1

SCH Number: 1982092310 File: O7-LA-710 (SR 710)

Project: EFIS 0700000191 (EA 187900) State Route 710 North Project

Comments on the SR-710 DEIR/DEIS Submitted to Caltrans by Southern California Scientists and Colleagues Who Study the Health Effects of Air

Pollution and Other Public Health Impacts from Transportation Infrastructure Projects

and Related Traffic*

Mr. Garrett Damrath Chief Environmental Planner Caltrans District 7 Division of Environmental Planning 100 S. Main Street, MS-16A Los Angeles, CA 90012 Submitted via website link Hard copy and CD-Rom hand-delivered to District 7 Caltrans Dear Mr. Damrath: As we understand it, a DEIR/EIS is designed to help policymakers better understand the potential impacts of their decisions concerning infrastructure and other projects. As documented below, we do not believe the DEIR/DEIS effectively or successfully serves this purpose. Policymakers reading this version of the DEIR/EIS will have a very difficult time understanding what the air pollution impacts of a proposed SR-710 extension would be, particularly as it pertains to the tunnel alternative. We respectfully submit our concerns as a group of scientists and public health experts. Some of us have been studying the health effects of air pollution in southern California individually and collectively for decades. Others are experts in public health, working to ensure that the community is adequately informed of the potential health impacts of new infrastructure projects, and that proposed infrastructure projects are designed to minimize environmental and health impacts. Southern California has a world-class community of scientists and experts studying the health impacts of air pollution and other impacts from infrastructure projects that is unique in this field. Despite there being hundreds upon hundreds of published papers on this topic by investigators from the University of Southern California (USC), University of California, Los Angeles and Irvine (UCLA and UCI), and other investigators around the world, the DEIR is completely lacking in a discussion of the health effects of air pollution related to the alternatives, other than diffuse claims that the project will “improve air quality.”

2

We are particularly concerned about the increased number of vehicles (and their emissions) that will chose to use a tunnel, if it is selected as an alternative, and the lack of attention in the DEIR/EIS to the increased vehicle emissions on the SR-710 north of the SR-60 Freeway up to the south tunnel portal. We are also very concerned about vehicle emissions inside the tunnel and emissions that will be “vented out” but not necessarily captured by a filter and about the lack of discussion of the health effects from portal emissions, near-roadway emissions, ultrafine particles and diesel exhaust/particulate emissions. We are concerned about other impacts, such as noise, as described below, and of the failure of the DEIR/EIS to address environmental justice concerns in the most vulnerable communities, such as lower-income Latino communities in East Los Angeles. Our overall evaluation of this document and its attachments leads us to conclude the following: The DEIR/DEIS has so many deficiencies related to a lack of information on potential health impacts of the project, particularly of the Tunnel and the LRT alternatives, that we recommend that the DEIR/DEIS be redone and recirculated for review and comment.

This important determination is based upon our identification of the following deficiencies related to public health in the DEIR/EIS:

1. Failure to describe, discuss or cite any of the dozens of studies from around the world, including many from Southern California, linking exposure to near roadway emissions with a wide range of health effects, including, as examples: • Exacerbation of asthma and new cases of asthma (Gauderman et al. 2005;

McConnell et al, 2006; McConnell et al, 2007; Jerrett et al, 2008; Perez L et al , 2012)

• Reduced lung function (Gauderman et al, 2007; Urman et al, 2014) • Cardiovascular heart disease (Brook et al, 2010; Gan et al. 2010, 2011; Hoffmann

et al. 2006; Kan et al. 2008) • Preterm birth, low birth weight and pregnancy disorders (Wu et al, 2009, 2011);

Wilhelm et al, 2012) • Autism (Volk et al, 2011, 2013) • Aging of the brain (Chen et al, 2015) • Possibly obesity and Type 2 diabetes (Weinmayr, G et al, 2015; McConnell et al,

2015) • Overall burden of disease related to near roadway air pollution (Perez et al,

20090; Brandt et al, 2012)

2. Failure to provide an accurate statement of the “Purpose and Need” of the Project with regard to creating a 30-mile connected truck corridor to and from the Ports, which Metro has claimed is a value of this project.

a. Legally, the DEIR/EIS is required to have a well-described and legitimate discussion of why the project is needed and its purpose. There is a failure in the DEIR/DEIS’s purpose and need statement to acknowledge that a major reason for the tunnel alternative in this project is to move goods to and from the Ports of Los Angeles and Long Beach. Obviously, the SR-710 tunnel, when linked to the I-710 goods movement corridor, would create a 30-mile goods movement truck

3

corridor, yet the words “goods movement” or “freight” do not appear in the purpose and need statement.

b. Metro officials have previously stated that this, indeed, is why completing the 710 north gap closure is so valuable. Please see this 2011 statement by Douglas Failing, then executive director of highway programs for Metro: “The 710 north gap closure between the I-10 and the I-210 would complete the natural goods corridor that was begun several decades ago.” Please find this quotation at: http://www.metro.net/news/simple_pr/metro s-highway-program-shifts-high-gear-18-new-pro/

c. Thus, the Purpose and Need of the Project, as stated, is erroneous because it fails to mention that a major purpose of the SR-710 tunnel project is to complete the “goods movement corridor” which heads north from the Ports of Los Angeles and Long Beach, between the I-10 and the I-210 Freeways. For this reason alone, the DEIR/EIS merits revision and recirculation for comments and additional opportunity for review.

3. Failure for the DEIR/EIS to accurately inform the public and policy decision-

makers about the volume and impact of heavy duty diesel big rig trucks in the tunnel – and along the lengthy approach to the tunnel’s portals.

a. The DEIR/DEIS’s truck traffic estimates greatly minimize freight traffic, instead relying on a set of “FAQs” about goods movement which have no citations, admit that detailed truck studies were not performed, and are completely misleading to the public. An example is the following statement from the FAQs: “Construction of a tunnel would not be expected to alter truck traffic destinations. Cars and trucks that are already going north (via surface streets or other freeways) may choose to take a tunnel to reduce their travel time, but no additional truck traffic will go north.” See http://media.metro.net/projects_studies/sr_710/images/sr_710_faqs_goods_movement.pdf. The public and policy makers deserve an accurate and appropriate method for estimating truck traffic in the Tunnel Alternatives – from the Ports and elsewhere – and the DEIR/DEIS should provide one. It currently does not. We request that Caltrans and Metro permanently remove this misleading set of “Frequently Asked Questions” from its web portals and websites.

b. On page 5-35 of the Air Quality Assessment, the DEIR/DEIS states that “there is a possibility that some traffic currently utilizing other routes would be attracted to use the new facility.” This ignores the widely accepted concept of “induced demand,” in which increases in traffic capacity are quickly met with increased traffic volumes whenever a new freeway is built or new lanes added. Certainly Caltrans is aware of the concept of “induced demand” when a new freeway is built. In a 2014 draft policy brief for the California Air Resources Board, two experts concluded that there is usually a growth in both vehicle miles traveled (that is there is “induced demand,” as more people choose to use the new highway) and in greenhouse gas emissions after a “capacity expansion” of a highway. They argue that the “induced demand” generally offsets any reductions in greenhouse gas (GHG) emissions that would result from improved traffic flow (Handy and Boarnet, 2014. “Given the induced travel effect, capacity expansion has limited potential as a strategy for reducing congestion,” Handy and Boarnet conclude. (See

4

http://www.arb.ca.gov/cc/sb375/policies/hwycapacity/highway_capacity_brief-4-21-14.pdf.

c. Truck estimates vary widely throughout the document, and these assumptions are critical to the Health Risk Assessment, the Air Quality Assessment, and other issues in the DEIR/EIS.

i. We note that the SR-710 tunnel project would allow, for the first time, trucks to travel north from the Ports for a continuous 30 miles on the I-710 to SR-710 Freeway directly to the I-210 (and then on north to the Central Valley or east to distribution centers in Riverside and San Bernardino Counties, or other points East). But Table 5.6 on increased VMT that will occur with tunnel project in the Air Quality Assessment makes little sense. It seems to show that at the I-210 eastbound on-ramp, there would be only about 400 more vehicles a day on the on-ramp if the tunnel allowed trucks than if it did not.

ii. Inexplicably, Table 3.5.7 on Truck Performance (see below) shows nearly identical “Vehicle Miles Traveled (VMT) for trucks in the No Build, Light Rail, and Tunnel Alternatives. How can the same VMT for trucks traveling in the “No Trucks Allowed Tunnels” occur as in tunnels that allow trucks? It is imperative to have a valid estimation of trucks in the tunnel if one is to have a valid Health Risk Assessment.

Table 1. 2035 Truck VMT with various alternatives, from the DEIR/EIS

iii. In contrast to the above, which estimates a minimal amount of trucks expected with the Tunnel Alternative, Table 4-12 shows that in 2035 there would be 25,600 trucks a day in the tunnel.

5

Table 2. 2035 modeled truck counts along the I-710 and in the tunnel from the DEIR/EIS

The above table also shows that on the I-710 north of Floral Drive there would be 26,500 trucks anticipated in 2035. Floral Drive is between the SR-60 and the I-10 Freeway. This is a clear indication that East Los Angeles will be seriously impacted by truck traffic when the tunnel opens. See map below for where Floral Drive is.

6

Map 1. Red mark and blue line showing east-west location of Floral Drive in East L.A. This can be matched with truck counts in Caltrans table above.

iv. The current volume of trucks that travel north of the SR-60 and north of the I-10 on the I-710 Freeway were obtained from Caltrans online truck counts and are shown below:

Map 2. Truck Counts Caltrans Data, 2013 in the study area

Floral Drive

7

The above truck counts show that in 2013 there were 16,910 trucks (one way) on the I-710 north of the 5 Freeway. Some 4000 trucks exited on the SR-60. Another 11,000 trucks exited on the I-10, meaning that only 1,239 trucks were left on the I-710 when it ended in Alhambra. These data are from the following Caltrans table of truck counts: Table 3. Caltrans truck counts along the I-710 during 2013

8

v. When using data from the Table 4-12 in the DEIR/EIS, the following maps show how many trucks are on the I-710 today in the study area versus how many are predicted through modeling for the future, when the tunnel is open.

Map 3. Comparison of truck counts in 2013 along the I-710 Freeway and 2035 predictions if the tunnel alternative is selected.

vi.

4. Failure to describe or discuss studies and rulings that conclude that diesel exhaust and diesel particulate are carcinogens, which is critical to understanding the potential health risks of a tunnel alternative.

a. We note that once constructed both the single bore tunnel and the dual bore tunnel would have “diesel PM emissions greater than or equal to the 2025 and 2035 emissions” (see page 35 of Executive Summary/DEIR/EIS).

b. Despite the above, concerns about the health impacts of diesel exhaust and diesel PM are minimized in the DEIR/DEIS. We can locate no mention of the 1998 ruling by the California Air Resources Board naming diesel particulate as a Toxic Air Contaminant because it causes cancer, nor of the 2012 ruling by the World Health Organization’s International Agency for Research on Cancer (IARC) designating “diesel exhaust as a Class I carcinogen.”

c. Page 2-17 of the HRA includes a lengthy description of OEHHA’s risk assessment uncertainties in 2002, but does not include anything about OEHHA’s diesel cancer risk assessment in 1998 (http://www.arb.ca.gov/toxics/dieseltac/part_b.pdf) which summarized more than 40 studies published before 1998 showing the diesel particulate causes cancer. The HRA also does not describe the new OEHHA Diesel Cancer Risk Guidelines

9

(proposed in 2014 and finalized in 2015). See 2014 proposal, issued before the DEIR was released and 2015 final guidance: http://oehha.ca.gov/air/hot_spots/riskguidancedraft2014.html http://oehha.ca.gov/air/hot_spots/hotspots2015.html. To our knowledge, the DEIR/EIS has no discussion of the multitude of studies showing that diesel causes cancer and other health effects, summarized in the the OEHHA document cited above or more recent studies, examples of which are in the References (Zhu et al, 2002; Olsson et al, 2011; Silverman et al, 2012; Attfield et al, 2012; Bhatia et al, 2012; Silverman et al, 2014; Vermeulen et al, 2014).

d. Pages 5-25 and 5-26 of the Air Quality Assessment fail to mention action in California in 1998 that declared diesel as a Toxic Air Contaminant, with a unit risk value of cancer potency for cancer risk. But it has several pages about concerns and uncertainties expressed at the national level about diesel, from the Health Effects Institute and U.S. EPA, in an apparent attempt to downplay the health effects of diesel exhaust. For example: page 3.13-34 of the DEIR/EIS states that: “… there is no national consensus on air dose-response values assumed to protect the public health and welfare for MSAT compounds, and in particular for diesel PM. The EPA and the Health Effects Institute have not established a basis for quantitative risk assessment of diesel PM in ambient settings. There is also the lack of a national consensus on an acceptable level of risk.” However, California’s OEHHA and the regions South Coast AQMD have, respectively, adopted quantitative risk value and an acceptable level of risk, which the DEIR/EIS fails to acknowledge.

5. Failure to use the most recent guidance from OEHHA in development of the Health Risk assessment for determining cancer risk from exposure to diesel exhaust; the HRA must be redone.

a. Although OEHHA had issued a draft of its new guidance document prior to completion of the DEIR/EIS, the Health Risk Assessment fails to include calculations for how this new guidance (now adopted) would impact the HRA. http://oehha.ca.gov/air/hot_spots/riskguidancedraft2014.html. The HRA should redone using the latest guidance document at: http://oehha.ca.gov/air/hot_spots/hotspots2015.html.

6. The Health Risk Assessment (HRA) has many other flaws including inadequate information about the most impacted individuals.

a. It fails to provide all necessary background assumptions about traffic volumes and minimizes the air pollution in both the approach (above SR-60 to the I-10) to and the exit from the South Portal (impacting East L.A. and Alhambra residents). In addition, the HRA does not provide a map showing the most impacted individuals/workers/students (see Table 3-4). An informative map must be included. The HRA must be redone to address traffic approaching the South Portal, to better address the cancer risk which is currently claimed to be “zero” due to the ventilation towers (see page ES-3) which states “Due to the installation of the particulate matter control system at the tunnel ventilation system, vehicle emissions from the tunnel ventilation towers contribute minimally to the cancer risks at the MEIR and MEIW locations” (that is most impacted

10

resident and most impacted worker). Please provide page numbers for these calculations.

b. The Health Risk Assesment states that “the maximum student cancer risk is at Maranatha H.S. west of the SR-710 near the north portal.” Did Caltrans alert this school to the increased noise and cancer risk that this project would bring to the school and its students and teachers?

c. Page 3-8 of the HRA states that “the area with cancer risk greater than 10 in one million is a narrow strip around the north and south portals and the adjacent interchange. There appears to be no analyses performed for increased cancer risks between the SR-60 and the portal of the tunnel even though there would be thousands more vehicles on the freeway when the tunnel opens. This increase in traffic on the I-710 due to the tunnel opening is completely ignored in the DEIR/EIS and its analyses for cancer risk – and for noise (see below). This is a major flaw in the HRA and the DEIR/EIS.

7. Failure to include information on the health impacts of ultrafine particles (UFPs),

the levels of exposure to passengers traveling in the tunnel, whether the UFPs would be “captured” by the particulate filters that are planned in the ventilation stacks, and how far from the portals and approach roads the ultrafine particles would travel.

a. Ultrafine particles (UFP; aerodynamic diameter < 0.1 micrometers) are a ubiquitous exposure in the urban environment and are elevated near highways (Fuller et al, 2012; Zhu et al, 2002a; Zhu et al 2002b; Zhu et al 2006). These particles are considered especially toxic because they can enter the lung, and stay there or get into the systemic circulation.

b. A study done by UCLA and USC researchers documented very high concentration of ultrafine particles in close proximity to the I-710 Freeway in SE Los Angeles. It found that the pollutants start to level off at about 150 meters from the freeway and are “back to background” in about 300 meters [985 feet] from the freeway during daytime dilution conditions. See diagram below from the study (Zhu et al, 2002). In fact, the impacts for ultrafine particles are 10 to 15 times further from the source than are the daytime impacts.

11

Figure 1. Ultrafine particle size distributions near the I-710 Freeway

c. These researchers from UCLA and USC also found that at night time when winds shifted, the pollutant levels of ultrafine particles did not reach background until 300 meters from the freeway (Zhu et al, 2006).

d. Other researchers from UCLA and USC also found that at night time when winds decrease, the concentrations of ultrafine particles did not reach background until 2500 feet from the freeway (Hu et al., 2009).

e. In fact, the impacts for ultrafine particles are 10 to 15 times further from the source than are the daytime impacts.

f. The DEIR/EIS contains no estimates on what levels of UFPs one would expect to find when driving through the enclosed environment of the tunnel, nor what ambient concentrations might be expected downwind from the ventilation stacks or portals.

g. Another study, by UC Davis researchers looked at a number of studies with regard to concentrations from the roadways (Karner et al, 2010). They conclude: ‘In general, concentrations decay to background within a few hundred meters downwind of a road, although studies measuring pollutants solely in the evening hours indicate that higher concentrations persist beyond 500 m (1640 feet)” (citing Zhu et al, 2006). Other researchers from UCLA and USC also found that at night time when winds decrease, the concentrations of ultrafine particles did not reach background until 2500 feet from the freeway (Hu et al., 2009). See graph below from Hu et al, 2009.

12

Figure 2. Ultrafine particles, distance from freeway

Also see table below from the UC Davis study which shows that many pollutants do not reach background level until 1000 meters or more (Karner et al, 2010). Table 4. UC Davis Study summary

The authors concluded that “background normalized results suggest that a range of approximately 160-400 meters [ 525-1312 feet ] is sufficient to reach background concentrations for the majority of pollutants.” Dozens of studies on ultrafine particles by investigators at the UCLA Particle Center directed by John Froines and by Costas Sioutas and his laboratory at USC are not included in any references or discussion in the DEIR/EIS. In fact, there are no

13

references to any studies on ultrafine particles, which is of great importance to the building of a tunnel alternative for the SR-710. (Examples: Delfino et al, 2005; Fanning et al, 2007; Kleinman et al, 2009; Fuller et al, 2012; Zhu et al, 2002; Zhu et al 2006)

8. The Air Quality Assessment (the AQA) has multiple flaws and does not provide adequate information to either the public or policymakers who must select an alternative.

a. The AQA mentions “sensitive receptors” but fails to include a map of where all of the sensitive receptors are. Such a map must be included in a revised DEIR/DEIS. The public and policymakers cannot be expected to “imagine” where the most sensitive receptors are based on seven pages of coordinates rather than visually presenting them on a map in the DEIR/EIS.

b. The Air Quality Assessment fails to describe operating filtration specifications of the ventilation system that will be installed in the tunnel and in the two ventilation stacks, making it nearly impossible to determine the accuracy of the claim that the stacks will remove 80% plus of the particles and gases.

c. Air quality levels are shown in Table 3.13.1 at the South Wilson Pasadena station, but fail to show PM2.5 levels for 2013, without an explanation. Failing to include the most recent levels for a significant pollutant is not acceptable. Similar problem with Tables 4-1 and 4-2 of the air quality analysis which fail to show PM10 levels for multiple years at the Pasadena station.

d. The assessment sometimes refers to tunnel mitigation measures as “scrubbers” and other times as “filtration devices.” There is no discussion of best practices in ventilating tunnels throughout the world. Thus neither the public nor policymakers can evaluate the efficacy of the mitigation measures suggested in the context of experiences elsewhere.

e. If a tunnel alternative is selected, there needs to be a better evaluation of what the contaminant levels and potential health risks inside the tunnel would be for those using the 4-mile tunnel. This needs to include truck estimates, based on validated truck studies (which have not been conducted according to the FAQs). A recent study (Orru et al, 2015.) estimated that there could be increased mortality due to tunnel exposures for those frequently using a proposed high volume urban tunnel in Stockholm.

f. If a tunnel alternative is selected, there needs to be more information about the emissions and air dispersion from both portals of the tunnel and from the tunnel’s ventilation stacks. The stacks are designed to primarily remove particles, not gases. Several experts have evaluated the tunnel ventilation and have submitted a separate set of comments on that topic.

g. We request that Caltrans/Metro describe and detail the maintenance plans for how they will maintain the filtration devices as part of the tunnel air pollution control plan. This cannot be found in the DEIR/EIS.

h. More information is needed to advise the public about details of an “exhaust duct along the entire length of the tunnel and jet fans within the tunnel.” We can find no details about this technology.

9. Failure to estimate what the pollution levels will be at the North and South Portals.

a. These portals are near schools and an acute care hospital and the air that rushes out from traffic will not be filtered at either portal. A voluminous medical literature has demonstrated the acute effects of particulate pollution on heart attacks, yet

14

there is no consideration of the potential impact on patients with heart attacks at Huntington Hospital at high risk of lethal post-infarct arrhythmias.

i. We request that if we are incorrect and the DEIR/EIS includes information about these effects, that the pages on this be made public and sent to u as commenters.

10. The DEIR/DEIS includes a faulty “study area” that fails to include impacted parts of unincorporated East Los Angeles, making this an environmental justice issue.

a. The study area is described as “approximately 100 square miles and generally bounded by I-210 on the north, I-605 on the east, I-10 on the south, and I-5 and SR 2 on the west.” (See front page of DEIR/DEIR). That means that the area between the SR-60 and the I-10 adjacent to the I-710 has not been studied with regard to the Freeway Tunnel Alternatives, thus failing to recognize the immense impact on East L.A. that vehicle traffic will create as drivers travel in or out of the South Portal. (See map below). The map below shows the study area – but the part of East L.A. that is shown is only studied with regard to the LRT alternative, not for the tunnel alternative

Map 4. DEIR/EIS Study Area. Area circled was studied in the DEIR/EIS for the Light Rail Alternative but apparently not for the tunnel alternatives.

b. In addition, the I-710 South DEIR/EIS evaluates impacts only from the south I-710 north to the SR-60, meaning that the East L.A. stretch of the I-710 is not evaluated in either DEIR/DEIS. East L.A. is 97% Hispanic, and there are multiple

15

sensitive receptors in this area. Failure to discuss the impacts of increased emissions and traffic in East LA make this is an environmental justice issue.

Map 5. The SR-710 DEIR/EIS “study area” exclusion zone. East L.A. was studied only for the Light Rail Alternative. It was not studied for volumes of additional truck or other vehicle traffic nor for noise mitigation nor for cancer risk.

c. Table 3-1 claims that there will be a “negative” cancer risk (that is reduced) as a result of building the tunnel alternative.

d. Also Table 3-4 calculates the “incremental cancer risks” for various alternatives. For some unexplained reason no addresses near the South Portal are included (See page 3-6 of HRA). We note that the text of the HRA states that “localized

16

cancer risk increases occur mostly near the tunnel portal areas and extend to the nearby interchanges and highways that vehicles would use as the main routes to or from the new freeway tunnel.”… “In the south, cancer risks would increase near the south portal and extend south to the SR 710/I-10 interchange.”

e. In fact, the cancer risks will not stop at the SR 710/1-10 interchange; they must be evaluated for the area within the area above, extending down to the SR-60. There will be thousands more trucks traversing the I-710 between the SR-60 and the SR-710 and these impacts of adjacent communities are not considered in SR-710 DEIR/EIS

i. If the 25,000 pages of the DEIR/EIS include information about elevated cancer risk from more traffic and more trucks on the I-710 north of SR-60, please provide the page numbers where this information appears.

ii. Again, this area of East L.A. is not considered in the DEIR/EIS and HRA – as though it does not exist and will not be impacted. This is a serious flaw and an environmental justice issue in the DEIR/EIS and HRA. (See page 3-8 of HRA).

f. Despite claims to the contrary in the DEIR/DEIS, if a tunnel alternative is selected, there will be significantly more traffic on the existing stretch of the I-710 Freeway heading north between the SR-60 and the I-10.

i. The DEIR/DEIS must perform an evaluation of the air pollution impacts on homes and schools on this stretch of the I-710. Currently, homes and schools in East L.A. are evaluated only for the light rail alternative. There is no analysis of noise or air pollution impacts in this area, although it will be heavily affected by truck traffic from the Ports of Los Angeles and Long Beach traveling to or from the new tunnel. This is an environmental justice issue.

11. The DEIR identifies high risk receptors near the north portal but not near the

south portal. In Table 3-4 of the HRA, a number of higher risk receptors are identified. Although there are higher risk receptors identified near the NORTH portal, there are none identified near the SOUTH portal. In addition, there is no map showing the areas with highest risk at the South Portal. Although page 3-8 of the HRA states that cancer risks would increase near the South Portal, there is no table showing the locations where that would occur. There need to be maps of the high risk receptors at both portals.

12. The DEIR fails to look at zero emissions technology either for trucks going through the tunnel or for its Bus Rapid Transit (BRT) alternative. Although Metro is the lead agency in the region of a collaborative on use of zero emissions technologies for transportation (see http://www.metro.net/projects/countywide-zero-emission-trucks-collaborative/), there is no discussion of requiring that trucks using the tunnel be zero emission technology nor of having truck age restrictions so that only newer trucks could use the tunnel. Although Metro has just bought five battery-electric buses for its fleet, there is no mention of using this zero emission technology for the BRT alternative, which is listed as an alternative to the tunnel.

13. Concerns about increase noise levels from traffic entering and exiting the tunnel and increased traffic volumes along the approaches to the tunnel are minimized in the DEIR/EIS without scientifically sound analyses or even tables showing the noise measurements and analyses.

17

a. The Project will generate two distinct types of noise impacts: construction equipment noise and traffic noise from the cars and trucks that will travel along the routes to the tunnel and into the tunnel. The World Health Organization recognizes noise, and in particular traffic noise, as a serious public health problem.

b. Given the proposed tunnel construction and increased traffic after it opens, it is likely that the Project will result in significant noise impacts. In addition to identifying residences, the revised document should seek to identify all sensitive receptor sites including each motel and hotel, library, religious institution, hospital, nursing home, active sports area, picnic area, recreation area, playground, active sport area and park that would be potentially affected by noise from the additional traffic that will be on the I-710 Freeway between SR-60 and the approach to the tunnel, if that alternative is selected.

c. Given the serious nature of the Project’s potential noise impacts, in conjunction with the effect that increased noise levels have been shown to have on public health, it is incumbent upon Caltrans through its DEIR/EIS to engage in a meticulous assessment of these potential impacts. The document’s analysis of this issue, however, is subject to the same type of cursory analysis and critical omissions found in the DEIR/S overall.

a. On page 3.3-34, the Community Impact section of the DEIR/DEIS states that both Cal State LA and Marantha High School would experience permanent noise increases of 3dB if the tunnel is built. The DEIR/EIR also states that “based on a visual inspection of the exteriors of these facilities and the warm climate in the portion of Los Angeles County in which these facilities are located, the University and the high school are likely to rely on air conditioning in lieu of opening windows for ventilation; therefore the permanent noise level increases … with the freeway tunnel alternative … would not adversely affect their ability to serve the community.” The DEIR/EIS community impacts report goes on to state that outdoor events at these two campuses would not be likely to be noise-sensitive because they “typically would produce their own noise.” Noise analyses and impact determinations should not be made by “looking” at a school or site. Measurements of existing and estimated future noise impacts should be carefully considered and included in the DEIR/EIS and -- if these have not been done, they should be done and then be included in a revised and recirculated DEIR/EIS. This is a particularly egregious flaw in the DEIR/EIS: evaluating noise impacts through a “visual inspection” is simply unacceptable.

14. Noise mitigation measures are not included for the stretch of the I-710 Freeway between the SR-60 and the I-10, with the exception of noise barriers at a Golf Course and at a Park along the I-710 in this location.

a. A redone and recirculated DEIR/EIS must include noise analyses and noise mitigation measures for the stretch of the I-710 Freeway north of the SR-60 and south of the I-10, which includes East Los Angeles among other communities. This is an environmental justice issue.

18

Maps 6 - 8. The noise mitigation area south of the I-10 along Corporate Center Drive, north of the SR-60, from the DEIR/EIS. The shape includes a golf course in Monterey Park and an adjacent park both alongside Corporate Center Drive. No noise mitigation measures are described for any locations south of this location along the I-710 Freeway between the I-10 and the SR-60, despite the huge volumes of additional traffic there will be, from trucks alone, on this stretch of the Freeway as documented above: Map 6:

Map 7

19

Map 8

15. There are significant environmental justice issues from the various proposed

alternatives, but these have been minimized by Caltrans even though various parts of East L.A. and El Sereno are documented in the DEIR/DEIS to have minority communities that would be disproportionately impacted. Page 3.3-66/67 states that the Build Alternatives “would not cause disproportionately high and adverse effects on any minority or low-income populations under Executive Order 12898 regarding environmental justice.” The graphic below shows the extent of the environmental justice population census tracts just in the area north of the SR-60 and South of the I-10 along the I-710 Freeway. An adequate l environmental justice analysis must be conducted and presented for review to the public.

Blue oval = area of noise barrier mitigation near golf course and park

Red oval = area including East Los Angeles where no noise barriers are proposed despite the dramatic increase of truck traffic there will be in this stretch of the I-710.

20

Map 9.

16. There was a clear lack of public participation and community outreach by Caltrans and Metro to East L.A. in the process of developing the Light Rail (LRT) Alternative.

a. This alternative appears to have been a surprise to many in East L.A., indicating a lack of community engagement by Caltrans on this alternative. There are significant environmental justice issues with the LRT alternative, such as (1) the LRT would be elevated in East L.A. but be in an underground tunnel in wealthier parts of the County, and (2) it would put an elevated rail line down a very popular street in East L.A. See map below.

Map 10. The Light Rail alternative would be “aerial” (elevated) (shown in blue below) in East L.A. and would be underground (pink) in other communities, including Pasadena.

21

b. Significant effects are identified in the DEIR/EIS about this alternative, which would displace numerous businesses and “adversely affect the community character and cohesion of this part of East L.A.,” which we note is 97% Latino.

c. In addition, the LRT alternative would cause permanent noise level increases at the Roybal Comprehensive Center, Catholic Mission of Soledad Church, Soledad Enrichment Action, East L.A. Education Center and Casa Maravilla (East L.A.), as well as Cal State L.A. (See page 3.3-33 of the Community Impacts report).

d. Many aspects of including this alternative, the lack of community awareness about it, and selection of a location that would adversely affect community cohesion and community character, indicate insensitivities by Caltrans and Metro to the East L.A. Latino community – an environmental justice issue. If this alternative is selected, a new stand-alone DEIR/DEIS on this alternative should be developed that includes extensive consultation with the East L.A. community.

For the reasons documented above, we request that the DEIR/DEIS be redone and recirculated for public review. Thank you for your consideration of our comments.

Keck School of Medicine at University of Southern California Department of Preventive Medicine Andrea Hricko, MPH* ** Professor of Clinical Preventive Medicine USC Keck School of Medicine ahricko@usc.edu 323-442-3077

22

Rob McConnell, MD Professor of Preventive Medicine USC Keck School of Medicine Scott Fruin, D.Env. Assistant Professor of Preventive Medicine USC Keck School of Medicine Frank Gilliland, MD, PhD Professor of Preventive Medicine USC Keck School of Medicine Ed Avol, MS Professor of Preventive Medicine USC Keck School of Medicine Tracy Bastain, MPH, PhD Assistant Professor of Clinical Preventive Medicine Rima Habre, ScD Assistant Professor of Clinical Preventive Medicine Kiros Berhane, PhD Professor of Preventive Medicine

University of Southern California Civil and Environmental Engineering

Constantinos Sioutas, ScD Fred Champion Professor of Civil and Environmental Engineering USC UCLA Fielding School of Public Health John Froines, PhD Professor Emeritus UCLA Fielding School of Public Health

Beate Ritz, M.D. Professor UCLA Fielding School of Public Health Ondine S. von Ehrenstein, PhD, MPH, MSc Associate Professor UCLA Fielding School of Public Health

23

Suzanne Paulson, PhD Professor of Atmospheric and Oceanic Sciences UCLA Michael Jerrett, PhD Professor and Chair Department of Environmental Health Sciences and Director, Center for Occupational and Environmental Health UCLA Fielding School of Public Health UC Irvine: Jun Wu, PhD Associate Professor of Public Health Ralph Delfino, MD Professor Epidemiology School of Medicine

*Primary contact for correspondence; all approvals for signatories are on file with Andrea Hricko. Andrea Hricko, MPH Keck School of Medicine of USC 2001 North Soto Street Los Angeles, CA 90089 ahricko@usc.edu 323-442-3077 **Please note that the affiliations of all signatories are for identification purposes only

CC:

Edmund G. Brown, Governor State of California governor@governor.ca.gov

24

Brian P. Kelly, Secretary California State Transportation Agency Brian.Kelly@CalSTA.ca.gov Will Kempton, Executive Director California Transportation Commission Will.kempton@dot.ca.gov Douglas Remedios Please distribute to all CTC Commissioners Douglas.remedios@dot.ca.gov

25

References

[1] M. D. Attfield, P. L. Schleiff, J. H. Lubin, A. Blair, P. A. Stewart, R. Vermeulen, J. B. Coble, and D. T. Silverman, “The Diesel Exhaust in Miners Study: A Cohort Mortality Study With Emphasis on Lung Cancer,” Jnci-Journal Natl. Cancer Inst., vol. 104, no. 11, pp. 869–883, 2012.

[2] W. Babisch, “Noise and health.,” Environ. Health Perspect., vol. 113, no. 1, pp. A14–5, Jan. 2005.

[3] W. Babisch, B. Beule, M. Schust, N. Kersten, and H. Ising, “Traffic noise and risk of myocardial infarction.,” Epidemiology, vol. 16, no. 1, pp. 33–40, Jan. 2005.

[4] R. Beelen, G. Hoek, D. Houthuijs, P. a van den Brandt, R. a Goldbohm, P. Fischer, L. J. Schouten, B. Armstrong, and B. Brunekreef, “The joint association of air pollution and noise from road traffic with cardiovascular mortality in a cohort study.,” Occup. Environ. Med., vol. 66, no. 4, pp. 243–250, 2009.

[5] R. Bhatia, P. Lopipero, and A. H. Smith, “Carcinogenicity of diesel-engine and gasoline-engine exhausts and some nitroarenes - 1-s2.0-S1470204512702802-main.pdf,” Lancet, vol. 13, pp. 663–664, 2012.

[6] S. J. Brandt, L. Perez, N. Kunzli, F. Lurmann, and R. McConnell, “Costs of childhood asthma due to traffic-related pollution in two California communities,” Eur. Respir. J., vol. 40, no. 2, pp. 363–370, 2012.

[7] R. D. Brook, S. Rajagopalan, C. A. Pope, J. R. Brook, A. Bhatnagar, A. V Diez-Roux, F. Holguin, Y. Hong, R. V Luepker, M. A. Mittleman, A. Peters, D. Siscovick, S. C. Smith, L. Whitsel, and J. D. Kaufman, “Particulate matter air pollution and cardiovascular disease: An update to the scientific statement from the American Heart Association.,” Circulation, vol. 121, no. 21, pp. 2331–78, Jun. 2010.

[8] J.-C. Chen, X. Wang, G. A. Wellenius, M. L. Serre, I. Driscoll, R. Casanova, J. J. McArdle, J. E. Manson, H. C. Chui, and M. A. Espeland, “Ambient Air Pollution and Neurotoxicity on Brain Structure: Evidence from Women’s Health Initiative Memory Study.,” Ann. Neurol., Jun. 2015.

[9] C. Clark, R. Crombie, J. Head, I. Van Kamp, E. Van Kempen, and S. a. Stansfeld, “Does traffic-related air pollution explain associations of aircraft and road traffic noise exposure on children’s health and cognition? A secondary analysis of the United Kingdom sample from the RANCH project,” Am. J. Epidemiol., vol. 176, no. 4, pp. 327–337, 2012.

26

[10] H. W. Davies, J. J. Vlaanderen, S. B. Henderson, and M. Brauer, “Correlation between co-exposures to noise and air pollution from traffic sources.,” Occup. Environ. Med., vol. 66, no. 5, pp. 347–350, 2009.

[11] R. J. Delfino, C. Sioutas, and S. Malik, “Potential Role of Ultrafine Particles in Associations between Airborne Particle Mass and Cardiovascular Health,” Environ. Health Perspect., vol. 113, no. 8, pp. 934–946, Mar. 2005.

[12] E. W. Fenning, J. R. Froines, M. J. Utell, M. Lippmann, G. Oberdörster, M. Frampton, J. Godleski, and T. V. Larson, “Particulate matter (PM) research centers (1999-2005) and the role of interdisciplinary center-based research,” Environ. Health Perspect., vol. 117, no. 2, pp. 167–174, 2009.

[13] C. H. Fuller, D. Brugge, P. Williams, M. Mittleman, J. L. Durant, and J. D. Spengler, “Estimation of ultrafine particle concentrations at near-highway residences using data from local and central monitors.,” Atmos. Environ. (1994)., vol. 57, pp. 257–265, Sep. 2012.

[14] W. Q. Gan, M. Koehoorn, H. W. Davies, P. A. Demers, L. Tamburic, and M. Brauer, “Long-term exposure to traffic-related air pollution and the risk of coronary heart disease hospitalization and mortality.,” Environ. Health Perspect., vol. 119, no. 4, pp. 501–7, Apr. 2011.

[15] W. Q. Gan, L. Tamburic, H. W. Davies, P. A. Demers, M. Koehoorn, and M. Brauer, “Changes in residential proximity to road traffic and the risk of death from coronary heart disease.,” Epidemiology, vol. 21, no. 5, pp. 642–9, Sep. 2010.

[16] E. Garshick, F. Laden, J. E. Hart, M. E. Davis, E. A. Eisen, and T. J. Smith, “Lung Cancer and Elemental Carbon Exposure in Trucking Industry Workers,” Env. Heal. Perspect, vol. 120, no. 9, pp. 1301–1306, 2012.

[17] W. J. Gauderman, H. Vora, R. McConnell, K. Berhane, F. Gilliland, D. Thomas, F. Lurmann, E. Avol, N. Kunzli, M. Jerrett, and J. Peters, “Effect of exposure to traffic on lung development from 10 to 18 years of age: a cohort study,” Lancet, vol. 369, no. 9561, pp. 571–577, 2007.

[18] W. J. Gauderman, E. Avol, F. Lurmann, N. Kuenzli, F. Gilliland, J. Peters, and R. McConnell, “Childhood asthma and exposure to traffic and nitrogen dioxide.,” Epidemiology, vol. 16, no. 6, pp. 737–43, Nov. 2005.

[19] S. Handy and M. G. Boarnet, “DRAFT Policy Brief on Highway Capacity and Induced Travel,” Sac, 2014. http://www.arb.ca.gov/cc/sb375/policies/hwycapacity/highway_capacity_brief-4-21-14.pdf

[20] B. Hoffmann, S. Moebus, A. Stang, E.-M. Beck, N. Dragano, S. Möhlenkamp, A. Schmermund, M. Memmesheimer, K. Mann, R. Erbel, and K.-H. Jöckel, “Residence close to high traffic and prevalence of coronary heart disease.,” Eur. Heart J., vol. 27, no. 22, pp. 2696–702, Nov. 2006.

27

[21] S. Hu, S. Fruin, K. Kozawa, S. Mara, S. E. Paulson, and A. M. Winer, “A Wide Area of Air Pollutant Impact Downwind of a Freeway during Pre-Sunrise Hours.,” Atmos. Environ. (1994)., vol. 43, no. 16, pp. 2541–2549, May 2009.

[22] M. Jerrett, K. Shankardass, K. Berhane, W. J. Gauderman, N. Künzli, E. Avol, F. Gilliland, F. Lurmann, J. N. Molitor, J. T. Molitor, D. C. Thomas, J. Peters, and R. McConnell, “Traffic-related air pollution and asthma onset in children: a prospective cohort study with individual exposure measurement.,” Environ. Health Perspect., vol. 116, no. 10, pp. 1433–8, Oct. 2008.

[23] H. Kan, G. Heiss, K. M. Rose, E. A. Whitsel, F. Lurmann, and S. J. London, “Prospective analysis of traffic exposure as a risk factor for incident coronary heart disease: the Atherosclerosis Risk in Communities (ARIC) study.,” Environ. Health Perspect., vol. 116, no. 11, pp. 1463–8, Nov. 2008.

[24] A. A. Karner, D. S. Eisinger, and D. A. Niemeier, “Near-roadway air quality: synthesizing the findings from real-world data.,” Environ. Sci. Technol., vol. 44, no. 14, pp. 5334–44, Jul. 2010.

[25] M. T. Kleinman, C. Sioutas, J. R. Froines, E. Fanning, A. Hamade, L. Mendez, D. Meacher, and M. Oldham, “Inhalation of concentrated ambient particulate matter near a heavily trafficked road stimulates antigen-induced airway responses in mice.,” Inhal. Toxicol., vol. 19 Suppl 1, no. June 2006, pp. 117–126, 2007.

[26] R. McConnell, K. Berhane, L. Yao, M. Jerrett, F. Lurmann, F. Gilliland, N. Kunzli, J. Gauderman, E. Avol, D. Thomas, and J. Peters, “Traffic, susceptibility, and childhood asthma,” Env. Heal. Perspect, vol. 114, no. 5, pp. 766–772, 2006.

[27] R. McConnell, K. Berhane, L. Yao, M. Jerrett, F. Lurmann, F. Gilliland, N. Künzli, J. Gauderman, E. Avol, D. Thomas, and J. Peters, “Traffic, susceptibility, and childhood asthma,” Environ. Health Perspect., vol. 114, no. 5, pp. 766–772, 2006.

[28] A. C. Olsson, P. Gustavsson, H. Kromhout, S. Peters, R. Vermeulen, I. Brüske, B. Pesch, J. Siemiatycki, J. Pintos, T. Brüning, A. Cassidy, H. E. Wichmann, D. Consonni, M. T. Landi, N. Caporaso, N. Plato, F. Merletti, D. Mirabelli, L. Richiardi, K. H. Jöckel, W. Ahrens, H. Pohlabeln, J. Lissowska, N. Szeszenia-Dabrowska, D. Zaridze, I. Stücker, S. Benhamou, V. Bencko, L. Foretova, V. Janout, P. Rudnai, E. Fabianova, R. S. Dumitru, I. M. Gross, B. Kendzia, F. Forastiere, B. Bueno-de-Mesquita, P. Brennan, P. Boffetta, and K. Straif, “Exposure to diesel motor exhaust and lung cancer risk in a pooled analysis from case-control studies in Europe and Canada,” Am. J. Respir. Crit. Care Med., vol. 183, no. 7, pp. 941–948, 2011.

[29] H. Orru, B. Lövenheim, C. Johansson, and B. Forsberg, “Potential health impacts of changes in air pollution exposure associated with moving traffic into a road tunnel.,” J. Expo. Sci. Environ. Epidemiol., Apr. 2015.

[30] H. Orru, B. Lövenheim, C. Johansson, and B. Forsberg, “Potential health impacts of changes in air pollution exposure associated with moving traffic into a road tunnel,” J. Expo. Sci. Environ. Epidemiol., no. April 2014, pp. 1–8, 2015.

28

[31] L. Perez, F. Lurmann, J. Wilson, M. Pastor, S. J. Brandt, N. Kunzli, and R. McConnell, “Near-roadway pollution and childhood asthma: implications for developing ‘win-win’ compact urban development and clean vehicle strategies,” Env. Heal. Perspect, vol. 120, no. 11, pp. 1619–1626, 2012.

[32] L. Perez, N. Künzli, E. Avol, A. M. Hricko, F. Lurmann, E. Nicholas, F. Gilliland, J. Peters, and R. McConnell, “Global goods movement and the local burden of childhood asthma in southern California.,” Am. J. Public Health, vol. 99 Suppl 3, pp. 622–628, 2009.

[33] D. T. Silverman, J. H. Lubin, A. E. Blair, R. Vermeulen, P. A. Stewart, P. L. Schleiff, and M. D. Attfield, “RE: The Diesel Exhaust in Miners Study (DEMS): a nested case-control study of lung cancer and diesel exhaust,” J Natl Cancer Inst, vol. 106, no. 8, 2014.

[34] D. T. Silverman, C. M. Samanic, J. H. Lubin, A. E. Blair, P. A. Stewart, R. Vermeulen, J. B. Coble, N. Rothman, P. L. Schleiff, W. D. Travis, R. G. Ziegler, S. Wacholder, and M. D. Attfield, “The Diesel Exhaust in Miners study: a nested case-control study of lung cancer and diesel exhaust,” J Natl Cancer Inst, vol. 104, no. 11, pp. 855–868, 2012.

[35] R. Urman, R. McConnell, T. Islam, E. L. Avol, F. W. Lurmann, H. Vora, W. S. Linn, E. B. Rappaport, F. D. Gilliland, and W. J. Gauderman, “Associations of children’s lung function with ambient air pollution: joint effects of regional and near-roadway pollutants,” Thorax, vol. 69, no. 6, pp. 540–547, 2014.

[36] R. Vermeulen, D. T. Silverman, E. Garshick, J. Vlaanderen, L. Portengen, and K. Steenland, “Exposure-Response Estimates for Diesel Engine Exhaust and Lung Cancer Mortality Based on Data from Three Occupational Cohorts,” Env. Heal. Perspect, vol. 122, no. 2, pp. 172–177, 2014.

[37] H. E. Volk, F. Lurmann, B. Penfold, I. Hertz-Picciotto, and R. McConnell, “Traffic-related air pollution, particulate matter, and autism,” JAMA Psychiatry, vol. 70, no. 1, pp. 71–77, 2013.

[38] H. E. Volk, I. Hertz-Picciotto, L. Delwiche, F. Lurmann, and R. McConnell, “Residential proximity to freeways and autism in the CHARGE study.,” Environ. Health Perspect., vol. 119, no. 6, pp. 873–7, Jun. 2011.

[39] J. Wu, C. Ren, R. J. Delfino, J. Chung, M. Wilhelm, and B. Ritz, “Association between local traffic-generated air pollution and preeclampsia and preterm delivery in the south coast air basin of California.,” Environ. Health Perspect., vol. 117, no. 11, pp. 1773–9, Nov. 2009.

[40] J. Wu, M. Wilhelm, J. Chung, and B. Ritz, “Comparing exposure assessment methods for traffic-related air pollution in an adverse pregnancy outcome study.,” Environ. Res., vol. 111, no. 5, pp. 685–92, Jul. 2011.

[41] Y. Zhu, W. C. Hinds, S. Kim, and C. Sioutas, “Concentration and size distribution of ultrafine particles near a major highway,” J. Air Waste Manag. Assoc., vol. 52, no. 9, pp. 1032–1042, 2002.

29

[42] Y. Zhu, W. C. Hinds, S. Kim, S. Shen, and C. Sioutas, “Study of ultrafine particles near a major highway with heavy-duty diesel traffic,” Atmos. Environ., vol. 36, no. 27, pp. 4323–4335, Sep. 2002.

[43] Y. Zhu, T. Kuhn, P. Mayo, and W. C. Hinds, “Comparison of Daytime and Nighttime Concentration Profiles and Size Distributions of Ultrafine Particles near a Major Highway,” Environ. Sci. Technol., vol. 40, no. 8, pp. 2531–2536, Apr. 2006.