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2009 OCT 20 - CC PACKET - Item 9 MTA Crenshaw Transit Corridor ProjectElected Officials: Kelly McDowell, Mayor Eric K. Busch, Mayor Pro Tem Carl Jacobson, Council Member Bill Fisher Council Member Don Brann, Council Member Cindy Mortesen, City Clerk Ralph Lanphere, City Treasurer Appointed Officials: Jack Wayt, City Manager Mark D. Hensley, City Attorney Department Directors Bill Crowe, Assistant City Manager Deborah Cullen, Finance Robert Hyland, Human Resources Kevin Smith, Fire Chief Debra Brighton, Library Services Greg Carpenter, Planning and Building Safety David Cummings, Police Chief Dana Greenwood, Public Works Robert Cummings, Recreation d Parks www.elsegundo.org October 22, 2009 i Office of the City Manager Mr Roderick Diaz, Project Manager Los Angeles County Metropolitan Transportation Authority One Gateway Plaza, MS 99 -22 -3 Los Angeles, CA 90012 -2952 Re: Comments Regarding the Crenshaw Transit Corridor Project Draft Environmental Impact Statement /Draft Environmental Impact Report The City of El Segundo has reviewed the Draft Environmental Impact Statement /Draft Environmental Impact Report (DEIS /DEIR) and has serious concerns about the adequacy of the environmental review for the proposed Site "D" maintenance and operations (M and O) facility. The review of this facility contained in the DEIS /DEIR is incomplete, internally inconsistent, and in certain instances does not correctly analyze information. Theanalysis of the M and O facility is not a minor and insignificant component the project. The M and O facility includes a substantial portion of land and involves the construction of numerous buildings within the City of El Segundo, T.he=Omprise for this project component is more than 55 million dollars Table - and 5% to 7% of the overall capital cost of the Crenshaw Corridor project. The 55 million dollar figure does not include site acquisition, rail line relocation and site remediation costs, which all should be identified to disclose the total cost of placing the maintenance facility at the Site "D" location. The DEIS/DEIR does not contain an adequate level of environmental review f and 0 the proposed M and O facility. The Site "D„ or analysis to ensure compliance with the National Envirronmental Policy a full (NEPA) and California Enviromnental Quality Act (CE QA). Act be analyzed and fully disclosed prior to certification Qof the IDE S /DEIReand decision- making on the project. i 350 Main Street, El Segundo, California 90245 -3893 FAX (390) 322 -7137 Phone (390) 524 -2309 F I• PROJECT DESCRIPTION A) Where is Site "D "? The Executive Summary (ES -26) states that the ultimate facility size will be determined once the project operating plan is finalized. CEQA does not permit deferral of defining the scope of a project. An EIR must have an accurate and complete project description. The DEIS/DEIR contains numerous different, incomplete and conflicting descriptions of Site "D." The presentation of conflicting information on the boundaries and scope of the Site "D" maintenance facility results in questionable environmental conclusions. El Segundo City Staff identified at least five variations of Site "D" boundaries in the document. None of the descriptions are consistent with each other and in some cases there are significant discrepancies in size and configuration. The identified variations of the Site "D" project area are as follows: 1) An aerial photo diagram that outlines Site "D" is included on pages ES- 16, ES -21 and 2 -17. This diagram identifies Site "D" asi a landlocked rectangular portion of land 14.8 acres in size, bounded by vacant land on two sides and by existing rail corridors on two other sides. 2) Two conceptual diagrams included in Volume II for the Site "D" Bus Rapid Transit (BRT) M and O facility (C -148) and the Site "D" Light Rail Transit (LRT) M and O facility (C -436) define the project area much differently than the aerial photo. Both conceptual engineering drawings appear to be much larger areas of land that include portions of parcels that are located as far east as Douglas Street and could potentially involve parcels with occupied buildings. i 3) There is a list of Site "D" affected parcels (Table 4 -12). There are 13 parcels on this list. City calculations identify that the 13 parcels have a total area of 29.88 acres. When these parcels are highlighted on a map, it appears the area affected does not match either the conceptual drawings or the aerial photo. Also this list of parcels does not include either the Union Pacific (UPRR) or the Burlington Northern Santa Fe (BNSF) railway right -of -way which would make using this grouping of parcels impossible to use as the site would be bisected by both existing rail lines; Therefore it is clear that the list in Table 4 -12 does not even include all the parcels that are affected. 4) There is a verbal description of the project area on page 2 -16 of the document that describes Site "D" as bounded by the Harbor Subdivision, a Union Pacific Branch Line and Rosecrans Avenue. This description does not correspond with either of the conceptual drawings for the facility, the aerial diagram nor the list of affected parcels. 5) In the analysis of impacts on property revenues Site "D" is identified as being 29.3 acres in size and comprised of 12 parcels (page 4 -401). This identifies an area more than ten acres larger than the size referenced in the Executive Summary and the rest of the document. The DEIS does not contain any clear definition of the 29.3 acres that are included in the economic impact section. An accurate analysis of the environmental impacts of this portion of the project is impossible without consistency in the maintenance facility description. Questions regarding vehicle access, facilities buffering, visual quality, biological resources, hazardous materials, archeological resources, cultural resources, economic impacts, impacts to existing rail lines and impacts to adjacent landowners cannot be adequately addressed without a consistent and more precise description of the land area involved. Certain environmental determinations within the DEIS/DEIR are incorrect if Site "D" consists of the area identified in the BRT and LRT M and O facility conceptual drawings. These include the following: • Page 4 -76 states "Site D does not include any buildings. Therefore, relocation assistance would not be required." This statement is not correct if the LRT maintenance facility is built in the configuration shown on drawing C -436. Under this circumstance at least one existing commercial building, if not more, would be affected by the project and relocation assistance would be required. • Page 4 -318 states "Site D is located on vacant industrial land located between and surrounded by two existing freight railroad lines." If the boundaries of Site "D" are accurately reflected in the conceptual drawings or comprised of the list of affected parcels (page 4 -75) this statement is inaccurate. Based Upon the scenarios identified in the conceptual drawings, the site area is much larger than the area defined on Page 4 -318 and the site area would incorporate the existing rail lines as well as additional parcels located beyond the rail lines. The parcels involved would include parcels that are not vacant. Occupied buildings would be included in the project area. Industrial uses and a recreational vehicle storage use would be included in the project area. Under those scenarios the site area .is much larger than defined in this statement and would incorporate the existing rail -lines as well as parcels beyond the rail lines, and incorporate parcels and buildings that are not vacant, that are currently used for industrial and recreational vehicle storage uses. I B) What Does the M and O Facility Consist of? The document states in section 2.1.3 Maintenance and Operations Facilities Screening "The size, location, construction and operations of the required light 3 rail vehicle (LRV) maintenance and operations facilities must be considered as part of the BRT and LRT Alternative evaluation." However the size and scope of the Site "D" M and O facility is inconsistent in the document, which raises questions about the adequacy of the environmental evaluation. Page 2 -32 of the document describes the BRT M and O facility as having an initial capacity of 24 buses. with a capacity of 100 buses at maximum buildout. The facility would have a 40,000 square -foot administrative building, 30,000 square foot maintenance building, a paint and body shop, and parking for 150 employees and visitor vehicles. This is inconsistent with conceptual drawing C- 148, which shows a much larger BRT M and O facility with a 300 bus capacity, 50,000 square -foot administrative building, 40,000 maintenance facility, 27,000 square -foot heavy repairs facility, and parking for 300 employee and visitor vehicles. Page 2 -46 of the document describes the LRT M and O facility as having capacity of 60 light rail vehicles with a 50,000 square foot,' administrat' building, and other associated facilities and parking for 200 employee and visitor vehicles. This is not consistent with conceptual drawing C -436 which shows a facility with a capacity of 102 light rail vehicles, a 55,000 square -foot administrative building, other associated facilities and parking for' well over 230 employee and visitor vehicles. The M and O facility conceptual drawings for the BRT site (C -148) and LRT site (C -436) identify potential building locations for the structures associated with the facility. These building footprints appear to be very small compared to the size of structures that they represent. For example the 55,000 square foot administration building identified on the LRT site plan appears to have a building footprint of less than 6,000 square feet. Is this building intended to be 9 or 10 stories in height? It is important that this information be clear in the project; description so that the project can be adequately analyzed for visual impacts, zoning and buffers. Additional City comments on the size, construction and operations of the M and O Facility include: • The document contains no discussion of environmental impacts on the properties surrounding Site "D ". This topic should be analyzed in the DEIS/DEIR. The maintenance facility is not compatible with the adjacent retail and dining commercial uses. I • The description of Site "D" as vacant land is inaccurate. There are existing uses on the site. There is a former brass foundry foundation at the site. There is an existing recreational vehicle storage business at the site. Also there is the potential that the project site includes parcels with occupied buildings. 11 C) Are Rail Lines in the Project Area? It is unclear from the differing project descriptions whether the two existing rail lines are affected by the project. There is a general statement on Page 4 -318 that the project includes the relocation as necessary of the existing UPRR and BNSF rail - lines. The document contains no analysis on how this will occur and the impacts of this relocation. Some questions that need to be answered regarding this statement include: Will the relocation affect where the trains cross Douglas Street? Will the rail relocation affect the viability of commercial development on adjacent parcels? Will the rail relocation increase the physical land area affected by this project? Are the associated relocation costs included in the cost estimate, and if not, what are they projected to be? The Chevron Corporation is the primary user of the rail network in the project area. How will the project affect this company's railway access? Will the current amount of storage and stacking space for freight cars be maintained? Is consolidation of the two existing tracks planned? D), How Does Access to Site "D" Occur? The environmental document contains no discussion of how employees, visitors and emergency service vehicles access Site "D." The engineering drawings in Volume II Appendix A for Site D are unclear as to how access is provided as nothing is labeled on the drawings. It appears that the intent may be to include a proposed access point at Douglas Street. The location depicted is currently a gated entry restricted for use by City of El Segundo emergency service vehicles only. Will access be taken from Douglas Street as it appears to be depicted on the BR -T conceptual plan (C -148) or will access occur from some other location? Some of the questions that are not answered by the environmental document include: Is an intersection required on Douglas Street? Are mitigation measures to maintain adequate traffic circulation on Douglas Street necessary as a result of this project? Would access to the site be located within close proximity of other intersections on Douglas Street and pose a public safety hazard? How would Douglas Street access to the site interface with the two existing rail lines that cross Douglas Street? A complete discussion of the access proposed for both the LRT and BRT maintenance facility alternatives must be included in the DEIS/DEIR. This discussion should include: general plan and zoning compliance, street width requirements, necessary street frontage, street capacity, adequacy of access and safety. II. SUMMARY TABLES There are two tables addressing the M and O facility impacts. In reviewing these two tables the City of El Segundo believes the statements made in these tables regarding Site 5 "D" cannot be substantiated because of lack of adequate review and analysis in the DEIS/DEIR. The first table, the screening summary, is identified as Table ES -2 in ' the Executive Summary and Table 2 -3 in the DEIS/DEIR. The statements in this table are highly subjective and are not supported by the analysis in the DEIS/DEIR. The City disagrees with the following statements in this table regarding Site "D ": Criteria DEIS/DEIR Statement for Site "D" Size and Proximity 14.8 Acres; not directly adjacent to alignment Land Use and Vacant; zoned Zoning commercial and industrial Buffers Buffers unnecessary Potential Greatest potential Expansion Community Low Disruption Pre - Emption Best of Most City of El Segundo Response 'regarding Site "D" Because of numerous conflicts and inadequate information in the document, the FThersize of the roject cannot be determined. e that the land is vacant is incorrect. parcels that appear within the a to have uses, as well as existing cu estructures. Strongly disagree with this statement as this site could directly abut a major existing commercial area and the future expansion of that commercial area and planned development projects. Placement of this facility could impact the adjacent existing and new commercial areas. Not possible without significant disruption of existing freight rail lines serving the Chevron Refinery and obstructing the ability to construct the planned Park Place Roadway extension. Location of facility would conflict with the stated General Plan Circulation Element goal of an additional east west roadway connection in the City for the future extension of Park Place (a portion of this roadway is already constructed) Completion of this roadway is also a mitigation measure for the Plaza El Segundo commercial development in the FEIR for the, project. Pre - empting this link could affect future area traffic and severely restrict future expansion of Plaza El Segundo, which could have substantial environmental and economic consequences. This conclusion is not supported) as the DEIS/DEIR contains no discussion of m Valuable/Best existing environmental documents and Use entitlements for the area in question. The land use could pre -empt the development of the area as a regional shopping and employment center through direct displacement or by being a conflicting adjacent land use. The second table is the "Summary of Impacts of the Maintenance and Operations Facilities" identified as Table 5 -3 within the DEIS/DEIR, and is reproduced in an abridged form as Table ES -5 in the Executive Summary. The City asserts that the following, environmental impact conclusions regarding the Site "D" M and O Facility are erroneous: Project GoaUCriteria DEIS/DEIR City of El Segundo Response regarding statement Site "D" regarding Site "D" Visual Quality No Adverse Effect M and O Facility Adverse, no Local Land Use and Development Consistent Conflicts with local zoning, General Plan Transportation No Adverse Effect and existing entitlements. Not enough information to make this Biological Resources with mitigation. determination, need a traffic study, need Division of an Established No Adverse Effect more detail on access and railroad impacts Adverse Effect, based on impacts to locally adopted and �nmmnr;t'. plans entitlements City of El Segundo Consistent General Plan Displacements I partial parcels 3 full parcels Visual Quality No Adverse Effect Air Quality Adverse, no mitigation feasible Noise and Vibration No Adverse Effect i Ecosystem and No Adverse Effect Biological Resources with mitigation. Native trees and vegetation removed 7 Project will dir�conflict ith Ci ty's General Plan. Cannot be determined based on the conflicting information presented in the document. Inadequate analysis, mitigations may be necessary to buffer facility from conflicting commercial land uses some mitigations should be included to lessen the adverse impacts of the facility Operational noise impacts should be analyzed and mitigated given this facility will be located next to a retail /dining commercial facility. Also noise impacts of turning movements of LRT facility should be analyzed and mitigated. Inadequate documentation of why no impact conclusion was reached. No information about a formal study conducted by oualifie.rl PXnPrt (ieotectinical/ No Adverse effect Incomplete and defen Hazards with mitigation review required to ad( Water No Adverse Effects Operations of facility Historic, No Adverse Effects ualit , should be ana Ground disturbance w Archaeological, mitigations should be Paleontological any disturbed resourcf Economic No Adverse Incomplete and flawe( Effects, $72,100 take into account full property tax loss the City of El Segundo Safety and Security No Adverse Effects No analysis of safety i Environmental No Adverse Effects facility. Should be stu The facility adds to ov Justice large regionally- servin in and immediately ad El Segundo that create quality, noise, safety ai materials impacts. ed analysis, complete could impact water lyzed and mitigates ill occur. Basic in place to protect S. I analysis. Does not :conomic impact on ssues related to the died and mitigated. ,rconcentration of g industrial facilities acent to the City of significant air id hazardous A more detailed discussion of each of the above issues is included in the next section of this letter. III. ENVIRONMENTAL ANALYSIS The City of El Segundo has the following comments and concerns! regarding the environmental analysis: A) 3.0 Transportation Impacts Page 3 -1 of the document states that "regardless of level of significance, all potentially adverse environmental impacts have been analyzed and mitigations proposed where feasible to reduce identified adverse impacts." The City disagrees that all potential adverse environmental impacts regarding transportation have been analyzed and appropriate mitigations been identified for Site ` °D ". There is insufficient information in the DEIS/DEIR to conclude that there is no adverse effect that would occur with the construction of a maintenance facility at Site "D ". A traffic study must be prepared that analyzes Site "D ". The analysis of the traffic impacts of the Site "D" maintenance facility consists of the following statement (Page 3 -51): "The addition of traffic to the street system as a result of staffing at these facilities is not projected to cause any increase in intersection delay. This conclusion was reached because principal arrival and departure times for employees are outside of typical weekday peak Have] periods. The impact analysis considers peak period for adverse impacts; therefore, no further analysis is required." The City considers this an inadequate analysis of the facility's traffic impacts. There is no discussion of how the maintenance facility operates to substantiate the statement that it will not generate any trips during peak periods. The document contains no information about how many individuals work at the facility and what the regular shifts are for the employees. The conceptual drawings (C -436 and C -148) show an administrative facility of up to 55,000 square feet with employee parking for close to three hundred vehicles. Do administrative personnel at the site also work irregular hours and not generate peak period trips? At a minimum the document should contain a mitigation measure to ensure that no new peak period trips are generated by the project. There is no analysis of the vehicle access to the Site "D" facility, therefore it is impossible to conclude whether the facility's interface with the local roadway network is adequate, feasible or has traffic impacts. The BRT maintenance facility conceptual drawing (C -148) appears to have vehicle access from Douglas Street. All other versions of the site contained in the DEIS/DEIR do not show or mention how employees will access the site. Providing basic access information is necessary to allow for analysis of how public safety (police and fire) personnel, facility maintenance personnel, and visitors access the site, whether the project could potentially affect existing rail alignments that cross Douglas Street and whether site access will conflict with existing intersections that exist on Douglas Street. The proposed BRT alternative would end at the Aviation Station. This is approximately V/2 miles away from Site "D." There is no discussion of the effects of moving "out of service" buses to and from the maintenance facility therefore the City is unable to assess the impacts of bus transfer operations on local streets. Why weren't site alternatives closer to Aviation Station considered for the BRT M and O facility? For example there are areas located under the 105 Freeway on Imperial Boulevard east of Aviation Boulevard that are very close to the Aviation Station that may be suitable for this facility. Also there is the possibility of incorporating the facility into the Aviation Station site itself. Other traffic and transportation comments the City has are: • 'The plans and project description do not discuss the impacts on freight rail ;service to Chevron. The Chevron El Segundo refinery processes approximately 5.2 million gallons of gasoline, 3.9 million gallons of jet fuel, and 170,000 gallons of LPG daily. Uninterrupted access to the refinery by rail IS imperative and needs to be more completely addressed in the DEIR. The City is currently unable to assess if there are traffic, circulation or other impacts on the facility. • The location of the Site D M and O Facility and /or its possible expansion will potentially eliminate the ability to construct the planned Park Place roadway extension identified in the City's General Plan and the Plaza El Segundo EIR. Not building this roadway could create a future impact to the operation and 9 level of service at the intersection of Rosecrans Avenue and Sepulveda Boulevard. • How will the LRT facility connect to the Green Line? A review of the environmental implications of connecting to the elevated track is necessary. • The existing Aviation Station provides a park and ride facility. ! City Staff has observed that this parking facility is well used and at capacity. With the addition of the Crenshaw Corridor Transit Line, additional parking should be provided at the Aviation Station to service the increased parking demand. The discussion in the DEIS/DE1R on Page 3 -61 does not identify additional park and ride facilities at Aviation Station. B) 4.1 Land Use and Development The document has inadequate analysis of the City of El Segundo's Iocal land use plan policies and regulations. First, the Site "D" M and O facility is inconsistent with local zoning and the General Plan Land Use classification. Portions of the proposed site are located in the City's Commercial Center (C -4) Zone and Commercial Center Land Use classification. The purpose of this land use classification and zoning district is to provide for developing regional commercial establishments serving the City and surrounding area. A heavy industrial use such as this maintenance facility is not a permitted use in the Commercial Center (C -4) Zone. The DEIS/DEIR contains some analysis of Crenshaw Corridor project and City of Los Angeles zoning (Pages 4 -6, 4 -7), however there is no analysis of the project in relation to City of El Segundo zoning. There is a statement on Page 4 -447 that construction of the maintenance and operations facility would not alter zoning and land use compatibility. The City strongly disagrees with this statement as construction of this facility would conflict with the intent of the Commercial Center (C -4) Zone and would potentially create an incompatible land use in this commercial zone. Second, it is stated in numerous locations the DEIS/DEIR that 'the Site "D" maintenance facility is consistent with the El Segundo General Plan. This statement is inaccurate as the project directly conflicts with the following adopted General Plan goals, objectives and policies: • The Circulation Element (adopted June 2004) of the General Plan anticipates the extension of Park Place so that traffic could travel from Dash Street to Sepulveda Boulevard. Attached is the City of El Segundo adopted Master Plan of Streets which identifies this extension as a four lane divided collector road. It appears that constructing the facility at the Site "D" location would directly interfere with completing this General Plan identified roadway project. This could severely hamper improving future circulation within the southeast portion of the City since there are no east -west oriented through streets between El Segundo Boulevard and Rosecrans Avenue. Obstructing the Park Place roadway extension project would result in the conflicts with the 10 following Circulation Element Policies: Conflict with the policy to upgrade all master plan roadways (Policy C1 -1.2); Conflict with providing adequate roadway capacity on all Master Plan roadways (Policy C1 -1.3); Conflict with constructing missing roadway links to complete the roadway system designated in the Circulation Element (C1 -1.4) and Policy C1 -1.15, conflict with the pursuit and protection of adequate right -of -way to accommodate future circulation system improvements. • Any property taking to accumulate land for a Site "D" facility (particularly west of parcels 4138- 012 -004 and 4138- 012 -005) will significantly reduce the financing options for the street's construction. This conflicts with Circulation Element Goal Cl of providing a safe, convenient and cost effective circulation system. • Circulation Element Policy C1 -1.14 requires the City to fully evaluate potential traffic impacts associated with proposed new developments prior to project approval and require the implementation of appropriate mitigation measures. The lack of Site "D" traffic impact information in this DEIS conflicts with the City's ability to achieve this policy. • The DEIS has not addressed Circulation Element Policy C2 -3.10 which encourages Metro to provide bicycle storage facilities at its stations. • The Site "D" facility appears to conflict with a significant portion of the Phase 1I of the Plaza El Segundo lifestyle /commercial center. Plaza El Segundo is the primary retail commercial center and largest retail sales tax generator in the city. As the City of El Segundo is essentially built out, with the exception of the proposed site and Campus El Segundo (a mixed -use development immediately south of LAX), the taking of these properties could result in the significant loss of future sales taxes due to the disruption or cancellation of the Phase II development. This would conflict with Land Use Element Goal LU4, the provision of a stable tax base for El Segundo through commercial uses and Economic Element Policy ED 1 -2.1, seek to expand El Segundo's retail and commercial base; and Policy ED 1 -2.2 maintain and promote land uses that 'improve the City's tax base. Land Use Element Policy LU 4 -1.1 requires permanent maintained ,landscaping on all new commercial developments. Placement of this facility 'in a commercial zone with no buffering will conflict with the General Plan policy. • ,The facility conflicts with Land Use Element Goal LU5 which is to retain and attract clean and environmental safe industrial uses that provide a stable tax base and minimize any negative impact on the City. The maintenance facility use will negatively impact the City's tax base by pre - empting commercial development and subsequent sales tax and eliminate property tax from the site. C) 4.2 Displacement and Relocation of Existing Uses This section of the DEIS states affected [M O "the preliminary physical locations of each parcel an facility] can be found in the conceptual engineering 11 drawings in Appendix A." The section then goes on to state that Site "D" does not include any buildings therefore relocation assistance would not be required. This statement appears to be incorrect as when the conceptual engineering drawings are superimposed on aerial photos of the location, it is apparent that existing uses and buildings could be physically impacted by the project. D) 4.3 Community and Neighborhood Impacts Impacts on the sensitive land uses of the Bright Horizons Day Care (2270 El Segundo Blvd), Oceanside Christian Fellowship (343 Coral Circle)' and the Vista Mar School (737 Hawaii St) have not been evaluated. These facilities are within close proximity to the maintenance facility and could both be subject to direct and indirect impacts. E) 4.4 Visual Quality The analysis of visual quality consists of this statement (Page 4 -128): Development of a maintenance and operations facility at this location would not have a negative effect on the visual environment as it would fit within the context of the existing uses and would not obstruct views or vistas. The City disagrees with this statement as the industrial use does not fit within the context of existing and proposed retail, office and restaurant uses. The DEIS/DEIR should include buffering mitigations to screen the use from the existing commercial areas, as well as screening for areas slated for future commercial development. The proposal also includes Traction Power Substation (TPSS) units in public view along rights -of -way. No screening of these units is proposed, which does not conform to zoning requirements to screen equipment from public view (El Segundo Municipal Code § 15 -2 -8). F) 4.6 Noise and Vibration The operational impacts of noise on adjacent office, retail and other commercial uses should be included and studied in the noise analysis. Noise impacts on nearby research and development facilities and manufacturing facilities, such as Raytheon Company, should also be studied. The Raytheon facility contains national security defense system projects that are sensitive to noise and vibration. Noise producing activities such as LRV turning movement should 'be analyzed. The noise and vibration analysis should discuss compliance with all relevant sections of ESMC Chapter 7 -2 for both construction and operational conditions. G) 4.7 Ecosystems /Biological Resources It is not clear from the document if a qualified professional conducted the May 14, 2008 visual survey of Site "D" for biological resources. There is no information about the scope and methodology of the review. A one day visual 12 analysis is not sufficient to determine the existence, location and extent of any w 'ildlife habitat. Suggested Mitigation Measure EB 1 defers the analysis of the biological resources. This analysis should be included in the DEIS/DEIR, not deferred to a later date. Prior studies in the area have identified potentially significant biological resources such as the burrowing owl, other native birds and raptors, and the pacific pocket mouse and therefore biological surveys should be conducted and evaluated to determine if any of these species are present on the site. H) 4.8 Geotechnical /Subsurface /Seismic /Hazardous Materials The DEIS/DEIR discloses that the Phase I Environmental Site Assessment (ESA) conducted for the project did not include the maintenance facility sites (Page 4- 220). The City strongly believes that the DEIS/DEIR needs to include a proper evaluation of the potential for hazardous materials at Site "D." Portions of the site were previously used by heavy industry and are known to be contaminated as documented in the Plaza El Segundo EIR and in various Environmental Protection Agency (EPA) and Los Angeles Regional Water Quality Control Board (LARWQCB) documents and orders. A basic level of disclosure needs to occur in this DEIS/DEIR and cannot be deferred to a later date. Given the potential for a high level of contamination for materials such as arsenic, a Phase II should also be included in the DEIS/DEIR and not deferred to a later date as is proposed in mitigation measure GEO2. Some key environmental hazards that the DEIS /DEIR should identify, study and analyze are: an investigation of the former Kramer brass foundry site, disclosure of abandoned oil wells on and in close proximity to the site as there is the potential of up to four wells being located on the site (see attachment), full disclosure of the chemicals that will be used at the maintenance facility, and a discussion of the safety procedures and mitigations related to the potential storage of large quantities of CNG fuel at the site, and identification of the location of underground utilities and pipelines that may transect the site. As an example, the DEIS/DEIR should discuss in detail that one of the parcels included in the list of affected properties, includes the former Kramer brass foundry site which was subject to an order issued in 1988 by the EPA. The EPA supervised surface cleanup of the site. The EPA also directed a subsurface investigation which determined that the uppermost aquifer had been impacted by arsenic from this parcel. Subsequently, the LARWQCB became the lead agency for site investigation and mitigation activities. Clean up and abatement orders were issued by the LARWQCB relating to groundwater and soil contamination for the arsenic. Lead and volatile organic compounds (VOC's) were also constituents of concern by the LARWQCB. The site has been capped and is subject to restrictions regarding future excavation activities on the cap. Since the site has restrictions regarding future excavation activities on the cap, the DEIS/DEIR should discuss this significant impact and propose mitigation measures that would address the additional site clean up that would be necessary subject to review and 13 approval by the LARWQCB. Phase I and Phase II risk assessments and analysis should be conducted and evaluated, along with incorporation of appropriate mitigation measures to address any significant impacts for each parcel that is included in the LRT Alternative and /or the BRT Alternative M and O facility. I) 4.9 Water Resources There is no discussion of how water will be provided to the site as there may not be adequate existing infrastructure for the proposed facility. J) 4.10 Energy There is no discussion regarding the energy requirements for the proposed maintenance facility. The impact on infrastructure and the power needs of Site "D" should be evaluated in the DEIS/DEIR document. K) 4.11 Historic, Archaeological and Paleontological Resources The historic resource located on Site "D" is not identified in the document. This resource is the brass foundry foundation (Resource 19- 186856) located on the Kramer portion of the site. This resource should be disclosed and further evaluation should be conducted to determine whether this resource is eligible for listing on either the California or National Registers. L) 4.13 Economic and Fiscal Impacts The analysis of economic and fiscal impacts is inadequate. The analysis focuses on property tax loss and estimates this loss at $72,100 a year. To fully assess the economic and fiscal impacts of using Site "D" as a maintenance facility the DEIS/DEIR needs to address sales, business and utility user tax losses to the City of El Segundo due to the inability to construct the remainder of the Plaza El Segundo project. Also if the maintenance facility disrupts rail access to the Chevron refinery, the economic impacts on this major facility need to be analyzed and mitigated. i Table 4 -75 incorrectly identifies that the El Segundo Elementary and High Schools are taxing entities for the site. The school taxing entities are the Wiseburn School District and Centinela Valley Union High School District. M) 4.14 Safety and Security There is no discussion on how the maintenance facility will be secured. The DEIS/DEIR should include information on lighting, security features, and any perimeter fencing or walls. Also the DEIS/DEZR should address any homeland security issues related to this major public facility. The site is in close proximity 14 to the Los Angeles Air Force Base immediately adjacent to Raytheon and this should be taken into consideration in the security analysis of the site. N) 4.18 Environmental Justice State environmental law affirms that all Californians have the right to a clean and healthful environment and protection from the release of and exposure to environmental contaminants under all environmental laws, regulations, policies, programs, and activities. Residents of the City of El Segundo already contend with a number of uses which denigrate and negatively impact their environment through noise, air pollution, ocean pollution, traffic congestion and the presence of many environmentally hazardous chemicals and industrial processes. El Segundo residents are impacted by emissions from: an investor owned utility (NRG El Segundo Power Generation Station), a large oil refinery (Chevron El Segundo which accounts for roughly 1/a of the city's land area), as well as, the largest concentration of LA City's environmentally - damaging 24 hour -by -7 day a week operational infrastructure including Los Angeles International Airport (which runs the length of the entire northern El Segundo boundary), the City of Los Angeles Hyperion Waste Treatment Facility (portion of the western El Segundo boundary) and the Scattergood Power Generation Station (portion of western El Segundo boundary). Furthermore, the proposed site is a contaminated brownfield that is in need of extensive remediation. Because of these considerations and the presence of a number of other heavy industrial uses (printing plants, aerospace and defense factories), the City of El Segundo already shoulders an over - concentration of environmentally impacting installations and bears a disproportionate burden of the regions polluting and environmentally damaging uses. Consequently, the addition of a rail yard maintenance and operations facility (another heavy industrial use with identified unmitigatable air quality impacts) would further exacerbate the quality of life, unnecessarily and unfairly further burden the community and represent a violation of the basic tenets of environmental justice laws and regulations. IV. INADEQUATE PARTICIPATION AND NOTICING Page ES -2 states that letters of invitation were mailed to addresses within a quarter mile of the Crenshaw Transit Corridor Alignment. Were letters mailed to addresses within a quarter mile of the proposed transit maintenance facility in El Segundo? If the footprint of the conceptual drawings of the BRT and LRV maintenance facilities is used to delineate Site B then numerous properties near Douglas Street could be directly impacted by the project. Have all landowners with property directly affected by a project at Site "D" been informed of this project and included in the public participation process? Have property owners within a 1/ mile of Site "D" been notified of the project? These property owners include, without limitation, Union Pacific Railroad, BNSF Railroad, Chevron, and Raytheon. 15 Has Vistamar High School, a school within a quarter mile of the P! roject and the affected school districts, Centinela Valley Union High School' District, and Wiseburn School District been directly notified about the project? V. CEQA COMPLIANCE The DEIS/DEIR does not comply with numerous Government Code Sections of the California Quality Act (CEQA) and CEQA Guidelines that need to be addressed. These Sections are listed and discussed below. A. Government Code § 21081 No approval of project if there are significant effects that are not studied. The DEIS/DEIR is inadequate, inconsistent, and deficient in that several studies (Phase I and Phase II Risk Assessments, Cultural Resources, Biological Surveys, and Traffic) were not performed or not performed beyond visual surveys that do not meet the minimum requirements for analysis to determine if 'there are any significant effects. Therefore based upon the requirements of Government Code § 21081 that states that no public agency shall approve or carry out a project if there are significant effects that are not studied. The project may have significant effects in these issue areas of controversy since insufficient studies have been performed. Feasible mitigation measures for impacts cannot be determined until the impact study and analysis has been completed. Furthermore, CEQA does not permit deferral of analysis. The City of El Segundo contends that the MTA Board should not and cannot make a decision regarding a locally preferred alternative because of potentially significant impacts that have not been studied based upon the requirements of Government Code § 21081. Therefore, any decision should be deferred until the DEIS/DEIR has been revised to address the issues raised in this letter and a full analysis of additional potentially significant impacts have been provided in the DEIS/DEIR with appropriate mitigation measures and full disclosure to the public and the MTA Board. B. Government Code § 21081.5 Substantial evidence required for findings. Government Code § 21081.5 requires that the public agency shall base its findings on substantial evidence in the record. The inadequacy and incompleteness of the DEIS/DEIR (including but not limited to the discrepancies between the project description and analysis and the lack of sufficient technical studies) results in insufficient evidence in the record for the Los Angeles County Metropolitan Transit Authority to make findings regarding the environmental impacts of the Crenshaw Transit Corridor Project, especially as it relates to the impacts of a proposed Maintenance Facility at Site "D." Therefore, the City of El Segundo contends that the MTA Board should not and cannot make a decision even regarding a locally preferred alternative because of the inadequacy of the E1R and its associated technical studies, and the requirement to have substantial evidence required for findings based upon the requirements of Government Code 16 § 21081.5. The decision should be deferred until the DEIS/DEIR has been revised to address the issues raised in this letter correcting the inaccuracies in the DEIS/DEIR providing a sufficient level of technical study and analysis and a full analysis of additional potentially significant impacts with full disclosure to the public and the MTA Board. C. Government Code § 21081.6 Public agency shall adopt a monitoring program of mitigation measures and insure their enforceability. Government Code § 21081.6 requires that the public agency shall adopt a reporting or monitoring program for the changes made to the project or conditions of approval, adopted in order to mitigate or avoid significant effects on the environment. It further states that the reporting or monitoring program shall be designed to ensure compliance during project implementation and that for changes which have been required or incorporated into the project at the request of a responsible agency or a public agency having jurisdiction by law over natural resources affected by the project, that agency shall, if so requested by the lead agency or a responsible agency, prepare and submit a proposed reporting or monitoring program. Additionally, it requires that a public agency shall provide the measures to mitigate or avoid significant effects on the environment which are fully enforceable. Since the analysis in the DEIS/DEIR for the Crenshaw Transit Corridor Project is inaccurate, incomplete, inconsistent, and lacks complete technical studies, and therefore significant impacts have not been fully identified and cannot be analyzed for mitigation, the necessary mitigation and enforceability of those measures cannot be determined. Further, the City of El Segundo requests that all mitigation measures be provided in a reporting and monitoring program with clear demonstration of the enforceability of the mitigation measures. D. Government Code § 21092.1 Significant New Information Requires Re- notification. Government Code § 21092.1 states that "When significant new information is added to an environmental impact report after notice has been given pursuant to Section 21092 and consultation has occurred pursuant to Sections 21104 and 21153, but prior to certification, the public agency shall give notice again pursuant to Section 21092, and consult again pursuant to Sections 21104 and 21153 before certifying the environmental impact report." The issues raised in this letter, including, without limitation, the inconsistent, inaccurate and incomplete project description, many inaccuracies in the DEIS/DEIR, and the lack of complete technical studies, clearly demonstrate that the necessary revisions to the DEIS/DEIR will raise significant new information. Therefore, re- notification and recirculation of the DEIS/DEIR for meaningful and complete public c must occur. omment 17 E. Government Code § 21098 Notification Requirements in "Low -Level Flight Path," "Military Impact Zone," and "Special Use Airspace." Government Code § 21098 requires military service notification if the project is within a two mile radius of a military impact zone; the project is of statewide, regional, or area -wide significance. Since the Crenshaw Corridor Transit Project, including both the location of the light rail line and the maintenance facility, and possibly the bus line are within two miles of the Los Angeles Air Force Base, military service notification is required. The Los Angeles Air Force Base was not listed as a facility that was sent notice or was part of the community, outreach. F. Government Code § 21151.4 and 21151.8 Hazardous Materials Near Schools and CEQA Guidelines § 15186 School Facilities. Government Code § 21151.4 and 211151.8 states that an environmental impact report shall not be certified involving the construction or alteration of a facility within one - fourth of a mile of a school that might reasonably be ',anticipated to emit hazardous air emissions, or that would handle an extreme hazardous substance or a mixture containing extremely hazardous substances! in a quantity equal to or greater than the state threshold quantity specifies; pursuant to subdivision 0) of Section 25532 of the Health and Safety Code, that may pose a health or safety hazard to persons who would attend or would be employed at the school, unless both of the following occur: (1) The lead agency preparing the environmental impact report or negative declaration has consulted with the school district having jurisdiction regarding the potential impact of the project on the school. (2) The school district has been given written notification of the project not less than 30 days prior to the proposed certification of the environmental impact report or approval of the negative declaration. CEQA Guidelines § 15186 has similar provisions that require notification and consultation with a school within one -fourth mile of the facility to be constructed or altered. The DEIS/DEIR indicates that the facility is anticipated to emit hazardous air emissions and that the air quality impacts are not mitigatable. Further, two school districts (Wiseburn School District, Centinela Valley Union High School District) and one private high school, Vistamar School, have not been notified of the project, the DEIS/DEIR or the potential impact of the project on Vistamar School located on Hawaii Street. G. Government Code § 15088.5 Recirculation of an EIR Prior to Certification The DEIS/DEIR will require recirculation as significant new information will need to be added after public notice is given of the availability of the DEIS/DEIR IV for public review. The new information will include changes in the project description, environmental setting, and data relating to the proposed BRT and LRT maintenance facilities in the City of El Segundo (described as Site "D "). The revisions to the project and the analysis that will be needed to correct the lack of accuracy and the inconsistency of the project description, site identification and project analysis in the DEIS/DEIR, and the lack of a sufficient level of information and analysis would deprive the public and the City of El Segundo from a meaningful opportunity to comment. The draft DEIS/DEIR is so fundamentally and basically inadequate and conclusory in nature that meaningful public review and comment would be precluded pursuant to Government Code § 15088.5(a)(4). H. Government Code § 15124 Project Description. Government Code § 15124 requires that the description of the project shall contain the precise location and boundaries of the proposed project and that it is shown on a detailed map, preferably topographic. As discussed earlier in this letter, the project description does not contain, the precise location and boundaries and dimensions of the parcel for the maintenance facility. Additionally, the description that is provided varies substantially throughout the document with 5 different project descriptions, and 3 different locations and configurations. The project description must be corrected and made consistent throughout the document with the precise location and boundaries defined. I. Government Code § 15131 Economic and Social CEQA Effects. Government Code § 15131 states that "An EIR may trace a chain of cause and effect from a proposed decision on a project through anticipated economic or social changes resulting from the project to physical changes caused in turn by the economic or social changes" and that "Economic or social effects of a project may be used to determine the significance of physical changes caused by the project." The analysis of economic and fiscal impacts in the DEIS/DEIR is not adequate. As stated earlier in this letter, the DEIS/DEIR needs to address sales, business, and utility user tax losses, not just property tax loses to the City of El Segundo due to the inability to construct the remainder of the Plaza El Segundo project to fully assess the economic and fiscal impacts of using Site "D" as a maintenance facility. Additionally, discussion of possible future expansion of the site as stated in the Executive Summary needs to be analyzed. The expansion of the site could result in physical changes such as the inability to complete the construction of Park Place and connect the two existing roadway segments together which would permanently affect the circulation and traffic in the southeast portion of the City. Also, if the maintenance facility disrupts rail access to the Chevron refinery, the economic impacts on this major facility need to be analyzed and mitigated. If the rail access to Chevron were eliminated as a result of the proposed maintenance facility, this would be a significant physical change and significant impact. This means of access is the only means of transporting 19 Chevron's products by rail to the Ports of Los Angeles and Long Beach for shipping. No other rail access would be feasible because of existing development in the area. I Government Code § 15144 Forecasting. Government Code § 15144 states that while foreseeing the unforeseeable is not possible, an agency must use its best efforts to find out and disclose all that it reasonably can. When studies have not been conducted to determine if there are impacts, the requirement to find out and disclose information has not been met. K. Government Code § 15146 Degree of Specificity. The DEIS/DEIR lacks the degree of specificity required to describe and analyze the proposed maintenance facility in the City of El Segundo (described as Site "D" in the DEIS/DEIR) for any of the proposed LRT or BRT alternatives in the DEIS/DEIR. Government Code § 15146(a) states that "an EIR on a construction project will necessarily be more detailed in the specific effects of the project..." L. Government Code § 15147 Technical Detail. i Government Code § 15147 requires that the information contained in an EIR shall include summarized technical data, maps, plot plans, diagrams,] and similar relevant information sufficient to permit full assessment of significant environmental impacts by reviewing agencies and members of the ';public. The DEIS/DEIR does not provide complete, accurate, consistent maps, plot plans and diagrams of the location and boundaries of "Site D," the proposed'maintenance facility in the City of El Segundo. The project description and maps, plot plans and diagrams are inconsistent with each other. Furthermore, none 'of these plot plans, diagrams or maps provide property line boundaries and dimensions and distances from identifiable, measurable benchmarks of streets, other parcels or readily identifiable structures. M. Government Code § 15148 Citation. The DEIS/DEIR provides no citations of the El Segundo General Plan, Municipal Code and other relevant documents (Plaza El Segundo Development Agreement and Amendments) in Appendix D ( "References "). No specific Goals, Policies and Objectives are citied when references are made to the LRT and BRT alternatives as "consistent with the El Segundo General Plan" throughout the DEIS/DEIR. Examples include, but are not limited to: Pages ES -47, ES -73, 4- 41, 4 -47, 4 -51, 4 -54, etc. KC N. Government Code § 15151 Standards for Adequacy of an EIR. Government Code § 15151 requires that an EIR should be prepared with a sufficient degree of analysis to provide decision - makers with information which enables them to make a decision which intelligently takes account of environmental consequences. The draft EIR must be prepared with sufficient adequacy, accuracy, completeness, and with a good faith effort at full disclosure. The DEIS/DEIR as discussed throughout this letter does not meet the standards for adequacy of an EIR because of the lack of accuracy, completeness, and consistency of information and the insufficient good faith effort at full disclosure. Thus the decision - makers do not have adequate and accurate information in which to, make a decision that accounts for the environmental consequences of the proposed project. The DEIS/DEIR must be revised as addressed throughout this letter, before this environmental document is evaluated and presented to the Los Angeles County Metropolitan Transportation Authority and considered in a public hearing for this project. Additionally, the City of El Segundo contends that the MTA Board should not and cannot make a decision even regarding a locally preferred alternative because of the inadequacy of the EIR based upon the requirements of Government Code § 15151. Therefore, any decision should be deferred until the DEIS/DEIR has been revised to address the issues raised in this letter correcting the inaccuracies in the DEIS/DEIR and a full analysis of additional potentially significant impacts have been provided with appropriate mitigation measures and full disclosure to the public and the MTA Board. VI. LAX CONNECTIVITY ISSUES The City of El Segundo is supportive of increasing the functionality, connectivity, and access to a regional transportation system in the Los Angeles metropolitan area. The City has supported and passed a resolution supporting the Green Line Extension to provide direct access into Los Angeles International Airport (LAX) to benefit the residents and business people of El Segundo and throughout Los Angeles. The City of El Segundo believes that the extension of the Green Line into LAX is a superior option to extending the Green Line to the Aviation/Century Boulevard Station with a connection to a people mover into LAX. The design of the Crenshaw Corridor Transit Project should be designed to ensure that the Green Line extension can occur with direct access into LAX from El Segundo. The City of El Segundo respectfully requests that the issues identified and discussed in this letter are addressed in the EIS/EIR. Further, the City of El Segundo believes that the DEIS/DEIR will need to be re- circulated once these issues have been addressed and corrected to allow adequate opportunity to provide meaningful comment based upon a clear project description and thorough and complete analysis in compliance with the requirements of the California Environmental Quality Act and the National Environmental Policy Act. Please direct any questions you may have regarding the comments provided in this letter to Greg Carpenter, Director of Planning and Building 21 Safety at (310) 524 -2345 (gcarnenter @elsegundo ora) or Kimberly Christensen, AICP, Planning Manager at (310) 524 -2340 (kchris tens en @else undo org). Attachments: I. Oil and Gas Well Map 2. Site List of Oil and Gas Wells Cc: Los Angeles County Metropolitan Transportation Authority Board of Directors Renee Berlin, Executive Officer, Metro El Segundo City Council Greg Carpenter, Director, Planning and Building Safety Kimberly Christensen, AICP, Planning Manager , Mark Hensley, City Attorney Karl Berger, Assistant City Attorney Dana Greenwood, Public Works Director Masa Alkire, Principal Planner PAPlanning & Building Safety\Planning - Old\PLANNING FILES BY TOPICNETRO -MTA Environmental Comment Letters and Documents \Crenshaw Corridor\2009.10.22.DEIS -DEIR El Segundo Comment Letter.doc 22 O m b m m m m m m r n r r n n r n r r m m m m m m op rm m emo m m m m rn rn m m o 0 0 0 0 o a o 0 0 a� F_ w m m J O > >W> uj F O J J J 1- 9 U K U Z w J J J V 1 O J J W J ¢ m J O a J w U J m U Ow�0 W t=.7� ¢� O O°a �} a Jw W W N CO M— Q LL y Q 0%,<t w J 0 D! Q Q � 0_ J J az wv�- ammW F- °a as F. 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