DRAFT
March 14, 2023
Georgia Sheridan
Project Manager
Los Angeles County Metropolitan Transportation Authority One Gateway Plaza, Mail Stop: 99-22-3
Los Angeles, CA 90012
Email: [email protected]
RE: Metro C Line Extension to Torrance Project Draft Environmental Impact Report Comments Dear Ms. Sheridan:
On behalf of the City of Redondo Beach, California, please accept this letter as the City’s official comment letter regarding the Metro C Line (Green) Extension to Torrance Project Draft Environmental Impact Report (DEIR). The City respectfully submits these comments to you, as the Metro representative accepting the DEIR comments for the project, for consideration as Metro prepares the Final EIR for this project and considers alternative alignments.
As noted in the City’s May 17, 2022 letter to LA County Supervisors Mitchell and Hahn, a copy of which was sent to the LA County Metro Board, the City Council expresses unified support of an elevated Hawthorne Boulevard alignment for the Metro C Line (Green) Extension to Torrance Project which would run along the historic Red Car route. The City of Redondo Beach continues to urge the LA County Metro Board not to gravitate to the Metro ROW alignments. As we detail below, the elevated Hawthorne Blvd. alignment is the most equitable, environmentally sound and the only alternative that promises to connect residents of Central Los Angeles County with the economic powerhouse coming to Redondo Beach along Hawthorne Blvd.
Hawthorne Blvd alignment is the superior to the ROW alignment in all regards except as to cost, which should not drive monumental generational investments.
As part of its decision-making process, Metro studied through the DEIR three potential alignments–the Metro railroad right-of-way (ROW) alignment at-grade, the Metro ROW Trenched, and the elevated Hawthorne Boulevard roadway alignment.
As a preliminary matter, we want you to know that L Catterton (the real-estate arm of LVMH) is in the process of investing nearly half a billion dollars in a mixed retail, 300-unit inclusionary apartment units, office space, and a 150-room hotel at the same intersection that would serve as the Redondo Beach stop for the Hawthorne Blvd. alignment. Between the mall and other uses, L Catterton projects about 750 new, permanent jobs to come to the site. Only the elevated Hawthorne Blvd. alignment would deliver residents from the Willowbrook/Rosa Park station to all of the economic, family and medical centers along Hawthorne Blvd. by delivering them to its intersection with Artesia Blvd. The ROW alignment would deliver these residents to a residential neighborhood. If the County does not seize this monumental, once-in-a-generation opportunity to send the C Line down the most utile path, the C Line could be destined to demise for nonuse.
If located along Hawthorne Blvd., the C Line would also deliver residents from Redondo Beach, Lawndale, Torrance and Hawthorne conveniently to the Crenshaw/LAX Transit Project. If, however, the C Line is extended into our residential neighborhood along the ROW, the C Line would not serve as a central hub to move the masses efficiently to LAX. It would be a pity for government to have spent hundreds of millions of dollars improving LAX and installing a people mover, only to build a C Line extension that does not maximize ridership.
The City of Redondo Beach is united behind elevated Hawthorne Boulevard alignment since it addresses many of our residents’ concerns regarding noise, vibration, resident/child safety, and other factors, as well as having an expeditious, speedy route to the Torrance Transit center which would likely bolster its usership at a time of Metro ridership decline. The Hawthorne Blvd. alignment would also revitalize local businesses through higher visibility and the creation of a vibrant destination for riders.
The City is united behind the Hawthorne Blvd. alignment and against the ROW.
We are very concerned for our mixed-income senior residents at the Breakwater Village. Breakwater Village was built along the Metro ROW in the early 2000’s. It boasts 191 units covenanted for seniors. It includes 20 affordable units, including Section 8 housing. The same is true for the mixed-income residents of the Ruxton Place and Ruxton Ridge, that are home to 27 and 28 units, respectively.
Shell’s drilling on the Metro ROW has created a sinkhole in close proximity to these sites, and even caused a sinkhole on the Ruxton property. For over a year now that sinkhole has been fenced off; residents of the affordable units there do not have regular access to their front doors because the conditions. The land subsidence that occurred at the Ruxton Place is merely symptomatic of the potential, serious hazards that could arise from heavy machinery and construction on the ROW so close to pre-existing, heavy residential developments. To date, Metro has not articulated confidence that the geology on the ROW would permit the C Line to be extended with no damaging effect on the dense residential developments adjacent to the ROW.
As well, the DEIR has concluded that the ROW options will have significant unavoidable noise impacts for the ongoing operations at those alignments. As well, during construction these alignments will have significant unavoidable impacts related to both noise and vibration. Based on the multi-year timeline needed to build the light rail within feet of where many of these neighboring residents sleep nightly, the negative impact that this will have on so many lives, including our seniors’, simply cannot be understated.
Below are the comments specific to the DEIR. With the concerns to the impacts to the quality of life and safety/security of more than 1000 residential households along the ROW alignment options, the City implores that Metro not to move forward with either of the ROW options.
Additional DEIR Comments.
Emergency Response Services:
Metro should not consider the ROW at-grade option. Life threatening delays could occur at the at-grade crossing at 182nd Street due to frequency of the light rail service stopping traffic and emergency response capabilities. In addition to police and fire, McCormick private ambulance service is located on and travels along 182nd Street regularly—this is a major corridor. ROW at-grade traffic stoppage will cause delays. The ability to get across tracks in a timely manner is critical for these life safety services.
Regarding public services and emergency responders, the DEIR does not go deep enough to address deployment practices and the impacts of these delays.
Geology/Soils:
DEIR 3.8-3.12 Subsidence and settlement - The Draft EIR identifies less than significant issues with subsidence that may be in conflict with other known reports There is a concern with safety with 3 sets of tracks over pipelines where there are unstable soils (including clay soils) along the ROW alignments. There are seemingly unrepairable unstable soils evidenced by a sinkhole in the area, including adjacent to the alignment and spread onto property of Ruxton Place.
The raised elevation route down Hawthorne has the opportunity for engineering over more stable soils where Red Car had been routed for several decades.
At-Grade Crossing:
The DEIR claims no impact on bicycle safety, yet riding bicycles across rail tracks is a hazard due to tire size and uneven surfaces. At this point there is only one set of tracks to cross at 182nd Street, but the proposed ROW at-grade option would have two additional sets of tracks, compounding the safety hazard.
Was there sufficient analysis of transportation impacts on Inglewood and 182nd Street as a result of the frequency of trains and resulting restriction of traffic in ROW at-grade option? Noise and Vibration
The significant unavoidable impacts of the ROW options regarding noise will be in perpetuity for operations. Metro should not move forward with those options. And even the Trench Option would only be LTSM if other agencies take action for Quiet Zone, relying on other agencies to do the mitigation. The City does not believe the benefits of these ROW project options outweigh the significant unavoidable impacts.
Noise and vibration metrics make no reference to the noise standards in residential districts per the Redondo Beach Municipal Code. The DEIR needs to respect the local municipalities’ regulations.
For the Proposed Project (right of way at grade) and the Trench Option, the projected noise levels are in excess of City’s noise ordinance during construction and during operation (RBMC 4-24.301) For the Proposed Project (right of way at grade) and the Trench Option, the projected noise levels during operation occur prior to 7 AM and after 10 PM and so are in violation of City’s noise ordinance (RBMC 4-24.301, 4-24.503) For the Proposed Project (right of way at grade) and the Trench Option, the projected vibration levels listed to have significant impact violates City ordinance (RBMC 4-24.504) Considering there are already vibration impacts as a result of the existing freight operations, are the proposed mitigation measures for ROW options proven sufficient for the lifetime of the project? Air Quality
For the Trench Option, air quality risk is listed as significant and unavoidable.
Safety
For the Proposed Project (right of way at grade) and the Trench Option, the City did not observe adequate discussion of safety issues related to brittle buried pipelines in the right of way.
The City did not observe adequate discussion of safety issues related to derailment.
Biological
The DEIR notes no wildlife impact, yet there have been observed owls and hawks in the El Nido Park and cemetery vicinity.
For the Hawthorne Option and the Trench Option, significant substantial adverse effects are projected either directly or through habitat modifications on local wildlife. Metro should provide better mitigation requirements to protect local wildlife.
Transportation
Metro should provide First / Last Mile improvements to the scope of the project.
Metro should elaborate on bus connectivity from the proposed Hawthorne Light Rail Station to the new Redondo Beach Transit Center. Explore partnership with South Bay Social District (SBSD - formerly South Bay Galleria) to make connection.
Provide some discussion of dedicated connectivity from the proposed C Line extension to the Del Amo Mall.
Discuss parking options for Hawthorne Light Rail Station and explore partnership with SBSD.
Other Issues
The “No Project Alternative” shows significant unavoidable impacts in many categories. Where is the significant data to support this? The Hawthorne Option is most environmentally sound option and should be the option pursued if Metro is going to build the project. The Hawthorne Option is the option that does not directly impact adjacent residential uses.
There is no level of service data or analysis. The DEIR mentions in the Land Use section that this is consistent with the local General Plans. However, the Redondo Beach Circulation Element requires this level of service analysis.
The ridership study should be included as a part of the DEIR since “improving mobility within the South Bay and encourage mode shift” is objective of project.
In the absence of selection of a light rail option, or if the no build option is selected, discuss how funds will remain invested into South Bay transit needs.
These comments have been reviewed and approved by the Redondo Beach City Council at their March 14, 2023 public meeting. If Metro has any questions regarding this comment letter, please contact Brandy Forbes, Community Development Director for the City of Redondo Beach at 310-318-0637 x2200 or [email protected]. Thank you for your consideration of our comments.
Sincerely,
Mayor William Brand
Joined by:
Nils Nehrenheim
Council Member, District 1
Todd Loewenstein
Council Member, District 2
Christian Horvath
Council Member, District 3
Zein E. Obagi, Jr.
Council Member, District 4
Laura Emdee
Council Member, District 5
CC: L.A. County Metro Board
Mike Witzansky, City Manager
Luke Smude, Assistant to the City Manager
Brandy Forbes, Community Development Director
L.A. County Supervisor Holly J. Mitchell
L.A. County Supervisor Janice Hahn
Attachments:
City of Redondo Beach Comments and Request Letter on Metro C Line Extension to Torrance Project May 17, 2022 Redondo Beach Planning Commission Recommended Comments February 16, 2023 Redondo Beach Public Works Commission Recommended Comments February 27, 2023 City of Redondo Beach Support Letter Green Line Alternative 3 Signed July 18, 2018 City of Redondo Beach Letter Submitting Comments on Revised and Recirculated Notice of Preparation Dated March 16, 2021 City of Redondo Beach Land Use and Noise Regulations Pertaining to Proposed Alternatives City of Redondo Beach March 14, 2023
Metro C Line (Green) Extension to Torrance Project DEIR Comments Page 2 of 5