Northridge Community Council Education Committee |
The is the final response to the traffic study concerning the new school. Than you for your assisance and comments
To make it more readable we have added and index and links to the traffic report and DEIR to which we refer
3H.1 Introduction
3H.2 Existing Setting
Existing transit operations
Existing Traffic Conditions
3H.4.2 Project Impacts
2004 with the Project Conditions
Monroe students by zip code
2004 With Project Traffic Analysis - Table 3H-6
Mitigation H-1 ATSAC/ATCS
Mitigations H2 to H5 walk in students
Impact H4 Parking
Impact H5 preferential
parking
Mitigation H-6 traffic
calming
3H.4.3 Cumulative Impacts
Safety
Summary
Education Committee Charles Brink acton@wgn.net
February 4, 2002
Ms Cecilia Masson
LAUSD Office of Environmental Health and Safety
355 S Grand Ave, 6th floor Los Angeles, CA 90071
Via fax 213-633-7100 and mail
Comments on Revised Section 3H Transportation/Traffic and Revised Traffic Impact Report (Appendix F) of the Draft Environmental Impact Report for Valley New High School No. 1 State Clearing House #2001031053
The Northridge Community Council has formed an Education Committee to provide input concerning this project. The community council is formed under the Charter of the City of Los Angeles, and is in the final process of being certified as the official neighborhood council for the community.
The project is well within our borders and while there may be other interest groups, we are the official group that represents the area.
All comments will be keyed to paragraph numbers in the report.
Members of the community made multiple responses to the original traffic report. Some of them had been answered in this new report, but most of them were ignored.
The traffic study fails to take into account all the projects that are pending in the area, along with the foreseeable growth within the area, but in fact limits its study to a few specific developments. By ignoring other pending developments, it falsely presents a lower traffic impact. To index
Reseda Blvd.- has restricted parking from Devonshire St. to Parthenia St. It is not unrestricted parking as claimed.
Zelzah Ave.- the description of this is wrong. You incorrectly describe the entire street as a four-lane roadway with a continuous left turn lane. On the west side between Nordhoff St. and Plummer St. most of the street does not have sidewalks.
In fact the section between Nordhoff St. and Parthenia St. is a two-lane low-density residential street, mostly without curbs and sidewalks. It has already been heavily impacted by CSUN and other projects. Speed bumps have been installed without a great deal of success. Parking is already restricted because of the impact of the University.
Parthenia Street - Parking along Parthenia St. is prohibited in many areas, and is restricted in others. It is not unrestricted parking as claimed.
White Oak Ave. - is shown as a 4-lane highway extending south of Parthenia St. In fact, White Oak Ave. (just like Zelzah Ave.) is a narrow two-lane street from Nordhoff St. to Parthenia St. and terminates at Parthenia St. It does not extend south of Parthenia as the figure shows. The community has been assured that White Oak Ave. will never be widened south of Nordhoff St. and never opened across the railroad. To index
The descriptions of the MTA lines are insufficient to show that these lines will actually be of any use to students attending the Valley New High School.
Line 158 - closest approach is from Devonshire St., which is 0.83 miles north of the school.
Line 166 - closest approach is from Nordhoff St., which is 0.63 miles south of the school.
Line 168 - closest approach would be from Lassen St., which is 0.36 miles north of the school.
Line 167 - is described as traveling on Plummer St. between De Soto Ave. and Woodman Ave. This is not true the University blocks Plummer St. at Zelzah Ave., so the line must detour to either to Lassen St. to the north or to Nordhoff St. to the south.
The description of the line routes clearly indicates that there is no bus service for the school. No line exists along Zelzah Avenue except for this questionable detour of Line 167. Therefore, there is no reasonable public transportation that serves the site of the school. To index
The traffic counts are unusable because they were specifically done at times that CSUN was not in full session. We find it incomprehensible that a school with 29,000 students and 5,000 employees would create only 5,470 morning peak trips. The thousands of employees of CSUN were apparently ignored in the study. Many of our members have seen streets around the University, and especially Nordhoff St., operating at gridlock levels between the 405 freeway and Reseda Blvd. in the morning.
We believe that the methodology chosen to predict the traffic, without CSUN in full session, as well as the referenced but not attached University Market Center project study, to be inaccurate and not acceptable to predict the effects of this project.
Even without the project, three of the four signalized intersections on Zelzah St. are already operating at levels E and F. This is the existing condition without the project, and without the various projects already approved and in the process of completion. Even without the proposed project, the approved projects would render all these intersections to an unmitigatable LOS F by their additional traffic. This is a particularly high burden for the community to bear, as Zelzah St. is strictly a residential street except for CSUN and CSUN’s commercial venture at MiniMed. To index
The cumulative effect of many uncompleted but approved projects in the area was ignored.
An incomplete list of projects that should be added to the study as follows:
1. Special care facility at White Oak Ave. and Devonshire St.
2. Apartments at Halsted St. and Zelzah Ave., approximately 148 units.
3. Various other apartment complexes planned are in the permitting process all along the White Oak Ave./Zelzah Ave. corridor.
4. The proposed development of the North Campus component of the CSUN Master Plan.
5. The expansion of the University Club, its catering/entertainment facility on the south end of CSUN at Prairie The conversion of the Prairie Street School to a parking lot, which will add at least 1500 parking spaces, in addition to the parking spaces already in use.
6. Further analysis of the conversion of all properties from single-family residential use to multi-family units should be included.
7. Medtronics expansion (MiniMed) (excluded because it was not to be completed before the new school was completed.) is mentioned below.
8. Three CSUN parking structures are in the master plan to be built on the west side of the campus. This will allow student enrollment to increase over the years and as a result will also create more cars in the community driving to the structures.
We object to these projects not being added to the existing traffic levels before adding the proposed project. As each of these projects, except items 3 and 7, are approved, the additional traffic predicted from these projects must be included in the pre-project data.
The following statement is from the traffic report:
"Phase III of the MiniMed project will not be constructed until after the proposed Valley High School No. 1 Project is occupied, therefore, traffic associated with this phase of the project is not included in the traffic analysis."
This shows the continuing inadequacy of the report, as phase 3 has been approved by CSUN and it will have no further permitting or public hearings. When it is constructed it will have an effect on the DEIR as it is approved, and its traffic impacts must be included in the pre-project study.
And again from the traffic report:
"As noted in the Draft EIR, the former Prairie School site is currently leased to CSUN for use as a parking lot. Therefore, traffic impacts associated with this site are taken into account in the traffic counts and the traffic analysis. Currently, CSUN has no future plans for the site (written communication with CSUN – December 11, 2001)."
The LAUSD Board required the removal of the school and the re-use by CSUN to be included in the DEIR. CSUN staff has publicly stated at various public meetings the entire approximate 10-acre site would be converted into a parking lot. CSUN now uses only 3 acres for parking. Expanding the full site, including the public streets that would become a private area, to be used by CSUN would add 1500+ parking places and new trips as a direct result of this project. These added trips must be added to the project’s effect. To index
The assumption that the trips caused by this high school will be relevant to trips at other high schools in the valley is flawed. Other valley high schools are local high schools, where students live close to the school, or they're provided transportation by busing.
The DEIR for this project specifically states that no busing (except special-education) will be provided. From the DEIR Executive Summary:
"The only students anticipated to be bused to the new school are Special Education students. Other students will either walk to school, be dropped off by parents or guardians, drive to school, or take public transportation."
The proposed use of the school in the EIR states that it will be solely a reliever school for Monroe High School. From the DEIR 2 Project Description:
2.2.4 Existing School Facility Needs LAUSD's School Facilities Master Plan establishes long-term goals for school facilities including:
"Providing a K-12 neighborhood school seat for every student in LAUSD Reducing class sizes at all grade levels.
To meet these goals, this new high school would relieve overcrowding at Monroe High School and would provide an opportunity to construct an academy high school. Projected enrollment at Monroe High School was over 3,800 students in 2000-2001 (LAUSD, 2000a)."
The Monroe High School attendance area does not even start until Louise Ave., which is 0.702 miles west of the project and Monroe High School is located 2.85 miles east of the project.
LAUSD has provided the following information on the current attendance of students at Monroe High School by zip code.
|
Monroe students by zip code |
||
|
ZIP CODE |
AREA STUDENTS |
% of total |
|
91325 |
89 |
1.87% |
|
91343 |
2125 |
44.69% |
|
91345 |
192 |
4.04% |
|
91402 |
2349 |
49.40% |
|
Total |
4755 |
100.00% |
This is nearly 1000 more than the DEIR states.
You'll note that there are only 89 students come from the adjacent area (91325), and that the majority of the Monroe High School students come from East of the 405 freeway, which is 3 to 5 miles from the new project. At best no more then 89 students can be considered as walking to the school. As there is no public transportation (neither MTA nor LAUSD provided) to the project school, we feel the assumption should be made that the trips to be at least 0.8 per seat instead of the 0.54 as shown in the project. This nearly doubles the trips from 479 to 710.
The DEIR does not propose any students attending from other high schools. The revised traffic study is in conflict with the DEIR by claiming that only 80% of the students will be from Monroe High School and 20% from other schools. We believe this claimed variance for the DEIR was made to minimize the community's complaints about the project.
As the two documents are now in conflict it casts doubt on the accuracy of both documents Even if we believe the revised traffic report and ignore the DEIR, with Cleveland High School located 2.72 miles to the southwest and Granada Hills High School 0.93 miles to the north, the trip ratio will be similar to the Monroe High School students’ trips. To index
This table shows 75% of the trips starting west of Balboa Blvd. This distribution pattern is filled with errors and bad assumptions.
For example- 10% of the trips entering from the east on Parthenia St. are all assumed to turn north at Balboa Blvd. to Plummer St. But the 20% entering from the east on Nordhoff St. all go straight ahead to Zelzah Ave. with only 16% turning north on Zelzah Ave. and 4% are just lost in route.
It is assumed that no one will travel on Superior St.
All these traffic projections fail to recognize that commuters and students will take the least congested path through the least congested intersections to get to school, and not some planner’s arbitrary dream.
The fact that most of the trips come from outside of the project area shows that the study of the project needs to be carried farther east to show the effect of these trips in that community.
The mitigation of a traffic signal at White Oak Ave. and Plummer St. will only force more traffic onto White Oak Ave. The traffic will travel south into the residential community of Sherwood Forest, which already bitterly opposed the recently and unwarranted traffic signal located at White Oak Ave. and Nordhoff St. Therefore, it would not be considered as valid mitigation. It will simply be shifting traffic from one street to another.
We do not accept the position that eight intersections will be fully mitigated.
A mitigation that was proposed by the community, which was not considered in this report, is the reopening of Plummer Street. This street is still an L.A. City owned right of way through the CSUN campus. A look at Table 3H-6 traffic peak A.M. hours shows this would remove 2000 cars going north and south on Zelzah Ave. which would mitigate the LOS E and F intersections at Nordhoff St. and Lassen St. To index
We do not believe that the ATSAC/ATCS will in fact mitigate any traffic problems on these intersections. This system is unproved and has no guaranteed installation date, and for the areas in which it is installed, it has failed to mitigate the traffic congestion. To index
These mitigations are useless as they only deal with walk in students. As the attendance data shows almost no students are close enough to walk to school. Because of the distance between the new high school and Monroe High School, which is the primary source of students, few students will walk.
The impacts are improperly assessed because far more students would have to drive to the new high school because of its greater distance from their homes than students who now drive to Monroe High School. We do not believe the LAUSD can develop any incentive for students to walk 2 to 4 miles each day to class and then home again. To index
Our estimates show that at least 300 parking spaces will be necessary for the students instead of the 67 proposed in the report. Because of the large distance from the students’ residences to the school and because no busing will be provided, most upper division students will drive to the new high school. To index
At a minimum, LAUSD should provide and pay for preferential parking within a 1 mi. radius of the school, based on the approval by petition of the majority of residents on a block-by-block basis. LAUSD should absorb these fees forever. To index
This is speculative in nature and protective of traffic calming measures. Speculative migration cannot be considered in a DEIR, only actual mitigation required as a result of the construction of the project can be considered. To index
The community will not accept the unmitigated impacts along Zelzah Ave. Zelzah Ave. has been turned from a residential street into a major highway by each of the prior projects, which claimed their impacts are were not significant. To index
Student safety is virtually ignored in this study. The study should address the impact of a decrease in safety to the students and their parents in relationship to the traffic congestion being created. The increase of traffic and students increases the probability of accidents. More than crosswalks and crossing guards need to be added.
One of our most important concerns is the safety of the students that will be added to Zelzah Ave., with its lack of sidewalks south of the school to Nordhoff St. (east side), putting both students on foot and in cars at risk.
The proposed school has only one public street facing the school, Zelzah Ave. Most schools, especially High Schools with students driving cars, have several streets surrounding them. Four public streets surround Monroe High School, being a prime example. This provides access to the school from several streets and tends to disperse congestion. At the proposed school, all cars and pedestrians from the school would be "dumped" onto Zelzah Ave.
The current speed of the cars on all the adjacent streets and particularly Zelzah Ave. make it unsafe for students that will be driving or crossing this street. Northbound traffic turning left into the school entrance will be forced to turn across the high speed and heavy flow of traffic going south. The Southbound drivers entering the school will have it easer but when they leave they will be forced to turn left against the same fast heavy flow of terrific putting them at risk.
You should note that a signal was added many years ago at Prairie Street to protect the traffic exiting the school, but no such protection is planned for this high school. To index
This report shows that the prior projects have had cumulative impacts that are significant and they have not yet been mitigated. The claim that the impacts from the prior projects and this proposed project cannot be mitigated unless they widen White Oak Ave. south of Nordhoff St. to a 4 lane highway and extend it across the railroad tracks and then widen Zelzah Ave. to a 4 lane highway to Parthenia St. is not acceptable to the residents of that residential area.
The best mitigation measure is ignored and that is to locate the school where the students actually are. This would conform to LAUSD’s policy as stated in the DEIR.
"2.2.3 LAUSD Facilities Master Plan In response to state and local legislation, and the need to provide additional school facilities throughout the LAUSD, the Los Angeles Board of Education adopted goals and guidelines that provided a policy framework for the development of a Facilities Master Plan (LAUSD, 1998). These basic goals include:
"Allowing K–12 students to attend their neighborhood schools, Providing classroom space for enrollment growth, Providing classroom space to implement Class Size Reduction, Option I, for K–3 in all schools and reduce class size for grades 4–12 to pre-1990 levels
"Allowing special education students to attend schools in their neighborhood."
This could place the school on one of the sites already controlled by LAUSD (the Van Nuys Drive-In or the Carnation Plant). Additionally, LAUSD claims that most of the growth at Monroe High School is caused by conversion of under utilized housing (single-family homes) into apartments in the area between Sepulveda Blvd. and Van Nuys Blvd.
LAUSD should be using some of the same under utilized home sites as new school sites for the children that will be living in these apartments, so they would have schools in their own community. This would substantially eliminate the overloaded streets around CSUN and reduce the travel time, costs, and safety issues to the students, and it would provide neighborhood schools for the students.
In general, we oppose the entire traffic document as inadequate, filled with errors, and containing assumptions that simply ignore obvious impacts.
The result from all of the prior projects, which all claimed to have no significant impact, is that they have produced LOS F intersections for which no mitigation can be provided, except for purchasing and demolishing private homes to widen roads. This shows why LA City fails to serve its residents.
What is being perpetrated on this community is that we’re becoming a copy of New York City – with bumper-to-bumper traffic 24 hours a day. It is nothing less than ridiculous that the residents are being asked to accept this. To index
We recommend that LAUSD spend the 38 million dollars on schools located in the community where the students live instead of at CSUN which is far removed from their residents This will reduce traffic impacts and increase safety, as the schools will be close (within walking distance) to the students.
Or in the alternative, re-do the DEIR and traffic study with correct data and proper mitigations. To index
To traffic page