PETITION FOR WRIT OF MANDATE AND COMPLAINT
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.) in that the EIS/EIR failed to comply with the informationdisclosure provisions of CEQA and failed to adequately analyze Project environmentalimpacts. MTA also failed to require all feasible mitigation and failed to consider anadequate range of alternatives. MTA failed to ensure that mitigation was certain andenforceable and failed to consider feasible alternatives, in particular grade separation of the rail line, proposed by the public. Lastly, the MTA adopted a Statement of Overriding Considerations which was not based on substantial evidence in the record.5.
The EIR finds that the Project will have significant and unavoidable impacts to theenvironment in the areas of construction air quality impacts and potentially to trafficimpacts at Crenshaw Boulevard/54
Street. The project approvals, if allowed to stand,would thus significantly affect the environment.6.
In approving the Project, the MTA also violated the provisions of Government Code §11135 (a) in that the MTA’s determination to approve the Project has a discriminatoryimpact on the African-American population in the Project area, the last majorconcentration of African-American owned and operated businesses in the area and theregion’s center of African-American culture. The MTA approved the Project with theknowledge that such approval would discriminate against African-American arearesidents as Petitioner and others commented that the Project would have a racially andsocio-economically disparate adverse impact.7.
By this verified Petition, Petitioner alleges the following:
Petitioner, Crenshaw Subway Coalition, is a California nonprofit corporation led bystakeholders along the Crenshaw Boulevard Corridor. Petitioner submitted commentsopposing approval of the Project to the MTA and FTA, which had/has discretionaryapproval authority over the Project.9.
Respondent and Real Party in Interest, MTA, is a local government agency chargedwith the authority of planning and implementing transportation and transit developmentwithin its territory in compliance with applicable provisions of state law including