Comment # Burbank Comments Metro Response
1 Introduction
2 The DEIR fails to include an adequate range of project alternatives to mitigate potential project impacts. Specifically, the nature of Bus Rapid Transit allows for different BRT elements and roadway cross sections to be implemented depending on the local context of the project. The DEIR includes a project alternative with full BRT implementation including dedicated bus lanes and transit priority lanes on virtually the entire corridor. It also includes an “Improved Existing Bus Service Alternative” that would implement regular transit service frequency improvements but would construct no BRT improvements. This “all or nothing” project alternative approach fails to comply with CEQA’s requirement to evaluate a reasonable range of feasible alternatives.
The DEIR does not acknowledge that the implementation of targeted BRT elements, like bus lanes or queue jumps, installed at high-congestion and other critical areas, can dramatically improve travel time and potentially meet project objectives without creating a significant adverse environmental impact. To be legally adequate, the DEIR should include a project alternative that includes targeted BRT elements in areas where they would have highest impact to improving transit service in the corridor.
The comment mischaracterizes the definition of project alternatives. While the comment characterizes the Proposed Project as implementing dedicated BRT lanes along “virtually the entire corridor,” the Proposed Project has been planned and designed with the local context in mind. There are multiple instances along the proposed route where the Project has foregone proposing dedicated bus lanes and other BRT features based on local considerations and contexts. For example, the Proposed Project would operate in mixed-flow traffic for a portion of the route on Central Avenue between Glenoaks Boulevard and Doran Street and for the entirety of the route in Pasadena. The Alternatives Analysis prepared as a predecessor to the Draft EIR evaluated multiple route alignments and street configurations, and the Proposed Project is the outcome of a multi-year planning process taking into account local considerations and contexts.
The alternatives to the Proposed Project are the No Project Alternative (Alternative 1) and the Improved Existing Bus Service Alternative (Alternative 2). The comment asserts that the Draft EIR must include an alternative that includes targeted BRT elements to satisfy legal requirements for a reasonable range of alternatives. As stated on page 6-8 of Chapter 6, Alternatives to the Project, Alternative 2 would be a local express service with some BRT characteristics. The service may be as frequent as that proposed for BRT with buses that would operate in mixed-flow traffic with transit signal priority systems (i.e., queue jumps as mentioned in the comment). Stops would be more frequent than the BRT line but less frequent than local bus lines (typically every 0.6 miles on average). Travel times would be faster than for local service but slower than the travel times expected from the BRT project. Stops would occur at existing bus stations and there would be no median-running, center-running, or side-running configuration. Alternative 2 includes the targeted BRT elements requested in the comment. In accordance with Section 15126 of the CEQA Guidelines, Consideration and Discussion of Alternatives to the Proposed Project, an EIR need not consider every conceivable alternative to a project. Rather it must consider a reasonable range of potentially feasible alternatives that will foster informed decision making and public participation. This requirement has been satisfied in the Draft EIR. 3 Also, more disruptive BRT elements, such as dedicated bus lanes, have tradeoffs with existing roadway elements like sidewalks, travel lanes and parking. And BRT elements have varying levels of transit improvement relative to adjoining vehicle traffic congestion and delays. The DEIR does not include adequate information on the existing congestion levels and delays on the corridor relative to the proposed transit service for the public and decision makers to evaluate the relative improvement and tradeoffs that BRT elements like dedicated bus lanes have along different segments of the project corridor. The DEIR therefore does not include adequate project alternatives nor information on existing roadway congestion levels to fully disclose the relative benefits, tradeoffs, and impacts that the project has on the environment. In particular, there is insufficient information in the DEIR for the public and decision makers to evaluate whether the proposed bus lanes on Olive Avenue and Glenoaks Boulevard should be implemented as peak-only bus lanes, or whether buses should travel in more mixed-flow segments because existing vehicle congestion and delay in the existing general purpose lanes is low and therefore bus lanes are not warranted.
The 2020 CEQA Guidelines do not require traffic congestion analyses. Metro is not required to consider traffic congestion in the CEQA process, although it may be considered by the Board of Directors during the decision-making process. Traffic analysis information has been provided to the City of Burbank outside of the CEQA process. Based upon the traffic analysis, signalized intersections along Olive Avenue are projected to operate at LOS D or better with the exception of the intersections at Buena Vista Street, Verdugo Avenue/Sparks Street, and Victory Boulevard, which are forecast to operate at LOS E or F in 2042 for No Project and/or Proposed Project Scenarios. Signalized intersections along Glenoaks Boulevard are projected to operate at LOS D or better under the No Build and With Project Scenarios. These results are generally consistent between the No Project and Proposed Project Scenarios.
Matrix of Burbank DEIR Comments and Metro FEIR Responses Attachment 4
ATTACHMENT 4-1
4 The project alternative proposes to install a new BRT transit station at the top of the Olive Avenue overpass to directly connect BRT riders to the Downtown Burbank Metrolink Station below. The City of Burbank suggested and proposes this direct connection. However, the implementation of this connection as described in the DEIR introduces substantial transportation policy and safety impacts by reducing travel lanes on Olive Avenue contrary to the Burbank General Plan and creating a pedestrian crossing and travel lane merge movements along an old bridge vertical curve that will likely introduce new safety impacts. The construction of the proposed station is also likely infeasible because any types of heavy construction including station platforms, ADA ramps, signal foundations, pull boxes, and underground conduits will likely compromise the structural integrity of the existing bridge. The DEIR should include a project alternative that implements this station by widening the Olive Avenue bridge to expand pedestrian sidewalks, improving substandard bridge railings, creating a bus turnout and station platform outside of the existing Olive Avenue roadway, and constructing a second elevator on the south side of Olive Avenue to eliminate the proposed hazardous pedestrian crossing. This project alternative would eliminate several project impacts identified above, and would likely contribute to an environmentally superior project alternative.
Metro has revised the design of the Proposed Project to eliminate the proposed station on the Olive Avenue bridge and is no longer considering implementing dedicated bus lanes in this location. The location of the station has instead been shifted to Olive Avenue at Lake Street.
5 The Project Alternatives section identifies that the No Project Alternative is environmentally superior, and then identifies the “Improved Existing Bus Service Alternative” (Alternative 2) as the environmentally superior alternative of the remaining two build alternatives. The project alternative is not identified as environmentally superior and the DEIR fails to address how the project alternative meets the stated project objectives better than the environmentally superior alternative to warrant it being chosen over the environmentally superior Alternative 2. Based on this omission, the public and decision makers are led to believe that Alternative 2 should be selected as the preferred project, rather than the proposed project. As such, the alternatives analysis is legally inadequate.
The comment misinterprets the purpose of identifying the environmentally superior alternative in a Draft EIR. The comment suggests that the Proposed Project could be the environmentally superior alternative, which is not accurate. As stated on page 6-17 of Chapter 6, Alternatives to the Project, CEQA Guidelines Section 15126.6 requires that an “environmentally superior” alternative be identified among the alternatives that are evaluated in the Draft EIR to foster informed decision-making. The environmentally superior alternative is the alternative that would be expected to generate the fewest adverse impacts when compared to the Proposed Project while attaining most of the basic objectives of the Project. For the North Hollywood to Pasadena Bus Rapid Transit Corridor Project, the No Project Alternative is considered the environmentally superior alternative because there would be no physical changes to the existing environment resulting in construction or operational impacts. If the No Project Alternative is identified as the environmentally superior alternative, CEQA requires identification of the environmentally superior alternative other than the No Project Alternative from among the Proposed Project and the other alternatives evaluated in the Draft EIR. Alternative 2 is the environmentally superior alternative among the remaining alternatives because, as compared to the Proposed Project, it avoids or reduces all construction impacts related to transportation, biological resources, cultural resources, noise, and tribal cultural resources. It also avoids or reduces operational impacts related to transportation, aesthetics, cultural resources, and geology and soils. CEQA does not require that the alternatives analysis in the EIR address how the Project or its alternatives meet the stated Project Objectives, simply that a reasonable range of alternatives to the project, or the location of the project, be identified for decision-making purposes. The comment does not take issue with the ability of either the Proposed Project or Alternative 2 to meet the Project Objectives. CEQA does not require the feasibility determination (including discussion of the degree to which the alternatives meet the objectives) to be included in the EIR (Flanders Foundation v. City of Carmel-by-the-Sea (2012) 202 Cal.App.4th 603.).
The decision to the approve the Project will require a finding on the feasibility of the alternatives to the project weighing the desirability of the project “based on a reasonable balancing of the relevant economic, environmental, social, and technological factors against the benefits of the Environmentally Superior Alternative. This decision is left to the Metro Board of Directors as the decision-making body for the Proposed Project.
6 Policy compliance intro
ATTACHMENT 4-2
7 The DEIR fails to disclose the significant adverse impact the project will cause on maintaining the City’s circulation network and street classifications. The Burbank General Plan designates Olive Avenue as a Major Arterial (General Plan Exhibit M-2) with five travel lanes. Major arterials should give priority to regional transit and auto traffic, and should encourage good transit and automobile progression using traffic signal timing (General Plan Page 4-11). The DEIR indicates that Olive Avenue would retain two travel lanes on Olive Avenue in each direction, but fails to disclose that the project would remove one travel lane in each direction on the Olive Avenue overpass of Interstate 5, which reduces the number of travel lanes from five lanes to three and conflicts with the General Plan street classification and roadway cross section requirements for major arterials which requires two lanes in each direction. The DEIR is inadequate in disclosing this significant roadway policy impact and in failing to identify appropriate mitigation measures for this impact. The DEIR must disclose congestion and potential impacts to public safety caused by narrowing of Olive Avenue to one lane in each direction. The DEIR must include a project alternative or mitigation measure that implements this station by widening the Olive Avenue bridge to expand pedestrian sidewalks, improving substandard bridge railing, creating a bus turnout and station platform outside of the existing Olive Avenue roadway, and constructing a second elevator on the south side of Olive Avenue to eliminate the proposed hazardous pedestrian crossing.
The comment incorrectly states that the Draft EIR must disclose and mitigate significant congestion impacts related to reducing travel lanes on Olive Avenue. The 2020 CEQA Guidelines do not require traffic congestion analyses. Metro is not required to consider traffic congestion in the CEQA process, although it may be considered by the Board of Directors during the decision-making process.
Review of the City’s Mobility Element and street classification system did not identify a requirement for Major Arterials to provide and maintain two travel lanes in each direction but rather a requirement for Major Arterials to maintain a 76-foot Traveled Way and a 100-foot Right of Way (Mobility Element on page 4-11). Regardless of the lane configuration of Olive Avenue, the existing width of right-of-way would by maintained by the Project. Further, the City’s Mobility Element street classification system identifies several priorities and requirements for Major Arterials. In order, the priorities are (1) Where transit conflicts with cars, design streets to maximize person versus vehicle throughput, (2) On-street parking may be removed to accommodate transit stops or turn lanes. Maximize traffic signal coordination; consider transit signal priority, and (3) Property dedication may be required to maximize sidewalk widths or to provide intersection capacity enhancements. To the extent that the Project presents a conflict between transit and cars due to the conversion of a travel lane to a side- running bus lane, the Project maximizes person versus vehicle throughput by providing a premium transit service along Olive Avenue, consistent with the street classification list of priorities.
Metro has revised the design of the Proposed Project to eliminate the proposed station on the Olive Avenue bridge and is no longer considering implementing dedicated bus lanes in this location thereby maintaining the existing lane configuration through the Olive Avenue Bridge.
8 The DEIR is inadequate in failing to disclose a roadway policy impact with Burbank General Plan Mobility Element Policy 1.2.
The project proposes to widen the entire length of Olive Avenue by one to two feet through the entire length of the City to accommodate a transit-only bus lane. Burbank2035 General Plan Policy 1.2 does not support “wholesale changes to street rights-of-way,” therefore the project is inconsistent with Policy 1.2.
The comment mischaracterizes the Proposed Project. The Proposed Project does not include street widening (i.e., narrowing of the sidewalk).
9 The DEIR is inadequate in identifying roadway policy significant impacts with the Burbank General Plan Mobility Element. The project would require the curb-to-curb street width of Olive Avenue and Glenoaks Boulevard to be widened by up to four feet along the entire length of the project, which conflicts with Mobility Element Policy 3.4. The DEIR does not investigate feasible mitigation measures to address this policy impact, such as project alternatives that preserve the existing street roadway width consistent with this policy. Further, the DEIR does not identify the numerous locations along Olive Avenue where the half-street street right-of-way width is only 40 feet, , which may be insufficient to accommodate the proposed project’s 36-foot wide half- street width (72-foot total width)without eliminating sidewalks. Providing ADA-accessible sidewalks in these locations may require property acquisition which is not disclosed in the DEIR, and which is inconsistent with Policy 3.4.
The comment mischaracterizes the Proposed Project. The Proposed Project does not include street widening (i.e., narrowing of the sidewalk). The Proposed Project has been designed to avoid widening and acquisitions as feasible. This is consistent with Policy 3.4 which states, “Consider street widening and right-of-way acquisitions as methods of last resort.” Details of the size and location of any potential acquisitions have not been identified at this stage in the design process. 10 The DEIR is inadequate in assessing the proposed project's impact on Olive Avenue and Glenoaks Boulevard arterial street efficiency, and does not disclose whether the project will cause arterial spillover traffic into adjacent residential neighborhoods.
The proposed project sincludes transit signal priority and queue jumps at intersections, but does not disclose how therse improvements may influence arterial street traffic. In particular, Olive Avenue isa diagonal street that intersects other north- south and eas-weststreets near the proposed project, and may prevent the City from synchronizing its other arterial streets.
The DEIR must disclose and analyze how potential transit system signal priority will affect the City's arterial traffic signal coordination and synchronization.
Where proposed, the curb-running bus lanes configuration is not anticipated to result in spillover traffic into residential neighborhoods, since the curb-running bus lanes configuration maintains the existing number of travel lanes throughout most of Burbank. The side-running bus lanes configuration, which reduces the number of travel lanes on Olive Avenue between Buena Vista Street and Lake Street, is expected to result in a shift of traffic to parallel streets including Alameda Avenue and Burbank Boulevard. Not much traffic is expected to divert to local residential roadways, since out-of-direction travel would be required resulting in longer travel distances and longer travel times, especially considering the speed impediments along the local residential roadways (e.g., stops signs, speed bumps). 11 The proposed corridor passes by, but does not serve, the Disney Studio Campus and St. Joseph's Hospoital and related medical complxes at the intersection of Buena Vista and Alameda Avenue….SEIR should study a route alternative to divert the project alignment onto Alameda Avenue and Buena Vista Street to serve this major employment and community center, and including a stop at the Buena Vista Street/Alameda Avenue intersection.
The Proposed Project follows the Alameda Avenue and Buena Vista Street alignment suggested in the comment and includes a station in proximity to the Alameda Avenue and Naomi Street intersection.
ATTACHMENT 4-3
12 The Burbank2035 General Plan identifies a future bus transit center to be located within the Burbank Media District, at a location where local and regional bus lines intersect. The proposed project includes a station located where this future transit center is identified. However, the DEIR fails to analyze how the proposed project supports or inhibits the development of this transit center. The DEIR should evaluate how the construction of the proposed project's stop at Hollywood Way/Riverside Drive/Olive Ave can serve as the foundation for a future bus transit center in the Media District, specifically how the proposed project's station will provide connections to BurbankBus, Metro Local, and Metro Express Service in the MEdia District while supporting required first-last mile improvements necesary to support the station.
The Proposed Project would not acquire land in Burbank that would potentially be used for a transit center in the Media District. The Proposed Project would improve, and not interfere, with the City’s ability to create a new transit center in the Media District, as set forth in Policy 4-3 of the Burbank2035 General Plan Mobility Element. 13 The DEIR fails to analyze how the propsoed project is compatible with Burbank2035 General Plan Mobility Element Policy 4.8 relating to the project's seamless connection between the Downtown Metrolink Station as well as the City's existing and planned off-street bicycle network that serves the Downtown Burbank Metrolink Station. The proposed transit station on the Olive Avenue overpass does not support a seamless connection to the existing Burbank Channel Class I Bikeway, and the future Chandler Extension Class I Bikeway because it requires eastbound riders to navigate a circuitous route across Olive Avenue and down the existing elevator. The proposed project should promote a more seamless connection to these other transportation systems by implementing this station by widening the Olive Avenue bridge to expand pedestrian sidewalks, improving substandard bridge railings, creating a bus turnout and station platform outside the existing Olive Avenue roadway, and constructing a second elevator on the south side of Olive Avenue to eliminate the proposed hazardous pedestrian crossing.
Metro has revised the design of the Proposed Project to eliminate the proposed station on the Olive Avenue bridge. The location of the station has been shifted to Olive Avenue at Lake Street. 14 The DEIR fails to analyze the proposed project’s potential ridership impacts to the existing BurbankBus Pink Route service in conflict with Burbank2035 General Plan Mobility Element Policy 4.8. The Pink Route provides local service along the Olive Avenue corridor and connects the Universal City Red Line Station and Downtown Burbank Metrolink Station to the Media District. This impact is especially pertinent as the City is being asked to become the primary local transit provider in the corridor due to the NextGen Bus Plan eliminating Metro 155 service.
The alignment of the Proposed Project overlaps with the BurbankBus Pink Route between Hollywood Way/Riverside Drive/Olive Avenue in the Media District and the Downtown Burbank Metrolink Station. The Proposed Project’s limited-stop service will complement the local service provided by the BurbankBus Pink Route. In addition, the BurbankBus Pink Route will obtain travel time and reliability benefits from the dedicated bus lanes implemented for the Proposed Project. 15 The DEIR fails to disclose a significant policy impact with Burbank2035 General Plan Mobility Element standard sidewalk width requirements. The project would widen Olive Avenue and Glenoaks Boulevard by one to two feet in both directions to convert the existing on-street parking into a bus-only lane. This would require sidewalks widths on Olive Avenue and Glenoaks Boulevard to be reduced below the standard widths identified in the Burbank2035 General Plan (Table M-2 – Sidewalk Standards, Page 4-21). The sidewalk width standards are generally 15 feet along the project corridor, and the required street widening would reduce these widths to 14 feet. In some locations on Olive Avenue, sidewalk widths would be reduced to 4 feet, which does not meet ADA minimum width standards. The DEIR fails to identify a significant transportation impact, nor does it identify feasible mitigation measures to this significant impact. Burbank General Plan Mobility Element Policy 9.2:
Address the needs of people with disabilities and comply with the requirements of the ADA during the planning and implementation of transportation improvement projects. The DEIR fails to disclose a significant policy impact with the Burbank General Plan Mobility Element because the project proposes to reduce sidewalk widths on Olive Avenue in certain segments to four feet wide, which is below the ADA minimum width.
The comment mischaracterizes the Proposed Project. The Proposed Project does not include street widening (i.e., narrowing of the sidewalk).
16 The DEIR fails to disclose a policy impact with the Burbank General Plan Mobility Element Planned Bicycle Routes and the Bicycle Master Plan Top Priority Projects, which both include the addition of Class II bicycle lanes on Glenoaks Boulevard between Providencia Avenue and Alameda Avenue, with connections to the Class III bicycle route on Providencia Avenue.
Further, the project precludes the City from connecting this planned facility to the Downtown Burbank Metrolink Station via Glenoaks Boulevard between Providencia Avenue and Verdugo Avenue, which is a bicycle network gap identified in the City’s Complete Streets Plan. The DEIR must identify a mitigation measure for this policy impact.
The Proposed Project would operate in mixed-flow traffic on Glenoaks Boulevard between Olive Avenue and Providencia Avenue; thus the Project would not impact the City of Burbank’s ability to address a gap in the bicycle network on Glenoaks Boulevard between Verdugo Avenue and Providencia Avenue.
ATTACHMENT 4-4
17 The DEIR fails to disclose a potential transportation impact by introducing a hazard due to a geometric design feature. The project proposes to construct a transit station at the top of the Olive Avenue Overpass, and install a signalized pedestrian crosswalk at the crest of the overpass. The DEIR did not analyze of the placement of this pedestrian crossing at the top of a 60 year old overpass with poor vehicle sightlines due to high roadway grades caused by the profile of the overpass. The project proposes to construct two roadway travel lane drops on the overpass immediately approaching the proposed station platform, and the DEIR does not disclose or analyze whether the introduction of this roadway design feature on the existing overpass creates a potentially significant adverse impact. The project also proposes to introduce additional pedestrian traffic travelling to and from the new station platform. These pedestrians will be boarding and alighting buses mixed with through pedestrian traffic on the bridge’s existing seven foot sidewalks. These sidewalks are located along bridge railings that are of substandard height (39 inches) separating pedestrian traffic from falling to the Interstate 5 freeway below Metro has revised the design of the Proposed Project to eliminate the proposed station on the Olive Avenue bridge. 18 The DEIR fails to analyze whether the proposed station loading platforms with midblock crosswalk on the Olive bridge is feasible. A midblock crosswalk on the Olive bridge is likely hazardous for pedestrians and vehicles due to creating a visibility issue on the bridge’s vertical curve. The DEIR did not adequately investigate whether a signalized crosswalk can be constructed on the existing Olive bridge given the types of heavy construction including station platforms, ADA ramps, signal foundations, pull boxes, and underground conduits that will be required and may likely compromise the structural integrity of the existing bridge. The DEIR is inadequate in analyzing these potential safety impacts and identifying mitigation measures for those potentially significant adverse impacts. The DEIR should include a project alternative or mitigation measure that implements this station by widening the Olive Avenue bridge to maintain four travel lanes, expand pedestrian sidewalks, improve substandard bridge railings, creating a bus turnout and station platform outside of the existing Olive Avenue roadway, and constructing a second elevator on the south side of Olive Avenue to eliminate the proposed hazardous pedestrian crossing.
Metro has revised the design of the Proposed Project to eliminate the proposed station on the Olive Avenue bridge. 19 The DEIR fails to analyze a potential transportation impact caused by a hazardous geometric design feature by proposing bus left turn movements to westbound Olive Avenue from the far-most right turn lane of northbound Glenoaks Boulevard. The DEIR does not disclose this potential hazardous condition or identify mitigation measures to reduce potential significant impacts. Making a left turn from the far-most right turn lane also violates California Vehicle Code Section 22100(b) and may cause other drivers to unintentionally copy the same movement, thereby introducing a new hazardous condition for pedestrians and road users.
The Proposed Project will operate in mixed-flow traffic on Glenoaks Boulevard on the approach to Olive Avenue; thus, the proposed BRT will execute a left-turn to westbound Olive Avenue from the left-turn lane shared with automobile traffic. 20 The DEIR fails to analyze a potential transportation impact caused by a hazardous geometric design feature by proposing to install center-running median bus lanes on Glenoaks Boulevard at the Alameda Avenue and Providencia Avenue intersections across conflicting left turn movements to these streets. The DEIR does not disclose this potential hazardous condition or identify mitigation measures to reduce potential significant impacts.
The Proposed Project would be designed in the engineering phase to confirm that left-turn movements can be executed in a safe manner at the Glenoaks Boulevard intersections with Providencia Avenue and Alameda Avenue. The eastbound-westbound left turns would operate under a protected signal phase. If geometric analysis demonstrates a conflict between the routing of the eastbound and westbound left turns if they operate concurrently, lead-lag signal phasing can be implemented so the eastbound and westbound left turns occur during separate protected signal phases.
21 The proposed project allows right-turning vehicles to merge with the curb-running bus lane approaching each intersection and allows right turns be made from the bus lane. Existing right turn lanes with protected right turn signal indication cannot be merged with the curb-running bus lane due to the complexity of the signal operation at these locations. Removing the protected right turn indication will compromise vehicular safety at these locations. The DEIR failed to analyze the impact of traffic circulation should these protected right turn lanes be removed. The DEIR fails to analyze a potential transportation impact caused by hazardous geometric design feature by proposing to integrate the bus stations into the sidewalk area and using a curb extension to facilitate access and pedestrian circulation.
The curb-running bus lanes configuration along Olive Avenue and the BRT stations along the sidewalks are not expected to create a hazardous geometric condition. Likewise, the side-running bus lanes configuration along Olive Avenue with the BRT stations provided along curb extensions are not expected to create a hazardous geometric condition. Right turns are allowed to be made from dedicated bus lanes across many BRT systems, including along Wilshire Boulevard locally. Metro will work with the City of Burbank during the Project’s engineering phase to confirm that the Proposed Project does not create hazardous geometric conditions. 22 The DEIR fails to adequately analyze if including 11 foot bus only curb lanes adjacent to the existing 10 foot travel lanes on Olive Avenue and Glenoaks Boulevard will create a potentially significant adverse safety impact. The DEIR should analyze how the geometric configuration of BRT elements, such as dedicated lanes, curb extensions, and bus stations may create hazardous geometric design features, particularly where the alignment is required to make left or right turns, enter, exit, and cross freeway ramps, bicycle facilities, and pedestrian crossings at intersections.
The Proposed Project’s BRT will abide by traffic regulations when operating in the street right-of-way. Lane widths and traffic control measures will meet the applicable design standards. Therefore, the Proposed Project is not expected to create hazardous geometric design features.
ATTACHMENT 4-5
23 The DEIR appears to use the “related projects list” method of analyzing potential cumulative impacts. The list of cumulative projects (Table 5-1, Page 5.2) included in the Cumulative Impact section of the DEIR omits several projects in the City of Burbank, including approved entitlements for the City’s three major studio campuses. The City of Burbank’s cumulative project list can be provided to Metro to add the additional cumulative projects located within ½ mile of the project alignment The comment states that the cumulative project list is missing several projects within the City of Burbank that should be included in the Cumulative Impact Analysis. Please see Chapter 3, Corrections and Additions, of the Final EIR for the updated cumulative projects list based on information provided by the City of Burbank on May 3, 2021. The updated cumulative projects list clarifies and amplifies the information provided in the Draft EIR. No new or substantially more severe cumulative impacts have been identified based on the updated list. The additions to the cumulative list do not directly or indirectly affect the environmental resource analyses included in Chapter 5, Cumulative Impacts, of the Draft EIR. Therefore, no revisions to the cumulative impact analysis are necessary. 24 The DEIR related projects list includes the City of Los Angeles Colorado Boulevard Specific Plan, but does not include the two City of Burbank Specific Plans that the alignment passes through (Media District and Burbank Center Specific Plans). Further, the Burbank Center Plan is not considered in the Population and Housing Section of the DEIR.
Both the Burbank Media District and the Burbank Center Specific Plans were included in the analysis of population and housing and land use impacts, as discussed in Appendices Q and L, respectively. Conflicts and compliance with these planning documents were assessed individually in these technical analyses rather than cumulatively. The Proposed Project would be compatible with the land use plans, goals, and policies adopted by the regional and local jurisdictions within the Project Area. While it is anticipated that land uses in the Project Area will change over time to address growing population and regional demands for infrastructure and services, individual City jurisdictions and metropolitan planning organizations such as SCAG are responsible for planning such development. Land uses surrounding the Proposed Project stations may intensify due to transit oriented development (TOD) pressures and zoning initiatives that have been planned and encouraged by the Project Area cities including the Cities of Los Angeles, Glendale, Burbank, and Pasadena. This growth pattern would be consistent with regional planning efforts to focus future growth in areas served by transit to address environmental concerns related to climate change and availability of services and infrastructure to meet future demand. Accordingly, the Proposed Project would be consistent with regional and local plans aimed at improving regional mobility and focusing growth in areas well served by transit. As described in Chapter 4, Other Environmental Considerations, of the Draft EIR, no significant impacts related to land use or population and housing were identified.
25 The DEIR related project list includes the unfunded Metro Los Angeles – Glendale – Burbank Feasibility Study, but does not include the funded Antelope Valley Line Improvement Project, which will fund capital improvements to expand Metrolink service to 30 minute, all-day, bi-directional service. The DEIR’s failure to include these service improvements as a cumulative project makes the DEIR inadequate in analyzing the need for the BRT project to seamlessly connect to this important regional connection, and inclusion of this cumulative project would likely provide support for the Olive Avenue / Metrolink transit stop improvements described elsewhere in this comment letter.
The comment states that the EIR omitted analysis of Metro’s Antelope Valley Line (AVL) Capacity and Service Improvements Project in the cumulative projects list and therefore omits necessary analysis of the need for the Project to have additional improvements to the Burbank Metrolink station connection. The AVL Capacity and Service Improvements Project has been added to the analysis in the EIR. Please see Chapter 3, Corrections and Additions, of the Final EIR. Adding AVL to the cumulative list does not directly or indirectly affect the environmental resource analyses included in Chapter 5, Cumulative Impacts, of the Draft EIR. The AVL Capacity and Service Improvements Project does not propose any improvements to the Burbank Metrolink station or tracks in the vicinity of the Proposed Project and simply proposes increased frequency of service to the station. The Proposed Project no longer proposes any improvements to the Olive Avenue bridge where the Burbank Metrolink Station is located. Thus, there is no potential conflict between the Proposed Project, the existing Burbank Metrolink Station, or existing and future Metrolink service. 26 The DEIR identifies the Metro / City of Burbank Olive/Verdugo/Sparks intersection improvement project as a related project, but does not identify the conflict the proposed project would have with the City’s planned improvement of this intersection, which would construct pedestrian, bicycle, and vehicle channelization improvements that would preclude the installation of bus lanes through the intersection.
The Draft EIR acknowledged proposed spot widening to add a curb-running bus lane through the Olive Avenue/Sparks Street/Verdugo Avenue intersection and potential overlap of the two projects’ construction activities. The Project now includes a side-running bus lane instead of a curb-running bus lane and Metro no longer proposes widening at this location. Metro is committed to working with the City of Burbank during engineering to confirm that improvements are not in conflict with the City’s planned improvements at the Olive/Verdugo/Sparks intersection. It should be noted that at the time of this Final EIR, the City of Burbank has not prepared publicly- available design plans for the improvements nor programmed funds for the improvements. 27 The DEIR identifies the City of Burbank Olive Avenue Bridge Improvement project as a related project, but does not disclose that the proposed narrowing of Olive Avenue to one lane in each direction is in conflict with one of the purposes of the bridge improvement, which is to improve operational efficiency while also adding bicycle and pedestrian improvements to the bridge.
Constructing a transit stop at the top of the bridge in the middle of the travelled roadway would conflict with this project. These numerous omissions and inconsistencies render the Cumulative Impacts analysis legally inadequate because the findings and conclusions are not supported by substantial evidence.
Metro has revised the design of the Proposed Project to eliminate the proposed station on the Olive Avenue bridge as well as dedicated bus lanes across the bridge.
ATTACHMENT 4-6
28 The DEIR identifies that a significant aesthetic impact would occur if the project would “substantially damage scenic resources, including…trees…” and identifies several impacts to existing mature tree landscape elements along the corridor outside the City of Burbank (Page 3.2-14). However, the project does not apply this threshold to the City of Burbank and therefore does not identify impacts to mature street trees in the City of Burbank. In particular, the project would require the removal of several rows of large mature street trees on Olive Avenue and Glenoaks Boulevard in Downtown Burbank. These trees would be removed because the project is required to widen Olive avenue by one to two feet for the proposed project. By applying the project’s aesthetic impact significance thresholds to the City’s street trees, the DEIR should identify a significant impact to aesthetic resources in Burbank by removing these trees, and should identify feasible mitigation measures to lessen these impacts. In addition, the DEIR must analyze the removal of these trees as a significant Biological Resources impact give the contribution these mature street trees give to the City’s urban forest resources. Without this additional analysis, the Aesthetics and Biological Resources impact analyses are legally inadequate because they are not supported by substantial evidence.
At this stage of the Conceptual Design, it is anticipated that a majority of the street trees along Olive Avenue would remain unaffected by the Project and further design refinement would be needed to identify the precise number and location of affected trees. Side-running bus lane configurations of the Proposed Project are anticipated to have fewer impacts on trees than the no longer considered curb-running configuration. The removal of street trees was not considered a significant impact alone unless those street trees have been identified by stakeholders as important aesthetic resources through scoping comments or in a planning document. In absence of a clear identification of a given resource’s importance, impacts to aesthetic resources were assessed based on the context to the aesthetic environment and input from stakeholders, local jurisdictions, and the public. The Draft EIR acknowledges that tree removals could occur at various locations but notes that further design refinement during the Preliminary Engineering phase would avoid most conflicts with existing street trees located within sidewalks. Further, Mitigation Measure VIS-1 would reduce any impacts to streetscape vegetation to a less-than-significant level by requiring replacement landscaping in accordance with local streetscape requirements and design criteria. 29 The DEIR indicates that the proposed project will cause no impact to police public services because it will not lead to an increase in police service calls or the local jurisdictional service ratio. However, there is no evidence to support this conclusion (Page 4- 22). The DEIR states that the project will be subject to Metro’s transit police strategy including Transit Services Bureau officers and contracted polices services. But it does not state directly if the proposed project will be patrolled and staffed by Metro transit police or local jurisdictional police, and if local police will be contracted to provide police service. Also, the DEIR is silent on whether local or Metro law enforcement will be required to enforce bus-only lanes and other transit-only facilities, and fails to define the requirements and costs to enforce bus-only facilities. The DEIR fails to adequately identify if the project will pose a significant adverse impact to police service. Therefore, the Public Service impact analysis is legally inadequate because it is not supported by substantial evidence.
Contrary to the comment’s assertion, the Draft EIR does not state that the Project would have no effect on police service calls or service ratios, but rather states that no police facilities would be affected and no changes in population would result requiring new or expanded police service or facilities. As stated in the Draft EIR, police response may improve as the dedicated bus lanes would be available to emergency vehicles in the event of an emergency, avoiding typical roadway congestion. Metro acknowledges that its transit policing strategy generally only applies to Metro facilities such as stations and that some local police service would be required to respond to service calls along the Project corridor; however, there are existing Metro bus services and facilities within the City of Burbank and it is anticipated that no significant change in the frequency, nature, or magnitude of police service requirements would be posed by the Project. As described in the Draft EIR, new BRT stations would be designed using Metro’s Design Criteria which maximize lighting, visibility, and overall user safety which may improve safety along the Project route. Regarding enforcement of bus lane restrictions, Metro would coordinate with the City and local police service agencies to develop appropriate enforcement strategies. Per newly enacted legislation under Assembly Bill (AB) 917, operations of the Proposed Project may incorporate camera enforcement on the buses. 30 The DEIR indicates that the project will have no impact to electric utility systems, but does not document why this statement is true. Metro is proposing to utilize electric transit vehicles for the project, which could require substantial electrical utility system improvements if vehicle charging is expected to occur within the City of Burbank. The DEIR indicates that “the location of charging stations for electric buses would be analyzed and located where sufficient capacity is located” (Appendix S, Page 29) but does not include this analysis in the DEIR. The DEIR is insufficient in determining whether the proposed project will create a significant impact to the City’s electrical utility system.
As discussed in Chapter 4, Other Environmental Considerations, of the Draft EIR there is no plan to locate electric bus charging infrastructure in the City of Burbank and the infrastructure required to charge vehicles for the Proposed Project and the Metro fleet generally would be located where adequate capacity is available. The Draft EIR does identify the North Hollywood Metro B/G (Red/Orange) Line Station as a likely location for charging infrastructure and another location at Pasadena City College is under consideration. Currently and for the purposes of the EIR, it has been assumed that overnight electric charging infrastructure for the Proposed Project would be located at one of Metro’s existing bus depots. No aspect of the planning or design for the Proposed Project has considered electric vehicle charging infrastructure within the City of Burbank.
31 The DEIR fails to identify a significant impact to the City’s recycled water interconnect with the City of Glendale located in the Glenoaks Boulevard median south of Alameda Avenue. The proposed project will likely impact this critical recycled water interconnect including hydrants, valves, vacuum/air release valves, meter boxes, and a fiber optic communication pull box. The DEIR should identify this significant impact and identify mitigation measures to mitigate it.
The comment identifies a recycled water interconnect with the City of Glendale located within the Glenoaks Boulevard median south of Alameda Avenue and states that the Proposed Project would result in impacts to the interconnect. Potential impacts to the referenced interconnect have not been identified during the Project’s early phase of conceptual design. If impacts to the interconnect are identified in the Proposed Project’s engineering and design phase, the design and engineering process will confirm the functionality of the interconnect.
ATTACHMENT 4-7
32 The DEIR fails to identify the impacts caused by several miles of street widening with respect to existing overhead and underground utilities, drainage, sidewalk width, street trees, street lights, sidewalk furniture, landscape, etc. The DEIR should disclose any potential significant impacts to public infrastructure. As such, the Utility Systems impact analysis is legally inadequate because it is not supported by substantial evidence.
The comment states that the Draft EIR does not adequately address potential utility impacts related to proposed street widening. As discussed in Chapter 4, Other Environmental Considerations, of the Draft EIR, construction of the Proposed Project is not anticipated to require or result in the construction or relocation of utilities which could cause a significant environmental impact because utility relocations would be coordinated with utility providers. At this stage in the conceptual design, utility facilities have not been identified as designs are not advanced enough to determine potential conflicts. As discussed in Appendix S Utilities and Service Systems of the Draft EIR a utility composite base map would be developed to outline the utilities within the Project boundary. The base map would be used to identify conflict locations with Proposed Project work and existing utility facilities. Each utility company would need to be contacted on a periodic basis to determine if there are any new plans for their facilities. The utility composite base map would be updated as new information becomes available. Utility coordination meetings would be set up with each utility company with potentially affected facilities to help determine if relocation would be required or the facility could be protected-in-place. The utility coordination meetings would help to confirm the utility companies are engaged early during project development. Preliminary relocation concepts would be developed and presented to each utility owner with affected facilities. In addition, the resource analyses factored in utility relocations, as necessary. For example, the air quality analysis is premised on a regional analysis that accounts for a conservative projection of the maximum daily equipment and vehicle activity that could be occurring along the entire Project corridor in a given day. Analyzing such a worst-case scenario ensures that all other construction activities would not produce air quality impacts that exceed those analyzed in this document. 33 The DEIR fails to document the increased annual pavement maintenance costs to the City’s streets caused by frequent heavy bus service operating in the curb lane of Olive Avenue and Glenoaks Boulevard. Identifying impacts to increased pavement wear could require mitigation measures such as strengthening the roadway cross section in the bus lanes to accommodate heavy bus travel. The DEIR also fails to identify maintenance costs for other roadway elements including signs, striping, traffic signals, and other roadway infrastructure. Additional comments related to civil public infrastructure are attached to this comment letter.
The comment states that the Draft EIR fails to address long-term effects of frequent bus travel on City pavement requiring increased maintenance cost and activities. As discussed in Chapter 2, Project Description, the Proposed Project’s BRT service would operate with 10- minute frequency throughout most of the day on weekdays tapering to 15 to 20 minutes frequency during the evenings, and with 15- minute frequency during most of the day on weekends tapering to 30 minutes in the evenings. Substantial deterioration of the pavement is not anticipated because the Proposed Project’s BRT service would provide only six buses per hour per direction (or approximately 200 buses per day) and would operate in travel lanes on Olive Avenue that already accommodate between approximately 22,000 and 28,000 vehicles per day, including automobiles, trucks, and buses. In addition, concrete bus pads would be installed at the Proposed Project’s BRT stations.
A joint maintenance agreement for Project elements will be developed during final design and prior to the opening of Project operations. 34 The City recognizes that impacts to public parking are not considered CEQA impacts. Nonetheless, the project proposes to eliminate 500 curb parking spaces along Olive Avenue and Glenoaks Boulevard without identifying a parking program or plan to address this lack of curb parking. These parking spaces currently serve a significant amount of mid-century, single story strip commercial development that does not include on-site parking. Removing parking for these land uses without providing a parking program to address this parking loss would create an economic impact on these strip commercial businesses who rely on this curb parking. Removing all parking inventory for these businesses would impact the business viability and prevent use and re-use of these older buildings. Further, wholesale removal of curb parking would push parking demand into adjacent residential neighborhoods, likely requiring the City of Burbank to implement additional permit parking zones in these residentially-adjacent neighborhoods. The DEIR should disclose this potential economic affect and provide a program or plan to offset the loss of parking caused by the proposed project. The DEIR should also propose project alternatives to the implementation of full-time bus lanes in areas where loss of curb parking will impact adjoining land uses.
Metro acknowledges that parking is a concern for the affected community and associated businesses; however, as the commenter states, parking loss and economic or social effects are not considered environmental effects for the purposes of CEQA. The side-running bus lanes configuration retains most of the existing on-street parking. 35 The DEIR fails to disclose if new transit stations will induce additional parking demand around them, especially if parking demand will impact sensitive residential or strip commercial land uses. Bus Rapid Transit is meant to operate similarly to light rail transit, but BRT stations, unlike light rail stations are built without parking. The DEIR should disclose the number of new transit riders at each station who are expected to arrive by automobile and identify potential parking demands caused by the proposed project.
The Proposed Project’s BRT system is not anticipated to induce parking demand, as the BRT stations are spaced more frequently (i.e., closer together) than light rail transit stations. In general, BRT stations are spaced at one-mile intervals, resulting in no greater than a 10-minute walk to access a station.
36 Thank you again for providing an opportunity to comment on the DEIR for the Noho to Pasadena Bus Rapid Transit Corridor Project located in the City of Burbank. If you have any questions regarding the contents of this letter, please feel free to contact David Kriske, Assistant Community Development Director with the Community Development Department, at 818.238.5269 or via email at [email protected].
The comment concludes the letter with contact information for City staff. Metro acknowledges the preceding comments and looks forward to continued coordination with the City of Burbank. No further response is required. 37-62 [Additional Specific Comments provided by Memorandum] [Metro included specific detailed responses to City's Specific Comments - See FEIR Section 4.0 for details] ATTACHMENT 4-8