Posted by Judy Filere Bergstresser on No on Measure J Facebook page
Ronald Kosinski
Deputy District Director, Division of Environmental Planning
California Department of Transportation - District 7
100 South Main Street, Suite 100, MS 16A
Los Angeles, CA 90012
Use the following link to submit your formal comments on the I-710 Corridor Project Draft Environmental Impact Report/Environmental Impact Statement (EIR/EIS). All comments received by September 28, 2012 will be part of the public record and responded to in the Final EIR/EIS which is scheduled to be released in early 2013.
http://www.mbimedia.com/I-710/
Whatever your points, preface them with a statement to this effect:
I am writing to CONTEST THE COMPLETENESS AND ACCURACY of the I-710 Corridor Project Draft Environmental Impact Report/Environmental Impact Statement (EIR/EIS) of June 2012.
Here are some points you can make:
The I-710 project WILL NOT Improve Air Quality or Public Health or Traffic Safety
* It is a primary fallacy that expanding any highway will reduce traffic or congestion.
* Metro accurately states that within the I-710 corridor study area, air quality would decrease and public health risk would increase due to increased traffic and congestion. Therefore, if traffic and congestion increase as a result of the I-710 expansion, air quality will decrease and public health risk will increase.
* Caltrans claims that air quality can be improved by creating more traffic lanes for cars and trucks is unproven and misleading -- increasing traffic capacity has not been and will not be proven to improve air quality or public health
* Increasing lane width and travel speeds has not been and will not be proven to improve traffic safety.
Caltrans Modeling, Estimates and Conclusions are Inaccurate, Misleading or Unfounded
* The analysis and applied screening criteria used by Caltrans to assess the relative benefits, impacts and costs of proposed EIR alternatives have been rejected as inadequate and inaccurate in three separate EIRs.
* Some of the alternatives for expansion showing increased PM (particulate matter pollution) levels, yet decreased health risks.
* The EPA and US Army Corps of Engineers have raised valid concerns regarding the analytical methodologies used to evaluate potential impacts of the I-710 Corridor project.
The I-710 Corridor is Already a “Diesel Death Zone” of Environmental Injustice
* The DEIR states “Diesel particulate matter (DPM) is the greatest contributor to air quality-related cancer risk in the South Coast Air Basin” and that “approximately half of the DPM is emitted by diesel trucks using the freeway and roadway systems” yet the preferred alternatives provide four new lanes dedicated exclusively to vehicular freight traffic.
* The communities along the I-710 corridor are subject to continuous over-exposure to hazardous particulate and noise pollution.
* Ninety one percent of the residents living in the I-710 corridor are people of color. Sixty four percent are low income families.
* Women who live near heavy traffic roadways have a greater risk of having low birth weight children and those children are more likely to develop asthma.
* Over a lifetime, living with freeway pollution increases the likelihood of adult onset asthma, heart attacks, cancer and premature death.
The I-710 project WILL NOT Reduce Energy Consumption or Improve Cost Effectiveness
* Building more freeway miles creates “induced demand.”
* Greenhouse gas emissions are directly related to fuel consumption. That means moving freight by rail instead of truck lowers greenhouse gas emissions by 75 percent.
* Los Angeles’ massive network of freeways has caused our region to have the worst air quality in the nation.
* Evidence and research show that if we expand a roadway to relieve traffic, additional drivers will fill the new, momentarily non-congested space, leading to an increase in VMT and emissions.
* Despite well-documented lessons from countless other freeway development projects, Metro claims that new traffic lanes will reduce congestion and truck idling and therefore improve air quality.
* Expanding freeways to accommodate more cars and trucks is not a long term solution to our transportation, infrastructure and environmental needs.
The I-710 project DOES NOT Accommodate Growth in Activities Related to Goods Movement
* Most damage and wear-and-tear to our freeway system is caused by high-tonnage freight vehicles
* High-fatality collisions, toxic spills, fire and explosion risks quadruple when diesel trucks share lanes with general traffic
* The massive reconstruction to correct “highway design deficiencies” is required for Heavy Duty Truck traffic, not general purpose traffic.
* For safety, cost effectiveness, efficiency, pollution control and to accommodate sheer volume, freight traffic must be segregated from passenger traffic
Goods Movement Must Be Rail-Based, Not Road-Based
* Caltrans’ own study states “…on certain freeway segments within the City of Long Beach…, Heavy Duty Trucks make up over 30 percent of the traffic stream during the day, as opposed to an average daily truck percentage of 6 to 13 percent on comparable freeways within Los Angeles County”
* Rail fuel efficiency is 1.9 to 5.5 higher than truck fuel efficiency in terms of ton-miles per gallon.
* 43% of all imported goods arrive in America through the Ports of San Pedro — It does not make sense to move freight one container at a time via truck when rail has a capacity of 600 to 700 containers per train
* Rail is faster, safer, cleaner and less damaging to health and the environment than truck transport.
Negative Right of Way Impacts Will Not be Corrected
* Near-roadway sensitive receptors (schools, hospitals, health centers, old-age homes, etc.) will be exposed to substantial pollutant concentrations that cannot be mitigated— creating “a significant unavoidable adverse impact” under CEQA law.
* The project design has not determined the specific locations of some utility relocations, especially the 66 kV lines owned by Southern California Edison between I-405 and SR-91.
* Metro’s own assessment is that “Permanent noise impacts will be a significant unavoidable adverse impact under CEQA.”
* Caltrans foresees 261 residential displacements causing “significant and unavoidable permanent population and housing impacts.”
* All build alternatives carried forward impact the following facilities: Parque Dos Rios, Rancho Rio Verde Riding Club, Golf Learning Center, Compton Par 3 Golf Course, Coolidge Park, Bandini Park, Cesar E. Chavez Park access/ parking benefit, and Los Angeles River Trail access.
* All build alternatives carried forward create permanent direct impacts to .94 to 4.08 acres of estuarine and riparian/riverine habitats and permanent indirect impacts to 13.46 to 16.21 acres of this habitat.
* Caltrans projects 19 miles of noise barriers will be required for their preferred alternative.