The South Pasadena Preservation Foundation attended the hearing regarding the supplemental Environmental Impact Report (FRDEIR/SDEIS) for the 710 extension on Wednesday, June 18. The two hour meeting was held at Maranatha High School and largely covered the cultural impacts that a 710 project would have on historic homes in Pasadena, South Pasadena, and the East Los Angeles area.
The presentation and hearing of CalTrans’ Supplemental EIR was held at 6:30. A comment period followed after, in which attendants were given two minutes to speak. Many of the people who spoke expressed their concerns and pointed out many problems and issues with the FRDEIR/SDEIS . The hearing process itself was in question by noted attorney Christopher Sutton who fiercely scolded the Caltrans/Metro leadership for mishandling the basic process of the hearing and, in his public comments, defined several crucial issues in the FRDEIR/SDEIS. Details to follow in a followup report.
Notably, South Pasadena Preservation Board Members Vice President, Mark Gallatin and Treasurer Odom Stamps were in attendance for the hearing. Some residents spoke at the event, and other members sent in written letters of complaint.
Below is the comments letter submitted by the South Pasadena Preservation Foundation:
July 3, 2018
District Deputy Director
Division of Environmental Planning
Department of Transportation District 7
100 South Main Street MS 16A
Los Angeles, CA 90012
Dear Mr. Kosinski,
The South Pasadena Preservation Foundation (SPPF) wishes to thank the California
Department of Transportation (Caltrans) for this opportunity to comment on the recently- released State Route 710 (SR-710) North Study Focused Recirculated Draft Environmental Impact Report/Supplemental Draft Environmental Impact Statement (FRDEIR/SDEIS). We wish to express our agreement with Caltrans’ enlightened decision to change the previous Finding of No Adverse Effect (FONAE) for this project to a Finding of Adverse Effect (FOAE). Nevertheless, our review of the FRDEIR/SDEIS reveals that there are still significant unanswered questions about potentially detrimental effects from the Freeway Tunnel, LRT, and BRT alternatives on historic resources in the project study area and specifically in South Pasadena. The concerns we have are summarized in the bullet points listed below:
• The FRDEIR/SDEIS still shows adverse effects from the Freeway TunnelAlternative on four properties which cannot be mitigated. Thus the Freeway Tunnel Alternative cannot be approved.
• The California Environmental Quality Act (CEQA) prohibits the approval of a project
with adverse effects where a less-damaging alternative is available. The less-damaging
alternative to the Freeway Tunnel, LRT, and BRT Alternatives in this case is the TSM/TDM
• We are concerned that constant vibration from both the Freeway Tunnel and LRT Alternatives construction and operation could cause potentially severe harm to historic resources and significant unavoidable impacts, thus disqualifying these alternatives when compared to the TSM/TDM Alternative.
• While alternative machinery was identified in the analysis of the BRT Alternative’s vibratory impacts on the Oaklawn Historic District, Rialto Theater, FairHope Building and Oaklawn Bridge and Waiting Station, it is unclear what the specific Peak Particle Velocity (PPV) would be for that alternative. Mitigation measures cannot be “one size fits all” and must be tailored to the specific impacts on each resource analyzed.
• For the LRT Alternative’s groundborne noise effect on the Rialto Theatre, it is
unclear what the specific decibel levels would be for that alternative. Other
mitigations, like rail on rubber placed on concrete ties attached to rubber pads on a concrete base or the use of box sections on rubber pads connecting to tunnel walls per Federal Transit Administration specifications have not been considered.
• Information regarding potential contingency plans related to a breakdown of the
tunnel boring machines (TBMs) has not been provided, nor have impacts and mitigation
measures associated with the potential breakdown of a TBM been identified. The lack of
this information fails to comply with CEQA and the National Environmental Protection Act (NEPA).
• There are still numerous unanswered questions regarding the Freeway Tunnel
Alternative’s impacts and mitigation measures associated with tunnel fires.
• No fault crossing design has been done for the San Rafael and Eagle Rock faults. Both the
LRT and Freeway Tunnel Alternatives require a significant amount of excavation within
these active fault areas and potential impacts associated with earthquakes on historic
resources within the study area have not been addressed.
• Caltrans has not categorically ruled out blasting methods in the excavation area.
• It is unclear if test boring has been conducted for the adequacy of drilling through the
Topanga soil formation and if TBMs would encounter alluvial boulders or igneous diorite
• Ground settling was previously stated as unlikely, but there is insufficient technical
analysis to support this claim. Ground settlement can cause damage to existing
structures and should be taken into consideration when evaluating the potential impacts
on historic resources and properties. The proposed Freeway Tunnel Alternative would
be the largest diameter hard rock TBM project in the US. Radically scaling up of the
size of projects calls for great caution. Geologic conditions within the alignment present
a broad array of geotechnical difficulties. The Freeway Tunnel Alternative is of an
unprecedented scale in terms of tunnel size. A major shift upward in project scale
creates uncertainties in both cost and impact. The environmental impact of the Freeway Tunnel Alternative is currently unknowable because the project as proposed features unacceptable risks including construction safety problems and a high likelihood of needing a major redesign or realignment during construction with unknown risks of massive cost overruns and delays of possibly years.
• It is unclear if Caltrans has evaluated the potential for sinkholes or conducted
a detailed construction methods assessment.
• The freeway tunnel alignment has curvatures near Huntington Drive and Kendall Avenue
and near SR 110 north to Columbia Street. These curvatures will increase costs, present placement problems, increase the potential for ground failures and would result in more transferred traffic vibrations if the ground is firm.
• It is still unknown if Caltrans is reserving subsurface rights for tunneling below
properties it is selling.
• CEQA requires that a preferred alternative be identified. (Please see Washoe Meadows
Community v. Department of Parks and Recreation (2017) 17 Cal.App.5th 277). The
court in Washoe Meadows stated “The presentation of five very different alternative projects in the DEIR without the designation of a stable project was an obstacle to informed public participation for the reasons previously discussed, even if we cannot say such input would have changed the project ultimately selected and approved.” Instead of a clearly identified single proposed project, the FRDEIR/SDEIS presents a set of alternatives without any distinction between them that would allow public comments to focus on the relevant proposal, thus depriving the public and public agencies of the ability to provide comprehensive, meaningful comments on the document. We respectfully request that Caltrans recirculate the DEIR/DEIS with the preferred alternative clearly identified.
• As part of the Federal Section 106 comment process, we urge Caltrans to commit to not
implementing any alternative other than the TSM/TDM Alternative unless a Supplemental
EIR/EIS is first prepared.
The San Gabriel Valley Council of Governments (SGVCOG) has removed the SR 710 North
Freeway Tunnel Alternative from its Measure M Priority Project List. The Los Angeles
County Metropolitan Transportation Authority (Metro) has allocated its remaining Measure R funds to the TSM/TDM Alternative. The elimination of these previously identified funding sources makes the Freeway Tunnel Alternative economically infeasible. Because funding to overcome the engineering challenges of the Freeway Tunnel Alternative is not available, the Freeway Tunnel Alternative is technically infeasible. For the reasons enumerated above, the Freeway Tunnel Alternative is also legally infeasible. We encourage Caltrans to join the City of South Pasadena, the SGVCOG, and Metro and focus its consideration on the TSM/TDM Alternative for the SR 710 North EIR/EIS to the exclusion of all other alternatives. Thank you for your consideration of our comments.
President, South Pasadena Preservation Foundation