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July 18, 2006 Randi Cooper SCOPING COMMENTS: South Region High School #14, Western Ave., San Pedro Thank you for this opportunity to respond to the Notice of Preparation and Initial Study for the proposed South Region High School #14. The project area falls within the boundaries of the Northwest San Pedro Neighborhood Council which represents approximately 20,000 residents and numerous businesses and community organizations. Members of our Council participated in two public workshops and reviewed the Initial Study for the proposed project. At our Council’s community meeting on July 10, 2006, the Council adopted the comments contained herein. The Los Angeles Unified School District (LAUSD or “the District”) has identified up to 24 acres of the “Ponte Vista” property on Western Ave. as its recommended site for a 2,025 student “full service” public high school. These 24 acres are the focus of the LAUSD Initial Study and these comments. An immediate major difficulty with this project is that it would peel away 39% of the parcel of property purchased by Bisno Development, which plans a large development on the full site, and is currently engaged in its own EIR process. Our council has concerns about both the proposal by Bisno Development and that by LAUSD. Between them the plans envisioned will deeply impact the entire San Pedro community for generations to come. Neither project as currently proposed is popular in the community. At the very least, Bisno and LAUSD need to be engaged in serious conversations to understand the other’s plans and to coordinate with each other. Many suggestions made and questions that have been raised about the school project in both neighborhood council committee meetings and two forums held in the community have not been addressed by the District. We strongly recommend that the District approach the City Council office, the community, and Bisno Development, with a more open attitude. We have made the same suggestions to Councilwoman Hahn and Bisno Development. In public meetings held by the Northwest San Pedro Neighborhood Council Planning and Land Use Committee, and by the full board of the Council, as well as in two public meetings called by the District, numerous community concerns about the high school project have been identified. These concerns are included in the attachment following this letter. Addressing these scoping questions and areas of concern does not imply any endorsement of the project by the Northwest San Pedro Neighborhood Council. Should the scope or size of the proposed project change, all due consideration must be given to the same questions and concerns, as even a much smaller school project will most certainly impact the community. Thank you for this opportunity to submit our comments and concerns. Please feel free to contact me at 310-831-1975 if you have any questions.
ATTACHMENT Northwest San Pedro Neighborhood Council 1. Overall Project We are concerned about the need for such a large high school
in light of unpredictable student population patterns now beginning to
emerge throughout the district. LAUSD contends that the school is needed
specifically to relieve crowding at San Pedro and Narbonne High School,
which the district states are both at capacity now. The district acknowledges
that any new school will not open before 2012. If the school populations
continue to increase between 2006 and 2012, what will happen as the schools
exceed their capacity? We think that creative planning for a tiered transition
(opening the school initially to only freshmen and sophomores, for instance)
needs to be thought through with the participation of the parents and
students of the existing high schools. There is certainly precedent for
a stepped opening among schools, including the recent opening of the Port
of Los Angeles High School. Additionally, it is hard to understand the
need for a new high school when it appears that no new elementary or middle
schools are being planned for the area. 2. Transportation/Traffic The district acknowledges “potentially significant impact” in several areas of traffic concern, primarily overcrowding and congestion on the existing road system (page 86 of Study). We question the efficacy of constructing a large public school on an already overcrowded traffic artery, Western Ave., especially in light of the additional burden that will be placed on Western by any Bisno housing development. Additional traffic is by far the most significant concern of the community. The District needs to be in communication with Bisno Development and the various traffic entities (the County of Los Angeles, Rancho Palos Verdes and the City of Los Angeles Department of Transportation) to devise strong mitigation measures. It is critical that traffic studies be conducted on regular school days between 7:00 and 9:00 am and 2:00 and 4:30 pm and on Saturdays. Any traffic study reflecting the reality of the location must take into account other development and events in the area, including the Bisno development, Mary Star of the Sea High School, Rolling Hills Preparatory School, new housing for Marymount College, a new Target Store and JCC Homes development, (both on Gaffey St.), and typically large funeral processions entering Green Hills Memorial Park. In addition the regular daily impacts of Dodson Middle School, Crestwood Elementary, Taper Ave. Elementary, Christ Lutheran School, Park Western Elementary, Dapplegrey Elementary (RPV) and existing retail and commuting impacts must be taken into account. Conversely, the District predicts “less than significant impact” on the level of access for emergency vehicles (page 86 of Study). We believe that if congestion and overcrowding of roadways may be a significant impact, then access by emergency vehicles both to a new school and to the neighborhood adjacent to the school will be impacted. Emergency vehicle access along Western Ave. and throughout the neighborhood and community adjacent to the school study area merits particular consideration. 3. Parking The District indicates “inadequate parking capacity,” and “potentially serious impact” as a result (page 86 of Study). LAUSD projects a minimum of 180 staff positions, but has allotted only 188 parking spaces on campus. The lack of on-campus parking for student vehicles is a huge concern to the neighboring community, and is unacceptable. The situation is exacerbated by the fact that only a small percentage of the students served by this school live within walking distance of the campus. Apparently the District believes that by not providing parking it will make parking difficult and thus discourage students from driving to school. This thinking is wrong. The use of either residential streets or Western Avenue for student parking creates an ongoing source of conflict between with the homeowners and residents in the surrounding community. Adequate student parking must be provided. 4. Gang and Crime Issues LAUSD has yet to acknowledge, let alone indicate any plan to ameliorate, deep community concern about mixing student populations from two aggressively competitive schools, in light of the very real urban problem of the presence of rival gangs in the area. Representatives of the Los Angeles Police Department have shared the same concern with the community at several public meetings. Additionally, LAPD has pointed out to us that attention needs to be paid to the potential for an increase in property crime whenever a high school is added to an existing community. This must be considered as a potentially significant impact on public services. 5. Policing We are concerned that the placement of the high school on the border of a neighboring city (Rancho Palos Verdes) will create overlap difficulties and unacceptable police response time, as the Western Ave. city border separates police jurisdictions. A student would move from the jurisdiction of LAPD and LA School Police in Los Angeles, to the LA County Sheriff’s Dept. in Rancho Palos Verdes, by crossing Western Ave. This jurisdictional problem has historically had negative impacts on our communities. 6. Air Quality The District Study acknowledges “potentially significant impact” in terms of violating air quality standards, a potential considerable cumulative increase of a criteria pollutant, the possibility of a non-stationary source “hotspot”, and the exposure of “sensitive receptors” to substantial pollutant concentrations (Page 39--#4C (b,c,d, and e) of the Study). The Harbor Area is subject to intense diesel emissions (particulate matter), which is especially damaging to vulnerable populations, particularly a student population during physical activity. Additionally, the Western Ave. corridor is heavily used by automobiles, buses, and commercial vehicles, and the vehicle count, with its attendant pollution issues, will only mount in coming years. LAUSD needs to include in its environmental study the latest South Coast Air Quality Management District information about local air pollution levels, and make plans to ameliorate the additional impact created by the school, buses, and increased vehicular traffic. This is not a “neighborhood school” in the conventional sense, where most students either walk or travel a short distance to the school. 7. Geology and Soils The Study indicates “potentially significant impact” from the rupture of a known earthquake fault, strong seismic ground shaking and potential landslides (Page 50--#4F, (a-i, ii, iii) of the Study). The existence of a portion of the Palos Verdes quake fault under the Bisno property and the potential for erosion of the natural slopes existing on the property should require a full study of geological and soil movement throughout the property being considered. 8. Hazards and Hazardous materials The selection of a piece of property directly adjacent to an underground Defense Fuel Depot fosters great concern for the potential of a hazardous leak or explosion adjacent to the proposed school site. The District believes there is “less than significant impact” from the possible dangers of underground pipelines, storage tanks, propane tanks and general incompatibility of neighboring properties so near a school. (Page 55--#4G (j,n,o,q and r) of the Study. We believe that each of these items reflects great potential risks to students and staff in an emergency, and needs to be considered as having “potentially significant impact”. Given the concerns regarding the safety of the Amerigas butane tanks on N. Gaffey St., they should also be included in any safety study. 9. Emergency Evacuation The District says that there is “little significant impact” of the location of the school in terms of impairing or interfering with an an adopted emergency response plan or emergency evacuation plan (Page 55--#4G (g) of the Study). The Port of Los Angeles is a target for an accident or terrorist event and residents and students may need to evacuate quickly. However, San Pedro is at the end of a peninsula and there are few exit routes from the community in case of an emergency. Western Ave. is the only immediate northbound means of escape from San Pedro for residents, students and shoppers on this corridor during any potential emergency--be it an earthquake, explosion or terrorist threat. As witnessed during the response to the recent robbery on Western Ave, Western Ave. would grind to a halt immediately in such an eventuality, exposing students to additional danger. This further emphasizes the importance of traffic mitigation measures to be taken by the District. It is imperative that the Los Angeles Police Department and Los Angeles Fire Department be consulted directly about emergency planning. 10. Hydrology & Water Quality The hydrology should be evaluated in terms of the potential impact on the storm drains that carry runoff from the proposed school development to Gaffey St. This community has recently experienced the collapse of three storm drains where they cross Western Ave. Additionally, we regularly experience flooding during heavy rains at several points along N. Gaffey St. Any study of development impact must include the impact on N. Gaffey from the Navy Fuel site to the I-110 offramp/I-47 onramp and to Channel St. and N. Pacific Ave. 11. Location on Property LAUSD has identified the northernmost, “flattest” portion of the Bisno property as its preferred site. For some of the reasons outlined above, the District may well have to deal with an adjustment in the size and location of its preferred site, within the Bisno property. As difficult negotiations over the entire property will be inevitable, the District needs to address the viability of the entire property as a building site, both in terms of the scoping questions being discussed here, and the viability of the high school itself should the area need to be modified. 12. Joint Facility Usage Fair consideration and study of use of school athletic and performing facilities by the community (including the adjacent portion of the Eastview section of Rancho Palos Verdes) must be taken into account, and a program of joint use should be developed as part of the consideration of this high school project. Additionally the potential for joint use of facilities developed by Bisno Development, Rolling Hills Prep, and Mary Star should also be studies. 13. Pedestrian Safety The District Study indicates “potentially significant
impact” to pedestrians due to substantially increased vehicular
traffic, potentially unsafe routes for students walking from local neighborhoods,
and by the school’s location on a major arterial roadway (page 78
of Study). In light of huge increases in traffic on Western because of
general development in San Pedro and specific development at the Ponte
Vista site and the increased presence of student drivers, pedestrian safety,
particularly to and from the Eastview neighborhood, and to and from Dodson
Middle School, must be studied carefully and pursued with vigor. |
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