0 SEQUOYAH SCHOOL August 4, 2035 Garrett Damrath, Chief Environmental Planner Division of Environmental Planning Department of Transportation, District 7 2005, Main Street, MS-164 los Angeles, CA 90012 Re: Draft Environmental impact Report/Environmental impact Statement SR 710 North ‘Study Dear Mir. Damath: ‘We write to provide comments with respect to potential adverse impacts of the Build Alternatives described in the State Route 710 (SR 710) North Study (collectively, the “Project’} on Sequoyah School. We are concerned thatthe environmental review pays ‘only cursory attention to the serious adverse impacts expected from the Project, and ‘Alternatives and within 500 feet of their construction.’ We have carefully reviewed the '5R 710 Draft Environmental Impact Report Statement forthe Project ("DEIR/S"), wi we believe is convoluted, internally inconsistent, and almost completely inaccessible for ‘the great majority ofthe general public. With these overarching concerns in mind, we respectfully submit these comments tothe DEIR/S in an effort to ensure thatthe agency {decision-makers overseeing the Project comply with the California Environmental ‘Quality Act ("CEQA"), Public Resources Code section 21000 et seq,, and the National Environmental Policy Act ("NEPA"), 42 US.C. section 4321 et seq ‘Mindful ofthe tremendous responst students and teachers and as stewar within our community, we submit the for safeguarding the wellbeing of our a historic resource and social institution lowing: 4. The DEIR/S reaches numerous conclusions with either false assumptions or Insufficient evidence; 6267954251 sequoyahahoolorg 538 South Psadena Avenue Pasadena CA 91105-30012, The DEIR falls in many ways to adequately describe the fll scope and measure of humerous impacts ofthe proposed alternatives and therefore does not provide a thorough understanding of how these impacts will be mitigated; and 3, The DEIR/S defers critical environmental studies and analysis until after a Preferred Alternative is chosen, thus forcing decision-makers to set a course without a complete understanding of an alternative’s potential consequences ~ real consequences for many ‘of us who wil ive, work, and attend school within the scope ofthe Preferred Alternative's construction and operation, ‘Throughout the process of reviewing the DEIR/S and preparing our comments, we have reviewed draft comments from a number of other institutions and groups that have articulated a variety of concerns and deficiencies in the DEIR/S. We agree with many of ‘these comments, but rather than reiterate them here, we have focused our attention on the specifc deficiencies n the DEIR/S that affect Sequoyah School. In accordance with this approach, Sequayah School hereby adopts, endorses, and incorporates by reference ‘the comments submitted by the 5ities Alliance Pasadena, South Pasadena and Sierra Madre), the National Trust for Historic Preservation, the No 710 Action Committee, Pasadena Heritage, and the National Trust for Historic Preservation. 1. The DEIR/S reaches conclusions with either false assumptions or Insufficient evidence. 2. Noise ‘The DEIR/S's findings with respect to noise are based on false assumptions. For example, in direct reference to Sequoyah, the DEIR/S states thatthe school could experience permar ion; therefore, the permanent noise evel increases under the TSM/TDM Alternative would not adversely affect ther ability to serve the community.” DEIR/S 3.3-29-30, \We find this tobe a curious and unsupported conclusion. First, the DEIR/S falls to define the appropriate noise-sensitve standard. Further, the DEIR/S neglected to take the particularized look necessary to support the conclusion that the “TSM/TDM Alternative ‘would not adversely affect {the facilites’ ability to serve the community.” Children attending school at Sequoyah are routinely outside Monday through Friday at recess, lunchtime, while walking to classrooms, during PE. and academic projectrelated activities, for before- and after-school enrichment lasses and free play. Qutdoor AllSchoo! Meetings, parent potlucks and special music and theater performances occur at least several times per semester. Classroom windows and siding doors are routinely open to take advantage of Southern Californias mild climate. Students and teachers, in an effort to conserve energy and minimize costs, rely on airconditioning or heating only when necessary, ‘The DEIR/S suggests that reliance on air conditioning will be absolutely necessary as 2 ‘means of mitigating the serious issue on hand. This assumption in addition to being false, shifts the burden for noise mitigation tothe school. ‘Sequoyah’s students are exposed to existing traffic noise from cars, trucks, motorcycles, ‘and buses, the DEIR/S does not provide evidence to answer the following questions cise generated by the Project result in a more damaging evel of. Will those experiencing the difference be adversely affected? (3) Willthe school's ‘operation be adversely impacted? At a minimum to be adequate, the EIR needs to define a noise standard, accurately forecast the impact, taking into account the actual (not made-up) operating conditions of the school, determine mitigation that would be the obligation ofthe Project proponent, and then acknowledge the unavoidable adverse impacts. The record is clear that fait conditioning is relied upon ex have a negative impact on current school operations, and such impact wl mitigated, ‘Sequoyah School (a process which wil take place over five years and include excavation, ‘grading, cut and cover construction, the launch and operation of the tunnel boring ‘machine, and truck trips to and from the construction staging area), the DEIR/S speculates that noise impacts willbe “typical” and does not provide useful discussion of ‘ype, duration and severity of noise impacts or mitigation for this particular project. DEIR/S 3.14-8, 4-70, Norisit clear how these impacts will be ameliorated during construction ».Air Quality Given the Schoo!'s proximity o the construction site ofeach of the TOM, TSM, LRT and Freeway Tunnel alternatives itis imperative that the analysis of ar-quality Impacts shouldbe considered prior to selection ofthe Preferred Alternative and that the most ‘demonstrably effective mitigation measures to address these impacts be required uring construction and eventual operation In consideration of the Freeway Alternative, we are particul cumulative effect of exposure to increased noxious emissions and noise over along, construction period on the health of young children at Sequoyah School and at the ‘neighborhood playground at Singer Park located at California Boulevard and St. John ty mindful of the‘Avenue. It should be noted that emissions generated by soll disturbance during site preparation, grading and excavation, operation of construction equipment, and worker commutes and construction related noise would extend beyond the boundaries of the construction area. DEIR/S 33-61 Nonetheless, the DEIR/S states that ant forthe freeway tunnel alterati area surrounding the construction site." The maps provided at p conducted by Caltrans and Metro indicate that Sequoyah Scho immediate area surrounding the construction site. Therefor students and staf wil be placed at risk and the DEIR/S presents an Inaccurate assessment ‘The DEIR/S provides a warning for those situated within this area: "[SJhort-term ‘degradation of air ‘may occur due to the elease of particulate emissions generated by excavation, grading, hauling, and other construction equipment.” DEIR/S 4.6, However, the DEIR/S does not disclose whether the Project's impact constitutes 3 significant impact. DEIR/S Table 3.13.8 at page 313-11. Furthermore, the DEIR/S fas to evaluate whether emissions cited will violate federal and state ambient air qual standards, lthough the DEIR/S alludes to mitigation measures, it does not provide sufficient evidence to support the conclusion that construction-related emissions would be les than significant or thatthe proposed mitigation would be the most effective or ‘most restrictive in comparison to other methods. DEIR/S 3.13-11. This sort of conclusive reasoning, unsupported by appropriate inferences, is a fundamental flaw that undermines the overall integrity of the DEIR. ‘Additionally, we note thatthe U.S. EPA has observed a significant relationship between exposure to particulate matter PM 2.5 and premature mortality, aggravation of respiratory and cardiovascular disease, lung disease, decreased lung function, and asthma attacks, especialy for older adults, people with heart and lung disease and en. See generally Air Quality Designations and Classifications for the Fine Particles ant Air Quality Stondards, 70 Fed. Reg. 944, 945 (Jon. 5, 2005) Vol 2, Ex.28-e. The DEIR/S does nat reference these findings, which we find particularly problematic in light of the contemplated Build Alternative. ‘The DEIR/S Technical Appendix discloses that operation of all ofthe various freeway tunnel alternative options may cause a localized cancer increase. DEIR/S Health Risk [Assessment Appendix at pages 3-8, Sequoyah Schoo!'s campus is among those locations identified near the narth portal and freeway interchanges that will be subject tothe greatest exposures, exceeding thresholds of significance established by SCAQMO Ar Toxics Hotspot Rule (Rule 1401). The DEIR/S's own documentation undermines its explicit claim that Build Alternatives would result in a net decrease of cancer risks, a ermal inconsistency. DEIN/S 4.8,6 Traffic impacts ‘The DEIR/S proposes hauling routes forthe excavation of the Fillmore Station LRT along, California Blvd uphill through three stop lights adjacent to Huntington Hospital and medical offices. Trucks servicing the LRT construction, hauling tunnel spoils, braking and idling at these lights, and turning right onto Pasadena Avenue to access the 210 Freeway ‘onramp running adjacent to the schoo! wil certainly cause further concentration of diesel particulates, increased noise, and traffic congestion at this pedestrian crossing regularly used by schoolchildren and accompanying adults. We see no study of these Impacts and no determination as to how the DEIR/S authors seemingly concluded that sch impacts are not significant ‘Additionally, the DEIR/S states that during construction ofthe Freeway Tunnel Alternative and other alternatives there will be traffic delays and detours imposed ‘on streets surrounding the north portal construction zone. However, the DEIR/S does not adequately address detal the concentrations of emissions resulting from five years ‘or more of cars and trucks idling on congested streets and the impacts on nearby residences, schools, hospital and convalescent homes. 4. Assessment of Construction Related Vibration impacts and Ground Settlement ‘The DEIR/S states that the Project's proposed excavation and tunneling could cause round settlement and diferentil settlement immediately above and adjacent to the ‘bored tunnel portion and the portal excavations ofthe tunnel alternative, DEIR/S 3.10- 30 to-12, However, the DEIR/S finds no adverse effect on the Markham Place Historic District and no adverse effect on 42 historic properties above the tunnel segments in the Freeway Tunnel Alternative. DEIR/S Table ES-1 at 32. ‘Sequoyah Schoo!'s campus is located within 2,500 feet ofthe proposed TBM launch at the north portal, where presumably the eventual depth of the bored tunne! closer tothe 20 feet below ground surface measured from the crown of the tunnel, DDEIR/S at 10, as it transitions from cut and cover portion rather than maximum depth of 280 feet below ground surface. ‘The Finding of no adverse effect on the Markham Place Historie District, DEIR/S 3.7-78, s reached despite Caltrans/Metro's SR710 North Study Technical Memorandum Potenti Settlement Effect an Historic Properties, prepared for Metro by Jacobs ‘Associates/CH2M HILL, copied to Caltrans, dated May 11, 2015, which appears to suggest just the opposite. While we appreciate that timing considerations may have precluded such findings from being included inthe DEIR/S, now that this information Is known, it must be fully considered in the DEIR/S. Neither Metro nor Caltrans provided copy of this memorandum to Sequoyah School, nor is it publily available at this time. Sequoyah School is fortunate to have received the copy from Pasadena Heritage,‘The Technical Memorandum provides that Sequoyah Schoo! will experience moderate to severe damage (with severe damage described as “extensive repair involving removal and replacement of sections and walls, especially over doors and windows required. ‘Windows and door frames distorted, floor slopes noticeably. Walls lean and bulge noticeably, some loss of bearing in beams, Utlity service disrupted.” Table 3 1 of Visible Damage (modified from Boscardin and Cording , 1988). The classification does not indicate, ifand when such damage occurs, whether the buliding Would remain habitable or safe for school operation, ‘The conclusion in the Technical Memorandum directly contradicts the DEIR/S, which ‘notes that "tJhe tunnel excavation below this Historic District may result in minor physical damage.” DEIR 37-78 It also contradicts the following staternent in the Summary of Potential Effects in Table 37.5 37-83 Effects ofthe Freeway Tunnel Alternative (Tunnel Segments) on Historical Properties inthe Area of Potential Effects in which Sequoyah School listed: “Asa result, finding of no detectable risk of adverse effect (i.e. damage) to any of the historic properties listed In this table would occur as a result ofthe Freeway Tunnel Alternative.” This contradiction is incredible and mandates revision and recirculation with the true facts considered, 2. The DEIR/S falls in many ways to adequately describe the full scope and measure of, ‘numerous impacts and therefore does not provide a thorough understanding of how ‘these impacts will be mitigated. ‘The DEIRY/S does not provide adequate details regarding the construction of the Bull Alternatives critical to understanding Project impacts. It does so while noting that ‘CEQA, on the other hand, does require Caltrans to identify each “significant effect on ‘the environment” resulting fcom the project as well as ways to mitigate each significant effect, If the project may have a significant effect on any environmental resource, then an EIR must be prepared. Each and every significant effect on the environment must be tisclosed in the EIR and mitigated, if reasonably feasible.” Executive Summary at 16. Below are some areas of particular concern: . Long-Houl Truck Tips Although the DEIR/S estimates the number of long-haul truck trips (360 trucks per day ‘or 15 trucks per hour) that would be needed to haul spoils from portal areas and asserts ‘that this number of trips would be a “very small percentage ofthe existing daily volumes ‘on the haul route roadways” and that "no mitigation is required”, DEIR/S 470, the DEIR/S does not provide information about the impact of those daily truck trips on the vicinity of the north portal where activity would be continuous during a lengthy construction period. The DEIR/S is riddled with similar instances of conclusive reasoning, as it des not clearly follow from the assertion that such truck trips represent percentage of existing daily volumes that no mitigation is necessary+b Tunnel Boring Operations If the Freeway Tunnel alternative were to be chosen, the School's science and 5-6" grade and junior high classrooms would directly overlook the cut and cover portion of, the route, the operation and maintenance building and its parking lot, and presumably 2 ial substation (although the location ofthat permanent substation is yet to construction, the Sequoyah School population \would witness and presumably feel the launch of the tunnel boring machines as they cut ‘their way through the face of the hill stoping down from Sequoyah Schoo!'s foundations, ‘and students would breathe the exhaust ofthe estimated 360 trucks per day hauling ‘tunnel spoils, DEIR/S 4-70, in addition to the fughive dust Ingering over the staging yard below as trucks idled in wat for over five years of continuous construction atthe north portal \We note that “—tJunnel boring operations and muck handling could potentially occur 24 hours per day, 7 days per week.” DEIR/S 2-58. Despite the evident scale and duration of hauling to service the tunnel boring operation the DEIR/S does not describe the possibilty of numerous idling trucks atthe laydown areas as they wat tobe loaded, the consequent airborne noxious exhaust emissions and noise traveling beyond the ste, the lispersal of dust, and other negative health effects. In the LRT and Freeway Tunnel alternatives, the tunnel would be fabricated from 2 precast concrete segmental lining system, DEIR/S 2-52, 2-80. The DEIR/S falls to consider and explain how the precast tunnel rings willbe transported to, or fabricated at the Project ste. Given the size of precast tunnel rings and the number needed to be assembled to complete tunnels ofthe length described in the DEIR/S, their transportation and fabrication deserve a Project impact al their own that addresses truck routes, diesel emissions, noise (air brakes and horns, the beeping of trucks backing ‘up and unloading), pedestrian crossing lane closures, and the staging of materials needed for fabrication (gravel, water, rock et). Furthermore, the DEIR/S neglects to describe the process by which the two tunnel boring machines will be transported to the north portal « Construction-Related incidents Responses to construction-related incidents, such as fallure ofthe tunnel boring machines, do not describe a TBM repair plan or strategy. Additionally, there iso description of the potential impacts regarding repar related excavation and extended tunnel construction, ground settlement, addtional nose, vibration or air-quality. Incidents such as sudden ground-level subsidence, exposure to hazardous waste, traffic incidents, equipment fuel spills, loading and how those types of incidents would be ‘managed (emergency communications planning, coordination of fist responders te.) are not detailed inthe DEIR/S.4. Electrica Substation ‘An electrical substation is proposed to deliver temporary power tothe tunnel boring ‘machine and permanent power for tunnel operation. The location of that substation wil be coordinated with Los Angeles and Pasadena Departments of Water and Power. DDEIR/S 2-72, Hows the community to understand the nature of environmental impacts Of sting a temporary substation to supply power for the construction of freeway tunnel ‘permanent substation for its operation when we are not told of its proposed location ‘or dimension? 13. The DEIR/S defers savironmental studies and analysis until ater a Preferred ‘Alternative i selected, thus forcing decision-makers to seta course without 2 complete understanding of an alternative’s potential consequences. Given Sequoyah’s proximity to the construction site of each ofthe TDM/TSM, LRT and Freeway Tunnel alternatives, we are concerned and would hope that the most comprehensive analysis of ale-quality impacts is considered prior to selection of 2 Preferred Alternative and that the most demonstrably effective mitigation to address the impacts ofthe Preferred Alternative is undertaken during construction and eventual ‘operation. ‘0. Timing of Geotechnical and Air-Quality Studies Geotechnical and alr-qualty studies critical tothe determination and understanding of potential impacts ofthe Freeway Tunnel alternative, its construction and operation are scheduled to be undertaken only after the Prefered Alternative is chosen. DEIR/S Table £5.2: Permits, Reviews, and Approvals Required for Project Construction at 41-43 ‘This timing makes it fficult if not impossible to understand and comment upon the significance of environmental impacts For example, how can the fullimpact of the Freeway Tunnel aternative’s construction and operat 10 emissions be understood without knowing the results and analysis ofthe required A ‘Quality Conformity and Hot Spot studies? This is an improper deferral of studies and wi prevent the public from being able to adequately participate in the decision-making process , Overly Optimistic Construction-Related Timelines ‘We note that the DEIR/S Executive Summary estimates that construction ofthe Freeway Alternative- dual bore tunnel will take “approximately five years" (only one year longer than single bore) and LRT “approximately six years". DEIR/S Executive Summary 24, 28However, we note later in the DEIR/S that "[clonstruction activities would no lst for ‘mote than 5 years at one general location, so construction-related emissions do not reed to be included in the regional and project-level conformity analyses (40 CFR '93.123{e\(5)." DEIR/S 3.13-10. We question the absolute certainty here of "five years", especialy in contrast tothe use ofthe word “approximately in the executive summary. We point to projects ofthis size and scale, such as Washington State's Alaskan Way Viaduct replacement project and Boston's “Big Dig,” which encountered substan delays and far exceeded construction cost and timing estimates, In adeition, we note that thatthe DEIR/S also describes tunnel construction activities at the north portal being continuous from beginning to end because of removal of tunnel spoils, construction staging and the construction of the cut-and cover portion, along with the TDMY/TSIM improvements and the St.John extension. Given that the estimate of five years is certainly approximate, that construction willbe continuous at this location, and that we are concerned about the health of young children present at Schools, Huntington Hospital, Singer Park and Ronald McDonald Home within the Immediate vicinity of construction, we argue that regional and project-level conformity analyses of construction related emissions should be undertaken prior to the selection of a Preferred Alternative. ¢ Hot-Spot Analysis ‘The DEIR/S states as follows: "The Freeway Tunnel Alternative single- and dual-bore {design variations are Projects of Air Quality Concern (POAQC), If the Freeway Tunnel ‘Alternative with elther the single-bore or dual-bore design variation i identified as the Preferred Alternative, a quantitative PM hot-spot analysis will be conducted to demonstrate thatthe project would not delay attainment of or worsen existing violation of or cause an exceedance of the PM2.5 or PMO NAAQS and meets conformity requirement." DEIR/S at 3. We believe 2 study should be conducted and evaluated prior to_an alternative selection, particularly when many young children will be continuously ‘exposed to these emissions and their health effects could lata lifetime. 4. Air Quality impacts of Excovotion ‘The DEIR/S states that there will be substantial excavation and ground disturbance in the area ofthe north portal during construction, and that excavated dirt resulting from boring willbe staged and hauled from this zone: “During construction, short-term degradation of ar quality may occur due tothe release of particulate emissions (airborne dust) generated by excavation, grading, hauling, and other activities related to construction, Emissions from construction equipment aso are anticipated and would include CO, NOx, volatile organic compounds (VOCs), directly-emited particulate matter (PNMiz9 and PMp_5), and toxic air contaminants (TACS) such as diesel exhaust particulate matter." DEIR/S at 3.13.9.10 ‘The DEIR/S continues: “In addition to dustrelated Po emissions, heavy trucks and construction equipment powered by gasoline and diesel engines would generate CO, ‘502, NOy, VOCs, and some soot particulate (PMgg and PMz 5) in exhaust emissions ‘construction activities were to increase traffic congestion in the area, CO and other emissions from traffic would inerease slightly while those vehicies are delayed. These. emissions would be temporary and limited to the immediate area surrounding the construction site." DEIR/S at 3.13.9 Although the DEIR/S describes adverse air quality effects during construction as temporary and short-term, DEIR/S at 3.3-61, we are concerned that the approximately five years of continuous construction described inthe report occurring adjacent to three schools (Maranatha, Waverly and Sequoyah) will have long-term health consequences forthe children enrolled at these schools. As previously noted, we are especially concemed about the effect of particulate matter generated by ‘onstruction activities, including dling truck traffic exacerbated by the anticipated traffic detours and delays outlined inthe DEIR/S. The DEIR/S estimates appr 360 haul trips per day depending on whether a single bore or dual constructed (and this number isin addition tothe trips needed tod equipment and material, which is not addressed inthe DEIR/S). We believe that itis rmost prudent to conduct analysis of construction related air quality impacts prior to selecting a Preferred Alternative «Blasting ‘The DEIR/S acknowledges that blasting may occur ifhigh strength bedrock is discovered In the cut-and-cover portion of the tunnel or in the excavation of cross passages. However, the DEIR defers analysis of impacts of basting to another date. Controlled lasting DEIR/S 3.14-9; 324-13. The impact ofthis blasting would have significant Impacts on the School and the surrounding community, and should be seriously considered before moving forward with a Preferred Alternative, ‘Jf. Construction Management Plan ‘We are concerned that in spite ofa five/si year construction period forthe freeway tunnel alternative, and numerous delays, detours and congestion (and attendant nose, ‘emissions, and imperiled safety of pedestrians) that are forecast inthe DEIR/S, the ‘construction traffic management plan, which would spell out the means intended to ‘manage these impacts, i to be delivered at a future date and we are a not assured that I}he formulated with consultation of those businesses and residents directly involved. Ther interests must be taken into account. 4. Conclusionuw For all Build Alternatives, the DEIR/S asserts thatthe character, cohesion and safety of ‘our community vill nt be affected by construction over the long-term, DEIR/S at 22, and that the "Freeway Alternative would not result in short-term adverse effects on community character and cohesion.” DEIR/S 3.3-27. These conclusions are difficult for usat Sequoyah to into question even by the limited det provided in the DEIR/S itelf—especially when considering the impact of five years of, continuous construction in the vicinity of the Freeway Alternative’s north portal. The DDEIR/S needs to be revised to include adequate noise, air quality and construction and heath impacts analyses that are grounded in fact, not assumption. The DEIR must be recirculated, for public review consistent with these comments‘Thank you for considering the comments of Sequoyah School Please feel free to contact us you have any questions Sincerely, pr Gol, sbsh Brody Director, Sequoysh Schoo! Michae! Barak President, Board of Trustees, Sequoyah School cc: Kelley Ewing-Toledo, Caltrans Christina Morris, National Tust for Historie Preservation Sarah Gavit, West Pasadena Residents Association Vince Berton, Planning & Community Development, City of Pasadena Clare Bogaard, No 710 Action Committee Jesse Latig, Pasadena Heritage