Appendix a Comment Letters Appendix A1 Comment Letters on the Draft EIR COMMENT LETTER NO
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Appendix A Comment Letters Appendix A1 Comment Letters on the Draft EIR COMMENT LETTER NO. 100 Los Angeles Unified School District Office of Environmental Health and Safety JOHN E. DEASY, Ph.D. Superintendent of Schools ENRIQUE G. BOULL’T Chief Operating Officer JOHN STERRITT Director, Environmental Health and Safety April 14, 2014 My La Department of City Planning City of Los Angeles 200 N. Spring Street Room 667, MS 395 Los Angeles, CA 90012. Sent via Electronic Mail SUBJECT: LAUSD COMMENTS ON THE DRAFT ENVIRONMENTAL IMPACT REPORT (Draft EIR) CITY OF LOS ANGELES MOBILITY PLAN 2035 Presented below are comments submitted on behalf of the Los Angeles Unified School District (LAUSD), Office of Environmental Health and Safety (OEHS), regarding the Draft Environmental Impact Report (Draft EIR) for the City’s Mobility Plan 2035 (Mobility Plan). Overall, LAUSD is supportive of the Mobility Plan, which aligns in goals and potential environmental, health and safety benefits with many LAUSD programs and policies. We would encourage an ongoing dialogue and cooperation between the City of Los Angeles and LAUSD to accomplish these goals and realize the potential benefits. Of particular relevance to LAUSD schools within the City are the issues related to pedestrian safety and mobility as it pertains to so-called “vulnerable users”, which should include students. In summary, LAUSD requests that proximity and utility to school-based populations be a key consideration as the City prioritizes projects to be implemented, especially those designed to achieve the following goals: 100-1 x Improve safety and increase overall walk-ability through targeted enhancements at 50 locations annually. x Increase the miles of roadways, paths and sidewalks that are repaired every five years. x Increase the number of curb cuts and other features that accommodate disabled and other vulnerable users. Thank you for the opportunity to comment on this important project. If you need additional information please contact Pat Schanen at (213)241-3921or the undersigned at (213)241-1517. Sincerely, John R. Anderson Senior CEQA Advisor 333 South Beaudry Avenue, 28th Floor, Los Angeles, CA 90017 x Telephone (213) 241-3199 x Fax (213) 241-6816 The Office of Environmental Health and Safety is dedicated to providing a safe and healthy environment for the students and employees of the Los Angeles Unified School District. COMMENT LETTER NO. 101 STATE OF CALIFORNIA EDMUND G. BROWN JR., Governor PUBLIC UTILITIES COMMISSION 320 WEST 4TH STREET, SUITE 500 LOS ANGELES, CA 90013 March 26, 2014 My La City of Los Angeles 200 North Spring Street, Room 667 Los Angeles, California 90012 Dear My: Re: SCH 2013041012 Los Angeles Mobility Plan 2035 – DEIR The California Public Utilities Commission (Commission) has jurisdiction over the safety of highway-rail crossings (crossings) in California. The California Public Utilities Code requires Commission approval for the construction or alteration of crossings and grants the Commission exclusive power on the design, alteration, and closure of crossings. The Commission’s Rail Crossings Engineering Section (RCES) is in receipt of the draft Environmental Impact Report (DEIR) from the State Clearinghouse for the proposed City of Los Angeles (City) Mobility Plan 2035 project. The DEIR will address all modes of circulation on the City’s street network, including pedestrian-, transit-, bicycle-, and vehicle-enhanced networks. Many of these transportation networks would cross over rail tracks. Any modification to the existing public crossings requires authorization from the Commission through the General Order (GO) 88-B process. RCES representatives are available for consultation on any potential safety impacts or concerns on the nearby crossings. More information can be found at: http://www.cpuc.ca.gov/PUC/safety/Rail/Crossings/go88b.htm. In addition, the opening of any new rail crossing will require a formal application to be submitted to the Commission for approval and construction. More information can be found on the 101-1 Commission’s web site: http://www.cpuc.ca.gov/PUC/safety/Rail/Crossings/formalapps.htm. The City should arrange a meeting with RCES to discuss relevant safety issues and requirements for authority to construct a new crossing and/or modify the existing crossings. If you have any questions, please contact me at [email protected], or 213-576-7076. Sincerely, (Yen) Ken Chiang, P.E. Utilities Engineer Rail Crossings Engineering Section Safety and Enforcement Division CC: State Clearinghouse COMMENT LETTER NO. 102 COMMENT LETTER NO. 103 103-1 COMMENT LETTER NO. 104 104-1 104-2 104-3 104-3 cont. 104-4 104-5 COMMENT LETTER NO. 105 105-1 105-2 105-3 105-4 105-5 105-6 105-7 105-8 105-9 105-10 Comment #2 Westwood South of Santa Monica Blvd Homeowner’s Association Incorporated November 8, 1971 P. O. Box 64213 Los Angeles, CA 90064-0213 May 13, 2014 My La Los Angeles Department of City Planning 200 N. Spring Street, Room 667 Los Angeles, CA 90012 Via email: [email protected] RE: City of Los Angeles Mobility Plan 2035 (MP 2035), ENV-2013-0911-EIR Dear Ms. La: Westwood South of Santa Monica Blvd. Homeowners Association (WSSM) represents approximately 3,800 single family and condominium households in the West Los Angeles Community Plan area. Our area includes a number of key arterials in the city including Pico, Olympic, Santa Monica, Beverly Glen and Sepulveda Blvds. We also have a number of narrow residential streets that carry large volumes of traffic including Overland and Veteran Avenues. As our area is located between a number of major Los Angeles destinations including UCLA, Westwood Village, Century City and the 10/Santa Monica and 405/San Diego Freeways, we are painfully aware of mobility-related issues. The Westwood Blvd. station of the soon-to- be-operational EXPO Line is predicted to be the busiest station on the entire light rail line with over 5,000 daily boardings. The need to get those riders from the station to Century City, Westwood, UCLA and other schools and employment locations will require a significant increase in the numbers of buses (and shuttles) utilizing Westwood Blvd. Pedestrian traffic will also markedly increase. We do not see where the DEIR has addressed the expected increase in bus traffic and other traffic generated by transit riders accessing EXPO. It is unfortunate that this document is being written before the opening of EXPO Phase 2 so that we do not have actual experience and knowledge of how it is working as we write this document. We are very concerned about the safety of those in our community and in the larger region and City as density and congestion increase. Cumulative impacts from EXPO and the recently approved Casden project at Sepulveda and Exposition Blvds. should be included in DEIR analysis. Additional construction planned in Century City will also contribute to EXPO-bound drivers and riders. We do not see that the DEIR document has evaluated any of these impacts. If project impacts go undefined then it is impossible to identify and evaluate mitigations. That void is a major flaw to the bike plan proposal in our area. The plan has not examined the potential for cut-through traffic on parallel and surrounding neighborhood streets. It therefore did not identify a set of traffic calming/diversionary measures (with requisite funding) that our neighborhood could implement when off the “enhanced” street and onto surrounding streets. Further, as the City has dismantled the NTMP program and its staff, there currently does not exist the staffing or structure needed to develop and/or implement neighborhood traffic management programs. Mitigations are sought to improve safety – for pedestrians, drivers and riders. Even now, when developer funds are available to mitigate existing cut-through traffic it is nearly IMPOSSIBLE to accomplish something so simple as to install a speed table. This is a gap in the DOT/Planning structure that must be addressed. Without a structure for implementation, all mitigations are merely hollow words. While it is entirely laudable to make improvements for bicycles, and it should be a part of our City’s Complete Streets Initiative, in our opinion it is unrealistic to remove much-needed traffic lanes on busy arterials to accommodate a small population of bike riders, especially when the installation of those lanes will have serious negative impacts on the local business community and on the quality of life (and safety) in the nearby neighborhood. Even if ridership were to increase to levels seen in Portland, Oregon, the resulting negative impacts to traffic and neighborhoods would be an unreasonable burden to bear (or to inflict). We support the installation of bike facilities that are safe and that provide good linkages to transit and help to meet the first and last mile trip gaps. However, we do not support or accept the reduction of any traffic or parking lanes on Westwood Blvd. for bike facilities. We have grave concerns related to the Bicycle Enhanced Network and specifically as it relates to the bike lanes proposed for Westwood Blvd. The language in the DEIR that addresses Bicycle Network Enhancements is lofty and undocumented. To state that “Operation of these proposed enhancements would not disrupt existing uses and would be considered compatible with surrounding residential, commercial, industrial, recreational and institutional uses” is incredibly broad and impossible to demonstrate. Each location must be evaluated for impacts such as delay time at traffic signals. The length of the delays to be experienced can then be evaluated for potential for cut-through traffic. WSSM hired Art Kassen, a Registered Traffic Engineer/Registered Civil Engineer, to evaluate the proposal for bike lanes on Westwood Blvd. His letter documenting his review of the City’s proposal is attached to this letter and is to be included in our correspondence for the DEIR record.