Letter No Impact Sciences, Inc Temporary use of the Rose Bowl by the NFL November 2012

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17 3.0 Responses to Comments 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 and Response 2-6 for a discussion of localized air quality impacts. Noise impacts from vehicles on nearby residences are discussed in Impact 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 Temporary Use of the Rose Bowl by the NFL

18 3.0 Responses to Comments 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 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 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 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 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 Temporary Use of the Rose Bowl by the NFL

19 3.0 Responses to Comments subject to detour on large event days. Nonetheless, as discussed above, buses would continue to service the City of Pasadena on event days. Response Refer to Response 8-15, Response 8-16, and Response 15-9 for discussion of displacement of recreational users. Response 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 The Final EIR includes Mitigation Measure MM 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 Refer to Response 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 Temporary Use of the Rose Bowl by the NFL

20 3.0 Responses to Comments Response Refer to Response 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 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 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 Please see Response 7-11 regarding proposed revisions to MM in response to public comment on the Draft EIR. Response Refer to Response 8-11, which relates to Brookside Golf Course and Response 8-12 regarding rainy day parking. Response As indicated on page 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 As discussed on pages and 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 Temporary Use of the Rose Bowl by the NFL

21 3.0 Responses to Comments Response Impact has been removed from the Final EIR. Response Refer to Response 8-10 and Response 15-9 regarding the need for a baseline study of recreational users. Response Refer to Response 8-44 regarding NFL fan violence, as well as the letter provided by CSC and included in Appendix F Temporary Use of the Rose Bowl by the NFL