SOUTHSTAR

Engineering and Consulting Inc.

May 25, 2011

Elbert Preston, Jr., President

West Adams Neighborhood Council
334-B E. 2nd Street
Los Angeles, CA 90012

David Winston, Chair

Empowerment Congress West Area NDC
3761 Stocker Street, Suite 108
Los Angeles, CA 90008

Damien Goodmon, Chair

South Los Angeles Neighborhood Council Joint Committee on Rail Transit
3761 Stocker Street, Suite 108
Los Angeles, CA 90008

Synopsis of Findings for the Review of Documents Related to the Crenshaw/LAX Transit Corridor, Park
Mesa Heights Area

Introduction:

As requested by South Los Angeles Neighborhood Councils Joint Committee on Rail Transit Southstar
Engineering has reviewed documentation related to the planning and study for the Park Mesa Heights segment of
the Crenshaw/LAX Transit Corridor to be constructed by the Metropolitan Transportation Authority (MTA). The
Park Mesa Heights segment is defined as a portion of Crenshaw Boulevard between 48th and 60th Streets. The
following are our findings from the document review.

The documents reviewed are:

 Crenshaw Transit Corridor Project Draft Environmental Impact Statement/Draft Environmental Impact
Report (DEIS/DEIR), September 2009.
 Measure R Project Delivery Committee, July 15, 2010, staff memorandum, subject: Crenshaw/LAX
Transit Corridor Project Park Mesa Heights Grade Separation Analysis.
 Crenshaw/LAX Transit Corridor, Park Mesa Heights Grade Separation (PMHGS) Analysis, June 2010.
 Correspondence to MTA from various agencies providing comment on the DEIS/DEIR.

Findings:

According to the PMHGS Analysis report, the Local Preferred Alternative (LPA) currently being considered utilizes
Light Rail Transit (LRT) along Alignment Alternative 5, described in the DEIS/DEIR as:

“Alignment Alternative 5 – Starts at Exposition Boulevard, runs south on Crenshaw Boulevard, and along
the Harbor Subdivision to the Metro Green Line Aviation/LAX Station at Aviation Boulevard/Imperial Highway
(Options A3, B, and C1). (8.5 miles)”
1650 Iowa Ave, Suite 160
Riverside, CA 92507
(951) 342-3120
www.SouthStarEng.com
A variation of Design Option 4 is also being considered as part of the LPA, described in the DEIS/DEIR as:

“Design Option 4. LRT Alternative Design Option 4 involves a cut-and-cover alignment instead of an aerial
alignment between Victoria Avenue and 60th Street. A below-grade alignment between South Victoria
Avenue and 60th Street would replace the aerial alignment proposed under the Base LRT Alternative, starting
on Crenshaw Boulevard and extending into the Harbor Subdivision. The below-grade alignment would be
built as a cut-and-cover tunnel.”

Although the DEIS/DEIR describes the construction method to be used for Design Option 4 as cut-and-cover
construction the PMHGS Analysis report describes this segment of the LPA to be constructed by a Tunnel Boring
Machine (TBM).

In addition, Design Option 6 may be included as part of the LPA, the DEIS/DEIR describes this option as:

“Design Option 6. LRT Alternative Design Option 6 involves a below-grade alignment between 39th Street
and Exposition with a below-grade station at Crenshaw Boulevard and Exposition Boulevard. A below-grade
alignment between 39th Street and Exposition Boulevard would replace the at-grade Base LRT Alternative
alignment and would extend the tunnel north of Martin Luther King Jr. Boulevard to Exposition Boulevard with
a below-grade station. The below-grade station would provide street level access for transferring to the
Exposition LRT. The below-grade alignment could be built as a bored tunnel. A final decision on a below-
grade alignment would be dependent on further analysis of environmental impacts and cost evaluation.”

Findings Analysis:

Project Schedule Impacts:

The PMHGS Analysis report recommends the construction method to be used for Design Option 4, a grade
separation along Crenshaw Boulevard between 60th Street and South Victoria Avenue, would be changed from
cut-and-cover to using a tunnel boring machine (TBM). This change requires additional environmental studies
however the PMHGS Analysis report does not mention this requirement nor the time needed to complete the
studies.

The PMHGS Analysis report states if the grade separation option is selected for the LRT segment along
Crenshaw Boulevard between 48th and 60th Streets start of construction may be delayed 6 to 18 months. The
report states this is due to additional environmental studies needed for the change in project scope to place the
proposed LRT line below grade.

It would seem preparation of the environmental studies needed for constructing the grade separation for the Park
Mesa Heights segment along Crenshaw Boulevard between 48th and 60th Streets may proceed at the same time
the environmental studies are prepared for the change in the construction methods for Design Option 4.
Therefore the project would not be delayed.

Another possible delay in the project schedule may be created during the application process to obtain California
Public Utility Commission (CPUC) approval for the construction of seven new at-grade crossings along Crenshaw
Boulevard between 48th and 60th Streets. The Commission’s policy is to reduce the number of new at-grade
crossings on rail corridors. In fact, in the CPUC October 28, 2009 letter states, “We encourage LACMTA to
evaluate grade separation of any proposed at-grade crossings.”

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Safety:

The DEIS/DEIR and the PMHGS Analysis report have not considered safety impacts caused by the at-grade
section of the LPA to vehicles, pedestrians, and train riders. By not recognizing safety impacts the costs of
mitigation measures have not been included in the cost to construct the LPA at-grade section.

The CPUC October 28, 2009 letter addresses safety concerns related to street-running configurations, stating,
“…proposed street-running configuration and the proposed at-grade crossings will present problematic interaction
between vehicles and Light Rail Trains. Experience has shown that this configuration leads to driver confusion
and vehicle-train collisions, especially from vehicles making left turns across LRT tracks at roadway intersections.”

In light of CPUC assessment of street-running configurations the statement made in the PMHGS Analysis report
Summary is not appropriate. On page 49 of the report under the heading of “Safety” it states, “The at-grade
recommendations for the LPA Option resulted in no significant safety impacts. The determination of safety
impact[s] for both options is the same.” Based on this assertion the credibility of the report’s safety impact
analysis must be questioned.

Lessons provided by the 20-year operation of the MTA Blue Line have not been used in the evaluation of the LPA
at-grade section. The 22-mile Blue Line has 103 at-grade street crossings and is considered one of the most
accident prone light rail lines in the country. MTA has had to make numerous after construction safety
improvements to the line, such as: Crossing gates; red light cameras; and video cameras on train engineers.
However none of the measures have been considered for inclusion with the LPA at-grade section. MTA must also
consider installation of fencing along both sides of the at-grade tracks to discourage pedestrians from crossing
mid-block and therefore limiting train/pedestrian encounters to controlled intersections.

Another LPA safety impact, not discussed in the DEIS/DEIR, is to vehicle passengers exiting to the traffic
(driver’s) side of the vehicle. Currently passengers in vehicles parked along the frontage roads between 48th
Street and Slauson Avenue may exit to the traffic (driver’s) side of the vehicle encountering low volume and slow
moving vehicles. The LPA will require these passengers to exit their vehicles into high volume and high speed
traffic of Crenshaw Boulevard.

Traffic Impacts:

The base LRT LPA proposes to locate a double set of tracks within the existing median area along Crenshaw
Boulevard between 48th and 60th Streets. The existing frontage roads along Crenshaw Boulevard between 48th
Street and Slauson Avenue will need to be eliminated using their area in the overall street cross section to provide
for the tracks, three through lanes, left-turn lanes, and parking lanes.

Neither the DEIS/DEIR or the PMHGS Analysis report discuss the traffic related impacts caused by the elimination
of these frontage roads. The residents along the east side of Crenshaw Boulevard between 48th and 50th Streets
will be impacted. Currently, when residents exit their driveway they can simply back into the frontage road that
has a low volume and slower traffic due to only serving adjacent properties. Entry into Crenshaw Boulevard is
restricted to median openings near intersections. If the LPA is implemented these residents will be forced to back
their vehicles into high volume and faster moving through traffic along Crenshaw Boulevard. This will both impact
the capacity of northbound Crenshaw Boulevard and resident safety.

Along the west side of Crenshaw Boulevard between 50th and 52nd Streets there is a secondary frontage road
parallel to Crenshaw’s primary frontage road. Between these frontage roads is a wall which acts as a visual
and/or noise barrier for the adjacent properties. This wall restricts the sight distance for vehicles exiting the
secondary frontage road. However, currently vehicles exiting the secondary frontage road enter the primary
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frontage road. The sight distance hazard is minimal due to the slower low volume traffic along the primary
frontage road. The LPA will worsen the sight distance hazard by eliminating the traffic buffer provided by the
primary frontage road. Mitigation measures such as providing acceleration for exiting vehicles must be provide by
the LPA project.

The traffic analysis must provide mitigation for the impacts caused by the elimination of the frontage roads related
to the loading and unloading of passengers at the View Park Preparatory Accelerated School. The elimination of
the frontage roads will cause parents to slow in front of the school to find parking, possibly double parking, or
circling the block, cutting through adjacent neighborhoods. This is only one example; there are many other similar
situations for churches and other schools along Crenshaw Boulevard that will not only impact street capacity but
also may impact safety. In order to mitigate safety impacts it may be necessary for these schools and churches,
long time members of the community, to construct passenger loading/unloading facilities on-site. The cost of
these mitigation measures should be borne by the LPA project.

The DEIS/DEIR offers as a mitigation measure to eliminate the left-turn lanes at the Crenshaw Boulevard/54th
Street intersection to improve its level of service. However, there is no discussion of where these vehicles will go
once the left-turn lanes are removed. The DEIS/DEIR must analyze the impacts of these vehicles on other
intersections and other streets within the community that parallel Crenshaw Boulevard. If the analysis finds the
elimination of left-turn lanes will encourage cut-through traffic in the adjacent neighborhoods, Metro must mitigate
these impacts so as not to conflict with the City of Los Angeles General Plan. If mitigation is not possible to
reduce the impacts to insignificance, Metro would be required to operate the LRT with left-turn lanes in service.

The DEIS/DEIR and the PMHGS Analysis report do not evaluate impacts to the operation of the LPA caused by
the inability to implement the left-turn mitigation measure. If the left-turn lanes remain in service train delays will
increase and therefore decrease ridership. All impacts whether upon the community or the LRT operation must
be fully evaluated in order to minimize the impacts of the project to all.

Noise Impacts:

The DEIS/DEIR and the PMHGS Analysis reports do not evaluate all noise impacts upon adjacent properties
within the segment of Crenshaw Boulevard between 48th Street and Slauson Avenue. This section of the LPA
causes the elimination of existing frontage roads, including their areas into the through traffic cross section. This
moves through traffic 18 feet closer to homes, businesses, churches, and schools.

The noise analysis must determine the anticipated noise level for the interior of each property within this segment
to assure the project will not cause City standards to be exceeded. If standards are not met Metro must provide
mitigation measures to decrease anticipated interior noise levels. Mitigation may include replacing windows,
doors, and in some cases upgrading structure insulation at no cost to the property owner, to attenuate noise.

The DEIS/DEIR does not discuss noise impacts caused by reflective noise produced at the transition portals from
at-grade to below grade. Because of the concrete retaining walls used to create these portals, noise will be
reflected from passing trains and vehicular traffic towards adjacent properties.

Parking Impacts:

The LPA project will eliminate 226 on-street parking stalls along the frontage roads of Crenshaw Boulevard
between 48th Street and Slauson Avenue, 69 of which are metered. The DEIS/DEIR provides the following
mitigation for the loss of this on-street parking.

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 ”…the curb parking supply along this corridor will be sufficient to satisfy demand for both the inner and outer
portions of the frontage road as neither is fully occupied, according to existing observations. Side street
parking is also available to motorists. This adverse impact can be mitigated by the shift of parking demand to
available on-street supply in the corridor.”

This mitigation measure is erroneous. It states that “according to existing observations” existing parking is not
fully occupied, however there is no indication as to the time of day or day of the week these observations were
taken. The observations may have been taken during the off-peak for vehicle parking. The analysis should
include numerous observations during the week, including weekends.

This mitigation measure also lacks relief of the project’s impacts to on-street parking in the following ways:

 It does not consider the impacts to the community by shifting “…parking demand to available on-street
supply in the corridor.” Shifting parking of an individual, forces them to park further from their destination,
such as their business or home.
 It does not consider the lost revenue to the local jurisdiction by the elimination of 69 metered parking
stalls.
 It does not consider future parking demands within the community. As traffic increases in a community,
as discussed in the DEIS/DEIR, it is reasonable that parking demands will also increase.

The LPA project must include mitigation measures to replace parking taken by the widening of Crenshaw
Boulevard between 48th Street and Slauson Avenue. The costs to implement these measures must also be
included in the LPA project costs.

In addition, there is no analysis of impacts to traffic capacity and safety caused by moving frontage road parking to
Crenshaw Boulevard. Parking along through traffic lanes will increase the number of potential conflicts between
parked vehicles, either parking or exiting, and passengers exiting vehicles along Crenshaw Boulevard will impact
street capacity.

Pedestrian Impacts:

Elimination of the frontage roads along Crenshaw Boulevard between 48th Street and Slauson Avenue will cause
an increase in the distance pedestrians must traverse to cross intersections, resulting in increased crossing times.
The DEIS/DEIR does not include a discussion of the need to increase pedestrian crossing times nor the impact to
intersection level of service.

Added Costs for LPA:

The cost analysis for the LPA must consider safety improvements needed along the proposed at-grade section
along Crenshaw Boulevard between 48th and 60th Streets. These safety improvements at a minimum should be
those proposed for the existing Blue Line, such as: Crossing gates, red light cameras, and video cameras on train
engineers. In addition to these improvements the LPA cost analysis must include construction of fencing along
both sides of the tracks. The fences will discourage pedestrians from crossing the tracks mid-block and directing
them to cross at control intersections.

Along Crenshaw Boulevard between 48th Street and Slauson Avenue where the LPA proposes to eliminate the
existing frontage roads, MTA must provide residents a way to exit their property by driving forward. This may
require reconstruction of driveways to allow residents paved areas to turn a vehicle around. In addition along the
west side of Crenshaw Boulevard between 50th and 52nd Streets MTA must provide an acceleration lane for
residents to safely exit the “secondary frontage road” to enter the through lanes of Crenshaw Boulevard.
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MTA must provide compensation or replace the 226 parking stalls eliminated by the LPA. They also must
compensate the local agency for lost revenue from the elimination of 69 metered parking stalls. These costs must
be part of the LPA cost analysis.

If the traffic analysis finds that on-site improvements are needed to allow schools and churches to safely load and
unload passengers to vehicles after the elimination of the frontage roads, MTA must provide compensation for
these improvements. These costs must be included with the LPA cost analysis.

Any mitigation measure needed to reduce the impact of eliminating the left-turn lanes at the Crenshaw Boulevard
and 54th Street intersection must be included in the LPA cost analysis. These measures may include installing
new traffic signals or the construction of speed humps in adjacent neighborhoods to slow or discourage through
traffic.

Mitigation measures needed to reduce noise levels, caused by the LPA, within homes, schools, churches, and
businesses must be paid for by the project. MTA must be responsible for the cost for installing noise attenuating
windows, doors, and insulation. The LPA cost analysis must include these costs.

Potential Cost Savings:

The PMHGS Analysis report proposes a track crossover be constructed, for the grade separated option, near the
intersection of Crenshaw Boulevard and Slauson Avenue. Construction of the track crossover is proposed in
conjunction with either a ventilation structure or underground station. However the cost becomes prohibitive when
constructing the crossover in conjunction with a station, due to additional excavation and structure length. More
cost effective locations to construct the track crossover would be; along the Harbor Subdivision right of way
between West Boulevard and South Victoria Avenue; or in conjunction with the Crenshaw/Vernon underground
station. If the Crenshaw/Vernon underground station is constructed within the limits of the “Vernon triangle” and
outside the street limits, the open cut construction of the station and a track crossover will be less costly to the
project than constructing the track crossover within the street at the Crenshaw/Slauson location. Using cut-and-
cover construction within a street requires the use of expensive ‘street decking” in order to keep the street in
service during construction.

Other cost savings may be realized in the construction of the proposed Crenshaw/Vernon underground station. If
the station is constructed outside the street limits, platform access can be directly from street level. A mezzanine
level would not be needed for passengers to cross over the trains to access the center platform. The street level
station entrance would be located over the platform with an elevator and escalator providing direct access. One
elevator and one escalator to carry passengers from the mezzanine level to the platform would not be needed.

Neither the DEIS/DEIR nor the PMHGS Analysis report provide for alternate tunneling methods to constructing
two separate tunnels. Other TBM methods are available such as, boring a single large tunnel or a single
binocular tunnel. A single large tunnel may have a greater volume of excavation than the two separate tunnels
however the construction time will be less. In the case of the singular binocular tunnel, its construction cost would
be equivalent to the cost of two single tunnels however the time to complete the work would be 50% to 60% less,
resulting in cost advantages.

The current proposal by the PMHGS Analysis report places the Crenshaw/Slauson underground station entrance
either at the northwest quadrant of the Crenshaw Boulevard and Slauson Avenue intersection, as stated in the
body of the report, or at the southwest quadrant as shown Appendix A. Either of these locations are not the most
cost effective. Placing the station entrance on either of these properties will require costly full parcel acquisitions
and relocation of businesses. There are several less expensive locations within the immediate vicinity of the

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Crenshaw Boulevard and Slauson intersection. The proposed Crenshaw/Slauson underground station entrance
may be located to the south at W. 58th Place reducing the amount of right of way needed to be acquired. West
58th Place may be closed at Crenshaw Boulevard by use of a cul-de-sac creating an area where the station
entrance may be located. Two other alternate station entrance locations are within parking lots along the east
side of Crenshaw Boulevard. One of these parking lots is across from W. 58th Place the other is north of the
Crenshaw Boulevard/Slauson Avenue intersection. Constructing the station entrance within either parking lot will
require the elimination of parking stalls; however no businesses would need to be relocated, therefore reducing
station construction costs.

Conclusion:

The DEIS/DEIR gives the sense of more a feasibility study for changes in the transit system rather than an
analysis of impacts caused to the community by changes in the transit system. The PMHGS Analysis report,
does not fairly analyze the impacts of the LPA or the environmental benefits of constructing and operating the LRT
below grade. The documents do not consider the significantly reduced impacts to the community TBM
construction will provide over the cut-and-cover construction method.

Safety improvements considered after construction of the Blue Line corridor must also be considered for the LPA
at-grade option. The costs of these mitigation measures must be considered to fairly compare to all alignment
options.

The PMHGS Analysis report must fairly consider impacts to the project schedule regarding the environmental
analysis for construction of the below grade section by TBM along Crenshaw Boulevard between 48th and 60th
Street. Design Option 4 presented in the DEIS/DEIR analyses the construction of the LRT below grade by cut-
and-cover method between South Victoria Avenue and 60th Street. However, in the PMHGS Analysis report this
same segment is to be constructed by TBM. Although ultimately the LRT will be below grade in both options, the
impacts are different for each construction method. The environmental analysis must reflect these differing
impacts. Therefore, during the time needed to analyze construction methods used to grade separate the South
Victoria Avenue and 60th Street segment, an analysis may be performed regarding the below grade construction
of the segment between 48th and 60th Streets. The project would not be delayed.

The environmental studies must address all impacts caused by the elimination of the frontage roads along
Crenshaw Boulevard between 48th Street and Slauson Avenue. The traffic analysis must consider vehicles
backing into through traffic from adjacent properties along the east side of Crenshaw Boulevard between 48th and
50th Streets. The analysis must also evaluate safety impacts caused by the LPA to vehicles exiting the secondary
frontage road along the west side of Crenshaw Boulevard between 50th and 52nd Streets. The traffic analysis
must also consider impacts to intersection level of service caused by increased pedestrian crossings times
needed for the widened intersections and consider impacts caused by vehicles stopping at schools and churches
along Crenshaw Boulevard to load and unload passengers without the benefit of the frontage roads.

The traffic analysis must evaluate the impacts upon other intersections and streets within the community caused
by the elimination of the left-turn lanes at the Crenshaw Boulevard/54th Street intersection. If vehicles currently
using these turn lanes cannot use the lanes in the future there will be impacts on the transportation system,
businesses, and residents. The DEIS/DEIR or PMHGS Analysis report must analyze impacts to the operation of
the LRT if the left-turn lanes remain in service. All impacts whether upon the community or the LRT operation
must be fully evaluated in order to minimize the effects of the project to all.

Noise studies included with the environmental documentation must consider moving through traffic lanes 18 feet
closer to adjacent properties. The LPA proposed the elimination of the existing frontage roads along Crenshaw
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Boulevard between 48th Street and Slauson Avenue and including the width for through traffic lanes. The impacts
of noise on residents, businesses, churches, and schools must be fully evaluated.

The DEIS/DEIR do not fully consider all of the LPA impacts upon on-street parking. The document presents
mitigation measures to shift vehicles, currently using stalls to be eliminated by the LPA, to other areas within the
community. The DEIS/DEIR must analyze all impacts of this shift upon the areas not immediately adjacent to the
LPA project. The parking analysis must consider impacts for future parking demands, much like considerations
for future traffic levels in the traffic analysis. The analysis of on-street parking elimination impacts must also
consider economic impacts upon the local jurisdiction due to the elimination of 69 metered parking stalls.

MTA must consider all options to provide the safest most cost effective project to not only the ridership but also
the community it serves. Above we have offered several options to decrease the construction costs for the
proposed underground LRT and costs not currently considered in the LPA. Construction and right of way costs
can be reduced by locating track crossovers and underground station entrances to sites where construction is
simplified and businesses are not relocated. Other cost savings in the construction of an underground LRT may
be realized by considering other tunneling methods that will decrease construction time, such as singular
binocular or single large tunneling. The single large tunneling construction method provides an additional benefit,
track crossovers may be constructed at any point with no increased cost for added excavation or structure length.

Thank you for considering Southstar to provide this analysis. If there are any questions please contact me at 951-
581-7661.

Sincerely,

Lauren F. Caldwell, P.E.

Project Manager

Expires 12/31/2011

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