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SMRR Letter to DEIR Regarding Maintenance Facility for Expo Phase II:

Santa Monicans for Renters Rights, an organization devoted to the protection of renters and to ensuring the continued availability of housing affordable to people of diverse incomes, has concerns about the proposed location of a maintenance yard and traction-power substation facility operating 24/7immediately adjacent to residential neighborhoods. This mixed-income neighborhood of multifamily and single-family homes includes some of the largest concentration of low-income, working-class, and minority residents in Santa Monica — especially immediately abutting the proposed site – raising serious issues of environmental injustice.

A. Noise and Vibration

A1. The DEIR admits that the moderate and severe noise impacts caused by the proposed maintenance yard and power substation (TPSS) for several residential units would exceed federal limits.

A2. Day and night there would be significant noise from high-pressure washing of the light-rail cars as well as testing of horns, lights, brakes, etc., in addition to the din of the traction-power substation, most intensely at the southern edge of the yard, affecting the neighborhood’s poorest residents.

A3. The DEIR fail to address the noise and vibration caused by trains passing over breaks in tracks (called frogs); “wheel squeal,” as trains negotiate sharply curved track; and noise and vibration caused by the repair equipment and facilities.

A4. The site is incompatible with the valuable technology-&-entertainment-office-zoned uses immediately adjacent to the east of the proposed site and just north of it on the other side of the tracks, in particular jeopardizing the specific need for quiet and lack of vibration on the part of sound studios and post-production facilities (which occupy these spaces in accordance with current zoning).

B. Traffic Impacts Unaddressed by the DEIR

B1. Trains crossing Stewart as they slow to enter yard, would block traffic both ways on Stewart especially during rush hours, when traffic to and from the special-office districts on Olympic and Stewart is heaviest.

B2. College students exiting the SMC shuttle parking lot at Stewart & Exposition are required to turn right onto Stewart north towards Olympic to minimize traffic on residential streets; this will exacerbate the congestion caused by the blocking of traffic by trains entering the yard.

B3. There will be traffic impacts from employees entering and exiting the proposed yard parking lot, and by deliveries of equipment and supplies, and the hours of these operations are not stated.

C. Hazardous Substances and Pollution Unaddressed by the DEIR

C1. There might be percolation into soil and/or the water table immediately adjacent to a residential neighborhood by chemicals, heavy metals, degreasers, dirty water from the washing facility, and other hazardous substances. The DEIR does not indicate whether there will be a wastewater treatment plant on the premises, nor whether wastewater will enter the sewage system instead of the storm-drain system.

C2. Liquids and particles laden with chemicals, dirt, and/or heavy metals from the wash-&-dry rooms might be carried through the air to the adjacent residential neighborhood.

C3. Existing soil and water-table conditions at the site have potential implications for the suitability of the site.

C4. The employee parking lot for the maintenance yard at the proposed site is located adjacent to Exposition Boulevard, and in addition to the traffic and noise that would be produced by the coming and going of employees and delivery vehicles, there may be significant amounts of hazardous fumes generated by the idling of these vehicles during congested hours, and during unloading of materials.

The DEIR is deficient in its failure to indicate that alternative locations were given sufficient study. There appear to be nonresidential areas along the line that might be more suitable, but they were not given due and sufficient consideration and study.

For example, during the February 9th, 2009, meeting of the Santa Monica City Council, Mayor Ken Genser suggested as one possible alternative the concrete-processing area along the right-of-way just west of the 405 Freeway. Councilmember Kevin McKeown cited another large block along the right-of-way just beneath and then east of the 405, bounded by Sawtelle , Pico, Sepulveda, and Exposition Boulevards. And there is a site near where the I-10 meets Robertson Boulevard that seems potentially suitable.

D. Questions that remain to be answered – has the agency explored the following?

D1. Acquiring an alternative maintenance yard site since property values have declined and property owners are finding it hard to raise capital for development projects?

D2. Purchasing a site for a smaller maintenance yard and storing vehicles on a side track along the right-of-way until a more appropriate site (i.e., one not adjacent to a residential neighborhood) can be acquired?

D3. Maintaining the cars at the proposed new, large maintenance yard at Union Station, and then storing them on side tracks along the Exposition right-of-way until another more appropriate site (or sites) can be acquired for Expo Phase 1 and 2 storage and/or maintenance?

D4. Using two or more lots to perform maintenance yard and traction-power substation functions?

In conclusion, the sole site proposed and studied for the Expo Phase 2 maintenance yard and traction-power substation is inappropriate, and other alternatives did not receive sufficient study and consideration, and SMRR therefore recommends that an alternative site be found.

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