Los Angeles Unified School District Office of Environmental Health and Safety

333 South Beaudry Avenue, 20th Floor, Los Angeles, CA 90017 • Telephone (213) 241-3199 • Fax (213) 241-6816

The Office of Environmental Health and Safety is dedicated to providing a safe and healthy environment for the 900,000 students and 80,000 employees of the Los Angeles Unified School District.

October 26, 2009 Roderick Diaz, Project Manager LACMTA One Gateway Plaza Los Angeles, CA 90012-2952 diazroderick@metro.net Re: Crenshaw Transit Corridor Project DEIS/DEIR: State Clearinghouse Number 2007091148 Dear Mr. Diaz,

The Crenshaw Corridor, a heavily traveled north-south-oriented urban corridor in Los Angeles County, California, is being considered for transit improvements by the Los Angeles County Metropolitan Transportation Authority (LACMTA) in cooperation with the Federal Transit Administration (FTA). The LACMTA has initiated an environmental review of proposed transit improvements in the corridor as a key step in providing the Metro Board and the general public with information that will support selection of a Locally Preferred Alternative (LPA). Issues raised by the Los Angeles Unified School District’s (District) review of the Draft Environmental Impact Statement (DEIS) / Draft Environmental Impact Report (DEIR) are related to the deficient analysis of issues related to the health and safety of school occupants at schools located in close proximity to the proposed transit corridor. Table 1 LAUSD Schools Along the Crenshaw Corridor lists schools along both the proposed Bus Rapid Transit (BRT) and Light Rail Transit (LRT) alignments. The main difference between the BRT and LRT alignments is that the BRT will extend north from Exposition Boulevard to Wilshire Boulevard, while the LRT ends at Exposition Boulevard. The extension of the LRT from Exposition Boulevard to Wilshire Boulevard will occur as a future project by the LACMTA. Our evaluation is based upon the technical adequacy of the environmental documentation and consideration of the project’s potential to: 1) compromise the health and safety of students, and staff, and 2) disrupt the learning environment during construction and subsequent operation. As such, identified impacts that may potentially affect our schools are related to the following areas of concern:

• Pedestrian Safety • Noise and Vibration • Derailment • Air Quality

Concerns related to the close proximity of the schools to the proposed alignments are as follows:

• Pedestrian Safety. The proposed identified alignments cross existing and proposed routes to schools. Mitigation must be provided to eliminate all pedestrian conflicts.

• Noise and Vibration. To ensure a quality learning environment, interior and exterior noise levels

must maintain acoustical standards not exceeding American National Standards Institute (ANSI S12.60-2002) values of 35 dBa (interior noise levels) and 67 dBa (exterior). Also, ground-borne vibration levels must not exceed ANSI and Federal Transit Administration standards.

RAMON C. CORTINES Superintendent of Schools

JAMES MORRIS Chief Operating Officer YI HWA KIM Deputy Environmental Health & Safety Director

Crenshaw Corridor DEIS/DEIR –2- October 26, 2009

333 South Beaudry Avenue, 20th Floor, Los Angeles, CA 90017 • Telephone (213) 241-3199 • Fax (213) 241-6816

The Office of Environmental Health and Safety is dedicated to providing a safe and healthy environment for the 900,000 students and 80,000 employees of the Los Angeles Unified School District.

• Train Derailment. Mitigation must be thoroughly analyzed and provide measures to ensure that hazards related to train derailment are totally eliminated. No discussion related to derailment is presented in the DEIR.

• Air Quality. Impacts associated with near-field pollutant emissions associated with construction-

related activities were not addressed. Although LACMTA is cognizant of SCAQMD’s Localized Significance Threshold (LST) Methodology, no analysis was conducted in this regard. Notwithstanding, the applicant reports that construction-related air quality impacts would be “temporary” and with implementation of mitigation measures “no substantial adverse construction effects are anticipated.” This finding is without merit as LACMTA fails to document their claim of insignificance or quantify the effectiveness of identified mitigation measures.

Due to MTA’s failure to prepare the appropriate analysis, the District contends that construction-related activities will generate excessive emissions and impact the health of students and staff attending and/or working in our local schools. As such, the District requests LACMTA complete an LST analysis and provide all relevant and appropriate documentation used to assess project-related impacts.

In general, the DEIS/DEIR does not analyze the above concerns in sufficient detail and provides only broad and generalized statements related to schools located in proximity of the proposed alignments. Since schools are occupied by sensitive receptors, CEQA requires specific mitigation requirements related to school-based occupancies. The District’s Office of Environmental Health & Safety serves to protect the health and safety of students, and staff, and to minimize any disruptions of the learning environment. We therefore request due consideration be given to our local schools and appropriate detail be provided in a subsequent analysis. As such, the District believes recirculation of the DEIS/DEIR is warranted. This will allow MTA sufficient time to complete the appropriate studies and allow our office time to review their technical adequacy. Respectfully,

Glenn Striegler – PG Environmental Assessment Coordinator LAUSD Office of Environmental Health & Safety Attachment c: Yi Hwa Kim, Deputy Environmental Health & Safety Director OEHS Pat Schanen, Environmental Health Manager OEHS Edward Morelan, Site Assessment Manager OEHS Bill Piazza, Site Assessment Coordinator OEHS Jay Golida, LAUSD Legal Council OGC

LAUSD Schools Along the Crenshaw Corridor Exposition Boulevard South to LAX (BRT & LRT)

• Crenshaw HS 486 ft E • View Park Prep Acc MS/HS Adjacent to W • Hyde Park Blvd ES 425 ft E (720 ft by MTA)

North of Exposition Boulevard to Wilshire (BRT Only)

• Wilshire Park ES 1,040 ft E-SE • Wilton Place ES 1,200 ft E-SE • Queen Anna Place ES 1,450 ft W-NW • LA Tech Center 1,150 ft E • Arlington Heights ES 1,170 ft E (Not Shown by MTA) • Johnnie Cochran MS 330 ft SE • New Design Charter School 1,370 ft E (Not Shown by MTA) • Virginia Road ES 1,280 ft W (960 ft by MTA)

Note: Italicized text indicates information either not shown by or information incorrectly reported by LACMTA in the DEIS/DEIR. Schools are listed from their location from north to south along proposed alignments.