Via U.S. Mail and Electronic Mail (garrett.damrath@dot.ca.

gov)
August 4, 2015
Mr. Garrett Damrath
Caltrans District 7
Division of Environmental Planning
100 S. Main St., MS-16
Los Angeles, CA 90012
Re: Draft Environmental Impact Report/Environmental Impact Statement (EIR/EIS) and
Draft Section 4(f) De Minimis Finding for the State Route 710 North Study
Dear Mr. Damrath:
On behalf of the El Sereno Organizing Committee (ESOC), a grassroots communitybased organization from El Sereno whose mission is to advocate on behalf of the interests of the
community in relation to the proposed 710 Freeway/Tunnel project, and the Natural Resources
Defense Council (NRDC), a national, non-profit environmental organization with tens of
thousands of members and activists in southern California, we are writing to convey comments
from residents who live, work, recreate, and conduct business in the community of El Sereno in
the City of Los Angeles regarding the draft environmental impact statement (EIS) and draft
environmental impact report (EIR) (collectively, EIR/EIS) for what Caltrans refers to as the
SR-710 North Gap Closure Project (Project). The community of El Sereno is and has been
directly in the path of this Project since its inception decades ago, and the construction and
operation of any of several of the Project alternatives would profoundly impact the communitys
residents and businesses.
As we have explained in prior correspondence, our organizations have longstanding
environmental justice concerns about building a freeway through the predominantly Latino
neighborhood of El Sereno. ESOC was one of the named plaintiffs, and NRDC represented the
plaintiffs as counsel, in the still-pending federal court lawsuit that alleged that the allocation of
mitigation measures for the proposed 710 Freeway extension was racially discriminatory. El
Sereno Neighborhood Action Committee et al. v. California Transportation Commission, No.
CV-95-6106 (C.D. Cal. filed Sep. 13, 1995). Our position is and always has been that no matter
what form the Project ends up taking, it must not impose disproportionate environmental and
housing burdens on the minority community of El Sereno.

Natural Resources Defense Council

1314 Second Street
Santa Monica, CA 90401
310-434-2300

El Sereno Organizing Committee

5302 Borland Road
Los Angeles, CA 90032
323-222-6625

Mr. Garrett Damrath

August 4, 2015
Page 2 of 3
We have documented and repeatedly raised concerns about the continued failure of the
transportation agencies to conduct effective outreach to the El Sereno community regarding this
Project. Please refer to Attachment 1 below for our prior correspondence on this issue. In an
effort to better inform the El Sereno community about the various transportation alternatives in
the EIR/EIS and their potential impacts on El Sereno, and to solicit input regarding potential
transportation solutions that would benefit the community, ESOC, NRDC, and the Office of Los
Angeles City Council Member Jos Huizar (CD14) co-hosted a public meeting on June 18,
2015 at the El Sereno Senior Center, 4818 Klamath Place, Los Angeles, CA 90032. Attachment
2 below contains the meeting agenda, a compilation of the notes that were taken during the
breakout sessions, with participants transportation concerns and proposed solutions broken out
separately and broken down further by specific issue, and photos from the public meeting. At
this meeting, eleven (11) community-based organizations from El Sereno, including some from
neighboring East Los Angeles, provided public statements in opposition to the five (5)
alternatives contained in the Draft EIR/EIS for the State Route 710 North Study. These
organizations also spoke in support of our effort to craft community-based transportation
alternatives.
ESOC, NRDC, and CD14 then held a follow-up public meeting on July 29, 2015 at the
same location to obtain feedback on those comments and narrow down and compile a
community-backed list of transportation concerns and proposed solutions to be submitted
officially to Caltrans for the record. That list is as follows:
Concerns
Traffic
The proposed tunnel would not solve traffic problems while it might relieve traffic in
some places, it would also create more traffic in other places, such as East Los Angeles.
Increased traffic congestion and pollution in El Sereno from the proposed tunnel would
create unsafe conditions for pedestrians, bikers, and drivers.
There is a need to improve connectivity between parts of El Sereno.
Health/Safety
Any explosions or earthquakes could cause the tunnel to collapse, especially considering
the route runs along a fault line.
The air quality at the end of each tunnel would be significantly worse due to car exhaust
venting from the tunnel into the community.
A traffic accident in the proposed tunnel would be dangerous.
Tunnel construction could cause damage to surrounding homes. Who would pay to
compensate the homeowners?
Construction of the proposed tunnel is dangerous due to the fact that it runs along a fault
line.
The Draft EIR/EIS fails to address existing impacts of overflow traffic and general unsafe
conditions on El Serenos streets.
There are no emergency exits in the proposed tunnel.

Mr. Garrett Damrath

August 4, 2015
Page 3 of 3

There have been many safety risks with tunnels similar to this one in other places.

Community
The proposed tunnel would destabilize the El Sereno community and threaten residents
quality of life. The quality of life in El Sereno needs to be improved or at least preserved
the proposed 710 tunnel would not do this.
The project would result in community members being displaced from their homes, many
of whom are seniors and may not have a place to go; this displacement of homes is not
analyzed in the Draft EIR/EIS.
The project would result in a huge loss of affordable housing.
The community does not support and would, in fact, oppose any transportation alternative
that would eliminate or otherwise adversely impact existing park space in El Sereno.
The money proposed for the tunnel would be better spent on areas that are more urgent
and needed in the community, such as education, open space, public transit, and creating
new permanent jobs.
Solutions

Instead of the proposed tunnel, funding should be used to fix potholes and improve
current road conditions this would decrease accidents and help traffic move faster.
More bus lines should be added, and service of bus lines should be more frequent and
consistent. Specifically, LADOTs DASH service needs to update its routes and expand
so that no one needs to walk further than three blocks to get to a DASH stop.
Students and seniors should be allowed free or very affordable transit prices, and direct
routes should be added to schools and senior centers.
The community would rather expand green space than build more roads and construct the
tunnel.
Bike paths need to be improved, and more bike paths should be put in.
The 710 Freeway should stop at the 10 and not go any further north.

Thank you for the opportunity to comment. Although the communitys concerns and
proposed solutions were not overly detailed, it was very clear that the community of El Sereno
stands opposed to any of the five proposed transportation alternatives contained in the EIR/EIS.
Very truly yours,
Hugo Garcia
President
El Sereno Organizing Committee
Phone: (323) 718-1223
Email: hgarcia4432@gmail.com
Attachments

Damon Nagami
Senior Attorney
Natural Resources Defense Council
Phone: (310) 434-2300
Email: dnagami@nrdc.org

ATTACHMENT1

March 3, 2011
Councilmember Jos Huizar, CD14
200 N. Spring Street, Room 465
Los Angeles, CA 90012
Dear Councilmember Huizar:
On behalf of the El Sereno Organizing Committee and the Natural Resources Defense
Council (NRDC), we are writing to call attention to the low turnout of El Sereno residents at last
weeks 710 Conversations meeting held on February 24th at the Los Angeles Christian
Presbyterian Church. According to the sign-in sheets at the meeting, approximately eight
members of the El Sereno community attended the meeting. Of that number, most were
individuals from the LA-32 Neighborhood Council or had previous interest in the project. They
were not residents who were new to the project. On February 24th, in conversations with MBIs
Mary McCormick, Metros principal outreach coordinator and meeting facilitator on this project,
she assured us that Metro undertook extensive measures to reach out and notify the El Sereno
community about this meeting. She further assured us that MBI, with the assistance of
subconsultant DSO, had distributed meeting flyers to several key community locations
throughout El Sereno and at businesses along Huntington Drive. Disturbingly, when Ms.
McCormick was identifying the outreach locations in El Sereno, she mistakenly named several
locations in South Pasadena. While we do not doubt that some type of outreach efforts were
undertaken, they appear to have been minimal and ineffective, as they failed to turn out El
Sereno residents on an issue in which this community has consistently shown tremendous
interest over several decades.
At first glance, these circumstances may appear both puzzling and alarming; however,
when viewed in a historical context, this is business as usual for El Sereno residents. This is not
the first time Metros or Caltranss outreach efforts have failed to adequately inform the El
Sereno community of important meetings related to the 710 Freeway saga. At a community
meeting in 2006 held at the El Sereno Senior Center to discuss a preliminary SR710 tunneling
feasibility study, while the room was packed with Metro and Caltranss consultants, very few
community members actually showed up. Like the current SR710 Conversations meetings,
this meeting was part of a series of Community Meetings organized and facilitated by Metro.
At that meeting, one of the undersigned, Mr. Garcia, voiced concerns to the project lead, Metros
Lynda Bybee, about issues of short notice and minimal outreach, poor community attendance,
and the fact that the community was not allowed to voice public comment. Our concerns were
ignored. At that meeting, Metro staff selected which public comments to present and address.

Similarly, in February 2009, Caltrans had a series of Community Meetings that mirrored
Metros efforts. Frustrated, the community, with support from the offices of then-Senator Gil
Cedillo, then-Assemblymember Kevin de Leon and Councilmember Huizar, intervened and
demanded that appropriate and effective outreach be implemented. To their credit, Caltrans and
their consultants rectified the situation.
Much to the chagrin of the El Sereno community, however, history appears to be
repeating itself with respect to the current SR710 Conversations meetings. As with previous
instances, last week's paltry turnout is unacceptable. These repeated failures point to a systemic
failure on the part of Metro to address a problem that must be fixed. For instance, with regard to
last week's meeting, it may be that Metro's messaging did not communicate the purpose of the
meeting in a manner that the residents of this community could clearly understand. Indeed, even
in English, the title "Transportation: Where Have We Been? Where Are We Going?" was vague
and ambiguous, and provided little context for the important discussions the meeting had hoped
to facilitate. Poor attendance at public events is oftentimes due to poorly planned or inadequate
outreach. We need to get to the bottom of this. We would like to see Metros outreach plan for
El Sereno, in its entirety, if one exists. We also would like to review the budget for the SR710
Conversations project. Specifically, we would like to know how much money is being paid for
this particular project, what are the terms and scope of MBIs contract and any task orders
carried out to date, and what are the terms and scope of any other related subcontracts between
MBI and DSO or any other firm that is assisting MBI with its outreach efforts.
Additionally, in the hopes of rectifying these recurring issues, we would like to
respectfully request your assistance in arranging a meeting that would include the appropriate
Metro representatives and consultants, including Doug Failing, Lynda Bybee, Susan Gilmore,
Mary McCormick, and Victor Griego; a representative from your office; representatives from the
offices of State Assemblymember Gil Cedillo, County Supervisor Gloria Molina, and State
Senator Kevin de Leon; and the undersigned to discuss, among other things, the possibility of rescheduling the February 24th public meeting and undertaking meaningful and effective outreach
to ensure that El Sereno residents have a real opportunity to participate in public dialogue.
Given that additional 710 Conversations are scheduled in El Sereno in the very near future
(e.g., the Series 2 CEQA/NEPA meeting on March 17th and the Series 3 Scoping meeting on
March 29th), this meeting should take place as soon as possible.
Councilmember Huizar, you are well aware that El Sereno is an impacted community -in fact, the most impacted community -- in relation to conversations related to the SR710. For
this reason, Metro and Caltrans need to pay particular attention to the El Sereno community, not
the opposite. You have consistently championed environmental causes such as Elephant Hill,
the Northeast Los Angeles Interim Control Ordinance and the Northeast Los Angeles Hillside
Zoning Ordinance. As our elected representative, we are again counting on your leadership and
support for our community to bring about fundamental change to the manner in which El Sereno
is treated by transportation agencies. The community does not deserve to continue to be
subjected to the social and environmental injustices that have been brought to bear throughout
the history of the proposed SR710 extension discussion.

Thank you in advance for your assistance in this important matter. Please do not hesitate
to contact us if you have any questions.

Respectfully,
Hugo Garcia
President
El Sereno Organizing Committee
Phone: (323) 718-1223
Email: hugogarcia1@sbcglobal.net

Damon Nagami
Staff Attorney
Natural Resources Defense Council (NRDC)
Phone: (310) 434-2300
Email: dnagami@nrdc.org

cc: Assemblymember Gil Cedillo

Los Angeles County Supervisor Gloria Molina
Senator Kevin de Leon

Via U.S. Mail and Electronic Mail (sr710conversations@metro.net)

April 14, 2011
Mr. Ron Kosinski
Deputy District Director
Caltrans District 7
100 S. Main St.
Los Angeles, CA 90012
Re: Scoping Comments Regarding the Notice of Intent to Prepare a Draft Environmental
Impact Statement and Notice of Preparation of a Draft Environmental Impact Report for
the SR-710 North Gap Closure Project in Los Angeles County, California
Dear Deputy Director Kosinski:
On behalf of the El Sereno Organizing Committee (ESOC), a grassroots communitybased organization from El Sereno whose mission is to advocate on behalf of the interests of the
community in relation to the proposed 710 Freeway/Tunnel project, and the Natural Resources
Defense Council (NRDC), a national, non-profit environmental organization with tens of
thousands of members and activists in southern California, we submit the following scoping
comments on the Notice of Intent (NOI) to prepare a draft environmental impact statement
(EIS) and Notice of Preparation (NOP) of a draft environmental impact report (EIR) for
what Caltrans refers to as the SR-710 North Gap Closure Project (Project).
Our organizations have longstanding environmental justice concerns about building a
freeway through the predominantly Latino neighborhood of El Sereno. ESOC was one of the
named plaintiffs, and NRDC represented the plaintiffs as counsel, in the still-pending federal
court lawsuit that alleged that the allocation of mitigation measures for the proposed 710
Freeway extension was racially discriminatory. El Sereno Neighborhood Action Committee et al.
v. California Transportation Commission, No. CV-95-6106 (C.D. Cal. filed Sep. 13, 1995). If
the Project moves forward now, no matter what form it ends up taking, it must not impose
disproportionate environmental and housing burdens on the minority community of El Sereno.
At a minimum, the EIR/EIS must consider and carefully analyze and mitigate any and all
environmental justice impacts.
We also wish to express our dismay at the woefully inadequate outreach efforts that the
Los Angeles County Metropolitan Transportation Authority (Metro) has made thus far to the
El Sereno community with respect to the Project. Located immediately north and west of the
Natural Resources Defense Council
1314 Second Street
Santa Monica, CA 90401
310-434-2300

El Sereno Organizing Committee

5302 Borland Road
Los Angeles, CA 90032
323-222-6625

Mr. Ron Kosinski

April 14, 2011
Page 2 of 9
intersection where SR-710 meets Valley Boulevard, El Sereno includes neighborhoods that will
be directly and heavily impacted by the Project. Metros ineffective attempts to include El
Sereno residents in discussions about the Project have failed to live up to the agencys promises
to involve an education and public involvement program to seek both regional and communitybased solutions that are suggested by you, your friends and family, your neighbors, and everyone
else in your community.1 This is unacceptable and contravenes the basic principles behind the
National Environmental Policy Act (NEPA) and the California Environmental Quality Act
(CEQA), which state unequivocally that public participation is an essential part of the
environmental review process. We are bringing this issue to Caltranss attention now to ensure
that these problems are fixed before the next round of community engagement on this Project.
In addition, we continue to strongly oppose all surface or tunnel highway alternatives for
the Project. We are extremely concerned about the environmental and public health impacts that
would result from building a five-mile highway or tunnel in this location. We also believe that
the immense financial outlay necessary to fund a tunnel or surface route would be much more
effectively directed toward transit investments and improvements across Los Angeles County.
We believe, therefore, that it is essential that Caltrans not only fully assess and mitigate the
significant impacts from the proposed Project under NEPA, CEQA, and their regulations, but
also seriously consider other alternatives to the Project, including no project at all. We are
encouraged that Caltrans is now taking a fresh look at the regional congestion problem and
considering heavy rail and bus/light rail systems, local street upgrades, [and] traffic
management systems as potential Project components. We would support a multi-modal
alternative that included these components, rather than a highway or tunnel that would
exacerbate the regions intractable air pollution and resultant health problems while doing
nothing to reduce traffic congestion. We would not, however, support any multi-modal
alternative that includes a connector road feature that would extend the freeway from its existing
terminus at Valley Boulevard to Alhambra Avenue.
Finally, the EIR/EIS needs to address all of the adverse impacts the Project will have on
the natural and human environment, including, but not limited to, impacts on air quality, cultural
and historical resources, biological resources, water quality and supply, local and regional
transportation patterns and traffic circulation, greenhouse gas emissions, and regional water
infrastructure. The EIR/EIS also must propose adequate mitigation measures, include a
comprehensive discussion of alternatives, and address the Projects compliance with other laws
as required under NEPA and CEQA. With that in mind, our comments below focus in greater
detail on a discrete few of the most critical issues that we want to make sure are fully considered
by Caltrans.
1.

The EIR/EIS must consider, analyze, and mitigate any and all environmental
justice impacts.

We are troubled that neither the NOP nor the NOI contains any references to evaluating
or mitigating environmental justice impacts, despite the fact that achieving environmental justice
1

Metro, SR-710 Conversations, at http://www.metro.net/projects/sr-710-conversations/.

Mr. Ron Kosinski

April 14, 2011
Page 3 of 9
has been made a priority for federal agencies by presidential decree. Exec. Order No. 12,898, 59
Fed. Reg. 7,629 (Feb. 16, 1994). What this means is that each federal agency is charged with
incorporating environmental justice into its mission by identifying and addressing, as
appropriate, disproportionately high and adverse human health or environmental effects of its
programs, policies, and activities on minority populations and low-income populations in the
United States. Indeed, the Council on Environmental Quality (CEQ) issued guidance in 1997
to assist federal agencies in carrying out this very mission.
As mentioned above, any highway route would cut through, and any tunnel route would
begin extremely near, El Sereno, a neighborhood that already experiences high levels of mobile
and stationary source emissions known to be toxic. The California Air Resources Board has
observed that Californians who live . . . along high traffic corridors are subsidizing the goods
movement sector with their health.2 Of particular concern are the adverse health effects of
diesel emissions, dramatically increased local levels of which would be implicated by the
construction and operation of a new highway or tunnel. The EIR/EIS must consider and
implement mitigation measures to eliminate all environmental justice impacts implicated by the
proposed Project, taking into account impacts introduced by the Project itself as well as
cumulative impacts that arise from existing and foreseeable future sources of air, light, and noise
pollution, including the tremendous increase in car and truck traffic that any highway Project
alternative would facilitate.
We urge Caltrans to consult CEQs guidance documents, consider and analyze the
Project through the lens of addressing environmental justice issues, and implement mitigation
measures to eliminate any and all environmental justice impacts implicated by the Project.
2.

Caltrans and Metro must rectify their recent and historical failures to
include the El Sereno community in the public participation process.

Both NEPA and CEQA require agencies to ensure and facilitate adequate public
participation in the environmental review process. See, e.g., 40 C.F.R. 1500.1(b) (requiring
NEPA procedures to [e]nsure that environmental information is available to public officials and
citizens before decisions are made and before actions are taken), 1500.2(d) (requiring federal
agencies to [e]ncourage and facilitate public involvement in decisions which affect the quality
of the human environment); see also Concerned Citizens of Costa Mesa v. 32nd Dist. Agric.
Assn, 42 Cal. 3d 929, 936 (1986) (stating that members of the public hold a privileged
position in the CEQA process, reflecting a belief that citizens can make important
contributions to environmental protection and . . . notions of democratic decision-making). Thus
far, however, Caltrans and Metro have failed in carrying out this charge with respect to the El
Sereno community.
The undersigned organizations first documented Metros inadequate outreach efforts in a
letter to Los Angeles City Councilmember Jos Huizar, dated March 3, 2011 and attached hereto
2

See Cal. Air Res. Bd., DRAFT EMISSION REDUCTION PLAN FOR PORTS AND INTERNATIONAL GOODS MOVEMENT IN
CALIFORNIA, Ch. 5, at 1, (Dec. 1, 2005).

Mr. Ron Kosinski

April 14, 2011
Page 4 of 9
for reference. In that letter, we pointed out the extremely low turnout of El Sereno residents at
the Series 1 community meeting in El Sereno on February 24, 2011, and explained that this
actually is a recurring problem for this community with respect to this Project. We also
suggested that Metros repeated outreach failures to El Sereno are a systemic problem, illustrated
by examples like the agencys insistence on directly translating into Spanish the ambiguous and
uninspiring title of the Series 1 meetings (Transportation: Where Have We Been? Where Are
We Going?). This title was hopelessly vague and provided little to no context for the important
discussions the meetings had hoped to facilitate. Finally, we asked for a meeting with Metros
principals, their outreach consultants, and elected officials including Councilmember Huizar to
ensure that El Sereno residents have a real opportunity to participate in public dialogue regarding
the Project.
The meeting we requested did not happen. In the meantime, Metro convened the Series
2 (CEQA/NEPA on March 17, 2011) and Series 3 (Scoping on March 29, 2011) community
meetings in El Sereno. At those meetings, in addition to running into similar issues as those
raised in our March 3rd letter, members of the El Sereno community experienced additional
concerns and frustrations related to this project, as described below.
a.

Lack of community engagement:

Metro had the same low turnout at the Series 2 (CEQA/NEPA) meeting as it
had at the Series 1 (Conversations) meeting, despite the outreach consultants promises
that they were doing everything they could to get the word out. The El Sereno Organizing
Committee, community residents and representatives from the LA-32 Neighborhood
Council voiced their concerns about the low turnout during public comment.
b.

Poor overall project planning:

The 20 total Series 1-3 meetings were hastily planned and scheduled too closely
together. This type of planning lends itself to problems associated with ineffective
outreach as meetings were scheduled in many cases back to back, in different cities, on
consecutive dates.
c.

Confusion over what is the project:

The project that the meetings were supposed to be about has never been
defined, which continues to confuse people. Several comments were made expressing
confusion with understanding what is being communicated in relation to the project.
Because of the vague and ambiguous explanations provided by the presenters, the
community was very dissatisfied and unclear on what they should be commenting about
at the Scoping meeting.

Mr. Ron Kosinski

April 14, 2011
Page 5 of 9
d.

Questionable execution of community outreach:

Towards the end of the CEQA/NEPA meeting in El Sereno, a representative from

the outreach consultant, Diverse Strategies for Organizing (DSO), read off a lengthy
laundry list of targeted outreach efforts in El Sereno. This list included several
community organizations, elected officials, the El Sereno Chamber of Commerce, school
principals, churches, Barrio Action, El Sereno Stallions, El Sereno Recreation Center, the
Voice newspaper, and the Senior Center, and also stated that flyer distribution at schools
was pending clearance by the school bureaucracies. However, while the consultant was
touting its comprehensive outreach efforts in El Sereno, residents were complaining
about the consultants failed efforts, as evidenced by the poor turnout.
It was clear to the community that the consultant had embarked on a poorly
conceived and ineffectual outreach strategy, which resulted in a failure to engage the
community of El Sereno. The consultants descriptions of its outreach activities have
been vague and incomplete, which, along with the poor turnout at two consecutive public
meetings, led the community to the conclusion that the consultants efforts were
inadequate in their scope, planning and execution. To provide just one example, on
March 17, 2011, the consultant finally sent out a flyer for the Series 2 meeting. This
flyer was transmitted via email at 1:24 PM, the same day of the Series 2 meeting,
approximately 4 hours prior to the scheduled meeting time.
e.

Failure by the outreach consultants to develop a strategic outreach plan:

The consultants meeting flyers were unimaginative and generic, and contained
uninspiring institutional text, layout and graphics. The flyers lacked any sense of need,
importance, or urgency characteristics essential to drawing the community to attend
these meetings. The flyers did not even attempt to appeal to the specific concerns of the
varying communities that were being targeted. There was no effort to consider messaging
that would appeal to the diversity in demographics, especially as it relates to El Sereno.
This revealed a serious lack of perception and understanding of the historical concerns
that relate to a predominantly Latino community like El Sereno, versus non-Latino
communities like South Pasadena and Pasadena.
Addressing linguistic concerns is another part of a successful strategic outreach
campaign. Up until the consultants untimely flyer on March 17th, there was no targeted
outreach to monolingual, Spanish-speaking residents in El Sereno. This is of paramount
concern. According to U.S. Census figures, in El Sereno, a predominantly Latino
community with approximately 48,000 residents, there are approximately 79.4%
Language other than English and 67.5% Spanish-speaking language households.
This is particularly true of census tracts running along the proposed SR-710 Freeway
surface and tunnel routes. Indeed, from a strategic standpoint, both Metro and the
consultant utterly failed in determining that it was appropriate to wait to outreach to the
Spanish-speaking residents of El Sereno until the 14th of 18 planned meetings.

Mr. Ron Kosinski

April 14, 2011
Page 6 of 9
f.

Improvement in outreach for the Series 3 (Scoping) meeting was not enough:

Although members of the El Sereno community attended the March 29, 2011
Scoping meeting in far greater numbers, this result was only minimally due to the
consultants efforts. At the strong urging of ESOC, the consultant purported to canvass
the 710 corridor. However, the consultants canvassing consisted of the same, ineffective
flyers and was simply a walking-man effort. The consultant did not knock on doors or
attempt to actually engage the community.
Because of the consultants largely ineffective outreach efforts, ESOC decided to
canvass the 710 corridor on a volunteer basis. ESOC went to every property in the
corridor, knocked on every door that could be accessed, and spoke with residents in
English and Spanish urging them to attend the meeting. ESOC also met with business
owners and organizations on Huntington Drive, Eastern Avenue and Valley Boulevard to
arrange to leave flyers for residents to pick up. ESOC left flyers at a total of 66 locations,
and observed the consultants flyers only at about three locations. ESOC also inserted
4,000 flyers into the Voice newspaper so that El Sereno residents would receive it at the
pending distribution and inserted flyers into the church bulletin at Guadalupe Church in
Rose Hills for their five Sunday masses. This is what we believe constitutes strategic and
effective outreach.
It is apparent that the consultants principal and most sustained outreach strategy
consisted of a barrage of emails during the week of the meeting. ESOC believes that
while email is convenient for many people, it should not be the primary outreach
technique for our community. It is difficult for us to believe that the Spanish-speaking
community in El Sereno can be effectively engaged via emails, Facebook, Twitter and
webcasts, when few residents receive news about the community through those outlets.
We believe that the communitys increased numbers at the Series 3 scoping meeting
was due to the effective and strategic outreach put forth by ESOC, and not the consultant.
Several attendees confirmed this during the public comment period.
g.

Disorganized CEQA/NEPA presentations:

The Metro staffers who presented information about the CEQA/NEPA process
used PowerPoint flow charts that did not correspond to the CEQA/NEPA flow charts
distributed to meeting attendees. When this was pointed out by the El Sereno Organizing
Committee at the South Pasadena CEQA/NEPA meeting, the staffers promised that it
would not occur at the upcoming El Sereno meeting. They failed to keep their promise.
As a result, many in the community remain confused about the environmental process.

Mr. Ron Kosinski

April 14, 2011
Page 7 of 9
h.
Lack of clarity regarding submission of public comments gathered by Caltrans
during the community meetings on the Geotechnical Study, and their possible
submission during the Scoping process:
A significant issue was raised by a community member in terms of public
comments and the Series 3 (Scoping) process. At issue was what was to become of all
the public comments made and recorded at the substantial public meetings following
Caltranss Geotechnical Study in early 2009. The community was led to believe that
those comments were recorded for a purpose. What happened to those comments, and
will they become part of the Scoping record? Metro officials fumbled with a response and
the El Sereno community was left unclear on this issue.
At the Series 2 meeting in El Sereno, Metros CEQA/NEPA presenter stated that the
most important aspect of CEQA is the public involvement process. However, that process
means absolutely nothing when the community is not informed about the process and is not
engaged in it. The El Sereno community deserves better than this. As such, we are submitting
these comments into the administrative record to call attention to this problem and to demand an
immediate and lasting solution. We also would like to reiterate our request for a meeting as soon
as possible with appropriate representatives from Caltrans, Metro, Metros outreach consultants,
and the elected officials copied on this scoping letter to discuss the inadequacies of outreach
efforts in the El Sereno community to date; arrange for an effective process to gather the El
Sereno communitys input on issues relating to the 710 Project; and collaborate to improve
outreach for all future phases of this Project.
3.

The EIR/EIS must contain an accurate and complete project description.

Courts have long held that [a]n accurate, stable, and finite project description is an
essential part of an informative and legally sufficient EIR. See, e.g., County of Inyo v. City of Los
Angeles, 71 Cal. App. 3d 185, 193 (1977). An accurate project description is needed to provide
agencies and the public with an intelligent evaluation of the potential environmental effects of a
proposed activity. McQueen v. Board of Directors of the Mid-Peninsula Regional Open Space
District, 202 Cal. App. 3d 1136, 1143 (1988).
As related in Section 2(c) above, community members are thoroughly confused about
what exactly constitutes the Project. For example, while the NOP states that the Project may
include one or more highway or non-highway components, the NOI refers in the Summary
section to a proposed highway project. Which is it? As shown in the reports above, Metro
staffers failed to provide the El Sereno community with any clarity in the pre-scoping and
scoping meetings, which disadvantaged community members who took the time to try to
participate in those meetings. We urge Caltrans to clarify the project description before the next
round of public participation and community engagement.

Mr. Ron Kosinski

April 14, 2011
Page 8 of 9
4.

The EIR/EIS must analyze greenhouse gas emissions.

Caltrans must consider and analyze the effects of greenhouse gas (GHG) emissions
from the Project. The EIR/EIS must contain an analysis of the extent to which the Project
significantly affects the quality of the human environment, which includes air quality.
42 U.S.C. 4332(2)(C); see 40 C.F.R. 1508.8 (defining effects as including
ecological . . . , economic, social, or health [effects], whether direct, indirect, or cumulative),
1508.14 (defining human environment comprehensively to include the natural and physical
environment and the relationship of people with that environment); Cal. Pub. Res. Code
21082.2(a), 21100(b)(1) (requiring that an EIR discuss all significant impacts of a project, and
that the lead agency make a determination as to whether the project may have any such
significant impacts); Cal. Pub. Res. Code 21002, 21081(a) (requiring that an EIR adopt
feasible mitigation measures to reduce or avoid all significant environmental impacts).
Cumulative effects clearly include impacts from climate change. 40 C.F.R. 1508.27(b)(7)
(defining significance as including [w]hether the action is related to other actions with
individually insignificant but cumulatively significant impacts).
The National Academy of Sciences recently confirmed in the first of a suite of studies
called Americas Climate Choices that climate change is occurring, is caused primarily by human
activities, and poses significant risks for a broad range of human and natural systems. This
reflects the overwhelming consensus view by the scientific community, which earlier had
prompted the CEQ to issue draft guidance in February 2010 on the ways in which Federal
agencies can improve their consideration of the effects of [GHG] emissions and climate change
in their evaluation of proposals for Federal actions under the National Environmental Policy Act
(NEPA).
In addition, NEPA requires a discussion of possible conflicts between the proposed
action and the objectives of Federal, State, and local land use plans, policies and controls for the
area concerned. 40 C.F.R. 1502.16(c); see also 40 C.F.R. 1508.27(b)(10) (defining
significant as including [w]hether the action threatens a violation of Federal, State, or local
law or requirements imposed for the protection of the environment). The EIR/EIS, therefore,
must evaluate the relationship between the Projects proposed GHG emissions and any relevant
California GHG emission reduction laws or policies, including the Global Warming Solutions
Act of 2006 (AB 32), through which California has committed to reducing GHGs to 1990
levels by 2020, and the 2008 Sustainable Communities and Climate Protection Act (SB 375),
which mandates that regions examine GHG emissions associated with infrastructure projects.
Clearly, GHG and climate change impacts must be considered under both NEPA and
CEQA. Thus, we encourage Caltrans to follow closely CEQs draft guidance and CEQA
Guidelines section 15183.5, and conduct a rigorous GHG analysis to evaluate and mitigate all of
the Projects GHG impacts.

Mr. Ron Kosinski

April 14, 2011
Page 9 of 9
5.

Conclusion

NEPA requires federal agencies to analyze the environmental impact of actions that
significantly affect the quality of the human environment, and CEQA requires agencies to
identify the significant effects on the environment of a project, to identify alternatives to the
project, and to indicate the manner in which those significant effects can be mitigated or
avoided. We urge Caltrans to uphold these laws. In doing so, we believe Caltrans will conclude
that there are many better ways to address southern Californias traffic congestion problems than
by spending several billion dollars on a five-mile freeway or tunnel that would devastate public
health and environmental and historic resources in El Sereno and throughout the study area. In
addition, we strongly urge Caltrans and Metro to take immediate measures to improve outreach
efforts in El Sereno, including, but not limited to, convening the meeting our respective
organizations requested above, so that members of the El Sereno community can fully participate
in this process as envisioned and required under both NEPA and CEQA.
Thank you for your consideration of our comments.
Very truly yours,
Hugo Garcia
President
El Sereno Organizing Committee
Phone: (323) 718-1223
Email: hugogarcia1@sbcglobal.net

Damon Nagami
Staff Attorney
Natural Resources Defense Council
Phone: (310) 434-2300
Email: dnagami@nrdc.org

Attachment (March 3, 2011 Letter to Councilmember Huizar)

cc:

Los Angeles City Councilmember Jos Huizar

Congressmember Judy Chu
Congressmember Xavier Becerra
Assemblymember Gil Cedillo
Senator Ed Hernandez
Senator Kevin de Leon
Los Angeles County Supervisor Gloria Molina
Michael Miles, Caltrans District 7 Director
Doug Failing, Metro Director of Highway Programs
Lynda Bybee, Metro Deputy Executive Officer for Regional Communications
Susan Gilmore, Metro Public Affairs
Mary McCormick, MBI Outreach Consultant
James Rojas, President, Latino Urban Forum

Via U.S. Mail and Electronic Mail

March 13, 2015
Mr. Arthur T. Leahy
Chief Executive Officer
Los Angeles County
Metropolitan Transit Authority
One Gateway Plaza
Los Angeles, CA 90012
sr710conversations@metro.net
Re: Concerns Regarding the Public Hearings Process for State
Route I-710 North Draft Environmental Impact
Report/Environmental Impact Statement (Draft EIR/EIS) for the
SR-710 North Gap Closure Project in Los Angeles County,
California
Dear Chief Executive Officer Leahy,
On behalf of the El Sereno Organizing Committee (ESOC), a grassroots
community-based organization from El Sereno whose mission is to
advocate on behalf of the interests of the community in relation to the
proposed 710 Freeway/Tunnel project, and the Natural Resources Defense
Council (NRDC), a national, non-profit environmental organization with
tens of thousands of members and activists in southern California, we are
writing to express our concerns regarding the public hearings process
associated with the draft environmental impact statement (EIS) and draft
environmental impact report (EIR) (collectively, EIR/EIS) for what
Caltrans refers to as the SR-710 North Gap Closure Project (Project).
As we have explained in prior correspondence, our organizations have
longstanding environmental justice concerns about building a freeway
through the predominantly Latino neighborhood of El Sereno. ESOC was

ESOC NRDC Letter re EIR/EIS Public Hearings

Page 2 of 4

one of the named plaintiffs, and NRDC represented the plaintiffs as

counsel, in the still-pending federal court lawsuit that alleged that the
allocation of mitigation measures for the proposed 710 Freeway extension
was racially discriminatory. El Sereno Neighborhood Action Committee et
al. v. California Transportation Commission, No. CV-95-6106 (C.D. Cal.
filed Sep. 13, 1995). Our position is and always has been that no matter
what form the Project ends up taking, it must not impose disproportionate
environmental and housing burdens on the minority community of El
Sereno.
With the release of the draft EIR/EIS last week and the announcement of
dates and locations for two of three public hearings, we are concerned that
the closest public hearing where El Sereno residents can provide public
comment has been scheduled at East Los Angeles College (ELAC), located
at 1301 Avenida Cesar Chavez in Monterey Park, a 13 mile round-trip
from El Sereno. This meeting location is highly inconvenient for El Sereno
residents, many of whom are transit dependent, and is likely to greatly
reduce the communitys access to, and participation in, the public comment
process.
We strongly feel that the third public hearing should be held in the El
Sereno community at the Los Angeles Christian Presbyterian Church
located at 2241 Eastern Avenue, Los Angeles, CA 90032. This church is
centrally located in El Sereno no farther than 2 miles from all points in the
community, and in fact was used previously by Metro for the 2011 Metro
Scoping meetings.
Holding an additional meeting in El Sereno would help to offset some of the
long history of differential relations and treatment of the El Sereno
community by Metro. Examples of Metros troubling actions with respect to
the El Sereno community arose during the Scoping process in 2011:
Linguistically Inappropriate Outreach Metro distributed Englishonly documents and outreach materials in the predominantly Latino
community of El Sereno, in spite of the fact that El Sereno contains
over 50% monolingual Spanish-speakers.
Walking Man delivery services Metros community outreach
consultants, MBI Media and DSO, used Walking Man delivery
services to distribute meeting flyers. Walking Man notices are

ESOC NRDC Letter re EIR/EIS Public Hearings

Page 3 of 4

typically attached to gates or wherever on the property by rubber

bands at 5:00 or 6:00 am. No door-knocking, actual community
contact or engagement took place. As a result of the poor outreach,
attendance at the first two Scoping meetings in El Sereno was in the
single digits.
Use of Social Media: Metro continued relying on social media
outreach for information, meetings and community input, even
though El Sereno residents have less access and usage of social media
technology due to language and economic barriers.
El Sereno Organizing Committee outreach: ESOC took on the task of
community outreach, including door-to-door outreach along the
proposed I-710 Freeway Corridor, at businesses and at public
facilities with high levels of foot traffic. It was only then that there
was an acceptable level of community attendance and participation at
the third and final Scoping meeting.
In summation, the ESOC and NRDC are asking that an additional public
hearing on the State Route I-710 North Draft EIR/EIS be scheduled in El
Sereno at the Los Angeles Christian Presbyterian Church facility for reasons
articulated in this communication.
Respectfully,
Hugo Garcia
President
El Sereno Organizing Committee
Phone: (323) 718-1223
Email: hgarcia4432@gmail.com

cc:

Damon Nagami
Senior Attorney
Natural Resources Defense Council
Phone: (310) 434-2300
Email: dnagami@nrdc.org

Assemblymember Jimmy Gomez

Senator Kevin de Len
Senator Ed Hernandez
Los Angeles CD14 Jos Huizar
Los Angeles County Supervisor Hilda Solis

ATTACHMENT2

El Sereno 710 Community Meeting

El Sereno Senior Center
Thursday, June 18, 2015

Agenda:
1. Welcome and Introduction to the meeting: Hugo Garcia
5 mins.

2. Elected Officials comments/acknowledgements: 7 mins.


3. Community Based Organization comments: 10 mins.


4. EIR Presentation: Paul Moore 20 mins.

5. El Sereno Transportation Opportunities: Paul Moore 10

mins.
6. Breakout into groups for community exploration of
transportation alternatives in El Sereno: 30 mins.

7. Breakout groups present suggested alternatives: 10 mins.

8. Whats next?: CD14 5 mins.
9. Public Comment Letter Writing Exercise: 20 mins

SUMMARYOFCOMMUNITYINPUTFROM710MEETINGINELSERENOONJUNE18,2015
OnJune18,2015,theElSerenoOrganizingCommittee(ESOC),theNaturalResourcesDefense
Council(NRDC),andLosAngelesCityCouncilDistrict14(CD14)cohostedapublicmeetingat
theElSerenoSeniorCentertoinformtheElSerenocommunityaboutthevarious
transportationalternativesinthe710environmentalstudy1andtheirpotentialimpactsonEl
Sereno,andtosolicitinputregardingpotentialtransportationsolutionsthatwouldbenefitthe
community.Belowisacompilationofthenotesthatweretakenduringthebreakoutsessions,
withparticipantstransportationconcernsandproposedsolutionsbrokenoutseparatelyand
brokendownfurtherbyspecificissue.ESOC,NRDC,andCD14plantoholdafollowuppublic
meetingonJuly29,2015inElSerenotoobtainfeedbackonthesecommentsandcompilea
communitybackedlistoftransportationsolutionstobesubmittedofficiallytoMetroand
CaltransbeforethecommentdeadlineexpiresonAugust5,2015.
CONCERNS
Traffic

StreetRelated

PublicTransit

Health/Safety

Althoughthetunnelwouldrelievetrafficinsomeplaces,
itwillalsocreatemoreinothers(3groupsmentioned)
Parkingcongestion
WouldGreenSpacecreatemoretraffic?
IncreasedtrafficcongestionandpollutioninElSereno,
creatingunsafeconditionsforpedestrians,bikers,and
drivers
Attheriverbedlotsoflandcouldbeused
Cleanupthelandfillsalongthe710:SybillBrand
(womensprisonlocation);cautionwhenmovingdirt:
fugitivedustemissions,healthconcerns
NobusonMission
Concernaboutlightrail:abovegroundtrainnotideal,
businesses/buildingswouldbetorndown,concern
aboutvibrations
Explosions/collapseinthetunnel(causedby
earthquakes)(3groupsmentioned)
Airqualityduetocarexhaust(2groupsmentioned)
Exhaustventingfromthetunnelintothecommunity
Concernfortrafficaccidents
Tunnelconstruction(iftheresdamagetohomes,who
paysforit?Insurance?)
Concernabouttunnelsafetywherethetunnelruns
alongactivefaultline

ToviewanelectronicversionoftheSR710DraftEnvironmentalImpactReport/DraftEnvironmentalImpact
Statement(EIR/EIS),pleasevisithttp://www.dot.ca.gov/dist07/resources/envdocs/docs/710study/draft_eireis/.

Personal
(Homes/Businesses)

Environmental

Other

TheD.E.I.Rfailstoaddressexistingimpactsofoverflow
trafficandgeneralunsafeconditionsonElSereno
streets
Lackofemergencyaccessintheproposedtunnel,as
wellasthepossibilityofgroundshiftingabovethe
tunnel
ProposedGoldenEagleBlvd.anditseffectonresidential
areatraffic,pollution,dangerofthecurveonthe
roundabout
DestabilizationofElSerenocommunity(thetunnel
threatenstheneighborhoodsqualityoflife)
Expensivetollsmaynotbeaffordableforthe
surroundingcommunities
GreenSpace:wouldittakeawaythingsalreadythere?
Howexactlywoulditwork?(However,peoplewhohave
familyliketheideaofgreenspace)(2groups
mentioned)
Lackofinformationabouttheenvironmentalimpactsof
theBeyondthe710alternativei.e.thecreationofthe
greenspace,river,roundabouts
Aestheticvalueoftunnel:makingsuretheareais
beautifulandwellkeptforfuturegenerations
Shiftmoneytootherareasthataremoreurgent/needed
(i.e.education,publictransit,creatingnewjobs)(3
groupsmentioned)
Communitiesnotbeingpittedagainsteachother
BetterOutreach(notthatmanypeopleknew/know
about710propositionandthedetailssurroundit)
Whatistheplanforexistingutilitiesandwaterlines
alongtheplannedroute?

SOLUTIONS
SpecificSolutionstoStreet
RelatedConcerns

CalStateLAneedsanofframp
WhatifonMissionorValley,justhavetrafficgoingone
way
UsingAlhambraAvenuerightofway
UseaportionofthebudgettopreservetheArroyoPark
throughimprovingparkaccesswithsafersidewalksand
roads
Supportforexpansionofparkspaceandadditionof
greenwaysalongCalStateLAcorridor(ideaspresented
byBeyond710organization)
2

GeneralSolutionstoStreet
RelatedConcerns

PublicTransit

RemovingtherecyclinglotonValleyattheendofthe
710tomakespaceforrenovationandcommunity
beautification
Createwestoverpassfromthe710N,ontoValleyBlvd.
toalleviatetraffic
CreatearoundaboutatValleyBlvd.andthe710
Stopthe710at110andlettheStatemitigatetraffic.
Updatethe110freewaysothattrucktrafficcanbe
divertedtothatroute
Fixthepotholesthatcauseaccidentsdecreasetraffic
Implementbetterbikelanes(maybeevenhavetheir
ownstoplights?)
Grandboulevardswouldprovidebenefitstothe
community,suchas:
o Goodforlocalbusinesses
o Saferforpedestrians
o Slowingtrafficdown
o Reducesthetrafficpollutionwhichleadstobetter
health/airquality
256:CommercetoAltadenaMetrolineistoo
infrequent!IfImissthetrain,Imlatebyanhour!
Increasedfrequencyofthisline(andothers)wouldbe
helpfulthesebusesbreakdownalotandarenoton
time!(concerns/solutionstofixinconsistentbusservice
wasaddressedby4groups)
Interestincaralternativestogetaroundthe
neighborhoodaddmoreDASHstops(3groups
mentioned)
Freeorveryaffordabletransitpricesforstudents(even
directroutestocolleges)(2groupsmentioned)
Moretransitoptionsinsteadofthetunnel(Bus?
Lightrail?)
LocaltransitjustinAlhambra?Busroutes!
ImplementelectricRedCars
MetrothatconnectstoGoldLine
Alightrail/metrolinedownthecenterofthefreeway
thatconnectsLongBeachtoValleyBlvdwouldreduce
traffic(thislineshouldmeetupwiththegreenline)
LightRailshouldbesimilartogreenline
Aparkandrideprogramtotakecommutersinto
Pasadena