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Crenshaw-LAX Independent Traffic Review

Crenshaw-LAX Independent Traffic Review

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Certified traffic engineering firm Sasaki Transportation Services independent review of the traffic segments of the Crenshaw-LAX Transit Corridor Final Environmental Impact Statement/Final Environmental Impact Report. The report also highlights several significant legal deficiencies in the document.
Certified traffic engineering firm Sasaki Transportation Services independent review of the traffic segments of the Crenshaw-LAX Transit Corridor Final Environmental Impact Statement/Final Environmental Impact Report. The report also highlights several significant legal deficiencies in the document.

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10/14/2011

pdf

 
Sasaki transportation services, INC.
p.o. box 5159 laguna beach, ca 92652 (949) 376-6613
October 11, 2011Park Mesa Heights Community Council South Los Angeles Neighborhood Councils5349 Crenshaw Boulevard, Suite 107 Joint Committee on Rail TransitLos Angeles, California 90043 3761 Stocker Street, Suite 108Los Angeles, California 90008SUBJECT: Professional Traffic/Transportation Review of the Crenshaw/LAX Corridor ProjectFEIS/FEIS/R and Associated IssuesDear Residents and Stakeholders of the Park Mesa Heights Community:This letter provides a professional Traffic/Transportation Engineering review of the
Crenshaw/LAX Transit Corridor, Final Environmental Impact Statement/Final EnvironmentalImpact Report
(“
FEIS/R 
”) dated August 2011
, on behalf of the Park Mesa Heights CommunityCouncil & South Los Angeles Neighborhood Councils Joint Committee on Rail Transit. The
Federal Transit Administration (“FTA”) is the federal lead agency and Metro serves as the lead
State Agency, for this joint NEPA (EIS) and CEQA (EIR) document.Given the volumes of materials
generated for this proposed “Crenshaw/LAX Transit Corridor” project (“Project”)
and constrained time frames, these comments should be considered asrepresentative, but not likely a complete and total summary of all FEIS/R defects and issues of concern. It is also possible some responses to our comments may already be contained withinthe existing FEIS/R, as we were unable to review
“every page.” T
his, however, should notdetract from our review; the point is there are deficiencies within the existing documents, wehave identified in this letter.Our comments serve to highlight significant traffic/transportation technicalconcerns/issues/defects and/or related CEQA issues, found during our review of the FEIS/R. Inaddition, we focused more closely on
issues related to the proposed “at grade”
(i.e., street-level) portion of the proposed Project on Crenshaw Boulevard between 48
th
Street and 60
th
Street in thecommunity of Park Mesa Heights. For some issues we also referenced
the “Crenshaw Transit
Corridor Project, Draft Environmental Impact Statement/Draft Environmental Impact Report
(“
DEIS/R 
”) dated September 2009, as well as other associated materials.
 
 
 
Sasaki transportation services, Inc.
Crenshaw-LAX Transit Project
Crnshw-LAX rail,FEIR,f2.docx
FEIS/R Review
2
Overall, we believe there are significant errors and undisclosed Project impacts related to thetraffic/transportation sections of the FEIS/R. There are also more general environmental/CEQA problems with the current FEIS/R. The various outstanding issues serve to challenge theadequacy of the FEIS/R and associated environmental documents. Our comments to date arelisted below.
EXECUTIVE SUMMARY
As an informational document, with respect to traffic/transportation, the FEIS/R and previousDEIS/R fail, in part due to the absence of the mandated
“Existing + Project”
traffic analyses. Wefind the transportation evaluations become too focused on a narrow range of issues, resulting inthe oversight of other obvious and significant impacts.For example, in order to construct the at-grade portion of the rail Project (in the middle of Crenshaw Boulevard between 48
th
Street and 60
th
Street), the focus in the DEIS/R and FEIS/R documents is to provide significant road widening sufficient to satisfy analysis methodologyrequirements. This approach, however, results in the oversight of tremendous changes to thearea traffic operations, community impacts, pedestrian issues, parking concerns, land usesimpacts, shifting of impacts outside the Crenshaw Boulevard corridor, etc.; essentially notdisclosing the secondary impacts of the mitigations, themselves.Some of the critical issues highlighted in this letter are:-
 
Existing, and Existing + Project analyses are needed to inform decision makers of thetraffic/transportation impacts. These analyses are essential for comparing the at-gradeand below-grade options for the Project (Crenshaw Boulevard between 48
th
Street and60
th
Street.-
 
The proposed Project will construct a rail line down the middle of an already congestedand impacted arterial roadway
. The “mitigation” is to widen
the arterial road enough toaccommodate the train and also add capacity for traffic vehicles. These actions, however,generate substantial impacts to the surrounding areas, which are not sufficientlyaddressed in the documents.-
 
 Need for the documents to disclose all traffic/transportation impacts, even those
“secondary” impacts caused by the mitigation measures being proposed.
 -
 
The DEIS/R and FEIS/R fail as informational documents. We have decades of experience in preparation and review of these documents and we had substantialdifficulties just locating needed materials for our review, within the document, and somecritical elements were missing.
 
 
Sasaki transportation services, Inc.
Crenshaw-LAX Transit Project
Crnshw-LAX rail,FEIR,f2.docx
FEIS/R Review
3
COMMENTS:1
.
 
Failur
e
to provid
e
 
“Existing + Project” analyses as required under CEQA.
o
 
It is our understanding “Existing + Project” analyses are required to satisfy CEQA
analyses, including traffic/transportation impact evaluations.
o
 
In the court case, Sunnyvale West Neighborhood Association v. City of Sunnyvale CityCouncil (December 2010) (Sunnyvale), the California Court of Appeal, Sixth Districtinvalidated the use of a baseline consisting of future, post-project approval conditions toanalyze a project's impacts in an environmental impact report (EIR).
o
 
In Sunnyvale, the court found that the failure to assess traffic impacts against the existingconditions resulted in the failure to proceed in the manner required by law. TheCrenshaw/LAX Transit Corridor FEIS/R succumbs to the same analytical error.
o
 
In our review of the FEIS/R 
“Cha
 pter 3, Transportation Impacts of the Alignment and
Stations,” “Chapter 9, Responses to Comments Received,” and “Appendix G, TrafficAnalysis,”
there is an absence of 
the required “Existing + Project” analyses.
 
o
 
Lack of Existing + Project, traffic intersection analysis published in the FEIS/R andDEIS/R is one example of an
“Existing + Project”
analysis deficiency, but please note theCEQA problems are not limited to this one example.
o
 
On Page 3-1, of Chapter 3 of the FEIS/R,
the first sentence states the “California
Environmental Quality Act (CEQA) requires that the effects of the proposed project be
compared with the existing conditions…” but then
the FEIS/R and previously publishedDEIS/R, fails to provide these evaluations. (The DEIS/R was
reviewed and “Existing +Project” intersection analyses were absent from that document as well.
)
2
.
 
Th
e
 
“Existing +
 
Project”
int
e
r
s
ec
tion analy
s
e
s
ar
e
 
ce
rtain to
s
how
s
ignifi
c
ant traffi
c
 impa
c
t
s
,
whi
c
h
c
urr
e
ntly r
e
main undi
s
c
lo
s
e
d
.
 
o
 
When
the intersection analyses for conditions “with Project,” p
rior to mitigation, are provided (
 particularly for the “at
-
grade” sections of Crenshaw Boulevard between 48
th
 Street and 60
th
Street,) those analyses will certainly show substantial Project impacts not presently disclosed.
o
 
The Crenshaw/LAX trains will not only occupy significant roadway and intersectioncapacity, they will require time from the hourly capacity as the trains use the corridor.This is why we are certain the Project impacts will be significant when compared toexisting conditions.
o
 
Given the substantial
Project impacts expected to be shown through the “Existing +Project”
intersection analyses (in particular for the at-grade portion of the Project onCrenshaw Boulevard between 48
th
Street and 60
th
Street) all intersections through this

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