Charles Brink's 11-7-01 Comments concerning the proposed Valley New High School.

The DEIR is defective in numerous ways, and because insufficient information is provided, complete comments cannot be provided at this time and the public hearing must be continued until such time as data is available to the community. Here are a few but not nearly all of problems in the DEIR.

Assumption that the high school is a local high school The DEIR claims that there is no need for local elementary or junior high schools but there is a local need for a high school. This flies in the face of logic, as children first go to elementary, then to junior high school, and then on to high school. In researching how LAUSD evaluates the need for a local elementary school I found that LAUSD only looks at students attending LAUSD in its evaluation of needs. It does not look at the population data from the U.S. Census Bureau or students attending private schools within the same region.

Therefore, the conclusion that no local elementary or junior high school is needed is false based on the inadequate research of students who could attend the local schools.

If you assume that the high school is needed for regional not local use, all the traffic analysis of the DEIR is wrong, The DEIR argues only a few of the 888 students will need parking places (73). It states that only 177 trips would be required to get the 888 students and 74 teachers and staff to school. This averages 5.43 persons per car. The DEIR's claims that 54 percent of the students are local and will walk to school are wrong.

The DEIR claims that the proposed school serves as relief for Monroe HS. James Monroe High School is 2.65 mi. in a straight line and over 3 mi. by road, and its students cannot be considered to be within walking distance of the school. See A attached To analyze the traffic one would need to review the attendance by zip code of the Monroe students. I am requesting that data be added to the DEIR and the entire document restated as to its impacts based on the fact that this is not a typical local high school. Fundamentally, the D E I R is flawed by its conclusion that it will be a local high school while simultaneously taking a position that the existing elementary school is unneeded and can be torn down.

Other Cumulative Impacts The EIR does not evaluate the cumulative impacts of numerous previously approved and planned projects in the neighborhood. It's traffic impacts report is the most egregious in its failure to evaluate the impact of tearing down the Prairie Street School and making it a large parking lot with the addtional traffic it would create.

It uses false information in the traffic study in June of 2001, which is during a period that CSUN is closed and summer school has not yet started. Therefore, the traffic counts in the EIR have been understated to allow the project to continue.

It fails to take into effect the additional fully approved expansion of Mini-Med facilities, and the number of apartments and condos that have been planned (and under construction) on Zelzah. Also, various planned CSUN projects including the conversion of the Prairie Street School into a parking lot, expansion of the Faculty Center into a banquet center and numerous projects on the North Campus and various other traffic issues.

One of the most critical intersections, Zelzah and Nordhoff, already has a level of service (LOS) rated F as a failure. It will be made far worse, but absolutely no mitigation is planned or possible according to the DEIR.

Common Use of CSUN Facilities One of the justifications for the preferred school location is common utilization of the CSUN athletic fields, classrooms and Labs by the high school students. From what I can determine there is no agreement between CSUN and LAUSD to allow this use, nor any information on how the vulnerable young high school students would be protected from the adults that attend CSUN. CSUN has had a number of sexual attacks on campus. The issue of how the high school students would be protected must be in the document for the safety of the students.

CSUN has inadequate fields for its own use and according to various articles in its internal newspaper there are complaints of students having inadequate facilities. It would seem the impact of taking away CSUN facilities for use by LAUSD must be included as an impact study.

The same public information indicates CSUN's classrooms and Labs are overcrowded and that CSUN has insufficient facilities and instructors to deal with its own student body. If the prime argument in the DEIR for the facility is to allow the students to attend CSUN classes, the impact of these additional students on the University needs to be evaluated in the DEIR.

Without an agreement on the co-utilization of the athletic fields and the classrooms one cannot comment on its effect. This agreement, or lack of agreement, would radically affect the alternate project of building a larger high school facility at Zelzah and Lassen or the conversion of the larger Prairie site to a High School. The DEIR favors the proposed site because of these nonexistent agreements.

Potential Traffic Mitigation

I brought this up as possible mitigation at the EIS, and it has been ignored in the DEIR. Traffic could be mitigated by reopening Plummer and Lindley through CSUN to relieve the access traffic on Nordhoff and Lassen. The aerial Photo (Figure 2-2) clearly shows Plummer and Lindley continuing through the school with only a small portion of Plummer blocked by landscaping between Lindley and Zelzah. CSUN serves as a roadblock to both North - South and East - West traffic. Some of the worst intersections, Nordhoff and Reseda, Lindely and Zelzah are caused by this roadblock. Reopening Plummer and Lindley as a secondary highway through the school, should be required mitigation for any project at CSUN or the high school because CSUN is the major source for the intersection impacts around the school.

Airport Effects

It should be pointed out that the school is 1.98 mi. from the Van Nuys Airport. This is the busiest general aviation airport in the world, operating hundreds of jets ranging from smallest, and by the way noisiest jets, to 737 business jets. It is public that Disney keeps a large intercontentantal jet at Van Nuys, as the Burbank Airport has not a big enough runway to allow it to takeoff fully laden with fuel for a nonstop trip to Ireland. See B Attached.

The school lies directly beneath the base landings for Van Nuys and is subject to noise pollution.

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