33. Page 3.2-45 “To achieve this, one Industrial Zone within the city and various Overlay Zones have been deemed best suited to carry out these regulations.” Much of the area within the Malabar Yard Study Area has been rezoned for mixed uses allowing for residential uses and is no longer in the Industrial Zone.
34. Page 3.2-45 “While improvements associated with the Malabar Yard railroad improvements would reduce on- and off-street parking, and may encroach into current setback requirements, the affected parcels meet the Legal Nonconforming Status of Section 26.5.3.” Vernon Municipal Code § 17.64.020 Restrictions on nonconforming buildings and uses.
D. There shall be no decrease in the parking, loading, or maneuvering capacities as they exist as of the effective date of the ordinance codified in this title if such decrease would either make conforming capacities non-conforming or would decrease capacities of an already nonconforming lot.
The 21-foot building setback is a requirement to provide a safe distance between buildings and utility infrastructure.
The proposed permanent loss of parking spaces, the reduction in maneuvering capacities, and the reduction in building setback from the required 21-feet to 10-feet from this parcel are not allowed under Vernon’s Comprehensive Zoning Ordinance and would therefore create direct adverse impacts.
35. Page 3.2-45 “The Malabar Yard railroad improvements could result in decreased parking availability and reduced setbacks; however, the allowable pre-existing nonconformance with the zoning code would not change with construction of the railroad improvements. Long-term access to adjacent properties will be maintained in coordination with the City of Vernon and nearby business and/or property owners. No indirect adverse effect would occur.” Private rail crossings such as those proposed to access driveways on 46th Street do not run with the land and are instead licensed by the railroad to the property owner and must be renewed when property changes ownership. These licenses are subject to cancellation and may require future rail safety upgrades at the property owner’s cost. This is an adverse impact.
Access to adjacent properties in coordination with the City of Vernon and/or nearby property owners creates an adverse impact on the City, adjacent property owners and directly impacted property owners.
36. Page 3.2-2 “City of Vernon General Plan Circulation and Infrastructure Element (2007)” This reference is out of date. This element of the City of Vernon’s General Plan was amended in 2023.
37. Page 3.3-3 “The traffic analysis methodology, especially the traffic count normalization approach due to the COVID-19 pandemic impacts, was coordinated with and approved by the City of Vernon in August 2020.” ..
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This methodology was “coordinated with” but it was not approved by the City of Vernon.
Actual post Covid-19 counts should be taken to verify the validity of the traffic count normalization since it is crucial to an accurate analysis.
38. Page 3.3-4 “This approach was coordinated with and approved by the City of Vernon prior to performing the traffic analysis.”
This methodology was ”coordinated with” but it was not approved by the City of Vernon.
39. Page 3.3-5 Table 3.3-2 lists six traffic scenarios. In five of the six scenarios “This condition assumes City of Vernon General Plan improvements to roadways in the study area are complete.” This assumption is inaccurate, a physical survey of impacted streets in their existing condition should have been performed as part of the analysis. The improvements to roadways have not been completed and there is no anticipated date for completion due to a variety of constraints.
40. Page 3.3-9
Queuing analysis should include the following additional rail crossings:
Rail Crossing #7: At-Grade Crossing at Alcoa Avenue s/o Vernon Avenue Rail Crossing #8: At-Grade Crossing at Boyle Avenue s/o Vernon Avenue Rail Crossing #9: At-Grade Crossing at Soto Street n/o 46 Street Rail Crossing #10: At-grade Crossing at Pacific and 46th Street Rail Crossing #11: At-grade Crossing at Pacific e/o Santa Fe
41. Page 3.3-10 “The driveway counts were not normalized like the intersection and roadway counts because the driveways are not affected by COVID-19 since the businesses are all working full time.”
These counts should be retaken post COVID-19, since they ignore the number of persons that at the time were working remotely, and the number of customers that at the time relied on delivery instead of in person pick up of orders. At a minimum, counts should be normalized like the technique used for traffic counts.
42. Page 3.3-12 “Freight Project-related effects on freight would be considered adverse if physical impacts to freight facilities would create operational inefficiencies or increased congestion on the shared passenger/freight rail network in the region.”
The Malabar Yard project is a project to mitigate freight impacts created by the Link US project. It would be incorrect to include impacts to freight created by the Link US project in the environmental evaluation of Malabar Yard Mitigation.
43. Page 3.3-14 “As previously discussed, the raw traffic counts that were conducted in August 2020 were normalized to pre-COVID-19 traffic levels by increasing the counts by a COVID factor of 1.67 in the AM peak hour and 1.54 in the PM peak hour.” ..
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Actual post COVID-19 counts should be taken to verify the validity of the traffic count normalization since it is crucial to an accurate analysis.
44. Page 3.3-31 “In 2040, the following improvement is also included in the analysis as it is reflected in the City of Vernon General Plan Circulation Element”
The City of Vernon General Plan is merely a guidance document and should not be construed as a planning document and cannot be relied upon for purposes of future analysis.
45. Page 3.3-34 “Metro, the City of Vernon, or the contractor shall post advance notice signs prior to construction in areas where access to local businesses could be affected.” Vernon is not the project proponent, nor the contractor for this project. Vernon cannot be held responsible for providing mitigation for the project.
46. Page 3.3-35 “The intersection of the Pacific Boulevard and 46th Street is currently operating as a two-way stop control under the Existing (2020) conditions.” The intersection of Pacific Boulevard and 46th Street is a tee intersection with only a single stop sign for vehicles traveling west on 46th Street. It is not a two-way stop-controlled intersection. Metro needs to ensure that the analysis for this intersection was properly performed since the basic geometry of the intersection is improperly characterized.
47. Section 3.3 Transportation
The analysis of traffic impacts fails to focus on the direct impact of rail operations on traffic. While the train volume moving through Vernon will reportedly remain the same, the number of rail cars in train sets will increase. This increase in the number of rail cars increases the duration of at-grade crossings being closed to vehicular traffic, which in turn impacts road segment levels of service as well as impacting intersection levels of service. These impacts do not appear to have been analyzed.
48. Page 3.3-47 “Malabar Yard Mitigation Measure TR-6 minimizes the potential roadway hazard; however, to establish the level of effectiveness of this mitigation measure, further coordination with CPUC and the City of Vernon is required.”
This statement implies that the level of mitigation being provided, if any, is unknown and so is not mitigation.
49. Page 3.5-9 Methodology Criteria Air Pollutants
The methodology described is one that is suited to the Link US project and not the Malabar Yard Project by examining the regional impacts of the combined projects and not addressing the local impacts within the ¼ mile buffer from the Malabar Yard. A continued flaw in analysis is to focus specifically on the 49th Street closure and the 46th Street extension buffer areas without including a buffer area around the entire Malabar Yard.
50. Page 3.5-13 “Residences at 2415-2427 E 53rd St. (located approximately 1,325 feet [0.25 mile] south from the Malabar Yard railroad improvements). ..
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• Vernon City School at 2360 East Vernon Avenue (located approximately 1,350 feet [0.25 mile] northwest from the Malabar Yard railroad improvements). • Residences on Furlong Place located approximately 1,650 feet (0.31-mile northwest from the Malabar Yard railroad improvements).”
This project expands the intensity of use of Malabar Yard and includes track work throughout the length of Malabar Yard. The buffer area should not be measured from the 49th Street closure but should instead be measured from the limits of the Malabar Yard. Using this approach, the Residences at 2415-2427 E 53rd St. are approximately 675 feet from the Malabar Yard, Vernon City School is 800 feet from the Malabar Yard, the Residences on Furlong Place are located approximately 870 feet from the Malabar Yard. Using this methodology sensitive receptors are within one-quarter mile of the project and new analysis should be conducted.
Additionally, one quarter mile is 1,320 feet. Even by the methodology used, to exclude sensitive receptors from the analysis because they are 5 feet, and 30 feet outside of the quarter mile zone is problematic.
51. Page 3.5-17 Topic 3.5-A
This is an environmental analysis of the Malabar yard, and yet this analysis ignores increases in local air pollution due to increased rail operations in Vernon, as well as the traffic impacts created by the increased rail operations which in turn lead to increases in vehicle engine idling which results in increased air pollutant emissions at the local level. While Table 3.5-6 quantifies the emissions reduction on a regional scale, the local impacts to air quality are dismissed with a paragraph and no data to support the conclusion being drawn.
52. Page 3.5-20 Topic 3.5-B
Again, this is an environmental analysis of the Malabar yard, and yet this analysis ignores negative impacts to local air quality and instead focuses on the regionwide impacts.
53. Page 3.6-3 “Geographic Area Considered. The FTA screening distances for noise and vibration are the geographic areas used to characterize the affected environment and to determine potential effects related to noise and vibration.”
A continued flaw in analysis is to focus specifically on the 49th Street closure and the 46th Street extension areas without including the entire Malabar Yard. This project expands the intensity of use of Malabar Yard and includes track work throughout the length of Malabar Yard. The buffer area should not be measured from the 49th Street closure but should instead be measured from the limits of the Malabar Yard. Using this approach, the Residences at 2415-2427 E 53rd St. are approximately 675 feet from the Malabar Yard, Vernon City School is 800 feet from the Malabar Yard, the Residences on Furlong Place are located approximately 870 feet from the Malabar Yard.
Using this methodology sensitive receptors are within 1,000 feet from the project and new analysis should be conducted.
The analysis in Section 3.6 is incomplete until the geographic area being considered is expanded to include the entire Malabar Yard and not just the 49th Street Closure. ..
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54. Page 3.6-9 “Any combination of design options for the Malabar Yard railroad improvements would occur in an industrial-zoned area and are unlikely to encourage residential and commercial infill development”
This is incorrect. Several properties immediately west of the Malabar Yard have been zoned Mixed- use which allows and encourages residential development.
55. Page 3.7-3 The reference to “City of Vernon Tree Protection Bylaw #4152 (1996)” in Table 3.7-1 does not refer to a local law or regulation for the City of Vernon, California, USA but instead refers to a bylaw of the City of Vernon, British Columbia in the nation of Canada. This confusion of the two cities on the part of the Draft EIR preparer may have been carried on throughout the environmental documents. All references and citations concerning the City of Vernon, California, USA should be verified.
56. Page 3.7-3 “Geographic Area Considered”
A continued flaw in analysis is to focus specifically on the 49th Street closure and the 46th Street extension areas without including the entire Malabar Yard. This project expands the intensity of use of the Malabar Yard and includes track work throughout the length of Malabar Yard. The geographic area considered should not be measured from the 49th Street closure but should instead be measured from the limits of the Malabar Yard.
57. Page 3.7-19 “Tree Preservation Ordinance. The BSA is located in the City of Vernon and would be subject to the City’s Tree Protection Bylaw #4152.”
The reference to “City of Vernon Tree Protection Bylaw #4152 (1996)” in Table 3.7-1 does not refer to a local law or regulation for the City of Vernon, California, USA but instead refers to a bylaw of the City of Vernon, British Columbia in the nation of Canada. This confusion of the two cities on the part of the Draft EIR preparer may have been carried on throughout the environmental documents. All references and citations concerning the City of Vernon, California, USA should be verified.
58. Page 3.7-20 “Although there is a slight increase in potential for mortality (e.g., collisions with trains) resulting from increased train traffic.”
This is the first reference to increased train traffic due to the Malabar Yard Project in this environmental document. “Increased train traffic” is not mentioned in the project description.
59. Page 3.7-21 Topic 3.7-B
The reference to “City of Vernon Tree Protection Bylaw #4152 (1996)” in Table 3.7-1 does not refer to a local law or regulation for the City of Vernon, California, USA but instead refers to a bylaw of the City of Vernon, British Columbia in the nation of Canada. This confusion of the two cities on the part of the Draft EIR preparer may have been carried on throughout the environmental documents. All references and citations concerning the City of Vernon, California, USA should be verified. ..
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60. Page 3.7-23
“MY BIO-2” is based on the regulations of the City of Vernon, British Columbia in the nation of Canada, and should be revised to reflect local law and rules.
61. Page 3.8-6 “Geographic Area Covered”
A continued flaw in analysis is to focus specifically on the 49th Street closure and the 46th Street extension to determine the Malabar Yard study area, without including the entire Malabar Yard in making that determination. This project expands the intensity of use of Malabar Yard and includes track work throughout the length of Malabar Yard.
62. Page 3.8-14 “Based on a review of California’s Groundwater Live, the DWR’s interactive dashboard, the nearest groundwater well to the Malabar Yard study area is located near the intersection of Alameda Street and Laura Avenue.”
This is incorrect. See https://storymaps.arcgis.com/stories/f2b252d15a0d4e49887ba94ac17cc4bb.
There are three public supply wells located closer to the Malabar Yard than the one at Alameda and Laura.
Two of these wells are near the intersection of Vernon and Santa Fe and a third well is on 55th street between Alameda Street and Santa Fe Avenue.
63. Page 3.10-6 “Geographic Area Considered”
A continued flaw in analysis is to focus specifically on the 49th Street closure and the 46th Street extension to determine the Malabar Yard study area, without including the entire Malabar Yard in making that determination. This project includes track work throughout the length of Malabar Yard.
64. Page 3.10-16 “Proximity to Schools”.
The Malabar Yard Study Area has been drawn to exclude the Vernon City School located at 2360 East Vernon Avenue. The School is located at the corner of Vernon Avenue and Santa Fe Avenue.
The Malabar Yard Study Area includes the full width of Santa Fe Avenue including the sidewalk abutting the Vernon City School. A continued flaw in analysis is to focus specifically on the 49th Street closure and the 46th Street extension areas without including the entire Malabar Yard. This project expands the intensity of use of Malabar Yard and includes track work throughout the length of Malabar Yard. The geographic area considered should not be measured from the 49th Street closure but should instead be measured from the limits of the Malabar Yard.
65. Page 3.10-18 “Direct Effects – Operations”
No facts are presented to explain how an increase in the quantity of hazardous materials stored in an increased number of rail cars would not increase the risk of accidental release. This requires actual numerical analysis, before drawing a conclusion that no adverse effect would occur.
66. Page 3.10-21 “Direct Effects – Operations”
No facts are presented to explain how an increase in the quantity of hazardous materials stored in an increased number of rail cars would not increase the risk of accidental release. This requires actual numerical analysis, before drawing a conclusion that no adverse effect would occur.
Additionally, it is unclear what the second to the last sentence, “With the installation of the 1,000 .- .
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foot connector track and realignment of the existing is expected due to the heavy presence of existing freight rail operations in the immediate surrounding area” means.
67. Page 3.10-21 “Indirect Effects”
Two unsupported claims are made to draw the conclusion that “No Indirect adverse effect would occur.” The first claim is that if operations are handled in accordance with applicable regulations a hazardous release is not expected. Based on the history and frequency of hazardous releases from railroads this is a false claim. The second claim is that an increase in rail activity involving hazardous materials does not increase the likelihood of release. No data is presented to support either of these claims.
68. Page 3.11-17 “Indirect Effects – Construction and Operations” This section ignores the increases in energy consumption from idling traffic. According to Page 2-4 “North Entrance” “The foreseeable length of future trains operating on the 46th Street Connector could range from 2,000 feet to 4,000 feet. To serve customers on the existing spur line track east of Pacific Boulevard and south of 46th Street, the Pacific Boulevard and Vernon Avenue at grade crossings could be occupied for “head-end moves” as necessary to facilitate continued freight operations on the existing spur line”
This project will block 49th Street as well as Pacific Avenue and Vernon Avenue by effectively cutting off east-west traffic through the city for extended periods of time. This will also impact north and south bound traffic along Santa Fe as vehicles stuck at the rail crossings queue through the intersections. In addition to other impacts this will increase fuel consumption due to excessive idling time created by the changes to rail operations that the Malabar Yard project will allow.
69. Page 3.13-1 “Metro’s Relocation Assistance Program” Why isn’t Metro just purchasing the BNSF property adjacent to Union Station instead of expanding the Malabar Yard and in so doing creating several environmental and economic burdens on the residents, businesses and workers of Vernon? Shouldn’t BNSF be treated the same as other businesses being impact by Link US? Why is the loss of BNSF storage being treated as something that requires “mitigation” through the Malabar Yard Project? Only environmental impacts are mitigated. The taking of property is compensated through payment not mitigation.
70. Page 3.13-2 “Geographic Study Area”
The Malabar Yard Project impacts a local area and is the mitigation being proposed and economic impact being created by the larger Link US. The Malabar Yard project has its own environmental evaluation, a part of, but separate from the Link US environmental evaluation.
Therefore, the economic and fiscal impacts of the Malabar Yard Project should be evaluated at the local level and not the county level.
71. Page 3.13-5 “Land Use” As stated previously, much of the area within the Malabar Yard Study Area has been rezoned for mixed uses allowing for residential uses and is no longer in the Industrial Zone.
72. Page 3.13-6 “Businesses subject to displacement would be referred to potential and/or suitable replacement sites pursuant to Metro’s Relocation Assistance Program.” Why isn’t BNSF being referred to Metro’s Relocation Assistance Program instead of displacing ..
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additional businesses through the Malabar Yard Project. It appears that Metro’s mitigation is just compounding the BNSF business impacts by displacing other businesses.
73. Page 3.13-10 “Operations”
The conclusion that no direct or indirect effect would occur ignores the permanent loss of jobs, property values and property taxes. It also ignores the economic impact of truck and automobile traffic delays due 2,000- to 4,000-foot-long trains blocking major streets in Vernon for extended periods of time.
74. Page 3.13-12 “Operations”
The conclusion that no direct or indirect effect would occur ignores the permanent loss of jobs, property values and property taxes. It also ignores the economic impact of truck and automobile traffic delays due 2,000- to 4,000-foot-long trains blocking major streets in Vernon for extended periods of time.
75. Page 3.13-12 “Mitigation Measures”
The logic used to make the determination that no mitigation is required could similarly be applied the Link US project’s use/acquisition of BNSF storage track near Union Station. If no mitigation were required for the use of BNSF storage track the Malabar Yard Project would not be required.
76. Page 3.14-9 “Fire Protection” Using information published by the Vernon Chamber of Commerce instead of information provided by the Los Angeles County Fire Department is not a valid method of ascertaining the level of service being provided. Information should be obtained from Los Angeles County Fire Department.
77. Page 3.14-17 “No pedestrians or bicyclists were observed during 2020 traffic counts.” These counts were taken during the COVID-19 shut-downs and are not representative of counts during normal conditions. The counts for automobile, bicycle and pedestrian traffic should be redone for the sake of accuracy.
78. Page 3.14-20 “If the Malabar Yard railroad improvements were not implemented, the existing atgrade crossings would not be enhanced with new safety features and would pose a potential safety risk at the existing at-grade crossings.”
This potential safety risk is at best minimal. Page 3.14-14 reads: “FRA accident data for the four at- grade crossings where the railroad improvements would occur indicate that there has been one accident in the past 45 years. The one accident involved a pedestrian at the Pacific Boulevard/46th Street crossing in 1989, prior to implementation of PTC technology. There have been no other rail accidents at the four at-grade crossings (FRA 2023).” Based on this, the finding should be “If improvement were not implemented no direct or indirect adverse effect would occur.”
79. Page 3.14-21 “This would not substantially affect emergency response”.
The Malabar Yard project will impact traffic at several major intersections and effectively stop east and west bound traffic while trains between 2,000 and 4,000 feet long are either being built or stored at the seven storage tracks in the Malabar Yard. This will substantially affect emergency ..
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response times due to the configuration of adjacent roadways, and likely push traffic into surrounding EJ communities.
80. Page 3.24-22
Mitigation measures TR-3, TR-4, TR-5 and TR-6 should be modelled to determine their effectiveness using current traffic counts.
81. Page 3.14-23 “The 46th Street Connector would not increase potential for derailment due to the improvements being constructed per applicable code requirements and the grade and extent of proposed improvements.”
Since the Malabar Yard project would significantly increase rail operations in the area, and since according to the Association of American Railroads, “The vast majority of train derailments happen in rail yards where the average train speed is about five MPH – not on mainline track.” There appears to be no factual basis for the statement about not increasing the potential for derailments.
82. Page 3.14-26 “Mitigation Measures”
As previously stated, mitigation measures to improve traffic flow should be modelled to determine their effectiveness using current traffic counts, and the projected amount of time these long slow- moving trains will be blocking the intersection during all phases of operation.
83. Page 3.15-1 “3.15 Socioeconomics and Communities Affected” The following comments are applicable throughout this section. As stated previously, the Malabar Study Area should be expanded to include a radius along the entire length of the Malabar Yard since the operations of the yard will be significantly altered by this project and since there will be construction along the entire length of the Malabar Yard.
Additionally, much of the area within the Malabar Yard Study Area has been rezoned for mixed uses allowing for residential uses and is no longer in the Industrial Zone.
84. Page 3.15-20 “Indirect Effects” – “Any combination of design options for the Malabar Yard railroad improvements would not indirectly generate substantial population or employment growth that would cause new or increased demand for fire protection and law enforcement services. No indirect adverse effect would occur.”
This statement ignores the fact that the City will be divided into east and west by rail operations with several of the major east and west streets being shut down by rail operations for extended periods of time. The City of Vernon is served by one police station, west of the Malabar Yard. To mitigate the impacts on police department response times a second police station east of the Malabar Yard should be constructed.
85. Page 3.15-20 “67 percent of the industrial businesses could be assumed to relocate in Los Angeles County (FHWA 2010).” Statistically speaking, this means that approximately one-third (or 15) of the displaced jobs would not relocate in Los Angeles County. Based on the heavy industrial nature of the businesses in Vernon, it is very foreseeable that none of the 46 jobs would relocate in Los Angeles County or even in the State of California due to the regulations imposed on these types ..
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of businesses in most California jurisdictions outside of the City of Vernon.
86. Page 3.15-21 “Indirect Effects”
It is unclear how a loss of 46 jobs, and a reduction in the amount property tax, business license tax, and sales tax received is a “beneficial effect,” unless the destruction of businesses and jobs is seen as a benefit by Metro and the CHSRA.
87. Page 3.15-21 “Mitigation Measures”
Mitigation measures should be modelled to determine their effectiveness using current traffic counts.
88. Page 3.16-18 “Safety”
Feedback concerning the “Delay to emergency responders during railroad crossing gate down time” is not adequately addressed with roadway reconfigurations and modifications. This can only be addressed through the construction of an additional police station on the east side of the Malabar Yard.
89. Page 3.16-24
How is operational efficiency for freight trains beneficial for the city of Vernon and surrounding Environmental Justice Communities?
90. Page 3.16-42 “The local EJ communities living and traveling within the Malabar Yard study area would predominantly benefit from the improvements, including a reduction in emissions by shifting some freight rail activity away from an EJ community.”
This statement is false. Rail activity in the Malabar Yard study area will significantly increase and with that increase in activity comes an increase in diesel emissions. Emissions from cars and trucks that are impacted directly and indirectly by long idles during railroad crossing gate down time will significantly increase.
Sincerely,
Daniel S. Wall, P.E.
Director of Public Works
In conclusion, the Malabar Yard Mitigation will have detrimental impacts on the City of Vernon and surrounding communities, particularly concerning air quality, public safety, traffic congestion, housing developments, and the well-being of local businesses and the jobs they provide for the community. The city urges Metro to act in accordance with its Relocation Assistance Program and California’s Relocation Assistance Act and pay BNSF for the use of its storage tracks rather than facilitating BNSF's relocation of its storage operations to Vernon. ..
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Link Union Station
(Link US) Project
City of Vernon
City Council Presentation
June 17, 2025
June 17, 2025
Item 15
Staff Presentation
..
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Presentation Purpose:
Provide update on Link US Project and show how it improves citywide circulation and supports Vernon’s goals for economic vitality and future growth
..
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Presentation Agenda
1. Project Overview
2. Improved Citywide Circulation
3. Additional Community Mitigations
4. Next Steps & Questions ..
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Project Improves Citywide Circulation
3.5 fewer
Fewer Daily
Train Movements
30-minute
improvement
Reduced Train
Blockage
5-minute
improvement
Faster Emergency
Response
..
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Vernon Collaboration
- Past Nine Months
Working to Support the City's Long-term Vision
JUNE 2024
Draft EIS/SEIR published
29 Mitigation Measures
Required by Draft EIS/SEIR
SEPTEMBER 2024 – MARCH 2025
Collaboration with Vernon
10 Workshops
with City of Vernon
12 Vernon Property
Owner Meetings
90 comments and 8 key
areas of concern
identified / addressed
AUGUST 2024
Vernon Mayor and Director
of Public Works submit
comment letters
104 Additional
Community Mitigations
Total
over $100k per resident & over $13k per business
$24,564,000 worth of improvements to the City Of Vernon Total Additional Community Mitigation Measures
FEBRUARY 2025
Metro Offers 22 Additional Community Mitigations
Vernon requests 82 more
Additional Community
Mitigations
..
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Vernon Benefits & Additional Mitigations
Optimized
emergency response
time & routing 4 locations
with train detection cameras
for at-grade crossings
Upgraded
communications &
radio-systems
New
mobile Emergency
Operations Center
Expanded Emergency
Response System
High visibility crosswalk
at Vernon Elementary
7 crosswalks
improved for visibility
25 new
bus shelters
Quiet Zone support
near planned development
Grant support
for Metro Transit
Oriented Communities
Enhanced Community
Features
Fewer
daily trains
Decreased
local emissions
Minimized
traffic delays
Reduced
Train Impacts
Road restriping
to maintain traffic flow
AI-based
traffic control system
5 locations
with pan-tilt-zoom
smart cameras,
software & screens
Improved
Traffic Control
..
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Additional Community Mitigations
A. Train Detection Cameras
B. Quiet Zone Infrastructure
(Overhead Cantilevered
Signals)
C. Quiet Zone Infrastructure
(Detectable Warning Strips)
D. Mid-block Crosswalk
(with Cool Pavement)
E. Bus Shelter
F. PTZ Smart Camera
G. Mobile Emergency
Operations Center ..
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Project Overview
..
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Project Location & Major Components
N. Main St. safety
improvements
6 new lead tracks
New Vignes St. & Cesar
Chavez Ave. Bridges
a
Elevated rail yard with new
platforms & canopies
Expanded passageway
Up to 10 new run-through tracks
Common rail infrastructure
(LAUS to First St.)
Permanent removal of 5,500 ft. of
storage track capacity
Dedicated lead tracks for BNSF
freight trains & Amtrak trains
46th St. Connector
49th St. Closure
b
c
d
e
f
g
h
i
j
k
North of LAUS
At LAUS
LEGEND
South of LAUS
Vernon
BNSF WEST BANK YARD BNSF MALABAR YARD
abc
de
fghi
jk
..
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Mitigation Sites Considered
Malabar Yard is the only site that meets operational requirements, has the least property impacts, and improves citywide circulation.
SIX Mitigation Sites Evaluated:
Hobart Yard
Commerce Yard
Malabar Yard
Los Angeles Junction
Pico Rivera Yard
Eastern BNSF Facilities
123456
Link US Project
..
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BNSF Malabar Yard Improvements in Vernon
46TH STREET CONNECTOR
Track connecting Malabar Yard
and Los Angeles Junction
49TH STREET CLOSURE
Closure of crossing, resulting in
additional storage track capacity
at Malabar Yard
..
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Improved Citywide Circulation
..
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Current Movements in Vernon
Citywide Train Movements
Length of trains in existing & proposed condition would be up to 3,000 feet long ..
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Project Implementation Reduces Movements Citywide
Citywide Train Movements
Length of trains in existing & proposed condition would be up to 3,000 feet long
MALABAR YARD
Used for storage of
empty train chassis
Ex:
LAJ YARD
Used for all train
building for Vernon
customers
Reduces intersection
blockage
..
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Train Observations in Response to Community Concerns
Vernon Train Observations
Background:
Cameras recorded 24/7 train activity (April 19-25, 2025) Objectives:
Identify current daily train counts and times in the City of Vernon Determine intersection blockages due to current daily train activity Report intersection blockages that would result from the proposed Malabar Yard modifications ..
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“Through Train”
– Serves East Vernon Businesses
LAJ/Downey Road - Existing
..
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“Through Train” at Pacific Blvd.
– Serves West Vernon Businesses
Malabar Yard - Existing
..
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“Train Building” at Pacific Blvd.
Malabar Yard - Existing
Project moves majority of train building out of intersections to LAJ Rail Yard Improves citywide circulation and emergency response
..
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NOW
1 hour,
41 minutes
of blockage daily
Existing Intersection Blockages without Project
Train Observation Results
Minutes:0-5 5-10 10-15 15-20 20+
..
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NOW
101
minutes
blocked daily
WITH LINK US
Future Intersection Blockages with Project
Train Observation Results
Minutes:0-5 5-10 10-15 15-20 20+
Daily Blockage
Reduced by
30 minutes
If longer trains are needed
due to Vernon customer
demand, reduction increases
..
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Additional Community Mitigations ..
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Additional Community Mitigations ..
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Additional Community Mitigations
Train Detection Cameras – 4 locations
1. 37th Street
2. 38th Street
3. Pacific Boulevard
4. Vernon Avenue *
Mobile Emergency Operations Center (EOC) *
Mobile EOC to be used during emergencies or if
central EOC is shut down
Communications & Radio-Systems Upgrade *
New cameras, dispatch, radios & antennae
enables ability for all departments to
communicate (PD, PUD, PW LA County Fire)
AI-Based Traffic Control System (Traffic Upgrades) *
47 transportation controllers
(locations specified by City)
PTZ Smart Cameras, Software & Screens – 5 locations
1. Downey Road at Bandini Boulevard *
2. 25th Street at Santa Fe Avenue*
3. Fruitland Avenue at Malabar Street *
4. Vernon Avenue at Santa Fe Avenue *
5. Pacific Boulevard at Santa Fe Avenue *
Bus Shelters – 25 locations
1. 5 locations
2. 20 additional locations *
High Visibility Crosswalk – 1 location
1. Santa Fe Avenue (Vernon City School) Cool Street Paving * Crosswalk Improvements (Restriping) – 7 locations
1. Santa Fe Avenue/37th Street
2. Santa Fe Avenue/38th Street
3. Santa Fe Avenue/Vernon Avenue
4. Santa Fe Avenue/Pacific Boulevard
5. Santa Fe Avenue/Fruitland Avenue
6. 46th Street/Pacific Boulevard
7. 46th Street/Seville Avenue Cool Street Paving (7 locations) *
Quiet Zone Infrastructure – 5 locations
1. 37th Street
2. 38th Street
3. Vernon Avenue
4. Pacific Boulevard
5. 49th Street MOU to support regulatory process
*
Metro Transit-Oriented Communities (TOC) Program Support
1. Technical Assistance
2. Grant Writing Assistance
* Additional Community Mitigations requested by City of Vernon ..
Item 15 Page 79 of 88
Next Steps & Questions
..
Item 15 Page 80 of 88
Project Schedule
Final EIS/SEIR
Ongoing Stakeholder Engagement within each Project Development Phase Final Design
Right-of-Way
Construction
Development of
Final EIS/SEIR
(Fall 2025 Certification)
We are here
12 Property Owner/
Tenant Meetings
(December 2024 –
February 2025)
10 City of Vernon
Workshops
(September 2024 –
March 2025)
Draft EIS/SEIR
Public Comment
Period
(June 21, 2024 –
August 9, 2024)
..
Item 15 Page 81 of 88
Link US Contact Information
Questions
213.922.2524
[email protected]
www.metro.net/linkus
facebook.com/losangelesmetro
Scott McConnell, P.E., Metro Project Manager
Carlos J. Montez, Metro Environmental Lead
Danielle Valentino, Metro Community Relations Manager
Kim Tachiki-Chin, Manager, Community Relations, Gateway Cities ..
Item 15 Page 82 of 88
Thank You
Questions/Comments? ..
Item 15 Page 83 of 88
From: Guerrero, Adam W.
To: Public Comment; Genoveva Rocha
Cc: Jonathan Wong; Corri Nicol; Michelle Rojas; Cindy Ruffin; Vincent Bohanec; Sestanovich, Tom R.; Sestanovich, Tom R.; Eileen Conn; Rufino Pineda; Marisa Olguin
Subject: Metro Link Union Station (Link US) Project--Council Mtg - June 17, 2025 at 9 AM Date: Monday, June 16, 2025 6:54:12 PM
Attachments: image001.png
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image003.png
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Notice of Rejection of Proposed Modifications.pdf
Hello,
This firm represents the property owner of 4900 S. Santa Fe Avenue, in the City of Vernon (the “Property”). My client is aware of, and objects to, the proposed Malbar Yard and 49th Street modifications (the “Project”).
My client learned of tomorrow’s city council meeting (the “Meeting”) to discuss the Project only today. Unfortunately, my colleague (and the lead attorney on this matter), Tom R. Sestanovich, Esq., is out of the country until later this week and will be unable to attend the Meeting.
My client desires to renew its objection to the Project and wants its objection to be communicated to the city council in advance of the Meeting. For the city council’s convenience, I am attaching a copy of Mr. Sestanovich’s letter of May 14, 2025 (the “Notice of Rejection”), that we have confirmed was delivered to the Los Angeles Metropolitan Transportation Authority (“Metro”). In addition, my client hereby respectfully requests that:
1. a copy of the Notice of Rejection be provided to all city council members in advance of the Meeting; and
2. the Notice of Rejection be read into the Meeting record.
As set forth in the Notice of Rejection, the Project has already affected the value of the Property and, if implemented, is expected to greatly reduce the value of the Property.
Accordingly, my client’s objection to the Project remains unchanged.
At this time, my client does not have any further evidence to provide in advance of tomorrow’s Meeting. Please note, however, that my client reserves its right to present additional evidence against the Project as same is developed and becomes available to my client. In particular, my client will want to present evidence based on the traffic impacts report and environmental impacts report for the Project once those are made available to my client by Metro.
Please confirm receipt of this email and kindly let me know if you need anything else from me in order to ensure that this Notice of Rejection is provided to all city council members and that it is read into the Meeting record.
June 17, 2025
Item 15
Public Comment
..
Item 15 Page 84 of 88
Respectfully,
Adam W. Guerrero
Adam Guerrero
Counsel
(310) 255-6126
[email protected]
Read my bio >>
1888 Century Park East
Suite 1500
Los Angeles, CA 90067
CA•DE•FL•IL•MA•MD•MN•NJ•NY•PA•DC
"Saul Ewing LLP (saul.com)" has made the following annotations:
+~~~~~~~~~~~~~~~~~~~~~~~+
This e-mail may contain privileged, confidential, copyrighted, or other legally protected information. If you are not the intended recipient (even if the e-mail address is yours), you may not use, copy, or retransmit it. If you have received this by mistake please notify us by return e-mail, then delete.
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Item 15 Page 85 of 88
Tom R. Sestanovich
Phone: (310) 255-6123
Fax: (310) 255-6223
[email protected]
www.saul.com
File No. 728092-900
188 8 Ce ntury Pa rk Ea st, Suite 1500 Los An ge les, Ca lifornia 90067 Ph one : (310) 255-6100 Fax: (310 ) 255-62 00
C A L I F O RN I A DE L A WA R E F L O R I DA I L L I N OI S M A R Y L AN D M A SS A CH U SE T T S M I NN E S OT A NE W J E RSE Y NE W Y O R K PE N N S Y L VA NI A W A S HI N GT O N , D C
A DELAWARE LIMITED LIABILITY PARTNERSHIP
NOTICE OF REJECTION OF PROPOSED
MALABAR YARD AND 49TH STREET MODIFICATIONS
May 14, 2025
VIA E-MAIL AND CERTIFIED MAIL (RRR)
Los Angeles Metropolitan Transportation
Authority (Metro)
(California High Speed Rail Authority)
One Gateway Plaza
Los Angeles, California 90012-2952
Attention: Mr. Carlos Montez
Mr. Scott McConnell
Ms. Danielle Valentino
Mr. Vincent Chio
E-Mail: [email protected]
[email protected]
[email protected]
[email protected]
RE: KB New York B/H, LLC (“Owner”)/Proposed Link Union Station/BNSF Malabar Yard Project (the “Project”) -- 4900 S. Santa Fe Avenue in Vernon, CA (the “Subject Property”)
Dear Ladies and Gentlemen:
Our Firm represents the above Owner in connection with the Subject Property and the potential impact of Metro’s Project thereon, especially in relation to the proposed changes to the existing public use of 49th Street.
Back in November, 2020, and most-recently in February of this year, we received information that Metro and the California High-Speed Rail Authority were proposing to proceed with the Project in the City of Vernon, and we understand that, as currently proposed, the Project will result in the closure of the at-grade portion of 49th Street across the now-existing BNSF railroad tracks, effectively severing 49th Street into two (2) streets on either side of the railroad ..
Item 15 Page 86 of 88
Los Angeles Metropolitan Transportation
Authority (Metro)
May 14, 2025
tracks with a proposed 49th Street East and 49th Street West. As set forth in our client’s prior correspondence of November 4, 2020, PLEASE TAKE NOTICE that this proposal is unacceptable to Owner and several of Owner’s neighbors. Owner's Subject Property is presently and approximately 200,000 square feet plus in size and is fully-occupied. The Subject Property is currently used for warehousing and distribution by a single tenant: RGGD, Inc. (and prior to this tenant, the Subject Property had been demised as a multi-tenant building and property).
Despite no formal notice (yet) of any proposed or temporary complete or partial taking of our Subject Property, PLEASE TAKE FURTHER NOTICE that our client’s Subject Property has already been negatively affected by the Project. As you have already acknowledged in a Project proposal that we have seen, and from February's last meeting, the Project will negatively affect the Subject Property and result in a taking, and has already damaged Owner by complaints from our current tenant regarding a number of issues, including the potential loss of the use of 49th Street and our truck access and loading and unloading areas; and our tenant’s lack of interest in wanting to stay on our Subject Property. There may already be an actual diminution in the FMV of our Subject Property and our future ability to re-lease, insure and finance same, if at all.
If Metro’s Project moves forward, as proposed, we understand that there are only a couple of possible ways that the loss of use at the at-grade portion of 49th Street is to be mitigated (with two (2) possible designs of a truck turnaround), but any such solutions are completely unacceptable. There are other properties along the affected portion of 49th Street which depend on large truck deliveries, as does our client’s tenant at the Subject Property, and the proposed turnarounds both appear to be inadequate for the volume of traffic and the size of the trucks, such that the ongoing business at our Subject Property will be severely and negatively impacted. There are also other major issues like security, fencing and vandalism for and from the Project; material increases in insurance costs, which affect the value of the Property; the lack of police, fire and other emergency response services on 49th Street as a thoroughfare; the creation of an attractive nuisance for parked and abandoned vehicles at the ballards on the proposed 49th Street West; and issues with trucks running into these same ballards and our Subject Property, and possibly into our neighbor’s property, when trying to navigate a tight and difficult truck turnaround. Further, the loss of the at-grade crossing will cause traffic to stack up on the proposed 49th Street West, even with a turnaround, thereby making the road stub completely congested and resulting in the loss of time and economic use by our tenant, together with the loss of actual street parking and the ability to navigate the West side of 49th Street. Thus, as proposed, the Project could result in the total taking of all economic value of our client’s Subject Property.
Our client and its underlying members are long-time Southern California business people that have owned the Subject Property for many years, and they want to try and do what is best for the local community and be cooperative, but the Project, as currently configured and impacting 49th Street, is unacceptable as set forth above. We look forward to a further meetings with Metro and different proposals, along with Metro’s study of the traffic mitigation and environmental impacts of same, which Owner is willing to further review and comment on. ..
Item 15 Page 87 of 88
Los Angeles Metropolitan Transportation
Authority (Metro)
May 14, 2025
If you have any questions regarding this Notice of Rejection and/or the Subject Property, please feel free to call me at my Firm or you may have Metro’s representatives reach out to Owner directly at ARKA Properties Group, Inc. (at 310 274-2259) and/or Black Equities, LLC (at 310 278-5333).
Sincerely,
Tom R. Sestanovich
TRS/BA
cc: Owner - ARKA Properties Group, Inc. [via e-mail]
Owner – Black Equities, LLC [via e-mail]
Angela Kimmey, Deputy City Administrator, City of Vernon [via e-mail:
[email protected]]
Supervisor Janice Hahn, L.A. County [via e-mail or telecopier] Mario Osavio, HDC Inc. [via e-mail: [email protected]] Mike Melideo, Consolidated Fabricators [via e-mail: [email protected]] David Freitag, Daum Commercial [via e-mail: [email protected]] Elizabeth U. Witmer, Esq. at SE [via e-mail]
William E. Adams, Esq. at SE [via e-mail]
55508117.1 ..
Item 15 Page 88 of 88