SCH Number: 1982092310 File: 07-LA-710 (SR 710) Project: EFIS 0700000191 (EA: 187900) State Route 710 North Study March 26, 2015 Mr. Garrett Damrath Chief Environmental Planner Caltrans District 7 Division of Environmental Planning 100 S Main St, MS-16A Los Angeles, CA 90012 Subject: Initial Comments on the SR 710 North Study Draft ETR/EIS ‘Dear Mr, Damrath: respectfully request the following actions be considered by Caltrans regarding the State Route 710 North Study Project Draft Environmental Impact Report/Environmental Impact Statement (Draft EIR/EIS): 1. Extend the public review comment period for an additional 60 days beyond the 120-day comment period, and add more public hearings near the end of the public review period. 2. Release the cost-benefit analysis now. 3. Assess the potential risk for a tunnel boring machine (TBM) failure during tunnel construction as related to the tunnel and the light rail alternatives, and develop mitigation measures for significant direct and indirect impacts. As an environmental planning professional with over 34 years of experience in CEQA and NEPA preparation and processing, I recognize the importance of the SR.710 North Study Project and the need for the analysis to be thorough, complete, and transparent for both the decision makers and the public. The three items cited above are crucial to have in place so that the public can fully participate in the CEQA/NEPA process and prepare thoughtful and meaningful comments, Below I elaborate the reasons why these three requests are necessary. Extension of Comment Period and Additional Public Hearings ‘As noted by a FHWA website (http://environment.fhwa.dot.gov/projdev/tdmpubiny2.as} “Public involvement and a systematic interdisciplinary approach are essential parts of the development process for proposed actions. (23CFR § 771.105(c)]” In essence, the importance of public involvement, inclusion, and participation is supported by the FHWA and must therefore be part of Caltrans” directive in assessing and processing the Draft EIRVEIS. The typical CEQAMr. Garrett Damrath, Caltrans March 26, 2015 ‘SR 710 Study Project DEIR/DEIS Page 2 public review period is normally 45 days for a Draft EIR and Caltrans has indeed gone beyond that requirement with 120 days. However, it should be noted that the regulations also state that normally a typical EIR should be 150 pages long or for a more complex one, 300 pages (California Code of Regulations § 15141). Of course, no agency today can accomplish the presentation of technical and general information in an EIR for such an important project with a mere 300 pages So, why then, must it be assumed that the “average” citizen can read, understand, and comment on documentation containing roughly 26,625 technical pages within 120 days? To better visualize this, if the pages were all letter sized and photocopied on both sides, the documentation ‘would fill about five drawers of a vertical, letter-sized cabinet. Assuming a highly optimistic average of 2 minutes per page to read, cross check with other pages as needed, and write down a comment, it could take up to 53,250 minutes or more for one human being to read through the entire documentation. Taking this visualization one step further, assume that this “average” citizen took time off from his/her job and focused solely on the documentation, 8 hours per day, 5 days a week, on average 160 hours per month, So, 53,250 minutes equals 887.5 hours or over 5.5 months. Caltrans has only offered up 4 months (120 days) to review their documentation. Instead, 2 more months are warranted. Many individuals are now taking the time to read in the evenings and on weekends while balancing the needs of their families, work, and other personal/social/teligious activities, With this commitment by so many members of the public and civic representatives to read the documentation posted s0 far, itis not asking a lot from Caltrans to extend its comment period by a reasonable amount so that the public can fully understand the complexities and enormity of this very important project and its alternatives. As you know, Caltrans and its consultants have had since March 2011 to work on this documentation based on the release of the NOI and NOP. That’s four solid years of research, analysis, and report writing. The most reasonable approach therefore is to allow the public to have at least 6 months to review as much as is humanly possible. With respect to the two public hearings currently scheduled, this portion of the public involvement is unfortunately deficient. The timing of holding both hearings mid-April premature and assumes that the public has had time to read a substantial portion of the documentation (released in March) and then present their comments at the two public hearings. To extend the challenge even more, the scheduling of one hearing at Spm on the weeknight would be very difficult indeed for most employed individuals to attend. Why the hurdles to conducting this very public and important phase of the CEQA/NEPA process? With so many previous attempts at having workshops and scoping meetings (regardless of whether or not these events evoked meaningfulness and clarity) prior to the release of the documentation, why then have only two public hearings at this point of the environmental process? More hearings are ‘warranted given the size of the study area, the numbers of stakeholders, and the ramifications of the project to all affected communities and the region. ‘As noted by FHWA, on the previously cited website: “Public involvement is more than simply following legislation and regulations. In a democratic society, people have opportunities to debate issues, frame alternativeMr. Garrett Damrath, Caltrans March 26, 2015 SR 710 Study Project DEIR/DEIS Page 3 solutions, and affect final decisions. Knowledge is the basis of such participation. The public needs to know details about a plan or action in order to evaluate importance or anticipated costs and benefits. Through continued interaction with the entire community, agencies and project sponsors can build support and, more importantly, assure that the public has the opportunity to help shape the substance of plans and actions. In summary, public agencies must act as public servants.” The public wants more public hearings and have those scheduled near the end of the comment period—not at the beginning when they have just begun to review this tome. Cost-Benefit Analysis Others have more eloquently stated the purpose and the need for a cost-benefit analysis and its inclusion into the EIR/EIS process. I concur and incorporate by reference the letter recently sent to you by the Honorable Anthony Portantino. That said, I have two points to make on this issue. According to NEPA guidelines (40 CFR 1502.23): “{fa cost-benefit analysis relevant to the choice among environmentally different alternatives is being considered for the proposed action, it shall be incorporated by reference or appended to the statement as an aid in evaluating the environmental consequences.” Of course per the California Code of Regulations (§ 15150), anything incorporated by reference in an EIR shall also be made available to the public. With a multi-billion dollar project at stake, why wouldn’t the cost-benefit analysis be done and be made available to the public now during the review period? Additionally, here is some relevant guidance on cost-benefit analysis and transportation planning from another FHWA web-link (http://environment.fhwa.dot.gov/projdev/tdmnced.asp): “The purpose and need section is in many ways the most important chapter of an environmental impact statement (EIS). It establishes why the agency is proposing to spend large amounts of taxpayers’ money while at the same time causing significant environmental impacts, A clear, well-justified purpose and need section explains to the public and decisionmakers that the expenditure of funds is necessary and worthwhile and that the priority the project is being given relative to other needed highway projects is warranted. In addition, although significant environmental impacts are expected to be caused by the project, the purpose and need section should justify why impacts are acceptable based on the project's importance.” ‘The cost-benefit analysis must be part of the basis in creating the purpose and need, along with framing up the appropriate alternatives studied in the Draft EIR/EIS. This information should be made available to the public to further explain the rationale and justification of the project.Mr. Garrett Damrath, Caltrans March 26, 2015 SR 710 Study Project DEIR/DEIS Page 4 Contingency Plan for TBM Failures 1 could not find anything in the Draft EIR/EIS regarding TBM failures during tunnel construction. TBMs are highly sophisticated mechanical systems that are designed to be subjected to an array of harsh geologic and hydrologic conditions; however, no one can say with absolute certainty that a catastrophic failure can never happen during the construction phase. Planners deal with this risk through a reasonably foreseeable analysis of such an event during the environmental planning phase of the project. Indirect impacts in the immediate area as well as impacts to the surrounding community could occur including impacts to utilities, transport networks, access by public health responders, and so forth should a shaft and access pit be required to “rescue” the TBM if repairs cannot be made inside the tunnel. As noted in the California Code of Regulations (§ 15378), a project means the whole of an action for purposes of a CEQA analysis. For example, a typical environmental analysis will describe mitigations or best management practices for significant impacts by above ground construction equipment and pickup trucks that may inadvertently leak oil into nearby streams or wetlands, if such habitats ‘occur within the construction zone. No one intends for that to happen, but equipment can leak and spills can occur, So, during the CEQA/NEPA phase, the EIR/EIS describes what steps will be taken to minimize such possible risk to the environment. This same treatment of a potential risk is equally valid for consideration of a possible catastrophic TBM failure. We are already witnessing the events in Seattle and with the heroic efforts to secure and repair “Bertha,” a roughly 57-foot in diameter TBM. Hence, a contingency plan needs to be developed and assessed in the Draft EIR/EIS to deal with the potential catastrophic failure of a TBM and how significant impacts/adverse effects resulting from needed repairs will be mitigated. ‘The various tunnel alignments for the tunnel and light rail alignments are beneath mostly urban areas with homes, offices, shops, schools, and hospitals, An assessment on such failure in relation to the communities and public services is indeed warranted and should not be ignored at this time. Lastly, since first responding to your NOP in 2011, my family and I have moved. Please update your mailing list with our new address as noted below. I would appreciate receiving your responses to my comments, along with future planning/environmental documentation on this project. I do intend to submit additional comments later in the review period, Sincerely, Lp ) Ap wy ans L), Sore MSS. Delaine W. Shane 2003 Meridian Avenue, South Pasadena, CA 91030 wehoa_402@outlook.com