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LAUSD Motion to Enter

LAUSD Motion to Enter

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LAUSD Motion to enter the CPUC Proceeding as a Party
LAUSD Motion to enter the CPUC Proceeding as a Party

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06/15/2009

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In the Matter of the Application of the ExpositionMetro Line Construction Authority for an order authorizing the construction of a two-track at-gradecrossing for the Exposition Boulevard Corridor LightRail Transit Line across Jefferson Boulevard, AdamsBoulevard, and 23
rd
Street, all three crossings locatedalong Flower Street in the City of Los Angeles,County of Los Angeles, California.And Related Matters.BEFORE THE PUBLIC UTILITIES COMMISSIONOF THE STATE OF CALIFORNIA
Application 06-12-005(Filed December 6, 2006)
Application 06-12-020(Filed December 19, 2006)Application 07-01-004(Filed January 2, 2007)Application 07-01-017(Filed January 8, 2007)Application 07-01-044(Filed January 24, 2007)Application 07-02-007(Filed February 7, 2007)Application 07-02-017(Filed February 16, 2007)Application 07-03-004(Filed March 5, 2007)Application 07-05-012(Filed May 8, 2007)Application 07-05-013(Filed May 8, 2007)
MOTION OF THE LOS ANGELES UNIFIED SCHOOL DISTRICTFOR LEAVE TO BECOME A PARTYAND TO FILE A POSITION STATEMENT
M
ICHAEL
J.
 
S
TRUMWASSER 
(SBN 58413)
F
REDRIC
D.
 
W
OOCHER
(SBN 96689)Z
AHIRAH
W
ASHINGTON
(SBN
 
222140)STRUMWASSER & WOOCHER LLP100 Wilshire Boulevard, Suite 1900Santa Monica, California 90401Telephone: (310) 576-1233Facsimile: (310) 319-0156e-mail:mstrumwasser@strumwooch.com
 Attorneys for the
December 17, 2007
 Los Angeles Unified School District 
 
2
MOTION OF THE LOS ANGELES UNIFIED SCHOOL DISTRICTFOR LEAVE TO BECOME A PARTYAND TO FILE A POSITION STATEMENT
Pursuant to California Public Utilities Commission’s (“CPUC”) Rules of Practice andProcedure, rules 1.4 and 11.1, the Los Angeles Unified School District (“LAUSD” or “theDistrict”) requests leave to become a party to the instant proceeding and to file a statementof its position concerning the instant proceeding.The District is the second largest school district in the nation. It works to protect thehealth and safety of nearly 780,000 students, teachers, and staff, and to maintain the thrivinglearning environment that has brought these individuals together. The instant proceedinginvolves a project that will adversely impact many of the District’s proposed and existingschools. The District seeks to participate in this proceeding on behalf of itself, including itsOffice of Environmental Health and Safety and its Facilities Maintenance and OperationsDepartment.In the instant proceeding, the District is particularly interested in the safety concernssurrounding the Exposition Metro Line Construction Authority’s (“Expo Authority”) requestfor authorization to construct a “four-quadrant two-track 
at-grade
crossing at FarmdaleAvenue, in the City of Los Angeles . . . adjacent to Dorsey High School [a District operatedschool].” (Oct. 16, 2007, CPUC, Scoping Memo and Ruling, p. 6 [emphasis supplied].) Asthe operator of the school that is adjacent to the proposed project, the District is in the unique position to provide vital information that will “be reasonably pertinent to the issues already presented.” (CPUC, Rules Prac. & Proc., rule 1.4, subd.(b)(2).) Until now, the District has
 
3
 been an “information only” interested party in the proceeding. But it has become clear thatthe Expo Authority desires to implement adjacent to one of the District’s most populatedschools a crossing alternative that puts students in harm’s way. The District’s participationin this proceeding is necessary to ensure that the proposed rail line is authorized in a manner that will protect generations of young students.Accompanying this motion is the District’s position statement regarding its pedestrianand traffic safety concerns surrounding an at-grade crossing at Farmdale Avenue, specificallythose factual issues related to A.07-05-013 — the application for an at-grade crossingadjacent to Dorsey High School — including “the high traffic volumes, the types of crossingwarning devices, the special needs of student populations, and the necessity and practicabilityof a grade separation at Farmdale Avenue.” (Oct. 16, 2007, CPUC, Scoping Memo andRuling, p. 6.) The thousands of individuals who come together in the learning environmentof Dorsey High School will be approximately 50 feet from the operation of the ExpoAuthority’s proposed rail line. Therefore, if the project goes forward as currently requested,the rail line will be located approximately 50 feet from and at the same grade level as highvolumes of traffic and thousands of adolescents. The District would like to afford all of the parties to the proceeding access to a detailed discussion of its position before the evidentiaryhearing takes place, so that the duration of this proceeding need not be expanded for the parties to respond to these concerns.For these sound reasons, the District seeks leave to intervene and to participate and

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