds.

Response 11-14

Refer to Topical Response 2 regarding historic resources.

Response 11-15

Refer to Response 9-6 related to policy consistency.

Response 11-16

Impact 3.3-1 states the proposed project would not divide an established community. Generally division
of a community under CEQA is found to have a significant impact when some physical barrier is being
proposed that would have permanent or long-term impacts on the community. For example, a highway
project, pipeline, or transmission line all could divide an established community permanently or for the
foreseeable future. The proposed project would not create a long-term physical barrier, as the barrier will
be temporary and intermittent, residents can (and do) remove the temporary barriers and join the traffic
along one of the routes into or out of the neighborhood. In addition, residents can walk or bike across the
road if so desired. Although the traffic generated by the project would be a nuisance, it would not create a
physical barrier that would divide the community.

Response 11-17

The land use consistency analysis includes policies applicable to the proposed project. As discussed in
Topical Response 2 above, the proposed project would have no impact on historic resources; therefore
the discussion of land use policies would not differ.

Response 11-18

Refer to Response 9-7 regarding internal consistency.

Response 11-19

Pollutants occurring as a result of tailgating would be expected to consist of typical urban pollutants,
including oil and other fluids from motor vehicles and food waste. Compounds and pollutants from
surface areas can move through the soil and end up in the groundwater. For example, pesticides and
fertilizers can find their way into groundwater supplies over time. Pollutants such as oil and gas leaking
from cars parked on the grassy areas such as Lot H and Brookside Golf Course could also find their way
into groundwater over time. The trace amounts of motor vehicle-related pollutants deposited during a
displacement event would be filtered by the soils and would not be expected to be present at

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concentrations high enough to reach groundwater. These pollutants would remain within areas of the
Brookside Golf Course used for parking during displacement events and would break down gradually, a
process that would be facilitated by irrigation of the golf course. All projects within the City must comply
with Section 8.70 (Stormwater Management and Discharge Control) of the Pasadena Municipal Code.
Implementation of good housekeeping requirements such as the collection, storage, and minimization of
runoff would occur under this ordinance. This would reduce water quality impacts associated with
operational activities to less than significant. Further, information provided by the RBOC indicates that
irrigation is closely monitored to ensure that it is done only when and to the extent necessary, and thus
does not generate runoff.

Should rain occur immediately after a displacement event, the landscaping at the golf course would be
expected to retain surface flows within the golf course area. Since the pollutants expected to occur as
result of additional displacement events would be typical urban pollutants, compliance with the City’s
Standard Urban Stormwater Mitigation Plan (SUSMP) would ensure that impacts are less than
significant. Although impacts would be less than significant, the following mitigation measure will be
suggested to the City Council for inclusion into the project:

MM 2.0-2 After each NFL event at the Rose Bowl, RBOC shall be responsible for visually inspecting
parked areas for signs of oil, fluids, or other potentially harmful substances within 24
hours of an NFL event. In the event such substances are discovered, the soil shall be
removed and disposed of in accordance with applicable regulations. RBOC shall provide
the City of Pasadena Department of Public Works with a written summary of the visual
inspection and any necessary soil removal.

Response 11-20

Refer to Response 8-43, above for the summary of the differences in police services required for UCLA
games, as compared to a sold out Rose Bowl game. As can be seen from the difference in police protection
services, the PPD has the resources available to staff events of more than 75,000 which is the anticipated
attendance of an NFL event at the Rose Bowl. Regarding the difference in treatment of this topic in the
Draft EIR and the LA Convention and Event Center (Farmer’s Field) EIR, the Farmer’s Field project
includes construction of a new multi-purpose stadium, new convention space, and two parking
structures. Although both projects include the use of a stadium by the NFL, the scope of the Farmer’s
Field project is far greater than the use of an existing stadium by the NFL. As such, it would not be
particularly useful to readers of the Draft EIR to compare the two environmental documents due to the
vast differences in scope. Therefore the treatment of issues such as public services is appropriately

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different. Please also see the letter from CSC set forth in Appendix F3.0 which indicates that security
needs are not expected to be different for NFL and college football games.

Response 11-21

The Draft EIR includes a discussion of the closure of Fire Station #39 in Section 3.5-1 Fire Protection.
Based on information provided by the Pasadena Fire Department, the Fire Station will reopen in 2013
before the Rose Bowl is in use as a temporary facility for the NFL. As discussed in Section 3.5.1, the
Pasadena Fire Department has indicated that it has adequate facilities and staff to serve the project.

Response 11-22

Section 3.6 Recreation of the Draft EIR analyzes the potential for an increase in nearby parks due to
displacement around the Rose Bowl due to NFL events. Due to the wide variety of uses at the Rose Bowl,
hiking, biking, running, softball, baseball, golf, and many more, it can be assumed that no one park or
open space could accommodate all of the displaced uses. Therefore, it is more likely that recreational
users would be dispersed throughout the City and region. Due to the natural lack of organization
associated with most recreational uses it is difficult to quantify the number of users that would be
displaced, and even more difficult to determine where users might go. Some users may choose a different
type of recreation and some might choose to stay home. For this reason, it would be speculative to
attempt to quantify the impact on nearby parks. Although no significant impact is anticipated, mitigation
measure MM 3.6-5 was included in the Final EIR. Similarly, traffic associated with NFL events could
dissuade some users from accessing Hahamongna and the Lower Arroyo, however, depending on the
location of the user, some users may have better access to these areas than the Central Arroyo on game
days and choose to utilize these areas rather than the Central Arroyo. As discussed, MM 3.6-5 has been
incorporated into the project.

Response 11-23

Refer to Response 8-10 regarding the need for baseline studies.

Response 11-24

Impact 3.6-3 has been removed from the Final EIR.

Response 11-25

Please refer to Response 10-4.

Response 11-26

As stated in the Draft EIR under mitigation measure MM 3.7-6 on Page 3.7-107, Parking and traffic
management staff for the Rose Bowl will implement all traffic control and neighborhood protection plans

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for NFL game days, as are implemented for other events at the Rose Bowl. The protection plan involves
barricading of local neighborhood streets to prevent un-authorized spectator parking and cut through
traffic on streets that are susceptible to spillover parking because of proximity to the Rose Bowl.

Response 11-27

Refer to Response 6-17.

Response 11-28

Please refer to Response 7-16.

Response 11-29

Please refer to Response 7-16.

Response 11-30

Page 3.7-2 of the Draft EIR correctly refers to the City’s 2004 Mobility Element. The reference in Table 3.7-
6 is a typo and has been corrected to say “2004.”

Response 11-31

Please refer to Response 6-1.

Response 11-32

Please refer to Response 8-28.

Response 11-33

Please refer to Response 6-7.

Response 11-34

Refer to Response 6-9.

Response 11-35

Provided below is a summary of the sources used to inform the Average Vehicle Occupancy (AVO) for
the traffic study. This is a combination of empirical data (from surveys) and information from other
planning studies:

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Average Vehicle Occupancy (AVO) Data

AVO
Stadium Reference
Weekday Weekend
Pasadena Rose Bowl, Field Data Collection --- 2.5
UCLA vs. Cal, 2011
Arizona Cardinals Field Data Collection 2.7 --
Stadium, BCS Game,
2007
Arizona Cardinals Field Data Collection 3.0 --
Stadium, Fiesta Bowl,
2007
Pasadena Rose Bowl Traffic Operations Manual 3.0
Farmers Field, Convention and Event Center Project EIR, 2012 2.7 3.0
Downtown Los Angeles
3Com Park, San Farmers Field EIR 2.5
Francisco
49ers Santa Clara Farmers Field EIR 3.0
Stadium Project, City of
Santa Clara
Arizona Cardinals Farmers Field EIR 3.0
Stadium
Los Angeles Coliseum Farmers Field EIR 2.7
City of Industry Stadium Farmers Field EIR 3.0
Rose Bowl Renovation Rose Bowl Stadium Renovation Project EIR, 2005 3.0
Pasadena Rose Bowl EIR for the Temporary Use of the Rose Bowl 2.7 3.0
Stadium by the NFL

As can be seen in the table, the AVO factors used in the traffic analysis are consistent with other NFL
venues summarized above. Observations were conducted for the UCLA vs. vs. Cal (UC Berkley) game on
Saturday, 10/29/2011. The results of the survey indicated an AVO of 2.5

Response 11-36

Based on the responses to the comments above, it is not anticipated that the proposed project would
generate any additional significant impacts aside from those disclosed in the Draft EIR.

Response 11-37

Refer to Response 6-18 related to the range of alternatives, and specifically the reduced attendance
alternative.

Response 11-38

This comment does not refer to the analysis provided in the Draft EIR. Instead, the commenter asks
whether CEQA requires that the City make every good faith effort to fully mitigate all negative

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environmental impacts before recommending the adoption of a statement of overriding considerations.


Without regard to whether City staff will recommend a statement of overriding considerations to the City
Council, State CEQA Guidelines Section 15126.4 requires that an EIR propose and describe feasible
mitigation measures to minimize the significant environmental impacts identified in the EIR.

Response 11-39

Having reviewed the comments received to date on the Draft EIR, the preparers of this EIR believe that it
meets the requirements of CEQA, including all requirements related to the adoption of mitigation
measures.

Response 11-40

A list of the preparers of the EIR is provided in Section 7.0 List of Preparers, of the Draft EIR.

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Letter No. 12

To: David Reyes, Principal Planner/Zoning Administrator Job No. 1136.01


From: Jessica Kirchner, Impact Sciences
Subject: Planning Commission Comments
Date: September 27, 2012

Rose Bowl Planning Commission 9/19

Commissioner Hanson

EIR needs a cultural resources section.


1
Farhat – see attached comments

Norton 2
The SOC and findings should be circulated for 90 days and adequate public comment should be provided
3
prior to City Council. There should be a limit on tailgating. The project description is inadequate - must
4
know the details of the contract. An alternative exploring 2 or 3 years of use should be included to see if
5
there would be fewer long term impacts. There should be an analysis of other sources of revenue
enhancement that do not have the impacts associated with NFL use. 6
Jones

Historical resources should be included; public services impact needs to be addressed, project description is
7
inadequate, additional alternatives should be explored.

Hickambottom
8
More public notice is needed; certain communities are missing from the meeting. What are the spillover
effects of recreational impacts to other parks to the east and north? There needs to be meaningful mitigation
9
measures.

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Pescio
10
How was 75,000 picked for attendance when seating capacity is 88,000? Recreational impacts need to be
11
analyzed – are there any counts for weekend users? What percent tailgate? Is the peak arrival/departure
reduced or longer due to tailgating? Is it possible to limit tailgating? 12

Quirk
13
Public notification needs to go beyond the minimum. The only benefit of the project is the financial benefit.
14
Cultural resources should be addressed. Land use impacts due to more events. What is the baseline for
public safety and services of neighborhoods? The traffic boundary should be extended? Alternative 2 is
15
arbitrary, is it realistic? Would the NFL allow attendance of 55,000?
16

Nelson 17
Cultural resources should be included. Traffic impacts are understated. Land use is inconsistent with the
18
General Plan and Parks Element. Will Lot H areas be acceptable by the next day for AYSO games? Parsons 19
parking may be lost, what would the effects of that be? What is the loss of revenue to the City by losing the 20
ability to park/shop in Old Pasadena on game days? The Planning Commission should be reviewing the
project as a matter of right. 21
Hansen
22
Reducing the five years – at what point do impacts become irreversible? What are the deal points with the
NFL? Mitigation measures must be reasonable and be supported. There needs to be a baseline study for the
arroyo, factual is better than estimated. How many recreational users are at the Bowl and where do they
23
come from? What are the effects of garbage and chemical waste? In Table 3.3.1 the project is inconsistent
24
with the majority of the policies. 25

Hall
26
Where does the 75,000 number come from? The public services impact should be further studied. Cultural
resources should be included. The traffic study did not sufficiently study traffic on residential streets.
27

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Letter No. 12: Rose Bowl Planning Commission Meeting September 19, 2012
Rose Bowl Planning Commission Meeting
September 19, 2012

Response 12-1

Refer to Topical Response 2 regarding historic resources.

Response 12-2

Refer to Response 7-1, regarding circulation of Statement of Overriding Considerations.

Response 12-3

Please see Response 8-44 for a discussion on tailgating.

Response 12-4

Please see Topical Response 1 for a discussion on the adequacy of the Project Description.

Response 12-5

The comment suggests an alternative exploring a shortened time frame of two to three years rather than
five years. First, it is certainly possible that the project will result in occupancy of the Rose Bowl by an
NFL team for no more than two to three years. Second, analyzing an alternative that would limit the
maximum time for temporary occupancy by an NFL team to two to three years would not offer
substantial environmental advantages over the project or other alternatives that were presented in the
EIR. The impacts identified in the EIR as significant and unavoidable are event specific. For example,
traffic and air quality impacts exceed the thresholds at each individual event, while recreation impacts
occur due to the displacement of users on event days. Reducing the timeframe of the use of the Rose Bowl
by the NFL would possibly reduce the number of occasions on which significant impacts would occur,
but those impacts would remain significant and unavoidable. Thus, this alternative would reduce
impacts in the same manner as Alternative 3, which would reduce the number of displacement events
that could occur in any one year. Both under the suggested alternative and alternative 3, the same
number of intersections would be significantly impacted and recreational users would be displaced on
event days. However, under both alternatives, the number of occasions on which the impacts occur
would be reduced.

Response 12-6

Alternative 3 analyzes an alternative project that does not involve NFL use of the Rose Bowl.

Response 12-7

Refer to Topical Response 2 regarding historic resources.

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Response 12-8

Refer to Response 11-3 regarding adequacy of notice.

Response 12-9

Section 3.6 Recreation of the Draft EIR describes the surrounding recreational opportunities including
nearby local and regional parks. Due to the wide diversity of users at the Rose Bowl and the Central
Arroyo, it would be speculative to try to determine where each of the users might go on an NFL event
day. For example, some families may choose to picnic in nearby parks, while hikers may choose Eaton
Canyon, golfers may choose Griffith Park or Santa Anita Golf Courses, cyclists would choose still a
different location, and so forth. Section 3.6-1 of the Draft EIR analyzes the impact on recreational facilities
from the displacement of Central Arroyo users on game days and concludes that there would not be a
significant impact on such facilities.

The comment includes a suggested mitigation measure to provide for a written Central Arroyo
Recreational Displacement Plan which “fully takes account of all lost recreation, relocation of lost
recreation and…measures required to fully mitigate….impacts.” It is important to note that the proposed
project, the temporary use of the Rose Bowl by the NFL, would displace users of the Rose Bowl no more
than 13 times per year. The suggested mitigation measures would not restore the recreational
opportunities lost due to the increased number of displacement events and would not mitigate any
significant impact identified in the Draft EIR. However, the Final EIR includes Mitigation Measure
MM 3.6-5 which was suggested during the comment period. Although not necessary to mitigate an
environmental impact, this measure requires the City to evaluate the use of City parks and provide
funding for additional maintenance and improvement of facilities as necessary.

MM 3.6-5 Prior to approval of any lease agreement with the NFL, the City shall develop a plan for
monitoring park use during event days and develop a strategy for repairing or
improving parks and recreational areas as necessary to address increased usage on event
days. The City shall be responsible for funding those repairs and/or improvements.

Response 12-10

Attendance of 75,000 is consistent with the typical capacity of an NFL stadium. Therefore, 75,000 was
chosen as an appropriate attendance number to host an NFL team without imposing on the community
the full impacts of maximum attendance at the Rose Bowl.

Response 12-11

Refer to Response 15-9 for additional counts for recreational users. Tailgating at NFL games is expected
to occur to the same extent as tailgating at college football games played at the Rose Bowl and the

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experience with tailgating is expected to be similar. As discussed in the letter provided by CSC and
provided in Appendix F3.0 of the Final EIR, The duration of tailgating on the West Coast is somewhat
limited because patrons are not allowed to arrive at the parking lot until a certain time, and the evening
West Coast games begin earlier in the day (in order to maximize national viewing of all games). Thus, the
earlier kick-off times of evening West Coast games reduces the duration of pre-game tailgating. In
addition, West Coast games often do not have games televised immediately afterward, which minimizes
tailgating after the game. Thus, there are inherent limits on the duration of tailgating for West Coast
games. Also, per current RBOC policy, tailgating is required to shut down after kickoff. To the extent that
tailgating encourages vehicles to arrive before the peak hour, this would reduce the most significant
traffic and noise impacts, which occur during the peak hour.

Response 12-12

[The commenter (Planning Commissioner Pescio) questions if the peak arrival/departure is reduced or longer due to
tailgating.]

Please refer to Response 12-11, regarding duration of tailgating expected at the proposed NFL
displacement events.

Information pertaining to the percentage of tailgaters is not available and may vary from game to game
and to a large extent, depends on the policies for tailgating at the venue. The peak arrival period is based
on the assumption that 50 percent of spectators arrive in the hours before a weekday game and 75 percent
depart in the hour immediately after the weekday game is over. On a weekend, 40 percent of spectators
arrive in the hour before a game and 60 percent of spectators depart in the hour after game. It is possible
that a percentage of these spectators may tailgate during the hours prior to the event or post event. To the
extent that tailgating encourages vehicles to travel outside the peak hour, this would reduce the most
significant traffic and noise impacts, which occur during the peak hour. Limiting tailgating would be at
the discretion of the Pasadena Police Department and the Rose Bowl. Tailgating is currently prohibited
during games. Further limiting the times of tailgating would not be anticipated to reduce any significant
environmental impacts identified in the Draft EIR.

Response 12-13

Refer to Response 12-8.

Response 12-14

Please see Topical Response 2, regarding cultural resources. Land use impacts and addressed in
Section 3.3 of the Draft EIR. The existing public services conditions (baselines) are described in Section 3.6
of the Draft EIR.

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Response 12-15

The traffic boundaries as part of the scope of work for the traffic analysis was developed in conjunction
with Pasadena Department of Transportation (PDOT) and follows the City of Pasadena’s adopted traffic
study guidelines. The study area was determined in coordination with Rose Bowl Operations staff, PPD
and PDOT. The agencies provided input based on their vast experience at the Rose Bowl events over the
past 30 years, including ground and aerial observations of traffic during events. In addition, observations
were taken at a UCLA/Cal football game from last season. Comments from the 2005 EIR were also taken
into consideration. The traffic study area included all areas of potential significant impact based on
historical experience. Therefore, the traffic study area was considered suitable for this analysis.

Response 12-16

Refer to Response 11-37 for a discussion of the appropriateness of Alternative 2.

Response 12-17

Refer to Topical Response 2 regarding historic resources.

Response 12-18

Refer to Response 6-17 for a discussion of Parson’s parking availability.

The second part of the comment relates to consistency with the General Plan and Parks element. Refer
to Response 9-6.

Response 12-19

Mitigation Measure MM 3.6-1 has been revised and included in the EIR to address potential impacts to
Lot H and other grassy areas around the Rose Bowl. Refer to Response 7-11.

Response 12-20

Refer to Response 6-17.

Response 12-21

Refer to Response 7-1.

Response 12-22

The comment suggests reducing the proposed five year term of the lease. Refer to Response 12-5 for
analysis of a reduced timeframe for the project. The comment asks at what point impacts associated with
the project are “irreversible.” Some impacts such as resources committed to the project would be
irreversible. These irreversible effects are discussed in Section 5.0, Other CEQA Considerations, of the
Draft EIR. With the exception of those impacts specifically listed as irreversible in Section 5.0, Other

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CEQA Considerations, the remaining impacts are event specific and would not occur beyond the five
year time frame of the project.

Please also see Topical Response 1 regarding the adequacy of the Project Description.

Response 12-23

Refer to Topical Response 1 regarding the Project Description.

Several mitigation measures have been revised in the Final EIR; refer to Section 2.0 Corrections and
Additions.

Refer to Response 8-10 regarding the need for a baseline study.

Response 12-24

Refer to Response 8-22 for a discussion of trash. Refer to Response 11-19 for a discussion of chemical
waste.

Response 12-25

The comment indicates that the project is inconsistent with the policies listed on Table 3.3-1 of the Draft
EIR. Table 3.3-1 lists each applicable policy and provides an explanation of why the project is consistent
with the policy.

Response 12-26

Attendance at NFL games generally average between 60,000 and 80,000 depending on the team. Only five
teams (Dallas Cowboys, New York Giants, New York Jets, Washington Redskins, and Denver Broncos)
consistently average attendance above 75,000. Therefore, assuming average attendance of 75,000 allows
for a realistic discussion of potential impacts. Additionally, the proposed ordinance limits the additional
displacement events to a maximum attendance of 75,000 persons.

The comment also states impacts related to public services should be further studied. The Draft EIR
includes a discussion of the anticipated demand on police and fire protection services that would be
associated with the proposed project. As discussed in Section 3.5 Public Services, both the police and fire
departments have indicated they have sufficient resources to handle the additional events at the Rose
Bowl. Further, as stated on page 3.5.2-9 of the Draft EIR the operator of the project would be required to
provide sufficient private security to offset any increased demand for police protection services as a result
of the project.

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Please also see Response 8-40, Response 8-41, Response 8-45, and Response 11-20 for further discussion
of the project’s impacts on public services.

Refer to Topical Response 2 related to historic resources.

Response 12-27

The selection of neighborhood street segments for analysis as part of the scope of work for the traffic
analysis was developed in conjunction with Pasadena Department of Transportation (PDOT) and follows
the City of Pasadena’s adopted traffic study guidelines. The study area was determined in coordination
with Rose Bowl Operations staff, PPD and PDOT. The agencies provided input based on their vast
experience at the Rose Bowl events over the past 30 years, including ground and aerial observations of
traffic during events. In addition, observations were taken at a UCLA/Cal football game from last season.
Comments from the 2005 EIR were also taken into consideration. The study area of street segments
included all areas of potential significant impact based on historical experience. Therefore, the scope of
the street segment analysis was considered suitable for this project.

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Letter No. 13

To: David Reyes, Principal Planner/Zoning Administrator Job No. 1136.01


From: Jessica Kirchner, Impact Sciences
Subject: TAC Comments
Date: October 2, 2012

TAC Commission Comments October 2, 2012

Salzer

After listening to the comments, there are quality of life issues that concern everything that happens in the
arroyo, if the City passes this EIR that might not be as comprehensive as we need it. Do we have a
comprehensive, complete EIR for everything that happens: Rose Bowl, flea market, UCLA games, U2
concerns, motocross? If we do pass this EIR and it doesn’t include everything that is happening in and 1
around the Rose Bowl, it is a half assed EIR. It doesn’t cover everything. Is this a complete EIR that covers
everything at the Rose Bowl? Only the NFL is being discussed tonight but there are many other events that
happen at the Rose Bowl and to answer concerns from residents, need to be sure every event is included.
Does this EIR improve the quality of life of residents of the arroyo?

Acker
2
Some comments that stood out and should be incorporated by staff. Two events on a weekend seems that
3
would be significant, the effect of rain on parking at Brookside, the effect of the ticketless patrons. Are the 4
intersections listed all of the intersections that were considered? Are there other intersections or other areas
5
of the city that were considered but not put into the report. That should be clarified. There are a lot of areas
in east Pasadena that are impacted by events at the Rose Bowl, such as Mountain Street. The issue of parking 6
management consistency is huge – that should be covered. The observations that residents on Rosemont
7

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have made are terribly important. What is the benefit of the proposal if there are impacts that cannot be
mitigated?
7

Adhami
8
There should be more economic quantitative analysis. Based on other comments, getting out of the area can
take hours, there is no discussion of circulation in the EIR. There is a direct correlation to pollution, did 9
anyone look into that? Should be some evaluation of circulation and how it will affect the environment. If
mitigation is being proposed, is there an alternative area for the cars to park, maybe on the other side of the
210 to bus people into the area. When there are two events, would any pollution be left over from Saturday
10
that Sunday would add to it? A number of intersections and streets that will be mitigated by signal timing –
what will signal timing do? It doesn’t mean anything when all directions are saturated with traffic. What
will the traffic officers be doing? 11

Burner

The report identified significant impacts. The project is similar to existing events and impacts would be 12
similar to existing events although may be different due to NFL use. Report states impacts cannot be
mitigated. There should be further exploration of incentives for alternative modes of traffic. This stadium is a
neighborhood stadium, not similar to other stadiums.

Segovia
13
An effective EIR would have a much more comprehensive and specific mitigation strategy. The vast
majority of people are allowed to drive into the stadium creating negative effects. Let them park at parsons –
we can do better than that. Hollywood bowl has satellite parking facilities and bus in 20-30 miles. That 14
approach could help. Typically when transportation changes are being recommended there is a Title VI
review of the changes. It is worth considering the socio-economics of the area. Document compares NFL
traffic to UCLA games and the strategies dealing with traffic are the same. The data in the study is not from
those games, observing a game is not the same as taking data from a game, taking traffic counts. If relying 15
on UCLA game strategies then should use UCLA data and measurements to craft the mitigation strategies.

Delgado

The EIR is adequate. This is a formal document. This EIR says significant and unavoidable, regardless of 16
mitigation it cannot be fixed. The decision to go ahead is political. The document is a disclosure. This EIR is

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conservative. The City Council is responsible for certifying the document. Under state law economics is not
considered in an EIR but decision makers can include that as another study. 16
Booker

The EIR is inadequate in the lack of analysis and collection of date regarding a much wider arena that would
contribute to an adequate study. A study is as good as the data it collects; the data has not been collected
fully. There is a focus on cars, levels of service and a passing observation about pedestrians and cyclists.
17
Many people walk and cycle in this area. The study could have considered a much wider source of
information that would speak to the spirit of complete streets and taking into consideration of other modes
than just automobiles. It could create creativity in terms of how to move people into the arroyo.

Chair Higginbotham 18
Page 3.7-34 why doesn’t the study reference the Pasadena freeway coming in? Page 3.7-35 it references a
couple of mobility element polices but does not refer to deemphasized streets and Orange Grove is a
19
deemphasized street. Ticketless attendees should be considered. Page 3.7-36 need more documentation 20
comparing college football fans to pro football fans, what are the similarities and differences? Page 3.7-37 21
talks about the gold line, but doesn’t address capacity on the gold line for weekday games – the assumption
22
in the EIR is that there is additional capacity. The EIR does not consider establishing special game day transit
routes as a mitigation measure. The EIR does not study bike/pedestrian safety. In the evenings it is
23
dangerous to walk or bike – should include mitigation measures to address safety. Figure 3.7-7 does not
address trips coming from the 710 freeway. EIR looks at peak hours - how many minutes or hours per event
24
day is LOS affected by the event? The EIR states one hour but impact is actually over a longer period of time. 25
Page 3.7-88 should explore requiring prepaid parking as mitigation and an alternative for reduced onsite
parking. The reduced capacity alternative does not seem feasible as the NFL would not allow it. Reduced 26
parking onsite may be more feasible, shared parking, etc, given that so much has to do with vehicles coming
into the stadium. Should the EIR consider the effects of construction or loss of parking at the Parson’s site?
The non-NFL events are there unique characteristics of NFL attendees what are the characteristics of non
NFL attendees. Would behavior be significantly different? If not, assumption should be mentioned in the
27
EIR that attendees would be that same, or if they would not.

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Letter No. 13: Transportation Advisory Commission


Transportation Advisory Commission
September 27, 2012

Response 13-1

Please see Topical Response 1 regarding the adequacy of the Project Description.

Response 13-2

Regarding the occurrence of two events in one weekend, it is unlikely that such an occurrence would
happen more than once or twice per year due to the need to have optimal turf conditions for an NFL
event and the time needed for set up and breakdown of UCLA and NFL events. However, if such an
event were to occur, the majority of the impacts disclosed in the NFL are event specific, meaning that cars
would drive to the event on Saturday and a new set of patrons would drive to the event on Sunday.
Similarly, noise, air quality, and recreational impacts would occur on both Saturday and Sunday. There
would not be a cumulative effect of the two events, meaning that impacts related to traffic, air quality,
noise, or recreation would not be any greater due to an event on the day before the game. In such a case,
it is possible that full cleanup of the site may not occur between a UCLA game on Saturday and an NFL
game on Sunday, and repairs to Brookside may not be made. However, Brookside Golf Course would be
used for parking during the NFL event and therefore would not be playable on an NFL game day
following a UCLA game. Further, as required by Mitigation Measure MM 3.6-1, the golf course would be
returned to playable condition within one day of an NFL event. Regarding recreational uses, if two events
were to occur in one weekend, users would be displaced on both days. The loss of recreational use
around the Rose Bowl was found to be significant and unavoidable because users would be displaced on
13 additional events per year (compared to existing conditions). The analysis evaluates the proposed
project condition (NFL use of the Rose Bowl) with the current baseline condition (displacement during
UCLA events) as required under CEQA. Therefore, the determination of significance includes
displacement of users from the Rose Bowl during college events.

Response 13-3

Refer to Response 8-12.

Response 13-4

Please refer to Response 6-2.

Response 13-5

The scope of work for the traffic analysis was developed in conjunction with Pasadena Department of
Transportation (PDOT) and follows the City of Pasadena’s adopted traffic study guidelines. The study

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area was determined in coordination with Rose Bowl Operations staff, PPD and PDOT. The agencies
provided input based on their vast experience at the Rose Bowl events over the past 30 years, including
ground and aerial observations of traffic during events. In addition, observations were taken at a
UCLA/Cal football game from last season. Comments from the 2005 EIR were also taken into
consideration. The traffic study area included all areas of potential significant impact based on historical
experience. Therefore, the scope of the traffic analysis was considered suitable for this project.

Response 13-6

The Rose Bowl staff, PDOT and PPD has successfully been managing parking at the bowl for both large
and small events for a number of years. There is a parking operations plan that will be used at NFL
games to manage parking. Significant and unavoidable parking impacts are not anticipated as a result of
the project.

Response 13-7

Under CEQA, the City Council is asked to weigh the benefits of the project against the potential
environmental impacts and determine whether the benefits outweigh those impacts. A proposed
statement of overriding considerations will be circulated for public review before this issue is considered
by the City Council.

Response 13-8

The transportation section of the Draft EIR describes the key routes that patrons of the Rose Bowl are
expected to take to an NFL game as well as existing levels of traffic on the circulation system. The traffic
analysis also evaluates impacts based on the most congested periods before and after a game.

Response 13-9

Please refer to Response 2-6, the project’s localized impact on air quality. As the project is not expected to
significantly impact local air quality, no mitigation is required.

Response 13-10

As part of the traffic operation plan, PDOT will implement an event period traffic signal priority plan
which is coordinated and monitored from the Traffic Management Center (TMC) for numerous
intersections in the vicinity of the Rose Bowl. The optimized traffic signal timing plan will supplement
the traffic operations plan and facilitate flow of traffic from freeway ramps to Rose Bowl during ingress
and vice-versa during the egress period.

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Response 13-11

As part of the proposed traffic operations plan and also mitigation measure at some intersections, traffic
control officers will be positioned at key locations to prioritize event traffic flow.

Response 13-12

As shown on Page 3.7-88 of the Draft EIR, a travel demand management program was included as an
additional mitigation measure AM 3.7-2.1. This is aimed at promoting ride sharing, alternative forms of
transportation, and maximizing the efficiency of vehicular travel.

Response 13-13

The comment is noted and is hereby part of the Final EIR, and will be forwarded to the decision makers
for their consideration prior to taking any action on the Project.

Response 13-14

The EIR recommends a transportation demand management program that includes the following
measure: “Solicit interest in charter bus service from season ticket holders, groups, and other potential
users and provide charter bus service from locations such as downtown and neighboring cities in
response to demand.” The measure will be revised in the Final EIR to make clear that charter bus service
includes the concept of “park and ride.”

Title VI of the Civil Rights Act of 1964, prohibits discrimination based upon race, color, and national
origin. Specifically, 42 USC 2000d states that “No person in the United States shall, on the ground of race,
color, or national origin, be excluded from participation in, be denied the benefits of, or be subjected to
discrimination under any program or activity receiving Federal financial assistance.” Title VI and the
additional nondiscrimination requirements are applicable to federal programs in addition to programs
receiving federal financial assistance due to the Civil Rights Restoration Act of 1987. The proposed
temporary use of the Rose Bowl by the NFL is not a federally funded project and therefore, Title VI does
not apply.

The comment is noted and is hereby part of the Final EIR, and will be forwarded to the decision makers
for their consideration prior to taking any action on the Project.

Response 13-15

The following information was collected during the UCLA vs. Cal game on October 29, 2011:

 Average Vehicle Occupancy

 Shuttle Boardings

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 24-hour street segment counts

 Turning movement counts

 Traffic saturation flow rates through intersections with and without a traffic control officer

The above information in addition to information available from other sporting venue in Southern
California and NFL stadiums throughout the nation was used in the traffic study.

Response 13-16

The City acknowledges your input and comment. The comment will be included as part of the record and
made available to the decision makers prior to a final decision on the proposed project.

Response 13-17

The scope of work for the traffic analysis was developed in conjunction with Pasadena Department of
Transportation (PDOT) and follows the City of Pasadena’s adopted traffic study guidelines. Per the
guidelines, the analysis focuses on the peak traffic hour prior to an event and the peak traffic hour post-
event. This analysis represents the timeframes when congestion is expected to be at its worst level.

A complete streets methodology has not been adopted by the City as part of its traffic study guidelines.
Therefore, the traffic study does not use a complete street analysis methodology to analyze intersections
and street segments for significant traffic impacts.

Response 13-18

The traffic study does reference the Pasadena Freeway (SR-110) as one of the freeway routes to the Rose
Bowl. As shown in Figure 3.7-7 of the Draft EIR, a total of up to 30 percent of the project traffic is
expected to use the Pasadena Freeway to travel to/from the Rose Bowl on event days. The traffic study
analyzed a total of six freeway monitoring stations along the I-110/SR-110 Freeway. As summarized on
Page 3.7-96, the proposed project will result in a significant impact at the following five CMP freeway
monitoring stations out of the six analyzed:

 I-110 at Manchester Boulevard (northbound)

 I-110 at Slauson Avenue (northbound)

 I-110 south of US 101 (northbound)

 I-110 at Alpine Street (northbound)

 SR 110 at Pasadena Avenue (northbound)

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Response 13-19

Please refer to Response 6-1.

Response 13-20

Please refer to Response 6-2.

Response 13-21

Please refer to Response 6-3 and 6-7. Also, the information provided on page 3.7-36 of the Draft EIR is
based on observations from a UCLA event as well as NFL venues and other stadiums in Southern
California.

Response 13-22

During large events at the Rose Bowl, Metro Gold Line runs three-car trains at peak hour headways,
which is every 6 minutes, or 10 trains per hour. Per information obtained from Metro, each car has a
capacity of 144 passengers per car for a total of 4,320 passengers per hour in each direction. Using the
transit ridership factors described above, a total of 5,850 weekday and 4,350 weekend spectators were
estimated to travel by transit. These riders will typically be spread over a span of multiple hours prior to
start of a game or after the game is over. However, since a higher percentage travel to/from the Rose Bowl
during the peak 1 hour prior to the event and post-event, the Draft EIR identifies a significant transit
impact.

For response to comments regarding establishing special game day transit route, please refer to
Responses 6-6 and 8-36.

Response 13-23

Please refer to Response 6-5.

Response 13-24

Refer to Response 6-11.

Response 13-25

Refer to Response 6-11.

Response 13-26

In addition to the mitigation program described in the Draft EIR, a transportation demand management
program is recommended as an Additional Measure (AM 3.7-2.1) on page 3.7-88 of the Draft EIR. This
includes a pre-paid parking program.

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Please refer to Response 6-18, regarding a reduced on-site parking alternative.

Response 13-27

Refer to Response 6-17.

Response 13-28

Refer to Response 6-19.

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Letter No. 14

Parks and Recreation Committee Member Comments

October 4, 2012

Don Rix

Absence of a baseline study, the EIR gives estimates for annual use adding up all of the visitors and
dividing by 365 that is 7,800 visitors per day. The Final EIR should obtain some solid figures for how 1
many people use the central arroyo and these facilities on a weekend day.

Ann Schied

(see full letter)


2

Notification was not adequate. There should be wider notification and a delay to allow more people to
comment. The EIR is silent on historic resources, despite the fact that historic resources will be impacted
by additional air pollution, traffic and noise generated by the additional displacement events. These
include the Prospect Park historic district, the old Pasadena historic district, arroyo terrace district, 3
Markham place and Bellefontaine historic districts, lower arroyo seco historic district and the arroyo seco
national register historic district.

The lower arroyo seco is not considered in the report and there is no analysis of impacts on that area.
4
There has not been a recent study of habitat and air pollution and noise pollution concentrate on impacts 5
on human beings but fails to assess damage to the natural world. Air pollution and noise measurements
do not consider the topography of the arroyo which is depressed and generally windless. These factors 6
may cause different impacts than the rest of Pasadena. There are 30-40 storm drains that drain into the
soil that channel runoff. Nine of the drains are from south arroyo boulevard, which is a major traffic 7
street. An analysis of impacts on water quality is lacking in the draft EIR. The displacement of
recreational activities is a serious problem. Pasadena residents want more open space for passive 8
recreation and are less interested in spectator sports.
9
The figures on parking in the report vary the numbers on 2.0-16 and 3.7-1 are not the same. How will
parking in Old Pasadena be accomplished where there is a significant commercial activity? Buses may
transport more people, but also generate diesel pollution and that is not addressed in the report. Buses 10
idle up to 2-3 hours generating odors, health effects and noise.

The Hahamonga and Lower Arroyo Master Plans were not looked at for consistency they are important
features of the Arroyo Master Plan and have different purposed and goals, the potential impacts need to 11
be addressed.

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Donna Estacio

Without a proposal from the NFL it is hard to evaluate the impacts in the EIR. The mitigation measures in 12
the recreation section need to be more fully developed. How will that happen? Time of day impacts are
absent from this report. If there are night games are aquatic center impacts less than during day games. It
13
would be great to comment if any of the assumptions from Farmer’s Field overlap with this EIR. 14
Don Rix

The EIR should give the best numbers they can rather than estimates for the year. To say those people 15
will go somewhere else ignores the fact that the arroyo is unique. Other parks do not have all of the same
features. Alternatives for all of the activities do not exist anywhere.

Patricia Keane

16
There should be some additional analysis of where those users would go, the identification of impacts to
the sites they would utilize. Repairs to the other fields, should have a plan for how the repairs will take
place. There is a mention of a traffic demand management, but it feels like deferred analysis to not spell
out with detail what could be done to more fully mitigate the significant and unavoidable impacts. The
17
City has a responsible to mitigate as much as possible, there is not enough detail related to traffic
mitigation. Tailoring measures are likely already known because there are similar events occurring, but
the measures are not included in the EIR. There is nothing encouraging the use of transit. Some of the
18
language in the mitigation measures is permissive rather than mandatory, that should be fixed.
19
Kelley Holmes

Concern for displacement of the users, it will go somewhere, would like to see a mitigation measure that
a portion of the revenue the city realizes be set aside to maintain and enhance the arroyo, specifically
20
giving priority to areas most impacted in the City. If we are asking adult leagues to go somewhere else
then those fields should be maintained to a higher standard because it is the City’s agreement with the
NFL that causes them to be displaced. The repair to the turf needs to be detailed and all turf areas that
21
will have vehicular use should be addressed. The impact on kidspace and the aquatic center, they have
events that are major fundraisers that would be precluded on weekends, could result in a falloff of
22
supporters.

Rita Mareno

Pasadena does not do traffic well. The time of the year of the displacement a lot of activities are on the
23
weekends because it gets dark earlier. The recreational activities cannot be moved to other facilities, the

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other parks cannot absorb more soccer playing and so forth. There are not enough fields in the city. Some
uses can move but there will be impacts to other parks due to the increased use. More people will require 23
more staff or programs and there will be a cost.

Chair Thom Mrozek

The ULI report made certain findings about the condition in the central arroyo. To say the turf will be 24
restored in a day is ridiculous. To repair a divot takes seven to 10 days. That is not addressed to the extent
that it should in this document.

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3.0 Responses to Comments

Letter No. 14: Recreation and Parks Commission Member Comments


City of Pasadena
Parks and Recreation Committee
October 2, 2012

Response 14-1

The comment relates to the need for a baseline study of recreational users. Refer to Response 8-8.

Response 14-2

Refer to Response 12-8.

Response 14-3

Refer to Topical Response 2 regarding historic resources.

Response 14-4

The comment states there is no analysis of impact on the lower arroyo. Refer to Response 15-10 for the
methodology for analyzing recreation impacts. Refer to Response 51-3 for the methodology for analyzing
air quality impacts. Refer to Response 11-28 and Response 11-29 for the methodology for analyzing
traffic impacts.

Response 14-5

Air quality impacts were analyzed according to SCAQMD guidelines and accepted methodology. No
guidelines or procedures are available for suitably analyzing air quality impacts on flora or fauna other
than human beings. Likewise, local topography was taken into account to the extent recommended by
current SCAQMD guidelines for analyzing air quality impacts. Impacts were found to be significant.
Also, please refer to Response 51-3.

Response 14-6

The relationship between topography, weather, and air pollutant concentrations can be complicated and
difficult to fully analyze. For example, high temperatures in canyon areas often create strong updrafts
along the canyon walls that would tend to quickly flush any air pollutants in the canyon out into the
surrounding areas as opposed to concentrating pollutants within the canyon. Nevertheless, as discussed
in Response 2-6, the contaminants generated by the project are not expected to exceed the local
significance thresholds set by the SCAQMD (LSTs). Emissions that are below the LSTs are not expected to
cause an exceedance of the most stringent applicable federal or state ambient air quality standard
regardless of wind conditions. With regard to noise impacts within the Arroyo, the noise analysis is based
on measurements taken in the Arroyo during football games played at the Rose Bowl.

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Response 14-7

Refer to Response 11-19. Potential impacts to groundwater and surface waters as a result of project
implementation were addressed in the Initial Study for the proposed project, which is provided in
Appendix 1.0 of the Draft EIR. As stated in the Initial Study, the pollutants expected to occur as result of
additional displacement events would be typical urban pollutants, and compliance with the City’s
Standard Urban Stormwater Mitigation Plan (SUSMP) would ensure that impacts are less than
significant.

Response 14-8

Please see Draft EIR section 3.6 for a discussion of recreation impacts. The comment addresses general
subject areas, which received extensive analysis in the Draft EIR. The comment does not raise any specific
issue regarding that analysis and, therefore, no more specific response can be provided or is required.
However, the comment will be included as part of the record and made available to the decision makers
prior to a final decision on the proposed project.

Response 14-9

The comment points to a typographical error. Section 2.0 of the Final EIR has been updated to reflect the
correct parking availability as 21,518. See Section 2.0 Corrections and Additions.

Response 14-10

[The commenter questions how parking in Old Pasadena will be accomplished where there is a significant
commercial activity. The commenter states that buses may transport more people, but generate diesel pollution that
is not addressed in the report. The commenter states that buses idle up to 2-3 hours generating odors, health effects,
and noise.]

Buses were included in the air quality analysis as a portion of the vehicle fleet traveling to the Rose Bowl.
There is no information indicating that buses would idle for 2 to 3 hours.

The traffic study does acknowledge that some people may choose to park in parking facilities located in
the Old Pasadena and Civic Center area (Page 3.7-106), however, the project does not rely on parking
available in Old Pasadena and the Civic Center area to meet its parking demand. As described under
Mitigation Measure MM 3.7-5 on Page 3.7-106 of the Draft EIR, “parking operators shall monitor parking
demand on game days to ensure sufficient supply is available to meet parking demand around the Rose
Bowl. If excess parking demand is anticipated, stacked parking will be implemented as needed in one or
more of the following parking lots to ensure that there is sufficient supply to meet demand:

 Lot H

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 Lot BD 2 & 3

 Lot 1 A

 Lot 1

 Lot 2

 Lot 3

 Lot 4

 Lot 5

 Lot 6

 Lot 7

 Lot 8A

 Lot 9

 Lot 10

The use of stacked parking at these lots can increase parking supply by up to approximately 3,000
spaces.” A total parking demand of 27,689 spaces is estimated on a weekday game and 25,633 spaces on a
weekend game. With additional 3,000 spaces from stacked parking at the aforementioned parking lots,
the project parking supply is estimated at 29,018 spaces (Central Arroyo = 21,518 spaces + Parsons’ = 4,500
spaces + Stacked parking at specific lots in the Central Arroyo = 3,000 spaces), which is determined to be
sufficient to meet its parking demand on both weekday and weekend games.

With respect to comment regarding the number of parking spaces available at the Central Arroyo, page
3.7-1 of the Draft EIR correctly refers to the available parking at 21,518 spaces in the Central Arroyo. The
reference page 2.0-16 is a typographic error and has been corrected to say “21,518.”

Response 14-11

Refer to Response 9-6 regarding land use plans.

Response 14-12

Please see Topical Response 1 regarding the adequacy of the Project Description.

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Response 14-13

Based on comments received on the Draft EIR including suggested mitigation measures, several
mitigation measures have been revised and new mitigation measures have been included in the Final
EIR. Refer to Response 8-11, Response 8-13, Response 8-15, and Response 8-43, above.

Response 14-14

The comment indicates that impacts to recreational uses could vary based on the time of day of an NFL
event. The analysis in the Draft EIR assumes that access to recreational uses such as the Aquatic Center
and Kidspace would be lost up to 8 hours prior to the event. Most games would start at 1:00 PM.
Regardless of the start/end time of the games, users of the Rose Bowl would be displaced from the area
for approximately 14 hours (8 hours prior, 4 hour event, and 2 hours after the event) on each event day. It
is possible that users could return to the Rose Bowl after an event. For a 1:00 PM kickoff the game would
end around 5:00 PM and most patrons would be out of the Rose Bowl by 7:00 PM. However, there would
likely still be traffic limiting accessibility. Further, resources such as Kidspace and the Aquatic Center
require staff for maintenance and supervision during operating hours. Due to the limited accessibility, it
is expected that both venues would choose to remain closed for the day. Therefore, although it is possible
that users could access the Rose Bowl for recreational activity either before or after the games, due to the
duration of inaccessibility (approximately 14 hours) for purposes of this analysis it is assumed that the
impact would last for the entire day.

The comment also requests information on the similarities in the assumptions included in the Draft EIR
with the Farmer’s Field EIR. The Farmer’s Field project includes construction of a new multi-purpose
stadium, new convention space, and two parking structures. Although both projects include the use of a
stadium by the NFL, the scope of the Farmer’s Field project is far greater than the use of an existing
stadium by the NFL. As such, it would not be particularly useful to readers of the Draft EIR to compare
the two environmental documents due to the vast differences in scope.

Response 14-15

Refer to Response 12-9, above for a discussion of the displaced park users. Several mitigation measures
have been revised or added to the Final EIR. These measures include MM 3.6-1, MM 3.6-2, and
MM 3.6-5.

Response 14-16

This comment requests additional information on the displacement of recreational users and also
suggests a plan should be included for the repair of grassy areas used for parking. Refer to Response 12-9
for a discussion of displaced uses. Several mitigation measures have been revised or added to the Final
EIR. These measures include MM 3.6-1, MM 3.6-2, and MM 3.6-5.

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Response 14-17

The traffic study provides a detailed summary of mitigations considered for significantly impacted
intersections. A number of mitigations are proposed as part of the traffic study. These include operational
improvements at individual intersections; transit mitigation and transportation demand management
strategies. Operational improvements include deployment of traffic control officers and use of traffic
control devices to increase traffic flow capacity through an intersection. Transportation demand
management includes strategies to incentivize use of alternative modes of transportation among others to
reduce the number of vehicular trips to Rose Bowl.

Response 14-18

To encourage the use of transit, the proposed project proposes the following:

 Shuttle bus park-and-ride - A shuttle bus park-and-ride at the Parson’s facility. A total of
4,500 spaces are provided at this facility for event days. Patrons can park their vehicle and board the
exclusive shuttle bus to travel to/from Rose Bowl. The shuttle travels on a partially exclusive route
to/from Rose Bowl.

 Charter Bus Service – The EIR recommends that Rose Bowl explore interest in charter bus services
from season ticket holders and other potential users. This type of private service could be provided
from locations such as downtown Los Angeles and neighboring cities in response to demand. The
Rose Bowl may encourage charter bus service by providing preferential/subsidized bus parking at
the Rose Bowl.

 Public Information - The RBOC will also enlist the use of social media, the internet, and other
methods to encourage the use of transit to the events.

Response 14-19

All mitigation measures are considered to be mandatory.

Response 14-20

Refer to Response 12-9 for a discussion of displaced users. Although not required to mitigate a significant
impact, Mitigation Measure MM 3.6-5 has been included in the project to address maintenance of parks
in Pasadena.

Response 14-21

Mitigation Measure MM 3.6-1 has been revised to address repair of grassy areas around the Rose Bowl.

Response 14-22

The comment suggests evaluation of potential fundraising impacts on the Aquatic Center and the
Kidspace Museum. The comment overstates the impact of the project on fundraising events for these

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institutions. The project would only preclude on-site fundraisers on 13 days per year for a maximum of
five years. The project would not preclude fundraising events on weekends. CEQA requires a discussion
of potential physical impacts that could result from a project. The loss of revenue or fundraising dollars
for the Kidspace Museum and the Aquatic Center due to constraints on on-site fundraising events on
13 days per year is not expected to result in a physical impact.

Response 14-23

The comment indicates there would be costs associated with maintenance of nearby parks that could
experience increased use by displaced users of the Rose Bowl. Although the EIR does not anticipate a
significant environmental impact on nearby parks, please see Mitigation Measure MM 3.6-5 related to
maintenance and repair of Pasadena parks.

Response 14-24

The comment relates Brookside Golf Course. Based on information provided by RBOC, and the Golf
Course Operations staff, both fairways and the rough are parked (greens are not parked). Of the golf
course’s approximately 180 acres, typically less than 0.5 acre are damaged from parking. Current practice
after an event (UCLA, Rose Bowl Game, etc.) is to clean up any trash or debris on the golf course
immediately following the game, address any damaged areas with sand and seed and return the golf
course to a playable condition by the following day (the day after the event).

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Letter No. 15

To: David Reyes, Principal Planner/Zoning Administrator Job No. 1136.01


From: Jessica Kirchner, Impact Sciences
Subject: Planning Commission Comments
Date: September 27, 2012

Rose Bowl Planning Commission 9/19

Nina Chomsky

The project description is inadequate and should describe the project scope. The project scope should
include the term sheet or contracts, lease, and financial agreement. Could Lot H, ingress and egress,
1
installation of retail outlets, etc. change based on the conditions with the NFL? The project objectives as
stated focus on revenue, without the financial agreement can the objectives be met? Every effort must be
made to mitigate impacts.

Norman Parker
2
Mitigation measures are inadequate; maintaining access to the central arroyo during events is false and
cannot be implemented. Currently access is closed 6.5 hours prior to the event. The fans are different for
3
each team. The DEIR needs to include a mitigation measure that the Oakland Raiders will not be permitted.
Fans without tickets should not be allowed into the central arroyo. The mitigation measure regarding the
4
golf course should also address the cumulative effects of damage of the course. The LVAA disagrees with
5
the assessment that emergency services are adequate and City emergency plans should not be relied on. 6

Lee Zanterson
7
Baseline data on recreation is missing – need to define current users and who will be displaced as well as
address the cumulative impact to recreation. All recreational activities need to be addressed including

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7
impacts on the lower arroyo and the Hahamonga. EIR does not take into account all potential land use
policies addressing the central arroyo, for example, the ASPLO bans commercial activity in the arroyo.
8
Pasadena is under parked. Public services should include a consideration of the City resources that will be
required to serve the project and the potential burden to the city. 9
Leland Skylar

Rose Bowl is not like other stadiums. There is total gridlock on the streets which are essentially one-way 10
during games. Police should come into the neighborhoods. The kids that direct traffic do not help and the
police do not show up when called. It is a quality of life issue.

Bob Snodgrass
11
The City does not know how many people are really using the loop. There are no other options for exercise
(jogging strollers) that are similar to the exercise loop. Mitigation measure to keep the loop open is a fraud.
The project is not a recreational benefit (Impact 3.6.3).
12

Jonas Peters 13
The City should have distributed more information to all residents. There is no meaning to the term 14
“significant” in the document. The document does not address hazards such as terrorism or violent crimes
and does not provide how people would be medical care. The cumulative impact of chemical waste on
15
ground water, leaking trash bins into the arroyo seco should be discussed.
16
Diane Newnan
17
Questions how the process was put forward (EIR selection, traffic consultant). Is there a conflict of interest?
The air quality analysis does not address the Wilson site and specific contaminants on children, asthma. 18
What City services would be benefited by the project? The EIR is vague and uncompelling.
19
Ken Van Waggoner

If this project is approved it is against the wishes of the City. The project has been put to a vote previously 20
and was voted down. Nobody wants the project; the EIR is a waste of money. It is an unreasonable
inconvenience for the residents.

Mike Duran

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NFL events are different from college events. Farmer’s field bans tailgating, without a ban on tailgating
resources at the Rose Bowl would be overwhelmed. The increases in crime, noise, violence will create 21
challenges to public order. Many tailgaters come without tickets and watch the game on TV.

Wes Ruderman
22
Health should be considered, the public health impacts of taking away an active recreational resources
should be addressed. Six hours of tailgating before games is excessive and there is little DUI enforcement.
Some facilities allow 3 hours of tailgating. 23

Ron Taylor

San Rafael neighborhood association is opposed to the use of the Rose Bowl for the NFL. There are safety
concerns since there is no fire station currently serving the area. It takes 8 minutes for the fire department to
24
arrive. The intersection of San Rafael and the 134 Freeway already experiences gridlock. IT’s a quality of life
issue with tailgating, DUI’s etc.

Bill Urban
25
The impact to recreational users is understated. The Rose Bowl loop is closed 8 hours before the game, the
effects on the rest of recreational users in the arroyo is not addressed. Traffic is understated since UCLA has 26
fewer attendees. What are the cumulative effects of 710 construction? FEIR should be submitted to Planning
Commission before City Council. 27
Lori Gassus
28
What are the lighting impacts on the eastern side of the stadium during cleanup? During the five month
period of the project the Rose Bowl will be a 24-7 activity. Are other stadiums constructed in high-end 29
communities? What are the noise impacts from unticketed patrons? What about the loss of the benefits to the
recreational users? The project ignores people who pay taxes. Additional clarification on the public services
30
threshold is needed.
31

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Letter No. 15: East Arroyo Neighborhood Preservation Committee


East Arroyo Neighborhood Preservation Committee
Bob Snodgrass
October 8, 2012

Response 15-1

The comment includes two topics, the first being the “bunching of events” and the second being the use
of temporary structures. Regarding the occurrence of two events in one weekend, it is unlikely that such
an occurrence would happen more than once or twice per year due to the need to have optimal turf
conditions for an NFL event. However, the impacts of the project are event specific. There would not be a
cumulative effect of two events on consecutive days. In other words, impacts related to traffic, air quality,
noise, or recreation would not be any greater due to an event on the day before the game. In such a case,
it is possible that full cleanup of the site may not occur between a UCLA game on Saturday and an NFL
game on Sunday, and repairs to Brookside may not be made. However, Brookside Golf Course would be
used for parking during the NFL event and therefore would not be playable on an NFL game day
following a UCLA game. Further, as required by Mitigation Measure MM 3.6-1, the golf course would be
returned to a playable condition within one day of an NFL event.

Refer to Response 7-8 and Response 8-23 for additional discussion of temporary structures with NFL
events.

Response 15-2

Please see Topical Response 1 related to the adequacy of the Project Description.

Response 15-3

The comment includes introductory statements to comments contained later in the letter. See specific
responses below.

Response 15-4

The comment includes general introductory comments and indicates specific comments are discussed
later in the letter. See responses to the individual comments below. The comment also states Impact 3.6-3
“betrays arrogance and ignorance.” This impact has been removed from the Final EIR.

Response 15-5

It is standard practice, accepted by the various air districts in California including the SCAQMD, to use
the nearest air quality monitoring station for data on ambient air quality. These stations have been
carefully sited by the air districts to provide quality data for the area in which they are located. They are
also carefully calibrated and maintained, and collect data over long periods of time to provide an accurate

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measure of ambient air quality that is largely independent of statistical outliers. Taking ambient air
quality measurements locally and only during displacement events at the Rose Bowl would provide
results that are not a true reflection of ambient air quality. This would also likely result in baseline
pollutant levels much higher than generally experienced in the area, which would be counter to the
conservative analysis typical of a CEQA assessment.

CalEEMod includes output sheets detailing construction calculations regardless of whether any such
calculations were performed. Construction was not included in this analysis as none will be performed,
but CalEEMod does not allow the option of only including operational calculation outputs.

Default values were used in CalEEMod where data specific to the project is not available. Idling vehicles
are primarily an issue with regards to CO hotspots, which were analyzed for this project with no
exceedances found even under extremely conservative meteorological conditions. CO hotspots were
analyzed using the standard simplified Caline analysis, as described in the EIR.

Additionally, the CalEEMod is not used to determine localized air quality impacts, including potential
impacts on health in the immediately surrounding area. As discussed in Response 2-6, the project does
not exceed the localized significance thresholds (LSTs) recommended by the SCAQMD. If a project does
not exceed the LSTs, then the project is not expected to cause an exceedance of the most stringent
applicable federal or state ambient air quality standard and therefore is not expected to have any
significant health impact on nearby residents or other sensitive receptors.

Response 15-6

Emissions from grills during tailgating at displacement events has now been included in the final EIR and
would be relatively small. Banning the use of charcoal would indeed decrease emissions but the decrease
would be immaterial and would not mitigate any significant localized air quality impact because no
significant localized impact is anticipated.

As discussed in Response 2-6, the project does not exceed the localized significance thresholds (LSTs)
recommended by the SCAQMD. If a project does not exceed the LSTs, then the project is not expected to
cause an exceedance of the most stringent applicable federal or state ambient air quality standard and
therefore is not expected to have any significant health impact on nearby residents or other sensitive
receptors.

Response 15-7

Significance thresholds, emissions guidelines, and rules provided by the SCAQMD are designed for the
protection of all residents, with particular attention to sensitive receptors. The presence of even a single

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sensitive receptor in the area triggers consideration of such receptors, regardless of their relative density
in the area of the proposed project.

Response 15-8

The Draft EIR found that impacts from air pollutant emissions would be significant. No statement is
made denying that nearby residents will not be affected.

Response 15-9

The comment relates to the use of the Arroyo for recreational purposes. The comment states the Draft EIR
does not include information related to the number of users at the loop. Page 3.6-24 includes a graphic
depicting the number of estimated users of the loop. The counts were taken in 2008. In addition, the City
conducted additional counts at the loop on Sunday October 21, 2012 from 11:15 AM to 12:15 PM to
supplement the 2008 counts. These counts were taken at the entrance to Gate C and are as follows:

 Walk/jog: 232

 Bicycle: 65 (non-Peloton)

 Skate/Scooter: 3

 Motor Vehicle: 234

The numbers of users are generally similar to the number of users observed by the commenter on
August 4, 2012. Both counts are lower for walk/jog and bicycle counts than the counts obtained by Crain
and Associates, and included in the Draft EIR, on a weeknight in September. Excluding the bike counts
(many of the bicyclists were likely counted up to 10 times as they completed a lap around the loop), the
Crain and Associates found a total of 510 walk/joggers (296 clockwise and 214 counter clockwise) which
is double the numbers observed on the weekends of August 4 and October 21, 2012. Nonetheless, the
analysis in the EIR presents a conservative scenario by evaluating the potential displacement of these
users.

City staff also conducted surveys of the various users of the Rose Bowl in October and November of 2010.
These surveys were conducted to assess improvements to the loop that occurred in February 2010. The
findings of the survey were presented to the City Council in February 2011 in the form of a memo. The
memo is included in Appendix F3.0 of this Final EIR. The survey results indicated that approximately
half (51 percent) of the users of the loop were Pasadena residents and the majority of responders
(75 percent) used the loop for walking/running.

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The commenter suggests the City should obtain golf course revenues for days of minor events to
determine the effect of “minor” events on the recreational use of the Rose Bowl. This comment seems to
relate to the loss of revenue from golfers and raises issues that do not appear to relate to any physical
effect on the environment. The comment will be included as part of the record and made available to the
decision makers prior to a final decision on the proposed project. However, because the comment does
not raise an environmental issue, no further response is required.

Response 15-10

The comment states the Draft EIR ignores users of the lower arroyo. The Draft EIR appropriately focuses
on the loss of recreational facilities in the Central Arroyo, specifically the loop, Brookside Park and Golf
Course and the Aquatic Center. The lower arroyo will be available to the public on days when a
displacement event occurs at the Rose Bowl. While some users may be dissuaded from using the Lower
Arroyo due to increased traffic on event days, other users may find it easier to access these facilities than
those located in the Central Arroyo and choose to recreate in the Lower Arroyo.

The loss of the use of Brookside Golf Course is discussed in Section 3.6 of the Draft EIR and is addressed
through Mitigation Measure MM 3.6-1. The comment suggests the City should survey the golfers to
determine what additional facilities they would like in the clubhouse. Such a survey would not be clearly
connected to the environmental impact of the inability to golf at Brookside an additional 13 times per
year. Nonetheless, the City acknowledges your input and comment. The comment will be included as
part of the record and made available to the decision makers prior to a final decision on the proposed
project.

Response 15-11

The comment states that destruction of existing parks will occur as a result of the project. The comment
also states the Draft EIR does not include data to support the assertions that the project would not
damage neighborhood or regional parks. The Draft EIR includes a discussion of the number of users that
typically use the Rose Bowl facilities (additional information on the number of users is provided in
Response 15-9, above) and a description of nearby facilities. Section 3.6 Recreation of the Draft EIR
includes a discussion of potential displacement of users of the Central Arroyo on game days. Regarding
the physical impacts of displacement, page 3.6-22 states the following, “It is possible that on event days,
typical users of the Rose Bowl would choose a different recreational area within the City resulting in a
slight increase in use at nearby parks…” The commenter references the number 750,000 as an
approximate number of the users of the Rose Bowl who would be displaced. Assuming 750,000 visitors
use the facilities at the Rose Bowl per year, that would be approximately 2,055 users per day
(750,000/365). These 2,055 users would be displaced on 13 occasions as a result of the proposed project

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and would either chose not to exercise on that particular day or choose another location to exercise. Due
to the wide variety of uses accommodated at the Rose Bowl, no one single facility could accommodate all
2,055 users, as no one facility can accommodate cycling, running, football, soccer, etc. Therefore, the
2,055 users would be further distributed across various facilities throughout the City and region. The
Draft EIR lists 24 parks in the City of Pasadena (not including special facilities such as the Gamble
House). If all 2,055 users were dispersed across only City of Pasadena parks, that would be
approximately 85 people per park per day on 13 days per year as a result of the proposed project.
However, from the survey conducted by the City, it is clear that nearly half of the users of the Rose Bowl
loop are not Pasadena residents and therefore may choose to use a park closer to home. Based on the total
number of users that would be expected to use nearby Pasadena parks on 13 occasions per year, it is
unlikely that any one park would be degraded or that new facilities would need to be constructed as a
result of the proposed project. Nonetheless, mitigation measure MM 3.6-5 described under
Response 8-15, above, was suggested during the public comment period and therefore has been included
in the Final EIR. Although impacts to local parks were found to be less than significant, this measure
would ensure funds are appropriately used to maintain the quality of Pasadena parks and open spaces.

The comment states the repair of Brookside Golf Course within one day will be at a considerable cost. As
described in Mitigation Measure MM 3.6-1, the RBOC will be responsible for the repair of the golf course,
including any associated costs of repair.

The comment states maintaining access to the loop on event days is “absurd.” In response to public input
concerning the feasibility of mitigation measure MM 3.6-2, the mitigation measure has been revised.

The comment further states Impact 3.6-3 is “offensive.” This impact has been removed from the Final EIR.

The comment lastly includes summary comments. The individual comments are addressed above.

Response 15-12

The comment relates to tailgating and alcohol use at NFL events and provides factual background
information only and does not raise an environmental issue within the meaning of CEQA. The comment
will be included as part of the record and made available to the decision makers prior to a final decision
on the proposed project. However, because the comment does not raise an environmental issue, no
further response is required.

Response 15-13

The comment relates to drunk driving and fan behavior. The comment does not raise an environmental
issue within the meaning of CEQA. The comment will be included as part of the record and made

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available to the decision makers prior to a final decision on the proposed project. Please also note that
based on information from CSC, which provides security services to NFL and college football games,
NFL fan behavior at the Rose Bowl is not projected to be more unruly than the behavior of college
football fans at the Rose Bowl.

Response 15-14

The parking demand estimates for the event can be satisfied through on-site parking at the Rose Bowl
and off-site parking at the Parsons campus. The traffic management plan is designed to protect
residential neighborhoods from off-site street parking. In addition residents could consider petitioning
the City for a residential preferential parking program. Please see Response 8-40 and Response 8-41
related to public services impacts from tailgating and enforcement of laws against drunken driving.
While tailgating is not expected to create a significant impact on public services, the Final EIR
recommends mitigation measure MM 3.5.2-1 to limit tailgating to 3 hours prior to the event.

Response 15-15

Please refer to Response 6-2.

Response 15-16

The commenter states that from his work commute that Monday traffic is substantially worse than Thursday traffic,
coming and going. The commenter states that the Draft EIR never states that the wished of the NFL often conflict
with the interest of Pasadena citizens.]

The comment is noted and is hereby part of the Final EIR, and will be forwarded to the decision makers
for their consideration prior to taking any action on the project.

Regarding the comment related to traffic conditions on a Monday versus Thursday, the scope of the
traffic study was developed in conjunction with PDOT and follows the City adopted traffic study
guidelines. Per typical industry practice and per requirements by some agencies within the Southern
California region (e.g., City of Los Angeles, Los Angeles County, etc.), traffic counts are conducted on
Tuesdays through Thursdays during non-Summer months. Generally, weekday evening peak hour traffic
on Mondays and Fridays is considered to be slightly lower on City’s streets than traffic on Tuesdays
through Thursdays except for under special conditions where the PDOT requires counts on Mondays
or/and Fridays. Therefore, traffic counts obtained on a Thursday are determined to be a reasonable
approach to establish existing baseline traffic conditions within the study area.

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[The commenter notes that the intersection data show that many intersections south of Colorado function poorly in
the weeknight baseline data. The commenter notes that 30 percent of those attending NFL game will come from the
south, including Orange and San Diego counties. The commenter states that most would use either the 110 or 710
freeways or some of those who use the 710 freeway may come north on streets east of Arroyo Parkway, such as
Marengo and Los Robles Avenues, which were not monitored. The commenter states that asking these people to take
the I-5 up to the 134 is not a solution for the weeknight games, because I-5 has very heavy traffic during the evening
rush hour]

Regarding the comment about patrons using I-710 Freeway to travel to Rose Bowl on an event day, please
refer to Response 6-9. The study intersections were selected in coordination with Rose Bowl Operations
staff, PPD and PDOT as those most likely to be affected. The agencies provided input based on their vast
experience at the Rose Bowl events over the past 30 years, including ground and aerial observations of
traffic during events. Also, with respect to the comment regarding some spectators travelling on streets
east of Arroyo Parkway, such as Marengo Avenue and Los Robles Avenue, the proposed traffic control
plan, and neighborhood protection plan focuses on keeping event traffic on streets intended for use
during events. However, some event patrons may choose to travel on streets located east of Arroyo
Parkway. These streets provide parallel north/south and east/west routes to Rose Bowl, but these patrons
will eventually have to traverse through the analyzed intersections and streets segments to reach the Rose
Bowl. Based on historic traffic patterns for displacement events at the Rose Bowl, project traffic on the
streets located east of Arroyo Parkway is expected to be minimal and would not cause a significant
impact. Any assignment of trips to these streets would be speculative and would divert trips from their
more likely path of travel, reducing impacts at other intersections.

Response 15-17

The comment is noted and is hereby part of the Final EIR, and will be forwarded to the decision makers
for their consideration prior to taking any action on the Project. Parking in residential neighborhoods
may interfere with the convenience and quiet of a neighborhood on game days, but is not a significant
environmental impact.

Response 15-18

Devil’s Gate Dam & Reservoir Sediment Removal Project (#27) and Parson’s Mixed-Use Project (#28) are
included in the analysis as related projects. Traffic projections for both sites are incorporated in the traffic
analysis. Please refer to Table 10 of the Traffic Study for reference.

Response 15-19

Page 3.4-6 of the Draft EIR states, “Noise monitoring was conducted for a 24-hour period at four locations
around the project site on June 17 and four different locations on June 24, 2012,” and further specifies that

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no formal events were occurring at the Rose Bowl Stadium on the days that noise measurements were
taken. Noise measurements taken in the absence of any event provide a baseline level to which projected
traffic and event noise can be added to determine whether thresholds for noise exposure would be
exceeded. As stated on page 3.4-15 of the Draft EIR, noise levels for the 2003 UCLA football game were
provided in the Rose Bowl Stadium Renovation Project EIR.

Regarding the methodology used to forecast future traffic noise, page 3.4-11 of the Draft EIR states:

Noise modeling procedures involved calculating existing and future vehicular noise levels along
individual roadway segments in the vicinity of the proposed project site. This task was
accomplished using the Federal Highway Administration Highway Noise Prediction Model
(FHWA-RD-77-108). The model calculates the average noise level at specific locations based on
traffic volumes, average speeds, roadway geometry, and site environmental conditions. The
average vehicle noise rates (energy rates) utilized in the FHWA Model have been modified to
reflect average vehicle noise rates identified for California by the California Department of
Transportation).

This is a standard methodology for predicting traffic noise, and is adequate to evaluate whether the
proposed project would result in substantial increases in noise levels.

Response 15-20

Refer to Topical Response 2 regarding historic resources.

Response 15-21

The comment suggests an alternative that would allow 2 preseason games, only Sunday games during
the regular season and up to three post-season games with additional post-season games played at a
venue such as the Coliseum. Thus, this alternative would reduce the number of increased displacement
events to 11. This alternative would not offer significant environmental advantages over Alternative 3,
which would also reduce the number of increased displacement events at the Rose Bowl. It is
acknowledged that eliminating weeknight displacement events would reduce traffic impacts slightly
because due to the higher AVO on weekends, meaning fewer overall trips would occur on weekends
compared to weeknights. However, traffic impacts would remain significant and unavoidable. Other
impacts would be unchanged.

Response 15-22

The comment includes summary points addressed throughout the letter. The comment is noted. No
further response is required given that the comment does not address or question the content of the Draft
EIR.

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Letter No. 16

To: David Reyes, Principal Planner/Zoning Administrator Job No. 1136.01


From: Jessica Kirchner, Impact Sciences
Subject: Transportation Advisory Committee Comments
Date: October 4, 2012

TAC Comments September 27, 2012

Michael Duran

Opposed to the NFL project. Assuming staffing at barricades at NFL events will be equivalent to UCLA
1
games, these barricades do not serve the function they are alleged to serve. Most people at barricades are
young and not supervised. Barricades do not offer real mitigation. What is the expected area NFL fan would 2
travel from? The farther they would come, the more impacts from traffic and pollution. What data was relied
on to conclude the threshold increases in traffic volume will be five percent or greater? Doesn’t the phase “or
greater” render the whole phase meaningless, is it seven percent is it 10 percent or more? The use of freeway
3
signs is not mitigation; people still want to get to the same location. Mitigation Measure 3.7-1, 3.7-2,
according to the draft EIR results in significant and unavoidable impacts and likewise 3.7.4 dealing with
freeway segments. The DEIR admits no feasible way to mitigate to less than significant. Page 2.6 of the staff
report includes a typo should say unavoidable. The only way to avoid a traffic nightmare is to decline to
extend an invitation to the NFL. To ignore these points will expose the City to costly litigation. The project 4
ignores the views of neighbors around the arroyo.

Bob Snodgrass (see comment letter)

DEIR gives no quantification and guesses at things. Air quality measurements are taken at a single site at 5
CalTech not in the arroyo where particulates are likely to remain. There are no measurements from UCLA
games; instead there are theoretical calculations which are above threshold. That is not satisfactory, should

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know how bad the impact is and should measure pollutants and measure them in the arroyo because the 5
AQMD station at Caltech does not see a lot of the pollutants produced in the arroyo. That is a serious
deficiency. Another deficiency relates to recreation. The largest group of users is those using the loop,
estimated at 1.5 million visits per year. The City does not know about users of the loop, how many are
Pasadena residents and how many come only on the weekends? The City says they can be handled at City 6
parks and lists the Gamble house as a place to handle people exercising. There is a very offense mitigation
which says recreation is being improved by bringing more events. This confuses passive spectator sports
with healthful recreation. The EIR does say there are consequences that cannot be avoided but gives no idea
of the magnitude. 7

There is an attempt to give data on peak traffic on weeknights, but there is nothing about duration of
congestion. Weeknight events are qualitatively different. Congestion lasts a long time and the EIR does not
consider that. There is also a difference between Monday night and Thursday night. Monday traffic is
8
greater than Thursday night traffic. Monday would be a worse night than a Thursday but the EIR does not
mention this. Weeknight games would be good for the NFL and disastrous for the City of Pasadena. There
should be an alternative that disallows weeknight games.

Devil’s gate sedimentation project will take many years to remove silt from the area. Trucks will come across
the 210 Freeway by the northern part of the arroyo six days a week. It will produce noise, congestion and
pollutants. The analysis may not be able to quantify that but it is not mentioned as a factor. The analysis says
there is a problem and it is above threshold but the City says there are goodies but you need to know how
big the “baddies” are. The Parsons project involves construction of four buildings when it starts weekday
9
traffic coming to a weekday game will encounter trucks coming out of the Parsons site. The Parsons site will
be less available and it is not mentioned as a consideration. There needs to be a quantitative understanding
of the magnitude of the problems, particularly with air quality, cannot just say it is above threshold and
these are the theoretical calculations, it has to be measures. Particulates are bad for people’s health.

Nina Chomsky

This EIR jumps to statements of overriding consideration because the effort has not been put in to study and
mitigate and factually analyze. Statements of overriding consideration cannot be used as a shield, all effort 10
should be put in to study all impacts and all facts, to look at all feasible and creative and in-depth
mitigations and only then go to a statement of overriding considerations.

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The project description is inadequate and in error and illegal because it just describes a phase of the project,
that is to amend the arroyo seco public lands ordinance. The entire project would include the deal, the
contracts, the franchise agreement, and the finance agreement with the NFL so the benefits of the project
could be judged as compared to the impacts that cannot be mitigated. What is the gross or net economic 11
benefit of the NFL to the City? There isn’t one piece of information that states that. It’s just speculation that
they will come here and dump millions and millions of dollars to save us from the renovation economic
disaster. To jump to the conclusion that we can have these overriding considerations has problems on both
ends and the middle.

All these people being displaced for days on end, weeks on end, weekends on end, Saturday and Sunday
games. Where are they going? It’s not the Gamble House. They are going to other sources of recreation in the
12
City, other parks maybe, neighborhoods, they’ll start walking the neighborhoods, how are they getting
there? How are they parking? Who are they displacing once they get there? There is no analysis of that.
Intersections and streets are omitted from the study area. Why does the DEIR fail to include intersections on
Arroyo Boulevard south of California, the intersection of Arroyo Boulevard and Seco Street, any streets east
13
of arroyo parkway such as Marengo and Los Robles? We are operating under the 2004 Mobility Element not
the 1994 Element.

“Complete streets” applies to all new projects in the City, but the traffic study ignores it. The traffic study is 14
inadequate and needs to go back and start over. Where is the alleged traffic management plan? The plan that
we have now is unreliable from game to game. The police reserve the right to change parking and resources 15
as necessary and whatever this management plan is, is it in writing, is it going to have public review. What
is the process? What the administrative burden in terms of police and fire that to the City? How many more
police are going to be necessary with the NFL? How many more police and fire will have to be hired? 16
Alcohol is limited at UCLA games – at NFL games alcohol will be sold throughout the game. How will the
police manage the drunk drivers existing? 17
Susan McClemmons

DEIR is inadequate related to transportation for the following reasons:

The DEIR speculates as to the percentage of fans who would arrive in the hour before the game and who 18
would leave in the hour immediately after the game. Fans start arriving six hours before, and the Rose Bowl
encourages fans to come within the six hour period before the game. After the game it is a full two hours

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that the fans are exiting and clogging the streets. There’s no substantiation to the claim that a certain
percentage arrives an hour before. There is a ripple effect on all of the impacts about traffic, barricades, etc. 18

All of the discussion in the DEIR talks about the number of ticketholders and the number of seats in the
stadium as the estimate for how many fans will be attending the game. There are also a number of ticketless
fans who come to the venue to enjoy the celebration, the NFL event. This could add thousands of people
coming into the arroyo on a game day. The report is inadequate because it does not identify the impact of 19
the ticketless fans, their impact on the traffic, how they will be lured into using the shuttle systems as
alternative transportation. Will they be kept from parking in the neighborhoods?

In the DEIR there’s speculation that it’s 2.7 occupants per car, but there is no substantiation of that. 20
The estimate of the number of shuttle trips in the hour before and the hour after an NFL game presented in
the report are not substantiated. There’s no mention of the time required for each round trip. Assuming it
takes 20 minutes for a complete trip, for the 211 shuttle trips in the report that would require 70 shuttles 21
running at the same time. The report should include a specific mitigation plan for the shuttle trips and
should give information about what the shuttles can achieve and how they would be used.

The EIR assumes that NFL fans will be content to park away from the stadium and shuttle into the venue.
Tailgating is an integral part of the NFL experience, this will impact on site parking, and how effective
alternative transportation will be. The report does not adequately explore how likely is that that people will 22
be enticed to use alternative transportation? The report needs to provide specific facts that shuttles and
alternative transportation will be effective.

Brookside golf course is not available when it is raining or two to three days after rain. The report does not
take into account the impact of the loss of the Brookside golf course when grounds are wet. It is likely that
23
people will then park in the neighborhoods.

There is no restriction on alcohol sales at an NFL event. As more people park in the neighborhoods that will
increase the impacts of drunk driving issues, police protection, on the streets and in the communities around 24
the bowl.

Diane Newman (see comment letter)

Comments related to the air quality section included a consultation with Dr. John Seinfeld. Dr. Seinfeld’s 25
email states: the analysis of the air quality section appears to follow standard practice. The report includes

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analysis of Carbon Monoxide, however, from the standpoint of human health impacts, emissions of
particulate matter need to be considered as well. In summary the report concludes that projected emissions
would exceed SCAQMD significance thresholds and no feasible mitigation measures exist. The logical
conclusion from Dr. Seinfeld’s email is this project should be a no-go. What could be a more important
question than how will bringing the NFL to the Rose Bowl affect the air we breathe and human health? The
25
EIR under represents the potential harms because it fails to measure or model particulate matter in close
proximity on game days. The measurements that are made are made at a distance both at Caltech and
Burbank. There are standard models that can be used to make measurements that are more relevant within
the basin being considered. This was done for CO it was not done for particulate matter. The increase in
particulate matter if the NFL comes will be damaging. The effects of particulate matter should be made
aware to the public as part of the analysis of the costs and benefits. The EIR states bringing the NFL to the
Rose Bowl would negatively impact air quality. If the City proceeds it will be doing so in conflict with
regional and national air quality legislation designed to protect human health.

Jonas Peters
26
(See full letter)

Leland Skylar
27
Concerns about what was in the report, regarding the police saying this will be okay. Maybe things will be
okay around the perimeter of the bowl, but by six am for a noon game there is already traffic on Rosemont.
There are issues with the streets being made one way and people are making streets one way and nearly
getting into accidents. This stadium is the least equipped to move traffic in and out, most stadiums have
almost a freeway line built that directs traffic in and out in multiple lanes. Rosemont is a two lane street and
is gridlocked with one car parked on it. The kids manning the barricades walk to other barricades to hang 28
out with their friends. People move barricades and start tailgating in front of the homes, they throw trash in
the yards. People sell food with no license. This will bring a huge element into the area that doesn’t even
know the area exists and a lot of them are here to case the neighborhood. There was an article in the
Huntington Press about increasing violence at NFL games. People come out of the games drunk. The fire
and police say it is okay, maybe along the perimeter, there are scalpers getting into altercations with people, 29
garbage, and parking. The quality of life for residents in this area is diminished during these events.

Ken Van Waggoner

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Public awareness for this project has been dismal. Distribution of a pamphlet to people within 500 feet of the
Rose Bowl barely gets off the lawn. There was no big, effective, media blitz because they don’t want to have
a thousand angry people here. The vast majority of residents rejected the NFL at the Rose Bowl. The Rose
Bowl is not designed for the NFL and the residents do not want it. The City commissioned a $400,000 EIR 30
when the project has been rejected by residents. The EIR was exposed at the Planning Commission and
systematically exposed and filled with poorly justified assumptions. There are glaring, unbelievable holes in
the arguments.

Felicia Williams

The traffic mitigation measures are inadequate because the EIR is focused on managing cars and not
removing them. The General Plan objective is to have city where people can circulate without a car, yet the
Rose Bowl gets an exemption because the contractors make a ton of money off the parking. This EIR won’t
touch it because it is a conflict of interest to affect the parking revenues at the Rose Bowl. The EIR includes 31
measures such as carpooling and social media but how do those help parking? The point is to get cars away
from the Rose Bowl. There need to be incentives and should include a true TDM plan that removes cars
instead of just managing them to get the revenues. The conflict of interest needs to be addressed over the
long term. There are no bike racks at the Rose Bowl – there is a long term conflict of interest and a true EIR
should address this conflict and manage it so cars are removed.

Jerome Whittiker

There will be weekends where there will be two major events. The EIR only looks at the impacts from one
32
game on a given day and nothing else beyond that. What is the cumulative impact when you have two
games on a weekend, both in air quality and traffic?

Lauren Gassus

Most residents who live near the arroyo have chosen to move to this community for the services, habitat,
educational opportunities, not for the NFL. The scope of the EIR has been limited due to the cost being 33
much less than the Farmer’s Field EIR. Most of the issues are ignoring the tax payers, division of a
community, the western residents on the weekends will not be spending tax dollars in Pasadena.
Huntington Hospital will be impacted due to the problems residents will suffer through toxic substances.
The compression of the events, 25 events in four months, there will be a number of weekends where there 34
will be two games. Two games back to back every weekend would double the impact, whether the golf

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course on a rainy day, or other areas. Is it reasonable to put the compression of the events on the citizens 34
here?

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3.0 Responses to Comments

Letter No. 16 Planning Commission Public Comments


City of Pasadena Planning Commission Meeting
Public Comments
September 19, 2012

Response 16-1

The comment relates to the adequacy of the Project Description. Please see Topical Response 1 regarding
the Project Description.

Response 16-2

Refer to Response 8-13, which addresses Mitigation Measure MM 3.6-2.

Response 16-3

Refer to Response 8-44, which addresses the inclusion of a Mitigation Measure to not permit the Oakland
Raiders as a team at the Rose Bowl.

Response 16-4

The comment suggests that patrons without tickets should not be allowed into the Central Arroyo. As
discussed in the letter provided by CSC and provided in Appendix F3.0 of the Final EIR, a relatively
small number of fans generally arrive at the stadium in hopes of receiving a free ticket or purchasing a
reduced price ticket. While some persons may remain in the parking lots during the game if they are
unsuccessful in obtaining a ticket, in the experience of CSC this has not constituted a significant problem.
In addition, many stadiums, including the Rose Bowl, patrol the parking lots during the game to request
that ticketless patrons leave the premises. For these reasons, it is not anticipated that ticketless fans would
congregate in the parking lots to tailgate during the game or in neighborhoods surrounding the Rose
Bowl merely to be close to the stadium.

Response 16-5

Refer to Response 8-11.

Response 16-6

The comment states the Linda Vista Annandale Association disagrees with the assessment of public
services provided in the Draft EIR. Refer to Response 8-45 for a discussion of the appropriate method for
determining impacts related to public services under CEQA.

Response 16-7

Refer to Response 8-8 regarding baseline data.

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Response 16-8

The comment states the Draft EIR does not take into account all potential land use policies addressing the
Central Arroyo. Refer to Response 11-9 for a discussion of land use policies. Table 3.3-1 Project
Consistency with Existing Land Use Plans, has been updated to include additional policies. Please also
see Response 8-23 related to the use of signage and commercial activity in the Arroyo.

Response 16-9

The comment states the discussion of public services should include a consideration of the City’s
resources that will be required to serve the project and the “potential burden to the City.” CEQA requires
a consideration of the potential impacts a project may have on public services such as police and fire
protection services to determine if the project would result in the need for the construction of new
facilities, the construction of which could have an impact on the environment. The proposed project
would not meet this threshold as (1) the PPD has indicated to the City that they have adequate services to
serve the proposed project (2) the PPD currently is budgeted for additional service positions that have not
been filled but could be filled if the need arises (3) the project would be temporary and any demand on
services would return to current levels once the NFL use of the Rose Bowl ends, and (4) PPD would be
supplemented with private security patrols which would not place an administrative burden on the City.

Response 16-10

The comment raises a general concern regarding traffic and other issues that do not appear to relate to
any physical effect on the environment. The Draft EIR addresses traffic issues in Section 3.7 Traffic,
Circulation and Parking. The comment will be included as part of the record and made available to the
decision makers prior to a final decision on the proposed project. However, because the comment does
not raise an environmental issue, no further response is required.

Response 16-11

Refer to Response 15-9 regarding the number of users of the recreational loop.

Response 16-12

Refer to Response 15-11 regarding Mitigation Measure MM 3.6-2 and Impact 3.6-3.

Response 16-13

Refer to Response 12-8.

Response 16-14

Included in the Draft EIR is a subsection “thresholds of significance” which includes a discussion of the
methodology for determining significance for each topic area. The comment states the Draft EIR does not

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3.0 Responses to Comments

address hazards such as terrorism or violent crime. The commenter is referred to pages 3.5.2-4 through
3.5.2-7 of the Draft EIR which address PPD training and capability to respond to violent crimes and in the
event of a terrorist attack.

Response 16-15

The comment states the Draft EIR does not address how people would get medical attention in the event
of an emergency. The commenter is referred to pages 3.5.2-7 and 3.5.2-8 of the Draft EIR which address
natural disasters and emergency response traffic.

Response 16-16

Refer to Response 11-19 related to groundwater

Response 16-17

On March 12, 2012 the City Council authorized the City Manager to enter into contracts with Impact
Sciences for the preparation of the EIR for this project and with Fehr & Peers to prepare the traffic impact
study. Impact Sciences was selected based on the firm’s experience in preparing EIRs for large and
complex projects throughout Southern California. Fehr & Peers was selected for their experience in
preparing traffic analyses for large and complex entertainment and sports venues in California.

Response 16-18

The analysis in the Draft EIR addresses all air pollutants produced in substantial quantities by the
proposed project, as well as their impact on all local sites and populations. Please also refer to
Response 2-6.

Response 16-19

The comment raises issues that do not appear to relate to any physical effect on the environment. The
comment will be included as part of the record and made available to the decision makers prior to a final
decision on the proposed project. However, because the comment does not raise an environmental issue,
no further response is required.

Response 16-20

The comment raises issues that do not appear to relate to any physical effect on the environment. The
comment will be included as part of the record and made available to the decision makers prior to a final
decision on the proposed project. However, because the comment does not raise an environmental issue,
no further response is required.

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3.0 Responses to Comments

Response 16-21

The comment asserts that NFL events are different from college events and suggests a ban on tailgating to
reduce crime, noise, and violence. As indicated in the letter provided by Mr. Mark Glaser of CSC, NFL
fans and college fans are generally similar in their behavior and tailgating habits. Currently, CSC
provides security service to the Rose Bowl during college events where tailgating takes place. CSC
deploys bicycle patrols throughout the parking areas to maintain order. It is expected that CSC would
continue to provide security services during NFL events. The current and expected tailgating activity
would not create a significant environmental impact within the meaning of CEQA. However, the
comment further states the project would create a challenge to the public order and states many tailgaters
come without tickets. The comment will be included as part of the record and made available to the
decision makers prior to a final decision on the proposed project. However, because the comment does
not raise an environmental issue, no further response is required.

Response 16-22

The comment states health impacts associated with the loss of recreational use at the Rose Bowl should be
evaluated. The Draft EIR discusses the loss of recreational opportunities in the Arroyo and concludes that
the loss of recreational opportunities in the Arroyo on event days is a significant and unavoidable
environmental impact. While recreational opportunities in general are important to a healthy community,
the unavailability of a particular facility for active recreation on 13 days per year is not expected to have
any measureable impact on health. The comment will be included as part of the record and made
available to the decision makers prior to a final decision on the proposed project.

Response 16-23

The comment states an opinion that 6 hours of tailgating prior to a game is “excessive.” Please see
Response 8-44 regarding the potential public services impacts of tailgating.

Response 16-24

Refer to Response 7-19, which relates to fire protection services in the San Rafael area.

Response 16-25

The comment states the impact to recreational users is understated and the effects on the rest of the
Arroyo are not addressed in the Draft EIR. Refer to Response 7-10 through Response 7-12.

Response 16-26

The traffic generated for the project is based on a maximum of 75,000 spectators and 4,000 employees for
an NFL game. The analysis conservatively assumes that up to 94 percent of the spectators and 80 percent
of employees will arrive via an automobile.

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3.0 Responses to Comments

Response 16-27

Refer to Response 7-1.

Response 16-28

The comment relates to lighting impacts related to clean up after events. Lighting would be used around
the Rose Bowl to clean up after an event. It is anticipated that the duration of clean up would be similar to
a college event and would result in similar lighting effects. Lighting associated with cleanup is minimal
compared to lighting associated with events at the Rose Bowl. As no spillover effects of game lighting
were found in the Initial Study and further discussed in Response 8-2, the minimal lighting associated
with clean up would also not be anticipated to spill over into the adjacent properties. The comment also
asks for information on other stadiums constructed in high-end communities. Staff is unaware of any
other stadium that is constructed in a similar location to the Rose Bowl.

Response 16-29

Refer to Response 16-4 for a discussion of ticketless patrons. Due to the inability of ticketless patrons to
stay in the parking lots at the Rose Bowl after kickoff, it is not anticipated that noise associated with the
minimal number of ticketless patrons would materially change the noise analysis presented in Section 3.4
Noise, of the Draft EIR.

Response 16-30

The comment relates to the loss of a recreational use due to the proposed project. The Draft EIR analyzes
the potential for users to be displaced from the Rose Bowl on event days and determined this would be a
significant and unavoidable impact.

Response 16-31

The comment asks for additional clarification on the threshold for public services impacts. CEQA
requires the consideration of a project’s impacts on the environment. As these relate to public services,
the physical change in the environment is generally related to the need to construct new or expanded
facilities. It is the construction of those new or expanded facilities that would result in a change in the
physical environment and a significant impact under CEQA.

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Letter No. 17

To: David Reyes, Principal Planner/Zoning Administrator Job No. 1136.01


From: Jessica Kirchner, Impact Sciences
Subject: Parks and Recreation Committee Meeting
Date: October 9, 2012

Parks and Recreation Committee Public Comment

October 4, 2012

Michael Duran

How many additional patrons will be advantaged by having the NFL here versus the current number of
users? How is this beneficial? Do we know how many and who uses the recreational facilities in the arroyo? 1
If we don’t how can be conduct a cost/benefit analysis and decide it would be better to have the NFL than to
not have the NFL? How is it possible to restore the damage done by parking at Brookside within one day if 2
the NFL game follows a UCLA game, or there is a rain storm? What is the beneficial impact of NFL games as
recreational opportunities? The fact that the document asserts these are equivalent is incredible. The recent
Star News article that discussed the recreational loop flies in the face of the assertion that the recreational 3
loop will be maintained even during a game day.

Jonas Peters
4
In Pasadena it rains in December and January, does the EIR adequately assess the damage to the grassy
fields such as Lot H? The EIR does not provide a fair assessment. The EIR does not discuss the accumulated
5
waste that would accumulate on these fields that are used for adults and children to play on. Also, the
accumulated chemical waste of having 100,000 visitors to these areas and what happens to the soils, are kids
6
exposed to these wastes such as oil and gasoline leaking from cars. The waste gets into the soil and can then

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6
get mobilized into the groundwater. What is the socio-economic and racial demographic of people that use
the parks now? Those people that will be displaced versus the demographic that will replace them. It should
7
be discussed in the EIR.

Bill Francis

There is no proposal from the NFL. This is potentially a financial windfall to the city. The City should try to 8
work through the process.

Ken VanWaggonon

The publicity about this project has been disappointing. The last proposal was widely disapproved. There
9
are many reasons residents of the City don’t want this project. The project is not wanted. The parking is
impossible.

Nina Chomsky
10
The project description is inadequate because it only describes a phase of the project. What is the deal with
the NFL, what are the real impacts? The DEIR is missing required baseline data in the Central Arroyo. There
is no specific analysis. Recreation impacts cannot be adequately understood without a baseline study of all
11
current actual arroyo recreational users. The mitigation measures are minimal and fail to accomplish
anything. Mitigation 3.6-2 is false and cannot be implemented and should be removed from the EIR. All 12
references in the DEIR to enhanced recreation and beneficial impacts must be removed. Where are all the
recreational users going to be relocated? How are they going to get there? What is the plan? The EIR does
not take into account all of the layers of land use plans supporting recreation which deemphasize
commercialism. The ASPLO, and other plans all recognize that Pasadena is under parked and recreation
13
spaces are a high priority. The EIR is in error by asserting the proposed project does not conflict with
recreational plans.

Lee Zanterson

The ULI report identifies the central arroyo as declining from overuse and lack of investment. What would
14
be the actual physical results on the arroyo of the further degradation of the central arroyo due to overuse by
the NFL. What is the tipping point where the arroyo cannot be restored? What will be the cumulative
impacts from continued use? The failure of the DEIR to include a historic resources section is a gross
inadequacy. The EIR fails to identify cumulative degradation over the current baseline degradation. The EIR 15

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should include a comprehensive written plan for central arroyo restoration, including specific 15
recommendations in the ULI report. LVAA is concerned about conflicts with tournament of roses, kidspace,
the aquatic center. How can tournament of roses and NFL both be accommodated in December? The EIR 16
does not provide detailed plans for relocating and mitigating the NFL impacts on central arroyo activities.

Norm Parker 17
Mitigation 3.6-1 should be removed, it is infeasible, the turf areas cannot be repaired in one day. Nearly
tripling the number of events might triple the cumulative effect and require real mitigation, which means a 18
written plan, including time tables, discussion with the golfers and an analysis of the costs of repairing and
preserving the golf course. Why doesn’t the DEIR similarly address repairing all grassy areas such as 19
Brookside Park and lot H? A real plan must also include specific measures with rainy day parking measures,
that is the unavailability of the golf course for parking on rainy days. Rainy days are not adequately 20
considered in the EIR. When the golf course is unavailable, patrons are parked in the neighborhoods. The
EIR does not mention this. Unlike UCLA fans, NFL fans cannot be parked in the neighborhoods. The
neighborhoods will not tolerate it. NFL fans will be consuming alcohol before, during and after games. The
21
DEIR must include mitigation specifically addressing relocation of NFL fan parking in the event of rain.

Don Orsey
22
The EIR compares an NFL game to an average UCLA game which is incorrect. NFL crowds cannot be
compared to college, there is increased alcohol. The EIR does not include a mitigation measure that the 23
Raiders will not be permitted as an NFL team in Los Angeles. The EIR should include mitigation limiting
alcohol consumption in the central arroyo and the stadium within the same limits as UCLA. The EIR should
24
include a mitigation prohibiting or limiting entry into the central arroyo by cars or shuttles without a ticket
25
to the game. The EIR ignores the problem of ticketless patrons. The section on recreation concludes with a
statement saying no mitigation is required and the residual impacts are beneficial. That does not make sense. 26
Susan McClemmons

The DEIR does not study the impact of NFL related plastic pollution and other trash and the impacts on the
Central Arroyo, Lower Arroyo and the Arroyo Stream. The report states the RBOC has a standard trash
removal plan, but fails to recognize that the plan is inadequate. After games plastic zip ties, bottles, caps, 27
grocery bags, cans, bottles, and charcoal are left for days. The trash is degrading the arroyo and finds its way
into the arroyo stream which feeds into the Pacific Ocean. There are sensitive areas under the Colorado
Street Bridge and in the lower arroyo. The City and nonprofits have worked on restoring those areas but

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they are clogged with trash. The current plan does not address what will happen if there is 75,000 plus the
ticketless patrons tailgating and picnicking. How many more tons of trash will be in the arroyo stream? It is
27
not addressed in the report.

Fred Zepeta

The EIR is deficient because there is no specific proposal instead there are assumptions and estimates. The 28
EIR uses college games and has not done any checking to find out the difference between college and NFL
games. The EIR for Farmer’s Field would be a baseline. The project description differs between the project 29
and the alternatives. The EIR says the project is consistent with General Plan objectives 2 and 17 and policies
17.3 and 17.2 but yet there is a significant recreational impact. The EIR does not include any baseline studies
30
of actual recreational activities in the arroyo. The omission of factual data raises concern as to the accuracy of 31
any of the impacts being measured. The EIR concludes there would be a slight increase in the use of nearby
32
parks. They don’t measure the impacts to those parks. This EIR should have all the questions asked the
description of the overriding concerns should be made public for 90 days. 33
Bill Christian

34
Requests a delay to provide additional time for comments. There is no analysis of alternative sources of
revenue. There is no guarantee the NFL stadium will be built in five years, the EIR should look at longer
term use by the NFL, 10 years. On game days people are prevented from any part of the loop or trails, it is 35
only going to get more restrictive with the NFL. People of color use that facility and the analysis should
focus on the socioeconomic effects of displacing those people from the rose bowl. The air quality and traffic
36
impacts are not mitigable, the committee should think hard about whether or not to do this.
37
Loring Guessous
38
(see comment letter)

Elizabeth Borth 39
The disruptive activities will affect float building. If there will be a practice field it should be addressed as
should equipment storage and uniform storage. The aesthetics would be disturbed and that has not been 40
addressed. The trails are essentially closed to equestrian users while activities are going on. The existing
agreement with the Santa Monica Mountains Conservancy guarantees the trails will remain open 365 days a 41
year. There could be impacts upstream, and other projects such as the sediment removal need to be
42

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42
43
addressed. That will also have a tremendous effect on air quality and water quality. The project would
contribute to obesity problems and remove opportunities for people who cannot afford a gym membership.
44
The opportunity for kids to be outdoors also needs to be considered.

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Letter No. 17: Public Comments from the Transportation Advisory Commission Meeting
September 27, 2012
Transportation Advisory Commission
September 27, 2012

Response 17-1

The traffic management plan implemented by the PPD is designed to protect residential neighborhoods
and facilitate the flow of traffic into and around the Rose Bowl. It is considered to be a dynamic plan,
where adjustments can be made, if barricades are not working in the manner they are proposed.

Response 17-2

The project trips generated by an NFL game are expected to come from all geographic directions with the
majority arriving by freeway. The study area for the traffic analysis was developed in conjunction with
Pasadena Department of Transportation (PDOT) and follows the City of Pasadena’s adopted traffic study
guidelines. The area was determined in coordination with Rose Bowl Operations staff, PPD and PDOT.
The agencies provided input based on their vast experience at the Rose Bowl events over the past 30
years, including ground and aerial observations of traffic during events. In addition, observations were
taken at a UCLA/Cal football game from last season. Comments from the 2005 EIR were also taken into
consideration.

Response 17-3

The data used to forecast traffic increases on street segments was developed using mode split and
average vehicle occupancy estimates. The trips were then assigned to the street system and in some cases
resulted in increases of more than 5 percent over existing traffic volumes. The increase in traffic volumes
are indicated in Table 3.7-18 on page 3.7-91 of the Draft EIR.

Use of changeable message signs on the freeway as mitigation is aimed at facilitating ingress/egress on
game days. These do not fully mitigate the additional trips generated by the project but help improve
access to the Rose Bowl area.

Response 17-4

The comment points out a typographical error contained in the staff report included in the agenda for the
meeting and expresses opinions related to traffic associated with the proposed project. The Draft EIR
addresses traffic in Section 3.7 and concludes that traffic impacts will be significant and unavoidable. The
comment will be included as part of the record and made available to the decision makers prior to a final
decision on the proposed project. However, because the comment does not raise an environmental issue,
no further response is required.

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Response 17-5

It is standard practice, accepted by the various air districts in California including the SCAQMD, to use
the nearest air quality monitoring station for data on ambient air quality. These stations have been
carefully sited by the air districts to provide quality data for the area in which they are located. They are
also carefully calibrated and maintained, and collect data over long periods of time to provide an accurate
measure of ambient air quality that is largely independent of statistical outliers. Taking ambient air
quality measurements locally and only during displacement events at the Rose Bowl would provide
results that are not a true reflection of ambient air quality. This would also likely result in baseline
pollutant levels much higher than generally experienced in the area, which would be counter to the
conservative analysis typical of a CEQA assessment. For a discussion of localized air quality impacts
please see Draft EIR impact discussion 3.1-4 and Response 2-6.

Response 17-6

The comment relates to the displacement of recreational users. Refer to Response 15-9 and
Response 15-10.

Response 17-7

The comment relates to recreational uses. Refer to Response 15-11. The comment also states the EIR does
not state the magnitude of impacts. The purpose of the environmental document is to disclose the
potential for environmental impacts associated with the project. CEQA does not provide a means to rank
or otherwise indicate that impacts are greater or lesser other than to indicate they are significant.

Response 17-8

Refer to Response 15-16.

Response 17-9

Devil’s Gate Dam & Reservoir Sediment Removal Project (#27) and Parson’s Mixed-Use Project (#28) are
included in the analysis as related projects. Traffic projections for both sites are incorporated in the traffic
analysis. Please refer to Table 10 of the Traffic Study for reference.

Please see Response 2-6 regarding localized air quality impacts on health

Response 17-10

The comment states the EIR jumps to statements of overriding considerations and does not fully mitigate
impacts. The Draft EIR discloses potential significant impacts based on data, research, and technical
expertise, and includes mitigation measures aimed at reducing those potential impacts. The unique
nature of the proposed project, specifically the fact that it is temporary, limits the ability to include

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permanent mitigation measures that would typically be used to mitigate traffic and noise impacts, such
as constructing new turn lanes, or erecting noise barriers. Nonetheless, effective and innovative traffic
measures have been included in the proposed project. Please also see Response 8-7 regarding effective
mitigation measures.

Response 17-11

Refer to Topical Response 1 regarding the Project Description.

Response 17-12

Refer to Response 8-15 for a discussion of displaced users.

Response 17-13

Please refer to Response 7-16 regarding the intersections on Arroyo Boulevard south of California, the
intersection of Arroyo Boulevard and Seco Street and any streets east of Arroyo Parkway such as
Marengo and Los Robles

Page 3.7-2 of the Draft EIR correctly refers to the City’s 2004 Mobility Element. The reference in
Table 3.7-6 is a typo and has been corrected to say “2004.”

Response 17-14

Please refer to Response 8-28.

Response 17-15

Please refer to Response 8-39.

Response 17-16

Refer to Response 16-9 regarding the administrative burden on the City.

Response 17-17

Refer to Response 8-41.

Response 17-18

The analysis presented in the EIR estimates that 50 percent of spectators will arrive in the hour before a
game on a weekday and 40 percent on a weekend. This is based on a worst-case scenario and data from
other studies and stadiums.

Response 17-19

Please refer Response 6-2.

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Response 17-20

Please refer to Response 6-3.

Response 17-21

A specific mitigation plan is not included for the shuttles as they are considered in the overall assignment
and distribution of vehicles on the circulation system. Mitigation measures have been developed to
address traffic impacts where feasible and are described in the Draft EIR. Also, please also refer to
Response 8-33.

Response 17-22

Please see Response 8-35.

The mode share for the project concludes that 8 percent and 6 percent of spectators will use an active
(transit, bike, and walk) mode of transportation on a weekday and weekend respectively. Additionally,
20 percent of employees are expected to use an active mode of transportation on weekdays and weekend.

Traffic congestion is likely to play a large role in encouraging patrons of the Rose Bowl to use an active
transportation mode.

Response 17-23

Refer to Response 8-12.

Response 17-24

Refer to Response 17-17, above.

Response 17-25

It is standard practice, accepted by the various air districts in California including the SCAQMD, to use
the nearest air quality monitoring station for data on ambient air quality. These stations have been
carefully sited by the air districts to provide quality data for the area in which they are located. They are
also carefully calibrated and maintained, and collect data over long periods of time to provide an accurate
measure of ambient air quality that is largely independent of statistical outliers. Taking ambient air
quality measurements locally and only during displacement events at the Rose Bowl would provide
results that are not a true reflection of ambient air quality. This would also likely result in baseline
pollutant levels much higher than generally experienced in the area, which would be counter to the
conservative analysis typical of a CEQA assessment. For a discussion of localized air quality impacts
please see Draft EIR impact discussion 3.1-4 and Response 2-6.

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Response 17-26

Refer to responses to comment Letter No. 48.

Response 17-27

The comment restates information contained in the Draft EIR and does not raise an environmental issue
within the meaning of CEQA. The comment will be included as part of the record and made available to
the decision makers prior to a final decision on the proposed project. However, because the comment
does not raise an environmental issue, no further response is required.

Response 17-28

The comment is noted and is hereby part of the Final EIR, and will be forwarded to the decision makers
for their consideration prior to taking any action on the Project.

Response 17-29

The comment raises issues that do not appear to relate to any significant environmental impacts that were
not discussed in the Draft EIR. The comment will be included as part of the record and made available to
the decision makers prior to a final decision on the proposed project.

Response 17-30

Refer to Response 12-8.

Response 17-31

The Draft EIR includes a TDM plan as an Additional Measure (AM 3.7-2.1). This includes ways to
incentivize carpooling, the use of alternative transportation modes and the use of social media to
communicate information regarding potential modes of travel other than passenger vehicles to/from the
Rose Bowl (rail/bus/shuttle routes, timetables, etc.). The goal of the TDM plan is to reduce automobile
trips.

The comment on the bicycle racks is noted and is hereby part of the Final EIR, and will be forwarded to
the decision makers for their consideration prior to taking any action on the Project Free bicycle parking
is available at Brookside Park across from the Aquatic Center (www.visitPasadena.com) and the Draft
EIR recommends bicycle valet parking at the Parsons site in order to encourage use of bicycles and
discourage vehicle use.

Response 17-32

Refer to Response 15-1.

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Response 17-33

The comment suggests the scope of the EIR has been limited compared to Farmer’s Field due to the cost
to prepare the EIR. Regarding the difference in scope between the Draft EIR and the Farmer’s Field EIR,
the Farmer’s Field project includes construction of a new multi-purpose stadium, new convention space,
and two parking structures. Although both projects include the use of a stadium by the NFL, the scope of
the Farmer’s Field project is far greater than the use of an existing stadium by the NFL. As such, there are
vast differences in scope of the two documents. Therefore the treatment of issues within the Draft EIR is
appropriately different from treatment of issues in the Farmer’s Field EIR.

The comment states Huntington Hospital will be impacted due to the health effects of the project on
residents. Refer to Response 2-6 for a discussion of localized air quality effects associated with the
project. Refer to Response 11-19 regarding chemical seepage. Based on the analysis in the Final EIR there
is no evidence to suggest the proposed project would result in adverse health effects to the extent that
local hospitals would be affected.

Response 17-34

The comment states that two games on a weekend would double the impact associated with the project.
Refer to Response 15-1 which relates to impacts associated with two events in a weekend.

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3.0 Responses to Comments

Letter No. 18: City of Pasadena Recreation and Parks Commission Meeting, Public
Comments
City of Pasadena
Parks and Recreation Commission Meeting
October 2, 2012

Response 18-1

The comment asks the number of users of the arroyo. Section 3.6 Recreation, Existing Conditions, On-Site
Sports and Recreation, of the Draft EIR, provides general estimates of the number of users of the
recreational facilities around the Rose Bowl. In addition, as discussed in Response 15-9, additional counts
were taken to estimate the number of users specific to the loop. The comment also asks who the project
would benefit. This question raises issues that do not appear to relate to any physical effect on the
environment. The comment will be included as part of the record and made available to the decision
makers prior to a final decision on the proposed project.

Response 18-2

Refer to Response 7-11 and Response 14-24.

Response 18-3

The comment relates to Impact 3.6-3. This impact has been removed from the Final EIR.

Response 18-4

The comment relates to the effects of parking on grassy areas during rain. Refer to Response 7-11 and
Response 14-24 for a discussion of maintenance of grassy areas. Refer to Response 18-20 for a discussion
of parking at the Rose Bowl on rainy days.

Response 18-5

Refer to Response 8-22.

Response 18-6

Refer to Response 11-19.

Response 18-7

The comment raises issues that do not appear to relate to any physical effect on the environment. The
comment will be included as part of the record and made available to the decision makers prior to a final
decision on the proposed project. However, because the comment does not raise an environmental issue,
no further response is required.

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Response 18-8

Please see Topical Response 1 regarding the Project Description and any potential deal with the NFL.

Response 18-9

Refer to Response 12-8.

Response 18-10

Refer to Topical Response 1 regarding the Project Description.

Response 18-11

Refer to Response 8-10 and Response 15-9 regarding a baseline study for use of the arroyo.

Response 18-12

Refer to Response 8-7, Response 8-13, Response 8-14 and Response 8-15 regarding the adequacy of
mitigation measures and Impact 3.6-3.

Response 18-13

Refer to Response 8-24 regarding consistency with land use plans. The comment further states an opinion
that the proposed project is not consistent with recreational plans. The Draft EIR also includes Table 3.3-1
which summarizes the project’s consistency with the General Plan, Green Space Recreation and Parks
Element, and Arroyo Seco Design Guidelines.

Response 18-14

The comment asks what the physical effects of the arroyo would be due to overuse by the NFL. The
purpose of the Draft EIR is to identify the potential significant physical effects of the temporary use of the
Rose Bowl by the NFL. This includes the cumulative effects (effects of the proposed project in
combination with other projects). The determination of significance is based on a comparison of the
proposed project (temporary use of the NFL) to the existing condition. In this case, the commenter is
suggesting the existing condition is degraded as compared to some previous condition (the commenter
does not indicate when the decline started). The commenter also states the Arroyo is declining due to
“overuse” and “lack of investment.” As discussed in the Draft EIR, the temporary use of the Rose Bowl
by the NFL would result in significant and unavoidable impacts related to traffic, noise, air quality, and
recreation. Some potential physical impacts such as the degradation of the golf course could be mitigated
through periodic repair. As discussed in Response 8-10, the golf course continues to be attractive and
highly regarded despite periodic repairs that take place after events take place at the Rose Bowl. Other
impacts described in the Draft EIR are event specific. Therefore, use of the Rose Bowl for displacement

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3.0 Responses to Comments

events on an additional 13 occasions per year for a period of five years is not expected to degrade the
arroyo to the point where it could not be restored.

Response 18-15

Please see Topical Response 2 regarding historic resources and Response 13-1.

Response 18-16

Refer to Response 8-19 regarding the conflict with Central Arroyo activities.

Response 18-17

Refer to Response 8-11 regarding Mitigation Measure MM 3.6-1.

Response 18-18

Refer to Response 8-11 regarding a written plan for the repair and preservation of the golf course.

Response 18-19

Refer to Response 8-11 regarding repair of grassy areas.

Response 18-20

Refer to Response 8-12.

Response 18-21

Please refer to Response 8-12.

Response 18-22

The comment states the comparison of NFL crowds to college crowds is incorrect. Based on information
provided by CSC and included in Appendix F3.0 of the Final EIR, the behavior of NFL fans is not
expected to be materially different than the behavior of college football fans.

Response 18-23

Refer to Response 8-44 related to a mitigation measure to not permit the Oakland Raiders as a team in
Los Angeles.

Response 18-24

The comment suggests a mitigation measure limiting alcohol sales at NFL events. The suggested
mitigation measure would not reduce an environmental impact caused by the proposed project.
Therefore, the suggested mitigation measure has not been included in the project. However, the
suggestion will be provided to the City Council a comment in the Final EIR

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Response 18-25

The comment suggests a mitigation measure limiting ticketless patrons from accessing the Rose Bowl on
NFL game days. The suggested mitigation measure would not reduce an environmental impact caused
by the proposed project. Therefore, the suggested mitigation measure has not been included in the
project. However, the suggestion will be provided to the City Council as a comment in the Final EIR.

Response 18-26

The comment refers to a statement discussing a beneficial effect of the proposed project. Impact 3.6-3 has
been removed from the Final EIR.

Response 18-27

Refer to Response 8-22.

Response 18-28

Please see Topical Response 1 related to the adequacy of the Project Description and Response 18-22
regarding similarities between college and NFL fans. The comment also suggests the use of the Farmer’s
Field EIR for baseline data. The Farmer’s Field project includes construction of a new multi-purpose
stadium, new convention space, and two parking structures. Although both projects include the use of a
stadium by the NFL, the scope of the Farmer’s Field project is far greater than the use of an existing
stadium by the NFL. As such, it would not be particularly useful to readers of the Draft EIR to compare
the two environmental documents due to the vast differences in scope.

Response 18-29

Refer to Response 7-6 regarding the statement of project objectives.

Response 18-30

Refer to Response 9-7 regarding internal consistency.

Response 18-31

Refer to Response 8-10 and Response 15-9 regarding baseline studies.

Response 18-32

Refer to Response 9-9 and Response 15-11 regarding recreational impacts to nearby parks.

Response 18-33

Refer to Response 7-1.

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Response 18-34

Refer to Response 7-1 regarding additional review. Alternative 3 analyzes an alternative that provides a
source of revenue other than the NFL.

Response 18-35

The Project Description of the Draft EIR (Page 2.0-14) explains that the NFL would use the Rose Bowl
Stadium on a temporary basis until a permanent stadium is selected and built in the Los Angeles area or
the completion of a five-year lease term, whichever comes first. A 10-year period is not proposed as part
of this project.

Response 18-36

The comment states that access to the loop and trails will be more restrictive during NFL use. The Draft
EIR includes Mitigation Measure MM 3.6-2 to maintain access to the trails in accordance with the City’s
agreement with the Santa Monica Mountains Conservancy. Please see Response 7-11 regarding proposed
revisions to MM 3.6-2 in response to comments on the Draft EIR

Response 18-37

The comment provides factual background information only and does not raise an environmental issue
within the meaning of CEQA. The comment will be included as part of the record and made available to
the decision makers prior to a final decision on the proposed project.

Response 18-38

Refer to Response to letter 33.

Response 18-39

The comment states the proposed project would disrupt float building that occurs in the arroyo. Please
see Response 8-3 regarding conflicting activities in the arroyo. The comment will be included as part of
the record and made available to the decision makers prior to a final decision on the proposed project.

The comment further states the use of practice fields should be addressed. Under the proposed project,
the Rose Bowl would not be used for any team practices. This is stated in the Draft EIR on page 2.0-15.
The NFL team using the Rose Bowl would need to obtain practice facilities outside of the Rose Bowl and
the Arroyo Seco.

Response 18-40

Refer to Response 8-23 for a discussion of aesthetics.

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Response 18-41

Refer to Response 18-36 regarding trail access.

Response 18-42

The Draft EIR includes the sediment removal project in its list of cumulative project. Therefore, the
potential effect of the sediment removal project is addressed in the Draft EIR.

Response 18-43

The comment indicates the sediment removal project will have an effect on air and water quality. As
discussed in Response 18-42, the sediment removal project was included in the cumulative analysis
provided in the Draft EIR. Therefore, the potential cumulative effect of the sediment removal project is
included in the Draft EIR.

Response 18-44

Refer to Response 16-22.

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Letter No. 19

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3.0 Responses to Comments

Letter No. 19: Mary Alexander


Mary Alexander
580 Prospect Boulevard
Pasadena, CA 91103
October 8, 2012

Response 19-1

The comment concerns the overall merits of the proposed project. The comment will be included as part
of the record and made available to the decision makers prior to a final decision on the proposed project.

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Letter No. 20

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Letter No. 20: Eunice and Ho Bae


Eunice and Ho Bae
October 4, 2012

Response 20-1

The comment concerns the overall merits of the proposed project. The comment will be included as part
of the record and made available to the decision makers prior to a final decision on the proposed project.

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Letter No. 21

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Letter No. 21: Adele Baquet

Adele Baquet
Sierra Madre, CA

Response 21-1

The letter concerns the overall merits of the proposed project. Refer to Section 3.6 Recreation of the Draft
EIR which determined the proposed project would result in significant and unavoidable impacts related
to recreation. The comment will be included as part of the record and made available to the decision
makers prior to a final decision on the proposed project.

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Letter No. 22

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Letter No. 22: Kristina Bell and Andrei Marinescu


Kristina Bell and Andrei Marinescu
910 Linda Vista Avenue
Pasadena, CA 91103
August 13, 2012

Response 22-1

The comment concerns the overall merits of the proposed project. The comment will be included as part
of the record and made available to the decision makers prior to a final decision on the proposed project.

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Letter No. 23

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Letter No. 23: Don Bremner


Don Bremner
1680 Walworth Ave
Pasadena, CA 91104
n.d.

Response 23-1

The comment restates information contained in the Draft EIR and does not raise an environmental issue
within the meaning of CEQA. The comment will be included as part of the record and made available to
the decision makers prior to a final decision on the proposed project. However, because the comment
does not raise an environmental issue, no further response is required.

Response 23-2

The comment states the Draft EIR ignores that other parks and trails listed in the document are not the
same as the Arroyo Seco. The commenter is referring to the list of community and neighborhood parks
and special facilities provided in Section 3.6 Recreation of the Draft EIR. It is not the intention of this
section to imply that any one park is similar and contains all of the features of the Rose Bowl. In fact, each
facility includes a description of the features (ball fields, picnic areas, etc.) associated with that park. The
intent of this listing of parks is simply to provide the reader with an understanding of the available parks
in the Pasadena area as required by CEQA.

Response 23-3

Refer to Response 8-10 related to a baseline study of recreation. Please also see Response 15-9 for
additional counts conducted by the City of users of the loop.

Response 23-4

Refer to Response 8-11 and Response 14-24.

Response 23-5

The comment indicates that the project is inconsistent with the policies listed on Table 3.3-1 of the Draft
EIR. Table 3.3-1 lists each applicable policy and provides an explanation of why the project is consistent
with the policy.

Response 23-6

The comment points to a Section 3.32.060 (C) of the Arroyo Seco Public Lands Ordinance. This subsection
has been added to Section 3.3 Land Use of the EIR. Please see Section 2.0 Corrections and Additions.

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Response 23-7

The comment concerns the overall merits of the proposed project. The comment will be included as part
of the record and made available to the decision makers prior to a final decision on the proposed project.

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Letter No. 24

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3.0 Responses to Comments

Letter No. 24: John Boyle


John Boyle
1119 Wotkyns Drive
Pasadena, CA 91103
October 3, 2012

Response 24-1

The City acknowledges your input and comment. The comment will be included as part of the record and
made available to the decision makers prior to a final decision on the proposed project.

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Letter No. 25

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Letter No. 25: Petrea Burchard Sandel


Petrea Burchard Sandel
551 Eldora Road
Pasadena, CA
October 5, 2012

Response 25-1

Please see Response 8-11 regarding impacts to the golf course. Please see Response 2-6 regarding
localized air quality impacts

Response 25-2

The comment raises issues that do not appear to relate to any physical effect on the environment. Any
diminution of property values during the maximum five-year period during which an NFL team would
play at the Rose Bowl is not expected to result in physical impacts to the neighborhood. The comment
will be included as part of the record and made available to the decision makers prior to a final decision
on the proposed project. However, because the comment does not raise an environmental issue, no
further response is required

Response 25-3

Please see Response 8-40, Response 8-41, Response 8-45, and Response 11-20 regarding impacts on
public services.

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Letter No. 26

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Letter No. 26: Cabriera-Johnson Family


Cabriera-Johnson Family
September 24, 2012

Response 26-1

The City acknowledges your input and comment. The comment will be included as part of the record and
made available to the decision makers prior to a final decision on the proposed project.

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Letter No. 27

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Letter No. 27: Samir Das


Samir Das
October 1, 2012

Response 27-1

The comment concerns the overall merits of the proposed project. The comment will be included as part
of the record and made available to the decision makers prior to a final decision on the proposed project.

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Letter No. 28

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Letter No. 28: Michael F. Duran


Michael F. Duran
721 Washington Boulevard

Response 28-1

The comment refers to the No Project Alternative. As stated in Section 4.0 Alternative, State CEQA
Guidelines Section 15126.6(e)(2) requires if the No Project Alternative is identified as environmentally
superior, then another environmentally superior alternative shall be identified among the other
alternatives. Therefore, although the No Project Alternative would not create any new impacts related to
transportation, air quality, greenhouse gas emissions, recreation, and noise, Alternative 2 is selected as
the environmentally superior alternative in accordance with CEQA.

Response 28-2

The comment incorporates the letter submitted by the Linda Vista Annandale Association. Refer to the
responses to Letter No. 8.

Response 28-3

The comment concerns the overall merits of the proposed project. The comment will be included as part
of the record and made available to the decision makers prior to a final decision on the proposed project.

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Letter No. 29

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Letter No. 29: Michael Duran


Michael Duran
October 8, 2012

Response 29-1

The comment concerns the overall merits of the proposed project. The comment will be included as part
of the record and made available to the decision makers prior to a final decision on the proposed project.
The comment also indicates that the Draft EIR is “flawed” without providing additional detail. As
detailed in responses to other comments, the Draft EIR fully complies with CEQA.

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Letter No. 30

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Letter No. 30: Eleanor Edwards


Eleanor Edwards
313 Arlington Drive
Pasadena, CA 91105
October 8, 2012

Response 30-1

The comment concerns the overall merits of the proposed project. The comment will be included as part
of the record and made available to the decision makers prior to a final decision on the proposed project.

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Letter No. 31

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Letter No. 31: Barbara Ellis


Barbara Ellis
October 8, 2012

Response 31-1

The Draft EIR acknowledges significant traffic and air quality impacts. Please see Response 2-6 regarding
localized air quality impacts.

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Letter No. 32

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Letter No. 32: Gregory Fu


Gregory Fu
October 8, 2012

Response 32-1

The Draft EIR acknowledges the significant and unavoidable impact on recreation caused by limiting the
use of the Central Arroyo on event days. The comment concerns the overall merits of the proposed
project. The comment will be included as part of the record and made available to the decision makers
prior to a final decision on the proposed project.

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Letter No. 33

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Letter No. 33: Loring Guessous


Loring Guessous
804 Linda Vista Avenue
Pasadena, CA 91103
October 2, 2012

Response 33-1

The first part of the comment includes an introduction to comments that follow. No further response is
required.

Response 33-2

Refer to Response 7-10 for a discussion of the number of active users at the Rose Bowl in the fall.

Response 33-3

Refer to Response 6-2.

Response 33-4

The comment concerns the overall merits of the proposed project. The comment will be included as part
of the record and made available to the decision makers prior to a final decision on the proposed project.

Response 33-5

Draft EIR Section 3.7 acknowledges significant traffic impacts. Please see Response 8-45 regarding
emergency access before and after events. Please see discussion of Impact 3.6-1 in the Draft EIR and
Response 8-15 for a discussion of impacts on other parks in Pasadena. The comment regarding potential
economic impacts will be forwarded to the City Council as part of the Final EIR.

Response 33-6

See Response 8-11 regarding repair of the golf course after game day activities. The comment regarding
potential economic impacts will be forwarded to the City Council as part of the Final EIR.

Response 33-7

Refer to Response 16-28.

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Letter No. 34

Sent by Certified Mail and Email

October 7, 2012

Gary Hackney
P.O. Box 92713
Pasadena, California 91109

David Sinclair, Planner


Planning Department
175 N. Garfield Avenue
Pasadena, California 91109

Subject: Comments on the Draft Environmental Impact Report for Temporary Use of the Rose Bowl
Stadium by the National Football League (NFL).

Dear Mr. Sinclair;

Thank you for the opportunity to comment on the draft EIR for temporary use of the Rose Bowl for NFL
games. As I review the draft EIR, I can’t help but reflect back on how we got to this point. Only a few
years ago after much review and study, the residents of Pasadena overwhelmingly voted against the
Rose Bowl hosting an NFL football team. Clearly, even back then, the Rose Bowl was in serious need of a
major renovation and the NFL proposal was touted as a way to finance needed improvements.
Fortunately our City leaders stepped back and developed a renovation plan that was much more in
keeping with the character of Pasadena and also preserved and modernized this iconic venue. As the
plans evolved, so did a financing mechanism and the best part was, it didn’t involve the NFL. Now here
we are reviewing another draft EIR that would allow the NFL to “temporarily” use the Rose Bowl. The
document seems to be an improvement over the initial study, but unfortunately, it appears that most
impacts are dismissed as either temporary or unavoidable and effective mitigation is not provided.
Further, it is not clear from the document who will be financially responsible for the mitigation
measures that have been identified. In some cases, the document ignores real operational impacts by 1
defining a “threshold of significance” that only considers physical impacts. This could be valid under
CEQA, but certainly doesn’t represent what appeared to be the original intent of the Arroyo Seco
Ordinance or assurances from City officials at the start of current discussions regarding the NFL. As we
all know, there is no plan to construct physical facilities so we could have eliminated the expense of an
EIR had we known that the review would be limited to physical impacts.

When the most recent talk of hosting an NFL team first began about a year ago, we were told that it was
only two years, it would bring in millions of dollars of revenue that would offset the budget gap on the
renovation, create hundreds of jobs, and impacts if there were any, would be taken care of. Now after
reviewing the EIR, we find that there will be no significant job creation and many of the impacts are
either unavoidable or do not require mitigation under CEQA. Hopefully, prior assurances that the
renovation budget gap will be substantially reduced or eliminated are still valid, but we won’t know this
until the “NFL deal” is disclosed. Thus far, we appear to be down a half a million dollars that was spent

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to prepare an EIR for the NFL. The document certainly favors the NFL by failing to identify the
responsible party for costs that will be incurred for items such as traffic management and recreational
facility repairs. The potential duration of the NFL lease has now increased to 5 years and there is no
certainty that this can be relied on either. My requests for further assurances that this time limit is valid
were ignored in the EIR by referring the commenter to the ALTERNATIVES ANALYSIS that is silent on this
matter. The Farmer’s Field proposal is still in a state of flux and now the sponsoring organization, AEG is 1
up for sale with no guarantee the project will continue under new ownership. I am only relieved that
none of this happened while we were “temporarily” hosting the NFL at the Rose Bowl. Clearly, the Rose
Bowl renovation was necessary and the progress thus far is an excellent improvement to the historic
stadium. However, the financing plan that was shared with the public for the renovation did not
contain any mention of the NFL as part of the financing scheme. At this point, I think I have to agree
with the Urban Land Institute, that temporary use of the Rose Bowl by the NFL is a bad idea.

My specific comments on the draft EIR are as follows. The preparer of the draft EIR failed to address
several of my comments on the NOP and relies on the casual unsubstantiated conclusions in the initial
study to dismiss impact areas as insignificant. The preparer needs to clarify throughout the document, 2
that the proposed tenant will be responsible for all mitigation measures in conjunction with the RBOC
and the City.

In Section 2 PROJECT DESCRIPTION, under description of NFL events on page 2.0-15 there is no mention
of set up and tear down of temporary facilities outside of the Rose Bowl stadium such as in Lot H. This is
good news, but should be made a contract requirement to reduce recreational diversion impacts (i.e.
Lot H can be used for game day parking only and no other activities are allowed). On the same page, the
description states that NFL games may not be held on the same weekends as UCLA games. This should
3
be clarified, will they or won’t they? On page 2.0-16, under signage and lighting, the NFL’s Sports
Lighting Design Criteria is described. If special lighting is required for the NFL, they should pay for it.
Furthermore, the statement that stadium lighting is comparable to residential street lighting, is not
consistent with public testimony that has been received on this project.

In PUBLIC SERVICES under Section 3.5.1 Fire Protection on page 3.5.1-6, Impact 3.5.1-1 states that “The
Project could increase the demand for fire protection services…..”. Under Section 3.5.2 Police
Protection on page 3.5.2-4, Impact 3.5.2-1 states that “The Project could affect police levels on event
days……..”. Under Cumulative Impacts on page 3.5.2-8 and page 3.5.2-9 beginning with the second
sentence states “Police levels of service could decrease due to elevated police workload associated with
the increased visitor population of cumulative development within the City of Pasadena. However, the 4
proposed project would be temporary in nature and after a period of five years would not add to any
cumulative demand on police protection services.” The document goes on to characterize these
significant impacts as insignificant because they do not create physical impacts. It is ridiculous to
suggest that the residents of Pasadena are concerned about physical impacts associated with new fire or
police facilities in evaluating this project. How will these significant impacts be mitigated and who will
pay for it?

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Section 3.6 RECREATION, page 3.6-22, Impact 3.6-1 “The proposed project would not result in physical
deterioration of neighborhood or regional parks…….” For all practical purposes, the Central Arroyo is a
regional park. The increased frequency of utilizing the Brookside Golf Course, the Brookside Park and
Lot H for parking will significantly increase the deterioration of these facilities requiring weekly repairs
5
and substantial refurbishment at the end of the football season. The tenant should be responsible for
these increased maintenance activities. Mitigation Measure 3.6-1 should specify the tenant as the
responsible party for immediate and annual repairs. In addition, the mitigation measure should identify
the tenant as the responsible party for repairs of all turf and non-paved areas designated for use by the
tenant for parking or any other purpose. On page 3.6-23, last paragraph after Impact 3.6-2 fourth line
add Kidspace as another unavailable facility resulting from the proposed project. On page 3.6-24, first
paragraph, last sentence add after “ ….traffic around the Rose Bowl” and the complete absence of
parking. On page 3.6-29, Mitigation Measure 3.6-2 will have no measurable affect because parking will 6
be prohibited or very costly. A more meaningful attempt at mitigation would be through lease
agreement conditions stipulating no day games, no entry or parking before 12 noon, and temporary
reservation of parking for loop users until 12 noon on game day. On page 3.6-30, the statement that the
residual impact is beneficial is subjective and should be removed with the annotated explanation that
use of the Rose Bowl by the NFL was previously rejected by Pasadena voters and the Urban Land 7
Institute does not recommend this use for the Central Arroyo.

Section 3.7 TRAFFIC, Page 3.7-81 through page 3.7-90, Mitigation Measure 3.7-1, Mitigation Measure
3.7-2, Additional Mitigation Measure 3.7-2.1. It is not clear from the mitigation measures who will cover
the cost of the additional expanded Traffic Operations Plan. The mitigation measures should be
8
expanded to require the tenant to contract with the City for implementation of the TOP with all costs
borne by the tenant. On page 3.7-102, clarify the tenant’s responsibility to comply with Mitigation
Measure 3.7-4.

Again, thank you for the opportunity to comment on the Draft EIR. I will look forward to reviewing your
response to comments in the Final EIR. Unfortunately, based on the inability to mitigate impacts, any
proposal involving the NFL’s use of the Rose Bowl is still not in the best interest of Pasadena.

Sincerely,

Gary Hackney

C: City Manager Michael Beck (mbeck@cityofpasadena.net)


Mayor Bill Bogaard (bbogaard@cityofpasadena.net)
Council Member Jacque Robinson (jrobinson@cityofpasadena.net)
District 1 Field Representative Tina Williams (twilliams@cityofpasadena.net)
East Arroyo Residents Association Board of Directors

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3.0 Responses to Comments

Letter No. 34: Gary Hackney


Gary Hackney
PO Box 92713
Pasadena, CA 91109
October 7, 2012

Response 34-1

The comment asks who will be paying for the mitigation measures included in the EIR. The following
measures are anticipated to have a cost associated with implementation:

MM 2.0-1 RBOC will be responsible for costs associated with this measure.

MM 2.0-2 – RBOC will be responsible for costs associated with this measure.

MM 3.6-1 – RBOC will be responsible for implementing the measure including any costs associated with
implementation.

MM 3.6-2 – Minimal cost associated with periodic oversight. The City of Pasadena Public Works
department will be responsible, and the City of Pasadena will be responsible for any costs associated with
oversight of the measure.

MM 3.6-3 – RBOC shall be responsible for the costs associated with notification.

MM 3.6-4 – Minimal costs associated with negotiation of the existing leases.

MM 3.6-5 – The City will be responsible for the costs associated with monitoring and repairing nearby
parks.

MM 3.7-1 - The City of Pasadena will be responsible for the costs associated with this traffic control
measure.

MM 3.7-2 – The City of Pasadena will be responsible for the costs associated with this traffic control
measure.

MM 3.7-3 – The City will be responsible for costs associated with coordination with Metro this costs, as
well as costs associated with increase transit as discussed in Response 3-1.

MM 3.7-4 – RBOC will be responsible for the costs associated with operating the changeable message
signs.

MM-3.7-5 - No additional costs associated with this measure.

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MM 3.7-6 – No additional costs associated with this measure.

The second part of the comment states the EIR “ignores real operation impacts by defining a ‘threshold of
significance’ that only considers physical impacts.” The Draft EIR analyzes physical impacts associated
with the project in accordance with CEQA, as correctly pointed out in the comment letter.

Response 34-2

The comment relates to the mitigation measures contained in the Draft EIR. Several measures have been
revised to clarify responsible party, please see Section 2.0 Corrections and Additions of the Final EIR.

Response 34-3

The comment relates to set up and tear down of temporary facilities. Based on information provided by
RBOC it is anticipated that some set up and tear down would occur on the day prior to an NFL event.
However, recreational uses would not be restricted until the day of the event. The comment suggests that
limitations to the use of Lot H be included in the contract with the NFL. Temporary structures would be
located immediately outside the stadium. It is not anticipated that they would be located in Lot H, as Lot
H will be used for parking on event days. Also refer to Response 7-8 related to temporary structures. The
comment will be included as part of the record and made available to the decision makers prior to a final
decision on the proposed project.

The comment also asks for further clarification on whether NFL events will be held on the same weekend
as UCLA events. Refer to Response 15-1

Response 34-4

The comment restates information contained in the Draft EIR related to public services. The Draft EIR is
prepared in accordance with the State CEQA Guidelines, which require a discussion of the project’s
impacts on the environment. Within the meaning of CEQA, a project will have an impact related to public
services when demand is increased such at new facilities will need to be constructed. The opinion of the
commenter will be included as part of the record and made available to the decision makers prior to a
final decision on the proposed project.

Response 34-5

Mitigation measure MM 3.6-1 states the RBOC would be responsible for the maintenance of the golf
course.

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Response 34-6

The commenter is referred to page 3.6-29 of the Draft EIR which states “In addition to the potential loss of
active and passive recreational uses described above, the increase in unavailability of Lot H, Brookside
Park (including Kidspace Children’s Museum), Brookside Golf Course, and the Rose bowl Aquatic
Center during major stadium events due to parking need would increase the number of days (an
additional 13) these facilities would be unavailable for use by the general public to 25 per year.”

The comment suggests several measures to be added to lease agreements with the NFL. However, as
discussed in Response 14-4, preparation for NFL games will begin up to 8 hours before game time and,
as a practical matter, the Arroyo will be unavailable for recreation use during the day even if an NFL
game is scheduled to begin in the evening.

Response 34-7

Impact 3.6-3 has been removed from the Draft EIR along with the discussion of the beneficial effect of the
impact.

Response 34-8

As proposed, MM 3.7-1, MM 3.7-2, AM 3.7-2.1, and MM 3.7-4 will mitigate the environmental impacts to
the extent feasible, without regard to who pays for the measure. The ultimate financial responsibility for
implementing the mitigation measures will be an item for negotiation between the City and the NFL.
Regardless, either the City or the RBOC will implement the mitigation measures if the cost is not
otherwise passed on to an NFL team.

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Letter No. 35

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Letter No. 35: Ron Hemingway


Ron Hemingway
August 21, 2012

Response 35-1
Refer to Response 8-11 and Response 14-24.

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Letter No. 36: Jenna Kachour


Jenna Kachour
Preservation Director
Pasadena Heritage
September 13, 2012

Response 36-1

Effects found not to be significant are addressed in Section 5.0, Other CEQA Considerations, of the Draft
EIR and in Appendix 1.0, which includes the Initial Study prepared for the proposed project. The
typographical error on page 1.0-26 noted in this comment has been corrected in the Final EIR. As stated
on page 1.0-5 of the Draft EIR, Appendix 1.0 also contains a list of comments received on the NOP and
the location where these comments are addressed in the Draft EIR. Please also refer to Topical
Response 2 regarding historic resources.

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Letter No. 37

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Letter No. 37: Guido Meindl


Guido Meindl
August 11, 2012

Response 37-1

The City acknowledges your input and comment. The comment will be included as part of the record and
made available to the decision makers prior to a final decision on the proposed project.

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Letter No. 38

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Letter No. 38: Gloria Morrison


Gloria Morrison
September 10, 2012

Response 38-1

The comment concerns the overall merits of the proposed project. The comment will be included as part
of the record and made available to the decision makers prior to a final decision on the proposed project.

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Letter No. 39

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Letter No. 39: Lorig Mushegain


Lorig Mushegain
1245 Church Street
September 13, 2012

Response 39-1

Impacts related to traffic during displacement events are discussed in Section 3.7, Transportation,
Circulation, and Parking, of the Draft EIR. As discussed in that section, the implementation of provided
mitigation measures would reduce the severity of impacts related to traffic during displacement events,
but those impacts would remain significant and unavoidable, as stated in this comment.

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Letter No. 40

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Letter No. 40: Arundhati Nag


Arundhati Nag
October 1, 2012

Response 40-1

The comment concerns the overall merits of the proposed project. The comment will be included as part
of the record and made available to the decision makers prior to a final decision on the proposed project.

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Letter No. 41

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Letter No. 41: Dianne K. Newman


Dianne K. Newman
Professor of Biology & Geobiology and
Investigator, Howard Hughes Medical Institute
California Institute of Technology
1200 E. California Blvd
Pasadena, CA 91125
August 15, 2012

Response 41-1

The comment concerns the overall merits of the proposed project. The comment will be included as part
of the record and made available to the decision makers prior to a final decision on the proposed project.

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Letter No. 42

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Letter No. 42: Dianne K. Newman


Dianne K. Newman
Professor of Biology & Geobiology and
Investigator, Howard Hughes Medical Institute
California Institute of Technology
1200 E. California Blvd
Pasadena, CA 91125
October 7, 2012

Response 42-1

Refer to Response 17-5 and Response 2-6 regarding localized air quality impacts.

Response 42-2

Refer to Response 11-19.

Response 42-3

Section 3.6 Recreation of the Draft EIR includes a discussion of the loss of the Rose Bowl as a recreational
use during displacement events. The Draft EIR found this to be a significant and unavoidable impact. The
comment will be included as part of the record and made available to the decision makers prior to a final
decision on the proposed project.

Response 42-4

The comment refers to Impact 3.6-3 of the Draft EIR; this impact has been removed from the Final EIR.

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Letter No. 43

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Letter No. 43: Dianne Newman


Dianne Newman
596 Rosemont
Statement to the Transportation Advisory Committee
September 27, 2012

Response 43-1

Refer to Response 17-5 and Response 2-6 regarding localized air quality impacts.

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Letter No. 44

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Letter No. 44: JoAnn Newman


JoAnn Newman
1220 Linda Ridge Road
Pasadena, CA
August 16, 2012

Response 44-1

The comment concerns the overall merits of the proposed project. The comment will be included as part
of the record and made available to the decision makers prior to a final decision on the proposed project.

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Letter No. 45

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Letter No. 45: Steve Onderdonk


Steve Onderdonk
707 Rockwood Road
Pasadena, CA 91105
September 10, 2012

Response 45-1

The comment concerns the overall merits of the proposed project. The comment will be included as part
of the record and made available to the decision makers prior to a final decision on the proposed project.

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Letter No. 46

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Letter No. 46: Susann Perry


Susann Perry
August 19, 2012

Responses 46-1

The comment concerns the overall merits of the proposed project. The comment will be included as part
of the record and made available to the decision makers prior to a final decision on the proposed project.

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Letter No. 47

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Letter No. 47 Jonas Peters


Jonas Peters
596 Rosemont Ave
Pasadena, CA 91103
August 15, 2012

Response 47-1

The comment raises issues that do not appear to relate to any physical effect on the environment. The
comment will be included as part of the record and made available to the decision makers prior to a final
decision on the proposed project.

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Letter No. 48

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Letter No. 48: Jonas Peters


Jonas Peters
California Institute of Technology
Division of Chemistry
Bren Professor of Chemistry
Warren and Katherine Schlinger Laboratory
For Chemistry and Chemical Engineering
October 8, 2012

Response 48-1

As stated in the Draft EIR, some air pollutant emissions will be significant and unavoidable during
displacement events. The comment will be included as part of the record and made available to the
decision makers prior to a final decision on the proposed project.

Response 48-2

This comment restates data from the Draft EIR and expresses an opinion concerning the overall merits of
the project. The comment will be forwarded to the City Council as part of the Final EIR.

Response 48-3

This comment restates data from the Draft EIR and expresses an opinion concerning the overall merits of
the project. The comments are noted and are hereby part of the Final EIR, and will be forwarded to the
decision makers for their consideration prior to taking any action on the project. As summarized under
Response 48-2, the measures described in the Draft EIR have the effect of reducing the level of traffic
impact but not to levels of insignificance.

Response 48-4

Please see Impact discussion 3.1-4 and Response 2-6 for a discussion of localized air quality impacts.
Noise impacts from vehicles on nearby residences are discussed in Impact 3.4.1.

Response 48-5

Behavior of NFL fans is not expected to be substantially different than behavior of college football fans.
Please see Response 8-40, Response 8-41, and Appendix F3.0 which contains a letter from CSC. The
concern of residents regarding drunk driving is acknowledged and the comment will be included as part
of the record and made available to the decision makers prior to a final decision on the proposed project.
However, college football games have not presented a significant public safety or public services
environmental impact and, as discussed in the EIR, NFL games are not expected to create a significant
public safety or public services environmental impact.

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Response 48-6

The Draft EIR addresses potentially significant environmental impacts. The comments regarding the
extraordinary inconvenience resulting from access/traffic/parking controls are noted and are hereby part
of the Final EIR, and will be forwarded to the decision makers for their consideration prior to taking any
action on the project.

Response 48-7

Refer to Response 8-12.

Response 48-8

The comment raises issues that do not appear to relate to any significant environmental impact. The
comment will be included as part of the record and made available to the decision makers prior to a final
decision on the proposed project. However, because the comment does not raise an environmental issue,
no further response is required.

Response 48-9

Areas where parking is prohibited around the Rose Bowl are understood. The project will have sufficient
parking supply at the Rose Bowl and Parsons campus to accommodate demand created by the project.
No significant impacts are anticipated from parking prohibitions in residential neighborhoods.

Response 48-10

Access to/from residential streets for residents and visitors is permitted on game days. The traffic analysis
in the Draft EIR accounts for the closure of specific streets and its effect on the circulation system.

Response 48-11

The traffic analysis in the Draft EIR accounts for the closure of specific streets, one-way travel and its
effect on the circulation system.

Response 48-12

The comment states the EIR does not study impacts to bus service in Pasadena and the potential impacts
on disadvantaged groups. Local bus service in Pasadena provided by multiple agencies (Metro,
Pasadena’s ARTS, La Canada Flintridge Transit and Foothill Transit), would continue to operate on
existing routes and according to planned schedules on event days. The only exception would be ARTS
Bus Routes 51/52 which run from downtown Pasadena to the Art Center College of Design North
Campus (Route 51) and Jet Propulsion Laboratory (JPL) (Route 52). Route 52 only operates during the
AM and PM peak hours on weekdays. Routes 51/52 provides service on Seco Street and are the only
routes that provide direct access to the project site. As discussed in the Traffic Study, the ARTS bus is

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subject to detour on large event days. Nonetheless, as discussed above, buses would continue to service
the City of Pasadena on event days.

Response 48-13

Refer to Response 8-15, Response 8-16, and Response 15-9 for discussion of displacement of recreational
users.

Response 48-14

The Draft EIR concludes that the project will have a significant and unavoidable impact in the area of
recreation due to the reduction in availability of the Central Arroyo to recreation uses. This impact is not
offset by attendance at a football game and a comparison of the demographic characteristics of those
attending football games and those recreating in the Central Arroyo would not change or further the
environmental impact analysis. The comment will be included as part of the record and made available to
the decision makers prior to a final decision on the proposed project.

Response 48-15

The Final EIR includes Mitigation Measure MM 3.6-1 which relates to the repair of Brookside Golf Course
and other grassy areas used for parking during events. The measure was developed in consultation with
RBOC, as RBOC will be responsible for the repairs. The City of Pasadena Department of Public Works
will provide oversight for this measure.

Response 48-16

Refer to Response 11-19 regarding chemical seepage from parked cars.

The primary source of air pollutants associated with the proposed project is passenger vehicles.
Passenger vehicles emit a variety of air pollutants, with the majority being criteria pollutants such as
NOx, ROG and CO. These pollutants are not known to pollute ground or surface water, even after rain
events. Passenger vehicles also emit small amounts of other pollutants that may be washed out of the
atmosphere during rain events and potentially infiltrate local water. However, in the context of regular
daily traffic outside of events at the Rose Bowl, the very limited number of displacement events allowed
under the proposed project, and the limited number of times rain would correspond with displacement
events this would not represent a meaningful source of contamination for ground or surface water. It is
unlikely that the total contribution to pollution levels in local water sources would even be detectable,
nor would it represent a cumulatively significant source, as the operation of the proposed project is
limited to 5 years, after which period there would be no contribution at all to local water pollution levels.

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Response 48-17

Refer to Response 8-22. Also, the quantity of small bits of food which might escape containers or clean up
on 13 additional days from August through January, and which is spread throughout the areas in which
tailgating is permitted, is not expected to be able to support a substantial increase in the pest population
or to otherwise translate into health impacts. There is no evidence that the pest population in the Arroyo
is currently constrained by lack of food resources. Small bits of food waste would also be expected from
picnics and organized sports activities that occur in the Arroyo in the absence of a displacement event.
Although impacts related to trash and debris would be less than significant, MM 2.0-1 has also been
included in the project. This measure would ensure trash does not remain on the site, thereby further
reducing the potential for a substantial increase in the pest population.

Response 48-18

The comment raises issues that do not appear to relate to any physical effect on the environment as
defined by the State CEQA Guidelines. The comment will be included as part of the record and made
available to the decision makers prior to a final decision on the proposed project.

Response 48-19

Please see Response 7-11 regarding proposed revisions to MM 3.6-2 in response to public comment on
the Draft EIR.

Response 48-20

Refer to Response 8-11, which relates to Brookside Golf Course and Response 8-12 regarding rainy day
parking.

Response 48-21

As indicated on page 3.6-30 of the Draft EIR, impacts resulting from the displacement of recreational
activities, including the Aquatic Center, during displacement events would be significant and
unavoidable, as stated in this comment.

Response 48-22

As discussed on pages 3.6-28 and 3.6-29 of the Draft EIR, many active recreational users, including AYSO
soccer, would be displaced on event days. The City’s Human Services and Recreation Department
maintains the ongoing calendar for use of all City of Pasadena recreation facilities and would be the
primary contact for scheduling such events. Many events could be scheduled for days when
displacement events are not occurring, or at different facilities. However, as indicated in the Draft EIR,
the displacement of these users on 13 occasions per year would be a significant and unavoidable impact.

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Response 48-23

Impact 3.6-3 has been removed from the Final EIR.

Response 48-24

Refer to Response 8-10 and Response 15-9 regarding the need for a baseline study of recreational users.

Response 48-25

Refer to Response 8-44 regarding NFL fan violence, as well as the letter provided by CSC and included in
Appendix F3.0.

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Letter No. 49: Jonas Peters


Jonas Peters
September 27, 2012

Response 49-1

See Response 48-3.

Response 49-2

See Response 48-3.

Response 49-3

Refer to Response 48-4.

Response 49-4

The comment raises issues that do not appear to relate to any physical effect on the environment. The
comment will be included as part of the record and made available to the decision makers prior to a final
decision on the proposed project.

Response 49-5

Refer to Response 48-12.

Response 49-6

Refer to Response 48-12.

Please refer to Response 15-1 regarding the cumulative impact of two games in one weekend.

Response 49-7

Refer to Response 48-14.

Response 49-8

Refer to Response 48-16.

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Letter No. 50

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Letter No. 50: Sylvia Plummer


Sylvia Plummer
1331 Court Terrace
Pasadena, CA 91105
October 8, 2012

Response 50-1

The comment concerns the overall merits of the proposed project. The comment will be included as part
of the record and made available to the decision makers prior to a final decision on the proposed project.

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Letter No. 51

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Letter No. 51 Ann Scheid


Ann Scheid
500 South Arroyo Boulevard
Pasadena, CA
Commissioner, Parks and Recreation Commission
October 2, 2012

Response 51-1

Refer to Response 12-8.

Response 51-2

Refer to Topical Response 2 regarding historic resources.

Response 51-3

Please see Response 2-6 regarding localized air quality impacts. No guidelines or procedures are
available for suitably analyzing air quality impacts on flora or fauna other than human beings. As stated
in Response 2-6, the project does not exceed localized significance thresholds for impacts on human
beings, and is therefore not expected to have an impact on flora of the Arroyo, as the flora and fauna are
generally less sensitive to air pollution than humans. Similarly, the project is not expected to significantly
impact local animal populations for the same reasons. Therefore, it is expected that emissions that would
not present a localized health issue for humans would similarly not present a localized health risk for
plants or animals that are successfully surviving in the urban environment of the area.

Response 51-4

Refer to Response 11-19.

Response 51-5

The comment relates to the displacement of recreational users in the Arroyo. Refer to Response 8-10 and
Response 8-15. Mitigation Measure MM 3.6-2 regarding maintaining access to the loop has been revised.
Please see Response 7-11.

Response 51-6

With respect to comment regarding the number of parking spaces available at the Central Arroyo, page
3.7-1 of the Draft EIR correctly refers to the available parking at 21,518 spaces in the Central Arroyo. The
reference page 2.0-16 is a typographic error and has been corrected to say “21,518.”

With respect to availability of parking at Parson’s site and in Old Pasadena, the comment is noted and is
hereby part of the Final EIR, and will be forwarded to the decision makers for their consideration prior to

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taking any action on the project. The study does not assume the use of commercial parking structures in
Old Pasadena as part of the game day parking supply. The parking supply at the Rose Bowl and Parsons
site will adequately address the demand for both a weekday and weekend game. See Response 6-17
regarding impacts of potential redevelopment of Parson’s site.

Response 51-7

See Response 2-6 regarding localized air quality impacts. Buses were included as part of this analysis.

Response 51-8

The proposed project’s consistency with applicable land use plans, including Arroyo Seco Master Plans,
is discussed on pages 3.3-14 through 3.3-17 of the Draft EIR.

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Letter No. 52

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Letter No. 52: Joy Selby


Joy Selby
Urban Resident
Pasadena
September 10, 2012

Response 52-1

The City acknowledges your input and comment. The comment will be included as part of the record and
made available to the decision makers prior to a final decision on the proposed project.

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Letter No. 53

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Letter No. 53: Leland Sklar and Maureen Gay McGillan-Sklar


Leland Sklar
Maureen Gay McGillian-Sklar
585 Rosemont Avenue
October 1, 2012

Response 53-1

This comment is an introduction to comments that follow. No further response is required.

Response 53-2

The comment relates to the uniqueness of the Arroyo. Refer to Response 8-16 and Response 15-9.

Response 53-4

Refer to Response 8-11 and Response 8-12 regarding impacts to Brookside Golf Course.

Response 53-5

Section 3.7 of the Draft EIR includes an extensive analysis of traffic impacts and concludes that traffic
impacts are significant and unavoidable.

Response 53-6

Please see Draft EIR page 3.5.2-7 and page 3.5.2-8 and Response 8-45 for a discussion of emergency
access.

Response 53-7

Refer to Response 12-8.

Response 53-8

See Response 8-40 and Response 8-41 related to public services impacts from tailgating.

Response 53-9

The comment concerns the overall merits of the proposed project. The comment will be included as part
of the record and made available to the decision makers prior to a final decision on the proposed project.

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Letter No. 54: Bob Snodgrass


Bob Snodgrass
September 20, 2012

Response 54-1

Please see Response 8-40 and Response 8-41 regarding tailgating, and Response 9-8 regarding behavior
of NFL fans.

Response 54-2

Refer to Response 15-1, Response 15-9, Response 15-10, and Response 15-11 which relate to impacts to
recreational users.

Response 54-3

Please refer to Response 17-8.

Response 54-4

The comment concerns the overall merits of the proposed project. The comment will be included as part
of the record and made available to the decision makers prior to a final decision on the proposed project.

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Letter No. 55

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Letter No. 55: Bob Snodgrass


Bob Snodgrass
Comments to the Transportation Advisory Committee
September 27, 2012

Response 55-1

Please see Response 17-5 and Response 2-6 regarding localized air quality impacts

Response 55-2

Refer to Response 15-9 regarding recreational users.

Response 55-3

Please refer to Response 17-8.

Response 55-4

Please refer to Response 15-18 with respect to comment about inclusion of Devil’s Gate reservoir
sediment removal project and the proposed mixed-use project at Parson’s site.

As shown in Table 10 of the Appendix 3.7 - Traffic Study, the Draft EIR did analyze potential
environmental impacts associated with the development of the Parsons site. This project was included as
part of background cumulative traffic for the proposed project. As shown in the table, approximately
1,454 trips were assumed as a result of this project during the weekday pre-event peak hour. Any
construction traffic as a result of this project would likely be lower than the number of trips estimated
once the Parsons project is complete and therefore no additional traffic analysis is needed.

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Letter No. 56

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Letter No. 56: Patrick Lauren Theofanis, Ph.D.


Patrick Lauren Theofanis, Ph.D.
October 1, 2012

Response 56-1

The comment concerns the overall merits of the proposed project. The comment will be included as part
of the record and made available to the decision makers prior to a final decision on the proposed project.

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Letter No. 57

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Letter No. 57: Andrea Totten


Andrea Totten
732 Rosemont Ave
Pasadena, CA 91103
September 27, 2012

Response 57-1

The comment restates information contained in the Draft EIR. The comment will be included as part of
the record and made available to the decision makers prior to a final decision on the proposed project.

Response 57-2

The comment provides factual background information only. The Draft EIR already concluded that traffic
impacts would be significant and unavoidable. The comment will be included as part of the record and
made available to the decision makers prior to a final decision on the proposed project.

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Letter No. 58

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Letter No. 58: Unknown


XX<67867@sbcglobal.net
August 15, 2012

Response 58-1

The comment concerns the overall merits of the proposed project. The comment will be included as part
of the record and made available to the decision makers prior to a final decision on the proposed project.

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Letter No. 59

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Letter No. 59: Susann Walker Perry


Susann Walker Perry
550 Woodland Road
Pasadena, CA 91106
September 10, 2012

Response 59-1

The comment concerns the overall merits of the proposed project. The comment will be included as part
of the record and made available to the decision makers prior to a final decision on the proposed project.

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Letter No. 60

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Letter No. 60: Michele Zuck


Michele Zuck
October 8, 2012

Response 60-1

The comment concerns the overall merits of the proposed project. The comment will be included as part
of the record and made available to the decision makers prior to a final decision on the proposed project.

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Letter No. 61: Christy Zamani


Christy Zamani
Executive Director
Day One, Inc.
175 N. Euclid Ave
Pasadena, CA 91191

Response 61-1

Refer to Response 8-16 and Response 15-9 related to recreational facilities outside of the Rose Bowl. As
stated on page 3.6-30 of the Draft EIR, impacts to existing recreational uses at the Rose Bowl would be
significant and unavoidable. Other recreational facilities in the area are listed as part of the Draft EIR’s
consideration of potential impacts to such facilities and are not presented as alternative sites for the types
of recreational activities that are available within the Central Arroyo.

Response 61-2

Refer to Response 7-11 and Response 8-15.

Response 61-3

Refer to Response 61-2 above. Please also see Response 7-11 regarding the proposed modification to
MM 3.6-2 relating to maintaining access to the loop during event days. As stated on page 3.6-30 of the
Draft EIR, impacts related to the disruption of recreational uses within the Central Arroyo would remain
significant and unavoidable, even with implementation of the mitigation measures provided in the Draft
EIR. The measures recommended in the comment will be forwarded to decision makers. None of these
measures would reduce the significant environmental impacts of displacement events, and therefore
implementation of these recommended measures is not required under CEQA.

Response 61-4

Behavior of NFL fans is not expected to be substantially different than behavior of college football fans.
Please see Response 8-41 and Appendix F3.0 which contains a letter from CSC. The concern of residents
regarding drunk driving is acknowledged and the comment will be included as part of the record and
made available to the decision makers prior to a final decision on the proposed project. However, college
football games have not presented a significant public safety or public services environmental impact
and, as discussed in the EIR, NFL games are not expected to create a significant public safety or public
services environmental impact.

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Response 61-5

See Response 61-4. The suggested measures are not necessary to mitigate a significant environmental
impact within the meaning of CEQA and therefore have not been recommended as mitigation measures
in the Final EIR. The comment will be included as part of the record and made available to the decision
makers prior to a final decision on the proposed project.

Response 61-6

See Response 61-4. The suggested measures are not necessary to mitigate a significant environmental
impact within the meaning of CEQA and therefore have not been recommended as mitigation measures
in the Final EIR. The comment will be included as part of the record and made available to the decision
makers prior to a final decision on the proposed project.

Response 61-7

This concluding statement summarizes the comments responded to above. No further response is
required.

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Letter No. 62

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Letter No. 62: Barbara Zimmermann


Response 62-1

The comment raises issues that do not appear to relate to any physical effect on the environment. The
comment will be included as part of the record and made available to the decision makers prior to a final
decision on the proposed project.

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Letter No. 63

From: Madhu Kumar [mailto:madhukumar@earthlink.net]

Sent: Tuesday, April 17, 2012 12:33 PM

To: Sinclair, David; Madison, Steve; Suzuki, Takako; Beck, Michael

Subject: Re: Draft Environmental Impact Report (EIR) on Temporary Use of the Rose Bowl Stadium

Dear Mr. Sinclair: Thank you for the opportunity to comment on the EIR concerning temporary use of
the Rose Bowl Stadium for an NFL team in transition or similar uses.

We believe it is essential that the EIR also fully address the issue of stadium lights and video boards and
their glare at night on residents living in the hillside above the Rose Bowl. Our experience in the past
year has been that the stadium lights and the video boards were operated the entire night for several
nights in a row, and that the video boards were actually operated nonstop in some instances for a week
or more, day and night. Needless to say, the extraordinary amount of light was a serious nuisance and
had serious impact on the surrounding areas. We want to ensure that no testing or other preparation by
the NFL or other users is done overnight. As such, there should be Conditions in the EIR that restrain 1
such nighttime activities. All stadium lights and video boards should be turned off by 11 p.m. at the
latest, or within two hours following the end of an event if an event for any reason goes beyond 11 at
night (which hopefully will never be the case given the other impacts on the surrounding areas). And if
for any reason stadium lights need to be on for security or cleanup, the EIR should be explicit as to when
that might happen, what testing has been done regarding the levels of light reaching the hillside and
other areas, what limitations will be imposed, and what mitigation steps will be required. Madhu
Kumar, Michael Roster, other residents in the hillside.

Madhu Kumar
1341 Fairlawn Way
Pasadena 91105
Madhukumar@earthlink.net

Michael Roster
1321 Fairlawn Way | Pasadena, CA 91105 | (626) 449-9797
mroster@earthlink.net or mroster@stanfordalumni.org

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3.0 Responses to Comments

Letter No. 63: Madhu Kumar


1341 Fairlawn Way
Pasadena 91105
Madhukumar@earthlink.net

Response 63-1

The comment relates to the use of nighttime lighting for the NFL. Please refer to Response 8-2 and
Response 33-7. Additionally, as discussed in Response 14-14 and in the letter provided by CSC included
in Appendix F3.0, the majority of the games would occur at 1:00 PM on Sunday and would conclude by
5:00 PM, therefore, the need for nighttime lighting would be minimal.

Impact Sciences, Inc. 3.0-366 Temporary Use of the Rose Bowl by the NFL
1136.001 November 2012
Letter No. 64

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A

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B

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C

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            

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Impact Sciences, Inc. 3.0-585 Temporary use of the Rose Bowl by the NFL
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Y

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3.0 Responses to Comments

Letter No. 64: No NFL at Rose Bowl Petition


Response 64-1

The letter includes a petition that concerns the overall merits of the proposed project. The comment will
be included as part of the record and made available to the decision makers prior to a final decision on
the proposed project.

Response 64-1A

Refer to Response 15-9 regarding recreational users

Response 64-1B

The Draft EIR determined the proposed project would have a significant and unavoidable effect on
recreational facilities and traffic.

Response 64-1C

Refer to Response 8-38 regarding NFL fan behavior and the letter provided by CSC and included in
Appendix F3.0. Also refer to Response 8-22 regarding trash.

Response 64-1D

Refer to Response 8-38 regarding NFL fan behavior and the letter provided by CSC and included in
Appendix F3.0.

Response 64-1E

Refer to Response 8-22 regarding trash, as well as Topical Response 2 related to historic resources.

Response 64-1F

Refer to Response 2-6 regarding health effects. Refer to Response 7-11 regarding closure of the Rose Bowl
on event days.

Response 64-1G

Refer to the Draft EIR Section 3.7 Transportation, Circulation and Parking for a discussion of traffic and
parking impacts.

Response 64-1H

Refer to Draft EIR Section 3.4 Noise for a discussion of noise impacts.

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3.0 Responses to Comments

Response 64-1I

Refer to Section 3.7 Transportation, Circulation and Parking of the Draft EIR for a discussion of traffic
impacts. Refer to Response 8-38 regarding NFL fan behavior and the letter provided by CSC and
included in Appendix F3.0.

Response 64-1J

Refer to Section 3.7 Transportation, Circulation and Parking of the Draft EIR for a discussion of traffic
impacts. The Draft EIR determined impacts related to the displacement of recreational users would be
significant and unavoidable.

Response 64-1K

The comment expresses an opinion. The Draft EIR determined traffic, noise, and air quality impacts
would be significant and unavoidable.

Response 64-1L

The Draft EIR analyzed impacts associated with displacement of recreational users on event days and
found this impact to be significant and unavoidable.

Response 64-1M

The comment addresses general subject areas, which received extensive analysis in the Draft EIR. The
comment does not raise any specific issue regarding that analysis and, therefore, no more specific
response can be provided or is required. However, the comment will be included as part of the record
and made available to the decision makers prior to a final decision on the proposed project.

Response 64-1N

Refer to Response 8-22 regarding trash and refer to Section 3.7 Transportation, Circulation and Parking of
the Draft EIR which includes a determination that traffic related impacts would be significant and
unavoidable.

Response 64-1O

Refer to Section 3.7 Transportation, Circulation and Parking of the Draft EIR which includes a
determination that traffic related impacts would be significant and unavoidable. Refer to Response 8-38
regarding fan behavior and the letter provided by CSC included in Appendix F3.0.

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3.0 Responses to Comments

Response 64-1P

Refer to Response 8-22 regarding trash. Refer to Section 3.4 Noise of the Draft EIR which determined that
noise impacts would be significant and unavoidable. Also refer to Response 2-2 regarding pollution and
Section 3.1 Air Quality of the Draft EIR.

Response 64-1Q

Refer to Topical Response 2 regarding historic resources.

Response 64-1R

Refer to Response 2-2 regarding pollution and Section 3.1 Air Quality of the Draft EIR. Refer to Section
3.7 Transportation, Circulation and Parking of the Draft EIR which found traffic related impacts to be
significant and unavoidable.

Response 64-1S

Refer to Section 3.6 Recreation of the Draft EIR which found displacement of recreational users would be
a significant and unavoidable impact. Also refer to Section 3.7 Transportation, Circulation and Parking of
the Draft EIR which found traffic impacts would be significant and unavoidable.

Response 64-1T

Refer to Section 3.1 Air Quality of the Draft EIR which found the project would have significant and
unavoidable impact related to air quality. Refer to Section 3.7 Transportation, Circulation and Parking of
the Draft EIR which found the project would have significant and unavoidable impacts related to traffic.
Also refer to Section 3.6 Recreation of the Draft EIR which found the proposed project would result in a
significant impact related to the displacement of recreational users.

Response 64-1U

Refer to Response 2-2 and Section 3.1 Air Quality of the Draft EIR. Also refer to Section 3.6 Recreation of
the Draft EIR which found the project would result in a significant and unavoidable impact due to the
displacement of recreational users. Also refer to Section 3.7 Transportation, Circulation, and Parking of
the Draft EIR which found the project would result in significant and unavoidable traffic impacts.

Response 64-1V

The comment expresses an opinion about the project. Refer to Section 3.7 Transportation, Circulation and
Parking of the Draft EIR which determined the proposed project would result in significant and
unavoidable traffic impacts.

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3.0 Responses to Comments

Response 64-1W

Refer to Section 3.6 of the Draft EIR which determined impacts related to displacement of recreational
users would be significant and unavoidable. Also refer to Section 3.7 Transportation, Circulation and
Parking of the Draft EIR which determined significant and unavoidable traffic impacts would occur as a
result of the proposed project.

Response 64-1X

Refer to Section 3.7 Transportation, Circulation and Parking of the Draft EIR which determined that the
project would result in significant and unavoidable traffic impacts.

Response 64-1Y

Refer to Section 3.7 Transportation, Circulation and Parking of the Draft EIR which determined that the
project would result in significant and unavoidable traffic impacts. Refer to Section 3.1 Air Quality of the
Draft EIR which determined the project would result in significant air quality impacts. Also refer to
Response 2-2 regarding localized impacts. Refer to Response 8-23 which relates to fan behavior, as well
as the letter provided by CSC and included in Appendix F3.0.

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1136.001
Impact Sciences, Inc.
3.0-592
                               
              
                           
     
Letter No. 65

November 2012
Temporary use of the Rose Bowl by the NFL
    
   

  

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3.0 Responses to Comments

Letter No. 65: Petition


Response 65-1

The letter includes a petition that concerns the overall merits of the proposed project. The comment will
be included as part of the record and made available to the decision makers prior to a final decision on
the proposed project.

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Letter No. 66

From: Cruz, Ruben <RCRUZ@dpw.lacounty.gov>


Sent: Thursday, October 25, 2012 5:09 PM
To: RoseBowlNFLComments
Cc: Ibrahim, Amir; Yanez, Jarrett; Enriquez, Renee; Dubiel, Matthew; Wong, Isaac; Pletyak,
Jeff
Subject: RE: Rose Bowl Stadium- City of Pasadena- DEIR- Due to LDD: 09/10/12

Thank you for the opportunity to review the Draft Environmental Impact Report for Temporary Use of
the Rose Bowl Stadium by the National Football League project. The project is to allow an additional
13 annual displacement events at the Rose Bowl Stadium for a period of up to 5 years. The project
area is located at 1001 Rose Bowl Drive within the jurisdiction of Pasadena.

The following are County of Los Angeles, Department of Public Works comments are for your
consideration and relate to the environmental document only:

Services-Traffic/Access

1. We generally agree with the Draft Environmental Impact Report’s proposed measure for controlling
departure traffic after an event at the intersection of North Arroyo Boulevard at I-210 Freeway 1
Westbound Ramps by placing the intersection in flash mode and manually controlling signal
operations with a traffic control officer.

2. We also suggest the City of Pasadena contact us regarding the development of coordinated traffic
signal operations and traveler information systems which could be implemented and monitored via
the traffic management centers operated by each agency. We believe the implementation of pre-
determined traffic response plans for event management may potentially eliminate the need for
manual control using a traffic control officer. 2
If you have any questions regarding the traffic/access comments, please contact Isaac Wong at (626)
300-4796 or iswong@dpw.lacounty.gov.

If you have any other questions or require additional information, please contact Ruben Cruz at
(626) 458-4921 or rcruz@dpw.lacounty.gov.

Ruben Cruz, P.E.


County of Los Angeles,
Department of Public Works
Land Development Division
Subdivision Management Section
rcruz@dpw.lacounty.gov
(626) 458-4910

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3.0 Responses to Comments

Letter No. 66: Los Angeles County of Public Works


Ruben Cruz, P.E.
County of Los Angeles,
Department of Public Works
Land Development Division
Subdivision Management Section
rcruz@dpw.lacounty.gov

Response 66-1

The comments are noted and are hereby part of the Final EIR. To facilitate event day traffic flow, City of
Pasadena’s traffic management center (TMC)’s staff will coordinate with Los Angeles County’s Depart of
Public Works’ Traffic Division regarding traffic signal operations and special event traffic response plan.

Response 66-2

Refer to Response 65-1.

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4.0 MITIGATION MONITORING AND REPORTING PROGRAM

PURPOSE

The Mitigation Monitoring Program (MMP) has been prepared in conformance with Section 21081.6 of
the California Environmental Quality Act. It is the intent of this program to (1) verify satisfaction of the
required mitigation measures of the EIR; (2) provide a methodology to document implementation of the
required mitigation; (3) provide a record of the Monitoring Program; (4) identify monitoring
responsibility; (5) establish administrative procedures for the clearance of mitigation measures;
(6) establish the frequency and duration of monitoring; and (7) utilize existing review processes wherever
feasible.

INTRODUCTION

The Mitigation Monitoring Program describes the procedures that will be used to implement the
mitigation measures adopted in connection with the approval of the project and the methods of
monitoring such actions. A Monitoring Program is necessary only for impacts which would be significant
if not mitigated. The following consists of a monitoring program table noting the responsible entity for
mitigation monitoring, the timing, and a list of all project-related mitigation measures.

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4.0 Mitigation Monitoring and Reporting Program

Table 4.0-1
Mitigation Monitoring and Reporting Program Matrix

Mitigation
Mitigation Responsible Measure
Mitigation Measure Monitoring Timing Monitoring Entity Complete? Effectiveness
Impact – None
MM 2.0-1 RBOC shall be responsible for removal of all trash and debris Within 24 hours of an Department of Public
associated with NFL events. Clean up shall commence within 24 hours of an NFL event Works
NFL event and shall including all areas where patrons are directed to park
within the Central Arroyo. Clean up shall be conducted to the satisfaction of
the Department of Public Works. The RBOC shall provide funding as
necessary.
MM 2.0-2 After each NFL event at the Rose Bowl, RBOC shall be responsible Within 24 hours of an Department of Public
for visually inspecting parked areas for signs of oil, fluids, or other potentially NFL event Works
harmful substances within 24 hours of an NFL event. In the event such
substances are discovered, the soil shall be removed and disposed of in
accordance with applicable regulations. RBOC shall provide the City of
Pasadena Department of Public Works with a written summary of the visual
inspection and any necessary soil removal.
Impact – Air Quality
MM 3.1-1 Any RFP for vendors to serve NFL events shall specify that the Ongoing Department of
vendor must utilize 2010 or later diesel trucks or alternatively fueled delivery Finance
trucks or demonstrate practices that will provide equivalent reduction of air
emissions compared to a typical vendor who does not use such equipment.
MM 3.1-2 Any maintenance vehicles or forklift purchased to serve NFL events Ongoing Department of Public
at the Rose Bowl shall be electric or use alternative fuel, provided that electric Works
or alternative fuel equipment is available.
MM 3.1-3 Prior to the hosting of an NFL game at the Rose Bowl, the RBOC Prior to first NFL event Department of Public
shall provide electrical outlets to the extent feasible in Lot I to allow for electric Works
barbecues to be used by those who choose to tailgate and use portable electric
barbecues.
MM 3.1-4 The RBOC shall ensure that cleaning products used to clean the Rose Ongoing Department of Public
Bowl and surrounding areas after NFL games are water based or low VOC Works
cleaning products

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4.0 Mitigation Monitoring and Reporting Program

Mitigation
Mitigation Responsible Measure
Mitigation Measure Monitoring Timing Monitoring Entity Complete? Effectiveness
Impact - Recreation
MM 3.6-1 The RBOC shall ensure for the timely repair (repair shall commence Within 24 hours of an Department of Public
within 24 Hours) of damaged Brookside Golf Course turf areas, and any other NFL event Works
grassy areas (such as Lot H), that are damaged as a result of parking during
NFL events. The RBOC shall ensure that all turf areas are returned to useable
conditions within one-day of an NFL event. Prior to the commencement of the
use of the Rose Bowl by the NFL, the RBOC shall approve a plan for
maintenance of damaged turf areas. The plan shall be developed in
coordination with the City and Brookside Golf Course Management and shall
include a timetable detailing estimated time of repair and methodology for the
repair of the turf areas. RBOC shall be responsible for the costs of all repairs.
MM 3.6-2 In accordance with the provisions of the Santa Monica Mountains During an NFL event Department of Public
Conservancy trail agreement dated January 10, 1985 (SMMC Grant), the RBOC Works
shall ensure access as required by the agreement.
MM 3.6-3 RBOC shall notify residents and neighborhood associations of Ongoing Office of the City
upcoming NFL games. A schedule of games shall be provided to nearby Manager
residents, neighborhood associations and interested parties prior to the start of
each NFL season.
MM 3.6-4 The City and the NFL shall ensure, through provisions in the lease Prior to execution of Office of the City
agreement, that the Tournament of Roses and Rose Bowl game activities will lease Manager
be accommodated in a manner consistent with the traditional operating
circumstances, needs, and locations of Tournament activities.
MM 3.6-5 Prior to any NFL use of the Rose Bowl, the City shall develop a plan Prior to any NFL use of Department of Public
for monitoring park use during event days and develop a strategy for the Rose Bowl Works/Department of
repairing or improving parks and recreational areas as necessary to address Human Services
potential increased usage on event days. The City shall be responsible for
funding those repairs and/or improvements.
Impact - Traffic
MM 3.7-1 The following 22 significantly impacted intersections are projected
to operate at LOS C or better during both arrival (prior to event) and departure
(post-event) under both the weekday or/and weekend Existing With Project
and Future With Project scenarios:
Intersection 1: San Rafael Avenue & SR-134 Freeway EB Ramps
Intersection 4: West Drive and Seco Street
Intersection 5: Rosemont Avenue and Washington Boulevard
Intersection 11: I-210 Freeway EB Ramps & Howard Street
Intersection 12: Lincoln Avenue & I-210 Freeway WB Ramps
Intersection 19: I-210 Freeway WB Ramps & Berkshire Place

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Mitigation
Mitigation Responsible Measure
Mitigation Measure Monitoring Timing Monitoring Entity Complete? Effectiveness
Intersection 20: Linda Vista Avenue & Highland Drive
Intersection 21: Linda Vista Avenue & Oak Grove Drive
Intersection 23: North Arroyo Boulevard/Windson Avenue & Woodbury Road
Intersection 24: Arroyo Boulevard & Lower Arroyo Park Entrance
Intersection 25: Arroyo Boulevard & California Boulevard
Intersection 30: St. John Avenue & Colorado Boulevard
Intersection 31: Pasadena Avenue & Union Street
Intersection 32: Pasadena Avenue & Colorado Boulevard
Intersection 39: Lincoln Avenue & Woodbury Road
Intersection 40: Fair Oaks Avenue & Woodbury Road
Intersection 41: Lincoln Avenue & Washington Boulevard
Intersection 45: St. John Avenue/I-210 Eastbound Off-Ramp & Walnut Street
Intersection 46: Pasadena Avenue/I-210 Westbound On-Ramp & Walnut Street
Intersection 50: Arroyo Parkway & Union Street
Intersection 61: St. John Avenue & Del Mar Boulevard
Intersection 62: Pasadena Avenue & Del Mar Boulevard
Proposed Project Feature: Out of the aforementioned 22 intersections, the
following 11 intersections will either be supplemented with a traffic control
officer (TCO) to prioritize event traffic flow through the intersection or will
operate under an optimized traffic signal timing plan to prioritize peak event
traffic flow:
Traffic Control Office Post*
Intersection 1: San Rafael Avenue & SR-134 Freeway EB Ramps
Intersection 4: West Drive and Seco Street
Intersection 5: Rosemont Avenue and Washington Boulevard
Intersection 24: Arroyo Boulevard & Lower Arroyo Park Entrance
Intersection 25: Arroyo Boulevard & California Boulevard
Intersection 41: Lincoln Avenue & Washington Boulevard
Traffic Signal Optimization
Intersection 31: Pasadena Avenue & Union Street
Intersection 32: Pasadena Avenue & Colorado Boulevard
Intersection 41: Lincoln Avenue & Washington Boulevard
Intersection 45: St. John Avenue/I-210 Eastbound Off-Ramp & Walnut Street
Intersection 46: Pasadena Avenue/I-210 Westbound On-Ramp & Walnut Street

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4.0 Mitigation Monitoring and Reporting Program

Mitigation
Mitigation Responsible Measure
Mitigation Measure Monitoring Timing Monitoring Entity Complete? Effectiveness
*Appendix A of the traffic study includes details of changes in lane
configuration at some of the intersection where a TCO is deployed during
arrival or/and departure of event traffic.
Mitigation Measures for intersections operating at LOS D, E, and F
The following 38 significantly impacted intersections are projected to operate
at LOS D, E or F during either/both arrival (prior to event) and departure
(post-event) under the weekday or/and weekend Existing With Project and
Future With Project scenarios:
Intersection 2: San Rafael Avenue & SR-134 Freeway WB Ramps
Intersection 3: West Drive and Salvia Canyon Road
Intersection 6: Rosemont Avenue and Seco Street
Intersection 7: Orange Grove Boulevard & Holly Street/I-210 Freeway WB Off-
Ramp and EB On-Ramp
Intersection 8: Orange Grove Boulevard & SR-134 Freeway EB Off-Ramp and
WB On-Ramp/Colorado Boulevard
Intersection 9: North Arroyo Boulevard & I-210 Freeway WB Ramps
Intersection 10: North Arroyo Boulevard & I-210 Freeway EB Ramps
Intersection 13: I-210 Freeway EB Ramps & Mountain Street
Intersection 14: I-210 Freeway WB Ramps & Mountain Street
Intersection 18: I-210 Freeway EB Ramps & Berkshire Place
Intersection 26: Orange Grove Boulevard & California Boulevard
Intersection 27: Arroyo Parkway & California Boulevard
Intersection 28: Pasadena Avenue & California Boulevard
Intersection 29: St. John Avenue & California Boulevard
Intersection 34: Fair Oaks Avenue & Walnut Street
Intersection 35: Fair Oaks Avenue & Union Street
Intersection 36: Pasadena Avenue & Colorado Boulevard
Intersection 37: Fair Oaks Avenue & Green Street
Intersection 38: Arroyo Parkway & Colorado Boulevard
Intersection 43: Lincoln Avenue & Mountain Street/Seco Street
Intersection 44: Fair Oaks Avenue & Mountain Street
Intersection 47: Fair Oaks Avenue & Orange Grove Boulevard
Intersection 48: Fair Oaks Avenue & Maple Street/I-210 Westbound Ramps/SR
134 Westbound Ramps

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Mitigation
Mitigation Responsible Measure
Mitigation Measure Monitoring Timing Monitoring Entity Complete? Effectiveness
Intersection 49: Fair Oaks Avenue & Corson Street/SR 134 Eastbound Ramps
Intersection 51: Linda Vista Avenue & Holly Street
Intersection 52: Arroyo Parkway & Del Mar Boulevard
Intersection 53: Fair Oaks Avenue & California Boulevard
Intersection 54: Fair Oaks Avenue & Glenarm Street
Intersection 55: Arroyo Parkway & Glenarm Street
Intersection 56: Fair Oaks Avenue & I-110 Southbound On-Ramp/State Street
Intersection 57: Fair Oaks Avenue & I-110 Northbound Off-Ramp/Grevalia
Street
Intersection 58: Orange Grove Avenue & I-110 Southbound Ramps
Intersection 59: Orange Grove Avenue & I-110 Northbound Ramps
Intersection 60: Orange Grove Avenue & Del Mar Boulevard
Intersection 63: Fair Oaks Avenue & Del Mar Boulevard
Intersection 64: Orange Grove Avenue & Columbia Street
Intersection 65: Pasadena Avenue/Fremont Avenue & Columbia
Intersection 66: Fair Oaks Avenue & Columbia Street
Proposed Project Feature: As part of the proposed project traffic operations
plan, out of the aforementioned 38 intersections, the following 23 intersections
will either be deployed with a TCO to prioritize event traffic flow through the
intersection or will operate under an optimized traffic signal timing plan to
prioritize peak event traffic flow:
Traffic Control Office Post*
Intersection 2: San Rafael Avenue & SR-134 Freeway WB Ramps
Intersection 3: West Drive and Salvia Canyon Road
Intersection 6: Rosemont Avenue and Seco Street
Intersection 7: Orange Grove Boulevard & Holly Street/I-210 Freeway WB Off-
Ramp and EB On-Ramp
Intersection 8: Orange Grove Boulevard & SR-134 Freeway EB Off-Ramp and
WB On-Ramp/Colorado Boulevard
Intersection 9: North Arroyo Boulevard & I-210 Freeway WB Ramps
Intersection 10: North Arroyo Boulevard & I-210 Freeway EB Ramps
Intersection 26: Orange Grove Boulevard & California Boulevard
Intersection 43: Lincoln Avenue & Mountain Street/Seco Street
Intersection 51: Linda Vista Avenue & Holly Street

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4.0 Mitigation Monitoring and Reporting Program

Mitigation
Mitigation Responsible Measure
Mitigation Measure Monitoring Timing Monitoring Entity Complete? Effectiveness
Intersection 53: Fair Oaks Avenue &California Boulevard
Intersection 54: Fair Oaks Avenue & Glenarm Street
Intersection 60: Orange Grove Avenue & Del Mar Boulevard
Intersection 63: Fair Oaks Avenue & Del Mar Boulevard
Intersection 64: Orange Grove Avenue & Columbia Street
Traffic Signal Optimization
Intersection 34: Fair Oaks Avenue & Walnut Street
Intersection 35: Fair Oaks Avenue & Union Street
Intersection 36: Pasadena Avenue & Colorado Boulevard
Intersection 37: Fair Oaks Avenue & Green Street
Intersection 44: Fair Oaks Avenue & Mountain Street
Intersection 47: Fair Oaks Avenue & Orange Grove Boulevard
Intersection 48: Fair Oaks Avenue & Maple Street/I-210 Westbound Ramps/SR
134 Westbound Ramps
Intersection 49: Fair Oaks Avenue & Corson Street/SR 134 Eastbound Ramps
*Appendix A of the traffic study includes details of changes in lane
configuration at some of the intersection where a TCO is deployed during
arrival or/and departure of event traffic.
In addition, it is recommended that traffic management strategies, including a
program of operational improvements be employed as mitigation to help
manage demand and improve traffic operations over and above the changes
currently proposed as part of project’s traffic operations plan.
The operational improvements include priority or additional roadway
capacity for certain traffic movements to or from the Rose Bowl during arrival
or departure of event traffic. To quantitatively account for the benefit of
proposed mitigations, additional capacity has been applied to the prioritized
movements in the V/C and LOS analysis under the “with mitigations”
scenarios. Reduced capacities have been applied to non-prioritized
movements, reflecting the priority that would be transferred to other
movements
MM 3.7-2 Unless on-the-ground conditions (e.g., traffic accidents or other
unanticipated traffic events) require the Pasadena Police Department to
deviate from these specific mitigation measures and implement alternative
traffic control measures, the traffic operations plan shall include, and the City
shall implement, the following intersection-specific mitigation measures:
Intersection #8 Orange Grove Boulevard and SR-134 Freeway EB Off-Ramp
and WB On-Ramp/Colorado Boulevard – As an additional improvement over

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Mitigation
Mitigation Responsible Measure
Mitigation Measure Monitoring Timing Monitoring Entity Complete? Effectiveness
and above the aforementioned traffic operations plan, the westbound right
turns from Colorado Boulevard would be allowed to operate as free-flow with
the provision of an additional receiving lane on northbound Orange Grove
Boulevard using traffic cones.
Intersection #9 North Arroyo Boulevard and I-210 Freeway WB Ramps –
During the peak hour for departure traffic after a game, this intersection’s
signal would be placed in flash mode and manually controlled by a TCO to
prioritize the northbound traffic from Rosemont Avenue onto the I-210 freeway
westbound on-ramp. This intersection would be operated using way-finding
signage and traffic cones to allow left turns from both the northbound left-turn
lane and adjacent through lane.
Intersection #10 North Arroyo Boulevard and I-210 Freeway EB Ramps – As
an additional improvement over and above the aforementioned traffic
operations plan, the northbound approach at this location would operate as two
through lanes and an exclusive right-turn lane using traffic cones
Intersection 13# I-210 Freeway EB Ramps and Mountain Street – During the
peak hour for arrival traffic before a game, this intersection would be manually
controlled by a TCO to prioritize westbound traffic on Mountain Street.
During the peak hour for departure traffic after a game, this intersection would
be operated to allow three lanes of eastbound traffic with one free flow right-
turn lane onto the I-210 westbound on-ramp, one shared through/right-turn
lane and one through lane using traffic cones. During egress, pedestrian
movement at the intersection impacts the flow of vehicles. A TCO is
recommended to control pedestrian movement and facilitate the flow of
vehicular traffic.
Intersection #14 I-210 Freeway WB Ramps and Mountain Street – During the
peak hour for arrival traffic before a game and departure traffic after a game,
this intersection would be manually controlled by a TCO to improve traffic flow
and coordinate with operations at adjacent intersection #13 – I-210 Freeway
Eastbound Ramps and Mountain Avenue.
Intersection #34 Fair Oaks Avenue & Walnut Street – In addition to the traffic
signal optimization by the City of Pasadena Traffic Management Center (TMC)
as part of the proposed Project traffic operations plan, eastbound left turns off
the freeway would be allowed from both the left-turn lane and the adjacent
through lane using way-finding signage and traffic cones.
Intersection #49 Fair Oaks Avenue & Corson Street/SR 134 Eastbound Ramps
– The northbound right-turn lane would operate as a free-flow right-turn lane
onto the Corson Street using traffic cones. The eastbound approach would
operate as one left-turn lane, one shared through/left-turn lane, and two right-
turn lanes.

Impact Sciences, Inc. 4.0-8 Temporary Use of the Rose Bowl by the NFL
1136.01 November 2012
4.0 Mitigation Monitoring and Reporting Program

Mitigation
Mitigation Responsible Measure
Mitigation Measure Monitoring Timing Monitoring Entity Complete? Effectiveness
Intersection #53 Fair Oaks Avenue & California Boulevard – This
intersection’s signal would be manually controlled by a TCO to provide
additional green time to northbound traffic during the peak hour for arrival
traffic before a game and southbound traffic during the peak hour for departure
traffic after a game.
Intersection #54 Fair Oaks Avenue & Glenarm Street – This intersection’s
signal would be manually controlled by a TCO to provide additional green time
to northbound traffic during the peak hour for arrival traffic before a game and
southbound traffic during the peak hour for departure traffic after a game.
Intersection #56 Fair Oaks Avenue & I-110 Southbound On-Ramp/State Street
– This intersection’s signal would be manually controlled by a TCO to provide
additional green time to northbound traffic during the peak hour for arrival
traffic before a game and southbound traffic during the peak hour for departure
traffic after a game.
Intersection #57 Fair Oaks Avenue & I-110 Northbound Off-Ramp/Grevalia
Street – During the peak hour for arrival traffic before a game, this intersection's
signal would be placed in flash mode and manually controlled by a TCO. The
northbound off-ramp would operate as one left-turn lane and one shared
left/through/right-turn lane onto Fair Oaks Avenue. No mitigation measure has
been identified for the departure peak hour after a game.
In addition to the operational improvements recommended in Mitigation
Measure 3.7-2, a transportation demand management program might further
reduce impacts to a small and not quantifiable extent by encouraging the use of
transportation other than automobiles, encouraging ride sharing, and
increasing the efficiency by which vehicles could be moved off of streets and
into the Rose Bowl parking lots. Therefore, a transportation demand
management program is recommended as Additional Measure 3.7-2.1.
However, as the success of this program is neither guaranteed nor quantifiable,
no credit for reducing impacts has been calculated as a result of this
recommended measure and it is not considered to be mitigation. Additionally,
some flexibility has been provided to coordinate measures with the future team
that would play football at the Rose Bowl and to be able to adjust programs
based on whether any individual incentive or implementation measure is
proving successful.
AM 3.7-2.1 The RBOC, in conjunction with the tenant, shall implement a
transportation demand management program that shall incorporate the
following elements to promote ride sharing, alternative forms of
transportation, and to maximize the efficiency of vehicle travel.
Incentivize Carpooling
Develop and implement incentives for carpools of four or more persons per

Impact Sciences, Inc. 4.0-9 Temporary Use of the Rose Bowl by the NFL
1136.01 November 2012
4.0 Mitigation Monitoring and Reporting Program

Mitigation
Mitigation Responsible Measure
Mitigation Measure Monitoring Timing Monitoring Entity Complete? Effectiveness
car, and incentives for alternative fuel vehicles. Incentives may include,
without limitation, preferential parking, reduced parking costs, or other
discounts.
Pre-paid Parking Program
Provide pre-paid parking options. The use of pre-paid parking passes could
increase the throughput for vehicles at the Rose Bowl parking entrances by
eliminating the need to collect parking fees at critical access points to the
stadium from those vehicles with pre-paid parking, thus improving traffic
operations.
Bicycle Valet at Parsons
Provide a bicycle valet parking service at the Parson’s parking lot. Spectators
may valet park their bicycles and ride on the shuttle bus to/from the Rose
Bowl. This would incentivize the use of bicycles as a mode of travel to/from
the event and help reduce the number of vehicular trips.
Charter Bus
Solicit interest in charter bus service from season ticket holders, groups and
other potential users and provide charter bus service from locations such as
downtown and neighboring cities in response to demand. The service will
include the concept of “park-and-ride,” which will encourage event patrons to
leave their vehicles and transfer on to a charter bus for the remainder of the
journey. Rose Bowl will encourage charter bus service by providing drop off
for passengers in preferred areas close to the stadium.
Rideshare Program for Employees
The RBOC will implement a Rideshare program for employees.
Temporary Changeable Message Signs
The use of temporary changeable message signs is already employed at
different locations around the Rose Bowl. Expand the use of temporary
changeable message signs to include two changeable message signs along the
I-210 or/and SR-134, depending on traffic demands, to help facilitate
ingress/egress on game days.
Way Finding Signage for Transit Patron
The City of Pasadena and RBOC will work together with Metro to install way-
finding signage to guide patrons to/from the Gold Line Memorial Park Station
and the shuttle bus pick-up/drop-off location.
Use of Social Media
Use social media to communicate current information regarding directions
to/from the Rose Bowl from regional freeways and roadways, preferred routes
to various parking lots, and detailed information regarding potential modes of

Impact Sciences, Inc. 4.0-10 Temporary Use of the Rose Bowl by the NFL
1136.01 November 2012
4.0 Mitigation Monitoring and Reporting Program

Mitigation
Mitigation Responsible Measure
Mitigation Measure Monitoring Timing Monitoring Entity Complete? Effectiveness
travel other than passenger vehicles to/from the Rose Bowl (rail/bus/shuttle
routes, timetables, etc.).
MM 3.7-3 To mitigate the potential impact to the regional transit system, it is
recommended that Metro increase transit service to meet the demand of both
commuter peak hour transit ridership, as well as the demand generated from
the project. Since this mitigation measure is the responsibility of another
jurisdiction, it is recommended that the City of Pasadena provide information
to Metro in order to determine the level of transit service that is adequate to
meet game day demands
MM 3.7-4 The Traffic Command Center shall coordinate with PDOT and
Caltrans to place two changeable message signs along the I210 or/and SR-134
to help facilitate ingress/egress on game days. However, given the volume of
traffic that would utilize the freeways, there is no feasible operational
mitigation measure that could fully mitigate the project’s potential for impacts.
MM 3.7-5 Parking operators shall monitor parking demand on game days to
ensure sufficient supply is available to meet parking demand around the Rose
Bowl. If excess parking demand is anticipated, stacked parking will be
implemented as needed in one or more of the following parking lots to ensure
that there is sufficient supply to meet demand:
Lot H, Lot BD 2 & 3, Lot 1 A, Lot 1, Lot 2, Lot 3, Lot 4, Lot 5, Lot 6, Lot 7, Lot
8A, Lot 9, Lot 10
The use of stacked parking at these lots can increase parking supply by up to
approximately 3,000 spaces.
MM 3.7-6 Parking and traffic management staff for the Rose Bowl will
implement all traffic and parking control plans for NFL game days, as are
implemented for other events at the Rose Bowl to monitor and direct traffic to
minimize spillover parking and other disruptions to residential neighborhoods
adjacent to the Rose Bowl.

Impact Sciences, Inc. 4.0-11 Temporary Use of the Rose Bowl by the NFL
1136.01 November 2012
APPENDIX F3.0
Final EIR Supplemental Documentation
Contemporary Services Corporation Letter
Cultural Resources Consultation

1
To: David Sinclair, Planner
City of Pasadena, Planning Department
Date: October 26,2012

Please find our revised version of the topical response regarding historic resources below.
We believe it now addresses the majority of issues that were raised.

TOPICAL RESPONSE
The DEIR addresses the temporary use of the Rose Bowl Stadium by the National Football
League (NFL), which requires an amendment of the Arroyo Seco Public Lands Ordinance
to allow an additional thirteen annual displacement events at the Rose Bowl Stadium for a
period of up to five years.

The Initial Study that was prepared prior to the DEIR found the additional events to have
No Cultural Resources Impact on the Rose Bowl Stadium or the surrounding area,
including the Pasadena Arroyo Parks and Recreation District and adjacent residential
neighborhoods that have been designated as historic districts. The Rose Bowl Stadium and
its environs include a number of historic resources recognized at the national, state, and
local levels. The Rose Bowl Stadium itself is a National Historic Landmark and a
contributing structure to the Pasadena Arroyo Parks and Recreation District, which is listed
in the National Register of Historic Places. The Pasadena Arroyo Parks and Recreation
District is roughly bounded by the Foothill Freeway on the north, the city limits to the
south, Arroyo Boulevard to the east and San Rafael Ave on the west. It contains twenty-
seven contributing buildings, structures, sites, and landscape features, including the
Brookside Golf Club, Brookside Park, the Brookside Theater, Jackie Robinson Memorial
Field and Stadium, the Fannie Morrison Horticultural Center, the Holly Street Bridge, the
Colorado Street Bridge, the Mayberry and Parker Bridge, Lower Arroyo Seco Park and the
Lower Arroyo Bird Sanctuary.

There are also three residential neighborhoods within the project vicinity that have been
listed in the National Register of Historic Places as historic districts: Prospect Park located
east of Brookside Park, Arroyo Terrace located south of Brookside Park, and the Lower

Rose Bowl Temporary NFL Project DEIR


Cultural Resources Consultation
HISTORIC RESOURCES GROUP
12 S. Fair Oaks Avenue, Suite 200, Pasadena, CA 91105-1915
Telephone 626 793 2400, Facsimile 626 793 2401
historicla.com

Arroyo Seco located south of the 134 Freeway. Resources listed in the National Register 2
of Historic Places are also listed in the California Register of Historical Resources. All of the
resources mentioned above qualify as historic resources under CEQA.

CEQA states that a project would normally have a significant impact on historic resources
if it would result in a substantial adverse change in the significance of a historic resource.
According to CEQA Guidelines, a substantial adverse change in the significance of a
historic resource means demolition, destruction, relocation, or alteration of the resource or
its immediate surroundings such that the significance of a historical resource would be
1
materially impaired. The Guidelines go on to state that “[t]he significance of an historic
resource is materially impaired when a project… [d]emolishes or materially alters in an
adverse manner those physical characteristics of an historical resource that convey its
historical significance and that justify its inclusion in, or eligibility for, inclusion in the
California Register of Historical Resources… local register of historic resources… or its
2
identification in a historic resources survey.”

The temporary NFL project will not cause a substantial adverse change that would
threaten the eligibility for historic designation of the Rose Bowl Stadium, the Pasadena
Arroyo Parks and Recreation District, or the three adjacent residential historic districts,
based on the following analysis:

1. Would the Project involve the demolition of a significant resource?

The proposed temporary use of the Rose Bowl by the NFL for a period up to five
years would not involve any demolition either on the Rose Bowl site or within its
vicinity. Therefore, the proposed project will not demolish any historically
significant resources, either on the Rose Bowl site or within its vicinity.

2. Would the Project involve relocation that does not maintain the integrity of a
significant resource?

The proposed temporary use of the Rose Bowl by the NFL for a period up to five
years would not relocate any historically significant resources, either on the Rose
Bowl site or within its vicinity.


1
2
CEQA Guidelines, section 15064.5(b) (1).
CEQA Guidelines, section 15064.5(b) (2).

Rose Bowl Temporary NFL Project DEIR


Cultural Resources Consultation
HISTORIC RESOURCES GROUP
12 S. Fair Oaks Avenue, Suite 200, Pasadena, CA 91105-1915
Telephone 626 793 2400, Facsimile 626 793 2401
historicla.com

3. Would the Project involve conversion, rehabilitation or alteration of a significant 3
resource which does not conform to the Secretary of the Interior’s Standards for
Rehabilitation and Guidelines for Rehabilitating Historic Buildings?

The proposed temporary use of the Rose Bowl by the NFL for a period up to five
years would not convert, rehabilitate or alter any historically significant resources,
either on the Rose Bowl site or within its vicinity. The Rose Bowl stadium and its
related ancillary buildings are currently being rehabilitated according to the
Secretary of the Interior Standards, and no additional rehabilitation or alteration is
proposed to accommodate the proposed temporary use by the NFL.

The Rose Bowl was constructed specifically to accommodate football games. The
general wear and tear that results from the regular use of a resource is not
considered a substantial adverse change under CEQA. The materials that could be
impacted by football games are primarily reinforced concrete, arroyo stone
retaining walls, stucco, and asphaltic concrete. These materials always have and
will continue to be repaired and maintained as needed. An increase in the number
of football games each year for a temporary period will not materially impact any
of the significant character-defining features of the stadium.

Golf Courses 1 and 2 at Brookside Golf Club are currently used to accommodate
parking for large events, including college football games and large-scale
entertainment events. Although use of the golf courses as parking can damage
fairways and landscaping, there are systems and procedures in place for
maintaining and repairing the landscaping after such events that would remain in
place for any NFL use. Moreover, the actual tees, bunkers, fairways and
landscaping of the golf courses have been altered and changed numerous times
3
during the Golf Club’s history, and are not considered character-defining.

4. Would the Project involve construction that reduces the integrity or significance of
important resources on the site or in the vicinity?

The proposed temporary use of the Rose Bowl by the NFL for a period up to five
years would not include any new construction. Therefore, the proposed project


3
Pasadena Arroyo Parks and Recreation District National Register of Historic Places Registration Form, prepared by Teresa
Grimes for Pasadena Heritage, July 13, 2007. (7)

Rose Bowl Temporary NFL Project DEIR


Cultural Resources Consultation
HISTORIC RESOURCES GROUP
12 S. Fair Oaks Avenue, Suite 200, Pasadena, CA 91105-1915
Telephone 626 793 2400, Facsimile 626 793 2401
historicla.com

would not involve any construction that reduces the integrity or significance of any 4
historically significant resources, either on the Rose Bowl site or within its vicinity.

In conclusion, temporary use of the Rose Bowl by the NFL will increase the number of
times the Rose Bowl is used as a football stadium per year. The proposed temporary use
would result in a maximum of sixty-five additional events over the life of the stadium. The
project will not introduce a new use for the Rose Bowl but will instead temporarily
expand the number of times it is used for its historic purpose. The Rose Bowl is a
reinforced concrete structure specifically designed and constructed as a football stadium. It
has successfully hosted football games and capacity crowds since 1922. Moreover, the
Rose Bowl is currently undergoing rehabilitation according to the Secretary of the Interior’s
Standards. There is no evidence to suggest that use of the Rose Bowl for thirteen
additional football games annually for a period of up to five years will cause any undue
stress that might damage character-defining features such that the Rose Bowl would no
longer be eligible for historic designation.

Use of the Rose Bowl by the NFL will not involve the demolition, relocation, conversion,
rehabilitation or alteration of any historically significant resource. Nor will it involve any
construction that reduces the integrity or significance of any historic resources. Therefore,
the proposed project will not result in significant impacts to historic resources.

Rose Bowl Temporary NFL Project DEIR


Cultural Resources Consultation
HISTORIC RESOURCES GROUP
12 S. Fair Oaks Avenue, Suite 200, Pasadena, CA 91105-1915
Telephone 626 793 2400, Facsimile 626 793 2401
historicla.com
Peyton Hall, FAIA, Managing Principal and Director of Architecture, has
practiced architecture, planning and historic preservation since 1974.
He has a Bachelor of Architecture degree from the University of Virginia
and a Master of Environmental Design degree from Yale University.
Academic honors include the Parsons Medal in City Planning at Yale.
Post-graduate studies include a certificate from the Center for Palladian
Studies in Vicenza, Italy, and a fellowship from the National Endowment
for the Arts for study at the National Cultural Properties Institute in
Tokyo, Japan.

Mr. Hall has experience as an instructor in the University of Southern


California's Summer and Certificate Programs in Historic Preservation,
and has presented papers at the annual meetings of the Association for
Preservation Technology International and the Western Association for
Art Conservation. His historic preservation projects have received
recognition from the National Trust for Historic Preservation, the
California Preservation Foundation, the Cultural Heritage Commission
of the City of Los Angeles, and the Los Angeles Conservancy. Mr. Hall is a
former President of the California Preservation Foundation and former
Chair of the Board of Directors of Pasadena Heritage.

Mr. Hall meets the Secretary of the Interior’s Professional Qualifications


in historic architecture and consults with architects, developers and
construction managers during all phases of building projects, from
predevelopment to conceptual drawings, design documents and through
construction as needed. Completed and active projects include six
structures in Old Pasadena, CA; twelve buildings in El Pueblo de Los
Angeles Historic Monument; the Los Angeles Memorial Coliseum;
Angels Flight Funicular Railway; the Rose Bowl; the Annenberg
Community Beach House at 415 PCH, Santa Monica; the Gamble House;
the Shrine Auditorium; the Egyptian Theatre in Hollywood, CA; the
Orpheum Theatre in Wichita, Kansas; Fox Studio in Century City; Hotel
Casa del Mar in Santa Monica; the Town House Apartments, Los
Angeles; and Grauman's Chinese Theatre, Hollywood.

HISTORIC RESOURCES GROUP


12 S. Fair Oaks Avenue, Suite 200, Pasadena, CA 91105-1915
Telephone 626 793 2400, Facsimile 626 793 2401
www.historicla.com
PEYTON HALL, FAIA SELECTED HONORS AND PROFESSIONAL AFFILIATIONS

WORK EXPERIENCE 2011 Recipient of the Robert F. Winter


Award from the Blinn House Foundation,
HISTORIC RESOURCES GROUP Pasadena, California

1995-Present AMERICAN INSTITUTE OF ARCHITECTS:


Managing Principal
Member of Advisory Group to the Historic
Clients and projects include Grauman’s Resources Committee (national level), 2010-
Chinese Theatre, the Gamble House present
Conservation Project, the Hollywood
Palladium, the Annenberg Community NATIONAL TRUST FOR HISTORIC
Beach House, the Egyptian Theatre, the Rose PRESERVATION
Bowl, the Freeman House, Playa Vista, Doris National Honor Award: American
Duke’s Shangri-La Historic Structure Report, Cinematheque at the Egyptian Theatre,
Cabrillo Beach Bath House, Kidspace 2000
Museum, Fox Studio, and the Harada House
in Riverside. CALIFORNIA PRESERVATION
FOUNDATION
UNIVERSITY OF SOUTHERN Trustee, 1998-2004; President, 2002-2004
CALIFORNIA, SCHOOL OF
ARCHITECTURE Preservationist of the Year, 2007.

1998-Present Recent Preservation Design Awards include:


Adjunct Professor
Ennis House Stabilization & Restoration Los
EDUCATION Angeles, CA 2008

Master of Environmental Design, The Gamble House Conservation Project


Yale University School of Architecture, Pasadena, California 2005
New Haven, CT1980
LOS ANGELES CONSERVANCY
Bachelor of Architecture, University of
Virginia, Charlottesville, VA 1974 Recent Preservation awarded projects
include:
Certificate “Andrea Palladio”, Centro di
Storia Dell-Architettura, Vicenza, Italy, Annenberg Community Beach House, Santa
1972 Monica, CA, 2009

National Endowment for the Arts The Palladium


Fellowship, Tokyo National Cultural Hollywood, CA 2009
Properties Institute, Tokyo, Japan
1978-1979
LICENSE
California Licensed Architect #12867, 1982

HISTORIC RESOURCES GROUP


12 S. Fair Oaks Avenue, Suite 200, Pasadena, CA 91105-1915
Telephone 626 793 2400, Facsimile 626 793 2401
www.historicla.com
Loop Improvement Survey Memo
NAHC Correspondence
From: Dave Singleton [mailto:ds_nahc@pacbell.net]
Sent: Wednesday, October 17, 2012 11:34 AM
To: Reyes, David
Subject: Re: Rose Bowl EIR

October 17, 2012

Dear Mr. Reyes:

This is to confirm our (California Native American Heritage Commission)


recommendation that a Sacred Lands File search is not necessary for
the proposed Rose Bowl Project as there is no 'ground-breaking' proposed.

Best regards,

Dave Singleton
California Native American Heritage Commission
915 Capitol Mall, Room 364
Sacramento, CA 95814
(916) 653-6251

On Oct 17, 2012, at 11:13 AM, Reyes, David wrote:

Good Morning David,


As we discussed this morning, there is no groundbreaking and no new construction associated with this project. As such,
as you advised, there should be no need for NAHC to perform a Sacred Lands File search for this project.

Can you please confirm. Thank you,


David

David Reyes
Principal Planner/Zoning Administrator
City of Pasadena - Planning Department
175 N. Garfield Ave. (Hale Building)
Pasadena, CA 91101-1704
Tel. 626.744.7171 Fax. 626.396.7626
SMMC Grant Agreement

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