City of Culver City, California
City Council Agenda Item Report
RECOMMENDATION:
That the City Council adopt Resolution No. 2005-R_____, and the Redevelopment
Agency Adopt Resolution No. 2005-RA_____ “Transmitting the Official City and
Agency Response to the 2005 Final Environmental Impact Report/Statement for the
Proposed Metro Mid-City/Exposition Light Rail Transit Project. ”
BACKGROUND:
On October 14, 2005, the Los Angeles County Metropolitan Transportation Authority
(“Metro”) in conjunction with the Federal Transportation Administration (the “FTA”),
and U.S. Department of Transportation circulated a Final Environmental Impact
Report/Statement (the “Final EIR”), dated October 2005, for the Exposition Light Rail
Transit project as required by the California Environmental Quality Act (CEQA) and
National Environmental Policy Act (NEPA). Metro, the Federal Transit
Administration (FTA) and the U.S. Department of Transportation are the “Lead
Agency(s)” for this Final EIR.
Culver City received the Final EIR on Wednesday, October 12, 2005, and
immediately distributed it to City Departments and the City Council for review. The
45-day public comment period on the Final EIR began on October 14, 2005 and
ends on November 28, 2005.
Meeting Date: 11/21/05 Item Number: J-1
AGENDA ITEM: A Joint Item Consideration of Resolutions Transmitting the
Official City and Agency Response to the 2005 Final Environmental Impact Report
/Statement for the Proposed Metro Mid-City/Exposition Light Rail Transit Project.
Contact Person/Dept.: Susan Yun/
Community Development
Phone Number: (310) 253-5755
Fiscal Impact: Yes [x] No [] General Fund: Yes [] No [x]
Public Hearing: [] Action Item: [x] Attachments: [x]
Public Notification: Citywide postcard notification on 10/13/05; Publication in the Culver
City News on 10/13/05; 10/20/05; 11/10/05 and 11/17/05; Posted on City’s Website on
10/13/05 and Master Notification List on 10/12/05, 10/19/05 and 11/16/05. Additional
email notification was sent on 11/14/05 to the Design for Development stakeholder list,
Local Developers, and Major Culver City Employers.
Department Approval:
Susan Evans 11/10/05
CAO Approval:
Martin Cole for Jerry Fulwood 11/16/05
City Controller Approval:
Marlee Chang 11/16/05City of Culver City, California
City Council Agenda Item Report
On October 24, 2005, a joint Council and Agency meeting was held to discuss and
seek early Council/Agency and community input while staff was analyzing the Final
EIR and formulating detailed comments for Council and Agency consideration. At
the meeting, several community members, the Council and Agency members raised
a number of questions and comments in regards to the Final EIR and the Exposition
Light Rail project. A summary list of comments and questions received at the
meeting is attached to this staff report (Attachment 4). Many of these comments are
addressed in this staff report or incorporated as comments within the detailed
comments of “Exhibit A” of the Resolutions attached. Other comments and
questions will be addressed verbally by staff and/or consultants at tonight’s meeting.
The purpose of tonight’s meeting is to consider staff’s recommended comments,
listen to public comment, and then accept or modify these comments for transmittal
to the Lead Agency(s).
Consideration of the Final EIR document by the Council/Agency does not constitute
an approval of Metro’s Exposition Light Rail Transit project in any manner. As
required by the adopted Design for Development for the Exposition Light Rail Station
Area, the Agency will consider the Exposition Light Rail project at a separate time.
DISCUSSION:
Project Description
The Exposition Light Rail Transit (LRT) is a 9.6-mile, eleven-station project (three
stations will be shared with Metro Blue Line and eight new stations will be
constructed exclusively for Exposition LRT trains). The alignment generally follows
the abandoned Exposition Rail Right-of-Way from Downtown Los Angeles to the
interim western terminus in Culver City.
In April 2001, Metro published the Draft EIR/EIS which considered a range of
alternatives for the Exposition Corridor and Wilshire Corridor. The alternatives
evaluated in the 2001 Draft EIR/EIS included a busway or a light rail system at a
shortened length (to Culver City) or full length alternative (to Santa Monica) along
the Exposition Corridor.
In June 2001, the Metro Board considered all the alternatives for the Exposition
Corridor and selected what is referred to in the EIR as the “Locally Preferred
Alternative (LPA)”. The LPA is the alternative which takes light rail versus busway to
a shortened length of the Exposition Corridor (from Downtown Los Angeles to Culver
City instead of the full length to Santa Monica). City of Culver City, California
City Council Agenda Item Report
The Final EIR evaluates solely the Light Rail Transit alternative for the Exposition
Corridor to the shortened length to Culver City (Phase II to Santa Monica will be
evaluated by Metro in a separate environmental document).
In addition to the 2001 LPA, the Final EIR considers five configuration options for the
terminus station at Venice and Robertson Boulevards. Four of the proposed options
feature at-grade stations that would be located on the east side of the Washington
and National Boulevard intersection. The fifth option would elevate the LRT track-
way from the Washington and National Boulevard intersection and construct an
aerial station at the same site considered for the 2001 LPA Venice/Robertson
Station. These proposed design options for the Venice/Robertson area are also
summarized in the attached matrix (Attachment 1).
The following summarizes the range of station options discussed in the Final EIR:
Metro’s 2001 Locally Preferred Alternative –The Locally Preferred Alternative
(LPA) adopted by Metro Board of Directors in June 2001 called for an at-grade
station on the right of way between Washington and Venice Boulevards at
Venice/Robertson, with at-grade crossings of Washington and National
Boulevards. This option is no longer Metro staff’s recommended alternative in
the Final EIR because it violates terms of the Culver City General Plan and
Redevelopment Agency’s Design for Development, which prohibits at-grade
crossings by fixed rail transit.
Venice/Robertson Design Options
Aerial Design Option – This option proposes an aerial, center-platform station
located between Washington and Venice Boulevards. As the aerial station would
elevate the LRT track-way east of the Washington and National Boulevard
intersection, operational conflicts at this intersection would be avoided. This
option is proposed to be the ultimate permanent configuration. All other options
described below are temporary or “interim”.
Right-of-Way (ROW) Design Option – This option proposes an at-grade, center-
platform station in the Metro owned ROW where Wesley Street dead ends at the
ROW and National Boulevard. This is Metro staff’s recommended revised
Locally Preferred Alternative as it is the least costly and does not require property
acquisitions.
North of ROW Design Option A – This design option proposes an at-grade,
center-platform station on the northeast corner of the Washington and National
Boulevard intersection. Implementation of this design option would displace an City of Culver City, California
City Council Agenda Item Report
existing business (currently a roofing supply company) located on the proposed
site. This property is currently in escrow with a private developer who proposes
to develop a mixed-use project at this site.
North of ROW Design Option B – This design option proposes an at-grade,
center platform station north of ROW and east of Wesley Street. Implementation
of this design option would displace a sound studio and auto body shop located
off of Wesley Street.
North of ROW Design Option C – This design option proposes an at-grade
station located north of the ROW on the parcels occupied by an auto-body shop
and two vacant lots on the east side of Wesley Street.
Phased Implementation Option (Crenshaw, Vermont or La Cienega)
Both the 2001 LPA and the recommended revised LPA include possible phased
implementation segments. These optional project lengths were evaluated in the
event that there is insufficient funding to build the full project to Venice/
Robertson station in Culver City. Possible phased segments would stop at
Vermont Station, Crenshaw Station or La Cienega Station.
According to the Final EIR, construction of the proposed project can be
accomplished in approximately 36 months (3 years). The anticipated year of
completion is 2010. In April 2005, the Metro Board of Directors adopted a project
budget of $640 million for the Exposition Transit Corridor. The funding plan consists
of various Federal (38%), State (2%) and Local (60%) funds committed to the
proposed project.
The Final EIR indicates that the option that would locate an interim, at-grade station
east of the Washington/National Blvd. intersection on the Metro ROW near Wesley
Street would be the only option that is affordable within the approved budget of $640
million. Any other options, including an Aerial station, would require additional
funding beyond the currently approved project budget. For this reason, the Metro
staff recommended revised LPA includes the on the ROW east of National
Boulevard interim station as the recommended design option for the
Venice/Robertson Station. Further, the revised LPA (on the ROW option) is also
recommended by Metro staff because the FTA requires a LPA to have an adopted
funding plan that is financially feasible.
The approved funding does include a contingency amount of $71.7 million. It is
unknown at this time the precise formula Metro used to allocate the amount for
contingency and what restrictions are placed on these funds by Metro. Metro staff City of Culver City, California
City Council Agenda Item Report
has indicated in the recent past however, that the contingency funds may not be
committed for construction of the aerial design option since they must be reserved
for potential cost overruns, unknown conditions that may be encountered during
construction, or construction bids higher than originally anticipated. Metro staff may
be able to further clarify this issue during tonight’s meeting.
Adequacy of the Final EIR
A City staff team, consisting of Community Development, Public Works,
Transportation, Fire, Police, City Attorney Departments and consultants evaluated
and prepared comments on the adequacy of the Final EIR for the Council’s
consideration. Staff’s detailed comments are shown in “Exhibit A” of City Resolution
No. 2005-R___ (Attachment 2) and “Exhibit A” of Agency Resolution No. 2005-
RA___ (Attachment 3).
The following is a summary of the major issues and concerns with the Final EIR:
Parking and Pedestrian Circulation
Based on the parking layout for the Venice/Robertson Design Options, except
the Aerial station option, there is insufficient parking located in close proximity to
the Venice/Robertson LRT station options located south of Washington Blvd.
Additional parking options located closer to the LRT station need to be
developed. Additionally, the Final EIR lacks specificity in discussing how
spillover/intrusion impacts will be physically mitigated, funded, implemented and
maintained.
The Final EIR indicates that the distance between Venice/Robertson station and
the proposed parking area north of Venice Boulevard would require a shuttle
system. However, no details were provided in regard to the proposed shuttle
system. For people who choose to walk to the LRT station (east of
Washington/National intersection) from the proposed parking area north of
Venice Blvd, it will take approximately 10 minutes since the parking lot is outside
of the ¼ mile-radius station influence area. Staff is concerned that not having
convenient access from the parking lot to the LRT station will work against the
use of the LRT station because it might be an easier choice for riders to drive
instead of using the LRT given the length of time it will take to get to the LRT
station from the parking lot.
On November 10, 2005, staff received from Metro staff preliminary
Venice/Robertson Parking Alternatives (Attachment 5) showing two parking
options in lieu of the proposed off-street Transit Center. These two options
provide additional parking nearer to the interim east of Washington/NationalCity of Culver City, California
City Council Agenda Item Report
Culver City station. Option 1 maximizes the use of the two Metro ROW parcels
south of Venice Blvd, providing a total of 430 spaces. Option 2 allows for a
center “pedestrian promenade” to increase connectivity with parking north of
Venice Blvd. and provides a total of 380 spaces.
Finally, staff recommends that the pedestrian crossing over the LRT track at
Wesley Street be eliminated in favor of a pedestrian path that will take residents
around the west end of the station and connect to the proposed pedestrian/bike
path north of the station at Wesley.
With the above change, there will be no pedestrian crossing within Culver City
that necessitates the need for audible warning devices. Page 53 of the Final EIR
Executive Summary states; “in Culver City, crossings are eliminated from Ballona
Creek to Wesley Street and there will be no audible warning devices located in
front of residential areas between these points.”
Traffic
A major concern is that the Final EIR does not take into account the potential
traffic impacts caused by the surge of pedestrians leaving or arriving at the LRT
station. Heavy pedestrian movements across the Venice/Robertson and
Washington/National intersections will potentially have significant impacts on
signal timing at these intersections. Additionally, as stated above under parking
issues, the Final EIR lacks specificity in discussing how spillover/intrusion
impacts will be physically mitigated, funded, Implemented and maintained.
Transit
Metro proposes both on-street and off-street transit centers that would allow for
the transfer of passengers between transportation modes, facilitate circulation
flow for buses, and organize passenger movements. The off-street transit center
is located on the ROW between Venice and Washington Boulevards. On-street
transit centers are located on the north side and south side of Venice and
Washington Boulevards near the right of way. With the assumption that bus
operators would modify their services to provide north-south connections to and
from LRT stations, the Final EIR anticipates 11 bus lines to serve
Venice/Robertson Station. Metro 733, Metro 434, LADOT 430/431, and Santa
Monica Big Blue Bus Super 12 are anticipated to use the off-street transit center,
while Metro 33 and 220, Santa Monica Big Blue Bus 10 and 12, and Culver
CityBus Lines 1, 4, and 5 are anticipated to use on-street transit centers. While
the Final EIR anticipates Culver CityBus Lines 4 and 5 to connect to the
Venice/Robertson station, Line 5 in fact does not serve the station area, and line City of Culver City, California
City Council Agenda Item Report
4 is currently pending City Council approval on service route change and
therefore may not serve the station area in the future.
Due to the geometry and street configuration of the proposed station areas (all
options), existing heavy traffic in the station vicinity, and the proximity of transit
center entrances and exits to intersections, bus activities associated with an off-
street transit center will only exacerbate the traffic situation in the station vicinity.
Furthermore, the proposed parking lots that are within reasonable walking
distance of the recommended revised LPA (ROW option) only contain 110
parking spaces, which is significantly lower than year 2010’s demand of 600
spaces. It is therefore recommended that off-street transit center be replaced by
on-street transit centers on Washington and Venice Boulevards and that the
proposed space for the off-street transit center is used to create more parking
spaces that provide more park-and-ride transit users better access to the interim
station.
Noise and Vibration
The Final EIR states that 14 single family residences along the right-of-way
between Fay and Helms Avenues would be impacted to some degree by noise.
However, the actual residences are not identified in the Final EIR. Landscape
berms adjacent to the trackway and soundwalls along the northern boundary of
the right-of-way are proposed as mitigation measures.
The estimated noise barrier heights identified as mitigation measures are low for
both the at-grade and aerial barriers and additionally there are no calculations
provided for the proposed sound wall’s acoustical performance and acoustically
absorptive sound walls are not discussed.
According to the Final EIR significant ground-borne noise and vibration impacts
may only impact a recording studio adjacent to the station locations proposed
under the Venice/Robertson Design Options. Mitigation for this potential impact
would be identified based on a site-specific noise impact assessment which
would include vibration impacts.
To help augment the mitigations listed in the Final EIR, staff is recommending
that National Blvd. be reconstructed/resurfaced with “Quiet Pavement” which is a
Rubberized Asphalt Concrete pavement surface. This would result in an overall
reduction of 4 to 10 decibels from roadway noise which would help offset the
additional noise from the LRT. City of Culver City, California
City Council Agenda Item Report
Construction Impacts
Metro indicates they will abide by local construction noise activity regulations but
acknowledge there may be times when nighttime construction will be necessary.
In such a case, they will seek a permit from the local agency for a waiver from
the local noise regulations. Nighttime construction at the La Cienega station may
cause noise impacts to Culver City residential areas. Culver City staff and the
East Culver City and Rancho Higuera Neighborhood representatives should be
advised of anticipated nighttime construction periods and provided with a Metro
liaison contact or ombudsman. Additionally, contractor parking within Culver City
must be reviewed and approved by Culver City staff to ensure minimal impact to
Culver City residents.
Land Use
The primary concern in regards to land use is that the Final EIR does not
acknowledge the Culver City Redevelopment Agency’s authority and jurisdiction
over the proposed project and does not acknowledge the land use plans which
apply to the proposed project.
Under the California Community Redevelopment Law, the proposed Exposition
Light Rail Transit project is proposed to be constructed within a Redevelopment
Component Area that was adopted through the authority of State law. The
Redevelopment Plan for Culver City provides direction for this area and states
very clearly that both public and private developers must conform to the
Redevelopment Plan and any Design for Development. Further, after extensive
public comment and input, the Agency adopted a Design for Development for the
Exposition Light Rail Transit area, which prohibits at-grade crossings.
The Agency, as a State agency empowered under the California Community
Redevelopment Law, has concurrent jurisdiction over the area impacted by the
Project within the Culver City Redevelopment Project Area, along with Metro and
the Public Utilities Commission (“PUC”) (Refer to “Exhibit A”, Page 28 of the
proposed Agency Resolution for a detailed discussion on the court case which
provides the basis of the Agency’s Authority).
Therefore, Metro cannot ignore the Redevelopment Plan and Design for
Development, both of which incorporate the City’s General Plan policies for this
Project. Most importantly, the Design for Development prohibits at-grade
crossings. Metro must address how it will comply with these regulations, and
analyze the inconsistencies between the Project and the potential significant
environmental effects that occur as a result of these inconsistencies. City of Culver City, California
City Council Agenda Item Report
Metro Board of Directors should not certify the Final EIR as to the 2001 Locally
Preferred Alternative (at grade crossing and at grade station at
Venice/Robertson), and must take formal action to eliminate that alternative from
further consideration.
Ridership
The Final EIR indicates that the forecast for average weekday boardings for the
full Mid-City/Exposition LRT Project from Downtown Los Angeles to
Venice/Robertson Station is estimated to be 42,900 boardings per day by the
year 2025. This number is slightly less than the ridership forecast of 43,600 daily
fixed guideway boardings for the year 2020. No explanation is given as to why
the projected ridership is expected to drop from the year 2020 to year 2025.
CONCLUSION
Culver City appreciates and is pleased that the “at grade” Venice Robertson station
is no longer recommended by Metro staff as the locally preferred alternative.
However, staff recommends the Council and Agency formally request that the Metro
Board of Directors not certify the Final EIR as to the 2001 Locally Preferred
Alternative (at grade crossing and at grade station at Venice/Robertson), and to
formally take action to eliminate that alternative from further consideration.
Further, staff recommends (in addition to the comments set forth in the Resolutions)
the Council and Agency also formally request that Metro Board of Directors
expressly certify the Final EIR to include the Aerial Design Option. This will allow for
flexibility to work on the Aerial Design Options as the “design/build” project moves
forward and, without the need to go through another EIR process.
Finally, in the event any of the four proposed options that feature at-grade stations
located on the east side of the Washington and National Boulevard intersection are
included in the Final EIR to be certified, staff recommends (in addition to the
comments set forth in the Resolutions) the Council and Agency formally request that
Metro Board of Directors certify the Final EIR as to the Right-of-Way Design option.
Separate resolutions have been prepared for consideration and adoption by the City
Council and the Redevelopment Agency. This is appropriate because the Agency is
a separate entity from the City. Furthermore, since the Agency is empowered by the
State of California, it is a Responsible Agency under CEQA. Responsible Agency(s)
are those entities having review and approval power over all or part of a project. City of Culver City, California
City Council Agenda Item Report
The Agency has concurrent jurisdiction over the portion of the project that lies within
the Culver City Redevelopment Project Area and therefore it is presumed that the
project would require approval from the Agency prior to commencement of
construction. This approval could take the form of a cooperative agreement or
memorandum of understanding.
FISCAL ANALYSIS:
The Final EIR is not specific enough to estimate the potential fiscal impacts to the
City from the Project. However, unmitigated and significant impacts from the
Exposition Light Rail Transit Project could result in significant costs to the City and
its residents in the future. The types of fiscal impacts that the City may expect if the
Exposition Light Rail project is implemented include but are not limited to: increased
street infrastructure maintenance, the need for additional transit services, and
increased demand for emergency facilities and personnel due to increased
congestion.
ATTACHMENTS:
1. Summary Evaluation of Station Alignments Matrix and Figures.
2. Resolution No. 2005-R____, including Exhibit “A” containing detailed comments
on the 2005 Final EIR.
3. Resolution No. 2005-RA____, including Exhibit “A” containing detailed comments
on the 2005 Final EIR.
4. Summary List of Comments and Questions from the October 24, 2005 Council
and Agency Meeting.
5. Venice/Robertson Station Parking Alternatives.
MOTION:
That the City Council and Redevelopment Agency:
Approve Resolution No. 2005-R____and Resolution No. 2005-R__ , Transmitting
the Official City and Agency Response to the 2005 Final Environmental Impact
Report for the Proposed Mid-City/Exposition Light Rail Transit Project.City of Culver City, California
City Council Agenda Item Report
Subject to the comments set forth in the Resolutions:
Formally request that the Metro Board of Directors do not certify the Final EIR as to
the 2001 Locally Preferred Alternative (at grade crossing and at grade station at
Venice/Robertson), and to formally take action to eliminate that alternative from
further consideration; and
Formally request that Metro Board of Directors expressly certify the Final EIR to
include the Aerial Design Option; and
Formally request that in the event any of the four proposed options that feature at-
grade stations located on the east side of the Washington and National Boulevard
intersection are included in the Final EIR to be certified, Metro Board expressly
certify the Final EIR to include the Right-of-Way (ROW) Design Option.
11/21/2005
A Joint Item Consideration of Resolutions Transmitting the
Official City and Agency Response to the 2005 Final
Environmental Impact Report /Statement for the Proposed Metro
Mid-City/Exposition Light Rail Transit Project
MEETING DATE
AGENDA ITEM
ATTACHMENTS
Pages
1 Summary Evaluation of Station Alignments Matrix and Figures 1-8
2 Resolution No 2005-R , including Exhibit "A"
containing detailed comments on the 2005 Final EIR 9-38
3 Resolution No 2005 RA, Including Exhibit "A" 39-71
containing detailed comments on the 2005 Final EIR
4 Summary List of Comments of October 24, 2005, City Council 72-74
Redevelopment Agency Meeting
5 Venice/Robertson Station Parking Alternatives 75Exposition Light Rail - Evaluation of Station Alignment Options/Scenario
Issues
Aerial Design Option
(Figure 1)
Metro s 2001 Locally
Preferred Alternative —
Venice/Robertson Station
(Figure 2)
Right of Way Option
(Figure 3)
North of Right of Way
Option A (Figure 4)
North of Right of Way
Option B (Figure 5)
North of Right of Way
Option C (Figure 6)
_
Stopping at La Cienega
Scenario' (Figure 7)
Description
Culver City s preferred option
At-grade station located at
Right of Way between
Washington and Venice
Boulevards
Note This option is no longer
Metro staffs recommended
At grade station alignment that
extends from nght of way to the
intersection of Washington and
National Boulevards Adjacent
to National Boulevard
At-grade station similar to Right
of Way Option but slightly north
of the nght of way alignment
At grade station north of right of
way and east of Wesley Street
Station located at La Cienega
and Jefferson Boulevards
option.
At-grade station located on the
Metro owned right of way Stop
is immediately west of Wesley
Street
Elevated station located
between Washington and
Venice Boulevards
Metro s recommended option in
the FEIR It violates terms of
Agency/City adopted
Washington National Transit
Area DFD, which prohibits at
grade crossings by fixed rail
transit
Associated Costs
More expensive
• Extra cost of constructing
an elevated station and
approach slope
• No land acquisition
required
Expensive
• Acquisition of
approximately 9826 square
feet of land 2 required
Least expensive option
• No land acquisibon
required
• Possibility of acquiring one
parcel of land to house
station related facilities3
Very expensive
• Acquisition of 4 parcels
(77 185 square feet) of land
required including Spartan
Lumber
Somewhat expensive
• Acquisition of 2 parcels
(28 554 square feet) of land
required
Expensive
• Acquisition of 3 parcels
(37 369 square feet) of land
required
Diminished economic potential
to Culver City businesses TOD
and properties near proposed
Venice/Robertson station area
Pedestrian Access
Best option most direct and
efficient access
Same as Aenal Design Option
Direct access from east
lengthened pedestrian travel
from west and north and
adequate access from south
Surface pedestnan crossing4
incorporates the use of horns
and crossing gate bells that add
to overall noise level
Limited access from east good
access from west south and
north
Surface pedestrian crossing
incorporates the use of horns
and crossing gate bells that add
to overall noise level
Limited access from east
lengthened access from west
and north and adequate
access from south
No pedestnan crossing
designated on the plan
Limited access from east
lengthened pedestrian travel
route from west south and
north
No pedestrian crossing
designated on the plan
Eliminate the LRT as a barrier
between the neighborhoods
north and south of the Right of
Way
Access to bus stops Best5 Same as Aerial Design Option Poor° Fair' Poor6 Poor9 Fair"
Access to parking Best11 Same as Aenal Design Option Poor12 Fair13
pooria
Poor15 Good"
Station Related
Traffic Impact
Minimal impact
At grade crossing on
Washington and National
Boulevards would significantly
hamper traffic operations at the
intersection of these streets
Potential for impact on National
Boulevard Washington
Boulevard and
Washington/Wesley intersection
due to station related activities
Potential for impacts on
Washington/National
intersection and National
Boulevard due to station related
activities
Potential for impact on National
Boulevard Washington
Boulevard and
Washington/Wesley intersection
due to station related activities
Potential for impact on National
Boulevard Washington
Boulevard and
Washington/Wesley intersection
due to station related activities
Minimal impacts 17 to City
This scenario is part of the phased implementation
2
As indicated in FEIR (4 2 10) approximately 2926 square feet on the southeast corner and approximately 6 900 square feet on the northwest corner of Washington/National intersection need to be acquired for the widening of National Boulevard to accommodate the at grade crossing
3 Such as Clean Mobility Center and parking
FEIR indicates that there will be no surface pedestrian crossing m the segment of Exposition LRT within Culver City
s Station location is within easy access to bus stops on Washington and Venice Boulevards
6 There is no bus line serving National Boulevard Bus nders will need to walk long distance to reach the bus stops at Washington/National intersection and even longer to reach the bus stops on Venice Boulevard
Station location is close to bus stops on Washington Boulevard but far from bus stops on Venice Boulevard.
s
There is no bus line serving National Boulevard. Bus nders will need to walk longer distance to reach the bus stops at Washington/National intersection and even longer to reach the bus stops on Venice Boulevard
Bus nders will need to walk long distance to reach the bus stops at Washington/National intersection and even longer to reach the bus stops on Venice Boulevard
w Station is located close to bus stops on La Cienega Boulevard
" In addition to 68 parking spaces within station site the station location is close to 735 surface parking spaces in the Right of Way north of Venice Boulevard and 42 spaces m the Right of Way east of Washington Boulevard
Station location is far from major parking (735 parking spaces) location north of Venice Boulevard
13 Station location is somewhat closer to major parking (735 parking spaces) location north of Venice Boulevard
i4
location is far from major parking (735 parking spaces) location north of Venice Boulevard
" Station location is far from major parking (735 parking spaces) location north of Venice Boulevard
16 Parking structure is adjacent to the station
17 Vehicles driving to station location would only be cutting through the City and not circulating around searching for parking
Attachment No 1Bike path
Bike path stops at Wesley
Street but may be extended up
Wesley Street to connect to
Washington Boulevard and light
rail station16
Same as Aenal Design Option
Bike path stops at Wesley
Street but may be extended up
Wesley Streett6 to connect to
Washington Boulevard
Bike path stops at Wesley
Street but may be extended up
Wesley Street to connect to
Washington Boulevard
Bike path stops at Helms
Avenue but may be extended
up Helms Avenue to connect to
Washington Boulevard
Bike path stops at Helms
Avenue but may be extended
up Helms Avenue26 to connect
to Washington Boulevard
Bike path along Jefferson
Boulevard and Exposition Right
of Way between La
Cienega/Jefferson and
Washington/National
intersection will be eliminated
Noise! vibration
Impact created by proximity of
station location to residential
neighborhood Negligible
Impact created by the proximity
of train crossover to residential
neighborhood
• No impact if the train
crossover is located on
elevated structure21
• High impact if the train
crossover is located at
grade before the approach
slope22
Less vibration due to greater
distance from source to
receiver
Impact created by proximity of
station location to residential
neighborhood Negligible
Impact created by the proximity
of train crossover to residential
neighborhood Minima123
Impact created by proximity of
station location to residential
neighborhood 2 nd most
Impact created by the proximity
of train crossover to residential
neighborhood 3 r6 most24
Impact created by proximity of
station location to residential
neighborhood 3rd most
Impact created by the proximity
of train crossover to residential
neighborhood 3rd most25
Impact created by proximity of
station location to residential
neighborhood Most
Impact created by the proximity
of train crossover to residential
neighborhood M0st26
Impact created by proximity of
station location to residential
neighborhood Most
Impact created by the proximity
of train crossover to residential
neighborhood 2 rid most27
Higher noise level due to tighter
turning curve
No impact on residential
neighborhood
Security
Highest visibility28 contnbutes
positively to the security of the
station area
Very high visibility26 contnbutes
positively to the secunty of the
station area
High visibilitym contributes
positively to the secunty of the
station area
Very high visibility31 contnbutes
positively to the secunty of the
station area
High visibility32 contributes
positively to the security of the
station area
Lower visibility33 contnbutes
negatively to the security of
station area
No issues
Station area
potentials
Transit Center Clean Mobility
Center and parking
Connection to proposed
adjacent TOD with urban plaza
and businesses
Transit Center Clean Mobility
Center and parking
By acquinng one parcel of land
there is potential to develop a
small urban plaza with a Clean
Mobility Center and some
parking
Potential to develop a large
urban plaza with subterranean
parking Clean Mobility Center
and shops
Potential to develop a small
urban plaza with Clean Mobility
Center facility
Potential to develop a large
urban plaza with subterranean
parking Clean Mobility Center
and shops
Scenario will not be
incorporated into any Culver
City developments fewer
modal choices for City
residents employee and
visitors to City
18 From Washington/National intersection the bike path continues along the street north of the station to connect to existing bike path on Venice Boulevard
Depending on future developments bike path may also be designated on National Boulevard from transit station to Washington/National intersection
29 Depending on station alignment adjustment, the bike path may be extended along light rail line and to Wesley Street
21 The tram crossover will be away from residential neighborhood
22 The train crossover will be adjacent to residential neighborhood
22 It is assumed that the train crossover will be located near the Washington/National intersection
24 Tram crossover is located at the western extent of residential neighborhood
25 Train crossover is located at the western extent of residential neighborhood
26 Tram crossover is located west of Caroline Avenue and adjacent to the most residential properties
27 Tram crossover is located immediately east of Helms Avenue
28 The station is visible from Washington Boulevard and Venice/Robertson intersection
29 The station is visible from Washington Boulevard and Venice/Robertson intersection
39 The station is visible from National Boulevard
2' The station is visible from Washington Boulevard and National Boulevard
32 The station is visible from National Boulevard
33 The station is partially visible from National BoulevardL
Figure 1 Aerial Design Option
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Figure 7 Stopping at La Cienega ScenarioRESOLUTION NO 2005-
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF
CULVER CITY, TRANSMITTING THE OFFICIAL CITY
COMMENTS ON THE OCTOBER 2005 PROPOSED FINAL
ENVIRONMENTAL IMPACT STATEMENT/ENVIRONMENTAL
IMPACT REPORT FOR THE PROPOSED METRO MID-CITY
EXPOSITION LIGHT-RAIL TRANSIT PROJECT
WHEREAS, in October 2005 the Los Angeles Metropolitan Transportation
Authority (Metro) released the Final EIS/EIR for the Los Angeles Mid-City Westside Transit
Corridor and Mid-City Exposition Light Rail Transit Project (the Final EIS/EIR ), and
WHEREAS, the City of Culver City (the City' ) has reviewed and considered
the Final EIS/EIR and provided the opportunity for interested parties to offer comments at a
public meeting on November 21, 2005, and
WHEREAS the City is a Responsible Agency for this project as defined by
the California Environmental Quality Act and
WHEREAS, portions of the Exposition Light Rail Project are located within,
and would have significant impacts on, the City of Culver City, and
WHEREAS the City has identified portions of the Final EIS/EIR where
corrections or additional information is needed to provide affected agencies and the public
with sufficient information upon which to fairly evaluate the environmental consequences of
the project These specific issues are identified in Exhibit A attached hereto
NOW, THEREFORE, the City Council of the City of Culver City DOES
HEREBY RESOLVE as follows
Attachment
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(pm)1 This Resolution, including attached Exhibit A, constitutes the City s
official comments on the Final EIS/EIR that was prepared for the proposed Mid-City
Exposition Light Rail Transit Project|109| Staff is directed to transmit this Resolution to the Los Angeles County
Metropolitan Transportation Authority for consideration by the Metro Board
APPROVED and ADOPTED this 21st day of November 2005
ALBERT VERA, MAYOR
City of Culver City California
ATTEST APPROVED AS TO FORM
CHRISTOPHER ARMENTA, City Clerk CAROL A SCHWAB City Attorney
P
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(jam)Exhibit A
CULVER CITY RESOLUTION NO 2005-
FINAL EIR/EIS (the "FEIR") COMMENTS
MID-CITY/EXPOSITION LIGHT RAIL TRANSIT PROJECT
November 21, 2005
General Comments
1 Revised LPA (Executive Summary Table S-2 Capital Cost Estimate for
Mid-City/Exposition LRT Page 39) The last column shows costs for the
Revised LPA (Metro Staff Recommendation) This revised LPA is
described in Note b in the Table The Revised LPA should be more fully
described and illustrated perhaps with a complete separate section This
is particularly important to Culver City as the Revised LPA incorporates a
Venice/Robertson station design option that is proposed to address
concerns expressed by Culver City with at grade crossings of National
Boulevard and Washington Boulevard An illustration or series of
illustrations depicting the Revised LPA are necessary
2 Venice/Robertson Interim Station Design Options (Page 55) The third
paragraph identifies the north of right of way options and the "On ROW"
Design Option This option is elsewhere identified as the only option that
would be affordable within the approved project budget and the option
incorporated into the Revised LPA This description should include such
references
3 Elevated Venice/Robertson Station Option Design and construction of a
truncated version of the elevated Venice/Robertson station to terminate south
of Washington Blvd with an elevated crossover over National Blvd yields
benefits on the following issues
a Does not require right-of-way acquisition
b Allows for full redevelopment of existing private property
c Provides for bike path to extend past Wesley crossing under the
elevated track crossing National Blvd at the signalized intersection at
Wesley and proceed along National Blvd on existing sidewalk to station
and the Venice Blvd bike lane
d Eliminates need to provide for a gated pedestnan crossing of the LRT
tracks
ItExhibit A
Culver City Resolution No 2005- November 21, 2005
e May provide for selected dedicated parking below and adjacent to the
elevated rail north of Wesley
f Eliminates one pedestrian roadway crossing from proposed parking lot
on Metro right-of-way north of Washington Blvd , present location of The
Jungle nursery
g Will provide a site for the CMC and possibly the electrical control building
under the raised platform/station
h Self advertises therefore less roadside directional signage needed
1 Noise generated by the station activity and the adjacent crossover track
will be at a further distance from residences
j Pg 4 17-8 states the aerial station may be considered
environmentally superior to the ROW option|109| Page 2 4 — 31 There is a Control Office Building at the Venice/ Robertson
Station (see Appendix A, Sheet A-402) The facility is dedicated to
regulate/control/monitor power to the LRT system In addition there is a
Traction Power Substation (Page 4 15-7, and Appendix A, Sheet A-404)
proposed on the portion of the LRT right-of-way, located between
Washington and National Boulevards None of the Venice/Robertson Design
Options ever discuss where these two facilities would be placed or how they
will be designed and situated so as to not generate any adverse impacts
5 Page 2 4-43 Figure 2 4-30 Venice/Robertson Station Area This Figure
indicates that a left-turn is proposed from the southerly end of the Bus Drop-
Off/Layover' to eastbound Washington Boulevard According to the plans for
the Station in the Executive Summary, Pages 68 and 69 only a right-turn
would be allowed The right-turn only movement is supported by Drawing A-
404 in Attachment A While this issue is related to the LPA which Metro
Staff is proposing to be revised, it should be noted that the City of Culver City
would not allow such a left-turn movement from any future Transit Center and
potentially any parking lot, due to limited queuing space from the
Washington/National intersection
Air Quality Issues|1010| We would note that transit is generally considered an air quality positive
strategy in a regional sense Any impacts are therefore either local near a
particular transit node, or short-term during construction The
environmental analysis concluded that carbon monoxide, as an indicator
of any local hot spot" potential, was less-than-significant Based upon the
Page 2 of 27Exhibit A
Culver City Resolution No 2005- November 21 2005
continued improvement of the regional vehicle fleet we would concur with
that assessment
Since the Draft EIR/EIS was released in 2001, there is a substantial gap
between the preparation of the DEIR/DEIS and the final documents A
limited amount of updating is included in the FEIR/FEIS, but even these
updates stop around 2003 There are several new air quality initiatives or
programs that have been promulgated in the last few years
Those technical issues that are not adequately addressed in the final
environmental documents (because of the passage of time or an initial de-
emphasis) include the following
a The analysis provides no meaningful analysis of air toms issues
associated with idling buses at transit centers or of delayed surface
trucks along priority bus or LRT corridors
b The analysis does not include any information on the air quality setting
since 2002 The basin has experienced some back-sliding in the last
few years that are a major concern in long-term ozone attainment
strategies
c The analysis does not include the concept of local significance
thresholds developed by the SCAQMD which are generally more
stringent than the regional significance thresholds from the 1993
SCAQMD CEQA Air Quality Handbook
d The FEIR/FEIS contains no reference to recently adopted California 8-
hour ozone air quality standard that is more stringent than the federal
standard
Land Use Issues|109| Culver City Redevelopment Agency Redevelopment Plan and DFD (Page
4 1-10) This section makes no reference to the 'DESIGN FOR
DEVELOPMENT FOR EXPOSITION LIGHT RAIL TRANSIT AND
STATION AREA (the DFD) approved by the Culver City Redevelopment
Agency on oJune 6, 2005 The DFD states in part, the following
Consistent with the purposes of this DFD and pursuant to the
authority of the Agency under Section 422 of the
Redevelopment Plan for the Culver City Redevelopment Project
(Component Area 3) and Section 363 of Component Area 4, the
Agency hereby establishes the following controls and
restrictions for development of the Exposition Light Rail Transit
Page 3 of 27
13Exhibit A
Culver City Resolution No 2005- November 21, 2005
continued improvement of the regional vehicle fleet, we would concur with
that assessment
Since the Draft EIR/EIS was released in 2001 there is a substantial gap
between the preparation of the DEIR/DEIS and the final documents A
limited amount of updating is included in the FEIR/FEIS, but even these
updates stop around 2003 There are several new air quality initiatives or
programs that have been promulgated in the last few years
Those technical issues that are not adequately addressed in the final
environmental documents (because of the passage of time or an initial de-
emphasis) include the following
a The analysis provides no meaningful analysis of air toms issues
associated with idling buses at transit centers or of delayed surface
trucks along priority bus or LRT corridors
b The analysis does not include any information on the air quality setting
since 2002 The basin has experienced some back-sliding in the last
few years that are a major concern in long-term ozone attainment
strategies
c The analysis does not include the concept of local significance
thresholds developed by the SCAQMD which are generally more
stringent than the regional significance thresholds from the 1993
SCAQMD CEQA Air Quality Handbook
d The FEIR/FEIS contains no reference to recently adopted California 8-
hour ozone air quality standard that is more stringent than the federal
standard
Land Use Issues|109| Culver City Redevelopment Agency Redevelopment Plan and DFD (Page
4 1-10) This section makes no reference to the DESIGN FOR
DEVELOPMENT FOR EXPOSITION LIGHT RAIL TRANSIT AND
STATION AREA (the DFD) approved by the Culver City Redevelopment
Agency on oJune 6, 2005 The DFD states in part, the following
Consistent with the purposes of this DFD and pursuant to the
authority of the Agency under Section 422 of the
Redevelopment Plan for the Culver City Redevelopment Project
(Component Area 3) and Section 363 of Component Area 4, the
Agency hereby establishes the following controls and
restnctions for development of the Exposition Light Rail Transit
Page 3 of 27Exhibit A
Culver City Resolution No 2005- November 21 2005
and Station Area DFD which are in addition to applicable
General Plan requirements and guidelines, Zoning, Building
Codes and other requirements of the Culver City Municipal
Code (CCMC)
2 Venice/Robertson Desiqn Options (Page 4 1-18 to 4 1-19) This
discussion should reference the DESIGN FOR DEVELOPMENT FOR
EXPOSITION LIGHT RAIL TRANSIT AND STATION AREA (the DFD)
approved by the Culver City Redevelopment Agency on June 6, 2005
The design options that are incorporated into the LPA and the Revised
LPA, respectively, should be identified
3 CEQA Determination (Page 4 1 -19 to 4 1-20) This analysis of applicable
land use policies does not include reference to the 'DESIGN FOR
DEVELOPMENT FOR EXPOSITION LIGHT RAIL TRANSIT AND
STATION AREA (the DFD) approved by the Culver City Redevelopment
Agency on June 6, 2005 This section also does not include discussion of
the "Revised LPA and associated impacts|109| Land Acquisition (4 2 2 1 Acquisition of Property, Table 4 2-2, Page 4 2-5
and Page 4 2-30) This paragraph references land acquisition
requirements for the LPA and for the three North of ROW Options It also
mentions that ROW and Aerial Station options would not require the
acquisition of properties However, on Table 4 2-2 Page 4 2-5, under the
West End section, it shows partial (P) takings listed for the Aerial and in
ROW options Which is correct'?
5 Financial Analysis (Venice/Robertson Station Design Options, Page 5 1-
6) The Metro Staff recommended Revised LPA incorporates the station
location option east of National Boulevard on the Metro right of way near
Wesley Street which is identified as the only option that would be
affordable within the approved project budget Please indicate whether
the certification of this EIS/EIR will encompass the Revised LPA7|109| Response to Comments (Page 7-131 to 7-133) Several paragraphs on
these pages discuss the Culver City General Plan and land
use/transportation policies Not addressed in this discussion is the
DESIGN FOR DEVELOPMENT FOR EXPOSITION LIGHT RAIL
TRANSIT AND STATION AREA (the DFD) approved by the Culver City
Redevelopment Agency on June 6, 2005
Public Safety Issues|109| These comments are common to both possible locations, Venice /
Robertson and the interim termination at Wesley Street The Expo Rail
Page 4 of 27
f 5-Exhibit A
Culver City Resolution No 2005- November 21 2005
Project will cause an overall increase in calls for police and fire service,
including
a An increase in criminal activity will occur in Culver City Adjacent
parking areas will see an increase in auto theft, auto burglaries, and
thefts from autos Increased pedestrians coming to and from the
location will increase the amount of violent crime, including robbery,
assaults, purse-snatches, etc If parking areas for the route are
within our jurisdiction, the reportable crime and the police
department s workload would likely increase
b Pedestrian and vehicle safety should be the highest priority
Elevating the railway will reduce the incidence of vehicle &
pedestrian collisions with the train
c Trains are a major terrorism target The police department will be
responsible for safety and criminal activity within the City limits
The City will have to take proactive steps whenever terror alerts are
given, Culver City Police does not have the personnel to handle this
at our present capacity
d The police department is responsible for the safety of all persons
within the City not just residents The police department estimates
that on any given day 325,000 persons are within our jurisdiction,
not the 39,119 as indicated on page 4 12-3 This is our policing
population which will likely increase
e The department will have to increase their personnel capacity to
accommodate the needs of this project, including stationary
security posts at the station s end and while citizens come and go
to the station
f Several public and private schools will be impacted in the project
Not mentioned in the report are Culver City High School Farragut
Elementary School Linwood Howe Elementary School, Willows
Community School, Hamilton High School Turning Point School
and Echo Horizon School In addition there are two new schools
currently entitled and/or in the process of entitlement (New Century
School off of Landmark and the proposed Expansion of Turning
Point School off of National and Landmark)
g
Regardless of which location is chosen, adequate parking will be an
issue By definition, this will be the western terminus of the rail
project, thus drawing riders from the entire west side Inadequate
parking will impact adjacent residential neighborhoods and traffic
Page 5 of 27
t L9Exhibit A
Culver City Resolution No 2005- November 21, 2005
congestion will increase Increased traffic will cause a
corresponding increase in calls for service, including injury traffic
collisions|109| Should the route terminate at Venice / Robertson, with planned parking
north of Venice in the City of Los Angeles
a An elevated train can be designed to minimize the affect of crossing
Washington and reduce the incidences of vehicle-pedestrian/train
collisions
b If parking is planned north of Venice, the reportable crime will be
the responsibility of the City of Los Angeles
c Pedestrians hurrying to catch a train across Venice are a safety
issue
d Some incidents will become Culver City Police responsibility, as
determined by jurisdictional boundaries
e At grade crossing will have a major impact on police and fire
response times on Washington Blvd & National which are major
arteries through Culver City
f A concurrent project is in the planning for redirecting Washington
Blvd at Culver, via Ince This is a couple of blocks west of the
planned route Adding a ground level crossing will promote gridlock
during train crossings, with no immediate alternate routes Police
and fire vehicles could become trapped' during a crossing
delaying or preventing an adequate response to routine and
emergency calls
g
The area is a mix of industrial and residential Truck deliveries will
be impacted The potential of trucks carrying hazardous materials
becoming involved in collisions will increase This area has the
designated truck routes of Venice and National that feed the
affected area In the past decade, the area has been expanding
and changing from industrial and manufacturing to corporate
offices design centers and business|109| Should the route terminate at Wesley
a Parking north of Venice will accommodate the needed spaces,
however, the riders will traverse over one-quarter mile to catch the
Page 6 of 27
I g-Exhibit A
Culver City Resolution No 2005- November 21, 2005
train The safety of these riders would then shift to our
responsibility, dramatically increasing our workload
b
Mitigation measures such as high fences will deny access to
McManus Park from the south side of the route
Transit Issues
1 Page 3 1 —3 though Pg 3 1 —9 There is a potential for a large congregation
of transit buses to arnve on-site because of the Venice/Robertson station
being a proposed Transit Center There is no discussion of where the buses
will stop if multiple arrivals overlap and over flow issues anse Will there be
sufficient queuing area along Venice Boulevard, out of the traffic lanes, to
accommodate buses waiting to access the Center, See Figure 2 4 — 15 Bus
Feeder Network|109| Page 2 4-15 Last Paragraph It is noted here that there is a railroad spur
located in the Hayden Tract and that Metro would maintain and plan the
parcels within the Hayden Tract Spur for local transportation use" There is
no information provided to explain what is implied by 'local transportation
use
3 Executive Summary (p 68) The station area plan indicates that buses
enter from Venice Boulevard and can only exit onto Washington
Boulevard by turning right (westbound) This is inconsistent with the
station area plan shown on Figure 2 4-30 on p 2 4-43
4 Locally Preferred Alternative (Figure 24-15 on p 24-8) The figure
depicts Culver CityBus Lines 1, 4, and 5 as modified to connect to
Venice/Robertson and La Cienega stations Culver CityBus does not
currently have plans to reroute these bus lines as according to the figure,
and Culver CityBus Line 1 is the only existing service that will directly
serve the Venice/Robertson station area|109| Stations (Figure 2 4-30 on p 2 4-43)
a The station area plan indicates Culver CityBus lines 4 and 5 as
serving the station area on Washington Boulevard, but Culver
CityBus line 5 does not directly serve the station area In addition,
Culver CityBus line 4 is undergoing service route change (to be
approved by City Council and if approved, implemented Jan 9,
2006) and the new route will no longer pass by the station area
The new Line 4, once approved, will continue going north on
Jefferson Boulevard from the intersection of Jefferson Boulevard
and Duquesne Avenue, and it will run on La Cienega Boulevard to|1010| Page 7 of 27Exhibit A
Culver City Resolution No 2005- November 21, 2005
eventually connect to West LA Transit Center It will directly serve
La Cienega Station and will connect the station with West L A
College and Fox Hills Mall
The segment of National Boulevard that extends from the Right of
Way immediately west of Wesley Street to Washington/National
intersection is not available for a bike path given that National
Boulevard does not have a sidewalk In addition, the land (on the
southeast corner of the Washington/National intersection) proposed
to be acquired to accommodate the widening of National Boulevard
as indicated by the Locally Preferred Alternative is currently in
escrow
The station area plan shows that buses entering into the transit
center from Venice Boulevard can either make a left (going
eastbound) or a right (going westbound) on Washington Boulevard
This is inconsistent with the station area plan shown in the
Executive Summary, p 68 The FEIR should be revised to reflect
which of these is correct The proximity of the bus exit to the
Washington/National intersection will make it extremely difficult for
buses to make a left turn to go eastbound on Washington
Boulevard, assuming that Culver City s traffic engineer will even
allow for such maneuver Furthermore, the turning angle/radius for
buses making right turns on Washington Boulevard will be
problematic buses making right turns will encroach upon the left
turn lane on the north bound direction of Washington Boulevard
Due to the geometry and street configuration of the proposed
station areas (all options), existing heavy traffic in the station
vicinity, and the proximity of transit center entrance and exit to
intersections, it is impractical, from the point of view of bus
operations to have buses leave the streets and enter the off-street
transit center to pick up passengers Doing so would significantly
decrease the efficiency of bus operations and further exacerbates
the traffic situation in the station vicinity when buses loop around to
get back to their original operating directions on Venice or
Washington Boulevards Furthermore the proposed parking lots
that are within reasonable walking distance of the recommended
revised LPA (ROW option) only contain 110 parking spaces
(located on the right-of-way between Venice and National
Boulevards), which is significantly lower than year 2010 s demand
of 600 spaces It is therefore recommended that off-street transit
center be replaced by on-street transit centers on Venice and
Washington Boulevards and that the proposed space for off-street
transit center is used to create more parking spaces that provide
more park-and-ride transit users better access to the interim
station Without this additional parking we do not feel the
Page 8 of 27
(9Exhibit A
Culver City Resolution No 2005- November 21, 2005
proposed parking layout are adequate or in close proximity to the
interim design options
e Pedestrian path is not clearly identified in the station area plan To
ensure the safety of pedestrians and passengers, safe and direct
pedestrian routes with good signage and lightings must be
provided|109| Bus Service
a The FEIR does not address the impact Exposition LRT will have on
existing transit services Culver CityBus Lines 1 and 4 will be
heavily impacted by Exposition LRT due to their proximity to the
Venice/Robertson and La Cienega stations, while Culver CityBus
Lines 2, 3 5 and 6 will be impacted to some degree The potential
impact of necessary service increase to accommodate bus riders
brought in by Exposition LRT will require additional funding to
mitigate (pp 3 1-1 to 3 1-9)
b The FEIR anticipates that Culver CityBus will implement changes to
its bus services to serve the LRT stations These anticipated
changes include improved headway on Culver CityBus Lines 4 and
5, as well as terminating Culver CityBus Lines 1, 4, and 5 at La
Cienega Blvd or Venice/Robertson station These anticipated
changes are not included in the Culver City s Short Range Transit
Plan, and Culver CityBus does not currently have plans or funding
to implement these changes as anticipated in the FEIR Additional
funding would be required to implement change in service route
and frequency The FEIR should evaluate the feasibility and
funding source of these bus transit improvements (pp 3 1-4 to 3 1-
8)
c The FEIR does not explain why the daily fixed guideway boarding
for the Forecast Year 2025 is lower than that for the Forecast Year
2020 (42,900 and 43 600 respectively) (Table 3 1-8 on page 3 1-
7)
d The FEIR does not explain the rationale for quadrupling the bus
frequency for Culver CityBus Line 5 as this line is currently the least
used line in Culver CityBus system (Table 3 1-9 on page 3 1-7 to
3 1-8)
e Under Venice/Robertson Station section, Santa Monica BigBlue
Bus 12's peak headway (under No Project scenario) is 10 min, not
30 min as reported in the FEIR
f Under Venice/Robertson Station section, the subtotal of frequency
(for bus lines Metro 33 to Culver City 5) under No Project' scenario
and the subtotal of frequency (for the same set of bus lines) under
ao
Page 9 of 27Exhibit A
Culver City Resolution No 2005- November 21 2005
With Project" scenario are incorrect The grand total for both sets
of bus frequencies are also incorrect
g
Under La Cienega Station section, Culver CityBus Lines 1 and 4
are listed twice in the table
h Under La Cienega Station section, the subtotal for the bus
frequencies (for bus lines Metro 68 to Culver City 5) and the grand
total of bus frequencies under No Project scenario are incorrect
7 Bus Operation and Maintenance (O&M) Costs Table 5 1-6 on page 5 1-9
and Table 5 1-7 on page 5 1-10 indicate that the operating cost per
vehicle-hour for Culver City Municipal Bus is $81 79 in 2005 dollars
Culver CityBus current operating cost per vehicle-hour is $100 46 This
would significantly shift the range of incremental annual bus O&M cost for
Culver CityBus to higher than the range of $1 1 to $10 7 million dollars as
indicated in Table 5 1-7 Funding assistance is required to accommodate
the additional O&M costs associated with serving Exposition LRT stations
The FEIR should evaluate the feasibility and funding source for the
assumed bus service improvements
8 Ridership The FEIR indicates that the LRT Build Alternative will
consolidate the West Los Angeles Transit Center at the planned La
Cienega and Venice/Robertson LRT stations The area where La
Cienega station is located is heavily congested In order to expedite bus
service, it is necessary to have road improvements in this area, such as
adding exclusive bus lanes on La Cienega Boulevard Furthermore, if bus
lines are to be re-routed to terminate at either Venice/Robertson or La
Cienega stations, amenities (such as restrooms and vending machines)
for bus drivers must be provided at both stations (Page 5 2-2)
9 Bus Service The recommended future Locally Preferred Alternative
station area (ROW option stopping short of National) does not
accommodate any fixed route transit services Culver City Santa Monica
and MTA buses will indirectly serve the station The closest bus stops are
on Washington Boulevard at National (CC Lines 1 and 4) The closest
MTA bus stops are on Venice Boulevard It does not appear that the MTA
will reroute buses to the station Since the MTA is the regional transit
provider it will be difficult to attract and transfer riders from the
surrounding communities to the LRT line without direct bus service to the
station Similarly, there is no discussion regarding Santa Monica Bus Line
services (SMBL) What SMBL routes does the MTA expect to serve the
station and where will they stop' ? Would the SMBL Line 10 Freeway
Express leave the freeway and divert to the station'?
Page 10 of 27
alExhibit A
Culver City Resolution No 2005- November 21 2005
Traffic Issues
1 Executive Summary, Pages 34-36 Regarding Jefferson Boulevard Design
Options, Option B provides a grade separation bridge over La Cienega
Boulevard that ends short of BaIlona Creek The LRT tracks cross
Jefferson Boulevard at-grade Option B requires an awkward connection
for eastbound bicyclists who cross BaIlona Creek in the Class I bike path,
and then need to cross Jefferson Boulevard to reach the Class II bike
lane The crossing location for bicyclists shown in the Site Plan for Option
B would pose a safety concern due to potential conflicts with eastbound
motorists on Jefferson Boulevard who are negotiating a right-hand
horizontal curve The Medium Bridge Design Option carries the grade
separation over BaIlona Creek and the National Boulevard/Jefferson
Boulevard intersection This provides for smoother traffic flow and a safer
connection between the Class I bike path and Class II bike lanes For this
reason, the Medium Bridge Design Option serves Culver City better than
Option B
2 Executive Summary Table S-4, Page S-2, and Page 3 2-12, Mitigation
Measure T2 We support Metro s contribution of $100,000 toward the
preparation of a study identifying the possible improvements and
reconfiguration of freeway ramps and connecting arterial streets to help
mitigate the impacts of a parking facility at Venice/Robertson station
However the actual construction of improvements would be the mitigation
of any of the impacts Therefore the proposed mitigation measure should
include the stipulation that above and beyond Metro's financial
participation as the regional transportation agency in any regionally
significant traffic improvement, Metro should also fund their proportional
share of any improvements to address any impacts of the proposed Mid-
City Exposition Light Rails Project
3 Executive Summary, Table S-4 Page S-6 Table S-4, and Page 3 2-62,
Mitigation Measure T16 The improvements listed in the Executive
Summary for T16 are not the same improvements listed on Page 3 2-62
Metro must provide an accurate and complete listing of mitigation
measures before certification of the Final EIR
4 Executive Summary, Table S-4, Page S-6 Mitigation Measure T19 It is
not clear from the discussion where the additional right-of-way required to
accommodate the proposed southbound right turn lane between Venice
Boulevard and Washington Boulevard will come from The Final EIR must
identify where the additional right-of-way well be obtained The City of
Culver City disagrees with the notion that providing additional lanes on
Washington Boulevard will mitigate the impacts of an at-grade crossing
Traffic at the intersection of Washington and National Boulevards will be
gg-
Page 11 of 27Exhibit A
Culver City Resolution No 2005- November 21 2005
stopped in all directions when a Light Rail Vehicle (LRV) is approaching
and/or leaving the station regardless of whether the additional lanes are
installed However, the installation of these additional lanes may help to
mitigate the impacts caused by increased LRT station related traffic
5 Executive Summary Table S-4, Page S-10, Mitigation Measure T20 This
mitigation measure which would essentially convert the westbound right-
turn lane on Washington Boulevard into a through-and-right lane, appears
to be sufficient to mitigate the impacts of LRT for all Venice/Robertson
Design Options, but not the LPA at-grade crossing
6 Page 2 4-63, Countdown Pedestrian Crossing Traffic Signals The Final
EIR states that installation of countdown pedestrian signals is encouraged
for the intersection of Venice and Robertson Boulevards Countdown
signals should be required at all adjacent intersections serving the Venice
Robertson Station transit stops and parking lots, such as Venice/National
and Washington/National intersections The countdown signals should
also be installed at the Washington/National intersection in the event an
east of National Boulevard, Venice/Robertson Design Option is selected
7 Page 3 2-41, Section 3 2 4 2 1 Impact on Intersection Level of Service
The Final EIR does not discuss the potential impacts to intersection
operations from the potential surge of pedestrians leaving or arriving at the
station especially at rush hour Such pedestrian surges could have a
negative impact on traffic movements and signal timing at the major
intersections As stated previously, City Staff and consultants have had
follow-up discussions with Metro Staff Metro Staff has stated that they do
not expect that there would be unusually high pedestrian crossing
volumes at Venice Boulevard Due to the elongated configuration of the
proposed station parking to be located along the Metro-owned ROW
north/west of Venice Boulevard, Metro anticipated that pedestrian
crossings of Venice Boulevard would be dispersed between crossings at
Bagley/Main, CulverNenice and Venice/Robertson during the peak travel
hour It should be noted that any pedestrian choosing to cross at
Bagley/Main/Venice intersection would double their walking distance
Crossing at CulverNenice would also increase the walking distance but to
a leaser degree The shortest direct route would be to cross at the
Venice/Robertson intersection As such Culver City Staff believe that
most pedestrians parking in the main lot north of Venice will cross at the
Venice/Culver intersection and if surges of pedestrians do occur there is
the potential for negative traffic impacts
City Staff is also concerned that in the event an east of National Boulevard
Venice/Robertson Design Option is implemented, the intersection of
Washington/National could be negatively impacted by such pedestrian
Page 12 of 27Exhibit A
Culver City Resolution No 2005- November 21, 2005
surges Metro Staff has advised the City that a detailed level of analysis
would occur during the final design phase of the project when specific
parking lot locations and access points are finalized Providing adequate
pedestrian crossing times would be developed in coordination with Culver
City and Los Angeles However, the Final EIR does not include a
mitigation measure to require that such study be prepared and any
recommendations implemented Therefore, City Staff recommends that a
mitigation measure be adopted that requires preparation of a detailed
analysis during the final design phase of the project when specific parking
lot locations and access points are finalized, in order to identify signal
timing, adequate pedestrian crossing times and identify any required
physical mitigation measures Such analysis and subsequent mitigation
measures should be funded and implemented by Metro in coordination
with and subject to the approval of the Cities of Culver City and Los
Angeles
8 Page 3 2-63, Mitigation Measures T17 through T21 These mitigation
measures should be revised to specifically state that the design and
physical improvements shall be reviewed and approved and completed
construction accepted by the City of Culver City prior to the beginning of
transit service to the Venice/Robertson Station
9 Page 3 2-66 The Final EIR acknowledges that implementation of the
Locally Preferred Alternative with at-grade crossings of Washington and
National Boulevards would reduce reliability of the LRVs
10 Page 3 2-69, Mitigation Measure T22 The mitigation measure should be
revised to state that the mitigation of project impacts should be
implemented within a reasonable and timely period The mitigation
measure should be revised to state that analysis of impacts and
implementation of required mitigation shall be accomplished within 180
days from the opening day of the Venice/Robertson Station The
mitigation measure should also be revised to specifically state that the
design and physical improvements shall be reviewed and approved and
completed construction accepted by the City of Culver City prior to the
beginning of transit service to the Venice/Robertson Station
11 Impact on Regional Travel Patterns (Page 3 2-7) It is unclear how the
regional benefits of the project will be achieved The FEIR lacks
specificity with regard to patronage and how it will be achieved There is
no discussion with regard to how many passengers are expected to drive,
kiss and ride or take the bus Where are the passengers coming from?
This information is critical to station area planning, and for that matter all
of the access routes leading to the station
al-1
Page 13 of 27Exhibit A
Culver City Resolution No 2005- November 21 2005
12 Kiss-and-Ride How will kiss-and-ride passengers be accommodated'?
Will they be dropped off on Washington Boulevard? If so, where'? What
pedestrian improvements will be provided for kiss-and-ride patrons and
pedestrians in general'?
Parking Issues
1 Executive Summary Page 36, regarding La Cienega Station Parking
Options, the City of Culver City opposes the No Parking Option', which if
implemented would potentially shift parking demand west into Culver City
This potential option and related impacts are not discussed in the parking
impact assessment (3 3 2 Pg 3 3-6)
2 Execution Summary, Table S-4, Pages S-11 through S-13, Proposed
Mitigation Measure P5 The Table acknowledges the potential for parking
spillover and intrusion into residential areas There is no detailed discussion
about what type of parking control will be employed to insure who is using the
parking facilities and how much parking is available on a real time basis to be
conveyed to patrons There is no detailed plan for how spillover/intrusion
impacts will be mitigated and who will bear the cost of implementing and
maintaining any required mitigations The potential problems seem to be left
to the City to resolve if they arise Typical mitigation measures cost the City
and individual residents on ongoing bases The proposed Mitigation
Measure P5, should specifically state that Metro shall be responsible for
paying for installation and maintenance of project relate mitigations
3 Page 3 3-1, Table 3 3-1 Loss of Off-Street West End According to this
table, 144 Off-street parking spaces will be eliminated as a result of the
project As stated in the Final EIR this loss could' and more likely would
increase demand for on-street parking in the area, including adjacent
commercial and residential areas The loss of these spaces and the potential
increased competition for on-street parking in the area of the
Venice/Robertson Station (i e, Exposition Boulevard) would force cars of
local employees and customers, and some transit riders, to seek parking in
the adjacent residential areas In order to address these potential impacts
Mitigation Measure P1 must be revised to include station with parking
facilities to determine if spillover impacts are occurring and specific language
that Metro shall be responsible for funding implementation, ongoing operation
and enforcement of parking programs to reduce impacts on adjacent streets
4 Page 3 3-9 and 11, Section 3 3 2 3 Addition of Station Area Parking The
Final EIR notes in the LPA and Venice/Robertson Design Option, if
parking demand exceeds supply at the Venice/Robertson station, it can be
increased by extending the number of spaces within the METRO s ROW
Page 14 of 27 05Exhibit A
Culver City Resolution No 2005- November 21 2005
at the Venice Robertson site This parking does not allow direct or
convenient access for pedestrians between the station and any of the
proposed parking lots The spaces located north of Venice Boulevard are
about a quarter to a third of a mile away depending on were the station is
constructed Not only does this exceed the maximum recognized distance
people will walk from a parking space to a destination, but represents a
walking time of nearly ten minutes With 5 minute LRV headways, it is
conceivable a passenger could park their car and not board a train for 15
minutes Assuming an average travel speed of about 25 miles per hour,
the 9 6 mile trip to downtown Los Angeles on the Expo line would be
about 23 minutes Travel time is one of the most critical factors in mode
choice This includes the time to drive to a station, transfer, travel and
then transfer at the work end The transfer/travel times starting at the
Culver City end are not a very attractive alternative to driving The
majority of the station parking must be located closer to the station
location If any of the Venice/Robertson Design Options are selected and
the station is locate east of National Boulevard, it is recommended that
proposed off-street transit center be replaced by on-street transit centers
(on Washington and Venice Boulevards) and that the proposed space for
off-street transit center be used to create more parking spaces that
provide more park-and-ride transit users better access to the interim
station|109| Page 3 3-10, 1 st Paragraph The Final EIR recommended in this
paragraph that on-street parking restrictions be installed along adjacent
streets to discourage parking by transit riders There is no detailed
discussion about what type of parking control should be employed to insure
who is using the parking spaces There is no detailed plan for how the
impacts will be mitigated and who will bear the cost of implementing and
maintaining any required restrictions The potential problems seem to be left
to the City to resolve if they anse Typical mitigation measures cost the City
on ongoing bases The proposed Mitigation Measure P1, should specifically
state that Metro shall be responsible for paying for installation and
maintenance of project relate parking restrictions
6 Page 3 3-10 and 11 Mitigation Measures P1 and P5 Other than the
statement in P5, after opening day, neither mitigation measure states
specifically when analyses of impacts/parking demand and
implementation of mitigations shall occur The mitigation of project
impacts should be reasonable and timely The mitigation measures
should be revised to state that analysis of impacts and implementation of
required mitigations subject to City of Culver City approval, shall be
accomplished within 120 days from the opening day of the
Venice/Robertson Station
P
Page 15 of 27Exhibit A
Culver City Resolution No 2005- November 21 2005
7 Page 3 3-13, Venice/Robertson Design Option States that a parking shuttle
system would be required However, the Final EIR does not include a
mitigation measure for the implementation and ongoing operation and
maintenance of a shuttle system In addition, the Final EIR further states that
even with a shuttle system operating, parking spillover into east Culver City
streets will occur While the discussion notes that Mitigation Measure P1
would be necessary to reduce the potential impacts, P1 does not include
station with parking facilities and there is no discussion of who would be
responsible for the ongoing operation and maintenance of a shuttle system
and operation and enforcement of parking programs to reduce impacts on
adjacent streets Mitigation Measure P1, must be revised to include station
with parking facilities to determine if spillover impacts are occurnng and
specific language that Metro shall be responsible for funding ongoing
operation and maintenance of a shuttle system and operation and
enforcement parking programs to reduce impacts on adjacent streets
Visual Quality Issues
1 Page 4 4-48, Mitigation Measure V15 The mitigation measure should be
revised to state that lighting on the Transit Parkway shall be directed away
from adjacent private property and designed to reduce spillover impacts
Noise and Vibration Issues
1 Absorptive sound walls Metro has indicated that based on the projected
increase in noise levels for residences on the north side of National
Boulevard, and the amount of noise mitigation required at this location to
meet Federal criteria, standard noise barriers (rather than absorptive walls)
have been recommended Absorptive barrier walls are normally used to
reduce the bounce that is often created when sound barriers bounce noise
in the opposite direction thereby causing secondary noise impacts In the
case of National Boulevard, the sensitive residential receptors are
exclusively located on the north side of the street and industrial or highway
uses are located on the other side Metro indicated that no further benefit to
the homes on the north side of the street would be provided by absorptive
treatments on the wall and the noise created by National Boulevard itself
seems to eliminate any benefit from the provision of absorptive treatments
to the uses on the predominantly commercial uses on the south side of the
street
It is true that absorptive soundwalls reduce the "bounce of sound back
toward the source This is why absorptive soundwalls are more effective at
reducing noise from trains operating in close proximity to the soundwalls
Page 16 of 27
a gExhibit A
Culver City Resolution No 2005- November 21, 2005
The sound generated by the passing train is bounced between the reflective
soundwall surface and the reflective side of the LRT vehicle, thus degrading
the acoustic performance of the soundwall An absorptive soundwall does
not exhibit this degradation that results from an increase in virtual sound
source height and a reverberant field build-up of train noise Also, focusing
on any residual benefit to the south-side commercial land uses regarding
noise from National Boulevard misses the point Because of the site
geometry, with houses located north of the Exposition Line and National
Boulevard, an acoustically absorptive soundwall could provide a beneficial
project effect by reducing noise impact from National Boulevard traffic on
these north-side residences In addition to better reducing train pass-by
noise, this beneficial effect would continue during periods of no trains
2 Executive Summary Page 53, Last Paragraph This paragraph includes a
statement that 'Special studies will be conducted as part of the Final
Design to direct warning device noise away from sensitive receptors
Pages 4 6-32 through 34, list the noise and vibration mitigation measures,
none of which relates to the above statement A new mitigation measure
should be added to a noise and vibration mitigation measure to prepare
the special studies described on Page 53
3 Page 24-15, 1 st Paragraph The Final EIR description of the LPA West
End states that 'landscape berms would face the ballasted LRT trackway
so that these berms act as screening of the trackway from residential
areas as well as acting as a sound buffer against LRT noise" Figure 2 4-
13 Cross Section S Fay Street to Wesley Street (no page number), as
well as the Partial Site Section West of Fay Avenue near Wesley Street on
Executive Summary Page 43 indicate what appears to be a soundwall
between the trackway and the landscape berm According to Mitigation
Measure NV1 on Page 4 6-32, last bullet, the soundwall is to be
constructed on the north side of the ROW The City is concerned that if
a soundwall is installed as shown on Figure 24-13 the Bike Path area
would be screened from view from National Boulevard Lack of visibility of
the Bike Path could result in low use and increased security concerns
4 Noise and Vibration Chapter 4 6 needs to identify the exact location of Site
V-4 where ground vibration was measured
5 Page 4 6-3 last paragraph says that monitoring results were
generalized Please clarify what is meant by and what process was
used to generalize results
6 Page 4 6-7 first paragraph Please define "while gates are active" does
this mean throughout entire pass-by while gates are down?
Page 17 of 27
9.6Exhibit A
Culver City Resolution No 2005- November 21, 2005
7 Page 4 6-7, Impact Criteria — Noise Criteria refers to Federal only, CEQA
requires applicable state and local criteria be utilized as well Were state
and local standards evaluated and applied as well'?
8 Page 4 6-11 3rd Paragraph The reference maximum sound level of 77
dBA at 50 feet from track centerline (over soft ground) was used There is
no statement whether this sound level is consistent with actual revenue
operation measurements of similar trainsets operating on the Green Line
and Gold Line branches It is our understanding, based on independent
measurements (conducted by three different consultants and Metro), that
the P2000 trains generally exhibit higher in-service noise emission than
what their specifications promise Is the reference level of 77 dBA L.
consistent with the 'in-service sound level measurements of P2000
trainsets operating on the other Metro lines' ? Also, most urban
environments (including Culver City) have 'hard ground between the
tracks and sensitive receptors, yet the analysis assumed propagation over
"soft ground What correction factor was applied to the analysis to
account for this discrepancy'?
9 Page 46-11, 5th Paragraph In a recent decision involving the Gold Line
grade crossing bells, the California Public Utility Commission (CPUC) has
approved setting the bells to sound at a level of 75 dBA at a reference
distance of 10 feet Will the project s proposed Audible Warning Devices
be modified to reflect this CPUC decision'?
10 Page 4 6-11 last paragraph and Page 4 6-12 first paragraph These
sections are not consistent with earlier discussions regarding the duration
of gate bells and again raises the issue of gate bell sound level
11 Page 4 6-12 3 rd Paragraph The assumption that the 75 dBA quacker
would be sounded provides an inadequate analysis if, in fact, the 85 dBA
warning device will be regularly used The Final EIR does not provide
analysis of the potential for the frequency of use of the 85 dBA warning
device and/or how the project has been designed to reduce the likelihood
of the louder warning device needing to be used
12 Page 4 6-14 last line from LRV should go after impacts
13 Page 4 6-16 third paragraph The correct technical term would be 'damp
as in to reduce the amplitude and duration not "dampen as in to make
wet
14 Page 4 6-15 1st Paragraph Table 4 6-7 Summary of Residential Noise
Impacts, states that 14 single family residences on the north side of
National Boulevard between Fay and Helms Avenues would be impacted
Page 18 of 27Exhibit A
Culver City Resolution No 2005- November 21 2005
(10 Impact/4 Severe) from air-borne noise from LRVs Appendix J does
not contain detailed maps showing where these noise (and vibration)
impacts would occur along the alignment Metro must provide the detailed
maps identifying the effected residences before final design of noise
mitigation is approved
15 Page 4 6-18 1 st Paragraph Based on previous experience with P2000
LRV both on aerial structure and at grade (viz, Green Line near Douglas
Station and Gold Line through South Pasadena) the estimated barrier
heights discussed in the FEIR are slightly low The aerial barriers should
be 6 feet high from the viaduct surface and the at-grade soundwalls
should be approximately 8 feet above grade It would be more accurate to
specify soundwall heights referenced to "top-of-rail" There are no
calculations provided for the proposed soundwall's acoustical
performance Please provide the calculations A discussion of acoustically
absorptive soundwalls is absent and should be provided
16 Page 4 6-19, Table 4 6-10 Regarding the Height (ft) column and the
Notes in the table same comment as above regarding the height of
proposed soundwalls One on-viaduct barrier is listed as 4 feet high, this
would only be one to two feet above the source height and its
performance would be questionable Please provide the calculations for
the proposed soundwall s acoustical performance
17 Page 4 6-19, 2 nd Paragraph It is asserted that barriers will reduce
quacker noise by 8 dBA The Final EIR does not include any calculations
for this Insertion Loss Please provide these calculations
18 Page 4 6-19 third paragraph We recommend that this paragraph be
revised to reflect the recent order by the CPUC and the terms of the
approved Gold Line Settlement Agreement regarding grade crossing bell
noise levels and directivity
19 Page 4 6-21 third paragraph Please insert a reference to Table 4 6-12
20 Page 4 6-23 Table 4 6-12 Last entry, ( 489 ) Contents of the Table are not
consistent with text on page 4 6-24, first paragraph
21 Page 4 6-24, 1 st Paragraph Location "489 is identified as experiencing
impacts However, unlike Locations 213 and 486, no proposed mitigation
for Location 489 is presented Due to the proximity of residential,
institutional and the identified recording studio uses to Location 489, a
mitigation measure for the installation of spring-rail frog crossover switch
must be adopted to address the potential impact
Page 19 of 27
0Exhibit A
Culver City Resolution No 2005- November 21 2005
22 Page 4 6-26, 8th Paragraph The vibration screening procedure in FTA
1995 shows potential adverse effects for Category 1 uses at a distance of
450 feet and for Category 2 at 150 feet These distances are known to be
conservative and that is why the General and Detailed methods are
also available in FTA 1995 However, the Final EIR states the threshold
used for Category 1 uses is 100' instead the FTA criteria of 450 The
difference between 450 feet and 100 feet in the Final EIR/EIS is not trivial
Thus, we would like to review the vibration calculations associated with
the Hayden tract, the recording studio and the row of residences
(Category 2) that back up to the proposed track along National Boulevard
in Culver City before final design and any mitigation is approved
23 Page 4 6-27, Vibration Attenuation Methods While a comprehensive
laundry list of available vibration reduction approaches is presented here
in the FEIR, none of the mitigation measures numbered 1 through 5 are
provided in Culver City Pursuant to NEPA, CEQA and court guidelines,
the EIR/EIS must contain a reasoned prediction of the likelihood that a
particular or any range of mitigation will be incorporated into the project
Discussion should be provided regarding the reasonableness and
feasibility of incorporating various levels or types of vibration mitigation
24 Page 4 6-28, Table 4 6-14 The table is not consistent with the discussion
of vibration mitigation It makes no reference to mitigation #6 nor lists any
track location within Culver City Also, notwithstanding Note /a/ in the
table, the comment supra applies to the Vibration Attenuation Methods
column in the table
25 Page 4 6-28, Venice/Robertson Design Options There is no discussion
about the potential impacts of the other options in this grouping if Option A
is not selected However, Mitigation Measure NV8 (Page 4 6-34), which
appears to be proposed to address the Option A impacts does not
specifically state if the measure is contingent on any specific option being
implemented Therefore Metro will be required to perform the noise and
vibration assessment regardless of which design option is selected
26 Page 4 6-28 Venice/Robertson Design Option According to this
discussion significant vibration and ground-borne noise impacts are
projected for the recording studio located to the north of the right-of-way
The Final EIR states that the project shall be required to fully mitigate the
impacts However, Appendix J does not identify the specified recording
studio as impacted
27 Page 4 6-32 Mitigation Measure NV1 There has been some 'relaxation'
of the proposed mitigation measure between the DEIR/EIS and the
FEIR/EIS as it relates to the proposed height of the sound wall along the
Page 20 of 27
3 •Exhibit A
Culver City Resolution No 2005- November 21, 2005
northern boundary line of the right-of-way along Fay Avenue to Wesley
Street The 2001 Draft EIS/EIR on page 3 9-20, (2 nd bullet), stated that to
be effective the at-grade walls must be 8 feet high However, the Final
EIR (NV1 7th bullet) is now proposing this wall be six feet tall We believe
this to be lower than adequate for at-grade soundwalls in this location
The soundwalls should be increased in height to eight (8) feet
28 Page 4 6-35 Ground-borne Vibration Mitigation Measures" This
paragraph does not, and should state that Mitigation Measure NV8 (Page
4 6-34) is required due to the potential for impacts to the recording studio
on Wesley Street In addition, this paragraph should include discussion of
the impacts to the recording studio discussed on Page 4 6-28
Venice/Robertson Design Options
29 Culver City recommends that Rubberized Asphalt Concrete (RAC), open-
graded friction course (Quiet Pavement) should be used for the
construction of the realignment of National Blvd that is required by the
project and furthermore that the entire stretch of National Blvd between
Jefferson and Washington that is not part of the reconstructed section of
the roadway should be overlayed with a minimum of 2 of RAC RAC has
a proven track record in reducing the noise levels on roadways by as
much as 4 to 10 db This noise reduction would help offset the additional
noise caused by LRT operations and would augment other proposed
noise mitigation measures
30 Page 4 6-32, NV-1, last bullet Please provide barrier calculations for the
soundwall between Fay Avenue and Wesley Street on the north side of
R/W
31 Page 4 6-33, continuation of NV-2, first bullet Please describe in more
detail the proposed or potential treatment(s)
32 Page 4 6-34 NV-7 Table 4 6-14 does not list Culver City locations
33 Pile driving vs drilling (Pg 4 15 — 25) C-22 Metro guidelines allow for pile
driving 250 feet or more away from residences yet at p 4 15 — 13 the
FEIR indicates that piles shall be drilled not driven Which is correct'?
34 The City recommends that the pedestrian crossing over the LRT track at
Wesley Street be eliminated in favor of a pedestrian path that will take
residents around the west end of the station and connect to the proposed
pedestrian/bike path north of the station at Wesley
Page 21 of 27
P'Exhibit A
Culver City Resolution No 2005- November 21 2005
Geology, Soils, and Seismicity
1 Page 4 7-2 Alquist-Pnolo Fault Hazard Zones The text on this page
erroneously states that the zone in the area of the project is located
southeast of the Intersection La Cienega and Washington Boulevards,
when it is actually southwest of the intersection However, the text
correctly states that the zone crosses the Exposition right-of-way in the
area of National Boulevard and Fay Avenue In addition, Figure 4 7-2 on
Page 4 7-4 also indicates that the zone crosses the right-of-way
2 Page 4 7-6 through 11 Any impact assessment and mitigation measure
discussion of an aerial station should include the approach structures over
Washington, National and Jefferson Boulevards and Ballona Creek
Water Resources
1 Page 4 9 3 Section 4 9 1 8 State Regulatory Framework The reference
to the project size threshold for triggering coverage under the General
Construction Storm Water Permit is based on outdated Information The
size threshold has been lowered from 5 acre and greater to 1 acre and
greater The Final EIR erroneously states the outdated size threshold in
various places in the document and should be revised appropriately
2 Page 4 9 3, Section 4 9 1 8 State Regulatory Framework The Final EIR
does not discuss in this Section the General Industrial Activities Storm
Water Permit (GIASP) requirements and their applicability to this project
Due to the scope of the project, once in operation it is likely that it will be
subject to the GIASP or an individual stormwater NPDES permit for its
discharge of stormwater to the municipal storm drain system
3 Page 4 9-4, Maintenance of the Water Quality of Municipally Separate
Storm Drainage Systems This Section should have reference the
requirements in the LA MS4 Permit that specifically pertain to this project-
' e for the construction and post-construction phases For example,
Under the Permit, City must ensure that the quality of the discharges
entering its storm drain system including those from construction site
meets the Maximum Extent Practicable (MEP) level by enforcing local
Storm Water Pollution Prevention Plan requirements and by conducting
inspections to verify the adequate implementation of Best Management
Practices (BMPs) This section should also have reference the Standard
Urban Stormwater Mitigation Plans (SUSMPs), which are a set of
development planning requirements that apply to specific categories of
development and redevelopment projects The SUSMPs requirements
are aimed at controlling pollutants generated from developed or
redeveloped sites after construction activities have been completed In
Page 22 of 27
23
3Exhibit A
Culver City Resolution No 2005- November 21, 2005
addition to the Waste Discharge Requirements (WDR) for Specified
Discharges to Groundwater in the Santa Clara River and Los Angeles
River Basins, the EIR should have specified a similar WDR for Ballona
Creek if there is a reasonable expectation of similar discharge entering
Ballona Creek Mitigation Measure WR1 should be amended to
specifically state that Metro shall prepare all analysis and plans and
implement all measures to comply with all relevant Federal, State and
Local stormwater regulations
4 Page 4 9-9 Page 4 16-9, Mitigation Measure 0M3 states that 'A
drainage plan shall be developed and implemented which shall ensure
that the Division 11 facility is engineered to direct water runoff into
appropriate drainage culverts and channels Mitigation Measure WR1
must be revised to include the same requirements to insure that if existing
storm drain inlets/catch basins located in the vicinity of the project are
inadequate to properly convey the runoff from the Exposition transit way,
additional catch basins should be constructed to prevent potential
flooding The drainage plan shall be developed after careful consideration
of the capacity of the existing storm drain system and the impact of the
additional volume on the Ballona Creek and the Estuary The City of
Culver City shall be consulted during the development of the drainage
plan and the plan and recommended improvements shall be subject to the
City's review and approval
Historical, Archaeological, and Paleontological Resources
1 Execution Summary Table S-4, Page S-48, Jefferson Boulevard Design
Option The Ballona Creek Railroad bndge is identified as a histonc
landmark and is proposed to be left in-place and incorporated into the Project
design However, The Final EIR does not include a mitigation measure to
address who will be responsible for the ongoing maintenance
Construction Impacts
1 Page 4 15-5 4 15 1 3 6 Bridge Construction Nighttime construction is
anticipated to occur at La Cienega Station over street This has the
potential to result in noise impact on Culver City residence Culver City
and the East Culver City and Rancho Higuera Neighborhood
representatives should be advised of anticipated nighttime construction
periods and contact numbers
2 Page 4 15-10, Section 4 15 3 2 Parking Mitigation Measure C5 — The City
of Culver City shall be the only approval authority for on-street contractor
employee parking within the City
Page 23 of 27Exhibit A
Culver City Resolution No 2005- November 21, 2005|109| Page 4 15 — 16, Mitigation Measure C42 Enforcement on construction sites
in Culver City shall be by Culver City Police Department
4 Page 4 15-18, Venice/Robertson Design Option - The Aerial Station
option would potentially require lane closures over National Boulevard, not
just Washington Boulevard as stated in the Final EIR
5 Page 4 15 —25 Impact pile driving According to Page 4 15— 13, Mitigation
Measure C22, Metro guidelines only allow pile installation by drilling Metro
must clarify which technique for pile installation will be used before the Final
EIR is certified
6 Level of Significance In the construction impact assessment section (p
4 15-8) the EIS/EIR states With implementation of mitigation measures
itemized below, no substantial adverse construction impacts are
anticipated ' However elsewhere in this section (e g , traffic at p 4 15-17)
the document states "Although the impacts would be temporary they
would be considered significant These sections of the document are
inconsistent and should be revised to indicate whether construction
impacts would be mitigated to a level of insignificance
7 Traffic In the discussion of traffic mitigation measures (p 4 15-9) the
document indicates that Metro is working closely with the City of Los
Angeles and Culver City in developing construction mitigation plans
CEQA requires that mitigation measures be disclosed in the Draft EIR, yet
this document is a proposed Final EIR and the details of construction
mitigation plans have still not been determined For example, haul routes
and hours of operation have not been identified (Section 4 153 1,
Mitigation Measure Cl) The effectiveness and adequacy of mitigation
measures cannot be determined if they are not revealed by the lead
agency The document should be revised to identify specific mitigation
measures for construction traffic impacts
8 Parking In the discussion of parking mitigation measures
(p4
15-10)
there is no attempt to quantify the temporary loss of parking, yet the
document concludes that these mitigation measures (e g, interviewing
business owners) would mitigate impacts to less-than-significant levels
Without identified thresholds for significance, it is not possible to
determine whether this conclusion is justified
9 Noise and Vibration The mitigation measures for noise and vibration
include monitoring (C16) and examples of noise reduction techniques
(C17-26) but no criteria or performance standards are identified While
monitoring is an important aspect of mitigation it is not sufficient without
further identification of clear performance standards and enforcement
Page 24 of 27Exhibit A
Culver City Resolution No 2005- November 21 2005
procedures Some mitigation measures contain weak language such as
Metro may require contractors (C18) and If temporary sound
barriers are required to meet City noise regulations, Metro shall review
sound barrier designs prior to implementation" (C25) (emphases added)
These deficiencies should be corrected prior to certification of the Final
EIS/EIR
Bikeway and Bikeway Facilities
1 Page 24-26 and 27 Design Option B and C Under each of these options
the Final EIR states that the Class I bikeway would connect to a Class III
bikeway at Wesley Street According to the preliminary design studies
provided to the City by Metro, the Class I bikeway would connect to a Class
III bikeway at Helms Avenue Metro must clarify which is correct before
selecting any design options
2 Page 2 4 — 47, West End According to the Final EIR the proposed Bike Path
ends at Wesley and bicyclists would be directed to use crosswalks to the
Venice/Robertson Station or directed to use National Blvd to access the
Venice Boulevard Bike Lane There is no further discussion of the
appropriateness of directing bicyclist to National Boulevard for purposes of
connecting from the Bike Path to/from the Venice Boulevard Bike Lane
There is no discussion of what, if any, physical improvements would be need
on National Boulevard to accommodate this potential increased activity The
City recommends that Metro adopt a mitigation measure which requires that
Metro prepare a bicycle and pedestnan access plan that analyses the
selected design option for the Venice/Robertson Station, associated parking
lots, bikeway connections and access to/from each, in order to identify the
required implementation improvement necessary to provide safe access and
egress The proposed bicycle and pedestrian access plan should be
required to be prepared prior to the final design for the project is approved
3 Page 2 4-47 The Bike Path is proposed to be 12-feet wide and is intended
to accommodate both bicyclists and pedestrians The Bike Path as it is
currently envisioned intersects and incorporates existing and relocated
sidewalk areas of cul-de-sacs at the end of Wesley Street, Helms and
Caroline Avenues The City is concerned that Metro s plans as proposed
are creating a potential hazardous conflict between pedestrian and bike
path users Specifically the concern is about the interface between the
public sidewalk in these locations and the Bike Path at the end of the cul-
de-sacs The Bike Plan should be designed to eliminate these potential
conflicts and to provide separate sidewalk area and if not separated
adequate notice and warning of the potential hazard
39
Page 25 of 27Exhibit A
Culver City Resolution No 2005- November 21 2005
In addition the City of Culver City will require that all cul-de-sacs modified
and/or relocated as a part of the project, shall be reconstructed to at a
minimum be restored to turning radius no less then the existing cul-de-sacs,
or better if possible All cul-de-sac design and construction shall be reviewed
and approved by the City prior to acceptance by the City
4 Page 24-53, Bikeway Features 2 nd Paragraph The Final EIR discusses the
use of applied surfaces on the Bike Path to create warnings and to instruct
cyclist to slow down for intersections and transitions These surfaces would
be applied using traffic paint or thermal plastic film Any applied material
should not create a slipping hazard and should be approved for bikeway use
in wet conditions
5 Page 7-116, Last Paragraph The first sentence of this paragraph would lead
the reader to believe the Class I Bike Path would connect directly to the
Venice Boulevard Class ll Bike Lanes This is not the case under any of the
proposed station options At the least cyclists would be required to negotiate
very challenging regionally serving intersections (i e, Washington/National
Venice/Robertson and/or Venice National) Depending on which station
design option is selected, cyclist would also be required to exit the Bike Path
at Washington Boulevard, Wesley Street or Helms Avenue None of these
streets currently are designated bikeways As both Wesley Street
(commercial) and Helms Avenue (residential) are narrow streets (curb to curb
width of approximately 32 to 34 feet) with parking on both sides, it is unlikely
that either would be generally used for a designated Class III Bike Route
National Boulevard was discussed as a potential route for connecting from
the Bike Path to/from the Venice Boulevard Bike Lane However, there is no
discussion in the Final EIR of what if any, physical improvements would be
needed on National Boulevard to accommodate this potential increased
activity The City recommends that Metro adopt a mitigation measure which
requires that Metro prepare a bicycle and pedestrian access plan that
analyzes the selected design option for the Venice/Robertson Station
associated parking lots bikeway connections and access to/from each in
order to identify the required implementation improvement necessary to
provide safe access and egress The proposed bicycle and pedestrian
access plan should be required to be prepared prior to the final design for the
project is approved
6 Page 7-117, 1 st Paragraph This paragraph erroneously states that the Class
1 Bike Path would not be accessible from north-south neighborhood streets
According to Metro s Preliminary Engineering Drawings issued June 3, 2005,
the Bike Path would directly connect to each street from Fay Avenue to
Wesley Street The Bike Path is intended to also serve as the primary
pedestrian path between the East Culver City and Rancho Higuera
Neighborhoods
Page 26 of 27
3TExhibit A
Culver City Resolution No 2005- November 21 2005
7 Clean Mobility Center (Appendix H) A CMC is slated to be built at the
Venice/Robertson station There are staffing and amenities such as
restroom and bicycle facilities associated with the CMC What will this look
like and where will it be placed as a part of any Venice/Robertson design
options'? Culver City would like to review and approve the final design and
location of the CMC (See the complete list of features in Appendix H)
Page 27 of 27
RESOLUTION NO 2005-RA
A RESOLUTION OF THE CULVER CITY REDEVELOPMENT
AGENCY TRANSMITTING THE OFFICIAL AGENCY
COMMENTS ON THE OCTOBER 2005 PROPOSED FINAL
ENVIRONMENTAL IMPACT STATEMENT/ENVIRONMENTAL
IMPACT REPORT FOR THE PROPOSED METRO MID-CITY
EXPOSITION LIGHT-RAIL TRANSIT PROJECT
WHEREAS, in October 2005 the Los Angeles Metropolitan Transportation
Authority (Metro) released the Final EIS/EIR for the Los Angeles Mid-City Westside Transit
Corridor and Mid-City Exposition Light Rail Transit Project (the 'Final EIS/EIR ), and
WHEREAS, the Culver City Redevelopment Agency (the "Agency") has
reviewed and considered the Final EIS/EIR and provided the opportunity for interested
parties to offer comments at a public meeting on November 21, 2005, and
WHEREAS pursuant to its authority under the California Community
Redevelopment Law, the Agency has concurrent jurisdiction to review and approve the
Exposition Light Rail Project and as such the Agency is a Responsible Agency for this
project as defined by the California Environmental Quality Act, and
WHEREAS, portions of the Exposition Light Rail Project are located within,
and would have significant impacts on the Culver City Redevelopment Project area and
WHEREAS the Agency has identified portions of the Final EIS/EIR where
corrections or additional information is needed to provide affected agencies and the public
with sufficient information upon which to fairly evaluate the environmental consequences of
the project These specific issues are identified in Exhibit A, attached hereto
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NOW, THEREFORE, the Culver City Redevelopment Agency DOES
HEREBY RESOLVE as follows
1 This Resolution including attached Exhibit A, constitutes the Agency s
official comments on the Final EIS/EIR that was prepared for the proposed Mid-City
Exposition Light Rail Transit Project|109| Staff is directed to transmit this Resolution to the Los Angeles County
Metropolitan Transportation Authority for consideration by the Metro Board
APPROVED and ADOPTED this 21 st day of November, 2005
ALAN CORLIN, Chair
Culver City Redevelopment Agency
ATTEST APPROVED AS TO FORM
VIDA FLOYD, Agency Secretary MURRAY 0 KANE, Agency Legal Counsel
-2-Exhibit A
CULVER CITY REDEVELOPMENT AGENCY RESOLUTION NO 2005- RA
FINAL EIRJEIS (the "FEIR") COMMENTS
MID-CITY/EXPOSITION LIGHT RAIL TRANSIT PROJECT
November 21, 2005
General Comments
1 Revised LPA (Executive Summary Table S-2 Capital Cost Estimate for
Mid-City/Exposition LRT, Page 39) The last column shows costs for the
Revised LPA (Metro Staff Recommendation) This revised LPA is
described in Note b in the Table The Revised LPA should be more fully
described and illustrated, perhaps with a complete separate section This
is particularly important to Culver City as the Revised LPA incorporates a
Venice/Robertson station design option that is proposed to address
concerns expressed by Culver City with at grade crossings of National
Boulevard and Washington Boulevard An illustration or series of
illustrations depicting the Revised LPA are necessary
2 Venice/Robertson Interim Station Design Options (Page 55) The third
paragraph identifies the north of right of way options and the On ROW
Design Option This option is elsewhere identified as the only option that
would be affordable within the approved project budget and the option
incorporated into the Revised LPA This description should include such
references
3 Elevated Venice/Robertson Station Option Design and construction of a
truncated version of the elevated Venice/Robertson station to terminate south
of Washington Blvd with an elevated crossover over National Blvd yields
benefits on the following issues
a Does not require right-of-way acquisition
b Allows for full redevelopment of existing private property
c Provides for bike path to extend past Wesley crossing under the
elevated track crossing National Blvd at the signalized intersection at
Wesley and proceed along National Blvd on existing sidewalk to station
and the Venice Blvd bike lane
d Eliminates need to provide for a gated pedestrian crossing of the LRT
tracks
hlExhibit A
Culver City Redevelopment Agency Resolution No 2005-RA November 21, 2005
e May provide for selected dedicated parking below and adjacent to the
elevated rail north of Wesley
f Eliminates one pedestrian roadway crossing from proposed parking lot
on Metro right-of-way north of Washington Blvd , present location of The
Jungle nursery
g Will provide a site for the CMC and possibly the electrical control building
under the raised platform/station
h Self advertises therefore less roadside directional signage needed
i Noise generated by the station activity and the adjacent crossover track
will be at a further distance from residences
j Pg 4 17-8 states ' the aerial station may be considered
environmentally superior to the ROW option|109| Page 2 4 — 31 There is a Control Office Building at the Venice/ Robertson
Station (see Appendix A, Sheet A-402) The facility is dedicated to
regulate/control/monitor power to the LRT system In addition there is a
Traction Power Substation (Page 4 15-7, and Appendix A, Sheet A-404)
proposed on the portion of the LRT right-of-way, located between
Washington and National Boulevards None of the Venice/Robertson Design
Options ever discuss where these two facilities would be placed or how they
will be designed and situated so as to not generate any adverse impacts
5 Page 2 4-43 Figure 2 4-30, Venice/Robertson Station Area This Figure
indicates that a left-turn is proposed from the southerly end of the Bus Drop-
Off/Layover to eastbound Washington Boulevard According to the plans for
the Station in the Executive Summary Pages 68 and 69, only a right-turn
would be allowed The right-turn only movement is supported by Drawing A-
404 in Attachment A While this issue is related to the LPA, which Metro
Staff is proposing to be revised it should be noted that the City of Culver City
would not allow such a left-turn movement from any future Transit Center and
potentially any parking lot, due to limited queuing space from the
Washington/National intersection
Air Quality Issues|109| We would note that transit is generally considered an air quality positive
strategy in a regional sense Any impacts are therefore either local near a
particular transit node, or short-term during construction The
environmental analysis concluded that carbon monoxide, as an indicator
of any local hot spot' potential, was less-than-significant Based upon the
Page 2 of 31Exhibit A
Culver City Redevelopment Agency Resolution No 2005-RA November 21, 2005
continued improvement of the regional vehicle fleet, we would concur with
that assessment
Since the Draft EIR/EIS was released in 2001, there is a substantial gap
between the preparation of the DEIR/DEIS and the final documents A
limited amount of updating is included in the FEIR/FEIS, but even these
updates stop around 2003 There are several new air quality initiatives or
programs that have been promulgated in the last few years
Those technical issues that are not adequately addressed in the final
environmental documents (because of the passage of time or an initial de-
emphasis) include the following
a The analysis provides no meaningful analysis of air toms issues
associated with idling buses at transit centers or of delayed surface
trucks along priority bus or LRT corridors
b The analysis does not include any information on the air quality setting
since 2002 The basin has experienced some back-sliding in the last
few years that are a major concern in long-term ozone attainment
strategies
c The analysis does not include the concept of local significance
thresholds developed by the SCAQMD which are generally more
stringent than the regional significance thresholds from the 1993
SCAQMD CEQA Air Quality Handbook
d The FEIR/FEIS contains no reference to recently adopted California 8-
hour ozone air quality standard that is more stringent than the federal
standard
Land Use Issues|109| Culver City Redevelopment Agency Redevelopment Plan and DFD (Page
4 1-10) This section makes no reference to the DESIGN FOR
DEVELOPMENT FOR EXPOSITION LIGHT RAIL TRANSIT AND
STATION AREA (the DFD) approved by the Culver City Redevelopment
Agency on oJune 6, 2005 The DFD states in part, the following
Consistent with the purposes of this DFD and pursuant to the
authority of the Agency under Section 422 of the
Redevelopment Plan for the Culver City Redevelopment Project
(Component Area 3) and Section 363 of Component Area 4, the
Agency hereby establishes the following controls and
restnctions for development of the Exposition Light Rail Transit
Page 3 of 31
q-3Exhibit A
Culver City Redevelopment Agency Resolution No 2005-RA November 21 2005
and Station Area DFD, which are in addition to applicable
General Plan requirements and guidelines, Zoning, Building
Codes and other requirements of the Culver City Municipal
Code (GCMG)
2 Venice/Robertson Design Options (Page 4 1-18 to 4 1-19) This
discussion should reference the DESIGN FOR DEVELOPMENT FOR
EXPOSITION LIGHT RAIL TRANSIT AND STATION AREA" (the DFD)
approved by the Culver City Redevelopment Agency on June 6, 2005
The design options that are incorporated into the LPA and the Revised
LPA respectively should be identified
3 CEQA Determination (Page 4 1 -19 to 4 1-20) This analysis of applicable
land use policies does not include reference to the "DESIGN FOR
DEVELOPMENT FOR EXPOSITION LIGHT RAIL TRANSIT AND
STATION AREA (the DFD) approved by the Culver City Redevelopment
Agency on June 6, 2005 This section also does not include discussion of
the Revised LPA" and associated impacts|109| Land Acquisition (4 2 2 1 Acquisition of Property, Table 4 2-2, Page 4 2-5
and Page 4 2-30) This paragraph references land acquisition
requirements for the LPA and for the three North of ROW Options It also
mentions that ROW and Aerial Station options would not require the
acquisition of properties However on Table 4 2-2, Page 4 2-5, under the
West End section, it shows partial (P) takings listed for the Aerial and in
ROW options Which is correct'?
5 Financial Analysis (Venice/Robertson Station Design Options, Page 5 1-
6) The Metro Staff recommended Revised LPA incorporates the station
location option east of National Boulevard on the Metro right of way near
Wesley Street which is identified as the only option that would be
affordable within the approved project budget Please indicate whether
the certification of this EIS/EIR will encompass the Revised LPA?|109| Response to Comments (Page 7-131 to 7-133) Several paragraphs on
these pages discuss the Culver City General Plan and land
use/transportation policies Not addressed in this discussion is the
"DESIGN FOR DEVELOPMENT FOR EXPOSITION LIGHT RAIL
TRANSIT AND STATION AREA' (the DFD) approved by the Culver City
Redevelopment Agency on June 6, 2005
Public Safety Issues|109| These comments are common to both possible locations, Venice /
Robertson and the interim termination at Wesley Street The Expo Rail
1-0
Page 4 of 31Exhibit A
Culver City Redevelopment Agency Resolution No 2005-RA November 21 2005
Project will cause an overall increase in calls for police and fire service,
including
a An increase in criminal activity will occur in Culver City Adjacent
parking areas will see an increase in auto theft, auto burglaries, and
thefts from autos Increased pedestrians coming to and from the
location will increase the amount of violent crime including robbery
assaults, purse-snatches, etc If parking areas for the route are
within our jurisdiction, the reportable crime and the police
department s workload would likely increase
b Pedestrian and vehicle safety should be the highest priority
Elevating the railway will reduce the incidence of vehicle &
pedestrian collisions with the train
c Trains are a major terrorism target The police department will be
responsible for safety and criminal activity within the City limits
The City will have to take proactive steps whenever terror alerts are
given Culver City Police does not have the personnel to handle this
at our present capacity
d The police department is responsible for the safety of all persons
within the City not just residents The police department estimates
that on any given day 325,000 persons are within our jurisdiction,
not the 39,119 as indicated on page 4 12-3 This is our policing
population which will likely increase
e The department will have to increase their personnel capacity to
accommodate the needs of this project, including stationary
security posts at the station s end, and while citizens come and go
to the station
f Several public and private schools will be impacted in the project
Not mentioned in the report are Culver City High School Farragut
Elementary School Linwood Howe Elementary School Willows
Community School Hamilton High School Turning Point School
and Echo Horizon School In addition there are two new schools
currently entitled and/or in the process of entitlement (New Century
School off of Landmark and the proposed Expansion of Turning
Point School off of National and Landmark)
g
Regardless of which location is chosen, adequate parking will be an
issue By definition, this will be the western terminus of the rail
project, thus drawing riders from the entire west side Inadequate
parking will impact adjacent residential neighborhoods and traffic
Page 5 of 31
46-Exhibit A
Culver City Redevelopment Agency Resolution No 2005-RA November 21, 2005
congestion will increase Increased traffic will cause a
corresponding increase in calls for service, including injury traffic
collisions|109| Should the route terminate at Venice / Robertson, with planned parking
north of Venice in the City of Los Angeles
a An elevated train can be designed to minimize the affect of crossing
Washington, and reduce the incidences of vehicle-pedestrian/train
collisions
b If parking is planned north of Venice, the reportable crime will be
the responsibility of the City of Los Angeles
c Pedestrians hurrying to catch a train across Venice are a safety
issue
d Some incidents will become Culver City Police responsibility, as
determined by jurisdictional boundaries
e At grade crossing will have a major impact on police and fire
response times on Washington Blvd & National, which are major
arteries through Culver City
f A concurrent project is in the planning for redirecting Washington
Blvd at Culver, via Ince This is a couple of blocks west of the
planned route Adding a ground level crossing will promote gridlock
during train crossings, with no immediate alternate routes Police
and fire vehicles could become 'trapped during a crossing,
delaying or preventing an adequate response to routine and
emergency calls
g
The area is a mix of industrial and residential Truck deliveries will
be impacted The potential of trucks carrying hazardous materials
becoming involved in collisions will increase This area has the
designated truck routes of Venice and National that feed the
affected area In the past decade the area has been expanding
and changing from industrial and manufacturing to corporate
offices, design centers and business|109| Should the route terminate at Wesley
a Parking north of Venice will accommodate the needed spaces,
however, the riders will traverse over one-quarter mile to catch the
Page 6 of 31Exhibit A
Culver City Redevelopment Agency Resolution No 2005-RA November 21, 2005
train The safety of these riders would then shift to our
responsibility, dramatically increasing our workload
b
Mitigation measures such as high fences will deny access to
McManus Park from the south side of the route
Transit Issues
1 Page 3 1 —3 though Pg 3 1 —9 There is a potential for a large congregation
of transit buses to arnve on-site because of the Venice/Robertson station
being a proposed Transit Center There is no discussion of where the buses
will stop if multiple arrivals overlap and over flow issues anse Will there be
sufficient queuing area along Venice Boulevard out of the traffic lanes to
accommodate buses waiting to access the Center, See Figure 2 4 — 15 Bus
Feeder Network|109| Page 24-15 Last Paragraph It is noted here that there is a railroad spur
located in the Hayden Tract and that Metro would maintain and plan the
parcels within the Hayden Tract Spur for local transportation use There is
no information provided to explain what is implied by local transportation
use
3 Executive Summary (p 68) The station area plan indicates that buses
enter from Venice Boulevard and can only exit onto Washington
Boulevard by turning right (westbound) This is inconsistent with the
station area plan shown on Figure 2 4-30 on p 2 4-43
4 Locally Preferred Alternative (Figure 2 4-15 on p 2 4-8) The figure
depicts Culver CityBus Lines 1 4, and 5 as modified to connect to
Venice/Robertson and La Cienega stations Culver CityBus does not
currently have plans to reroute these bus lines as according to the figure,
and Culver CityBus Line 1 is the only existing service that will directly
serve the Venice/Robertson station area|109| Stations (Figure 2 4-30 on p 2 4-43)
a The station area plan indicates Culver CityBus lines 4 and 5 as
serving the station area on Washington Boulevard, but Culver
CityBus line 5 does not directly serve the station area In addition,
Culver CityBus line 4 is undergoing service route change (to be
approved by City Council and, if approved, implemented Jan 9,
2006) and the new route will no longer pass by the station area
The new Line 4, once approved, will continue going north on
Jefferson Boulevard from the intersection of Jefferson Boulevard
and Duquesne Avenue and it will run on La Cienega Boulevard to
Page 7 of 31
4'4-Exhibit A
Culver City Redevelopment Agency Resolution No 2005-RA November 21 2005
eventually connect to West LA Transit Center It will directly serve
La Cienega Station and will connect the station with West L A
College and Fox Hills Mall
b The segment of National Boulevard that extends from the Right of
Way immediately west of Wesley Street to Washington/National
intersection is not available for a bike path given that National
Boulevard does not have a sidewalk In addition, the land (on the
southeast corner of the Washington/National intersection) proposed
to be acquired to accommodate the widening of National Boulevard
as indicated by the Locally Preferred Alternative is currently in
escrow
c The station area plan shows that buses entering into the transit
center from Venice Boulevard can either make a left (going
eastbound) or a right (going westbound) on Washington Boulevard
This is inconsistent with the station area plan shown in the
Executive Summary, p 68 The FEIR should be revised to reflect
which of these is correct The proximity of the bus exit to the
Washington/National intersection will make it extremely difficult for
buses to make a left turn to go eastbound on Washington
Boulevard, assuming that Culver City's traffic engineer will even
allow for such maneuver Furthermore, the turning angle/radius for
buses making right turns on Washington Boulevard will be
problematic buses making right turns will encroach upon the left
turn lane on the north bound direction of Washington Boulevard
d Due to the geometry and street configuration of the proposed
station areas (all options), existing heavy traffic in the station
vicinity, and the proximity of transit center entrance and exit to
intersections, it is impractical, from the point of view of bus
operations, to have buses leave the streets and enter the off-street
transit center to pick up passengers Doing so would significantly
decrease the efficiency of bus operations and further exacerbates
the traffic situation in the station vicinity when buses loop around to
get back to their original operating directions on Venice or
Washington Boulevards Furthermore the proposed parking lots
that are within reasonable walking distance of the recommended
revised LPA (ROW option) only contain 110 parking spaces
(located on the right-of-way between Venice and National
Boulevards), which is significantly lower than year 2010's demand
of 600 spaces It is therefore recommended that off-street transit
center be replaced by on-street transit centers on Venice and
Washington Boulevards and that the proposed space for off-street
transit center is used to create more parking spaces that provide
more park-and-ride transit users better access to the interim
station Without this additional parking we do not feel the
1-6
Page 8 of 31Exhibit A
Culver City Redevelopment Agency Resolution No 2005-RA November 21 2005
proposed parking layout are adequate or in close proximity to the
interim design options
e Pedestrian path is not clearly identified in the station area plan To
ensure the safety of pedestrians and passengers, safe and direct
pedestrian routes with good signage and lightings must be
provided|109| Bus Service
a The FEIR does not address the impact Exposition LRT will have on
existing transit services Culver CityBus Lines 1 and 4 will be
heavily impacted by Exposition LRT due to their proximity to the
Venice/Robertson and La Cienega stations, while Culver CityBus
Lines 2 3, 5, and 6 will be impacted to some degree The potential
impact of necessary service increase to accommodate bus riders
brought in by Exposition LRT will require additional funding to
mitigate (pp 3 1-1 to 3 1-9)
b The FEIR anticipates that Culver CityBus will implement changes to
its bus services to serve the LRT stations These anticipated
changes include improved headway on Culver CityBus Lines 4 and
5, as well as terminating Culver CityBus Lines 1, 4 and 5 at La
Cienega Blvd or Venice/Robertson station These anticipated
changes are not included in the Culver City s Short Range Transit
Plan, and Culver CityBus does not currently have plans or funding
to implement these changes as anticipated in the FEIR Additional
funding would be required to implement change in service route
and frequency The FEIR should evaluate the feasibility and
funding source of these bus transit improvements (pp 3 1-4 to 3 1-
8)
c The FEIR does not explain why the daily fixed guideway boarding
for the Forecast Year 2025 is lower than that for the Forecast Year
2020 (42 900 and 43,600 respectively) (Table 3 1-8 on page 3 1-
7)
d The FEIR does not explain the rationale for quadrupling the bus
frequency for Culver CityBus Line 5 as this line is currently the least
used line in Culver CityBus system (Table 3 1-9 on page 3 1-7 to
3 1-8)
e Under Venice/Robertson Station section, Santa Monica BigBlue
Bus 12s peak headway (under No Project scenario) is 10 min, not
30 min as reported in the FEIR
f Under Venice/Robertson Station section, the subtotal of frequency
(for bus lines Metro 33 to Culver City 5) under 'No Project scenario
and the subtotal of frequency (for the same set of bus lines) under
Page 9 of 31
49Exhibit A
Culver City Redevelopment Agency Resolution No 2005-RA November 21 2005
With Project scenario are incorrect The grand total for both sets
of bus frequencies are also incorrect
g
Under La Cienega Station section, Culver CityBus Lines 1 and 4
are listed twice in the table
h Under La Cienega Station section, the subtotal for the bus
frequencies (for bus lines Metro 68 to Culver City 5) and the grand
total of bus frequencies under "No Project" scenario are incorrect
7 Bus Operation and Maintenance (O&M) Costs Table 5 1-6 on page 5 1-9
and Table 5 1-7 on page 5 1-10 indicate that the operating cost per
vehicle-hour for Culver City Municipal Bus is $81 79 in 2005 dollars
Culver CityBus current operating cost per vehicle-hour is $100 46 This
would significantly shift the range of incremental annual bus O&M cost for
Culver CityBus to higher than the range of $1 1 to $10 7 million dollars as
indicated in Table 5 1-7 Funding assistance is required to accommodate
the additional O&M costs associated with serving Exposition LRT stations
The FEIR should evaluate the feasibility and funding source for the
assumed bus service improvements
8 Ridership The FEIR indicates that the LRT Build Alternative will
consolidate the West Los Angeles Transit Center at the planned La
Cienega and Venice/Robertson LRT stations The area where La
Cienega station is located is heavily congested In order to expedite bus
service, it is necessary to have road improvements in this area, such as
adding exclusive bus lanes on La Cienega Boulevard Furthermore, if bus
lines are to be re-routed to terminate at either Venice/Robertson or La
Cienega stations, amenities (such as restrooms and vending machines)
for bus drivers must be provided at both stations (Page 5 2-2)
9 Bus Service The recommended future Locally Preferred Alternative
station area (ROW option stopping short of National) does not
accommodate any fixed route transit services Culver City, Santa Monica
and MTA buses will indirectly serve the station The closest bus stops are
on Washington Boulevard at National (CC Lines 1 and 4) The closest
MTA bus stops are on Venice Boulevard It does not appear that the MTA
will reroute buses to the station Since the MTA is the regional transit
provider it will be difficult to attract and transfer riders from the
surrounding communities to the LRT line without direct bus service to the
station Similarly there is no discussion regarding Santa Monica Bus Line
services (SMBL) What SMBL routes does the MTA expect to serve the
station and where will they stop? Would the SMBL Line 10 Freeway
Express leave the freeway and divert to the station'?
V
Page 10 of 31Exhibit A
Culver City Redevelopment Agency Resolution No 2005-RA November 21 2005
Traffic Issues
1 Executive Summary, Pages 34-36 Regarding Jefferson Boulevard Design
Options, Option B provides a grade separation bridge over La Cienega
Boulevard that ends short of Ballona Creek The LRT tracks cross
Jefferson Boulevard at-grade Option B requires an awkward connection
for eastbound bicyclists who cross Ballona Creek in the Class I bike path,
and then need to cross Jefferson Boulevard to reach the Class II bike
lane The crossing location for bicyclists shown in the Site Plan for Option
B would pose a safety concern due to potential conflicts with eastbound
motorists on Jefferson Boulevard who are negotiating a right-hand
horizontal curve The Medium Bridge Design Option carries the grade
separation over Ballona Creek and the National Boulevard/Jefferson
Boulevard intersection This provides for smoother traffic flow and a safer
connection between the Class I bike path and Class ll bike lanes For this
reason the Medium Bridge Design Option serves Culver City better than
Option B
2 Executive Summary Table S-4, Page S-2, and Page 3 2-12, Mitigation
Measure T2 We support Metro s contribution of $100,000 toward the
preparation of a study identifying the possible improvements and
reconfiguration of freeway ramps and connecting arterial streets to help
mitigate the impacts of a parking facility at Venice/Robertson station
However, the actual construction of improvements would be the mitigation
of any of the impacts Therefore, the proposed mitigation measure should
include the stipulation that above and beyond Metro s financial
participation as the regional transportation agency in any regionally
significant traffic improvement, Metro should also fund their proportional
share of any improvements to address any impacts of the proposed Mid-
City Exposition Light Rails Project
3 Executive Summary Table S-4 Page S-6 Table S-4, and Page 3 2-62
Mitigation Measure T16 The improvements listed in the Executive
Summary for T16 are not the same improvements listed on Page 3 2-62
Metro must provide an accurate and complete listing of mitigation
measures before certification of the Final EIR
4 Executive Summary, Table S-4, Page S-6 Mitigation Measure T19 It is
not clear from the discussion where the additional right-of-way required to
accommodate the proposed southbound right turn lane between Venice
Boulevard and Washington Boulevard will come from The Final EIR must
identify where the additional right-of-way well be obtained The City of
Culver City disagrees with the notion that providing additional lanes on
Washington Boulevard will mitigate the impacts of an at-grade crossing
Traffic at the intersection of Washington and National Boulevards will be
Page 11 of 31
6- 1Exhibit A
Culver City Redevelopment Agency Resolution No 2005-RA November 21, 2005
stopped in all directions when a Light Rail Vehicle (LRV) is approaching
and/or leaving the station regardless of whether the additional lanes are
installed However the installation of these additional lanes may help to
mitigate the impacts caused by increased LRT station related traffic
5 Executive Summary Table S-4, Page S-10 Mitigation Measure T20 This
mitigation measure, which would essentially convert the westbound right-
turn lane on Washington Boulevard into a through-and-right lane, appears
to be sufficient to mitigate the impacts of LRT for all Venice/Robertson
Design Options, but not the LPA at-grade crossing
6 Page 2 4-63, Countdown Pedestrian Crossing Traffic Signals The Final
EIR states that installation of countdown pedestrian signals is encouraged
for the intersection of Venice and Robertson Boulevards Countdown
signals should be required at all adjacent intersections serving the Venice
Robertson Station, transit stops and parking lots, such as Venice/National
and Washington/National intersections The countdown signals should
also be installed at the Washington/National intersection in the event an
east of National Boulevard Venice/Robertson Design Option is selected
7 Page 3 2-41, Section 3 2 4 2 1 Impact on Intersection Level of Service
The Final EIR does not discuss the potential impacts to intersection
operations from the potential surge of pedestrians leaving or arriving at the
station, especially at rush hour Such pedestrian surges could have a
negative impact on traffic movements and signal timing at the major
intersections As stated previously City Staff and consultants have had
follow-up discussions with Metro Staff Metro Staff has stated that they do
not expect that there would be unusually high pedestrian crossing
volumes at Venice Boulevard Due to the elongated configuration of the
proposed station parking to be located along the Metro-owned ROW
north/west of Venice Boulevard, Metro anticipated that pedestrian
crossings of Venice Boulevard would be dispersed between crossings at
Bagley/Main CulverNenice and Venice/Robertson during the peak travel
hour It should be noted that any pedestrian choosing to cross at
Bagley/MainNenice intersection would double their walking distance
Crossing at CulverNenice would also increase the walking distance but to
a leaser degree The shortest direct route would be to cross at the
Venice/Robertson intersection As such, Culver City Staff believe that
most pedestrians parking in the main lot north of Venice will cross at the
Venice/Culver intersection and if surges of pedestrians do occur there is
the potential for negative traffic impacts
City Staff is also concerned that in the event an east of National Boulevard
Venice/Robertson Design Option is implemented, the intersection of
Washington/National could be negatively impacted by such pedestrian
Page 12 of 31Exhibit A
Culver City Redevelopment Agency Resolution No 2005-RA November 21, 2005
surges Metro Staff has advised the City that a detailed level of analysis
would occur during the final design phase of the project when specific
parking lot locations and access points are finalized Providing adequate
pedestrian crossing times would be developed in coordination with Culver
City and Los Angeles However, the Final EIR does not include a
mitigation measure to require that such study be prepared and any
recommendations implemented Therefore, City Staff recommends that a
mitigation measure be adopted that requires preparation of a detailed
analysis during the final design phase of the project when specific parking
lot locations and access points are finalized, in order to identify signal
timing adequate pedestrian crossing times and identify any required
physical mitigation measures Such analysis and subsequent mitigation
measures should be funded and implemented by Metro in coordination
with and subject to the approval of the Cities of Culver City and Los
Angeles
8 Page 3 2-63, Mitigation Measures T17 through T21 These mitigation
measures should be revised to specifically state that the design and
physical improvements shall be reviewed and approved and completed
construction accepted by the City of Culver City prior to the beginning of
transit service to the Venice/Robertson Station
9 Page 3 2-66 The Final EIR acknowledges that implementation of the
Locally Preferred Alternative with at-grade crossings of Washington and
National Boulevards would reduce reliability of the LRVs
10 Page 3 2-69, Mitigation Measure T22 The mitigation measure should be
revised to state that the mitigation of project impacts should be
implemented within a reasonable and timely period The mitigation
measure should be revised to state that analysis of impacts and
implementation of required mitigation shall be accomplished within 180
days from the opening day of the Venice/Robertson Station The
mitigation measure should also be revised to specifically state that the
design and physical improvements shall be reviewed and approved and
completed construction accepted by the City of Culver City prior to the
beginning of transit service to the Venice/Robertson Station
11 Impact on Regional Travel Patterns (Page 3 2-7) It is unclear how the
regional benefits of the project will be achieved The FEIR lacks
specificity with regard to patronage and how it will be achieved There is
no discussion with regard to how many passengers are expected to drive,
kiss and ride or take the bus Where are the passengers coming from?
This information is critical to station area planning and for that matter all
of the access routes leading to the station
Page 13 of 31
-63Exhibit A
Culver City Redevelopment Agency Resolution No 2005-RA November 21 2005
12 Kiss-and-Ride How will kiss-and-ride passengers be accommodated?
Will they be dropped off on Washington Boulevard ? If so, where? What
pedestrian improvements will be provided for kiss-and-ride patrons and
pedestrians in general'?
Parking Issues
1 Executive Summary Page 36, regarding La Cienega Station Parking
Options, the City of Culver City opposes the No Parking Option , which if
implemented would potentially shift parking demand west into Culver City
This potential option and related impacts are not discussed in the parking
impact assessment (3 3 2, Pg 3 3-6)
2 Execution Summary, Table S-4, Pages S-11 through S-13, Proposed
Mitigation Measure P5 The Table acknowledges the potential for parking
spillover and intrusion into residential areas There is no detailed discussion
about what type of parking control will be employed to insure who is using the
parking facilities and how much parking is available on a real time basis to be
conveyed to patrons There is no detailed plan for how spillover/intrusion
impacts will be mitigated and who will bear the cost of implementing and
maintaining any required mitigations The potential problems seem to be left
to the City to resolve if they arise Typical mitigation measures cost the City
and individual residents on ongoing bases The proposed Mitigation
Measure P5, should specifically state that Metro shall be responsible for
paying for installation and maintenance of project relate mitigations
3 Page 3 3-1, Table 3 3-1 Loss of Off-Street West End According to this
table, 144 Off-street parking spaces will be eliminated as a result of the
project As stated in the Final EIR this loss "could and more likely would
increase demand for on-street parking in the area, including adjacent
commercial and residential areas The loss of these spaces and the potential
increased competition for on-street parking in the area of the
Venice/Robertson Station (i e, Exposition Boulevard) would force cars of
local employees and customers, and some transit riders, to seek parking in
the adjacent residential areas In order to address these potential impacts,
Mitigation Measure P1, must be revised to include station with parking
facilities to determine if spillover impacts are occurring and specific language
that Metro shall be responsible for funding implementation, ongoing operation
and enforcement of parking programs to reduce impacts on adjacent streets
4 Page 3 3-9 and 11, Section 3 3 2 3 Addition of Station Area Parking The
Final EIR notes in the LPA and Venice/Robertson Design Option, if
parking demand exceeds supply at the Venice/Robertson station, it can be
increased by extending the number of spaces within the METRO's ROW
Page 14 of 31Exhibit A
Culver City Redevelopment Agency Resolution No 2005-RA November 21, 2005
at the Venice Robertson site This parking does not allow direct or
convenient access for pedestrians between the station and any of the
proposed parking lots The spaces located north of Venice Boulevard are
about a quarter to a third of a mile away depending on were the station is
constructed Not only does this exceed the maximum recognized distance
people will walk from a parking space to a destination, but represents a
walking time of nearly ten minutes With 5 minute LRV headways it is
conceivable a passenger could park their car and not board a train for 15
minutes Assuming an average travel speed of about 25 miles per hour,
the 9 6 mile trip to downtown Los Angeles on the Expo line would be
about 23 minutes Travel time is one of the most critical factors in mode
choice This includes the time to drive to a station, transfer, travel and
then transfer at the work end The transfer/travel times starting at the
Culver City end are not a very attractive alternative to driving The
majority of the station parking must be located closer to the station
location If any of the Venice/Robertson Design Options are selected and
the station is locate east of National Boulevard, it is recommended that
proposed off-street transit center be replaced by on-street transit centers
(on Washington and Venice Boulevards) and that the proposed space for
off-street transit center be used to create more parking spaces that
provide more park-and-ride transit users better access to the interim
station|109| Page 3 3-10, 1 st Paragraph The Final EIR recommended in this
paragraph that on-street parking restrictions be installed along adjacent
streets to discourage parking by transit riders There is no detailed
discussion about what type of parking control should be employed to insure
who is using the parking spaces There is no detailed plan for how the
impacts will be mitigated and who will bear the cost of implementing and
maintaining any required restrictions The potential problems seem to be left
to the City to resolve if they arise Typical mitigation measures cost the City
on ongoing bases The proposed Mitigation Measure P1, should specifically
state that Metro shall be responsible for paying for installation and
maintenance of project relate parking restrictions
6 Page 3 3-10 and 11, Mitigation Measures P1 and P5 Other than the
statement in P5 after opening day neither mitigation measure states
specifically when analyses of impacts/parking demand and
implementation of mitigations shall occur The mitigation of project
impacts should be reasonable and timely The mitigation measures
should be revised to state that analysis of impacts and implementation of
required mitigations, subject to City of Culver City approval, shall be
accomplished within 120 days from the opening day of the
Venice/Robertson Station
Page 15 of 31 5.0C.
s
Exhibit A
Culver City Redevelopment Agency Resolution No 2005-RA November 21, 2005
7 Page 3 3-13, Venice/Robertson Design Option States that a parking shuttle
system would be required However, the Final EIR does not include a
mitigation measure for the implementation and ongoing operation and
maintenance of a shuttle system In addition, the Final El R further states that
even with a shuttle system operating, parking spillover into east Culver City
streets will occur While the discussion notes that Mitigation Measure P1
would be necessary to reduce the potential impacts P1 does not include
station with parking facilities and there is no discussion of who would be
responsible for the ongoing operation and maintenance of a shuttle system
and operation and enforcement of parking programs to reduce impacts on
adjacent streets Mitigation Measure P1, must be revised to include station
with parking facilities to determine if spillover impacts are occurnng and
specific language that Metro shall be responsible for funding ongoing
operation and maintenance of a shuttle system and operation and
enforcement parking programs to reduce impacts on adjacent streets
Visual Quality Issues
1 Page 4 4-48, Mitigation Measure V15 The mitigation measure should be
revised to state that lighting on the Transit Parkway shall be directed away
from adjacent private property and designed to reduce spillover impacts
Noise and Vibration Issues
1 Absorptive sound walls Metro has indicated that based on the projected
increase in noise levels for residences on the north side of National
Boulevard and the amount of noise mitigation required at this location to
meet Federal criteria, standard noise barriers (rather than absorptive walls)
have been recommended Absorptive barrier walls are normally used to
reduce the bounce that is often created when sound barriers bounce noise
in the opposite direction thereby causing secondary noise impacts In the
case of National Boulevard the sensitive residential receptors are
exclusively located on the north side of the street and industrial or highway
uses are located on the other side Metro indicated that no further benefit to
the homes on the north side of the street would be provided by absorptive
treatments on the wall and the noise created by National Boulevard itself
seems to eliminate any benefit from the provision of absorptive treatments
to the uses on the predominantly commercial uses on the south side of the
street
It is true that absorptive soundwalls reduce the bounce of sound back
toward the source This is why absorptive soundwalls are more effective at
reducing noise from trains operating in close proximity to the soundwalls
Page 16 of 31Exhibit A
Culver City Redevelopment Agency Resolution No 2005-RA November 21, 2005
The sound generated by the passing train is bounced between the reflective
soundwall surface and the reflective side of the LRT vehicle, thus degrading
the acoustic performance of the soundwall An absorptive soundwall does
not exhibit this degradation that results from an increase in virtual sound
source height and a reverberant field build-up of train noise Also, focusing
on any residual benefit to the south-side commercial land uses regarding
noise from National Boulevard misses the point Because of the site
geometry, with houses located north of the Exposition Line and National
Boulevard, an acoustically absorptive soundwall could provide a beneficial
project effect by reducing noise impact from National Boulevard traffic on
these north-side residences In addition to better reducing train pass-by
noise, this beneficial effect would continue during periods of no trains
2 Executive Summary Page 53, Last Paragraph This paragraph includes a
statement that Special studies will be conducted as part of the Final
Design to direct warning device noise away from sensitive receptors
Pages 4 6-32 through 34, list the noise and vibration mitigation measures,
none of which relates to the above statement A new mitigation measure
should be added to a noise and vibration mitigation measure to prepare
the special studies described on Page 53
3 Page 24-15, 1 st Paragraph The Final EIR description of the LPA West
End states that landscape berms would face the ballasted LRT trackway
so that these berms act as screening of the trackway from residential
areas as well as acting as a sound buffer against LRT noise Figure 2 4-
13 Cross Section S Fay Street to Wesley Street (no page number), as
well as the Partial Site Section West of Fay Avenue near Wesley Street on
Executive Summary Page 43, indicate what appears to be a soundwall
between the trackway and the landscape berm According to Mitigation
Measure NV1 on Page 4 6-32 last bullet, the soundwall is to be
constructed on the north side of the ROW The City is concerned that if
a soundwall is installed as shown on Figure 2 4-13, the Bike Path area
would be screened from view from National Boulevard Lack of visibility of
the Bike Path could result in low use and increased security concerns
4 Noise and Vibration Chapter 4 6 needs to identify the exact location of Site
V-4, where ground vibration was measured
5 Page 4 6-3 last paragraph says that "monitoring results were
"generalized Please clarify what is meant by and what process was
used to generalize' results
6 Page 4 6-7 first paragraph Please define 'while gates are active", does
this mean throughout entire pass-by while gates are down?
Page 17 of 31
54-Exhibit A
Culver City Redevelopment Agency Resolution No 2005-RA November 21 2005
7 Page 4 6-7 Impact Criteria — Noise Criteria refers to Federal only, CEQA
requires applicable state and local criteria be utilized as well Were state
and local standards evaluated and applied as well?
8 Page 4 6-11 3rd Paragraph The reference maximum sound level of 77
dBA at 50 feet from track centerline (over soft ground) was used There is
no statement whether this sound level is consistent with actual revenue
operation measurements of similar trainsets operating on the Green Line
and Gold Line branches It is our understanding, based on independent
measurements (conducted by three different consultants and Metro), that
the P2000 trains generally exhibit higher in-service noise emission than
what their specifications promise Is the reference level of 77 dBA Lmax
consistent with the "in-service sound level measurements of P2000
trainsets operating on the other Metro lines ? Also, most urban
environments (including Culver City) have hard ground between the
tracks and sensitive receptors yet the analysis assumed propagation over
"soft ground" What correction factor was applied to the analysis to
account for this discrepancy?
9 Page 4 6-11, 5th Paragraph In a recent decision involving the Gold Line
grade crossing bells, the California Public Utility Commission (CPUC) has
approved setting the bells to sound at a level of 75 dBA at a reference
distance of 10 feet Will the project s proposed Audible Warning Devices
be modified to reflect this CPUC decision?
10 Page 4 6-11 last paragraph and Page 4 6-12 first paragraph These
sections are not consistent with earlier discussions regarding the duration
of gate bells and again raises the issue of gate bell sound level
11 Page 4 6-12 3rd Paragraph The assumption that the 75 dBA quacker
would be sounded provides an inadequate analysis if, in fact, the 85 dBA
warning device will be regularly used The Final EIR does not provide
analysis of the potential for the frequency of use of the 85 dBA warning
device and/or how the project has been designed to reduce the likelihood
of the louder warning device needing to be used
12 Page 4 6-14 last line from LRV should go after impacts
13 Page 4 6-16 third paragraph The correct technical term would be "damp
as in to reduce the amplitude and duration, not 'dampen as in to make
wet
14 Page 4 6-15 1st Paragraph Table 4 6-7 Summary of Residential Noise
Impacts, states that 14 single family residences on the north side of
National Boulevard between Fay and Helms Avenues would be impacted
Page 18 of 31
56Exhibit A
Culver City Redevelopment Agency Resolution No 2005-RA November 21, 2005
(10 Impact/4 Severe) from air-borne noise from LRVs Appendix J does
not contain detailed maps showing where these noise (and vibration)
impacts would occur along the alignment Metro must provide the detailed
maps identifying the effected residences before final design of noise
mitigation is approved
15 Page 4 6-18 1 st Paragraph Based on previous experience with P2000
LRV both on aerial structure and at grade (viz, Green Line near Douglas
Station and Gold Line through South Pasadena) the estimated barrier
heights discussed in the FEIR are slightly low The aerial barriers should
be 6 feet high from the viaduct surface and the at-grade soundwalls
should be approximately 8 feet above grade It would be more accurate to
specify soundwall heights referenced to top-of-rail There are no
calculations provided for the proposed soundwall s acoustical
performance Please provide the calculations A discussion of acoustically
absorptive soundwalls is absent and should be provided
16 Page 4 6-19, Table 4 6-10 Regarding the Height (ft) column and the
Notes in the table same comment as above regarding the height of
proposed soundwalls One on-viaduct barrier is listed as 4 feet high, this
would only be one to two feet above the source height and its
performance would be questionable Please provide the calculations for
the proposed soundwall s acoustical performance
17 Page 4 6-19, 2 nd Paragraph It is asserted that barriers will reduce
quacker noise by 8 dBA The Final EIR does not include any calculations
for this Insertion Loss Please provide these calculations
18 Page 4 6-19 third paragraph We recommend that this paragraph be
revised to reflect the recent order by the CPUC and the terms of the
approved Gold Line Settlement Agreement regarding grade crossing bell
noise levels and directivity
19 Page 4 6-21 third paragraph Please insert a reference to Table 4 6-12'
20 Page 4 6-23 Table 4 6-12 Last entry, ("489 ) Contents of the Table are not
consistent with text on page 4 6-24 first paragraph
21 Page 4 6-24, 1 st Paragraph Location 489 is identified as experiencing
impacts However, unlike Locations 213 and 486, no proposed mitigation
for Location 489 is presented Due to the proximity of residential,
institutional and the identified recording studio uses to Location 489, a
mitigation measure for the installation of spring-rail frog crossover switch
must be adopted to address the potential impact
Page 19 of 31
5-9Exhibit A
Culver City Redevelopment Agency Resolution No 2005-RA November 21, 2005
22 Page 4 6-26, 8th Paragraph The vibration screening procedure in FTA,
1995 shows potential adverse effects for Category 1 uses at a distance of
450 feet and for Category 2 at 150 feet These distances are known to be
conservative and that is why the General' and "Detailed" methods are
also available in FTA, 1995 However the Final EIR states the threshold
used for Category 1 uses is 100' instead the FTA criteria of 450 The
difference between 450 feet and 100 feet in the Final EIR/EIS is not trivial
Thus, we would like to review the vibration calculations associated with
the Hayden tract the recording studio, and the row of residences
(Category 2) that back up to the proposed track along National Boulevard
in Culver City before final design and any mitigation is approved
23 Page 4 6-27, "Vibration Attenuation Methods While a comprehensive
laundry list of available vibration reduction approaches is presented here
in the EIS, none of the mitigation measures numbered 1 through 5 are
provided in Culver City Pursuant to NEPA, CEQA and court guidelines,
the EIR/EIS must contain a reasoned prediction of the likelihood that a
particular or any range of mitigation will be incorporated into the project
Discussion should be provided regarding the reasonableness and
feasibility of incorporating various levels or types of vibration mitigation
24 Page 4 6-28, Table 4 6-14 The table is not consistent with the discussion
of vibration mitigation It makes no reference to mitigation #6 nor lists any
track location within Culver City Also, notwithstanding Note /a/ in the
table, the comment supra applies to the Vibration Attenuation Methods
column in the table
25 Page 4 6-28, Venice/Robertson Design Options There is no discussion
about the potential impacts of the other options in this grouping if Option A
is not selected However, Mitigation Measure NV8 (Page 4 6-34), which
appears to be proposed to address the Option A impacts does not
specifically state if the measure is contingent on any specific option being
implemented Therefore, Metro will be required to perform the noise and
vibration assessment regardless of which design option is selected
26 Page 4 6-28, Venice/Robertson Design Option According to this
discussion significant vibration and ground-borne noise impacts are
projected for the recording studio located to the north of the right-of-way
The Final EIR states that the project shall be required to fully mitigate the
impacts However, Appendix J does not identify the specified recording
studio as impacted
27 Page 4 6-32, Mitigation Measure NV1 There has been some "relaxation
of the proposed mitigation measure between the DEIS and the FEIR/EIS
as it relates to the proposed height of the sound wall along the northern
Page 20 of 31Exhibit A
Culver City Redevelopment Agency Resolution No 2005-RA November 21 2005
boundary line of the right-of-way along Fay Avenue to Wesley Street The
2001 Draft EIS/EIR on page 3 9-20, (2nd bullet), stated that to be effective
the at-grade walls must be 8 feet high' However, the Final EIR (NV1, 7th
bullet) is now proposing this wall be six feet tall We believe this to be
lower than adequate for at-grade soundwalls in this location The
soundwalls should be increased in height to eight (8) feet
28 Page 4 6-35 Ground-borne Vibration Mitigation Measures' This
paragraph does not, and should state that Mitigation Measure NV8 (Page
4 6-34) is required due to the potential for impacts to the recording studio
on Wesley Street In addition, this paragraph should include discussion of
the impacts to the recording studio discussed on Page 4 6-28,
Venice/Robertson Design Options
29 Culver City recommends that Rubberized Asphalt Concrete (RAC), open-
graded friction course (Quiet Pavement) should be used for the
construction of the realignment of National Blvd that is required by the
project and furthermore that the entire stretch of National Blvd between
Jefferson and Washington that is not part of the reconstructed section of
the roadway should be overlayed with a minimum of 2 of RAC RAC has
a proven track record in reducing the noise levels on roadways by as
much as 4 to 10 db This noise reduction would help offset the additional
noise caused by LRT operations and would augment other proposed
noise mitigation measures
30 Page 4 6-32, NV-1, last bullet Please provide barrier calculations for the
soundwall between Fay Avenue and Wesley Street on the north side of
RNV
31 Page 4 6-33 continuation of NV-2, first bullet Please describe in more
detail the proposed or potential treatment(s)
32 Page 4 6-34 NV-7 Table 4 6-14 does not list Culver City locations
33 Pile driving vs drilling (Pg 4 15 — 25) C-22 Metro guidelines allow for pile
driving 250 feet or more away from residences yet at p 4 15 — 13 the
FEIR indicates that piles shall be drilled not driven Which is correct'?
34 The City recommends that the pedestrian crossing over the LRT track at
Wesley Street be eliminated in favor of a pedestrian path that will take
residents around the west end of the station and connect to the proposed
pedestrian/bike path north of the station at Wesley
Page 21 of 31
(94Exhibit A
Culver City Redevelopment Agency Resolution No 2005-RA November 21, 2005
Geology, Soils, and Seismicity
1 Page 4 7-2 Alquist-Pnolo Fault Hazard Zones The text on this page
erroneously states that the zone in the area of the project is located
southeast of the intersection La Cienega and Washington Boulevards,
when it is actually southwest of the intersection However, the text
correctly states that the zone crosses the Exposition right-of-way in the
area of National Boulevard and Fay Avenue In addition, Figure 4 7-2 on
Page 4 7-4 also indicates that the zone crosses the right-of-way
2 Page 4 7-6 through 11 Any impact assessment and mitigation measure
discussion of an aerial station should include the approach structures over
Washington, National and Jefferson Boulevards and Ballona Creek
Water Resources
1 Page 4 9 3, Section 4 9 1 8 State Regulatory Framework The reference
to the project size threshold for triggering coverage under the General
Construction Storm Water Permit is based on outdated information The
size threshold has been lowered from 5 acre and greater to 1 acre and
greater The Final EIR erroneously states the outdated size threshold in
various places in the document and should be revised appropriately
2 Page 4 9 3, Section 4 9 1 8 State Regulatory Framework The Final EIR
does not discuss in this Section the General Industrial Activities Storm
Water Permit (GIASP) requirements and their applicability to this project
Due to the scope of the project, once in operation it is likely that it will be
subject to the GIASP or an individual stormwater NPDES permit for its
discharge of stormwater to the municipal storm drain system
3 Page 4 9-4 Maintenance of the Water Quality of Municipally Separate
Storm Drainage Systems This Section should have reference the
requirements in the LA MS4 Permit that specifically pertain to this project-
' e for the construction and post-construction phases For example
Under the Permit, City must ensure that the quality of the discharges
entering its storm drain system, including those from construction site,
meets the Maximum Extent Practicable (MEP) level by enforcing local
Storm Water Pollution Prevention Plan requirements and by conducting
inspections to verify the adequate implementation of Best Management
Practices (BMPs) This section should also have reference the Standard
Urban Stormwater Mitigation Plans (SUSMPs) which are a set of
development planning requirements that apply to specific categories of
development and redevelopment projects The SUSMPs requirements
are aimed at controlling pollutants generated from developed or
redeveloped sites after construction activities have been completed In
(a
Page 22 of 31Exhibit A
Culver City Redevelopment Agency Resolution No 2005-RA November 21, 2005
addition to the Waste Discharge Requirements (WDR) for Specified
Discharges to Groundwater in the Santa Clara River and Los Angeles
River Basins, the EIR should have specified a similar WDR for Ballona
Creek if there is a reasonable expectation of similar discharge entering
Ballona Creek Mitigation Measure WR1 should be amended to
specifically state that Metro shall prepare all analysis and plans and
implement all measures to comply with all relevant Federal State and
Local stormwater regulations
4 Page 4 9-9 Page 4 16-9, Mitigation Measure 0M3 states that A
drainage plan shall be developed and implemented which shall ensure
that the Division 11 facility is engineered to direct water runoff into
appropriate drainage culverts and channels Mitigation Measure WR1
must be revised to include the same requirements to insure that if existing
storm drain inlets/catch basins located in the vicinity of the project are
inadequate to properly convey the runoff from the Exposition transit way
additional catch basins should be constructed to prevent potential
flooding The drainage plan shall be developed after careful consideration
of the capacity of the existing storm drain system and the impact of the
additional volume on the Ballona Creek and the Estuary The City of
Culver City shall be consulted during the development of the drainage
plan and the plan and recommended improvements shall be subject to the
City s review and approval
His toncal, Archaeological, and Paleontological Resources |109| Execution Summary Table S-4, Page S-48, Jefferson Boulevard Design
Option The Ballona Creek Railroad bridge is identified as a historic
landmark and is proposed to be left in-place and incorporated into the Project
design However, The Final EIR does not include a mitigation measure to
address who will be responsible for the ongoing maintenance
Construction Impacts
1 Page 4 15-5, 4 15 1 3 6 Bridge Construction Nighttime construction is
anticipated to occur at La Cienega Station over street This has the
potential to result in noise impact on Culver City residence Culver City
and the East Culver City and Rancho Higuera Neighborhood
representatives should be advised of anticipated nighttime construction
periods and contact numbers
2 Page 4 15-10, Section 4 15 3 2 Parking, Mitigation Measure C5 — The City
of Culver City shall be the only approval authority for on-street contractor
employee parking within the City
Page 23 of 31
GSExhibit A
Culver City Redevelopment Agency Resolution No 2005-RA November 21 2005|109| Page 4 15 — 16, Mitigation Measure C42 Enforcement on construction sites
in Culver City shall be by Culver City Police Department
4 Page 4 15-18, Venice/Robertson Design Option - The Aerial Station
option would potentially require lane closures over National Boulevard, not
just Washington Boulevard as stated in the Final EIR
5 Page 4 15— 25, Impact pile driving According to Page 4 15— 13, Mitigation
Measure C22, Metro guidelines only allow pile installation by drilling Metro
must clarify which technique for pile installation will be used before the Final
EIR is certified
6 Level of Significance In the construction impact assessment section (p
4 15-8) the EIS/EIR states With implementation of mitigation measures
itemized below, no substantial adverse construction impacts are
anticipated However elsewhere in this section (e g , traffic at p 4 15-17)
the document states Although the impacts would be temporary, they
would be considered significant These sections of the document are
inconsistent and should be revised to indicate whether construction
impacts would be mitigated to a level of insignificance
7 Traffic In the discussion of traffic mitigation measures (p 4 15-9) the
document indicates that Metro is working closely with the City of Los
Angeles and Culver City in developing construction mitigation plans
CEQA requires that mitigation measures be disclosed in the Draft EIR yet
this document is a proposed Final EIR and the details of construction
mitigation plans have still not been determined For example, haul routes
and hours of operation have not been identified (Section 4 15 3 1
Mitigation Measure Cl) The effectiveness and adequacy of mitigation
measures cannot be determined if they are not revealed by the lead
agency The document should be revised to identify specific mitigation
measures for construction traffic impacts
8 Parking In the discussion of parking mitigation measures
(p4
15-10),
there is no attempt to quantify the temporary loss of parking yet the
document concludes that these mitigation measures (e g interviewing
business owners) would mitigate impacts to less-than-significant levels
Without identified thresholds for significance, it is not possible to
determine whether this conclusion is justified
9 Noise and Vibration The mitigation measures for noise and vibration
include monitoring (C16) and examples of noise reduction techniques
(C17-26) but no criteria or performance standards are identified While
monitoring is an important aspect of mitigation, it is not sufficient without
further identification of clear performance standards and enforcement
Ui
Page 24 of 31Exhibit A
Culver City Redevelopment Agency Resolution No 2005-RA November 21, 2005
procedures Some mitigation measures contain weak language such as
Metro may require contractors (C18) and If temporary sound
barriers are required to meet City noise regulations, Metro shall review
sound barrier designs prior to implementation (C25) (emphases added)
These deficiencies should be corrected prior to certification of the Final
EIS/EIR
Bikeway and Bikeway Facilities
1 Page 2 4-26 and 27 Design Option B and C Under each of these options
the Final EIR states that the Class I bikeway would connect to a Class III
bikeway at Wesley Street According to the preliminary design studies
provided to the City by Metro, the Class I bikeway would connect to a Class
III bikeway at Helms Avenue Metro must clarify which is correct before
selecting any design options
2 Page 2 4 — 47, West End According to the Final EIR the proposed Bike Path
ends at Wesley and bicyclists would be directed to use crosswalks to the
Venice/Robertson Station or directed to use National Blvd to access the
Venice Boulevard Bike Lane There is no further discussion of the
appropriateness of directing bicyclist to National Boulevard for purposes of
connecting from the Bike Path to/from the Venice Boulevard Bike Lane
There is no discussion of what, if any, physical improvements would be need
on National Boulevard to accommodate this potential increased activity The
City recommends that Metro adopt a mitigation measure which requires that
Metro prepare a bicycle and pedestrian access plan that analyses the
selected design option for the Venice/Robertson Station, associated parking
lots bikeway connections and access to/from each in order to identify the
required implementation improvement necessary to provide safe access and
egress The proposed bicycle and pedestrian access plan should be
required to be prepared prior to the final design for the project is approved
3 Page 2 4 —47 The Bike Path is proposed to be 12-feet wide and is intended
to accommodate both bicyclists and pedestrians The Bike Path as it is
currently envisioned intersects and incorporates existing and relocated
sidewalk areas of cul-de-sacs at the end of Wesley Street, Helms and
Caroline Avenues The City is concerned that Metro s plans as proposed
are creating a potential hazardous conflict between pedestrian and bike
path users Specifically the concern is about the interface between the
public sidewalk in these locations and the Bike Path at the end of the cul-
de-sacs The Bike Plan should be designed to eliminate these potential
conflicts and to provide separate sidewalk area and if not separated
adequate notice and warning of the potential hazard
Page 25 of 31
65-Exhibit A
Culver City Redevelopment Agency Resolution No 2005-RA November 21, 2005
In addition the City of Culver City will require that all cul-de-sacs modified
and/or relocated as a part of the project shall be reconstructed to at a
minimum be restored to turning radius no less then the existing cul-de-sacs,
or better if possible All cul-de-sac design and construction shall be reviewed
and approved by the City prior to acceptance by the City
4 Page 2 4-53, Bikeway Features, 2' Paragraph The Final EIR discusses the
use of applied surfaces on the Bike Path to create warnings and to instruct
cyclist to slow down for intersections and transitions These surfaces would
be applied using traffic paint or thermal plastic film Any applied material
should not create a slipping hazard and should be approved for bikeway use
in wet conditions
5 Page 7-116, Last Paragraph The first sentence of this paragraph would lead
the reader to believe the Class I Bike Path would connect directly to the
Venice Boulevard Class II Bike Lanes This is not the case under any of the
proposed station options At the least cyclists would be required to negotiate
very challenging regionally serving intersections (i e, Washington/National
Venice/Robertson and/or Venice National) Depending on which station
design option is selected, cyclist would also be required to exit the Bike Path
at Washington Boulevard, Wesley Street or Helms Avenue None of these
streets currently are designated bikeways As both Wesley Street
(commercial) and Helms Avenue (residential) are narrow streets (curb to curb
width of approximately 32 to 34 feet), with parking on both sides, it is unlikely
that either would be generally used for a designated Class III Bike Route
National Boulevard was discussed as a potential route for connecting from
the Bike Path to/from the Venice Boulevard Bike Lane However, there is no
discussion in the Final EIR of what, if any physical improvements would be
needed on National Boulevard to accommodate this potential increased
activity The City recommends that Metro adopt a mitigation measure which
requires that Metro prepare a bicycle and pedestrian access plan that
analyzes the selected design option for the Venice/Robertson Station
associated parking lots bikeway connections and access to/from each, in
order to identify the required implementation improvement necessary to
provide safe access and egress The proposed bicycle and pedestrian
access plan should be required to be prepared prior to the final design for the
project is approved
6 Page 7-117, 1 st Paragraph This paragraph erroneously states that the Class
1 Bike Path would not be accessible from north-south neighborhood streets
According to Metro s Preliminary Engineering Drawings issued June 3, 2005,
the Bike Path would directly connect to each street from Fay Avenue to
Wesley Street The Bike Path is intended to also serve as the primary
pedestrian path between the East Culver City and Rancho Higuera
Neighborhoods
Cl o
Page 26 of 31Exhibit A
Culver City Redevelopment Agency Resolution No 2005-RA November 21 2005
7 Clean Mobility Center (Appendix H) A CMC is slated to be built at the
Venice/Robertson station There are staffing and amenities such as
restroom and bicycle facilities associated with the CMC What will this look
like and where will it be placed as a part of any Venice/Robertson design
options'? Culver City would like to review and approve the final design and
location of the CMC (See the complete list of features in Appendix H)
Culver City Redevelopment Agency Issues
1 The Final EIS/EIR fails to properly address the significant impacts of the
Project due to inconsistency with the Culver City Redevelopment Agency
( 'Agency") Redevelopment Plan and the Design for Development for the
Exposition Light Rail Transit and Station Area ("DFD ) (including their
incorporation of applicable policies of the City s General Plan) by
proposing the at-grade crossing for the Project As explained further
below, the Agency has concurrent jurisdiction over this Project with the
Metro and Metro cannot ignore this concurrent jurisdiction The
Redevelopment Plan and DFD prohibit at-grade crossings Therefore, the
proposal of an at-grade crossing makes the Project inconsistent with all of
the above-mentioned Plans Metro has failed to analyze this
inconsistency, which amounts to a significant effect on the environment
and must be mitigated
Section 4 1 2 1 ( Land Use/Neighborhoods") Metro argues that Culver
City would not have jurisdiction over the Exposition LRT's crossings, and
the Culver City General Plan would no longer be applicable with respect to
the Project Further, Metro explains that since Culver City does not have
jurisdiction over the Exposition LRT s crossing the Culver City General
Plan is not applicable and there is no significant impact on land use as a
result of the Project s inconsistency with the Culver City's General Plan
As acknowledged in the Final EIS/EIR, the Project is within the
jurisdictional boundaries of the Redevelopment Plan for the Culver City
Redevelopment Project Pursuant to state law and as stated in the
Redevelopment Plan, the Project improvements must conform to the
City s General Plan and Redevelopment Plan The proposed at-grade
crossing is in conflict with those plans Under the California Community
Redevelopment Law, the station is proposed to be constructed within a
Redevelopment Component Area that was adopted through the authority
of state law The Redevelopment Plan for Culver City provides direction
for this area and states very clearly that both public and private developers
must conform to the Redevelopment Plan and any Design for
Development Further, after extensive public comment and input, the
Agency adopted the DFD, which prohibits at-grade crossing
Page 27 of 31
69-Exhibit A
Culver City Redevelopment Agency Resolution No 2005-RA November 21 2005
Agency, as a state agency empowered under the California Community
Redevelopment Law, has concurrent jurisdiction over the area impacted
by the Project within the Culver Redevelopment Project Area along with
Metro and the Public Utilities Commission ( PUC ) Under Orange County
Air Pollution Control District v Public Utilities Commission (4 Cal 3d 945),
the California Supreme Court found that the authority conferred on the
PUC to grant permission to construct and operate privately owned electric
generating units was concurrent with authority conferred on an air
pollution control district to condition construction of such unit on
compliance with district emission control standards Based on that, the
court found that the PUC did not have exclusive jurisdiction in this case
and that the air pollution control district had authority to regulate the
generating units
The air pollution control district is a state agency controlled by a local
governing body (board of supervisors) Similarly, the Agency is a state
agency also controlled by a local body The same logic the court used in
the above-mentioned case is applicable to this situation and Agency s
authority to review the Project The Agency has concurrent jurisdiction
with the PUC and Metro and has authority to review and approve the
Project Therefore, Metro cannot ignore the Redevelopment Plan and
DFD, both of which incorporate the City s General Plan policies for this
Project Metro must address how it will comply with these regulations, and
analyze the inconsistencies between the Project and the potential
significant environmental effects that occur as a result of these
inconsistencies
In furtherance of the argument that Agency has concurrent jurisdiction
over this Project is that fact that Metro is attempting to show benefit from
the Project by connecting to the Culver City Design for Development Area,
but refuses to acknowledge the need to comply with the requirements of
that same Design for Development Throughout the Final EIS/EIR Metro
acknowledges the involvement of the Agency In the Final EIS/EIR
Executive Summary, Page 68, under the Venice/Robertson heading
Metro describes the area being served by the Venice/Robertson Station
Metro specifically states that the Venice/Robertson Station is adjacent to a
site of potential mixed-use transit-oriented development at Venice
Boulevard, National and Exposition Boulevard, proposed by the Agency
Metro not only acknowledges the involvement of Agency in the Project but
also admits to the direct impacts of the Project to the City and Agency In
Section 7 18 ("Land Use' ) of the Final EIS/EIR, the Metro, in describing
how the Project is consistent with the 2001 Regional Transportation Plan
and policies, lists under Activity Centers other activity centers that will be
connected by the Project (such as Western Avenue Neighborhood and
(s.
Page 28 of 31Exhibit A
Culver City Redevelopment Agency Resolution No 2005-RA November 21 2005
Crenshaw District) and includes in this list reference to Culver City Design
for Development Area This is in contradiction to Metro s earlier statement
that because the PUC has exclusive jurisdiction over Light Rail Transit
( LRT ) crossings (including those LRT crossings of Culver City s streets)
that Culver City would not have jurisdiction over the Project and Culver
City General Plan would not be applicable with respect to the Project
The Final EIS/EIR is based on inadequate analysis because of the faulty
legal assumptions that the City s General Plan is not applicable and
Metro's complete disregard of the need for Agency approval of the Project
Metro does have to take into account the City s General Plan, which
standards and policies are incorporated in the Redevelopment Plan and
DFD Because Metro has failed to do so, there is a significant impact
which was not addressed nor mitigated Because the Final EIS/EIR does
not address these significant effects, it cannot be utilized without the
proper analysis and mitigation measures
2 The Final EIS/EIR incorporates a substantial number of individual
significant changes and new or modified analysis which collectively result
in significant changes to the Draft EIS/EIR since its circulation for public
comment
a Section 2 3 ("Los Angeles Mid-City/Westside Transit Corridor Draft
EIS/EIR') In describing the baseline analysis for the Project, Metro
states the Notice of Preparation was filed on May 8, 2000 and also
refers to the 2001 Regional Transportation Plan, which was adopted
after the Notice of Preparation Therefore, the Draft EIS/EIR used 2001
as the baseline year for analyzing impacts of the Project The Draft
EIS/EIR was originally circulated in 2001 and the Final EIS/EIR was
released in 2005 With the lapse of a total of four years between the
Draft and Final versions of the EIS/EIR, analysis with respect to
impacts such as traffic is outdated During these four years additional
projects have been developed and others are being proposed in this
area, not realized at the time of the Draft EIS/EIR and have not been
adequately analyzed and could not consider the cumulative impacts of
local projects from 2002-2005
b Section 3 3 2 2 ( Traffic ) Metro states that it worked closely with the
Los Angeles Department of Transportation (LADOT) to address their
comments and concerns and as a result, Metro entirely revised the
traffic analysis methodology for use in the Project impact analysis
Both the methodology and data significantly changed from that used in
the Draft EIS/EIR circulated to the public
Page 29 of 31
0Exhibit A
Culver City Redevelopment Agency Resolution No 2005-RA November 21 2005
3 Additional data and analysis is required regarding other important impacts,
including complete consideration and analysis of all Culver City schools
impacted impacts of at-grade crossing to surrounding parks impacts of
lack of adequate parking at the stations, and, addition of turn lanes and
the impacts of installation of turn lanes at particular intersections These
concerns are more particularly addressed in the paragraphs below
a Section 4 14 ("Parkland & Community Facilities") The Final EIS/EIR
provides a table (Table 4 14-3) summarizing the impacts to community
facilities within one-quarter mile of the Project under the Locally
Preferred Alternative ( LPA ) In this table, Turning Point is listed as
not being within one-quarter mile of the Project and therefore would not
be impacted While this is true for the LPA, this would not be true for
the Venice/Robertson Design Options The Venice/Robertson Design
Options would bring Turning Point within one-quarter of a mile of the
Project In addition, the Final EIS/EIR provides in footnote /g/ in
Table 4 14-3, that loss of parking at Turning Point Elementary is not
considered an adverse effect because the parking lot land is being
leased to the school by Metro However the Final EIS/EIR does not
address that there will still be impacts as a result of the
Venice/Robertson Station and an increase in the number of cars and
parking in the surrounding neighborhoods as a result of the Project,
regardless of this lease agreement with Metro The impacts and any
mitigation measures for the Venice/Robertson Design Options should
be addressed in the Final EIS/EIR
b Section 4 11 4 (Land Use/Neighborhoods ) Metro states that it will
work with Culver City and it's stakeholders to investigate transit
oriented and joint development opportunities It is unclear in the Final
EIS/EIR if this is a mitigation measure proposed by Metro The Final
EIS/EIR fails to state how this mitigation measure will be implemented
There is no discussion in the Final EIS/EIR of this as a mitigation
measure and how it will diminish the possible significant environmental
effects Metro should explain whether or not this is a proposed
mitigation measure and how it plans to implement it as a mitigation
measure
c Section 4 11 4 ( Land Use/Neighborhoods ) Metro states that the
LRT alignment on the bridge structure over Ballona Creek (designed
so that the LRT alignment and bridge structure touchdown at-grade
before the first single-family house at Fay Avenue) and the elimination
of all at-grade vehicular crossings from Fay Avenue to National
Boulevard, including the existing crossing at Hayden Avenue, would be
consistent with Culver City s General Plan policy of prohibiting aerial
and at-grade LRT alignments in front of residential areas in Culver
it
Page 30 of 31Exhibit A
Culver City Redevelopment Agency Resolution No 2005-RA November 21, 2005
City However there is no discussion or analysis with respect to the
impacts of the local adjacent parks near these residential
neighborhoods The impacts to the parks as a result of this alignment
should be addressed in the Final EIS/EIR
d Section 3 3 2 3 ( Parking ) Metro states that there are sufficient areas
to meet parking demand at each station location for Venice/Robertson
and Crenshaw Metro points to both Venice/Robertson and Crenshaw
as satisfying the anticipated demand in surface parking areas, while a
six-level parking structure is needed at the La Cienega station
Currently at these proposed sites the areas do not seem well suited
for placement of parking An explanation should be provided describing
where and how these surface parking areas will be provided for these
stations and any potential impacts which may result and any possible
mitigation measures to lessen the impacts
e Section 3 2 4 3 ( Traffic ) Metro provides in the Mitigation Measures
for the Washington Boulevard/ National Boulevard ( LPA, La Cienega
Station Option, Jefferson Boulevard Design Option' ) in the Final
EIS/EIR that it shall ensure that the westbound approach and
departures are converted to accommodate a left-turn lane, two through
lanes and a through/right-turn lane The Final EIS/EIR also states that
the westbound departure would require additional Metro right of way
and the removal of parking to accommodate the new approach
configuration The Final EIR/EIS however, does not address what the
impacts of adding this mitigation measure would have on the
surrounding area Metro should address the impacts of installing a left-
turn lane, two through lanes and a through/right-turn lane at this
intersection and any additional impacts which may result if the required
additional right of way can not be acquired at this location
Page 31 of 31October 24, 2005
Comments from City Council and Redevelopment Agency Meeting
Mid-City Exposition Light Rail Transit Project FEIS/FEIR
PUBLIC COMMENTS (Oral)
Vince Movtl
1 MOS Design Options for interim station adjacent to residential areas and schools
makes no sense
2 Metro has a history of failures (Gold and Orange Lines) and will not build a
quality project
3 There are no fully developed plans at this stage to review to determine what is
being proposed for the completed project
4 Would support a quality project
Susan Dean
1 Metro is using statistics for the larger Westside study area to support ridership
and not information from the areas specifically adjoining the Expo ROW
2 There is not a though discussion of the use of Metro policing services verses the
CCPD involvement
3 Wants the word "interim as it applies to the Culver City station options defined
4 Wants to know why Metro s budget included approximately 25% for
contingencies and cost escalations
5 Wants to know what impacts the distance from parking areas and the mode of
travel to the station areas have on ridership
6 Wants to know if the ridership projections from the Gold Line are consistent with
actual ridership
7 Believes the traffic discussion in the FEIS/FEIR is inadequate and does not
accurately identify and/or analyze the impacts
8 Believes the walking distance from the parking areas is too great and will limit
ridership
9 Stated that the FEIS/FEIR does not discuss any Shuttles to serve the station,
parking and surrounding areas
10 Believes that the noise and vibration discussion is inadequate
11 Wants more information on the proposed landscape berms and their
effectiveness on mitigating noise
12 Believe that the stop short station design option would impact the residential
areas more than just Helms Ave
Russell Tanner
• Wants to see EXPO LRT proceed along ROW through Cheviot Hills
Paul Goodwin
• Parking in the neighborhoods is a potential problem He has experience with the
Red Line in that before 8 30 AM, parking is generally available in Metro parking
lots After 8 30 AM the lots are full and people are searching adjacent
neighborhoods for street parking
Attachment No 4PUBLIC COMMENTS (Written)
Marta Zangoza
• Metro can not be trusted
Mark Alpers
• Supports the project and wants the City to push for Metro to begin work on the
Phase 2 DEIS/DEIR as soon as possible
Shelly Rothman
1 Warning devices will cause noise impacts to neighborhoods
2 Vibration impacts will be created
3 Concerned about the safety issues related to pedestrians and the proximity of
schools to the ROW
Loni Anderson
1 Concerned about the impacts to the neighborhoods from the proposed station
location Design Options
2 Concerned about potential traffic impacts in the station areas and the
neighborhoods
3 Concerned that the inconvenience of parking in the Metro lots will cause parking
in the neighborhoods
4 Concerned about LRT operations on emergency response times
COUNCIL AND AGENCY MEMBER COMMENTS
Corlin
1 Wants to know what the difference in traffic generated and impacts would be
between a Culver City station that was the interim end of the line verse if the
station were a station along a line that continued beyond
2 Wants to know what is meant by budget contingences
3 Wants to know what experience Metro has in demolishing and reconstructing
operating stations
4 Wants to know if Metro has asked Culver City for money to build the aerial
station project Doesn t want City to help pay for building it right the first time
Any Culver City money should be used for enhance station and lines connection
to the residential employment and commercial areas
5 Did not see any reference to the existence of the Alquist-Pnolo Seismic Safety
Zone intersecting the ROW in the FEIS/FEIR
6 Wants the FEIS/FEIR review period extended
7 Wants an explanation about the authority of the Public Utilities Commission
(PUC) over the project and how it relates to the City's and Agency s authority
(Page 7 132 — 133)
8 Wants to know what methodology Metro used to analyze traffic impacts
439 Wants to know what methodology Metro used to develop ndership, especially
how was walking distances factored into analysis
10 Wants information regarding Metro's past EIR ridership projections and actual
ridership once lines are in operation
11 Wants City to survey Culver City residents to determine how many would actually
ride the proposed LRT
12 What is the meaning of Locally Preferred Alternative
13 Wants to know what discussions the Council Subcommittee has had with Metro
regarding the Design Options
14 Wants to know if City and Metro Staffs have discussed the Design Options
15 Wants to know the process for the Agency to drive the Project and Design
Options
16 Will there be Agency/Metro land swaps
17 What is the Agency s ultimate power
Gross
1 How many pages of comments does the staff anticipate the City's comments will
be
2 The FEIR/FEIS includes a Metro Staff recommendation that the project not cross
Washington BI and National BI at this stage
3 There will not be warning devices cause noise impacts because there will not be
any at-grade crossings in the City
4 Has Metro asked us for funding contributions
5 Discussed timing for when naming of Culver City station will occur Supports
naming the station Culver Junction'
6 Wants to know if FEIS/FEIR analyzes National BI ambient noise and the noise
generated by LRT operations
Rose
• Will submit comments later prior to Nov 21 Council meeting
Silbiger
• Will submit comments later70 0 17'"E'
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Option 1 Maximized Parking
45 degree parking = 430 total stalls in 2 lots between Venice and National
Option 2 Pedestrian Promenade
90 degree parking = 380 total stalls in 2 lots between Venice and National
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Mid City Exposition Light Rail Transit Project
Venice-Robertson Station Parking Alternatives
Attachment No 5