The VAPP Project – Steve4VNC

IMPORTANT DISCLAIMER: This page is hosted on my Venice Neighborhood Council campaign site. However, my role on the Hurricane Pumps issues is SOLELY as an impacted Marina Peninsula resident. There is no correlation or connection, intended, suggested, or otherwise, to my role as a board member of the VNC. The material below does not purport to represent the views of the VNC except where specifically noted.

This is the time to step up. It is likely the last chance to seek meaningful modifications. Changes are far more difficult when a project is in motion.

VNC Motion Approved – September 17, 2024

Our motion was passed by the full VNC Board on Sept 17th. Here is the presentation made to the board that evening

Kenya-Lee-VAPP-presenttion-September-17th Download

Here is the material sent out to city officials notifying them this motion passed.

VNC-VAPP-Motion Download

VAPP-Background Download

* The Core Issues *

The community has never questioned the essential nature of the project. However, we have raised many important issues some of which are referenced in the mitigation document. We gathered community input and sent it to Public Works in December 2023. Despite a prior commitment, they have not provided any feedback to date and seem to be stalling to get past the Coastal hearing. We strongly encourage you to read/download the annotated Environmental Impact Report (EIR) document as well as the 2021 EIR addendum. Selected notes on key topics follow the files below. Both are eye-opening. We’ve highlighted some (not all) of the areas where the original EIR document falls short. All items can be brought up to Coastal Staff and at the March hearing.

Note: Public Works certified its own EIR and Addendum. It’s like a company approving its own financial audit rather than being reviewed by an independent auditor. In what world does this make logical sense?

Conformance with the certified Venice LUP – Policy I.C.1 states that the scale and design of industrial facilities much be compatible with adjacent and neighboring uses. This design does not meet this criteria. Policy 1.C.6 states that hazardous industrial uses shall not be located adjacent to residential areas. While the community does not claim to be experts on the chemicals and operations to be used at the plant, the operation is industrial in nature and some operations of the plant could reasonably constitute a hazardous use for nearby residents due to the potential for activities such as (but not limited to) transformer explosions, equipment fumes, sewage overflows etc. Further, this will be an industrial facility located on a site identified as a Low Medium residential site in the Ballona Lagoon West subarea of the certified Venice Land Use Plan. There are also conflicts with Policy 1.A.5 that seeks to preserve and protect stable multifamily neighborhoods and Policy 1.D.1 that states the only permitted development adjacent to the Grand Canal and Ballona Lagoon shall be habitat restoration, single family homes and parks.
Vibration issues – Section MM-NOI-2 of the mitigation plans does not adequately protect property from potential damage. The plan as currently written is far more reactive than proactive using terms such as “may include,” “if considered appropriate,” and “as feasible and practical.” The discretion is left entirely to a project assigned engineer. Also, there is no timely mechanism for issues to be addressed/project to be halted in the event damage is done. The “process,” as we have bene told, will not mitigate additional damage before the cause is investigated and modified. The city has strong motivation look past issues that may arise as a path to completing the project faster, especially with the Olympics on the horizon. This may include financial incentives to the construction company through bonuses (to whom the city has already indicated will be granted almost total purview) as well as the Public Works beginning to receive management payments for an active utility. The community has extensive experience with the vibration issue during the previously completed Dual Force Main Project (considered Phase 1 of the overall project) for which underground drilling was not as extensive as is planned for VAPP. During the earlier construction, vibrations damaged the condominium building located directly across the Lagoon at 3950 Via Dolce causing material damage to water pipes. Their condo association has been seeking restitution from the city for these damages, ad nauseam, without success. If this project is to move forward, there should be materially greater protections in place for impacted properties (not just before and after photos), many of which were built in the 1960’s and 1970’s, including but not limited to adequate money placed in escrow by the city to cover construction damage. The community also seeks the city to pay for an independent 3rd party chosen by the community to review and recommend changes to these mitigation plans.
Noise issues – Section MM-NOI-3 of the mitigation plan is also inadequate. It strains credibility to believe noise control features will “reduce overall operational noise levels from all Project related sources to within 5 dB of existing ambient noise levels in the surrounding community (53-57 db).” During the Dual Force Main Project construction, noise levels were consistently, materially higher even with the use of acoustical panels and other methodologies outlined in the mitigation plans. The community again seeks the city to pay for an independent 3rd party chosen by the community to review and recommend changes to these mitigation plans.
CEQA Issues – There are also CEQA issues. Public Works paid for and certified both its own EIR and Addendum. There was no arms length analysis nor public outreach for the Addendum, yet the community was notified by the State Dept of Toxic Substance Control that remediation was needed at the project site. City Planning did not properly review the CEQA compliance nor include the mitigation measures as conditions required by law. Each MMRP should have been included in in public and recorded conditions so the community would know what is required and can monitor their implementation. The MMRP can only be found on an obscure Public Works weblink. Finally, the EIR does not specify what the neighborhood will be exposed to during and after construction. We have a right to know upfront, not to be surprised after the fact.
Visual Compatibility – This project is not visually compatible with the neighborhood. Although the size of the “electrical building” has been designed to comply with height requirements, the visual appearance of the site is overwhelmed by industrial-sized transformers directly on the street and directly across the street from a beautifully landscaped residential property.
Design Input – There was no meaningful community input into the project design or landscaping plans.
Construction Hours – The community has NEVER been in favor of Mon-Sat construction. It should be on weekdays only.
Off-site work spaces for home-based workers – The city says it will be managed by the construction company but there have not been any guarantees of location or suitability.
VPP/VAPP Maintenance – The current VPP is not maintained in any meaningful way. The issues go far beyond graffiti and painting. There are environmental and safety issues. Garbage is strewn along the Grand Canal side of the structure which can readily fall into this ESHA (photo attached). The sidewalk around the structure is in a constant state of disrepair to the point of being dangerous (photos attached). And as referenced in the Coastal Staff presentation made in February, the VPP was, back in 2012, landscaped to (at least partially) help blend it in to the neighborhood. Since then, it has been left in a state of disrepair. Finally, the only reason the VPP was painted and the two empty lots given a modicum of TLC was because the community demanded it through multiple requests. There was and is no maintenance plan. How will the VAPP be different? And what will become of the VPP as it is transitioned out of use? What will eventually become of that structure and lot? Nobody within Public Works has ever provided a clear response.
Parking Lot @ 128 Hurricane St – The city does not need additional employee parking for the VAPP/VPP plants. During a Zoom call early in the process, one employee admitted the lot would be used on weekdays for occasional supervisor visits so they “don’t have to look for street parking.” REALLY? This lot will not be patrolled or secured against the homeless and vandals. Of note, the city used its eminent domain power to acquire the 128 Hurricane lot for $2.7M. How else could that $$ have been spent in the community? There was some discussion about limiting public access to the parking lot but no commitments have been made in writing by Public Works. Also, there is no need for an “art component” to call more attention to the lot than would otherwise be necessary.
Grand Canal Restoration Plan (Phase 2) – During these meetings, Public Works expressed interest in a “regional plan” that would address multiple issues simultaneously. The community brought forward Phase Two of the Grand Canal Restoration Plan which had previously been designed and approved by all stakeholders including the city. Most importantly, it would restore the west side of the Grand Canal from Washington to Hurricane and address many environmental issues in the EIR plan. You can learn more about the plan here. Additionally, it would result in far more parking thereby mitigating the need to build an oversized public lot at 128 Hurricane. The plan estimated that there could be as many as 40-45 public parking spaces if angled parking were to be striped in the middle of Via Dolce near Washington in accordance with the public access provisions of the Coastal Act – a win for merchants on Washington Blvd. It would also include the construction of a walking bridge at Driftwood St. This means there would be another critical path for peninsula residents to quickly leave the area – see “Resiliency” below.

The Community Meets with Coastal Staff – Feb 12th

We’ve also been seeking a meeting with Coastal Staff before the hearings take place to meaningfully express our concerns about the project. This meeting was held as scheduled on Monday, Feb 12th. It went well. It lasted :90 minutes, longer than expected. Coastal Staff listened with interest. The deck used for that meeting will be posted below. Our Coastal contact, Chloe Siefert, has provided the following useful information which is posted below in italics.

Next Steps After Meeting With Staff and Before Full Hearing

The meeting with staff is the best but not the only opportunity to provide input. Below is a general timeline of the hearing and methods in which the community can participate. Please note these dates and procedures may be subject to change, so this is intended solely as a general, illustrative schedule.

TBD – The hearing agenda will likely be published with each item assigned a number and date. Staff don’t know when items will be heard until the agenda is published.

TBD – Staff will likely publish a single report recommending actions on the two appeals and single dual permit application.

TBD – The public can review the Staff’s recommendation and email the assigned planner with response letters. These letters can identify errors and express support or disapproval of the Staff’s recommendation (as well as anything else the sender wishes to share.).

7-10 Days Before The Coastal Hearing – Staff will publish all correspondence to the public agenda under one document. Any correspondence received after that deadline is added to the project record, but might not be feasibly published to the agenda. At this point, staff may also publish an addendum responding to public feedback and/or correcting any errors.

By 5pm the day before the hearing – the public can submit a Speaker Request Form online to testify at the hearing in person or via Zoom. Testimony protocol differs between appeals and permit applications – see the website link above.

The Coastal Commission Process – It’s Time To Get Involved

Genevieve and Mike fought elements of the VAPP plan starting in 2017. Our community has been collectively engaged since February 2022. The culmination of these efforts is now at hand. It’s never been a question of whether this is a critical infrastructure improvement. It is about (1) identifying fair and reasonable solutions that serve both the city AND the community and (2) mitigating the project’s impact on our lives, our property, and critically, the fragile environmental ecosystem that surrounds us.

Since LA Planning gave its approval in August 2023, we have been waiting to learn when the Coastal Commission will hear Gen & Mike’s appeal of the VAPP project (the building and the parking lot) AND the city’s application for final project approval. it now looks like the hearing will be during 4th quarter of 2024. Stay tuned for details.

The Appeal Hearing – December 11-13, 2024?? (Newport Beach Civic Center)

This is the final frontier. We, as a community, cannot provide testimony regarding Gen & Mike’s appeal (see below). However, we can all comment on the Public Works permit application. Everyone in the community is encouraged to participate. This is the last opportunity to influence the city to make material changes to the plan. Essentially, this is our “speak now or forever hold your peace” moment. As we know from the Dual Force Main project, complaints voiced during the construction process often fall on deaf ears.

Coastal Staff has emphasized that the community can meaningfully engage in the March hearing via remote testimony. The Commissioners have acknowledged in past hearings that community members often can’t travel to hearings and thus take remote testimony just as seriously as in-person. You will have the opportunity to participate in person (preferred) or via Zoom, record video testimony in advance, and/or call in from a cell phone.

Appeals Process: The Commission doesn’t take public testimony (including from the appellants) unless at least 3 Commissioners request it. The assigned planner will provide a brief presentation, the Commissioners may ask questions and then make a final determination. If the Commission does opt to take testimony on whether the appeal raises a substantial issue, testimony is generally limited to three minutes total per side. Only the applicants, appellants, persons who opposed the application before the local government (or their representatives), and the local government shall be qualified to testify during this phase of the hearing.

Permit Application: The Commission does take public testimony. This means the assigned planner will provide a brief presentation before the Commission accepts testimony from the appellants, applicants, and local government (not necessarily in that order.) The Chair has discretion over how much time each side has to speak and it may depend on how packed the hearing is that day. Appellants are typically given a single amount of time, like 10 minutes per group rather than 10 minutes per person. Next, the Commission hears testimony from all parties who have signed up to speak virtually and in person. Anyone may speak during public testimony.

Once this process is complete, the Commissioners will discuss and vote on the permit application that day. If approved by Coastal, the city will initiate the process to identify a construction company and move the project forward. Construction could start as early as the latter part of 2024. If the permit application is not approved, it will likely be based on specific issues to be resolved. The entire process could then be delayed for an indeterminate length of time.

Recap of Meetings With Public Works – July-Dec 2023

The community held four meetings with Public Works as directed by the LA Planning Commission (in 2022) which found Public Works had not adequately presented the design of the project or properly engaged with the community. The Commission continued the matter so that Public Works could meet with the neighbors, present more complete plans and images of the project, and show changes in the design that would accommodate neighbor concerns. However, Public Works’ response to every material issue raised by neighbors was some variation of “this is already designed and cannot be changed.” Among the topics discussed sans written commitments were:

Additional Useful Materials

The VPP – Aug 2012
(yes, at one point it was landscaped)

The VPP and Proposed Parking Lot Location (128 Hurricane) – May 2023

VAPP – View From Canal Court. This is visually compatible with the neighborhood?

VAPP – Mitigation Measures From Final EIR. When did it change to Mon-Sat?

VPP – Venice Pumping Plant: Built in 1957. Has been in continuous use to date. Serves as the operational nerve center for all pumping stations throughout Los Angeles. Was surrounded by oil derricks at the time of construction.
VAPP – Venice Auxiliary Pumping Plant: Proposed new construction across from the current plant. Now surrounded by single and multi-unit, landscaped residences.

Timeline

Jan 2015: Dual Force Main project public hearing. No reference to the VAPP project.
Nov 2016: VAPP Draft EIR (Environmental Impact Report) released. The presentation included parking solely for employees and no separate parking lot. Community feedback included, “There should not be ANY public parking at ANY time, only employee parking.” Mike Bonin’s office added, “We should design the space with landscaping so no other available spaces for public parking.”
2017: VAPP project references were included during a public meeting for the Dual Force Main project as “BTW here is the next phase of the project which we will present in greater detail at a later date.” That date never arrived.
2017: VAPP project presented to VNC. No public parking was included in the plan.
2017-2022: No additional information or contacts with the community were held despite prior promises to work on design and mitigation. Genevieve & Mike repeatedly asked for a new presentation of the project since changes were made since the public hearings in 2017. The city has consistently denied changing the project.
Dec 2021: Genevieve & Mike file an appeal with Public Works for both the VAPP and parking lot projects.
Mar 2022: The VNC votes unanimously to rescind support of the public parking lot aspect of the VAPP project “until and unless the city addresses the issues of concern to the residents in the area.”
Aug 2022: LA Planning approves both projects with the requirement that Public Works conduct meaningful dialogue with the community to address issues.
Aug 2022-June 2023: No outreach from Public Works
July 2023-Dec 2023: Four community meetings were held with Public Works. Despite realistic proposals from the community, the city has not made any material changes to the project and has not even confirmed minor changes in writing.

Significant & Unavoidable Mitigation Issues

Page 47: Construction PLNG-5. The number, degree, and type of secondary impacts to surrounding land uses that could result from implementation of the Proposed Project. Secondary construction-related noise and vibration impacts during the construction period which is expected to be 2 years would be significant and unavoidable, even with mitigation incorporated. Cumulative noise and vibration impacts during construction would also be significant and unavoidable. Therefore, the number, degree, and type of secondary impacts to surrounding land uses that could result from the implementation of the Proposed Project during construction would be significant and unavoidable, even with the application of mitigation measures MM NOI-1 and MM NOI-2. You are forcing the community to suffer without any means to avoid it. This is wrong. It is not a “take one for the team” exercise.” Nobody signed up for it. Further, you are admitting a level of suffering for the entire community that is unacceptable. What resources will be made available for people – relocation expenses? Compensation for lost property value/income? Cost of mental/physical issues? You are essentially telling us this will be a miserable existence for residents for the duration of the project.
Page 50: Construction Hours – The operation of construction equipment shall occur only between 8:00 am to 6:00 pm Mondays through Saturdays. Construction hours should be Mon-Fri 9a-5p only. This was contained in the final EIR plan. No Saturday or Sunday work. Why did it have to change?
Page 50: Construction NOI-1. Exceed any of the construction noise criteria provided by the L.A. CEQA Thresholds Guide Project construction noise would exceed any of the construction noise criteria provided by the L.A. CEQA Thresholds Guide Unacceptable for quality of life. Another reason not to allow construction on Saturdays.
Pages 53-66: Construction NOI-2 and NOI-3 Result in ground-borne vibration levels that are distinctly perceptible at a receiving residential use, or could potentially result in building damage. Project construction would result in ground-borne vibration levels that are distinctly perceptible at a receiving residential use, or could potentially result in building damage. Various pieces of heavy equipment such as graders and excavators would be used at the Project Site, as well as pile driving equipment. For the building construction phase, vibration levels were estimated that a total of up to 30 days of Project construction would include pile driving. What is the city’s liability for damage to residential properties? What is the process to address issues promptly?

Environmental Impact

The project is adjacent to sensitive wetlands – The Grand Canal and Ballona Lagoon. There is minimal effort planned, at best, to mitigate impacts or improve existing conditions.
The community has proposed revisiting Phase Two of the Grand Canal Restoration Project which was approved but never completed. It would, among many things, meaningfully address many environmental concerns.
Upgrades should be required to the aesthetics of the existing plant including painting, consideration of a mural, and additional planting in currently empty and trash-filled planters and side yards.
Page 11: Construction BIO-1. Results in the loss of special status species or habitat. To confirm the presence or absence of special-status plant species within the disturbance footprint, a special-status plant survey shall be completed before construction. If any sensitive non-listed plant species is found, then the individuals shall be identified and avoidance measures shall be utilized to the extent practical. 1) This should be monitored by an independent 3rd party, selected by a reputable organization such as the Ballona Institute. The city should not make this selection. 2) “To the extent practical” has no meaning and cannot be enforced.
Page 13: Monitoring During Vegetation Removal. (a) A qualified biologist shall monitor all vegetation removal and ground-disturbing activities, such as staging and grading, for the duration of the Project to ensure that practicable measures are being employed to avoid incidental disturbance of habitat outside the Project footprint and to survey for sensitive wildlife species. Construction personnel shall strictly limit their activities, vehicles, equipment, and construction materials to the Project footprint, including designated staging areas, and routes of travel. 1) Who determines a “qualified biologist?” Should not be LABOE or Public Works. 2) Management of construction personnel was not successfully enforced during the dual-force main project. What will be different this time? What is the enforcement mechanism to ensure compliance?
Page 14: Construction BIO-2: Results in the loss or reduction of a locally designated natural habitat or plant community. The Project would result in a total of 0.37 acre of short-term temporary direct impacts to vegetation communities (excluding developed areas). These impacts would occur during the construction phase only. Restoration should be addressed through the Grand Canal Restoration Plan, as proposed by the community.
Page 19: Construction BIO-1: A Habitat Restoration Plan (HRP) shall be prepared and submitted to EMG for review and approval, prior to submittal to the agencies. The plan will include a native plant palette, and establishment period, as well as success criteria and monitoring requirements. In addition, a monetary contribution may be provided to the Grand Canal Restoration Project fund for wider restoration of the canal banks. Not simply a contribution, this project should fund a material amount of the Grand Canal Restoration project. There should be a written commitment in this plan to integrate that project as this project proceeds.
Page 22: Construction BIO-3: Results in an interference with habitat such that normal species behaviors are disturbed to a degree that may diminish the changes for the long-term survival of a sensitive species. A Habitat Restoration Plan (HRP) shall be prepared and submitted to EMG for review and approval, prior to submittal to the agencies. The plan will include a native plant palette, and establishment period, as well as success criteria and monitoring requirements. In addition, a monetary contribution may be provided to the Grand Canal Restoration Project fund for the wider restoration of the canal banks. This reference recognizes the viability of the Grand Canal Restoration Plan. However, not simply a contribution, this project should fund a material amount of the Grand Canal Restoration project. There should be a written commitment in this plan to integrate that project as this project proceeds. Where is the community involvement? We do not trust the city to do the right thing here.
Page 23: Construction BIO-4. Result in the alteration of an existing wetland habitat The Project occurs within the jurisdiction of several agencies including, but not limited to, USACE, RWQCB, and CCC, and would result in temporary direct and indirect impacts to aquatic resources, including an existing wetland habitat. These impacts are significant without mitigation. Applicable permits from resource agencies would be obtained during the permitting phase before construction and all permit conditions and avoidance and minimization measures will be implemented. These impacts are significant WITH mitigation. This entire environmental plan was approved by the city without appropriate input from recognized community organizations.
Page 43: Construction HAZ-1. Create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous chemicals into the environment. The parcel located at 128 Hurricane Street lies within the administrative boundaries of the Playa Del Rey Oil field. One oil well McDonald 2 was observed on the Project Site and is located within a methane zone. The well was originally plugged and abandoned in 1932. As such, the project would have the potential to result in impacts associated with releases of methane or oil from the abandoned oil well during excavation activities. Methane gas release? Are you kidding? This seems far more significant than “less than significant” even with mitigation incorporated. Long-term operations of the Proposed Project could encounter potential impacts related to the encroachment/seepage of methane into the VAPP structure so impacts are considered potentially significant. If the analytical results of the subsurface investigation under Mitigation Measure HAZ-1a determine that methane encroachment has the potential to affect VAPP operational activities, the environmental consultant shall provide recommendations during the construction of the Proposed Project to mitigate long-term potential impacts. This is scary and VERY concerning. We seek a firm, contractual commitment to action with accountability, not simply an investigation and recommendations.

Project Design

The project is poorly designed to fit within its residentially zoned neighborhood. There is no buffer between the new facilities and the directly adjacent residential buildings. The plan also does not include 10 feet of landscaping between both the parking lot and the new facility and the nearest adjoining residential property to the north and west.
Permanent noisy and dangerous equipment are located very close to multiple neighboring residential areas.
The project’s aesthetic design, proposed landscaping, and “public art” have never been presented to the community.
There are no plans to address ongoing issues with the existing VPP either during or after the construction of the VAPP.
Page 6: Operational AES-4. The degree of contrast between proposed features and existing features that represent the area’s valued aesthetic image. The design of the project is NOT aesthetically consistent with that of the neighborhood Who decided this? Not the community
Page 67-71: Operational NOI-3 and NOI-4. Exceed the operational noise criteria provided by the L.A. CEQA Thresholds Guide. Once completed, VAPP would contain a number of equipment items and systems that would generate noise during operation. The primary noise sources would include the following: Three submersible pumps, with associated electrical motors and variable frequency drives. Noise levels at the new VAPP are expected to be similar to the existing VPP. HVAC noise is anticipated to increase ambient noise levels at Receptor 2 by more than 5 dB CNEL, which would be a potentially significant impact. Adjusting the location of equipment items within the Project Site to increase the distance from the closest sensitive receptors and/or increase acoustical shielding provided by intervening structures, where practicable and feasible. This was proposed by the community and rejected by the city. Yet it is in the mitigation plans? Who oversees this? What is the level of community impact? The estimated CNEL that would occur if the generator were to run continuously for 24 hours in comparison to existing ambient noise levels is that generator noise levels would increase the overall CNEL by between 0 and 11 dB. This is an unacceptable impact. Put this near your house and see how much you like it.

Emergency Preparedness/Resiliency

The 2,000+ residents of the Marina Peninsula are rightfully concerned about the local impact of natural and man-made disasters. In an evacuation event, the only exit access is up to Washington Blvd or around the Marina to Admiralty Way. One aspect of the aforementioned Grand Canal Restoration Project would be to construct a walking bridge at Driftwood St. This would create another critical path for the residents to quickly leave the area.
Page 74: Construction TRANS-3. Result in inadequate emergency access. During the construction of the Proposed Project, procedures would be taken to ensure that all construction equipment, machinery, and construction personnel vehicles are kept off of Hurricane Street, between Canal Court and the Esplanade. However, there is the potential for access to be temporarily blocked during loading and unloading activities or transport. To reduce the potential construction impacts associated with the proposed Project, the implementation of MM-TRANS-2 would require all construction activities to be conducted by an approved construction traffic control plan and requires advance notice to emergency service providers. Construction workers would park at an off-site location and be shuttled to and from the Project Site each workday on 10- to 15-passenger shuttles or vans. How will this be enforced? What is the penalty for workers parking on/near the site? They should be towed that day. During the Dual Force Main project, there was no visible enforcement. Also, no construction-related parking across the Gand Canal on Via Dolce or Via Marina.

Community Impact During and After Construction

The recent Dual Force Main project resulted in multiple years of noisy and intrusive construction. Neighbors endured constant construction traffic, noise, dust, and equipment issues. Mitigation was minimal and mostly after the fact.
The current community impact mitigation plans are insufficient to address community issues. Further, Public Works is relying on the outside construction firm to be responsible for implementing plans and addressing issues as they arise. There are no binding conditions of approval that spell out all construction obligations so that neighbors can monitor and enforce them, including requirements for all project approvals. There are no clear penalties on this contractor to respond to such issues.
The existing VPP is not well maintained. It has no landscaping or attractive fencing. It is never upgraded, or cleaned and graffiti is often left for months before painting. There is no written, ongoing obligation to clean and maintain the existing and new facilities when they are complete.
Public Works has a history of poor maintenance at the existing facility and landscaping. Public Works has not demonstrated any reasons for the community to trust it will fulfill its obligations to keep this facility and the parking lot safe and attractive. What will change with this new project?
Page 4: Construction AES-6 – Dust from excavation and construction equipment would also be generated. To minimize any aesthetic impact construction dust may have on nearby neighboring cars and resident windows, the Public Affairs Office of the Department of Public Works shall provide vouchers to immediately adjacent residents for window washing and car washes, as appropriate. This is a wholly insufficient solution. Neighbors have invested hundreds and thousands of dollars in landscaping. How will ongoing dust be mitigated for all properties impacted by the construction? Paying to clean our properties after the fact is not acceptable Dirt and dust should be removed at the end of each day.
Page 5: MM AES-2: Nighttime Construction Activities. Should emergency construction activities occur at night, LABOE or its construction contractor shall ensure that lighting will be directed away from surrounding sensitive land uses, particularly residences, and toward the specific location intended for illumination. What is the enforcement mechanism to ensure mitigation measures are conducted as required?
Page 36: Construction GEO-1. Expose people or structures to potential substantial adverse effects, including the risk of loss, injury, or death involving strong seismic ground shaking and/or seismically related ground failure, including liquefaction. During construction, the Project Site could be subject to significant seismic ground shaking from regional faults; however, the VAPP would be designed in conformance with the City of Los Angeles Building Code, which would reduce potential ground-shaking hazards. Due to the presence of uncertified fill soils, seismically related ground failure, including liquefaction, could occur on the Project Site. The Project Site is located within a seismically active region that is capable of generating earthquakes (including ground shaking) of considerable magnitude that would be capable of causing damage to buildings and infrastructure located on site. The Project Site could also experience liquefaction, including up to 2 inches for structures and up to 1 inch associated with the pipe header. These impacts are considered potentially significant. 1) Does the city own responsibility for damage to nearby residential structures based on the extensive drilling and pile driving that will take place during construction? 2) Project site location is EXTREMELY concerning. Would you live here with these risks?

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