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All five of these assertions are conclusively challenged in this paper. Analysis of these assertions leads to the conclusion that the project proponents are trying to fit a square peg into a round hole. Substantial questions exist as to the engineering feasibility of the project as conditioned in the ROD. The environmental analysis has become the subject of a federal lawsuit, in which a preliminary injunction was issued in July 1998. Even if feasibility were not in question, the combined costs of the project far outweigh any potential benefit to the transportation system.

The following responses to the State’s stated purpose and need for the 710 project indicate serious problems with both its purpose and effect:

A. Provide a Critical Link in the Regional Transportation Highway System

What does the proposed freeway extension purport to do? The 4.5 mile 710 freeway project is defined in the ROD as a highway that will: 1) remove 100,000 cars from city streets, and 2) attract an additional 100,000 or more cars from elsewhere in the regional highway network, half of that coming from the Los Angeles downtown loop.

Are either or both of these results critical? Would these two results achieve the supposed improvements to the regional mobility system and is the proposed freeway extension the best means of achieving these two results? The answer is no.

The critical links concept exists on paper because they were drawn in 1953 and formally adopted in 1964 without any significant public review. Over the decades the rationale for the freeway has changed: at one time it was about regional integrity, at another time it was access to the ports, and now it has nothing to do with trucks as trucks would be prohibited. The critical links concept fails to incorporate the Blue Line into the analysis. On the one hand, the public transit line will remove automobile traffic, and, on the other hand, the 710 extension will discourage or reduce Blue Line ridership.

The travel demand models used to justify the 710 extension assume that the 100,000 vehicles removed from existing freeways and shifted to the 710 completion will be a permanent reduction, and that no new travel will be generated in response to the additional capacity and improved travel time on the freeways that have gained traffic relief. Nothing could be further from the truth, however. Extensive research done at the University of California Transportation Center concludes that, within five years of its opening, the new freeway link would induce enough new traffic to consume 90% of the new capacity added. In other words, of the 100,000 vehicles of capacity "created" by the shifting of traffic from other freeways to the 710, 90% or 90,000 vehicles of new traffic will be generated in response to the temporarily improved traffic conditions. The planning for the 710 completion does not take into account any of this induced traffic.

The low build alternative will improve the flow of traffic for the first 100,000 cars that exist today and that are anticipated by the year 2020 on local streets by installing improvements where these cars exist. The issue, therefore, becomes the second 100,000 cars proposed to be shifted from existing freeways to the proposed 710 freeway extension in order to improve traffic flow on those existing freeways.

Even if the map shows a potential new section of freeway between the 10 and the 210, this fact alone does not dictate that it be constructed. Many proposed freeway segments, such as the Beverly Hills extension of route 2, have now been abandoned. Even if it was once considered a "critical link," the State is not now obligated to construct it. The 710 freeway extension will most likely serve as a by-pass route for traffic from the Los Angeles metropolitan area and Orange County to alleviate other freeway facilities. Regardless of nomenclature, there are other alternatives to improving traffic flow that have not been implemented. The State itself has utilized other more contemporary approaches to situations where there is a "missing link."

Moving these cars that are now elsewhere in the transportation system to a new freeway should not be considered "critical" when to move them requires destroying longstanding, viable and livable neighborhoods. It would be more humane and fiscally sound public policy to upgrade the existing freeways and local roads. With the exception of the 100,000 cars of local traffic that will be handled by the low build alternative, the real problem is that there are too many cars on existing freeway facilities and that those facilities have not been expanded and improved. The system is not missing links; it is missing repair and upgrading. The system is critically missing a mass transit component. Yet this option of upgrading local surface streets and the existing freeways has not been studied at the same depth and consideration as the 710 freeway project. All feasible alternatives to serve these 200,000 cars without new freeway construction and community destruction have not been explored or implemented.

The failure to improve aspects of the existing system creates inconsistent public policy and contradictory results. The 110 freeway is an established freeway route that could be upgraded. It has not even been considered for capacity improvements in part because it is historic and should be preserved. To construct a new 710 connecting route that will destroy or permanently degrade many historic neighborhoods and hundreds of historic single family homes is inconsistent with this worthy approach.

There are numerous examples of the State deciding not to complete all once-contemplated freeways. There are several 1965-era freeways that were never built in the Los Angeles region that could have potentially alleviated traffic on other freeways:

• The Glendale (2) freeway, once known as the Beverly Hills freeway, was to continue beyond its present terminus westerly through Beverly Hills and Hollywood to the 405 freeway.

• The 2 freeway was also to extend northerly from the 134 freeway into the Angeles National Forest, following the route that is now the two-lane Angeles Crest (2) Highway.

• The Marina (90) freeway was to end up in Orange County to connect to the 91 freeway; however, today it is built just a few miles from Westchester to the 405 and a small 90 stump exists at the 91 in Orange County.

• The 164 would have followed Rosemead Boulevard from the 210 freeway to the 605 freeway.

• The 39 was planned from the 210 southerly to the Pacific Ocean in Orange County.

• The Antelope Valley (14) freeway was to extend across the San Fernando Valley down to the Pacific Coast Highway.

• The 170 was to be extended from the San Fernando Valley through Beverly Hills and Culver City to the 405.

There is also precedent for the State using non-freeway approaches within developed communities. The State recently agreed to relinquish control of a portion of the originally-designated 110 freeway corridor to the City of Pasadena (Senate Bill 1584 approved in August 2000). If completed as a freeway, this section could have connected the 110 freeway to the 210 freeway. Over the years commercial activity around this section has steadily grown, and the roadway has been functioning as a surface street major arterial. This section of 110 freeway was not deemed a "critical" link, however. Instead, the low-build approach will be used to rehabilitate this section and to coordinate with the City of Pasadena’s land use and circulation planning. The Blue Line light rail project through Pasadena will connect downtown Los Angeles to the 210 freeway. The initial projection for the Blue Line is 38,000 riders per day with growth to 70,000.

B. Divert Through Traffic From Local Arterials

The 100,000 trips on local surface streets to be diverted to a 710 freeway extension are incorrectly viewed by the California Department of Transportation (Caltrans) as "through traffic" when in fact they are local traffic. Highway planners assumed that a person getting off the 710 termini at either Valley Boulevard in Los Angeles or at the 210 in Pasadena is travelling the entire 4.5 miles "through" the corridor. The City of Pasadena conducted an origin and destination study that proved this assumption is wrong. Most motorists are not traveling the entire distance and do not wish to travel the entire 4.5 miles. A freeway would not be useful to such travelers.

For these local travelers who use the existing grid pattern of local streets, improvements to the local streets would be the greater benefit. These trips are more appropriately addressed by the low build alternative, the main objective of which is to efficiently accommodate these trips on the existing surface streets, and which can handle 100% of this objective. The 710 freeway is not needed to achieve this goal. The low build can fully address this part of the supposed need for the freeway extension, and can be completed and in operation within five years at much lower cost.

As an example, the grid system was altered in the Alhambra area when the depressed railroads eliminated north-south connections forcing many local trips to major arterials. The grid pattern could be re-established there by building bridges over the depressed railroad to major arterials to create the needed capacity for local trips. Intersections and signal systems of existing surface streets should also be upgraded. In Pasadena, the grid system has also been disrupted. The two main streets extending south from the existing 710 terminus (St. Johns and Pasadena Avenue) have been altered to one-way streets with the cross streets closed off with metal barriers. The low build would restore two-way traffic to these streets, filter local traffic through neighborhoods, and encourage through traffic towards the downtown commercial areas.

The goal of diverting local traffic from local arterials to a new freeway is no longer a desirable goal, nor consistent with Caltrans’ current policy. State highway policies shifted in the past decade to favor the use of the regional highway system for commuter, long distance and truck trips and to utilize surface streets for local trips. Accordingly, Caltrans has closed, reconfigured or planned for future closure of on and off ramps along many existing freeways to discourage local traffic from using the regional system.

C. Connect High Occupancy Vehicle (HOV) Lanes on Freeways

The proposed 710 freeway extension is stated to achieve the goal of gaining 4.5 miles of new HOV lanes to connect with HOV lanes on existing 10, 134, and 210 freeways. The purpose of HOV lanes is to discourage single occupancy vehicle (SOV) use. This purpose would be served best by not building a freeway extension at all. The Blue Line goes even further, by providing a positive travel option to avoid SOV use. In addition, this "connection of the HOV lanes" is not a valid goal because HOV lanes do not exist on all sections of the 10 and 210 or on any of the existing 710, much less on all the other existing freeways in the region. To construct a freeway for this reason, before the reason itself has been validated or understood, puts the cart before the horse, especially when other alternatives are available to address the other stated goals.

More importantly, even if connecting HOV lanes is a valid goal, the existing freeway systems should be improved and capacity increased before any new permanent freeway corridors such as the 710 extension are created. A more complete light-rail system or technologies such as the Maglev system should be considered.

D. Improve Air Quality

Air quality and traffic management go hand in hand. Better air quality is unquestionably an important goal. However, the air quality impacts of the 710 project have not been adequately studied and the long term impacts are not known. This study along with further study of the low build alternative is necessary before claims of improved air quality can be responsibly made. The United States Environmental Protection Agency (EPA), in a letter dated August 22, 2000, stated that:

"…any claims of air quality benefits of the 710 project are questionable because the proponents have not adequately considered long term impacts."

Federal regulations require that impacts stemming from emissions resulting from the actual construction and operation of the freeway should be studied and projected for a 20 year horizon, yet this study has not been conducted for the 710 project. The projected improvement to air quality is based on an assumed improved traffic flow on other freeways and local arterials discussed above. There is no data to support this assumption. As noted above, it is equally likely that shortly after opening the 710 freeway, it and surrounding freeways will be as congested as they are now.

If building freeways improved air quality, why wouldn’t we build more freeways? And, why does the AQMD oppose additional mixed-flow lanes? The assertion that freeways can improve air quality makes no sense.

E. Allow Planning Efforts for a 30-Year Old Project to Continue

The 710 freeway extension was conceived 40 years ago and received its first significant approval by Caltrans 36 years ago. The fact that it is decades old could be the single most important reason to completely re-evaluate the purpose and need of the project. Age in itself can never be a justification for its implementation, especially in light of all the changes during those decades. Responsible current planning should take advantage of and represent the lessons learned during those years, lessons in technology, traffic engineering, land use policy, plus changes in actual conditions of the economy, travel patterns, real estate development and land use. Current mainstream thinking in these areas seeks to integrate transportation planning with land use, economics, housing policy, historic preservation, social planning, and environmental protection. It is truly anachronistic to impose a 40-year old traffic solution onto 21^st century conditions.

At the same time, technological advancements in the past decade alone have made the low build alternative more viable than it once was. Intelligent Transportation Systems (ITS) and smart corridor concepts have vastly improved mobility in extremely congested conditions such as the Westside of Los Angeles.

It is important to recognize that times have changed, and there are many examples of good ideas that have given way to other better ideas as time passes. There are many people who remember when the 710 was proposed as a "truck route" from the Port of Long Beach. They may also remember that the 110 freeway was conceived to pass through Pasadena and through the hillside northerly to Palmdale. That plan was ultimately removed from the regional plan. The Alameda Corridor and Alameda Corridor East have overtaken that old idea.

One of the biggest changes since the 710 project was conceived is the change in the economy and accompanying changes in notions of economic development, and redevelopment practices. From the 1960s to the 1980s, both Pasadena and Alhambra relied on the 710 as a part of broad redevelopment plans that included big office complexes and auto malls. The ROD also identifies "urban revitalization" as a project benefit of the 710 extension.

This concept, while it may have been appropriate in those years, is no longer appropriate for two reasons. First, freeways can accomplish economic development in undeveloped areas by creating commercial value for freeway-adjacent and freeway-visible properties, which otherwise may have no intrinsic value at all. This is not true in this urban environment, which is already developed with residential and compatible low-scale commercial uses, which are already part of a flourishing economy.

The economy of this area and, therefore, the economic value of these properties, is not driven by freeway adjacency. To the contrary, with the exception of Alhambra, the destruction to the existing fabric and the presence of a huge freeway would create a barrier and disruption to the existing commercial activity and property values in the area. The State of California now looks at this type of redevelopment with great skepticism. In contrast to this is the positive and community-compatible economic development that accompanies the advent of the Blue Line.

Second, the whole notion of urban revitalization has shifted away from wholesale demolition and reconstruction to sensitive infill development that respects and is integrated with the existing urban context. The ROD’s notion of urban revitalization that depends on the existence of freeways has been discredited because it resulted in widespread disinvestment in the downtown core areas of cities. Now cities are using redevelopment funds to rebuild downtowns and become livable communities where residents can work, shop and play close to home. Preservation of historic buildings, re-use of existing structures, pedestrian-oriented neoclassical planning are common goals in cities today. Building the 710 freeway extension would be counter to this goal.

Both South Pasadena and Pasadena are blessed to have the characteristics other cities try to attain with the "livable communities" movement. Old Pasadena is a tribute to the reversal of ‘60s urban renewal policies. This year, Pasadena has torn down its "downtown urban renewal" mall built years ago and is replacing it with an outdoor pedestrian friendly development. In Pasadena during the 1960s the 710 freeway was seen as a key to redevelopment. Now it is hard to think that Old Town Pasadena was once slated for demolition to be replaced by office complexes and condominiums to be served by the 710 freeway.

Summary

In summary, a number of statements given by Caltrans as reasons for the 710 freeway extension do not stand up either in light of current conditions or in light of the lack of proof after years of effort:

Six cut and cover tunnels are planned for the 710 freeway project, equivalent to approximately 25% of the entire route. The remainder of the route will be open freeway. These tunnels are themselves to be covered with open space and previously displaced houses. While the idea of rebuilding part of the destroyed residential neighborhood is a well-intentioned mitigation, the concept is thought by Federal and State preservation officials to be unworkable for mature older houses and mature trees in well-established communities. It is not clear what are the probabilities for these houses in an earthquake, or for ground water related sinkage such as occurred with the newly constructed 105 freeway. Experiences related to the Northridge Earthquake and the Red Line subway construction give citizens very little comfort that these proposals can be effectively implemented as described by Caltrans.

There is no precedent for placing residences over freeways, an arrangement which is considered by many to be experimental, and there is debate as to whether these mitigations are feasible. When in 1996, the State Office of Historic Preservation raised this question, a 1996 report by the Federal Highway Administration stated that the concept had been successfully used, citing Freeway Park in Seattle, the I-10 in Phoenix, and Boston’s Central Artery project. The urban context for these three projects is non-residential areas within much larger metropolitan settings, and not the intimate residential neighborhoods found in Pasadena, South Pasadena, and El Sereno. Even if habitable houses and historic properties can be replaced on top of the covered tunnels, thequality of life and safety of their inhabitants will not be comparable to what exists now, and the community fabric will be destroyed forever. This level of destruction can never be mitigated on a human level.

There are market concerns as well as safety concerns. Would the neighborhoods created by these homes enjoy the same market conditions that these neighborhoods do currently? What would be the quality of life for the residents of those houses? There is not convincing information that single family houses on top of a freeway is either feasible or marketable.

The volume of dirt to be removed from the area has been estimated at approximately 5 million cubic yards, and a receptacle for the dirt not been formalized. There is no question that it will be an enormous volume of earth removed. The concern is that this will inevitably lead to destabilization of adjacent residential areas. In addition, the hauling of this dirt will need huge numbers of trucks carrying huge amounts of dirt for a long period of time, perhaps for years. This will cause daily constant disruption to the communities long before the project construction begins.

Eighty five percent of the proposed 4.5 mile freeway extension is planned to be depressed deep into the ground. The ground water impacts of the excavation and infill have not been fully addressed. Other recently constructed freeways have had a sinking problem due to groundwater conditions. The 105 freeway began sinking only a year or so after its completion for this reason. We do know that ground water and underground springs exist in the 710 project area within the boundaries of the proposed freeway. The studies have not shown that a similar I-105 problem will not occur once the freeway is constructed.

Proposed hillside cuts will be between 120 and 160 feet deep in several areas within South Pasadena and El Sereno. This depth, as well as the landscaped slope from the freeway to the houses, is extreme for an urban area containing fully built out residential streets where people live and children play. These deep cuts have not been fully studied. Caltrans conducted a study last year based on a limited boring investigation and records search, the results of which did not substantiate the safety and feasibility of these cuts. In response to requests from community members for pictures of locations where similar cuts have occurred on state highways, Caltrans planners brought in pictures from the toll roads that were built through mountainous terrain in Orange County and in the Los Angeles region that were not residential areas. This is completely different terrain. Here, irreparable damage to the hillsides could continue to destabilize homes outside of the freeway path years after the freeway is completed.

El Sereno, South Pasadena, and Pasadena

• Permanent loss of property tax revenue to each community from the houses removed for the freeway.

School Districts

• The estimated annual loss of revenues to the affected school districts in the area is $1.6 million.

Compare to Low Build Costs

• The low build alternative has been estimated to cost $135 million and will accommodate approximately 100,000 cars from the local existing streets.

B. Social Costs

Residential Disruption

The 710 project will remove approximately 1,000 homes and relocate 4,000 residents. The majority of the homes that will be removed are considered affordable housing and are owner occupied. Attached to this paper is a pie chart showing the break down of how many homes will be taken in each community.

This concern is not just about the removal of residential structures in favor of a freeway for cars. There is a housing shortage in the Los Angeles region. The people who are dislocated may be forced to outlying areas such as Antelope Valley, Santa Clarita area or the Inland Empire (Riverside and San Bernardino Counties) to find similarly affordable housing. This means moving more traffic to other congested freeways in the region. Equivalent affordable replacement housing simply does not exist within the Los Angeles region. This could mean that 4,000 people are induced to travel to work and other destinations (e.g., school, medical, and recreation) from much greater distances.

This dislocation will then create additional commuters in the freeway system. The model for the 710 neither addressed this phenomenon nor accounted for the shift of a certain percentage of trips to outlying areas.

Neighborhood Division

All three cities within the 710 corridor have long established neighborhood affiliations. Homes and neighborhoods have developed since the late 1800s without the consideration of being divided by a freeway. This would be destroyed. Approximately 1,000 homes would be removed, and only after years of dirt removal and construction would a new urban fabric evolve. By depressing the freeway in 25% of the project, building connector roads and cut and cover tunnels with either green landscaping or homes placed on top, the 710 freeway proposes to minimize disruption to neighborhoods. The fact is, however, that the existing neighborhoods will be destroyed. Whatever does survive or emerge will not have the same physical, historic, and social coherence that exists now, but will be separated by the barrier of the freeway.

Over 70 historic properties will be impacted from the 710 project. This includes historic districts that are eligible for listing in the National Register of Historic Places.

Trees removed

Over 6,000 mature trees will be permanently removed from the 710 project area.

Permanent noise impacts

The 710 freeway project will permanently elevate noise levels in the corridor area. This will affect thousands of additional homes on either side of the freeway corridor. There are many, many examples of this throughout Southern California.

Ongoing landlord conflicts

The ROD also requires the following studies, plans and actions:

• A supplemental Environmental Impact Statement focusing on issues developed in the design phase of the project is required. Any changed conditions, including changes in the project’s purpose and need, must be considered.
• An acceptable financial plan must be developed by the State to include the all proposed phases of the project including mitigation measures.
• An acceptable residential relocation plan must be completed.

Although the Southern California Association of Governments (SCAG) and Caltrans endorse the project, the ROD recognizes that the Metropolitan Transportation Authority (MTA) has not officially supported the project. In fact, the MTA does not include the 710 project in its current or proposed long range plan, and adopted a resolution March 22, 1995 stating that it would not support the 710 project until its environmental issues were resolved.

The results of this litigation raise serious doubts as to the future of the project approvals. In July of 1999, Federal Judge Dean D. Pregerson ordered a preliminary injunction against the 710 project preventing any construction or right of way acquisition and allowing only design activities for the 710 project. In his order, the court found that the plaintiffs were likely to prevail on all three sets of federal law claims, and that the equities tipped sharply against proceeding with the freeway. The court has not yet reviewed the claims brought separately against Caltrans and the CTC under California law, which are at least as strong as the federal claims. The court case is pending and is planned to continue throughout 2001.

B. Political Climate

The cities of Pasadena, South Pasadena, La Canada Flintridge and the El Sereno community of Los Angeles oppose the 710 extension. Alhambra and other cities in the San Gabriel Valley and Los Angeles area outside of the 710 corridor area support the project. There are many groups on both sides of the issue. Former Speaker of the Assembly Antonio Villaraigosa opposes the freeway. Two principal proponents in the California Assembly, Assembly members Mathew and Diane Martinez (father and daughter), are no longer in office.

Congressman James Rogan (27^th District) representing the freeway area has been successful in blocking federal funding for any activities related to the mainline 710 project. Congressman Rogan recently spearheaded the congressional appropriation of $46 million for low build type projects in the corridor to provide additional traffic congestion relief on the local streets, which would benefit approximately 100,000 cars in the vicinity. Additionally in 1999, $10.3 million was approved by the California Transportation Commission for projects listed in the ROD as "interim improvements" for local traffic congestion relief. This brings the total amount to $57.3 million that has already been appropriated for low build type projects for Pasadena, South Pasadena and El Sereno. These funds were initiated by the grassroots efforts of local citizens working with their elected representatives and are supported by the City Councils of South Pasadena and Pasadena, and the relevant Los Angeles City Councilmember Nick Pacheco.