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STATE OF CALIFORNIA
 
Arnold Schwarzenegger,
 
Governor 
 
PUBLIC UTILITIES COMMISSION
320 WEST 4TH STREET, SUITE 500LOS ANGELES, CA 90013(213) 576-7083
October 28, 2009Roderick Diaz, Project ManagerLos Angeles County MetropolitanTransportation AuthorityOne Gateway Plaza 201Los Angeles, CA 90012Re: Draft Environmental Impact Report for Crenshaw Transit Corridor ProjectDear Mr. Diaz:Thank you for providing us with a copy of your Draft Environmental Impact Statement/Report (DEIS/R) forthe Crenshaw Transit Corridor Project. Although the California Public utilities Commission (CPUC orCommission) has been interacting with the Los Angeles County Metropolitan Transportation Authority(LACMTA) regarding the project, the CPUC has not specifically provided written comments on this projectprior to this date and we appreciate the opportunity to provide the following comments:The project is subject to a number of rules and regulations involving the CPUC. These may include:Sections 1201 et al, and 99152 of Sate of California Public Utilities Code, which requires Commissionauthority to construct rail lines over existing streets. The design criteria of the proposed project must complywith CPUC General Orders (GOs), such as, GO 72-B rules governing the construction and maintenance of crossings at grade of railroads with public streets, roads and highways; GO 75-D regulations governingstandards for warning devices for at-grade highway-rail crossings; GO 143-B Safety Rules and Regulationsgoverning Light-Rail Transit; and GO 164-D regulations governing State Safety Oversight of Rail FixedGuideway Systems.As part of its mission to reduce hazards associated with at-grade crossings, the Commission’s policyis to reduce the number of new at-grade crossings on rail corridors. While we understand the cost of grade separating an at-grade crossing makes for a perceived detriment to your project, the CPUCnormally does not take cost into its consideration of the practicability of grade separating a crossing.We encourage LACMTA to evaluate grade separation of any proposed at-grade crossings.In acquiring Commission approval for construction of at-grade rail crossings, LACMTA has twooptions: (1) Filing a Rail Crossing Hazards Analysis Report (RCHAR), or (2) Filing formalapplications in accordance with the Commission’s Rules of Practice and Procedure. These optionsare contained in greater detail in Commission GO 164-D.The Light Rail Transit (LRT) Alternative described in your DEIR passes through high densitycommercial, residential and industrial regions of the greater Los Angeles Metropolitan Area. Higherdensity zones near the rail tracks lead to an increased amount of pedestrian activity around the tracks.Constructing tracks at the existing Right-of-Way elevations is likely to result in trespassing issues andpedestrian conflicts similar to those currently experienced along other Metro Rail corridors in LosAngeles. Elevating or tunneling the tracks would mitigate this concern. Additionally, fencing anyremaining at-grade portions of the rail alignment selected should be a requirement of the project.
 
Roderick DiazProject ManagerPage 2 of 4October 28, 2009
Commission staff has reviewed the Base LRT Alternative which includes segments along the existingHarbor Subdivision Right of Way, as well as segments at-grade, below grade and above grade. Staff has also reviewed the six additional LRT alternative design options being considered as variations of the Base LRT Alternative.Some at-grade segments are proposed for street-running configurations. Street-running or centermedian configurations present more problematic interaction between vehicles and Light Rail Trains,usually resulting in vehicle-train collisions, such as have been experienced along The LACMTA BlueLine’s Washington Boulevard segment and the street-running segment in downtown Long Beach.Below we provide specific project concerns for the Base LRT Alternative and six additional LRTalternative design options:Base LRT AlternativeCrenshaw Blvd Alignment: From Expo LRT Line to Harbor Subdivision1.
 
Your DEIR describes the alignment as located along the center of Crenshaw Blvd beginningat a connection with the Expo LRT at Exposition Blvd and heading south. We believe thatLACMTA should consider not connecting to the Expo LRT as indicated in your conceptualdesigns due to the complexity of the proposed at-grade crossing of two roadways (Rodeo Rdand Exposition Blvd).This proposal would create two at-grade crossings in close proximity with tracks at highlyskewed angles to the travelled roadways. Such configurations present safety concerns notonly to vehicles, but to narrow-wheeled vehicles like motorcycles and bicycles. In addition,both crossings would require traffic signalization and coordination with trains operating onboth the Expo LRT and Crenshaw LRT tracks. Staff believes that with the planned five andten minute headways of each line, the train frequency may not provide adequate vehicle flowand may result in extensive traffic congestion. Commission Staff cannot support such aproposal. Staff recommends LACMTA implement its Design Option 6which calls for abelow grade alignment between 39
th
St and Exposition Blvd with a below grade station.Otherwise, LACMTA can simply terminate its proposed street-running alignment at RodeoRd.2.
 
Additionally, this segment is proposed for street-running configuration and the proposed at-grade crossings will present problematic interaction between vehicles and Light Rail Trains.Experience has shown that this configuration leads to driver confusion and vehicle-traincollisions, especially from vehicles making left turns across LRT tracks at roadwayintersections.3.
 
One proposed street-running segment lies between Exposition Blvd. and 39th Stencompassing up to four roadway intersections (Exposition Blvd, Rodeo Rd, Rodeo Pl andColiseum St) that are proposed at-grade crossings. LACMTA should evaluate the reductionof vehicular left turn movements across LRT tracks at these intersections.4.
 
An additional proposed street-running segment lies between 48th St and 59th St. Thissegment encompasses up to seven roadway intersections (48th, 50th, 52nd, 54th, 57th,Slauson Ave and 59
th
St) that are proposed at-grade crossings. LACMTA should also
 
Roderick DiazProject ManagerPage 3 of 4October 28, 2009
evaluate the reduction of vehicular left turn movements across LRT tracks at theseintersections.In addition, Staff is concerned with the presence of the View Park Preparatory Charter HighSchool and the View Park Middle School located along the west side of Crenshaw Blvdbetween 57th St and Slauson Ave. Due to the large number of student pedestrian activityaround schools, particularly with both Middle and High Schools adjacent to the proposedLRT at this location, we recommend LACMTA grade-separate the intersections of 57
th
St andSlauson Ave. This may be accomplished by extending the elevated LRT structure currentlyplanned just south of 59
th
St and connecting to the Harbor Subdivision Right-of-Way.Harbor Subdivision Alignment: From Crenshaw Blvd to Metro Green Line at I-105 Fwy1.
 
Your DEIR describes the alignment as located within the Harbor Subdivision Right-of-Way(ROW) and continuing south to a terminus connection with the Metro Green Line. It is ourunderstanding that the ROW would be shared with BNSF Railway freight train operationsand will require shifting or relocating existing freight track to accommodate LRT track.Sharing the ROW with freight operations may require that LACMTA comply with certainFederal Railroad Administration (FRA) rules and regulations.2.
 
Staff recommends LACMTA evaluate closure of the existing S. Victoria Ave crossing andthe Brynhurst Ave crossing. Both roadways are adjacent to each other, are small 2-lane roadsin industrial areas, and alternate access to businesses exists to 67
th
St on the north and to 71
st
 St on the south. There are some residences in this area but they are generally located closerto 67
th
and 71
st
Streets, further away from the tracks. Closing either of these crossings wouldeliminate any potential for vehicle-train collisions.3.
 
You’ve indicated that the City of Inglewood is planning on realigning Redondo Blvd tocoincide with your project to create an at-grade crossing with a 90 degree track to roadwayconfiguration. Staff will need to evaluate any such reconfiguration of the roadway and anyproposed at-grade crossing at this location.4.
 
Staff is concerned with the presence of the St. John Chrysostom Church and School locatedon the south side of Florence Ave just south of the existing crossing. The Edward Vincent Jr.Public Park is also located on the northeast corner of the Florence Ave/Centinela Aveintersection and existing crossing. The St. Mary’s Academy is also located one block southof the crossing (just south of St. John Chrysostom School). Due to the large number of student pedestrian activity around schools, particularly having two schools and a public park adjacent to the proposed LRT at this location, we recommend LACMTA implement itsDesign Option 3and grade-separate the Centinela Ave crossing.5.
 
Staff is also concerned with the presence of the heavy industrial activity north of the CedarAve crossing. It appears that a large cement and gravel business uses the crossing totransport its products. Our concern is with the continued use of the crossing by largetransport trucks with dirt hauling trailers. While the
Harbor
Subdivision is not currentlybeing used frequently by BNSF Railway Company, the frequency of trains will dramatically
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