• Embed Doc
  • Copy Link
  • Readcast
  • Collections
  • CommentGo Back
Download
 
Los Angeles Unified School District
Office of Environmental Health and Safety
333 South Beaudry Avenue, 20
th
Floor, Los Angeles, CA 90017
•
Telephone (213) 241-3199
•
Fax (213) 241-6816
The Office of Environmental Health and Safety is dedicated to providing a safe and healthy environment  for the 900,000 students and 80,000 employees of the Los Angeles Unified School District.
October 26, 2009Roderick Diaz, Project ManagerLACMTAOne Gateway PlazaLos Angeles, CA 90012-2952
diazroderick@metro.net  
Re: Crenshaw Transit Corridor Project DEIS/DEIR: S
 tate Clearinghouse Number 2007091148
Dear Mr. Diaz,The Crenshaw Corridor, a heavily traveled north-south-oriented urban corridor in Los Angeles County,California, is being considered for transit improvements by the Los Angeles County MetropolitanTransportation Authority (LACMTA) in cooperation with the Federal Transit Administration (FTA). TheLACMTA has initiated an environmental review of proposed transit improvements in the corridor as akey step in providing the Metro Board and the general public with information that will support selectionof a Locally Preferred Alternative (LPA). Issues raised by the Los Angeles Unified School District’s(District) review of the Draft Environmental Impact Statement (DEIS) / Draft Environmental ImpactReport (DEIR) are related to the deficient analysis of issues related to the health and safety of schooloccupants at schools located in close proximity to the proposed transit corridor. Table 1
 LAUSD Schools Along the Crenshaw Corridor 
lists schools along both the proposed Bus Rapid Transit (BRT) and LightRail Transit (LRT) alignments. The main difference between the BRT and LRT alignments is that theBRT will extend north from Exposition Boulevard to Wilshire Boulevard, while the LRT ends atExposition Boulevard. The extension of the LRT from Exposition Boulevard to Wilshire Boulevard willoccur as a future project by the LACMTA.Our evaluation is based upon the technical adequacy of the environmental documentation andconsideration of the project’s potential to: 1) compromise the health and safety of students, and staff, and2) disrupt the learning environment during construction and subsequent operation. As such, identifiedimpacts that may potentially affect our schools are related to the following areas of concern:• Pedestrian Safety• Noise and Vibration• Derailment• Air QualityConcerns related to the close proximity of the schools to the proposed alignments are as follows:
•
 
 Pedestrian Safety
. The proposed identified alignments cross existing and proposed routes toschools. Mitigation must be provided to eliminate all pedestrian conflicts.
•
 
 Noise and Vibration
. To ensure a quality learning environment, interior and exterior noise levelsmust maintain acoustical standards not exceeding American National Standards Institute (ANSIS12.60-2002) values of 35 dBa (
interior noise levels
) and 67 dBa (
exterior 
). Also, ground-bornevibration levels must not exceed ANSI and Federal Transit Administration standards.
RAMON C. CORTINES
Superintendent of Schools
JAMES MORRIS
 Chief Operating Officer 
 YI HWA KIM
 Deputy Environmental Health& Safety Director 
 
Crenshaw Corridor DEIS/DEIR –2- October 26, 2009
333 South Beaudry Avenue, 20
th
Floor, Los Angeles, CA 90017
•
Telephone (213) 241-3199
•
Fax (213) 241-6816
The Office of Environmental Health and Safety is dedicated to providing a safe and healthy environment  for the 900,000 students and 80,000 employees of the Los Angeles Unified School District.
•
 
Train Derailment
. Mitigation must be thoroughly analyzed and provide measures to ensure thathazards related to train derailment are totally eliminated. No discussion related to derailment ispresented in the DEIR.
•
 
 Air Quality
. Impacts associated with near-field pollutant emissions associated with construction-related activities were not addressed. Although LACMTA is cognizant of SCAQMD’s LocalizedSignificance Threshold (LST) Methodology, no analysis was conducted in this regard.Notwithstanding, the applicant reports that construction-related air quality impacts would be“temporary” and with implementation of mitigation measures “no substantial adverseconstruction effects are anticipated.” This finding is without merit as LACMTA fails todocument their claim of insignificance or quantify the effectiveness of identified mitigationmeasures.Due to MTA’s failure to prepare the appropriate analysis, the District contends that construction-related activities will generate excessive emissions and impact the health of students and staff attending and/or working in our local schools. As such, the District requests LACMTA completean LST analysis and provide all relevant and appropriate documentation used to assess project-related impacts.In general, the DEIS/DEIR does not analyze the above concerns in sufficient detail and provides onlybroad and generalized statements related to schools located in proximity of the proposed alignments.Since schools are occupied by sensitive receptors, CEQA requires specific mitigation requirements relatedto school-based occupancies.The District’s Office of Environmental Health & Safety serves to protect the health and safety of students,and staff, and to minimize any disruptions of the learning environment. We therefore request dueconsideration be given to our local schools and appropriate detail be provided in a subsequent analysis.As such, the District believes recirculation of the DEIS/DEIR is warranted. This will allow MTAsufficient time to complete the appropriate studies and allow our office time to review their technicaladequacy.Respectfully,Glenn Striegler – PGEnvironmental Assessment CoordinatorLAUSD Office of Environmental Health & SafetyAttachmentc: Yi Hwa Kim, Deputy Environmental Health & Safety Director OEHSPat Schanen, Environmental Health Manager OEHSEdward Morelan, Site Assessment Manager OEHSBill Piazza, Site Assessment Coordinator OEHSJay Golida, LAUSD Legal Council OGC
of 00

Leave a Comment

You must be to leave a comment.
Submit
Characters: ...
You must be to leave a comment.
Submit
Characters: ...