SCH Number: 1982092310

File: O7-LA-710 (SR 710)

Project: EFIS 0700000191 (EA 187900)
State Route 710 North Project

Comments on the SR-710 DEIR/DEIS Submitted to Caltrans by

Southern California Scientists and Colleagues Who Study the Health Effects of Air
Pollution and Other Public Health Impacts from
Transportation Infrastructure Projects
and Related Traffic*

Mr. Garrett Damrath

Chief Environmental Planner
Caltrans District 7
Division of Environmental Planning
100 S. Main Street, MS-16A
Los Angeles, CA 90012
Submitted via website link
Hard copy and CD-Rom hand-delivered to District 7 Caltrans
Dear Mr. Damrath:
As we understand it, a DEIR/EIS is designed to help policymakers better understand the
potential impacts of their decisions concerning infrastructure and other projects. As
documented below, we do not believe the DEIR/DEIS effectively or successfully serves this
purpose. Policymakers reading this version of the DEIR/EIS will have a very difficult time
understanding what the air pollution impacts of a proposed SR-710 extension would be,
particularly as it pertains to the tunnel alternative.
We respectfully submit our concerns as a group of scientists and public health experts. Some
of us have been studying the health effects of air pollution in southern California individually and
collectively for decades. Others are experts in public health, working to ensure that the
community is adequately informed of the potential health impacts of new infrastructure projects,
and that proposed infrastructure projects are designed to minimize environmental and health
impacts.
Southern California has a world-class community of scientists and experts studying the health
impacts of air pollution and other impacts from infrastructure projects that is unique in this field.
Despite there being hundreds upon hundreds of published papers on this topic by investigators
from the University of Southern California (USC), University of California, Los Angeles and
Irvine (UCLA and UCI), and other investigators around the world, the DEIR is completely lacking
in a discussion of the health effects of air pollution related to the alternatives, other than diffuse
claims that the project will improve air quality.

We are particularly concerned about the increased number of vehicles (and their emissions) that
will chose to use a tunnel, if it is selected as an alternative, and the lack of attention in the
DEIR/EIS to the increased vehicle emissions on the SR-710 north of the SR-60 Freeway up to
the south tunnel portal. We are also very concerned about vehicle emissions inside the tunnel
and emissions that will be vented out but not necessarily captured by a filter and about the
lack of discussion of the health effects from portal emissions, near-roadway emissions, ultrafine
particles and diesel exhaust/particulate emissions.
We are concerned about other impacts, such as noise, as described below, and of the failure of
the DEIR/EIS to address environmental justice concerns in the most vulnerable communities,
such as lower-income Latino communities in East Los Angeles.
Our overall evaluation of this document and its attachments leads us to conclude the following:
The DEIR/DEIS has so many deficiencies related to a lack of information on potential
health impacts of the project, particularly of the Tunnel and the LRT alternatives, that we
recommend that the DEIR/DEIS be redone and recirculated for review and comment.
This important determination is based upon our identification of the following deficiencies related
to public health in the DEIR/EIS:
1. Failure to describe, discuss or cite any of the dozens of studies from around the
world, including many from Southern California, linking exposure to near roadway
emissions with a wide range of health effects, including, as examples:

Exacerbation of asthma and new cases of asthma (Gauderman et al. 2005;

McConnell et al, 2006; McConnell et al, 2007; Jerrett et al, 2008; Perez L et al ,
2012)
Reduced lung function (Gauderman et al, 2007; Urman et al, 2014)
Cardiovascular heart disease (Brook et al, 2010; Gan et al. 2010, 2011; Hoffmann
et al. 2006; Kan et al. 2008)
Preterm birth, low birth weight and pregnancy disorders (Wu et al, 2009, 2011);
Wilhelm et al, 2012)
Autism (Volk et al, 2011, 2013)
Aging of the brain (Chen et al, 2015)
Possibly obesity and Type 2 diabetes (Weinmayr, G et al, 2015; McConnell et al,
2015)
Overall burden of disease related to near roadway air pollution (Perez et al,
20090; Brandt et al, 2012)

2. Failure to provide an accurate statement of the Purpose and Need of the Project
with regard to creating a 30-mile connected truck corridor to and from the Ports,
which Metro has claimed is a value of this project.
a. Legally, the DEIR/EIS is required to have a well-described and legitimate
discussion of why the project is needed and its purpose. There is a failure in the
DEIR/DEISs purpose and need statement to acknowledge that a major reason
for the tunnel alternative in this project is to move goods to and from the Ports of
Los Angeles and Long Beach. Obviously, the SR-710 tunnel, when linked to the
I-710 goods movement corridor, would create a 30-mile goods movement truck
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corridor, yet the words goods movement or freight do not appear in the
purpose and need statement.
b. Metro officials have previously stated that this, indeed, is why completing the 710
north gap closure is so valuable. Please see this 2011 statement by Douglas
Failing, then executive director of highway programs for Metro: The 710 north
gap closure between the I-10 and the I-210 would complete the natural goods
corridor that was begun several decades ago. Please find this quotation at:
http://www.metro.net/news/simple_pr/metro s-highway-program-shifts-high-gear18-new-pro/
c. Thus, the Purpose and Need of the Project, as stated, is erroneous because it
fails to mention that a major purpose of the SR-710 tunnel project is to complete
the goods movement corridor which heads north from the Ports of Los Angeles
and Long Beach, between the I-10 and the I-210 Freeways. For this reason
alone, the DEIR/EIS merits revision and recirculation for comments and
additional opportunity for review.
3. Failure for the DEIR/EIS to accurately inform the public and policy decisionmakers about the volume and impact of heavy duty diesel big rig trucks in the
tunnel and along the lengthy approach to the tunnels portals.
a. The DEIR/DEISs truck traffic estimates greatly minimize freight traffic, instead
relying on a set of FAQs about goods movement which have no citations, admit
that detailed truck studies were not performed, and are completely misleading to
the public. An example is the following statement from the FAQs: Construction
of a tunnel would not be expected to alter truck traffic destinations. Cars and
trucks that are already going north (via surface streets or other freeways) may
choose to take a tunnel to reduce their travel time, but no additional truck traffic
will go north. See
http://media.metro.net/projects_studies/sr_710/images/sr_710_faqs_goods_mov
ement.pdf. The public and policy makers deserve an accurate and appropriate
method for estimating truck traffic in the Tunnel Alternatives from the Ports and
elsewhere and the DEIR/DEIS should provide one. It currently does not.
We request that Caltrans and Metro permanently remove this misleading set of
Frequently Asked Questions from its web portals and websites.
b. On page 5-35 of the Air Quality Assessment, the DEIR/DEIS states that there is
a possibility that some traffic currently utilizing other routes would be attracted to
use the new facility. This ignores the widely accepted concept of induced
demand, in which increases in traffic capacity are quickly met with increased
traffic volumes whenever a new freeway is built or new lanes added. Certainly
Caltrans is aware of the concept of induced demand when a new freeway is
built. In a 2014 draft policy brief for the California Air Resources Board, two
experts concluded that there is usually a growth in both vehicle miles traveled
(that is there is induced demand, as more people choose to use the new
highway) and in greenhouse gas emissions after a capacity expansion of a
highway. They argue that the induced demand generally offsets any reductions
in greenhouse gas (GHG) emissions that would result from improved traffic flow
(Handy and Boarnet, 2014. Given the induced travel effect, capacity expansion
has limited potential as a strategy for reducing congestion, Handy and Boarnet
conclude. (See
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http://www.arb.ca.gov/cc/sb375/policies/hwycapacity/highway_capacity_brief-421-14.pdf.
c. Truck estimates vary widely throughout the document, and these assumptions
are critical to the Health Risk Assessment, the Air Quality Assessment, and other
issues in the DEIR/EIS.
i. We note that the SR-710 tunnel project would allow, for the first time,
trucks to travel north from the Ports for a continuous 30 miles on the I-710
to SR-710 Freeway directly to the I-210 (and then on north to the Central
Valley or east to distribution centers in Riverside and San Bernardino
Counties, or other points East). But Table 5.6 on increased VMT that will
occur with tunnel project in the Air Quality Assessment makes little sense.
It seems to show that at the I-210 eastbound on-ramp, there would be
only about 400 more vehicles a day on the on-ramp if the tunnel allowed
trucks than if it did not.
ii. Inexplicably, Table 3.5.7 on Truck Performance (see below) shows nearly
identical Vehicle Miles Traveled (VMT) for trucks in the No Build, Light
Rail, and Tunnel Alternatives. How can the same VMT for trucks
traveling in the No Trucks Allowed Tunnels occur as in tunnels that
allow trucks? It is imperative to have a valid estimation of trucks in the
tunnel if one is to have a valid Health Risk Assessment.
Table 1. 2035 Truck VMT with various alternatives, from the DEIR/EIS

iii. In contrast to the above, which estimates a minimal amount of trucks

expected with the Tunnel Alternative, Table 4-12 shows that in 2035 there
would be 25,600 trucks a day in the tunnel.

Table 2. 2035 modeled truck counts along the I-710 and in the tunnel from
the DEIR/EIS

The above table also shows that on the I-710 north of Floral Drive there
would be 26,500 trucks anticipated in 2035. Floral Drive is between the
SR-60 and the I-10 Freeway. This is a clear indication that East Los
Angeles will be seriously impacted by truck traffic when the tunnel opens.
See map below for where Floral Drive is.

Map 1. Red mark and blue line showing east-west location of Floral
Drive in East L.A. This can be matched with truck counts in Caltrans
table above.

Floral Drive

iv.

The current volume of trucks that travel north of the SR-60 and north of
the I-10 on the I-710 Freeway were obtained from Caltrans online truck
counts and are shown below:
Map 2. Truck Counts Caltrans Data, 2013 in the study area

The above truck counts show that in 2013 there were 16,910 trucks (one way) on the I-710
north of the 5 Freeway. Some 4000 trucks exited on the SR-60. Another 11,000 trucks exited
on the I-10, meaning that only 1,239 trucks were left on the I-710 when it ended in Alhambra.
These data are from the following Caltrans table of truck counts:
Table 3. Caltrans truck counts along the I-710 during 2013

v.

When using data from the Table 4-12 in the DEIR/EIS, the following
maps show how many trucks are on the I-710 today in the study area
versus how many are predicted through modeling for the future, when the
tunnel is open.

Map 3. Comparison of truck counts in 2013 along the I-710 Freeway and 2035 predictions
if the tunnel alternative is selected.

vi.
4. Failure to describe or discuss studies and rulings that conclude that diesel
exhaust and diesel particulate are carcinogens, which is critical to understanding
the potential health risks of a tunnel alternative.
a. We note that once constructed both the single bore tunnel and the dual bore
tunnel would have diesel PM emissions greater than or equal to the 2025 and
2035 emissions (see page 35 of Executive Summary/DEIR/EIS).
b. Despite the above, concerns about the health impacts of diesel exhaust and
diesel PM are minimized in the DEIR/DEIS. We can locate no mention of the
1998 ruling by the California Air Resources Board naming diesel particulate as a
Toxic Air Contaminant because it causes cancer, nor of the 2012 ruling by the
World Health Organizations International Agency for Research on Cancer
(IARC) designating diesel exhaust as a Class I carcinogen.
c. Page 2-17 of the HRA includes a lengthy description of OEHHAs risk
assessment uncertainties in 2002, but does not include anything about OEHHAs
diesel cancer risk assessment in 1998
(http://www.arb.ca.gov/toxics/dieseltac/part_b.pdf) which summarized more than
40 studies published before 1998 showing the diesel particulate causes cancer.
The HRA also does not describe the new OEHHA Diesel Cancer Risk Guidelines
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(proposed in 2014 and finalized in 2015). See 2014 proposal, issued before the
DEIR was released and 2015 final guidance:
http://oehha.ca.gov/air/hot_spots/riskguidancedraft2014.html
http://oehha.ca.gov/air/hot_spots/hotspots2015.html.
To our knowledge, the DEIR/EIS has no discussion of the multitude of studies
showing that diesel causes cancer and other health effects, summarized in the
the OEHHA document cited above or more recent studies, examples of which
are in the References (Zhu et al, 2002; Olsson et al, 2011; Silverman et al, 2012;
Attfield et al, 2012; Bhatia et al, 2012; Silverman et al, 2014; Vermeulen et al,
2014).
d. Pages 5-25 and 5-26 of the Air Quality Assessment fail to mention action in
California in 1998 that declared diesel as a Toxic Air Contaminant, with a unit risk
value of cancer potency for cancer risk. But it has several pages about concerns
and uncertainties expressed at the national level about diesel, from the Health
Effects Institute and U.S. EPA, in an apparent attempt to downplay the health
effects of diesel exhaust. For example: page 3.13-34 of the DEIR/EIS states
that: there is no national consensus on air dose-response values assumed to
protect the public health and welfare for MSAT compounds, and in particular for
diesel PM. The EPA and the Health Effects Institute have not established a basis
for quantitative risk assessment of diesel PM in ambient settings. There is also
the lack of a national consensus on an acceptable level of risk. However,
Californias OEHHA and the regions South Coast AQMD have, respectively,
adopted quantitative risk value and an acceptable level of risk, which the
DEIR/EIS fails to acknowledge.
5. Failure to use the most recent guidance from OEHHA in development of the Health
Risk assessment for determining cancer risk from exposure to diesel exhaust; the
HRA must be redone.
a. Although OEHHA had issued a draft of its new guidance document prior to
completion of the DEIR/EIS, the Health Risk Assessment fails to include
calculations for how this new guidance (now adopted) would impact the HRA.
http://oehha.ca.gov/air/hot_spots/riskguidancedraft2014.html. The HRA should
redone using the latest guidance document at:
http://oehha.ca.gov/air/hot_spots/hotspots2015.html.
6. The Health Risk Assessment (HRA) has many other flaws including inadequate
information about the most impacted individuals.
a. It fails to provide all necessary background assumptions about traffic volumes
and minimizes the air pollution in both the approach (above SR-60 to the I-10) to
and the exit from the South Portal (impacting East L.A. and Alhambra residents).
In addition, the HRA does not provide a map showing the most impacted
individuals/workers/students (see Table 3-4). An informative map must be
included. The HRA must be redone to address traffic approaching the South
Portal, to better address the cancer risk which is currently claimed to be zero
due to the ventilation towers (see page ES-3) which states Due to the
installation of the particulate matter control system at the tunnel ventilation
system, vehicle emissions from the tunnel ventilation towers contribute minimally
to the cancer risks at the MEIR and MEIW locations (that is most impacted
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resident and most impacted worker). Please provide page numbers for these
calculations.
b. The Health Risk Assesment states that the maximum student cancer risk is at
Maranatha H.S. west of the SR-710 near the north portal. Did Caltrans alert this
school to the increased noise and cancer risk that this project would bring to the
school and its students and teachers?
c. Page 3-8 of the HRA states that the area with cancer risk greater than 10 in one
million is a narrow strip around the north and south portals and the adjacent
interchange. There appears to be no analyses performed for increased cancer
risks between the SR-60 and the portal of the tunnel even though there would be
thousands more vehicles on the freeway when the tunnel opens. This increase
in traffic on the I-710 due to the tunnel opening is completely ignored in the
DEIR/EIS and its analyses for cancer risk and for noise (see below). This is a
major flaw in the HRA and the DEIR/EIS.
7. Failure to include information on the health impacts of ultrafine particles (UFPs),
the levels of exposure to passengers traveling in the tunnel, whether the UFPs
would be captured by the particulate filters that are planned in the ventilation
stacks, and how far from the portals and approach roads the ultrafine particles
would travel.
a. Ultrafine particles (UFP; aerodynamic diameter < 0.1 micrometers) are a
ubiquitous exposure in the urban environment and are elevated near highways
(Fuller et al, 2012; Zhu et al, 2002a; Zhu et al 2002b; Zhu et al 2006). These
particles are considered especially toxic because they can enter the lung, and
stay there or get into the systemic circulation.
b. A study done by UCLA and USC researchers documented very high
concentration of ultrafine particles in close proximity to the I-710 Freeway in SE
Los Angeles. It found that the pollutants start to level off at about 150 meters
from the freeway and are back to background in about 300 meters [985 feet]
from the freeway during daytime dilution conditions. See diagram below from the
study (Zhu et al, 2002). In fact, the impacts for ultrafine particles are 10 to 15
times further from the source than are the daytime impacts.

10

Figure 1. Ultrafine particle size distributions near the I-710 Freeway

c. These researchers from UCLA and USC also found that at night time when winds
shifted, the pollutant levels of ultrafine particles did not reach background until
300 meters from the freeway (Zhu et al, 2006).
d. Other researchers from UCLA and USC also found that at night time when winds
decrease, the concentrations of ultrafine particles did not reach background until
2500 feet from the freeway (Hu et al., 2009).
e. In fact, the impacts for ultrafine particles are 10 to 15 times further from the
source than are the daytime impacts.
f. The DEIR/EIS contains no estimates on what levels of UFPs one would expect to
find when driving through the enclosed environment of the tunnel, nor what
ambient concentrations might be expected downwind from the ventilation stacks
or portals.
g. Another study, by UC Davis researchers looked at a number of studies with
regard to concentrations from the roadways (Karner et al, 2010). They conclude:
In general, concentrations decay to background within a few hundred meters
downwind of a road, although studies measuring pollutants solely in the evening
hours indicate that higher concentrations persist beyond 500 m (1640 feet)
(citing Zhu et al, 2006). Other researchers from UCLA and USC also found that
at night time when winds decrease, the concentrations of ultrafine particles did
not reach background until 2500 feet from the freeway (Hu et al., 2009). See
graph below from Hu et al, 2009.
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Figure 2. Ultrafine particles, distance from freeway

Also see table below from the UC Davis study which shows that many pollutants
do not reach background level until 1000 meters or more (Karner et al, 2010).
Table 4. UC Davis Study summary

The authors concluded that background normalized results suggest that a range of
approximately 160-400 meters [ 525-1312 feet ] is sufficient to reach background
concentrations for the majority of pollutants.
Dozens of studies on ultrafine particles by investigators at the UCLA Particle Center
directed by John Froines and by Costas Sioutas and his laboratory at USC are not
included in any references or discussion in the DEIR/EIS. In fact, there are no
12

references to any studies on ultrafine particles, which is of great importance to the

building of a tunnel alternative for the SR-710. (Examples: Delfino et al, 2005; Fanning
et al, 2007; Kleinman et al, 2009; Fuller et al, 2012; Zhu et al, 2002; Zhu et al 2006)
8. The Air Quality Assessment (the AQA) has multiple flaws and does not provide
adequate information to either the public or policymakers who must select an
alternative.
a. The AQA mentions sensitive receptors but fails to include a map of where all of
the sensitive receptors are. Such a map must be included in a revised
DEIR/DEIS. The public and policymakers cannot be expected to imagine
where the most sensitive receptors are based on seven pages of coordinates
rather than visually presenting them on a map in the DEIR/EIS.
b. The Air Quality Assessment fails to describe operating filtration specifications of
the ventilation system that will be installed in the tunnel and in the two ventilation
stacks, making it nearly impossible to determine the accuracy of the claim that
the stacks will remove 80% plus of the particles and gases.
c. Air quality levels are shown in Table 3.13.1 at the South Wilson Pasadena
station, but fail to show PM2.5 levels for 2013, without an explanation. Failing to
include the most recent levels for a significant pollutant is not acceptable. Similar
problem with Tables 4-1 and 4-2 of the air quality analysis which fail to show
PM10 levels for multiple years at the Pasadena station.
d. The assessment sometimes refers to tunnel mitigation measures as scrubbers
and other times as filtration devices. There is no discussion of best practices
in ventilating tunnels throughout the world. Thus neither the public nor
policymakers can evaluate the efficacy of the mitigation measures suggested in
the context of experiences elsewhere.
e. If a tunnel alternative is selected, there needs to be a better evaluation of what
the contaminant levels and potential health risks inside the tunnel would be for
those using the 4-mile tunnel. This needs to include truck estimates, based on
validated truck studies (which have not been conducted according to the FAQs).
A recent study (Orru et al, 2015.) estimated that there could be increased
mortality due to tunnel exposures for those frequently using a proposed high
volume urban tunnel in Stockholm.
f. If a tunnel alternative is selected, there needs to be more information about the
emissions and air dispersion from both portals of the tunnel and from the tunnels
ventilation stacks. The stacks are designed to primarily remove particles, not
gases. Several experts have evaluated the tunnel ventilation and have submitted
a separate set of comments on that topic.
g. We request that Caltrans/Metro describe and detail the maintenance plans for
how they will maintain the filtration devices as part of the tunnel air pollution
control plan. This cannot be found in the DEIR/EIS.
h. More information is needed to advise the public about details of an exhaust duct
along the entire length of the tunnel and jet fans within the tunnel. We can find
no details about this technology.
9. Failure to estimate what the pollution levels will be at the North and South Portals.
a. These portals are near schools and an acute care hospital and the air that rushes
out from traffic will not be filtered at either portal. A voluminous medical literature
has demonstrated the acute effects of particulate pollution on heart attacks, yet
13

there is no consideration of the potential impact on patients with heart attacks at

Huntington Hospital at high risk of lethal post-infarct arrhythmias.
i. We request that if we are incorrect and the DEIR/EIS includes information
about these effects, that the pages on this be made public and sent to u
as commenters.
10. The DEIR/DEIS includes a faulty study area that fails to include impacted parts
of unincorporated East Los Angeles, making this an environmental justice issue.
a. The study area is described as approximately 100 square miles and generally
bounded by I-210 on the north, I-605 on the east, I-10 on the south, and I-5 and
SR 2 on the west. (See front page of DEIR/DEIR). That means that the area
between the SR-60 and the I-10 adjacent to the I-710 has not been studied with
regard to the Freeway Tunnel Alternatives, thus failing to recognize the immense
impact on East L.A. that vehicle traffic will create as drivers travel in or out of the
South Portal. (See map below). The map below shows the study area but the
part of East L.A. that is shown is only studied with regard to the LRT alternative,
not for the tunnel alternative
Map 4. DEIR/EIS Study Area. Area circled was studied in the DEIR/EIS for the Light Rail
Alternative but apparently not for the tunnel alternatives.

b. In addition, the I-710 South DEIR/EIS evaluates impacts only from the south I710 north to the SR-60, meaning that the East L.A. stretch of the I-710 is not
evaluated in either DEIR/DEIS. East L.A. is 97% Hispanic, and there are multiple
14

sensitive receptors in this area. Failure to discuss the impacts of increased

emissions and traffic in East LA make this is an environmental justice issue.

Map 5. The SR-710 DEIR/EIS study area exclusion zone. East L.A. was studied only for the Light Rail
Alternative. It was not studied for volumes of additional truck or other vehicle traffic nor for noise
mitigation nor for cancer risk.

c. Table 3-1 claims that there will be a negative cancer risk (that is reduced) as a
result of building the tunnel alternative.
d. Also Table 3-4 calculates the incremental cancer risks for various alternatives.
For some unexplained reason no addresses near the South Portal are included
(See page 3-6 of HRA). We note that the text of the HRA states that localized
15

cancer risk increases occur mostly near the tunnel portal areas and extend to the
nearby interchanges and highways that vehicles would use as the main routes to
or from the new freeway tunnel. In the south, cancer risks would increase
near the south portal and extend south to the SR 710/I-10 interchange.
e. In fact, the cancer risks will not stop at the SR 710/1-10 interchange; they must
be evaluated for the area within the area above, extending down to the SR-60.
There will be thousands more trucks traversing the I-710 between the SR-60 and
the SR-710 and these impacts of adjacent communities are not considered in
SR-710 DEIR/EIS
i. If the 25,000 pages of the DEIR/EIS include information about elevated
cancer risk from more traffic and more trucks on the I-710 north of SR-60,
please provide the page numbers where this information appears.
ii. Again, this area of East L.A. is not considered in the DEIR/EIS and HRA
as though it does not exist and will not be impacted. This is a serious
flaw and an environmental justice issue in the DEIR/EIS and HRA. (See
page 3-8 of HRA).
f. Despite claims to the contrary in the DEIR/DEIS, if a tunnel alternative is
selected, there will be significantly more traffic on the existing stretch of the I-710
Freeway heading north between the SR-60 and the I-10.
i. The DEIR/DEIS must perform an evaluation of the air pollution impacts on
homes and schools on this stretch of the I-710. Currently, homes and
schools in East L.A. are evaluated only for the light rail alternative. There
is no analysis of noise or air pollution impacts in this area, although it will
be heavily affected by truck traffic from the Ports of Los Angeles and
Long Beach traveling to or from the new tunnel. This is an environmental
justice issue.
11. The DEIR identifies high risk receptors near the north portal but not near the
south portal. In Table 3-4 of the HRA, a number of higher risk receptors are identified.
Although there are higher risk receptors identified near the NORTH portal, there are
none identified near the SOUTH portal. In addition, there is no map showing the areas
with highest risk at the South Portal. Although page 3-8 of the HRA states that cancer
risks would increase near the South Portal, there is no table showing the locations where
that would occur. There need to be maps of the high risk receptors at both portals.
12. The DEIR fails to look at zero emissions technology either for trucks going
through the tunnel or for its Bus Rapid Transit (BRT) alternative. Although Metro is
the lead agency in the region of a collaborative on use of zero emissions technologies
for transportation (see http://www.metro.net/projects/countywide-zero-emission-truckscollaborative/), there is no discussion of requiring that trucks using the tunnel be zero
emission technology nor of having truck age restrictions so that only newer trucks could
use the tunnel. Although Metro has just bought five battery-electric buses for its fleet,
there is no mention of using this zero emission technology for the BRT alternative, which
is listed as an alternative to the tunnel.
13. Concerns about increase noise levels from traffic entering and exiting the tunnel
and increased traffic volumes along the approaches to the tunnel are minimized in
the DEIR/EIS without scientifically sound analyses or even tables showing the
noise measurements and analyses.
16

a. The Project will generate two distinct types of noise impacts: construction
equipment noise and traffic noise from the cars and trucks that will travel along
the routes to the tunnel and into the tunnel. The World Health Organization
recognizes noise, and in particular traffic noise, as a serious public health
problem.
b. Given the proposed tunnel construction and increased traffic after it opens, it is
likely that the Project will result in significant noise impacts. In addition to
identifying residences, the revised document should seek to identify all sensitive
receptor sites including each motel and hotel, library, religious institution, hospital,
nursing home, active sports area, picnic area, recreation area, playground, active
sport area and park that would be potentially affected by noise from the additional
traffic that will be on the I-710 Freeway between SR-60 and the approach to the
tunnel, if that alternative is selected.
c. Given the serious nature of the Projects potential noise impacts, in conjunction
with the effect that increased noise levels have been shown to have on public
health, it is incumbent upon Caltrans through its DEIR/EIS to engage in a
meticulous assessment of these potential impacts. The documents analysis of
this issue, however, is subject to the same type of cursory analysis and critical
omissions found in the DEIR/S overall.
a. On page 3.3-34, the Community Impact section of the DEIR/DEIS states that
both Cal State LA and Marantha High School would experience permanent
noise increases of 3dB if the tunnel is built. The DEIR/EIR also states that
based on a visual inspection of the exteriors of these facilities and the warm
climate in the portion of Los Angeles County in which these facilities are
located, the University and the high school are likely to rely on air conditioning
in lieu of opening windows for ventilation; therefore the permanent noise level
increases with the freeway tunnel alternative would not adversely affect
their ability to serve the community. The DEIR/EIS community impacts report
goes on to state that outdoor events at these two campuses would not be
likely to be noise-sensitive because they typically would produce their own
noise. Noise analyses and impact determinations should not be made by
looking at a school or site. Measurements of existing and estimated future
noise impacts should be carefully considered and included in the DEIR/EIS
and -- if these have not been done, they should be done and then be included
in a revised and recirculated DEIR/EIS. This is a particularly egregious flaw in
the DEIR/EIS: evaluating noise impacts through a visual inspection is simply
unacceptable.
14. Noise mitigation measures are not included for the stretch of the I-710 Freeway
between the SR-60 and the I-10, with the exception of noise barriers at a Golf
Course and at a Park along the I-710 in this location.
a. A redone and recirculated DEIR/EIS must include noise analyses and noise
mitigation measures for the stretch of the I-710 Freeway north of the SR-60 and
south of the I-10, which includes East Los Angeles among other communities.
This is an environmental justice issue.

17

Maps 6 - 8. The noise mitigation area south of the I-10 along Corporate Center Drive,
north of the SR-60, from the DEIR/EIS. The shape includes a golf course in Monterey Park
and an adjacent park both alongside Corporate Center Drive. No noise mitigation measures are
described for any locations south of this location along the I-710 Freeway between the I-10 and
the SR-60, despite the huge volumes of additional traffic there will be, from trucks alone, on this
stretch of the Freeway as documented above:
Map 6:

Map 7

18

Map 8

Blue oval = area of noise

barrier mitigation near golf
course and park

Red oval = area including East Los

Angeles where no noise barriers are
proposed despite the dramatic
increase of truck traffic there will be
in this stretch of the I-710.

15. There are significant environmental justice issues from the various proposed
alternatives, but these have been minimized by Caltrans even though various
parts of East L.A. and El Sereno are documented in the DEIR/DEIS to have
minority communities that would be disproportionately impacted. Page 3.3-66/67
states that the Build Alternatives would not cause disproportionately high and adverse
effects on any minority or low-income populations under Executive Order 12898
regarding environmental justice. The graphic below shows the extent of the
environmental justice population census tracts just in the area north of the SR-60 and
South of the I-10 along the I-710 Freeway. An adequate l environmental justice analysis
must be conducted and presented for review to the public.
19

Map 9.

16. There was a clear lack of public participation and community outreach by Caltrans
and Metro to East L.A. in the process of developing the Light Rail (LRT)
Alternative.
a. This alternative appears to have been a surprise to many in East L.A., indicating
a lack of community engagement by Caltrans on this alternative. There are
significant environmental justice issues with the LRT alternative, such as (1) the
LRT would be elevated in East L.A. but be in an underground tunnel in wealthier
parts of the County, and (2) it would put an elevated rail line down a very popular
street in East L.A. See map below.
Map 10. The Light Rail alternative would be aerial (elevated) (shown in blue below) in
East L.A. and would be underground (pink) in other communities, including Pasadena.

20

b. Significant effects are identified in the DEIR/EIS about this alternative, which
would displace numerous businesses and adversely affect the community
character and cohesion of this part of East L.A., which we note is 97% Latino.
c. In addition, the LRT alternative would cause permanent noise level increases at
the Roybal Comprehensive Center, Catholic Mission of Soledad Church, Soledad
Enrichment Action, East L.A. Education Center and Casa Maravilla (East L.A.),
as well as Cal State L.A. (See page 3.3-33 of the Community Impacts report).
d. Many aspects of including this alternative, the lack of community awareness
about it, and selection of a location that would adversely affect community
cohesion and community character, indicate insensitivities by Caltrans and Metro
to the East L.A. Latino community an environmental justice issue. If this
alternative is selected, a new stand-alone DEIR/DEIS on this alternative should
be developed that includes extensive consultation with the East L.A. community.
For the reasons documented above, we request that the DEIR/DEIS be redone and recirculated
for public review. Thank you for your consideration of our comments.
Keck School of Medicine at University of Southern California
Department of Preventive Medicine
Andrea Hricko, MPH* **
Professor of Clinical Preventive Medicine
USC Keck School of Medicine
ahricko@usc.edu
323-442-3077
21

Rob McConnell, MD
Professor of Preventive Medicine
USC Keck School of Medicine
Scott Fruin, D.Env.
Assistant Professor of Preventive Medicine
USC Keck School of Medicine
Frank Gilliland, MD, PhD
Professor of Preventive Medicine
USC Keck School of Medicine
Ed Avol, MS
Professor of Preventive Medicine
USC Keck School of Medicine
Tracy Bastain, MPH, PhD
Assistant Professor of Clinical Preventive Medicine
Rima Habre, ScD
Assistant Professor of Clinical Preventive Medicine
Kiros Berhane, PhD
Professor of Preventive Medicine
University of Southern California Civil and Environmental Engineering
Constantinos Sioutas, ScD
Fred Champion Professor of Civil and Environmental Engineering
USC
UCLA Fielding School of Public Health
John Froines, PhD
Professor Emeritus
UCLA Fielding School of Public Health
Beate Ritz, M.D.
Professor
UCLA Fielding School of Public Health
Ondine S. von Ehrenstein, PhD, MPH, MSc
Associate Professor
UCLA Fielding School of Public Health
22

Suzanne Paulson, PhD

Professor of Atmospheric and Oceanic Sciences
UCLA
Michael Jerrett, PhD
Professor and Chair
Department of Environmental Health Sciences and
Director, Center for Occupational and Environmental Health
UCLA Fielding School of Public Health

UC Irvine:
Jun Wu, PhD
Associate Professor of Public Health
Ralph Delfino, MD
Professor Epidemiology
School of Medicine

*Primary contact for correspondence; all approvals for signatories are on file with Andrea
Hricko.
Andrea Hricko, MPH
Keck School of Medicine of USC
2001 North Soto Street
Los Angeles, CA 90089
ahricko@usc.edu
323-442-3077
**Please note that the affiliations of all signatories are for identification purposes only

CC:
Edmund G. Brown, Governor
State of California
governor@governor.ca.gov
23

Brian P. Kelly, Secretary

California State Transportation Agency
Brian.Kelly@CalSTA.ca.gov
Will Kempton, Executive Director
California Transportation Commission
Will.kempton@dot.ca.gov
Douglas Remedios
Please distribute to all CTC Commissioners
Douglas.remedios@dot.ca.gov

24

References
[1]

M. D. Attfield, P. L. Schleiff, J. H. Lubin, A. Blair, P. A. Stewart, R. Vermeulen, J. B. Coble, and D. T.

Silverman, The Diesel Exhaust in Miners Study: A Cohort Mortality Study With Emphasis on Lung
Cancer, Jnci-Journal Natl. Cancer Inst., vol. 104, no. 11, pp. 869883, 2012.

[2]

W. Babisch, Noise and health., Environ. Health Perspect., vol. 113, no. 1, pp. A145, Jan. 2005.

[3]

W. Babisch, B. Beule, M. Schust, N. Kersten, and H. Ising, Traffic noise and risk of myocardial
infarction., Epidemiology, vol. 16, no. 1, pp. 3340, Jan. 2005.

[4]

R. Beelen, G. Hoek, D. Houthuijs, P. a van den Brandt, R. a Goldbohm, P. Fischer, L. J. Schouten, B.

Armstrong, and B. Brunekreef, The joint association of air pollution and noise from road traffic
with cardiovascular mortality in a cohort study., Occup. Environ. Med., vol. 66, no. 4, pp. 243
250, 2009.

[5]

R. Bhatia, P. Lopipero, and A. H. Smith, Carcinogenicity of diesel-engine and gasoline-engine

exhausts and some nitroarenes - 1-s2.0-S1470204512702802-main.pdf, Lancet, vol. 13, pp. 663
664, 2012.

[6]

S. J. Brandt, L. Perez, N. Kunzli, F. Lurmann, and R. McConnell, Costs of childhood asthma due to
traffic-related pollution in two California communities, Eur. Respir. J., vol. 40, no. 2, pp. 363
370, 2012.

[7]

R. D. Brook, S. Rajagopalan, C. A. Pope, J. R. Brook, A. Bhatnagar, A. V Diez-Roux, F. Holguin, Y.

Hong, R. V Luepker, M. A. Mittleman, A. Peters, D. Siscovick, S. C. Smith, L. Whitsel, and J. D.
Kaufman, Particulate matter air pollution and cardiovascular disease: An update to the scientific
statement from the American Heart Association., Circulation, vol. 121, no. 21, pp. 233178, Jun.
2010.

[8]

J.-C. Chen, X. Wang, G. A. Wellenius, M. L. Serre, I. Driscoll, R. Casanova, J. J. McArdle, J. E.

Manson, H. C. Chui, and M. A. Espeland, Ambient Air Pollution and Neurotoxicity on Brain
Structure: Evidence from Womens Health Initiative Memory Study., Ann. Neurol., Jun. 2015.

[9]

C. Clark, R. Crombie, J. Head, I. Van Kamp, E. Van Kempen, and S. a. Stansfeld, Does trafficrelated air pollution explain associations of aircraft and road traffic noise exposure on childrens
health and cognition? A secondary analysis of the United Kingdom sample from the RANCH
project, Am. J. Epidemiol., vol. 176, no. 4, pp. 327337, 2012.

25

[10]

H. W. Davies, J. J. Vlaanderen, S. B. Henderson, and M. Brauer, Correlation between coexposures to noise and air pollution from traffic sources., Occup. Environ. Med., vol. 66, no. 5,
pp. 347350, 2009.

[11]

R. J. Delfino, C. Sioutas, and S. Malik, Potential Role of Ultrafine Particles in Associations

between Airborne Particle Mass and Cardiovascular Health, Environ. Health Perspect., vol. 113,
no. 8, pp. 934946, Mar. 2005.

[12]

E. W. Fenning, J. R. Froines, M. J. Utell, M. Lippmann, G. Oberdrster, M. Frampton, J. Godleski,

and T. V. Larson, Particulate matter (PM) research centers (1999-2005) and the role of
interdisciplinary center-based research, Environ. Health Perspect., vol. 117, no. 2, pp. 167174,
2009.

[13]

C. H. Fuller, D. Brugge, P. Williams, M. Mittleman, J. L. Durant, and J. D. Spengler, Estimation of

ultrafine particle concentrations at near-highway residences using data from local and central
monitors., Atmos. Environ. (1994)., vol. 57, pp. 257265, Sep. 2012.

[14]

W. Q. Gan, M. Koehoorn, H. W. Davies, P. A. Demers, L. Tamburic, and M. Brauer, Long-term

exposure to traffic-related air pollution and the risk of coronary heart disease hospitalization and
mortality., Environ. Health Perspect., vol. 119, no. 4, pp. 5017, Apr. 2011.

[15]

W. Q. Gan, L. Tamburic, H. W. Davies, P. A. Demers, M. Koehoorn, and M. Brauer, Changes in

residential proximity to road traffic and the risk of death from coronary heart disease.,
Epidemiology, vol. 21, no. 5, pp. 6429, Sep. 2010.

[16]

E. Garshick, F. Laden, J. E. Hart, M. E. Davis, E. A. Eisen, and T. J. Smith, Lung Cancer and
Elemental Carbon Exposure in Trucking Industry Workers, Env. Heal. Perspect, vol. 120, no. 9,
pp. 13011306, 2012.

[17]

W. J. Gauderman, H. Vora, R. McConnell, K. Berhane, F. Gilliland, D. Thomas, F. Lurmann, E. Avol,

N. Kunzli, M. Jerrett, and J. Peters, Effect of exposure to traffic on lung development from 10 to
18 years of age: a cohort study, Lancet, vol. 369, no. 9561, pp. 571577, 2007.

[18]

W. J. Gauderman, E. Avol, F. Lurmann, N. Kuenzli, F. Gilliland, J. Peters, and R. McConnell,

Childhood asthma and exposure to traffic and nitrogen dioxide., Epidemiology, vol. 16, no. 6,
pp. 73743, Nov. 2005.

[19]

S. Handy and M. G. Boarnet, DRAFT Policy Brief on Highway Capacity and Induced Travel, Sac,
2014. http://www.arb.ca.gov/cc/sb375/policies/hwycapacity/highway_capacity_brief-4-2114.pdf

[20]

B. Hoffmann, S. Moebus, A. Stang, E.-M. Beck, N. Dragano, S. Mhlenkamp, A. Schmermund, M.

Memmesheimer, K. Mann, R. Erbel, and K.-H. Jckel, Residence close to high traffic and
prevalence of coronary heart disease., Eur. Heart J., vol. 27, no. 22, pp. 2696702, Nov. 2006.

26

[21]

S. Hu, S. Fruin, K. Kozawa, S. Mara, S. E. Paulson, and A. M. Winer, A Wide Area of Air Pollutant
Impact Downwind of a Freeway during Pre-Sunrise Hours., Atmos. Environ. (1994)., vol. 43, no.
16, pp. 25412549, May 2009.

[22]

M. Jerrett, K. Shankardass, K. Berhane, W. J. Gauderman, N. Knzli, E. Avol, F. Gilliland, F.

Lurmann, J. N. Molitor, J. T. Molitor, D. C. Thomas, J. Peters, and R. McConnell, Traffic-related air
pollution and asthma onset in children: a prospective cohort study with individual exposure
measurement., Environ. Health Perspect., vol. 116, no. 10, pp. 14338, Oct. 2008.

[23]

H. Kan, G. Heiss, K. M. Rose, E. A. Whitsel, F. Lurmann, and S. J. London, Prospective analysis of

traffic exposure as a risk factor for incident coronary heart disease: the Atherosclerosis Risk in
Communities (ARIC) study., Environ. Health Perspect., vol. 116, no. 11, pp. 14638, Nov. 2008.

[24]

A. A. Karner, D. S. Eisinger, and D. A. Niemeier, Near-roadway air quality: synthesizing the

findings from real-world data., Environ. Sci. Technol., vol. 44, no. 14, pp. 533444, Jul. 2010.

[25]

M. T. Kleinman, C. Sioutas, J. R. Froines, E. Fanning, A. Hamade, L. Mendez, D. Meacher, and M.

Oldham, Inhalation of concentrated ambient particulate matter near a heavily trafficked road
stimulates antigen-induced airway responses in mice., Inhal. Toxicol., vol. 19 Suppl 1, no. June
2006, pp. 117126, 2007.

[26]

R. McConnell, K. Berhane, L. Yao, M. Jerrett, F. Lurmann, F. Gilliland, N. Kunzli, J. Gauderman, E.

Avol, D. Thomas, and J. Peters, Traffic, susceptibility, and childhood asthma, Env. Heal.
Perspect, vol. 114, no. 5, pp. 766772, 2006.

[27]

R. McConnell, K. Berhane, L. Yao, M. Jerrett, F. Lurmann, F. Gilliland, N. Knzli, J. Gauderman, E.

Avol, D. Thomas, and J. Peters, Traffic, susceptibility, and childhood asthma, Environ. Health
Perspect., vol. 114, no. 5, pp. 766772, 2006.

[28]

A. C. Olsson, P. Gustavsson, H. Kromhout, S. Peters, R. Vermeulen, I. Brske, B. Pesch, J.

Siemiatycki, J. Pintos, T. Brning, A. Cassidy, H. E. Wichmann, D. Consonni, M. T. Landi, N.
Caporaso, N. Plato, F. Merletti, D. Mirabelli, L. Richiardi, K. H. Jckel, W. Ahrens, H. Pohlabeln, J.
Lissowska, N. Szeszenia-Dabrowska, D. Zaridze, I. Stcker, S. Benhamou, V. Bencko, L. Foretova,
V. Janout, P. Rudnai, E. Fabianova, R. S. Dumitru, I. M. Gross, B. Kendzia, F. Forastiere, B. Buenode-Mesquita, P. Brennan, P. Boffetta, and K. Straif, Exposure to diesel motor exhaust and lung
cancer risk in a pooled analysis from case-control studies in Europe and Canada, Am. J. Respir.
Crit. Care Med., vol. 183, no. 7, pp. 941948, 2011.

[29]

H. Orru, B. Lvenheim, C. Johansson, and B. Forsberg, Potential health impacts of changes in air
pollution exposure associated with moving traffic into a road tunnel., J. Expo. Sci. Environ.
Epidemiol., Apr. 2015.

[30]

H. Orru, B. Lvenheim, C. Johansson, and B. Forsberg, Potential health impacts of changes in air
pollution exposure associated with moving traffic into a road tunnel, J. Expo. Sci. Environ.
Epidemiol., no. April 2014, pp. 18, 2015.
27

[31]

L. Perez, F. Lurmann, J. Wilson, M. Pastor, S. J. Brandt, N. Kunzli, and R. McConnell, Nearroadway pollution and childhood asthma: implications for developing win-win compact urban
development and clean vehicle strategies, Env. Heal. Perspect, vol. 120, no. 11, pp. 16191626,
2012.

[32]

L. Perez, N. Knzli, E. Avol, A. M. Hricko, F. Lurmann, E. Nicholas, F. Gilliland, J. Peters, and R.

McConnell, Global goods movement and the local burden of childhood asthma in southern
California., Am. J. Public Health, vol. 99 Suppl 3, pp. 622628, 2009.

[33]

D. T. Silverman, J. H. Lubin, A. E. Blair, R. Vermeulen, P. A. Stewart, P. L. Schleiff, and M. D.

Attfield, RE: The Diesel Exhaust in Miners Study (DEMS): a nested case-control study of lung
cancer and diesel exhaust, J Natl Cancer Inst, vol. 106, no. 8, 2014.

[34]

D. T. Silverman, C. M. Samanic, J. H. Lubin, A. E. Blair, P. A. Stewart, R. Vermeulen, J. B. Coble, N.

Rothman, P. L. Schleiff, W. D. Travis, R. G. Ziegler, S. Wacholder, and M. D. Attfield, The Diesel
Exhaust in Miners study: a nested case-control study of lung cancer and diesel exhaust, J Natl
Cancer Inst, vol. 104, no. 11, pp. 855868, 2012.

[35]

R. Urman, R. McConnell, T. Islam, E. L. Avol, F. W. Lurmann, H. Vora, W. S. Linn, E. B. Rappaport,

F. D. Gilliland, and W. J. Gauderman, Associations of childrens lung function with ambient air
pollution: joint effects of regional and near-roadway pollutants, Thorax, vol. 69, no. 6, pp. 540
547, 2014.

[36]

R. Vermeulen, D. T. Silverman, E. Garshick, J. Vlaanderen, L. Portengen, and K. Steenland,

Exposure-Response Estimates for Diesel Engine Exhaust and Lung Cancer Mortality Based on
Data from Three Occupational Cohorts, Env. Heal. Perspect, vol. 122, no. 2, pp. 172177, 2014.

[37]

H. E. Volk, F. Lurmann, B. Penfold, I. Hertz-Picciotto, and R. McConnell, Traffic-related air

pollution, particulate matter, and autism, JAMA Psychiatry, vol. 70, no. 1, pp. 7177, 2013.

[38]

H. E. Volk, I. Hertz-Picciotto, L. Delwiche, F. Lurmann, and R. McConnell, Residential proximity to

freeways and autism in the CHARGE study., Environ. Health Perspect., vol. 119, no. 6, pp. 8737,
Jun. 2011.

[39]

J. Wu, C. Ren, R. J. Delfino, J. Chung, M. Wilhelm, and B. Ritz, Association between local trafficgenerated air pollution and preeclampsia and preterm delivery in the south coast air basin of
California., Environ. Health Perspect., vol. 117, no. 11, pp. 17739, Nov. 2009.

[40]

J. Wu, M. Wilhelm, J. Chung, and B. Ritz, Comparing exposure assessment methods for trafficrelated air pollution in an adverse pregnancy outcome study., Environ. Res., vol. 111, no. 5, pp.
68592, Jul. 2011.

[41]

Y. Zhu, W. C. Hinds, S. Kim, and C. Sioutas, Concentration and size distribution of ultrafine
particles near a major highway, J. Air Waste Manag. Assoc., vol. 52, no. 9, pp. 10321042, 2002.

28

[42]

Y. Zhu, W. C. Hinds, S. Kim, S. Shen, and C. Sioutas, Study of ultrafine particles near a major
highway with heavy-duty diesel traffic, Atmos. Environ., vol. 36, no. 27, pp. 43234335, Sep.
2002.

[43]

Y. Zhu, T. Kuhn, P. Mayo, and W. C. Hinds, Comparison of Daytime and Nighttime Concentration
Profiles and Size Distributions of Ultrafine Particles near a Major Highway, Environ. Sci. Technol.,
vol. 40, no. 8, pp. 25312536, Apr. 2006.

29