Open Letter to CHHA

Friends 4 Expo Transit
March 30, 2007

An open letter to Kevin Hughes, Cheviot Hills Homeowners Association President, and Colleen Mason Heller, CHHA Light Rail Chair, concerning the CHHA "Light Rail Update" dated 3/27/07.

We are responding because it contains a number of demonstrably false statements on important points of the Expo Line phases 1 and 2; it cites "Friends4Expo members" among its sources; and in keeping with Ms. Heller's earlier CHHA letter professing an interest in "facts" over "feelings".

Following is the entire CHHA text, in quotes, with our added factual corrections.

"The Cheviot Hills Homeowners' Association light rail committee has spent 2 months researching, meeting with politicians, talking with transit authorities, and Friends4Expo members. We have met and formed a working coalition with area Homeowners' Associations (Neighbors for Smart Rail), Expo Phase 1 residents, and Metro Gold Line residents. Here is what we've learned:

"• The Expo Phase 1 project was given a "not recommended" rating by the Federal Transportation Administration for funding through the federal New Starts Program because MTA failed to prove that the project would improve traffic or mobility. The FTA determined that any benefit from the Expo line was due to the extensive bus feeder network needed to bring passengers back and forth to the train!"

False. Phase 1 was "Not Rated at this time", not "not recommended". The FTA stated a strong case for the Expo Line including, "The Exposition Corridor parallels the Santa Monica Freeway (I-10) which currently maintains traffic volumes exceeding 300,000 vehicles per day. I-10 is often cited as the most congested highway in Los Angeles." (FTA 2006 Annual Report on New Starts, Appendix A, dated November 2004.)

To avoid further delay with the drawn-out FTA process, the MTA dropped its request for federal New Starts funding in 2005, and the FTA approved release of the Final EIS/EIR. The Expo Line is therefore not listed in the 2007 and 2008 Annual Report on New Starts. Feeder buses made up only a small part of the Expo Line's excellent projected ridership, documented in section 5.2.1 of the Final EIS/EIR.

"• The original Exposition LR line was conceived 20 years ago as a single project. It has now been tactically segmented into Phase 1 and 2, but, in fact, you had better take a keen interest in the design and construction of Phase 1. The materials, station designs, colors, safety features, and grade crossing designs are already contracted to be standardized throughout the line (Phase 1 and 2) regardless of whether the line goes through residential or commercial environments."

We at Friends 4 Expo Transit are taking a keen interest in the design and construction of Phase 1. We're pleased that it has well-planned urban design and extensive landscaping for its route through both residential and commercial environments, and will be a good model for phase 2.

"• The Expo Construction Authority (MTA) is trying to divide communities along the Exposition ROW but we all have the same interests and these are best promoted through a strong coalition. If the Expo Phase 1 project proceeds on the cheap with minimal mitigation and few grade separations, Phase 2 cannot reasonably fare any better and it shouldn't. Funding will be restricted if Expo is found to discriminate or favor one community over another. Even if Cheviot Hills gets a below grade crossing at Overland Avenue and our neighbors to the west and east get minimal grade separations we will all suffer from the resulting traffic and safety impacts."

False. Hardly designed "on the cheap with minimal mitigation", phase 1 has extensive mitigation specified in its Final EIS/EIR, including soundwalls (mapped in Appendix J) and three grade separations determined according to the 2003 MTA Grade Crossing Policy (Appendix E): an underpass at Flower-Figueroa-Exposition and overpasses at La Brea and La Cienega-Jefferson-Ballona Creek.

Phase 2 grade separations will be determined in the upcoming environmental study according to the same objective standard. They will likely include at least National-Washington-Venice, Overland and Sepulveda (if on the right-of-way option), Sawtelle-Pico, Bundy, and Lincoln-5th.

"• The Expo Construction Authority (MTA) is currently drafting legislation to be presented to the California legislature that seeks to shorten the time the California Public Utilities Commission has to evaluate grade crossing applications. The CPUC is the state agency responsible for highway and railway safety in California! This action by the MTA does two things, it compromises safety by reducing the time the Commission can take to do the necessary traffic research and safety evaluation of applications, but also this legislation is a blatant and bad faith attempt to exclude community input in the grade crossing policy decisions."

False. The environmental study addresses grade crossing safety and receives extensive public input. There is no need for the CPUC to drag out standard grade crossing applications for as long as two years, delaying construction and raising costs. There will be few gated grade crossings in phase 2, probably at most eight. The only street crossing by Cheviot Hills is Overland, which appears to exceed the 2003 MTA Grade Crossing Policy standard for a grade separation.

"• The Los Angeles Unified School District has complained to the CPUC about the lack of mitigation measures on Expo Phase 1 for noise, vibration and air contaminants for the 5 schools which (like Overland) are within 75 feet of the line. More than 20,000 students will have to walk across the double tracks of at-grade crossings to get back and forth to those schools each day. The school district environmental office went so far as to ask the PUC not to approve the Phase 1 light rail project until grade crossing issues satisfy their safety concerns."

False. Incredibly, the cited September 28, 2006 LAUSD letter didn't even know the final route of the Expo Line! Two of the five schools listed are on Hill Street, which is not on the final route adopted the year before. The third is by Exposition Blvd. where the Expo Line will go beneath Figueroa. The Final EIS/EIR documents noise and pedestrian safety mitigations for the remaining Foshay Middle and Dorsey High Schools (sections 4.6.3 and 4.12.2.1).

"• In terms of standard transportation protocol the MTA's dangerous imperative to put as many at-grade crossings as possible through densely populated areas is criminal. They seem to operate on an "acceptable casualties" philosophy when it comes to safety on its trains. The Metro Blue Line, has contributed to 74 fatalities to date, almost 40 times the number of catastrophic events (1 per 10 years) the Federal Railway Administration says is predictable. Non-fatal injuries far exceed that number. The CPUC found the Metro Gold Line to be so dangerous, because of the number of at-grade crossings, that it has been slowed to a crawl. It is now faster to drive the length of the route and at some intersections train barrier arms are lowered for more than 40 minutes out of each hour."

False. Grade crossings in urban areas are the norm in all cities with light rail lines. To call this "criminal" is uninformed and inflammatory. Designers of the Pasadena Gold Line learned from the Blue Line, and built a fast and safe project. The Gold Line is not slow; in fact, its average speed is even faster than the Blue Line's. Crossing gates at a typical grade crossing are only lowering and down for about 30 seconds — the same as typical traffic signal red lights everywhere. The Federal Railway Administration regulates freight railroads, not urban transit lines.

"• After indicating that the Phase 1 segment near USC/Exposition Park would be underground, the MTA is now attempting to renege on that commitment and put the train crossings at-grade in an area that is dense with vehicular and pedestrian traffic. Of course, if USC really wants it underground they can pay for it according to MTA. Culver City is also being asked to contribute money to the single station that touches the edge of their city if they want input as to the design and safety considerations. MTA will promise everything and then cry poor when it comes time to deliver!"

False. The route adopted by the MTA Board on 12/15/05 specified an underpass at the congested Flower-Figueroa-Exposition intersections. That is what is to be built. Tracks will then come up to grade at the Trousdale Walk pedestrian crossing from USC to the Exposition Park Rose Garden. USC sought a longer underground section, but that was never approved. Culver City is seeking to move its phase 2 aerial station into phase 1.

"Los Angeles is the largest economic center in the United States. Why is MTA building a long overdue public transportation system based on flawed planning, which circumvents public safety, and seeks to exclude meaningful input from the stakeholders who are going to live with their shortsighted blunders? Where are the public/private partnerships that support World Class transit systems in other cities? Where are the designs and the planning that can pass federal funding requirements? Why do we keep hearing that there is no money for grade separations that don't blight neighborhoods? Why is it that the only traffic improvement that this train route offers is due to the feeder bus system? Why is cheap the only project advantage that everyone agrees on? Where are the politicians elected to think harder, dig deeper, and deliver excellence in our communities?"

False. The Exposition Metro Line Construction Authority (not MTA) is building a "World Class" light rail line based on quality planning and extensive input from many stakeholders, to meet a critical need in the horribly-congested Santa Monica Freeway corridor. If the CHHA prefers other cities' light rail as models, why have they not cited any?

"Please go to our coalition website, Smartrail.org, and take a few minutes to compose a single thoughtful letter of your concerns to send to all MTA, Expo, and California city, state, and local authorities and demand more from them. If they don't hear from you cannot assume their best intentions on your behalf. You will be left as just one more NIMBY dangling in the wind."

Friends 4 Expo Transit's position on the phase 2 route options is to seek thorough environmental study of station locations, cost, travel time, ridership, and environmental impacts and mitigations, to enable an informed selection.

For more information on light rail and the Expo Line see our website www.friends4expo.org. The entire phase 1 Final EIS/EIR is available online. See Chapter 4 in particular for detailed discussions and specified mitigations for environmental issues including noise and safety (sections 4.6.3 and 4.12.2.1).

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