CRA LTR On Crenshaw Line DEIR

DATE I
Community Redevelopment Agency of the CITY OF LOS ANGELES

FilE CODE I

354 South Spring Street I Suite 800 Los Angeles I California 90013-1258

T 213 977 1600 I F 213 977 1665 www.crala.org

Mr. Roderick Diaz

Project Manager, Crenshaw Transit Corridor Project LACMTA

One Gateway Plaza

Los Angeles, CA 90012-2952

Dear Mr. Diaz:

Thank you for the opportunity to comment on the Draft Environmental Impact Statement - Draft Environmental Impact Report (DEIS/DEIR) for the Crenshaw Transit Corridor project.

The success of this project is immensely important to the fulfillment of CRA/LA's mission and the potentials of the Crenshaw community. That mission includes the elimination of conditions of blight and deterioration that have long plagued the communities along the Crenshaw Corridor, the dearth of quality consumer services, the relative isolation from the regional transportation system, limited local circulation, the poor and insecure quality of the pedestrian environment, inadequate hous.ing to meet the needs of the entire community, and a lack of access to jobs for the local population, especially youth.

The DEIS/DEtR contains a large volume of documentation. This letter highlights CRA/LA's priority concerns regarding the project. The Attachment to this letter provides additional details and comments that should be responded to in the subsequent environmental documents and transit corridor design program.

The Scope of Consideration in the DEtS/DEtR is Incomplete

The Crenshaw Transit Corridor project is a first phase of a larger major rail transit corridor that will be an important component in the region's rail transit system.

Failure to comprehend the larger context of this major rait project could cause the Crenshaw transit corridor to fall short of fulfilling its ultimate potential as part of the regional transit in the future. As a result, the possibilities of revitalizing the businesses and neighborhoods in the Crenshaw corridor will most certainly have been compromised as well.

LACMTA should appropriately expand the scope of the DEIS/DEIR to include the reasonably foreseeable system extensions, the potential cumulative implications of implementing those extents, and carefully reflect back as to how reasonable future growth and system scenarios should be given consideration in the design choices for this initial phase of the Crenshaw Transit Corridor.

A Below Grade Design is Preferable

An at-grade LRT on Crenshaw Boulevard would create significant impact that cannot be adequately mitigated. These impacts include:

• the loss of community parking resources,

• issues of vehicular and pedestrian safety,

• noise and visual intrusion, and

• the overall quality of the continued function of Crenshaw Boulevard as the central spine in this part of South Los Angeles.

But most fundamentally, we believe that at-grade and aerial alignments within the Crenshaw Boulevard right-of-way will forever limit and diminish the ultimate economic development and redevelopment potentials of Crenshaw Boulevard. The visual and physical impact of the at-grade and aerial alignments on the commercial and residential uses fronting on Crenshaw Boulevard could largely negate the blight eradication efforts of CRA/LA in this critical portion of South Los Angeles. For these reasons, CRA/LA believes the entirety of the line in Crenshaw Boulevard should be built n a below-grade configuration.

System Performance and System Alternatives

CEQA and NEPA require consideration of all reasonable and appropriate project and system alternatives and, for that reason, a Bus Rapid Transit alternative is included in the DEIS/DEIR, along with a TSM and No Build alternative. Frequent, efficient bus services along Crenshaw have been and will continue to be very important for the Crenshaw community and for the Hollywood, Wilshire and South Bay communities with which these services connect. However, in the context of a truly responsive plan for the region's transit, it has to be clear that buses operating on surface streets, even with efforts to create exclusive lanes to attempt to reduce traffic interference and increase speed, cannot effectively substitute for the higher patron travel speeds regional transit requires in this corridor. Moreover, the loss of on-street parking, turning options, the noise and intrusion impacts and the potential risk to pedestrians of over-sized, diesel buses moving at high speed in a curb lane would be difficult or impossible to mitigate to acceptable levels. Thus, CRA/LA believes that a bus rapid transit alternative is not a workable solution. It should also be clear, as mentioned above, that where the alignment is in a major urban arterial, CEQA and NEPA require that fully below-grade configurations be included among the alternatives considered and diesel buses cannot be effectively operated in tunnel configurations.

Finally, only a rapid rail alternative adequately responds to the mandate of Measure R and the long-held aspirations of the Crenshaw community. The LRT corridor alternatives presently represented in the DEIS/DEIR are not offering as competitive travel speeds as should be expected and those aspects should be evaluated for further improvement.

-2-

Attached to this letter are more detailed comments on aspects of the DEIS/DEIR for the present phase of the Crenshaw Transit Corridor construction that CRA/LA believes need to be addressed with additional analyses and mitigation measures for the best long-term results for the regional transit system and to best realize the aspirations and potentials of the Crenshaw community.

These very important concerns notwithstanding, I want to express CRA/LA's appreciation to you and your team for the dedication and quality of effort that you have brought forth on this project. It has been a privilege to share in your team's commitment to this project's success and we forward to continuing a fruitful and productive working relationship.

Cecilia V. Estolano Chief Executive Officer

Attachments:

Attachment A: CRA/LA Detailed Comments Attachment B: LADCP Detailed Comments Attachment C: LAEAD Detailed Comments

Cc with Attachments:

Mayor Antonio Villaraigosa Deputy Mayor Jaime de la Vega Deputy Mayor Bud Ovrom Deputy Mayor Helmi Hisserich

Council member Bernard Parks, Council District 8 Councilmember Herb Wesson, Council District1iO Councilmember Bill Rosenthal, Chair, Council Transportation Committee

S. Gail Goldberg, Director, Department of City Planning

Rita Robinson, General Manager, Department of Transportation Gary Lee Moore, City Engineer, Public Works Department County Supervisor Mark Ridley-Thomas, Second District

State Assemblywoman Karen Bass, 47th District

State Senator Curran Price, 26th District

Congresswoman Diane Watson, 33rd District

Congresswoman Maxine Waters, 35th District

Congresswoman Jane Harmon, 36th District

Raymond Sukys, FTA, Region IX, San Francisco

Ray Tellis, FTA, Region IX, Los Angeles

Hassan Ikhrata, Executive Director, SCAG

Jackie Bacharach, Executive Director, South Bay Council of Governments

-3-

ATTACHMENT A:

CRA/LA COMMENT LETTER DETAILS ON

CRENSHAW TRANSIT CORRIDOR PROJECT DEIS/DEIR

Cecilia Estolano to Roderick Diaz October 26, 2009

ATIACHMENT PAGE 1 OF 20

The following are additional CRA/LA detailed comments to be attached to the comment letter of Cecilia Estolano to LACMT A Crenshaw Transit Corridor Project Manager Roderick Diaz.

Overall System Selection

CEQA and NEPA require LACMTA to consider a range of alternatives using project evaluation criteria that focus on a specific, limited range of estimated cost and performance factors. As presently evaluated in the DEISIDEIR, a rail (LRT) system concept is among the most viable alternative for this initial phase of corridor construction. However, the extent of the LRT alternatives as currently outlined in the DEIS/DEIR contain elements that are contradictory to existing City of Los Angeles and CRA/LA plans and policies. CRA/LA supports a Light Rail Alternative that mitigates impacts to the surrounding communities to greatest extent possible. The mitigations that are needed may need to go beyond limited design and cost criteria that the DEIS/DEIR may have been operating within, however.

The No-Build and Transportation Systems Management (TSM) Alternatives do not alleviate the strain on the existing bus ridership or address the Southern California Association of Government's (SCAG) long term projections for the area (see chart below), which illustrate higher growth rates for population, dwelling units and employment compared to the City of Los Angeles.

1.00%
0.98%
0.96%
0.94%
0.92%
0.90%
0.88%
0.86%
0.84%
0.82%
0.80%
0.78%
Population . .... i-iil-crens~ Disbicl

lEI City of Los Angeles • Los Angeles County

Itluseholds

Employment

Demographic Prolil e- Projected Annual Growth ZlJ()S • <030.

The Bus Rapid Transit (BRT) Alternative as well as the Light Rail Transit (LRT) Baseline Alternative incorporate fundamental design features that are contrary to the Mid City Crenshaw Vision and Implementation Plan ("Crenshaw Vision Pian") approved by the Los Angeles City Council in February 2009 as well as the pending revisions to the West Adams-Leimert Park-Baldwin Hills Community Plan which are in the approval process.

ATTACHMENT A:


CRENSHAW TRANSIT CORRIDOR PROJECT DEISIDEIR


ATTACHMENT PAGE 2 OF 20

The Crenshaw Vision Plan is a comprehensive planning strategy that provides development incentives by addressing land use, zoning and design for development guidelines while providing public infrastructure improvements to streamline the entitlement process, stimulate economic development, spur job growth, and create a healthy community environment by increasing mobility and connectivity among pedestrians, bicycles, public transit and other vehicular transportation.

The State of California has awarded CRA/LA $14.7 million in Proposition 1C funds which commit the City to implementing the Crenshaw Vision Plan over the next 2 years with measures that-

• "Encourage the development of open space through limit street vacations," [page 67 of the Crenshaw Vision Plan) and

• "Emphasize retaining and enhancing the existing frontage roads," [page 71 of the Crenshaw Vision Plan]

All at-grade and above-grade Crenshaw Transit Corridor project alternatives conflict with the Green Street elements adopted, such as--

• Bioswales, wide landscaped medians, and traffic calming devices.

• Vehicular traffic management complementing the increased pedestrian oriented environment along wide Crenshaw Boulevard sidewalks

• Vehicular circulation and accessibility entering, leaving and along Crenshaw Boulevard, and

• The removal of visual bight in all forms along the corridor

All of these elements are required to enhance the desirability for both commercial and residential developers, tenants and customers of the Crenshaw Boulevard adjacent properties and communities. The BRT alternative and the LRT alternatives as currently presented would prohibit or destroy many of the infrastructure improvements approved in the Plan and awarded funding by the State of California.

In addition, portions of the Crenshaw/South Bay Transit Corridor Project are located within the Mid-City Recovery Redevelopment Project Area. The Mid-City Recovery Redevelopment Plan governing the Mid-City Project Area includes the following:

• "Support and encourage a circulation system which will improve the quality of life in the Project Area, including pedestrian, automobile, parking and mass transit systems, with an emphasis on serving seniors and the disabled" [paragraph 8, Section 105, page 3].

• "Promote the development of safeguards against noise and pollution to enhance the quality of the residential/commercial community" [paragraph 12, Section 105, page 3]; and

ATTACHMENT A:





• "Promote the provision of well-planned community uses and facilities, pedestrian and vehicular circulation, and adequate parking" paragraph 14, Section 105, page 3].

The DE1S/DEIR is thus not accurate in Table 5-1 when it characterizes without qualification that the LRT Baseline (and, in some cases, other system alternatives) as being in conformity with applicable City of Los Angeles plans and policies.

The BRT Alternative and the above-grade LRT Alternatives all require losses of onstreet parking without providing adequate mitigations (such as publically-available substitute local parking supplies. The loss of on site parking along the corridor removes an important buffer between vehicular traffic and the pedestrian zone and street front businesses. The loss of this buffering zone and this publically-available parking will be detrimental to economic viability of the existing businesses and the livability and amenity of the Crenshaw Boulevard corridor.

In our estimation, bringing into consideration requirements of the entire Crenshaw transit corridor, the larger range of land use relationships and community livability considerations that, are fundamental to sound, long-term decisions for this corridor, CRA/LA's response to "Issues To Be Resolved" [p.5-51 , section 5.6] is that a properly mitigated rail system is a far superior alternative for both the long-term productivity of the regional transit system and the sustainable revitalization of this portion of South Los Angeles than the No-Build, TSM or the BRT alternatives. We believe that only a properly-designed rail system fulfills the intent of Measure R as passed by the voters of Los Angeles County.

Insofar as, in CRA/LA's estimation, only a rail alternative is a truly viable-and truly acceptable--Iong-term transit investment for this regional corridor, this review focuses on providing guidance to the implementation of that option. Should there be serious consideration given to implementation of a non-rail alternative for this corridor, CRA/LA would respectfully request that additional time be given to address those system issues in more detail.

Overall System Definition and Assessment Parameters

As defined in Measure R, the Crenshaw Transit Corridor extends at least as far north as a terminus with an extension of the Purple Line along Wilshire Boulevard (at Crenshaw Boulevard, La Brea Avenue or another location). Measure R also provides that the north-south segment of the Green Line, which could logically be operated as part of Crenshaw rail transit operation, will be extended to the planned Torrance Regional Transit Center. In fact, at some time in the future, it would be logical to extend this corridor even further to the south into the South Bay and possibly further north into Hollywood.

ATIACHMENT A:





While it is understood that the present project document is only considering construction of an initial phase of the Crenshaw Transit Corridor, it has to be considered a potential, integral part of this larger corridor if appropriate, long-term system design decisions are going to be made.

The DEISIDEIR should, therefore, contain forecasts of critical factors that could bear upon the configuration of the Crenshaw corridor generally and the specific design issues of this initial phase in particular, including-

• Estimates and forecasts of corridor population and employment, currently and under various scenarios into the future, for the fuller extent of the corridor. Included among these scenarios must be appropriate responses to AB 32, SB 375 and other State mandates. Scenarios should also include the potentials of coordinated land use development with fully grade-separated rail transit.

• Estimates and forecasts of rail system operating speeds and travel times for a reasonable range system configurations over the fuller extent of the corridor. The DEISIDEIR gives some limited consideration to the performance of different LRT options (p. 3-43) but not as these considerations might relate to the entirety of a future transit corridor (as illustrated with the limitations of the table on p. 3- 36). In addition to an evaluation of a complete corridor LRT "baseline" with a related "street-running"lat-grade concept, one or more whole corridor gradeseparated configurations, perhaps below-grade in some instances to most directly serve the highest future development potentials, should be analyzed.

• Estimates of transit and vehicular delays that fully reflect the effects of on-street bus lanes and at-grade rail operations. It is not clear that the 2030 LOS and street congestion forecasts in the DEIS/DEIR (pp. 3-18 ff.) are fully incorporated into the LRT Baseline operations analyses (p.3-45), particularly if they may have an impact on transit running speeds, traffic speeds, demands for turning movements and impacts on pedestrian crossings. That needs to be clarified.

• Estimates and forecasts of a reasonable range of travel need and transit usage scenarios for the corridor configuration scenario alternatives. Modeling of travel need and potential transit patronage needs to take into account important future context issues such as potential automobile congestion delays, future household costs for transportation and other expenses, as well as prospective mandates to reduce greenhouse gas emissions.

Incorporating these analyses into the DEIS/DEIR will provide a better understanding of the ultimate needs and potentials of the transit corridor will add important dimensions to the long-term costs and benefits of design decisions that have to be made in this initial construction phase of the Crenshaw Transit Corridor project.

ATIACHMENT A:





In addition to questions as to whether the transportation performance factors of the alternatives have been fully and clearly reflected, we have to question a number of the environmental resource impacts that the DEISIDEIR assigns to the alternatives:

• Air Quality. As we understand the two primary "build" alternatives, the BRT alternative would use fossil-fueled (diesel-cycle) buses, while the LRT alternatives would all use electricity supplied by an overhead catenary. The alternatives using buses depend upon combustion processes that inherently produce toxic gas emissions (such as NOx) and carbon/Greenhouse Gas (GhG) emissions (such as CO and C02). The LRT alternatives, by contrast, use electricity which has the future potential to be produced entirely from nonpolluting, sustainable energy sources.

However, the DEIS/DEIR identifies the LRT alternatives as the only alternatives with and "Adverse Effect" on air quality [Table 5.1, p. 5-8]. The DEISIDEIR finds the LRT alternatives as the only alternatives that produce NOx emissions over the Federal threshold. The DEIS/DEIR also finds that the BRT alternative reduces GhG emissions by a very large amount while the LRT alternatives increase GhG emissions.

These assessments highly questionable and could only result from some very particular assumptions and calculation procedures. For such unusual and counter-intuitive assessments, the DEIS/DEIR needs to provide a very clear and detailed explanation of its calculations and its assumptions and why critical assumptions were made. Total dependence upon combustion-engine, fossilfueled transportation systems has generally not been held to be a sustainable policy for the South Coast Air Basin. The DEIS/DEIR needs to very thoroughly explain why it would appear to be commending this course of action for the Crenshaw transit corridor for purposes of air quality. The DEISIDEIR should also bring forth credible alternative calculation and analysis methods and provide a reasonable range of assessments of long-term air quality impacts of the alternative transit system investments.

• Energy Resources. Following upon the characterization of the alternatives above, the combustion engines that power buses in the BRT alternative are relatively inefficient, losing a great deal of their energy to heat. They are would also typically be using petroleum fuels, an ultimately unsustainable energy resource. The LRT alternatives, on the other hand, use electric traction which is much more energy efficient and delivers superior torque and acceleration and provides regenerative braking, helping recapture energy otherwise lost in braking. But equally important, by relying upon electricity, the LRT alternatives provide the broadest base for energy sustainability, utilizing a resource that can be sustainably generated in a variety of ways.

However, the only energy assessment of the alternatives in the DEISIDEIR identifies the BRT alternative as reducing energy consumption over the baseline

ATTACHMENT A:

CRA/LA COMMENT LETTER DETAILS· ON




condition by 560,523,312 BTUs/year, an amount over ten times the amount of energy saved by the LRT alternatives at 52,599,515 BTUs/year.

Again, these calculations are counter-intuitive and need to be thoroughly examined and explained. As above, it would appear that very particular assumptions and calculation procedures were used.

The basis for analysis is also inappropriately narrow and limited, neglecting as it does to clearly distinguish between the potentials for using sustainable energy resources and less sustainable energy resources (such as petroleum-based fuels). The DEISIDEIR must very thoroughly detail the assumptions and procedures it used in producing its assessments and then should also bring forth credible alternative calculation and analysis methods and provide a reasonable range of assessments of long-term energy resource impacts of the alternative transit system investments.

General Assessment of At-Grade Rail and Land Use Mitigation Measures

In general, CRA/LA would express skepticism about the appropriateness of installing regional rail infrastructure at-grade in the existing rights-of-way of urban arterials, given the rail system's need to achieve higher operating speeds, higher capacities and, collaterally, reduce the risks of delay and collisions with pedestrians and other traffic. CRA/LA's experience to date, for instance with the Blue Line operation on Washington Boulevard, has yet to demonstrate that the added mobility resulting from the construction of the transit way significantly outweigh the detriments to traffic and community development potential. It is also not clear that in-street running on major, congested urban arterials is viable as an operating environment for regional high-speed rail links over the long term.

Slower, local circulator rail systems ("trolleys" and "streetcars" such as CRA/LA has advocated in Downtown) may be designed to integrate with and support local corridor land use. These applications should not be confused with the fast, higher-capacity services into, out of and through the Crenshaw community that the Crenshaw Transit Corridor project is being developed to provide. In our examination, the DEIS/DEIR's treatment of the following issue areas needs to be enhanced:

• True high speed regional rail transit. There need to be clear and substantial assurances that the LRT Baseline system will be able to provide the overall average patron travel times (e.g. in excess of 35 mph) typically expected for competitive regional rail transit services, thus providing the level of benefit justifying the investment and the prospective disruption to the community;

ATTACHMENT A:





• Street traffic congestion, delays and collisions. We believe there needs to be a more thorough accounting of and forecasting of the street traffic delays, congestion and compromises to street safety that the at-grade portions of the Line have the potential to create.

• Loss of long-term development potential and community livability. The potential intrusion, noise and disruption engendered by at-grade transit operations will almost certainly compromise the long-term development potential of the Crenshaw corridor. Most certainly, the potential would be considerably lower than if the rail transit system were completely below grade. In our estimation, there could well be a question as to whether the overall long-term community development potential and livability is, on balance, significantly improved with the LRT Baseline (or other DEISIDEIR alternatives) for costs involved.

Over the last decade, transportation professionals have become increasingly sensitive to the need to appropriately "calm" and buffer the impacts of street traffic from the pedestrian zone and building frontages. Techniques such as bulb-outs and dedicated frontage alleys that have been hallmarks of great, classic boulevards are now being rediscovered for their value in building overall urban livability and function. As it happens, there are significant stretches of Crenshaw Boulevard that anticipated and embodied these enlightened design practices. The Crenshaw Transit Corridor project now proposes to remove these classic features.

We respect the fact that DEISIDEIR alternatives reflect pre-determined cost constraints imposed upon the project. It may be, however, that these cost constraints are below the threshold at which transit corridor investments can demonstrate the greatest productivity and benefit return over the long term. The real measure of the worthiness of a transit system investment is not simply in the operation of the system itself, but in the totality of benefit that its services engender over the life of that transit system investment.

The DEISIDEIR inventories existing land use and land use plans. However, the discussion of impacts between different LRT configurations (pp.4-33, 4-34) is really not that helpful for decision-makers. What CRA/LA believes would add important value to this information would be to draw upon the system scenarios and transit usage forecasts called for in the preceding section to create estimates of overall development potential that would be created (or diminished) with the critical LRT system options. These benefits should then be arrayed to help inform the MTA Board's decisions on this project.

An ACHMENT A:





Specific Concerns About the Impacts of Proposed Rail Facility Configurations and Mitigation Measures

The DEIS/DEIR has developed an extensive inventory of important parcels, historic properties, land uses and physical attributes along the corridor. CRA/LA has identified a number of specific areas of concern with the LRT system designs as presented in the DEIS/DEIR:

• Option 4. CRA/LA believes that the aerial configuration proposed in the LRT Baseline would permanently and irreversibly blight this length of Crenshaw Boulevard, which is already one of the most marginalized segments of the corridor. We very strongly believe that the Option 4 underground alternative is a necessary and appropriate investment.

• Option 5. In earlier parts of the design process, CRA/LA had the belief that a Leimert ParklVernon station, being at the very center of the Crenshaw community, would be integral to any LRT system design. We believe that still to be the case. A Leimert Park station is an essential part of the LRT system and must be included in the adopted design.

The characterization in the DEISIDEIR (Table 5-2, p. 5-14) that Option 5 would have a "Potentially Adverse Effect" on local land use and development is inappropriate. The suggestion that undesirable development would be created in Leimert Park by the provision of a subway station overlooks the provisions of the Crenshaw Specific Plan, sections 7-10 addressing development configurations, and section 14 addressing the jurisdiction of the Design Review Board.

• Option 6. CRA/LA strongly believes that an in-street, at-grade LRT alignment is patently unreasonable and inappropriate from Coliseum Road north. The adverse impacts to existing and potential development, particularly on the east side of Crenshaw Boulevard between Coliseum Road and Exposition Boulevard would be devastating to both existing and planned development and development potential. What should be an attractive, pedestrian-friendly hub for two major rail transit lines will instead be turned into a hazardous, congestionchoked "no-mans land" of traffic lanes and rail tracks crossing at odd angles.

CRA/LA takes very strong objection to the DEISIDEIR assertion (section 4.16.3.5, p.4-489) that " ... Option 6 would not alter the potential for growth from [that of] an at-grade station." There is a radical difference between the development potentials, the quality of traffic operation, the quality of the potential pedestrian environment and the general livability of the Exposition crossing that Option 6 could provide over the LRT Baseline design. This needs to be clearly acknowledged and evaluated by the DEISIDEIR.

ATIACHMENT A:





On page 5-21 in Table 5-2, CRA/LA believes the safety attributes of Option 6 are understated. While Option 6 " ... would eliminate collisions [between] LRVs and motorists ... ", the following two bullets on train crossings, traffic signals and pedestrian gates appear to apply to the LRT Baseline, not Option 6. Among those safety attributes that should be given to Option 6 (and Option 5) are their provisions for safe, direct, below-grade pedestrian connections, avoiding potential collisions on surface streets with vehicles and trains.

• Preservation of the Capability to Complete the Extension of the LRT Crenshaw Corridor North to Wilshire Boulevard. In addition to the concerns above about the necessity of incorporating Option 6 into the design of the LRT system, CRA/LA would further note that it has always been the intention of the Crenshaw Transit Corridor design, of Measure R, as well as the clear aspiration of the Crenshaw community that the Crenshaw Transit Corridor ultimately connect directly to the Wilshire subway. As recognized by the DEIS/DEIR, the extension of this corridor north of Exposition must be in subway, as no other configuration is feasible. However, were LACMTA to adopt the LRT Baseline design, with the track alignments turned to the east to parallel the Exposition Line, such an extension north would be highly problematic if not impossible. The ultimate potential for extending the Crenshaw corridor north as has always been intended can only be fulfilled it" its Exposition station is below ground as proposed in Option 6.

We strongly urge LACMTA to continue the LRT alignment below grade north of MLK Boulevard, providing an interim terminal station below grade that will facilitate the ultimate extension of the Crenshaw Transit Corridor north to Wilshire Boulevard.

• Need to Add Option 7: Underground Alignment from Option 4 Underground Alignment to Underground Alignment at 48th Street. To repeat a point raised at the start of comments, CEQA and NEPA require that all reasonable project alternatives be included for study and evaluation. For an instance where a major regional rail line is to go along a major, inner-city arterial where numerous conflicts and constraints have already been noted, there is no defensible basis for not including the option of running the entire length of the rail line under Crenshaw in subway. The merits of removing the last segment of above-ground LRT from Crenshaw Boulevard have been given mention throughout these comments. To recap a few points-

o Visual. Intrusion and Noise Impacts: The great majority of the extensive list of adverse visual impacts (noted Table 5-1, p. 5-7; pp.4-529ff. among other places) would disappear with the line placed entirely underground before entering Crenshaw. The characterization on p. 4-532 that "no disproportionate impact" is not, in our view, accurate, given the size and speed of the trains and the associated grade crossing safety devices that will likely be necessary.

ATTACHMENT A:





o Traffic Flow and Traffic Safety: The hazards of cross traffic and left-turn movements across in-street LRT operations have proven to be very significant in other Metro corridors. This experience is not adequately evaluated and applied in the DEISIDEIR for the Crenshaw Transit Corridors. These are significant costs of these risks and hazards that accrue not only to MTA rail operations, but to automobile users, truck traffic and pedestrians. All of these hazards would be avoided with the line underground in Crenshaw.

o Rail Operation Speed and Reliability: Needing to stop at intersections for traffic lights to cross intersections and (at the Exposition terminus) cross traffic lanes imposes both time delays and compromises reliability; this will become increasingly a problem over time as street congestion increases (and which the at-grade LRT system itself will exacerbate). While the LRT Baseline configuration has four grade-level transitions, an all-subway alternative would only have one transition (at the Harbor Subdivision), thus saving the additional energy required to bring the train up to grade or up to an aerial level. Incorporating gravity profiling in an all-subway segment could further enhance the energy efficiency of LRT operations. None of these considerations appear to be adequately evaluated and applied in the DEISIDEIR's analyses.

o Construction Efficiencies and Cost Savings. With the short below-grade sections as designed for the LRT Baseline, there are no opportunities to utilize larger economies of scale and the efficiencies of tunnel boring machines. The cut-and-cover construction techniques that would likely have to be employed are disruptive, costly and time-consuming ways to construct below-grade facilities. Even with all of the DEIS/DEIR's belowgrade options, the long at-grade section between so" and 48th Streets greatly limits options for staging and using TBM's. In the course of including an all-subway alignment LRT alternative under Crenshaw, the DEISIDEIR should pay particular attention to the opportunities for construction efficiencies, time and cost savings.

o Land Use and Development Potentials. The development potentials and commercial attractiveness of business property along segments of the LRT alignment between stations will, in almost all cases, suffer net decreases as a result of the effects of at-grade LRT operation. Arterial frontage residential development is likely to become particularly blighted and will no longer be viable along above-grade LRT segments. The DEISIDEIR fails to identify and account for these impacts. While station locations should provide some stimulus for economic activity, the level and range of development potentials will be much more limited around stations placed at-grade, such as Exposition and Slauson, than if these stations were in a below grade configuration with direct, safe, belowgrade patron connections into pedestrian-oriented development sites.

o Environmental Justice. The DEIS/DEIR acknowledges in section 4.18.3.1 [pA-514] that " ... the decisions for grade separations in the Crenshaw

ATTACHMENT A:





Transit Corridor were not driven by the type of community, but rather by engineering considerations" and that "Grade separation for BRT or LRT is typically engineering-driven, and is not dependent on the type of community where it is to be located." While CRA/LA would acknowledge that systems engineering and performance criteria should have a major role in the grade configuration decisions for a transit system, these criteria alone seem inadequate-and possibly inconsistent-as they are being applied.

On the one hand, it would be myopic and contrary to good practice to suggest that transportation infrastructure investments should only be configured with respect to their own operational criteria and without regard to the viability, sustainability or potentials of the adjacent land uses that could be affected. Grade separation decisions should go beyond just transportation systems engineering considerations and include long-term performance and sustainability standards for the larger corridor as a whole, including land uses.

On the other hand, in other corridors, it would seem that LACMTA is, in fact, taking community context into consideration. The proposed extension of the Metro Purple Line from Western to La Brea (with or without a prospectively optional station at Crenshaw) is presently being proposed only in a subway configuration. Most of that reach, from Wilton to Highland, borders a very low density, affluent residential district. That stretch is about the same length as the distance from 6th to 48th and could, conceivably with some right-of-way adjustments, be considered for the type of aerial configuration that is proposed for the Hyde Park section of the Crenshaw Transit Corridor. That would, as is being presented in the Crenshaw Transit Corridor planning, save some money without seeming to affect transit engineering criteria.

But that configuration would be absolutely terrible for that community context. Not only would it completely contradict the Park Mile Specific Plan and virtually all other plans and policies for the area, it would irreparably degrade the quality of life for those adjoining residential districts. Given that at some point that the Purple Line would need to return to a subway configuration, it would also introduce many of the excessive grade transition issues that confront the Crenshaw Transit Corridor. That LACMTA would directly define a subway configuration for that corridor extension is fully understandable. What CRA/LA believes is appropriate, however, is to acknowledge that community context deserves more consideration in the definition of grade configuration alternatives for the Crenshaw Transit Corridor and that a full Crenshaw subway configuration should be among those alternatives evaluated for this project.

ATTACHMENT A:





• Right-of-Way Takes at 6ih and Crenshaw. While the both the SWC and SEC of the intersection of Crenshaw and W.67th would necessarily (as shown in Drawing C-422) require a r-o-w take in order to support the bents for the aerial guideway of the LRT Baseline configuration, the property to be taken (and the appropriate accommodations to accommodate pedestrian circulation, clear sightlines and traffic safety) are not delineated. Parcels L-37 to L-43 involving several acres, are located at the vicinity of Exposition Blvd. and Crenshaw, and yet, the Assessor Block and Parcel Numbers identifies these parcels to be located at the SEC of 67th and Crenshaw. Additionally, the proposed use, as outlined in Chart on C- 550A states "0 & M FACILITY SITE D", which conflicts with Drawings shown on C-435.

In the Option 4 (below grade configuration), Drawing C-622 still shows facility intrusions into this corner, variously identified as subject parcel 32 (SEC), and L- 29, L-30, and L-31 (SWC) in Drawing C-621. Parcels L-37 to L-43 involving several acres, are located in the vicinity of Exposition Blvd. and Crenshaw; however, the Assessor Block and Parcel Number does NOT identify L-45 as shown on C-753a which Chart states ""0 & M FACILITY SITE D", consisting of 1,186,440 sq. ft. or 27.2 acres of land. There is no apparent delineation of the property taken shown or its purpose clearly defined. All of the proposed r-o-w actions and mitigation measures at this intersection need to be much more clearly delineated and described for all Alternatives.

• Potential Loss of Turning Movements, Cross Access from W.67th to W.59th Street [LRT Baseline ConfigurationJ. In CRA/LA's examination of the drawings in Volume II, we could not determine to what extent intersection left-turn lanes and mid-block left turn capabilities are compromised by the placement of aerial columns. There are a number of potential traffic conflicts that the DEISIDEIR should clarify, among them:

o Crenshaw at w.6ih Street: Appears that sIb left turn lane could be compromised;

o Crenshaw at W.66th Place, W.66th Street: Unclear if sIb left turn access preserved;

o Crenshaw at Hyde Park Blvd.: Unclear if left turn lanes preserved in both sIb and nIb;

o Crenshaw at W.63rd Street: Unclear if left turn lanes provided in both directions;

o Crenshaw from w.6ih to W.60th Streets: Unclear where mid-block left turn access is compromised. Mid-block left turn access into and out of properties from the continuous median lane along this stretch of Crenshaw is important to some properties' access.

ATIACHMENT A:

CRA/LA COMMENT LEITER DETAILS ON




o Crenshaw at W.60th Street: It appears that a sib left turn lane is provided by a nib left turn lane is not. Additionally, the 120- unit West Angelus Senior Housing Development is located at this intersection (SEC) as well as St. John's Catholic Elementary School (SWC), putting an imperative on maintaining full and complete safe access through the intersection for both vehicles and a wide range of pedestrian users.

o Crenshaw at W.59th Place: All left turn access appears blocked by LRT grade transition structure in both LRT Baseline and Option 4 alternatives.

• Potential Loss of Turning Movements. Effective Intersection Capacity and Other Traffic Impacts from W.59th Street to W.4Sth Street fLRT Baseline Configuration at Gradel. There are a number potential impacts that are of particular concern along this reach of the LRT Baseline corridor design. Among them are:

o Crenshaw at Slauson intersection: Essential that full capability for safe nib and sib turning movements be fully preserved. Volume II drawings (Drawing C-425) appear to indicate left-turn lanes are provided, but would want to confirm the full, safe preservation of traffic functions.

oWlS of Crenshaw to W. 57th Street;: The View Park Prep Charter High School is a major traffic generator which presently has unresolved dropoff, pick-up and parking conflicts. Current proposals call for a separate, dedicated loading andlor parking lane along this block face. The proposed curb adjustment does not appear to be consistent these proposals or with the need to remediate these conflicts. Left turn ingress and egress from W.57th to Crenshaw is important to maintain for this campus; it appears that the LRT Baseline design could compromise left turn access.

If the Crenshaw Transit Corridor is going to preclude the possibilities for resolving these traffic conflicts that are presently being pursued for this location, the DEIS/DEIR needs to provide appropriate and effective mitigation measures to resolve these land use traffic conflicts along this block face.

o Crenshaw at W.54th Street; It would appear (Drawing C-426) that all turning movements are being fully preserved at this intersection, but would want to confirm that this is the case. In any case, the preservation of left turn movements at this intersection is essential. West 54th Street is an important east-west corridor; its function and use levels seem to be under-estimated in the DEIS/DEIR count data [Appendix F, Tables F-1 and'F-2]. Additionally, CRA/LA is working with the site owners on a potential mixed use development at the southeast corner of this intersection. Southwest of this intersection is a major Economic Development Department office and Bank of America branch, both of which are heavily used by the community. Preserving full and safe

ATTACHMENT A:





access at this intersection for both vehicles and pedestrians must be assured.

o Crenshaw at W.50th Street: It would appear (Drawing C-427) that left turn access into and out of this off-set intersection is preserved. However, there is also a new curb line drawn across the entry point at this intersection. This would appear to close off the street, yet no cul-de-sac is shown in the street design. Please clarify what the design and function is for this intersection.

• Mature Median Street Trees. Mature street trees, particularly in the street median between 60th Street and Vernon Avenue, are mentioned as a visual resource (p.4-106; pp. 4-120 ff.) but not, in CRA/LA's estimation, given adequate consideration. In general, those segments of Crenshaw Boulevard proposed for at-grade operation (60th to 48thStreets and MLK to Exposition Boulevards) are wide and easily become barren and inhospitable without the visual relief provided by mature tree stock. Where there are losses of trees, there should be a commensurate level of mature forestation restored to the street. If it is not feasible to replace specimens in the median, then additional plantings should be made in the parkways to restore the overall ambience of the corridor.

• Transition to Below-Grade Configuration at 48th Street. As presently designed, the LRT line does not begin its transition from grade to below grade until it is north of W.48th Street. As a result, the transition structure appears to require the taking and removal of the Leimert Park gateway monument (designed parcel L- 32D) and likely otherwise obscure the potentials of this iconic viewpoint in the corridor. The DEISIDEIR does not specifically recognize this visual point of interest, but does recognize the unique scenic value of this corridor and its views north from so" Street (Exhibit A, p.4-106; Exhibit D-1, p.4-110). An important ingredient to the quality of this view are the mature trees in the median of this corridor, which the LRT Baseline will remove.

To help partially mitigate loss of visual quality and orientation (current and potential) that the gateway park provides, it would be recommended that the LRT Baseline design be modified to complete its descent before 48th Street, thereby removing the LRT line from this end of the viewshed and allowing the restoration of the gateway park and its monument features.

• Right-of-Way Take. Historic Resource Adverse Impacts of Traction Power Substation (TPSS). The LRT alternatives require a TPSS to be located somewhere between MLK and Rodeo. The DEIS/DEIR identifies a site for this TPSS, labeled L-37 A, immediately adjacent the Angelus Funeral Home (3886 Crenshaw Blvd). In section 2.3.4.5, the TPSS is described as requiring a pad 14 by 43 feet, housed in 16-foot high enclosure.

ATTACHMENT A:





It has been LACMTA's typical practice to locate TPSS facilities entirely above grade and directly on the frontage property line, thus creating the maximum adverse impact. While it is understood that there must be ready access for heavy equipment to quickly service (and, if necessary, remove and replace) major substation components, this can still allow for some flexibility in design and siting. A major reduction in impact can be achieved by situating the TPSS in a below grade vault where the surface area can revert to use as parking, alleyways or other open space use. Removal of the vault deck and heavy components will require the use of a crane, but this equipment is often required even when the equipment is on-grade. While removing the TPSS's visual impacts, below-grade siting also can serve to quiet potential noise and vibration, which could be a concern next to the Funeral Home. Another siting mitigation would be to avoid situating the TPSS on the front property line, but instead at least move it the back area of a surface parking lot where it could be behind building frontages.

CRA/LA respectfully requests that LACMTA employ these and other mitigation measures to the greatest extent possible in siting this installation. If this TPSS installation were to be done in a typical fashion, it would have a Significantly adverse effect on this stretch of commercial frontage.

• Right-of-Way Takes Proposed North of Coliseum Road. There appears to be considerable inconsistencies in the parcel acquisitions listed, their APN data and their listed locations. According to some tables in the DEIS/DEIR, various parcels along the east side of Crenshaw Boulevard north of Coliseum Road, now part of major commercial development proposals, are listed as "Full Takes". This would result in LACMTA acquiring huge parcels of prime land that CRA/LA presently has in discussion for development. It may be that LACMTA has concluded that the partial takes, as is indicated in the engineering drawings (volume II, C-434) are not feasible severances-a concern that CRA/LA shares.

We believe that these kinds of prospective right-of-way impacts cannot be justified and should further make the case for incorporating Option 6 into the LRT Baseline and removing the need for these very extensive property acquisitions.

• West Boulevard Station Location. CRA/LA believes that an alternative location for the station at West Boulevard, moved to the east of West Boulevard in a CRA/LA redevelopment project area, merits study. If situated with improved access and coordinated development, a station location east of West Boulevard could be ultimately be made into a more effective and attractive station complex than the LRT Baseline location. CRA/LA would advocate for consideration of this station location and, should it be selected, would look forward to working with LACMTA on a coordinated station area design and development plan for this location.

ATTACHMENT A:





Management and Mitigation of Parking Impacts

The proposed project creates two types of potentially adverse parking impacts:

• Loss of on-street parking due to street r-o-w because of rail facilities in and around the street and

• Induced parking demand as a result of transit patrons wanting to drive to the stations to use the rail system.

Lost Parking Spaces. According to Table 5-1 (p. 5-4), the LRT Baseline alternative would result in a loss of 295 on-street parking spaces. The great majority of this loss appears to be in the at-grade segment between W.60th and W.48th Streets. In addition to these losses, there appears to be significant losses of on-street parking between 6ih and so" that now has peak hour restrictions but would be permanently lost in the event that Option 4 of the LRT alternative is not adopted. In addition to on-street parking losses, approximately 69 on-street parking spaces are indicated as being lost in the LRT Baseline design in the segment between MLK and the Exposition Line.

On-street parking is essential to the viability of some smaller businesses in older parts of the corridor. In our review of the DEIS/DEIR (pp.3-25 ff., pp.3-63, 64) there was not an adequate analysis of where these impacts might occur, who would be affected, and a clear definition of the mitigation measures that are going to be programmed.

Of particular concern is the Hyde Park portion of the corridor (W.6ih to W.60th is a mixed business and residential area that is severely under-parked. Perhaps because of the existing peak-hour parking restrictions, the DEIS/DEIR seems to have made some assumptions and not treated the impacts to this area in depth. Should LRT Option 4 not be adopted, the DEISIDEIR must much more definitively identify potential impacts to parking resources in this area and identify its program to provide replacement spaces to fully mitigate any losses.

Also needing significant, additional analysis are the areas between W.60th Street and between W.48th Street and from W.39th to Exposition. To the extent that portions of the on-street parking has to be removed (or significantly limited in use), a clear program for providing replacement parking needs to identified as a mitigation measure, with appropriate attention to location, access, proximity to affected businesses and users, appearance, and resulting pedestrian environment.

Several developments would be directly and adversely impacted either by property condemnation or vehicular accessibility to their sites. Among these developments would the District Square project, located on the southeast corner of Rodeo and Crenshaw Boulevard. District Square is 318,000 sq ft retail center which will provide 491 construction jobs and 600 permanent jobs. This project is scheduled for the December

ATTACHMENT A:





15, 2009 CRA/LA Board of Commissioners meeting to request approval of the Owner Participation Agreement. According to the DEIS/DEIR, the LRT Baseline alternative could require the condemnation of a large portion of the site. In addition, to the safety issues outlined by the Los Angeles Department of Transportation (LADOT) the severe impact to the economic opportunity and vitality of the center is unavoidable with the atgrade option.

Some parts of the DEIS/DEIR seem to imply that losses of on-street parking will simply be absorbed by parking spaces that were observed off-street parking lots. This is simply not an acceptable or viable mitigation approach. Most all of those parking resources are owned by particular businesses and not available for public use. Even if LACMTA were to attempt to purchase these parking resources to mitigate the loss of public parking, in many cases those owners could not sell their parking without losing the code-required parking required to continue operating their businesses.

The Crenshaw corridor is an economically impacted area. That LACMTA would appear to asking the business community to sustain significant net, uncompensated losses in local public parking supply is simply not appropriate and acceptable. The DEISIDEIR must much more thoroughly identify, evaluate and define effective mitigation measures for the parking displaced by the Crenshaw Transit Corridor facilities.

Transit Station Parking Needs. Table 2-5 (p.2-44) lists "potential parking spaces at station locations. At the Exposition terminus, it identifies the need for 300-870 parking " ... Spaces [to] share with [the] Exposition LRT Line at a common station location at Crenshaw/Exposition[.] Park-and-Ride facilities at this location are assumed to be initially developed as part of the Exposition Line project."

At the Martin Luther King Jr. Station, the need for 100-300 spaces are identified. At Crenshaw and Slauson, although it could be expected to be a major intercept station for traffic coming along the Route 90 corridor from the west, the DEISIDEIR fails to identify what number of spaces the transit station function is going to need and how it is proposed to provide those spaces. The DEISIDEIR similarly fails to definitively evaluate the station parking impacts and mitigation measures for the Vernon Station of LRT Option 5.

It appears that LACMTA is assuming that it will be able to simply purchase the needed parking supplies needed for effective Crenshaw Transit Corridor park-and-ride operations at the transit corridor stations from commercial property owners abutting those stations and that this can be done without adversely impacting the commercial viability of these owner's investments. The DEIS/DEIR needs to much more thoroughly identify the overall accessibility needs of each station, what kind of parking needs each station can be expected to have, what are the various scenarios for effectively responding to those parking needs, and defining the feasible mitigation response that LACMTA is committing itself to for managing the parking impacts and needs created by the Crenshaw Transit Corridor stations.

ATTACHMENT A:





The Need for a Coordinated. Collaborative Approach to Managing Parking Impacts. As noted above, the Crenshaw Transit Corridor project is going to create a wide range of parking impacts. Rather than LACMTA mitigating these impacts in a piecemeal fashion, however, it is suggested that it would be more effective for the long-term benefit of both LACMTA and the local Crenshaw community to address parking issues in the context of local area parking and access management districts formed around areas of impact. LACMTA would be asked to participate in these local districts to the extent its facilities and operations required mitigating actions. But the larger objectives of these parking and access management districts would be to-

• Coordinate and integrate transit patron parking and access needs with those of local area businesses and, in some cases, perhaps local residents;

• Achieve, through coordinated management, more efficient use of available parking supplies and reduce unnecessary confusion and congestion, especially around station-area intersections;

• Create a comprehensive, multi-modal planning framework to manage parking and pedestrian access needs in precincts served by rail transit facilities, to promote transitions away from single occupant vehicleuse and towards more sustainable modes of local access;

• Directly and actively involve local businesses and residents in the planning and implementation of more measures for more sustainable local access and circulation around rail facilities.

It would be CRA/LA's intent, over time as regional rail transit services are provided and new development is attracted to the corridor, to try to broadly restrain the growth in parking and perhaps ultimately reduce the amount of parking provided relative to development. CRA/LA and other City departments would look forward to partnering with LACMTA on local parking and access management districts that could help achieve these public policy goals.

Station Area Development Potentials

As fundamental as providing quick, sustainable transit travel is to the success of the Crenshaw Transit Corridor project, another very important measure of success will be how effectively the effects of the Corridor's transit stations can be harnessed to create hubs of more sustainable, walkable commercial activity and vitality.

The DEIS/DEIR has the task of identifying the range of adverse and potentially adverse impacts of installing what should promise to be a very important and positive investment in high-speed rail transit. While the DEISIDEIR is called upon to provide appropriate mitigation measures, these measures taken alone and in the narrower sense fail both the potentials of the transit system investment and the community that the transit system

ATTACHMENT A:





serves. What CRA/LA would propose is that the DEIS/DEIR incorporate into the project program, as part of a larger, strategic mitigation framework, a long-term collaborative station area planning process. This collaborative planning and development process would partner LACMTA with CRA/LA and other City departments. It would be undertaken in phases, concentrating on the primary areas of concern and commitment the partners had as the project develops. As CRA/LA envisions this process, it would incorporate planning for joint station area development potentials, planning and programming for station area parking and access, and possibly concerns such as construction impact management and local employment development (discussed below).

Construction Impact Mitigation

Reducing the Impact of Below Grade Construction. There has been extensive preceding discussion of the desirability of putting the entirety of the Crenshaw Boulevard segment of the project below ground. As discussed in the DEISIDEIR as individual options, much or all of this construction would be anticipated to be constructed by cut-and-cover.

To the previously stated merits of putting the entirety of the Crenshaw reach in subway, the DEIS/DEIR should evaluate the possibility that this configuration would make it much more feasible to tunnel boring machines for much more if not all of the line's construction (except for the station box construction). The possibility that this could preclude the need for a great deal of surface disruption, expedite the construction schedule and, possibly, reduce the overall cost per-foot basis for underground construction needs to be assessed.

Reducing Adverse Business Impacts of Construction. It has been part of CRA/LA's mission to help revitalize businesses and to attract new economic activity and development to the Crenshaw district since the formation of the various redevelopment project areas. There are many businesses in the corridor that have been long marginalized and have now been even more impacted by the current economy. CRA/LA is very concerned that transit construction-related activities could have, if not fully and effectively mitigated, devastating effects on many of these businesses. The marginal circumstances of many of these businesses and the current economy create the need for measures and responses that are likely to go beyond the conventions of construction impact management.

CRA/LA would propose to formally partner with LACMTA in a program of concerted responses and customized support to local businesses directly or indirectly impacted by construction, with the goal of very substantially reducing the loss of businesses and business activity that could otherwise occur during construction.

ATTACHMENT A:





Local Resident Employment Participation

The CRA/LA and City of Los Angeles has adopted polices and procedures for its project areas to build livable and sustainable communities. As a significant portion of the Crenshaw Transit Corridor project is located within the City and CRA/LA project areas, we would strongly urge that the project's construction should conform to these policies. The policies include:

• Construction Careers program participation

• Joint Labor Agreements

• Local Hiring goals and program support

• Contractor participation.

Recent experience with LACMTA in meeting community expectations in participating in transit construction employment has been notably disappointing. This pattern must be decisively reversed with the Crenshaw Transit Corridor project.

CRA/LA believes that the best assurance of meeting the goals and expectations for community hiring could be brought about by LACMTA formally partnering with CRA/LA and the utilization of our established capabilities in managing project labor agreements in our redevelopment project areas.

Bicycles

As delineated in Figure 3-14 (p.3-13) of the DEIS/DEIR, there are (Class I and III) bicycle facilities proposed for Slauson and Martin Luther King Jr. Blvd. CRA/LA would respectfully request that LACMTA, should it pursue the street reconstructions involved in the LRT Baseline give serious consideration to incorporating a bicycle linkage (Class II or better facility) on Crenshaw between Slauson and the Crenshaw and Exposition station complex.

The DEISIDEIR needs to reflect the need for each LRT station to provide high-security, Class I bicycle parking accommodations.

ATTACHMENT B:

DEPARTMENT OF CITY PLANNING COMMENT LEDER REGARDING THE CRENSHAW TRANSIT CORRIDOR PROJECT DEIS/DEIR

October 26, 2009

CRA LTR On Crenshaw Line DEIR

Uploaded by

Document Information

Original Title

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

CRA LTR On Crenshaw Line DEIR

Uploaded by

Copyright:

Available Formats

DATE I

Community Redevelopment Agency of the CITY OF LOS ANGELES

You might also like

CRA LTR On Crenshaw Line DEIR

Uploaded by

Document Information

Original Title

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

CRA LTR On Crenshaw Line DEIR

Uploaded by

Copyright:

Available Formats

﻿DATE I

Community Redevelopment Agency of the CITY OF LOS ANGELES

You might also like

DATE I