Glam-harborsubdivision
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October 22, 2008 Kathleen McCune Project Manager Los Angeles County Metropolitan Transportation Authority One Gateway Plaza, Mail Stop: 99-22-3 Los Angeles, CA 90012 [email protected]
DELIVERED VIA EMAIL
Dear Ms. Kathleen McCune: The Harbor Subdivision is a unique asset that unlike most other properties owned by MTA provides the opportunity to connect several communities throughout our broad county in need of high-speed rail transit. This is the second most important transit corridor study currently being conducted by the $3 billion transportation agency, behind only the Downtown Regional Connector. I. The Harbor Subdivision must be studied considering lines likely to branch off the right-of-way MTA purports that it invests in major public infrastructure improvements to solve long-term problems. But corridor specific studies, evaluating short-term 10-20 year forecasts are inconsistent with that stated goal. As with all MTA environmental studies, the scope of the Harbor Subdivision Alternatives Analysis is too narrow. For a corridor with great capabilities such as the Harbor Subdivision, if the customary MTA mistakes are made in this study, the negative repercussions are epic. A tragic mistake in mode or alignment for the Harbor Subdivision could annually cost MTA millions of dollars and tens of millions of riders. The region would feel the mistake for generations. Simply, it is crucial that the Harbor Subdivision be studied in a scope that goes beyond 30 years and beyond the corridor boundaries. London had the vision to build tunnels in the 1860s, which are still operational today. Germans use stations with short spurs branching out, which every citizen understands to be future branch lines that will be built in 40 years. Such long-term visioning is needed if in no other MTA study, in this Harbor Subdivision Alternatives Analysis.
The following is a map of the Harbor Subdivision from Downtown LA to Normandie/Pasatiempo (orange line), included among the existing and underconstruction rail network (color lines) along with rail projects identified in Measure R (black lines):
- Page 1 of 6 P.O. Box 781267 • Los Angeles, CA 90016 • www.GetLAMoving.com
From a regional perspective, it’s clear that the 26-mile corridor will impact the planning of projects that will serve the region for the next 100 years. Specifically, the right-of-way can, should and likely will be utilized by many future lines. A. 405/Sepulveda Corridor Line: Use of the Harbor Subdivision south of the 190th/Crenshaw junction, indeed south of the Marine Avenue Green Line Station must be viewed in the context of a future 405/Sepulveda line. Such a line could connect the San Fernando Valley to the South Bay, serving Westwood, West LA, Palms, Howard Hughes Center/Fox Hills, LAX and the South Bay Galleria, among other locations en route.
The 405/Sepulveda line could eventually extend east to Cal State Long Beach/Veterans Hospital and/or south into San Pedro:
B. Gateway Cities Branch: The Harbor Subdivision presents the opportunity to connect the often-neglected southeast county Gateway Cities to the communities to the west (South Central LA/Inglewood/LAX) and/or north (Downtown LA). The Gateway cities could be connected by utilizing existing rights-of-way: the Los Nietos, La Habra and San Pedro Subdivisions.
- Page 2 of 6 P.O. Box 781267 • Los Angeles, CA 90016 • www.GetLAMoving.com
C. Playa Vista/MDR Branch: The Harbor Subdivision presents the opportunity to connect from the south or east a rail line to serve booming Playa Vista, Howard Hughes Center/Fox Hills, Marina Del Rey and Venice en route to Santa Monica, by branching off the rightof-way at Centinela and continuing down Jefferson and up Lincoln.
D. Crenshaw/Hawthorne Line: While in the near term, a Crenshaw Line that utilizes the right of way west of La Brea/Florence may be appropriate, for decades Crenshaw Line studies considered a line that traveled south down Hawthorne Blvd into Torrance. Hawthorne Blvd south of Florence has the highest residential density of any corridor in the county south of King Blvd and west of the 110 freeway. Such a line, within a broad rail network would prove successful if served by a rail line with fast operating speeds because it would serve a corridor currently without a freeway alternative. None of the above extensions/rail lines will be built tomorrow. But each of the communities/locations that would be served by the above extensions are either major job/economic centers, or dense residential and/or transit-dependent communities. They are communities and locations that eventually will need to be connected to our regional rail network if MTA’s is to ever reach or think of reaching mass transit ridership percentages comparable with other American cities of similar size. Thus, the decisions made in the near term on the Harbor Subdivision will have implications that impact the entire rail transit system in LA County south of the 10 freeway for the next 100 years. Therefore, it is crucial that near term decisions made on the Harbor Subdivision not prohibit the above future extensions 20, 30 or 50 years from now. Specifically, the corridor should be planned for 90-120 second headways or the capability to operate with such in the future, with minimal disruption to operations. There are ways of reducing capital costs of the initial investment, i.e. stations can be built as part of joint-development projects; knock-out walls can be constructed at locations for future stations that can’t afford to be built today, but are known to be needed in the future; projects can be expanded to capture economies of scale; projects can be built shorter; etc. But building incorrectly with limited capacity to expand is far more costly to correct, to the point of cost-prohibitive. - Page 3 of 6 P.O. Box 781267 • Los Angeles, CA 90016 • www.GetLAMoving.com
II. The appropriate mode for the Harbor Subdivision is “Grade Separated Light Rail” A. Light rail vehicles provide the necessary flexibility If the true potential of the corridor is to be maximized, interlining (lines sharing the same tracks) should be and will be utilized on several sections of the Harbor Subdivision. With so many different communities served, a mode and vehicle is necessary that has the flexibility to operate in a variety of environments and integrate smoothly into MTA’s existing infrastructure. Light rail vehicles provide the required flexibility. 1. Future interlining underscores the importance of grade separation The existing horrible traffic on our region’s streets and transit speeds required to handle long-distance commutes alone is enough to require grade separation of rail lines on the Harbor Subdivision. But the need for interlining accents the importance of grade separation, especially in the portion of the Harbor Subdivision between the Slauson Blue Line Station and LAX. "Grade Separated Light Rail” should be the focus of the study and at-grade crossings should have a heavy burden to overcome. B. DMU should be eliminated from consideration. There is no benefit to adding yet another rail mode to the transportation agency’s already diverse rolling stock, each of which requires it's own maintenance specialists, training program, parts department, etc. Within the light rail network alone there are 3 different sets of vehicles, which have compatibility challenges. Couple that with the heavy rail vehicles and the diverse Metrolink engines, and there is already excessive and unnecessary overhead in our region’s transportation agencies. Additionally, the capital costs savings in DMU is highly questionable. Light rail transit can perform equally as well without requiring new rolling stock. C. Metrolink should be eliminated from consideration. (These points also apply to DMU). Given that the corridor travels in the heart of several densely populated and transit dependent communities, Metrolink with 3-5 mile station spacing is insufficient and incompatible with future corridor use. If express service is desired it should be accomplished by constructing siding or a third or fourth track for the light rail mode, so that local service can be maintained for the transit-dependent communities especially between the Slauson Blue Line Station and LAX. Bypassing through South LA residential communities for regional commuters to travel between Downtown LA and LAX also presents several environmental justice issues. 1. Grade separations will be required regardless Any illusion of costs savings from utilizing Metrolink is just that. The proximity to several sensitive properties and busy intersections with blind-corners along the right-of-way, specifically between LAX and the Slauson Blue Line Station is sure to present CPUC, FRA and community challenges, which will ultimately lead to mandated investment in grade separations. Metrolink is the only vehicle on our Southern California roads more deadly than the Blue Line. These grade separations would be and should be required for light rail just the same, and light rail provides the capability of branching off the right-of-way into several communities, thus, there is no apparent benefit to Metrolink. 2. If Metrolink or DMU is the mode, evaluate grade separations utilizing the “life cycle cost analysis” defined in the Guidance on Traffic Control Devices at HighwayRail Grade Crossings published by the USDOT/FHWA in November 2002 at a minimum. If Metrolink is considered, given that no standard currently exists for determining where to grade separate Metrolink crossings, USDOT/FHWA Guidance on Traffic Control Devices at Highway-Rail Grade Crossings presents a base under which to BEGIN evaluation: The decision to grade separate a highway-rail crossing is primarily a matter of economics. - Page 4 of 6 P.O. Box 781267 • Los Angeles, CA 90016 • www.GetLAMoving.com
Investment in a grade separation structure is long-term and impacts many users. Such decisions should be based on long term, fully allocated life cycle costs, including both highway and railroad user costs, rather than on initial construction costs. Such analysis should consider the following: • eliminating train/vehicle collisions (including the resultant property damage and medical costs, and liability); • savings in highway-rail grade crossing surface and crossing signal installation and maintenance costs; • driver delay cost savings; • costs assocated with providing increased highway storage capacity (to accommodate traffic backed up by a train); • fuel and pollution mitigation cost savings (from idling queued vehicles); • effects of any “spillover” congestion on the rest of the roadway system; • the benefits of improved emergency access; • the potential for closing one or more additional adjacent crossings; and • possible train derailment costs. III. Addressing possible freight needs in the South Bay If night-time freight service is necessary in the southern portions of the Harbor Subdivision, an additional track should be constructed in the grade separated trench/tunnel; or “one freight track should be constructed on the surface, while the bulk of rail service on the corridor is below the surface,” similar to the Alameda Corridor. IV. LAXpress with light rail vehicles Express service from Downtown LA to LAX can be accomplished with light rail vehicles interior rearrangements suitable to handle airport passengers. A new fleet of vehicles on is not required. V. Additional environmental issues A. Abandon consideration of using the Right-of-Way between Manhattan Beach Blvd/ROW to Hawthorne/190th. Any passenger rail service in this section of the Harbor Subdivision should be placed in a tunnel or trench with cost-efficient trench stations in the middle of the wide Hawthorne Blvd right-of-way. Such a line would revitalize Hawthorne Blvd, generating higher ridership and creating a true opportunity for smart growth development and a thriving pedestrian oriented district. Comparatively, utilizing the right-of-way through this area would further damage a residential community composed of primarily single-family homes. If MTA continues consideration of this portion of right-of-way and ignores the obvious benefits of traveling under Hawthorne Blvd (benefits which most transportation agencies throughout the country recognize as crucial to the success of a rail transit system and vital to solving housing and economic challenges), the portion of the right-of-way should be trenched or in a tunnel. B. Below grade alignments (trench, cut-and-cover and/or bored tunnels) in all directly adjacent residential communities should be considered and followed through all environmental review phases. C. Environmental justice Future project meetings should be held in the heart of the environmental justice residential communities that will be most impacted by the decisions made, specifically, the communities of South LA, Inglewood, and Huntington Park. The neighborhood councils, and active block clubs and homeowners associations should receive personal presentations. - Page 5 of 6 P.O. Box 781267 • Los Angeles, CA 90016 • www.GetLAMoving.com
VI. Illustration of the regional implications and many possibilities presented by the Harbor Subdivision.
Thank you for your consideration of these issues, and we look forward to working with MTA on this important project. Sincerely, /S/ DAMIEN WESLEY CLARK GOODMON Damien Wesley Clark Goodmon [email protected] Founder
- Page 6 of 6 P.O. Box 781267 • Los Angeles, CA 90016 • www.GetLAMoving.com
DELIVERED VIA EMAIL
Dear Ms. Kathleen McCune: The Harbor Subdivision is a unique asset that unlike most other properties owned by MTA provides the opportunity to connect several communities throughout our broad county in need of high-speed rail transit. This is the second most important transit corridor study currently being conducted by the $3 billion transportation agency, behind only the Downtown Regional Connector. I. The Harbor Subdivision must be studied considering lines likely to branch off the right-of-way MTA purports that it invests in major public infrastructure improvements to solve long-term problems. But corridor specific studies, evaluating short-term 10-20 year forecasts are inconsistent with that stated goal. As with all MTA environmental studies, the scope of the Harbor Subdivision Alternatives Analysis is too narrow. For a corridor with great capabilities such as the Harbor Subdivision, if the customary MTA mistakes are made in this study, the negative repercussions are epic. A tragic mistake in mode or alignment for the Harbor Subdivision could annually cost MTA millions of dollars and tens of millions of riders. The region would feel the mistake for generations. Simply, it is crucial that the Harbor Subdivision be studied in a scope that goes beyond 30 years and beyond the corridor boundaries. London had the vision to build tunnels in the 1860s, which are still operational today. Germans use stations with short spurs branching out, which every citizen understands to be future branch lines that will be built in 40 years. Such long-term visioning is needed if in no other MTA study, in this Harbor Subdivision Alternatives Analysis.
The following is a map of the Harbor Subdivision from Downtown LA to Normandie/Pasatiempo (orange line), included among the existing and underconstruction rail network (color lines) along with rail projects identified in Measure R (black lines):
- Page 1 of 6 P.O. Box 781267 • Los Angeles, CA 90016 • www.GetLAMoving.com
From a regional perspective, it’s clear that the 26-mile corridor will impact the planning of projects that will serve the region for the next 100 years. Specifically, the right-of-way can, should and likely will be utilized by many future lines. A. 405/Sepulveda Corridor Line: Use of the Harbor Subdivision south of the 190th/Crenshaw junction, indeed south of the Marine Avenue Green Line Station must be viewed in the context of a future 405/Sepulveda line. Such a line could connect the San Fernando Valley to the South Bay, serving Westwood, West LA, Palms, Howard Hughes Center/Fox Hills, LAX and the South Bay Galleria, among other locations en route.
The 405/Sepulveda line could eventually extend east to Cal State Long Beach/Veterans Hospital and/or south into San Pedro:
B. Gateway Cities Branch: The Harbor Subdivision presents the opportunity to connect the often-neglected southeast county Gateway Cities to the communities to the west (South Central LA/Inglewood/LAX) and/or north (Downtown LA). The Gateway cities could be connected by utilizing existing rights-of-way: the Los Nietos, La Habra and San Pedro Subdivisions.
- Page 2 of 6 P.O. Box 781267 • Los Angeles, CA 90016 • www.GetLAMoving.com
C. Playa Vista/MDR Branch: The Harbor Subdivision presents the opportunity to connect from the south or east a rail line to serve booming Playa Vista, Howard Hughes Center/Fox Hills, Marina Del Rey and Venice en route to Santa Monica, by branching off the rightof-way at Centinela and continuing down Jefferson and up Lincoln.
D. Crenshaw/Hawthorne Line: While in the near term, a Crenshaw Line that utilizes the right of way west of La Brea/Florence may be appropriate, for decades Crenshaw Line studies considered a line that traveled south down Hawthorne Blvd into Torrance. Hawthorne Blvd south of Florence has the highest residential density of any corridor in the county south of King Blvd and west of the 110 freeway. Such a line, within a broad rail network would prove successful if served by a rail line with fast operating speeds because it would serve a corridor currently without a freeway alternative. None of the above extensions/rail lines will be built tomorrow. But each of the communities/locations that would be served by the above extensions are either major job/economic centers, or dense residential and/or transit-dependent communities. They are communities and locations that eventually will need to be connected to our regional rail network if MTA’s is to ever reach or think of reaching mass transit ridership percentages comparable with other American cities of similar size. Thus, the decisions made in the near term on the Harbor Subdivision will have implications that impact the entire rail transit system in LA County south of the 10 freeway for the next 100 years. Therefore, it is crucial that near term decisions made on the Harbor Subdivision not prohibit the above future extensions 20, 30 or 50 years from now. Specifically, the corridor should be planned for 90-120 second headways or the capability to operate with such in the future, with minimal disruption to operations. There are ways of reducing capital costs of the initial investment, i.e. stations can be built as part of joint-development projects; knock-out walls can be constructed at locations for future stations that can’t afford to be built today, but are known to be needed in the future; projects can be expanded to capture economies of scale; projects can be built shorter; etc. But building incorrectly with limited capacity to expand is far more costly to correct, to the point of cost-prohibitive. - Page 3 of 6 P.O. Box 781267 • Los Angeles, CA 90016 • www.GetLAMoving.com
II. The appropriate mode for the Harbor Subdivision is “Grade Separated Light Rail” A. Light rail vehicles provide the necessary flexibility If the true potential of the corridor is to be maximized, interlining (lines sharing the same tracks) should be and will be utilized on several sections of the Harbor Subdivision. With so many different communities served, a mode and vehicle is necessary that has the flexibility to operate in a variety of environments and integrate smoothly into MTA’s existing infrastructure. Light rail vehicles provide the required flexibility. 1. Future interlining underscores the importance of grade separation The existing horrible traffic on our region’s streets and transit speeds required to handle long-distance commutes alone is enough to require grade separation of rail lines on the Harbor Subdivision. But the need for interlining accents the importance of grade separation, especially in the portion of the Harbor Subdivision between the Slauson Blue Line Station and LAX. "Grade Separated Light Rail” should be the focus of the study and at-grade crossings should have a heavy burden to overcome. B. DMU should be eliminated from consideration. There is no benefit to adding yet another rail mode to the transportation agency’s already diverse rolling stock, each of which requires it's own maintenance specialists, training program, parts department, etc. Within the light rail network alone there are 3 different sets of vehicles, which have compatibility challenges. Couple that with the heavy rail vehicles and the diverse Metrolink engines, and there is already excessive and unnecessary overhead in our region’s transportation agencies. Additionally, the capital costs savings in DMU is highly questionable. Light rail transit can perform equally as well without requiring new rolling stock. C. Metrolink should be eliminated from consideration. (These points also apply to DMU). Given that the corridor travels in the heart of several densely populated and transit dependent communities, Metrolink with 3-5 mile station spacing is insufficient and incompatible with future corridor use. If express service is desired it should be accomplished by constructing siding or a third or fourth track for the light rail mode, so that local service can be maintained for the transit-dependent communities especially between the Slauson Blue Line Station and LAX. Bypassing through South LA residential communities for regional commuters to travel between Downtown LA and LAX also presents several environmental justice issues. 1. Grade separations will be required regardless Any illusion of costs savings from utilizing Metrolink is just that. The proximity to several sensitive properties and busy intersections with blind-corners along the right-of-way, specifically between LAX and the Slauson Blue Line Station is sure to present CPUC, FRA and community challenges, which will ultimately lead to mandated investment in grade separations. Metrolink is the only vehicle on our Southern California roads more deadly than the Blue Line. These grade separations would be and should be required for light rail just the same, and light rail provides the capability of branching off the right-of-way into several communities, thus, there is no apparent benefit to Metrolink. 2. If Metrolink or DMU is the mode, evaluate grade separations utilizing the “life cycle cost analysis” defined in the Guidance on Traffic Control Devices at HighwayRail Grade Crossings published by the USDOT/FHWA in November 2002 at a minimum. If Metrolink is considered, given that no standard currently exists for determining where to grade separate Metrolink crossings, USDOT/FHWA Guidance on Traffic Control Devices at Highway-Rail Grade Crossings presents a base under which to BEGIN evaluation: The decision to grade separate a highway-rail crossing is primarily a matter of economics. - Page 4 of 6 P.O. Box 781267 • Los Angeles, CA 90016 • www.GetLAMoving.com
Investment in a grade separation structure is long-term and impacts many users. Such decisions should be based on long term, fully allocated life cycle costs, including both highway and railroad user costs, rather than on initial construction costs. Such analysis should consider the following: • eliminating train/vehicle collisions (including the resultant property damage and medical costs, and liability); • savings in highway-rail grade crossing surface and crossing signal installation and maintenance costs; • driver delay cost savings; • costs assocated with providing increased highway storage capacity (to accommodate traffic backed up by a train); • fuel and pollution mitigation cost savings (from idling queued vehicles); • effects of any “spillover” congestion on the rest of the roadway system; • the benefits of improved emergency access; • the potential for closing one or more additional adjacent crossings; and • possible train derailment costs. III. Addressing possible freight needs in the South Bay If night-time freight service is necessary in the southern portions of the Harbor Subdivision, an additional track should be constructed in the grade separated trench/tunnel; or “one freight track should be constructed on the surface, while the bulk of rail service on the corridor is below the surface,” similar to the Alameda Corridor. IV. LAXpress with light rail vehicles Express service from Downtown LA to LAX can be accomplished with light rail vehicles interior rearrangements suitable to handle airport passengers. A new fleet of vehicles on is not required. V. Additional environmental issues A. Abandon consideration of using the Right-of-Way between Manhattan Beach Blvd/ROW to Hawthorne/190th. Any passenger rail service in this section of the Harbor Subdivision should be placed in a tunnel or trench with cost-efficient trench stations in the middle of the wide Hawthorne Blvd right-of-way. Such a line would revitalize Hawthorne Blvd, generating higher ridership and creating a true opportunity for smart growth development and a thriving pedestrian oriented district. Comparatively, utilizing the right-of-way through this area would further damage a residential community composed of primarily single-family homes. If MTA continues consideration of this portion of right-of-way and ignores the obvious benefits of traveling under Hawthorne Blvd (benefits which most transportation agencies throughout the country recognize as crucial to the success of a rail transit system and vital to solving housing and economic challenges), the portion of the right-of-way should be trenched or in a tunnel. B. Below grade alignments (trench, cut-and-cover and/or bored tunnels) in all directly adjacent residential communities should be considered and followed through all environmental review phases. C. Environmental justice Future project meetings should be held in the heart of the environmental justice residential communities that will be most impacted by the decisions made, specifically, the communities of South LA, Inglewood, and Huntington Park. The neighborhood councils, and active block clubs and homeowners associations should receive personal presentations. - Page 5 of 6 P.O. Box 781267 • Los Angeles, CA 90016 • www.GetLAMoving.com
VI. Illustration of the regional implications and many possibilities presented by the Harbor Subdivision.
Thank you for your consideration of these issues, and we look forward to working with MTA on this important project. Sincerely, /S/ DAMIEN WESLEY CLARK GOODMON Damien Wesley Clark Goodmon [email protected] Founder
- Page 6 of 6 P.O. Box 781267 • Los Angeles, CA 90016 • www.GetLAMoving.com
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