OPPOSITION GROUPS (PARTIAL LIST)

Caltrans Tenants of the 710 Corridor

Natural Resources Defense Council
East Yard Communities for Environ. Justice
Glassell Park Improvement Association
Far North Glendale Homeowners Association
San Rafael Neighborhoods Association
West Pasadena Residents Association
Highland Park Heritage Trust
Glendale Homeowners Coordinating Council
LOS ANGELES
NEIGHBORHOOD
COUNCILS
Arroyo Seco
Cypress Park
Eagle Rock
El Sereno
Glassell Park
Highland Park
Lincoln Heights
Sunland -Tujunga

INJUNCTION PLAINTIFFS
City of South Pasadena
Sierra Club
National Trust for Historic Preservation
California Preservation Foundation
Los Angeles Conservancy
Pasadena Heritage
South Pasadena Preservation Foundation
South Pasadena Unified School District

Crescenta Valley Town Council

La Canada Unified School District

CONTACT INFORMATION

LA RED, El Sereno

581 Garden Lane

GREEN SCISSORS 2011 REPORT GROUPS

Friends of the Earth
Taxpayers for Common Sense
The Heartland Institute
Public Citizen

Pasadena, CA 91105
no710extension@aol.com
www.no710.com

CITIES
City of Glendale
City of Sierra Madre
City of Los Angeles
City of South Pasadena
City of La Canada Flintridge
City of Pasadena

SCH Number 1982092310

File: 07-LA-710 (SR 710)
Project: EFIS 0700000191 (EA: 187900)
Title: State Route 710 North Study

Garrett Damrath
Chief Environmental Planner
Caltrans District 7
Division of Environmental Planning
100 S. Main Street, MS 16A
Los Angeles, California 90012

RE: Draft Environmental Impact Report/Environmental Impact Statement
SR 710 North Study

Dear Mr. Damrath:

On behalf of the No 710 Action Committee, we are submitting the following comments,
questions, and requests for additional information regarding the SR 710 DEIR/DEIS
(DEIR/S) released in March 2015. We are also including comments on the Cost Benefit
Analysis (CBA), which was released on 19 June 2015. We hereby request that all of these
comments be incorporated into the Administrative Record and receive full responses, as
contemplated by CEQA and NEPA.

The N0 710 Action Committee (NO 710 AC) was formed approximately five years ago.
The organization includes members from the west San Gabriel Valley (La Canada-
Flintridge, Pasadena, South Pasadena, Sierra Madre, Glendale, La Crescenta, San Marino,
Alhambra), Los Angeles (Mt. Washington, Highland Park, Eagle Rock, El Sereno, East Los
Angeles) and representatives from multiple Neighborhood Councils. We work in
cooperation with numerous elected officials, mayors, city councils and their staff
members. Our Committee meets monthly and our members are fully engaged in the SR

 Mr. Garrett Damrath, Caltrans

July 30, 2015
SR 710 North Study Project DEIR/S
Page 2

710 Project, attending public meetings such as those for Scoping, Open Houses,
Alternative Analysis, Community Liaison Committee, Public Hearings, TAC and SOAC,
Metro Board, CTC, San Gabriel Valley COG, and SCAG, as well as informational forums and
area City Council meetings.

As a group, the NO 710 AC is focused on searching for Project Alternatives that are
sensible, realistic, and ones that will provide the best transportation solutions for our
communities and for the Region. We recognize the need to improve mobility in our
communities. Our mission is to promote solutions that are environmentally and fiscally
sound, reduce pollution, lower health risks, relieve congestion and eliminate public
dependence on fossil fuels. We remain strongly opposed to the Tunnel Project included in
the DEIR/S because it is unrealistic, has disastrous negative environmental and health
consequences, is dangerous to construct and to operate, and is too costly.

The NO 710 Action Committee has been fortunate to confer with many experts to assist
us as we analyzed the approximately 26,000 pages of the DEIR/S. We are grateful to these
experts who come from renowned institutions, such as the National Resources Defense
Council, USC Keck School of Medicine, California Institute of Technology and the U. S.
Geological Survey Pasadena.

After a careful review of the DEIR/S, we have concluded that it fails to comply with many
requirements of CEQA and NEPA. CEQA requires that an EIR identify a projects
significant impacts and to identify effective ways to avoid or mitigate them. An EIR must
assess each mitigation proposal, even if such measures would not completely eliminate
the impact or render it less than significant. The DEIR/S fails to inform the public and the
decision makers of the environmental impacts of the proposed alternatives nor does it
identify ways to mitigate or to avoid those negative impacts as required by both CEQA
and NEPA.

In this letter, we have chosen to comment briefly on the issues most important to the NO
710 Action Committee. We recognize that there are MANY other issues that will be raised
and addressed by other members of the public. We will keep our comments brief because
we know a number of in-depth responses on these topics will be submitted by members
of the NO 710 Action Committee and affiliated organizations.

Purpose and Need
Prior to the release of the DEIR/S, Caltrans and METRO sponsored Scoping Sessions
which were open to the public. Many residents attended and most requested additional
public transit. The comments most voiced were:
- Please give us improved and reliable public transit
- We want to get out of our cars
- Dont build more freeways
- Freeways are 1950s thinking and we need 2000 mobility solutions
- Improve and complete and maximize use of the Alameda Corridor for goods movement

 Mr. Garrett Damrath, Caltrans

July 30, 2015
SR 710 North Study Project DEIR/S
Page 3

Yet, the DEIR/S clearly favors a tunnel freeway proposal and those many voices of the
Scoping Sessions have been ignored.

Current studies show that the Regions congestion is due primarily to local east/west
trips, not to a lack of a north/south freeway corridor for cut-through traffic. Only 13.7%
of current peak period traffic on study area arterials represents cut-through traffic. In the
area where the tunnel would be constructed, studies show that 90% of the motorists
would see no travel-time savings or that their travel-time would worsen. Those who
might benefit would likely have minimal savings of a mere 2.5 minutes.

Trucks & Goods Movement
It is widely believed that goods movement is the major force propelling the SR 710 Tunnel.
Goods movement from the Ports to the warehouses in San Bernardino and to the North by way
of the 5 Freeway is an important challenge but a tunnel to connect I-710 to the 210/134
Freeways is not the solution. Both of these freeways are seriously congested today and cannot
accommodate large numbers of additional big rigs and other traffic.

Why is there no information included in the DEIR/S about improvements to and increased use of
the Alameda Corridor, which is operating at only 1/3 capacity? In spite of recommendations by
our group and others to study electrified rail systems such as GRID or Cargo-Rail for goods
movement, the DEIR/S fails to address these safe, clean technologies. These options are less
costly, safer, and would relieve and improve many of the existing freeways in Southern
California.

Construction Site Noise and Emission Impacts
There is only limited information regarding the construction sites at either the north or south
end of the SR 710 North Project. The construction site in Seattle for Bertha and the SR 99
Alaskan Way Viaduct Replacement Tunnel is many blocks long and wide. How will such
construction sites be accommodated in the densely-populated areas of Pasadena, El Sereno,
Alhambra and Los Angeles? The DEIR/S provides no information on noise impacts or pollution
emissions from the construction equipment, which will be operating adjacent to residences,
businesses, and schools, such as Maranatha, Waverly and Sequoyah. The DEIR/S does not
provide information on the intensity, type, or duration (24 hours?) of construction noise nor
does the DEIR/S offer information of possible mitigation measures for these severe impacts.

Ground Settlement
The SR 710 DEIR/S does not provide an adequate analysis of the potential impacts from ground
settlement. A number of studies should have been completed prior to the release of the DEIR/S
to determine whether the proposed excavation and tunneling techniques are feasible or will
require adjustments. Without such studies, settlement could damage surface facilities, such as
existing buildings, residences, schools, the Huntington Memorial Hospital, utilities etc.
Groundwater inflow into excavation areas may require de-watering, which could cause more
ground settlement similar to what has occurred in Seattle.

 Mr. Garrett Damrath, Caltrans

July 30, 2015
SR 710 North Study Project DEIR/S
Page 4

Groundwater
The tunnel project will threaten two important groundwater basins: the Raymond Basin and the
Main San Gabriel Basin. The Raymond fault serves as a wall, or dam, and holds the Raymond
Basin water to the north. The Raymond aquifer is polluted and the tunnel alternatives would
allow the polluted water to flow into the San Gabriel aquifer, which would then become polluted.
At the same time, Pasadenas loss of water from its aquifer could be devastating.

The DEIR/S does not include a full analysis of these important impacts and does not propose any
mitigation measures to these very serious negative impacts on water supplies of Pasadena and
South Pasadena.

Geology, Seismic & Soil
Several renowned geotechnical engineers have reviewed the DEIR/S and their comments
will be submitted separately. All reach similar conclusions. There is a lack of complete
analysis of seismic, soils and groundwater impacts.

The information presented in the DEIR/S is severely deficient. Its analysis of geological
and seismic impacts, including fault offset, ground-shaking, and ground settlement is
inadequate. The mitigation measures included in the Draft are ineffective and inadequate.
In addition, the measures defer development of critical details and studies until after the
Project has been approved. Caltrans and Metro improperly rejected a safer tunnel design
in favor of a less expensive, more quickly built design, but one with more potential for
severe stress and risk to the tunnel. For unknown reasons, Caltrans & Metro relied on a
20 year-old study as a reference instead of the Wesnousky Study (2008) with improved
and more accurate information on ground movement.

There is no evaluation in the DEIR/S of the potential collapse of the tunnel, either
partially or completely, as the result of a seismic disturbance. Experts tell us that the
geological conditions along the proposed tunnels are probably among the most difficult
encountered in a major tunnel project. The tunnels will cross through the Raymond,
Eagle Rock and San Rafael faults and through an unknown variety of alluvial soils over
bedrock, resulting in difficult geologic conditions. All of this is located in an area often
referred to as one of the major tectonic hotspots in the world because of the destructive
earthquakes in the past decades and before. One question never answered: did Caltrans
& Metro ever study alternative routing of the tunnels in order to avoid constructing a
tunnel through active faults?
The NO 710 Action Committee has followed closely the problems with the controversial
Seattle Tunnel Boring Machine (TBM) known as Bertha. That project has not gone well.
As a result, our concerns for California include: serious failure of the TBM and its
abandonment, needed re-routing, worker casualties, sudden collapse, major delays, cost
overruns, etc.

The disposal of chemically contaminated soils and rocks and the need for continual heavy
truck movement (24 hours?) through residential neighborhoods, past schools and a

 Mr. Garrett Damrath, Caltrans

July 30, 2015
SR 710 North Study Project DEIR/S
Page 5

major regional hospital and trauma center are challenges not addressed in the
DEIR/DEIS.

Air Quality & Health Impacts
The DEIR/S fails to provide a comprehensive analysis of the Projects air quality impacts
and a plan to thoroughly mitigate these impacts. This deficiency is especially egregious
since the Project study area lies within the South Coast Air Basin, which has the worst air
quality in the United States.

The DEIR/S does not specify a significance threshold for construction emissions, in spite
of the fact that the report does acknowledge that construction emissions for all
alternatives exceed the SCAQMD thresholds for significance for one or more pollutants by
as much as 10 times. As a result, the report never comes to a conclusion about
significance of the Projects construction-related impacts nor does it identify sufficient
mitigation.

The projected air quality data for criteria pollutants, presented for vehicular emissions in
tabular form (5.11 in Appendix E of the Air Quality Analysis) in the DEIR/S and as bar
graphs at the March 11th meeting of the Technical Advisory Committee, strains credibility
and defies logic. Fundamentally, the emissions data for opening year 2025 and horizon
year 2035 demonstrate no significant differences in each criteria pollutant among all
build alternatives. Certainly, one would expect that all freeway tunnel alternative
operational variants would result in higher levels of criteria pollutants than the LRT, BRT
and TSM/TDM alternatives. According to the DEIR/S, this is not the case. At the very
least, the dual bore freeway tunnel operational variants capable of carrying twice as
many vehicles as the single bore operational variants should have shown a difference in
criteria pollutants. The DEIR/S reports virtually identical levels of criteria pollutants for
all operational variants of both the single and dual bore tunnels. The DEIR/S makes no
attempt to explain these surprising results.

Certain inadequacies of the traffic modeling result in underestimation of vehicular
emissions for the freeway tunnel alternatives. It is impossible to determine if the travel
demand model accurately estimates the vehicle miles traveled as a result of induced, or
latent, demand. Induced demand would increase congestion and reduce speeds, thereby
increasing emissions. Induced demand would also increase vehicle miles traveled at
slower speeds, increasing vehicle emissions of criteria pollutants.

A second phenomenon that would impact emissions is diversion of vehicles from the
freeway due to congestion or bottlenecks. Vehicles finding themselves in long lines of
traffic at a bottleneck may choose to leave the freeway in favor of arterials rather than
tolerate the additional time required to clear the freeway bottleneck. Traffic on arterials
generally travels at slower average speeds than traffic on freeways, resulting in greater
emissions of criteria pollutants. Finally, by using an average, bi-directional speed in the
traffic modeling, the impacts on emissions of extremes in speed the faster speeds in
periods of flowing traffic, and the slow speeds in periods of congested traffic would tend

 Mr. Garrett Damrath, Caltrans

July 30, 2015
SR 710 North Study Project DEIR/S
Page 6

to be minimized as the average speed would be more likely to fall into the speed range
where emissions are less than they are at extreme speeds on both the fast and slow ends
of the spectrum. This could lead to smoothing of criteria pollutant emission rates and
underestimation of total criteria pollutants produced by the freeway tunnel alternatives.
While they may not be totally responsible, both of these factors would result in an
underestimation of the predicted criteria pollutant levels for both tunnel alternatives, and
contribute to the appearance that the freeway tunnel alternatives do not produce any
more criteria pollutants than do the other, non-freeway alternatives.

The DEIR/S does not adequately analyze impacts relating to particulate hotspots, nor
does it provide adequate mitigation measures. Because the report does not identify
pollutant concentrations at each affected receptor location, the public is prevented from
determining the health impacts on a receptor-by-receptor basis. Therefore, the DEIR/S
fails to accurately assess the health impacts resulting from particulate emissions.

The report fails to address all applicable federal and state ambient air quality standards
(AAQS). While the DEIR/S does discuss Federal PM10 AAQS, it fails to discuss the State
AAQS. This is a significant omission with potentially damaging consequences to the
health and well-being of the public since the state standards are more restrictive than
federal standards.

In spite of adequate warning (more than a year before release of the DEIR/S) that the
DEIR/S should incorporate updated methodology, using higher estimates of potency
during early life exposures, adopted by the California Environmental Protection Agency
Office of Environmental Health Hazard Assessment for estimating cancer risk, the authors
of the DEIR/S used outdated methods resulting in an underestimate of air quality-related
cancer risk especially to children. The new methodology results in cancer risk
assessments that are considerably higher by a factor of about 2.5. Failure to employ the
new methodology results in unidentified significant impacts.

Safety Concerns
The DEIR/S contains incomplete information about the process for monitoring vehicles
carrying hazardous waste, the ability of Fire Departments to access the tunnels when
accidents or fires occur, and emergency procedures for motorists to flee on foot from the
tunnels following accidents, fires, or severe earthquakes.

How will trucks carrying hazardous waste be monitored and prevented from entering the
tunnel? If a truck is not permitted in the tunnel because of the potentially dangerous
cargo, how will the driver be stopped and how will the truck driver be prevented from
driving his cargo through nearby neighborhoods?

Representatives from the Pasadena Fire Department are asking if there will be enough
room in the tunnels for all the necessary fire-fighting equipment when needed. Will the
trucks and other equipment be able to cross over to the second tunnel or be able to travel
from one level to another? What kind of dedicated water tank will be installed in each

 Mr. Garrett Damrath, Caltrans

July 30, 2015
SR 710 North Study Project DEIR/S
Page 7

tunnel and how will it operate? Will there be trained fire personnel and fire-fighting
equipment available on site at all times as we have been told by METRO staff?

In the event of fire, how will drivers and their passengers exit the tunnels quickly and
safely? We have been told by METRO staff or consultants that following a serious
accident or fire, it is possible that there will be no way of escape for the injured, the
handicapped, or the elderly. Our understanding is that one might be able to escape by
traveling up long stairways to the streets above or one may enter some sort of a safe
room, which will have protected air for some limited time, such as several hours. Is that
correct information that we have received from METRO staff?

In the event of a major fire or possible severe earthquake, it is likely that the tunnels
would be closed to traffic for repairs. How will the tunnels, particularly following a
severe fire, be accessed for those repairs? How will the construction project impact the
neighborhoods, streets, houses etc. above?

Once again, by ignoring these important issues of potential accidents, fires, earthquakes
and even tunnel collapse, the DEIR/S fails to meet CEQA and NEPA s basic requirements.

Cultural Resources
The DEIR/S should include maps that identify the locations of historic resources and offer
a clear and complete explanation about how the freeway alternatives might have a
negative impact on any of the properties and how those impacts might be mitigated. No
information is provided about the impacts of the proposed ventilation structures on
nearby historic resources -- for example, the proposed 50 ft. tall ventilation towers on
Colorado Blvd. in the vicinity of the Old Pasadena Historic District and other nearby
districts, either listed, or eligible for listing on the National Register.

The tunnels, as proposed, will be under some of the oldest neighborhoods in Pasadena
and South Pasadena. Many of these neighborhoods and/or individual structures have
already been declared eligible for listing on the National Register. Geologists, with whom
we have confidence, maintain that these neighborhoods are in grave danger from the
proposed tunnel project due to vibrations, excavations, blasting, and the TBM. The land
above and around the tunnels will be disturbed and moved during construction. Damage
is likely to continue to nearby streets, utilities, and foundations of buildings as the ground
gradually settles over a period of years. The DEIR/S does not address this serious impact
nor does it propose any mitigation measures. The DEIR/S also fails to provide a
contingency plan for rescue should the tunnel boring machine (TBM) fail and need to be
retrieved for repair, as has occurred in Seattle. The need to excavate a rescue pit similar
to the 80 feet wide by 120 feet deep rescue pit required to rescue Seattles TBM be
required, could put multiple historic structures and neighborhoods at risk.
Cost Benefit Analysis
The Cost Benefit Analysis Report is flawed in its execution and in its selective, biased
presentation of results. The California Benefit/Cost (Cal-B/C) model template produces

 Mr. Garrett Damrath, Caltrans

July 30, 2015
SR 710 North Study Project DEIR/S
Page 8

three indices of performance: Net Present Value (NPV) which is the difference between
the monetized benefits and monetized cost of a project, Benefit/Cost Ratio (B/C) and
Return on Investment (ROI). All three are necessary to accurately interpret the results of
the model, yet the CBA report presents only NPV. Conclusions based on this simple
difference parameter cannot be considered valid when the alternatives being compared
have orders of magnitude differences in their cost and benefit values.

The goal of the study, as stated on page 1 of the reports Executive Summary, is
maximizing the cost efficiency (bang for the buck) of public investments. NPV does
not address cost efficiency, but B/C and Return on Investment do. When these indices
are included, the best performing alternative is TSM/TDM, not the single-bore tunnel as
reported. Without the inclusion of B/C and ROI for each alternative, no valid conclusions
about cost efficiency may be drawn from the study.

The CBA contains other flaws with the inclusion of and the way various model inputs
were calculated, but these details are not critical to results that demonstrate that even if
the data as presented in the report are used, the conclusion about which alternative
performs best is different when all three parameters are examined. Less than full
implementation of the model and full disclosure of the results is misleading to the public
and suggests manipulation of the data to produce a preferred outcome.

Conclusion
After studying the SR 710 North DEIR/S and conferring with experts in relevant fields, we
conclude that the document fails to comply with the requirements of both CEQA and
NEPA in numerous ways and should be withdrawn. Not only would the tunnel and all
other alternatives fail to relieve the congestion as intended, as it is now designed and
described in the DEIR/S, the tunnel is an extremely risky project to build and presents
serious threats to nearby neighborhoods and communities.

Based on data from other infrastructure megaprojects, it is very likely that the costs for
the tunnel will double or triple and some experts are questioning whether the tunnel is
truly feasible. The DEIR/S makes clear that the many studies necessary for the public to
be able to assess the value of a project of this size, complexity and fiscal, environmental
and physical risk have yet to be done.

We urge METRO & Caltrans to withdraw the DEIR/S and to re-start the process. The focus
should be a truly collaborative effort between Metro, Caltrans and the communities in our
region. Metro and Caltrans must be willing to engage additional agencies representing
other modes of transportation in the process to design interconnected, multimodal
approaches that are sensible, effective, realistic, and affordable.

Improvements to the Alameda Corridor, a serious study of electrified rail for goods
movement from the Ports, extension of the Gold Line to the Ontario Airport and beyond
and light rail connections to the Burbank Airport are but a few examples of needed and
widely supported transportation improvements which will benefit so many throughout

 Mr. Garrett Damrath, Caltrans

July 30, 2015
SR 710 North Study Project DEIR/S
Page 9

Southern California. More frequent and additional local and bus rapid transit lines should
be priorities, especially near population centers such as Pasadena City College and Cal
State LA. Bikeways and the Great Streets programs and even small parks should be part
of a broad and innovative transportation plan at much less cost both fiscally and
environmentally -- than the tunnel proposal in the DEIR/S.

We, as representatives of the No 710 Action Committee, appreciate the opportunity to
submit this overview of comments on the SR 710 North DEIR/S. Please notify us of any
further information on the environmental planning phases for this project. We thank your
for your kind attention.


Sincerely,

Claire Bogaard


581 Garden Lane

Pasadena, California 91105
cwbogaard@earthlink.net

Janice SooHoo



1339 El Vago Street
La Caada Flintridge, California 91011
jan@soohoos.org

cc:
Carrie Bowen, Director of the California Department of Transportation District 7
Malcolm Dougherty, Director of California Department of Transportation
Brian P. Kelly, Secretary of the California State Transportation Agency
Phillip Washington, CEO of Los Angeles County Metropolitan Transportation Authority