Date: April 9, 2012
Mr. Stephen Highter, P.E.
Supervising Engineer, Planning Section
Sanitation Districts of Los Angeles County
Facilities Planning Department
1955 Workman Mill Road
Whittier, CA 90601
RE: SCH# 2008101074, Clearwater Program, EIR/EIS CC H # 20 0 81010 74C H # 20 0 81010 74
DearMr. Highter:
This is my set of comments for The Clearwater Program and more importantly, the Joint Water Pollution Control Plant’s, (JWPCP) proposed new Outfall Tunnel System.
I am in great support of The Cleatwater Program and I have stated as much in interviews by staff members of The Clearwater Program, at various times and in various ways and in talking with representatives of my city and local residents of Rancho Palos Verdes and San Pedro. I believe it is necessary to upgrade the Los Angeles County Sanitations Districts’ Joint Outfall System (JOS) and I have been interested in learning more about The Program since I first learned of it, over five years ago.
My biography includes growing up very close to the two existing Joint Outfall Tunnel Systems under Western Avenue in the San Pedro and Rancho Palos Verdes areas. I continue to be a concerned resident of the area in which my wife and I reside.
I believe a new Joint Outfall Tunnel System is now necessary and should be welcomed by all those who would benefit from its construction and usage. My concerns lie not with the need or desire for this new construction, but rather the location of the new Tunnel System and a few of the aspects of the consideration of the Proposed Project’s alignment and construction of the new Joint Outfall Tunnel System.
I have studied the Environmental Impact Report and even though I find myself not as objectionable to the Proposed Project’s planned alignment of Alternative Number 4, as I was initially, both new and existing issues still plague me, with this Alternative and Alternative Number 3.
One of the most important issues I have with further work towards the construction of a new Joint Outfall Tunnel System with both Alternatives 3 and 4 is the fact that damage done to Paseo Del Mar, as a result of landslide activity, will create many new problems not previously considered, even in the EIR/EIS.
I am in agreement that the potential for new construction for any new Joint Outfall Tunnel System and Exit Shaft will not cause further damage to any area with landslide activity and I have confidence in the studies performed on the Geology of the areas, in the Report.
My major concern in this particular issue are the facts surrounding the possibilities that a major transit route for residents, visitors, construction teams and others has been eliminated from the areas near the sites for Alternative Nos. 3 and 4 and that there is no reconciliation of the landslide/road closure and there does not appear to be study or further analysis discussed between the Sanitation Districts and the City of Los Angeles, Department of Transportation, regarding these matters.
I feel very strongly that before much further study and work on the Proposed Project continues, everyone needs to feel confident that Paseo Del Mar will be restored to a viable thoroughfare long before any physical activity on a new Outfall Tunnel begins.
Another issue I found to be of concern is the routing of dirt haulers and other construction traffic related to the Proposed Project, Alternative Number 4 as it relates to routes not very well suggested in the EIR though the streets of San Pedro and/or the city of Rancho Palos Verdes.
I noted with the intersections where traffic counts were taken, they included intersections where construction vehicles might turn, but not necessarily through intersections that might see that particular traffic continue through, without turning.
One such intersection I found to be very lacking in study is the intersection of 25TH Street and Western Avenue, in San Pedro.
Since it appears to me in the EIR/EIS, that construction vehicles MIGHT not utilize this particular intersection for turning, it was left out of much of the traffic counts provided for other intersections.
This alarms me because that intersection would be used exclusively for most, if not all vehicle traffic related to the Proposed Project, Alternative Number 4, in relation to the Exit Shaft and other construction planned for the Royal Palms area of San Pedro.
It appears that no truck route is truly suggested for ingress and egress of traffic related to The Clearwater Program in the area of Royal Palms in San Pedro. The Report does not state whether large construction vehicles will proceed along Western Avenue, turn east onto 9TH Street, then north onto Gaffey Street, to access the (110) Harbor Freeway, as some have stated.
I feel this is a major issue at it relates to placing the Exit Shaft and other construction as proposed in Alternative Number 4.
Since there doesn’t seem to have been any ‘real’ documented study as to the routes through San Pedro, to be taken by massive dirt haulers and other construction vehicles, I find this particular portion of the EIR sorely lacking and in need of much further study long before any construction begins.
With the exception of residences and businesses in the ‘South Shores’ areas of San Pedro, most residents and businesses would not have any use for any new Tunnel System by the JWPCP, because the vast majority of those impacted during the construction period for Alternatives 3 and 4 use the city of Los Angeles’ Sewage Treatment Plant on Terminal Island.
While it is my strong opinion that a new Outfall Tunnel is necessary, I must conclude that there has not been sufficient study with potential traffic issues related to both the Proposed Project and Alternative Number 3. This is made much stronger since I learned via a person within The Clearwater Program’s representation, that little has been done between the Sanitation Districts and the city of Los Angeles concerning the entire scope of having lost Paseo Del Mar, in San Pedro, as a viable route and that this situation has the potential of becoming a permanent problem that was never studied, to this point.
I also feel it is unfair to task so many residents and businesses with the issues of having a major construction project for something they will not use. Those who would utilize the new Outfall Tunnel will benefit at the expense, for a period of time, of so many who would not only not have use of any new Outfall Tunnel, but would be encumbered with many negatives during construction periods and environmental issues that could linger even after a new Outfall Tunnel is finished.
While Alternative Number 1 is the most expensive and could take the longest construction period, I feel it remains the best Alternative for all and the aspects including close freeway access and potential rail transportation of diggings could be accomplished with Alternatives Numbers 1 and 2.
It was and remains my hope that the comment period of the EIR/EIS be extended or paused to allow for further study of the potential impacts caused by the unfortunate collapse of Paseo Del Mar and the now very necessary complete study and implementation of a positive resolution because of the unplanned loss of such a major roadbed.
I would also urge a much more thorough set of studies and information provision to all the residents and business owners near the areas of the Proposed Project’s route and Exit Shaft, so they are much more well informed about what representatives of The Los Angeles County Sanitation Districts intend to do or participate in the resolution of the Paseo Del Mar situation and all the potential routes dealing with construction traffic related to the Proposed Project, Alternative 4 and the entire scope of possibilities should that Alternative be ultimately selected as the final route for a new Joint Outfall Tunnel.
I do understand that this EIR/EIS had many of its studies done several years ago. But things change and there has been at least one very big change since the Traffic Studies were done, several years ago.
Also troubling to many I have talked to is the fact that the EIR/EIS does not include enough information and study to indicate the possible routes of large dirt haulers and other construction traffic though San Pedro. I feel this should be a major concern to all those who live along any possible route where they will be impacted by construction traffic for an extended period of time.
Thank you for your considerations.
Regards,
Mark Wells
Rancho Palos Verdes Resident
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