Regional Connector Letter

8/3/2019 Regional Connector Letter

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[Regional Connector Transit Corridor Project 2.14.2012.doc/4394.073]

GILCHRIST &RUTTER

PROFESSIONAL CORPORATION

1299OCEAN AVENUE,SUITE 900

SANTA MONICA,CA 90401(310)393-4000

DLAPIPER LLP(US)

1999AVENUE OF THE STARS,SUITE 400

LOS ANGELES,CA90067-6023

(310)595-3000

CHRISTOPHER SUTTON LAW OFFICES

586LA LOMA ROAD

PASADENA,CA91105

(626)683-2500

HILL FARRER &BURRILL L.L.P.

ONE CALIFORNIA PLAZA,37TH FLOOR

300SOUTH GRAND AVENUE

LOS ANGELES,CA90071-3147

(213)620-0460

February 14, 2012

VIA E-MAIL AND U.S.MAIL

Ms. Dolores Roybal Saltarelli

Los Angeles County MetropolitanTransportation Authority

One Gateway Plaza, MS 99-22-2

Los Angeles, CA 90012Email: [email protected]

Mr. Raymond Sukys

Office of Planning and Program DevelopmentFederal Transit Administration, Region IX

201 Mission Street, Suite 1650

San Francisco, CA 94105Email: [email protected]

Mr. Ray TellisFederal Transit Administration, Region IX

888 South Figueroa Street, Suite 1850

Los Angeles, CA 90017Email: [email protected]

Re: State Clearinghouse No. 2009031043

Los Angeles County Metropolitan Transportation AuthorityRegional Connector Transit Corridor Project

Final Environmental Impact Statement/Environmental Impact Report

(January 20, 2012)

Dear Ms. Roybal Saltarelli, Mr. Sukys and Mr. Tellis:

This letter is submitted on behalf of Thomas Properties Group (TPG), which is the realproperty owner and property manager of the properties located at 515-555 South Flower Street,

referred to as the City National Plaza and Towers in the Final Environmental Impact

Statement/Environmental Impact Report (Final EIS/EIR), and 400 South Flower Street,referred to as the J-2 Garage (collectively, the TPG Properties); Hines, which owns the

property located at 444 South Flower Street (Citigroup Center); The California Club, whichowns the property located at 538 South Flower Street; and the Westin Bonaventure Hotel and

Suites, which owns the property located at 404 South Figueroa Street (all collectively, the


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Ms. Roybal Saltarelli

Mr. Raymond Sukys

Mr. Ray TellisFebruary 14, 2012

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Affected Property Owners and the Affected Properties). The Affected Properties are all

immediately adjacent to portions of the proposed Los Angeles County MetropolitanTransportation Authority (LACMTA) Regional Connector Transit Corridor Project (RegionalConnector or Project), and are located on South Flower Street between 4th and 6th Streets (the

Financial District). Together, the Affected Properties provide millions of square feet of office

with accessory retail uses, hundreds of hotel rooms and employ thousands of people in theFinancial District.

Certain of the Affected Property Owners have previously submitted comments on the

Draft Environmental Impact Statement/ Environmental Impact Report (" Draft EIS/EIR") and on

the Supplemental Environmental Assessment/Recirculated Supplemental Draft EIR. See, for

example, TPGs letter dated September 1, 2011 and Hines letter dated September 2, 2011,

included in the Final EIS/EIR as comment letter R-BU4 and R-BU6, respectively.

The Affected Property Owners continue to be disappointed that LACMTA has failed to

sufficiently consider the significant adverse environmental impacts of and feasible mitigations

for the construction of the Regional Connector in the Financial District. In particular, the use ofcut and cover construction in the Financial District, instead of the use of the tunnel boring

machine ("TBM") method, which is being used for virtually all other portions of the line, is

highly impactful and consequently violates the California Environmental Quality Act (Pub. Res.

Code 21000 et seq.; CEQA). The result of the proposed use of the cut and cover methodcan only be further delays and costs for the Project.

1. The Failure To Mitigate Significant Adverse Environmental Impacts In TheFinancial District Is Contrary To The City's Goals Of Economic Growth.

The City of Los Angeles (City) has expressed its high priority for development of theFinancial District and surrounding downtown areas in its long-term plans and in its support of

development projects located in those areas, including without limitation, the Wilshire Grand

Hotel project, LA Live, and the Grand Avenue project. Yet, the Project as currently designed

would create substantial unmitigated adverse impacts over a period of years on traffic, transit,vehicular and pedestrian access, local businesses, parking, and safety, all of which will serve to

limit leasing and rental opportunities and prices at a time when this area of downtown is just

starting to show signs of recovery. LACMTAs refusal to avoid or mitigate these significantimpacts in the Financial District, as it has done in other areas, by refining the Project to use the

TBM method of construction is squarely incompatible with all of the goals and policiespromoting downtown development.

While future plans for the development of other districts in the downtown area, e.g.,

Little Tokyo, should certainly be encouraged, at the same time it must be recognized that theFinancial District and its substantial infrastructure already exist and serve as a key economic

driver for the entire region. The continued revitalization of the Financial District is critical to

any plans for renewing the greater downtown Los Angeles area and is the catalyst for the other


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developments along the light rail line. Damaging the vitality of the downtown core will hinder,

not promote, economic renewal in the whole area. As such, it is puzzling that LACMTA shouldfocus its priorities elsewhere along the line.

2. CEQA Mandates Mitigation Of The Cut And Cover Construction Impacts InThe Financial District, As Is Done For Little Tokyo.

The Affected Property Owners, who are developers, owners, and/or property managers ofpredominantly sustainable, transit-oriented developments, do support mass transit, and the

Regional Connector, specifically, as an overall matter. However, the Affected Property Owners

have significant economic interests in ensuring that the construction impacts of the RegionalConnector on the tenants, employees, patrons, and visitors of their respective Affected Properties

are avoided or at least minimized to the greatest extent possible.

This is not just a matter of mistaken priorities on LACMTAs part. As shown by the

significant involvement of legal counsel, it should be recognized that CEQA mandates that the

significant environmental impacts created by the construction of the Project be avoided orreduced through revisions to the Project, adoption of all feasible mitigation measures, and

consideration of alternatives. The Final EIS/EIR fails to meet these tests.

The Final EIS/EIR acknowledges that the overall construction impacts of the Project have

been reduced, many to a less than significant level particularly in Little Tokyo and in theFinancial District on Flower Street between 3rd and 4th Streets by eliminating cut and cover

construction and replacing it with use of the TBM. As the Final EIS/EIR states, thatrefinement reduces the number of business acquisitions required, reduces the need for road and

sidewalk closures, property acquisitions, job displacement and overall neighborhood disruption.

In addition, mitigation measures have been refined and expanded in those areas.

By contrast, however, the significant impacts in the Financial District created by the cut

and cover construction employed along Flower Street between 4th

and 7th

Streets remainunresolved. In fact, the Final EIS/EIRs conclusions that other impacts along Flower Street

between 4th and 7th Streets are less than significant are legally suspect, as they are not based on

substantial evidenceeither the mitigation is improperly deferred or the proposed mitigation is sovague as to be meaningless. The Final EIS/EIRs excuse for failing to reduce or avoid these

impacts is that the refinement to the Project and the mitigation measures employed in Little

Tokyo and on Flower Street between 3rd and 4th Streets are not practicable or not feasible forthe Financial District, but, as with many of its other conclusions, the Final EIS/EIR fails to

support these bald conclusions with substantial evidence.

The failure to provide feasible mitigation for such impacts, and to evaluate alternatives to

avoid those impacts, renders the Final EIS/EIR fatally flawed under CEQA. CEQA accords lead

agencies discretion in environmental reviews, but CEQA compels government first to identifythe environmental effects of projects, and then to mitigate those adverse effects through the


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imposition of feasible mitigation measures or through the selection of feasible alternatives

(Sierra Club v. State Board of Forestry (1994) 7 Cal.4th 1215, 1233); see also, Mountain LionFoundation v. Fish & Game Commission (1997) 165 Cal.4th 105, 134 [CEQA contains asubstantive mandate not to approve a project with significant environmental effects if there are

feasible mitigation measures or alternatives that can substantially lessen or avoid those effects].)

Impacts on the Affected Properties created by the cut and cover construction method and

the need for a temporary construction easement include:

Adverse vehicular access and circulation impacts to the Affected Propertiesresulting from barriers or grade differentials created by work on Flower Street.

Adverse impacts to pedestrians, many of whom are employees and visitors to theAffected Properties, resulting from barriers or grade differentials created by the

work on Flower Street.

Adverse health and safety impacts to the retail, office and restaurant tenants,customers and visitors resulting from interruption to access to the Affected

Properties during the cut and cover construction during emergency conditions.

Adverse health and safety impacts to disabled retail, office and restaurant tenants,customers and visitors resulting from interruption to access to the AffectedProperties during the cut and cover construction during normal as well as

emergency conditions.

Adverse impacts to the retail, office and restaurant tenants resulting from anyinterruption to access to the Affected Properties during the cut and cover

construction.

Adverse impacts to downtown traffic flow due to the interference with the FlowerStreet stop for transit, shuttle and other modes of transportation between 4 th and

7th Streets, including the size or ease of access to those stops.

Adverse impacts to freeway on-ramps and off-ramps resulting from the gradedifferentials (essentially giant speed bumps) at the intersections of 5th Street and

Flower Street and 6th Street and Flower Street.

Construction noise and vibration impacts on tenants and business owners.General mitigation measures have been identified in the Final EIS/EIR; however,no mitigation measure has been specifically identified to address the substantial

change in ambient noise and vibration levels in the immediate vicinity of the

Affected Properties. Two of the Affected Property Owners, the Westin


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Bonaventure Hotel and Suites and The California Club, are particularly affected

by these impacts, as their businesses serve sensitive receptors.

The Final EIS/EIR does not dispute these significant adverse impacts. Indeed, it

acknowledges the need for mitigation of significant construction impacts in other areas of theProject, and notes that many of these impacts, previously affecting Little Tokyo and Flower

Street between 3rd and 4th Streets have been avoided or reduced by employing the TBM. No

plausible analysis is offered why this mitigation cannot be employed elsewhere, particularly inthe Financial District. For example, when employed generally, Mitigation Measures TR-12 and

13 do not reduce the Projects construction impacts on public transportation to a less than

significant level; however, when employed in Little Tokyo, they do. (See, e.g., Final EIS/EIR

page ES-49.) The only difference between the disruption in transit experienced by the Affected

Properties in the Financial District and that experienced in Little Tokyo is the fact that in LittleTokyo, the Project has been refined to include use of the TBM.

3. The Final EIS/EIR Lacks Substantial Evidence That The TBM Cannot BeUsed In The Financial District Between 4

thand 7

thStreets.

The Final EIS/EIR claims with scant analysis that the TBM cannot be used in the

Financial District to reduce construction impacts caused by the cut and cover constructiontechnique due to physical constraints and, therefore, the impacts created by the cut and cover

technique can be adequately mitigated. Neither claim has any merit.

The Final EIS/EIR contains no substantial evidence supporting its conclusion that use ofthe TBM is infeasible or impractical. It asserts that use of the TBM would be hindered south of

4th Street due to existing tie-backs that would have to be removed, rendering the technique not

practicable, and that use of this excavation technique would not be feasible for constructing aproposed pocket track and possible crossover. However, for example, there is no evidence that:

The number of such tie-backs that exist south of 4th Street, or how they arelocated in the path of the TBM;

Similar tie-backs are not present in the Little Tokyo area along 2nd Street or onFlower Street between 3rd and 4th Streets where the TBM will now be used;

Tunneling would in fact have to be halted to address the tie-backs; Why addressing the tie-backs would render the use of the TBM not practicable,

and what LACMTA means by the term not practicable;

Whether the TBM would crunch through a tie-back, like a propeller gettingcaught in a net, and whether this would cause health and safety concerns;


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Whether the tie-backs, even if only present in the Financial District and not inLittle Tokyo or on Flower Street between 3rd and 4th Streets, render the use of theTBM legally infeasible under CEQA, and, if so, why;

Why cut and cover is no longer needed between 3 rd and 4th Streets (see FinalEIS/EIR, page F4-83);

Why use of the TBM would be legally infeasible in the Financial District due tothe possibility that a pocket track, and to the even more remote possibility that a

crossover, may be built in this location;

Why a pocket track is necessary between 4th Street and 6th Street; Why use of the TBM would be precluded now, should a Flower/5 th/4th station be

built in the future (see Final EIS/EIR, page F4-82);

How the existence of tie-backs makes the use of the TBM method notpracticable when it has been successfully used in other highly urbanized areaswith existing tie-backs in the path of the TBM, such as in Seattle, Washington.

Without such evidence supporting its conclusions, the Final EIS/EIRs conclusions are fatallyflawed under CEQA, and cannot suffice to support its failure to adopt the same refinement to the

Project in the Financial District as has been adopted in Little Tokyo and on Flower Street

between 3rd

and 4th

Streets to reduce the same significant impacts that the Project will create inthe Financial District to the Affected Properties and Affected Property Owners.

4. The Final EIS/EIR Lacks Substantial Evidence That The Adverse ImpactsOf The Cut and Cover On The Affected Properties Will Be Mitigated To A Less Than

Significant Level And Defers Mitigation.

In addition to lacking substantial evidence supporting its conclusion that use of the TBM

is infeasible or impractical, the Final EIS/EIR fails to provide substantial evidence that theadverse impacts of the cut and cover construction will be mitigated to a less than significant

level, where that claim is made. Similarly, the Final EIS/EIR violates CEQA by deferring themitigation of the adverse impacts. (See, e.g., Communities for a Better Environment v. City of

Richmond (2010) 184 Cal.App.4th 70, 92 [When setting aside a citys promise to adopt agreenhouse gas reduction plan in the future to mitigate a projects significant impacts, the Courtof Appeal noted that[n]umerous cases illustrate that reliance on tentative plans for future

mitigation after completion of the CEQA process significantly undermines CEQAs goals of full

disclosure and informed decisionmaking]; San Joaquin Raptor Rescue Ctr. v. County of Merced(2007) 149 Cal.App.4th 645, 670 [If [t]he success or failure of mitigation efforts may largely

depend on management plans that have not yet been formulated, and have not been subject to

analysis and review within the EIR, the EIR is defective].) For example:


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The Final EIS/EIR does not sufficiently address how impacts to vehicular accessand pedestrians, in particular pedestrians with disabilities, will be mitigated.Instead, the response to Comment R-BU4-5 simply states that any deckingconfigurations would be designed to safely accommodate the undercarriage and

overhead clearances of vehicles using the driveways, garages, and loading docks.

Similarly, it states that decking configurations would require construction of

ADA-compliant ramps and accesses as well as modifications to vehicular accesspoints (See Final EIS/EIR, pages F4-70, F4-64, F4-83.) Both statements are

simply vague conclusory statements regarding mitigation that will be attempted in

the future, but that has not yet been designed. In other words, the Final EIS/EIRoffers only deferred mitigation in violation of CEQA. By contrast, CEQA

requires that the Final EIS/EIR provide specific mitigation measures to address

these impacts not only to ensure that the level of the impact will indeed bereduced to a less than significant level, but also to determine whether the

mitigation, itself, creates any other impacts that must in turn be addressed.

The EIS/EIR does not specify how access to businesses, restaurants and retailestablishments will be maintained during construction, but merely assures that it

will. Vague language about installing signs and directing pedestrians to nearby

crosswalks is not sufficient. Neither is a bald statement that [n]o restaurants orother businesses on the referenced property would be required to close as part of

construction activities (see, e.g., Final EIS/EIR, page F4-74), which patently

ignores indirect economic impacts on such businesses caused by discouraging

patrons.

The EIS/EIR does not specify how vehicular access to buildings and parkinggarages will be maintained during construction, but merely assures that it will.

Mitigation Measure TR-1 simply states that a traffic management and

construction mitigation plan will be devised. The Final EIS/EIR further ensuresthat [a]ny decking configurations would be designed to accommodate the

undercarriage and overhead clearances of vehicles using the driveways, garages

and loading docks. (Pages F4-71, F4-73; emphasis added.) Once again, theFinal EIS/EIR has deferred critical mitigation, and has done so even when the

standards and mitigation methods are readily available now.

In fact, the Final EIS/EIR fully acknowledges that [i]t may not be possible to

keep all vehicular entrances to garages open at all times during operating hours,

but [LACMTA] would ensure that access is provided via other vehicularentrances during those times so that the garages can continue to operate. (Final

EIS/EIR, page F4-74.) However, some of the Affected Properties (such as the

Citigroup Center, Westin Bonaventure Hotel and Suites, and The California ClubProperties) have limited garage entrances, and alternative vehicular access is


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simply not available. Under such circumstances, this approach under Mitigation

Measure TR-1 is not feasible, and cannot reduce the level of this impact.Therefore, an unacknowledged significant impact remains.

The EIS/EIR does not specify how it would ensure the safe evacuation ofbuildings during construction in the event of an actual fire or other emergency atone of the Affected Properties. Instead, Mitigation Measure SS-15 simply states

that LACMTA shall protect public use of work areas and keep them clear of

obstructions. However, this statement is not supported with specific strategiesfor how this outcome will be achieved: how will safe pathways be created; where

will people be able to congregate away from the emergency and from emergency

personnel; how disabled, injured or impeded individuals will be directed or

handled; whetherconstruction will be halted and equipment and vehicles moved,etc. Again, the Final EIS/EIR merely assures that [LACMTA] would not allow

construction activities to impede safe evacuation of the retail area or access for

emergency personnel at any time (page F4-75), without providing any specifics.

Concerns raised regarding ADA access and decking for the Affected Propertieshave not been addressed. No mitigation measure guarantees that ADA access anddecking for the Affected Properties will be installed at existing grade level or that

ADA-compliant ramps and accesses would be provided. By contrast, Mitigation

Measure SS-9 guarantees an ADA accessible connection for the 2nd/Hope Streetstation to Upper Grand Avenue. Yet, the Final EIS/EIR includes no such

mitigation measure for the Affected Properties, some of which suffer equallysevere grade differentials.

Without such evidence supporting its claims of mitigation, the Final EIS/EIRs conclusions are

fatally flawed under CEQA.

5. LACMTA Is Required To Compensate The Affected Property Owners ForDamages Due To Their Loss Of Business.

Under California eminent domain law, LACMTA is, of course, required to compensatethe Affected Property Owners for the damages they suffer due to their loss of business

opportunities resulting from the construction of the Project, including, where applicable, the

value of the final Temporary Construction Easements ("TCE") that may be taken (see, e.g.,Pierpont Inn, Inc. v. State (1969) 70 Cal.2d 282 [noise, dust and disturbing vibrations caused by

heavy equipment during construction of freeway interfered with use of adjacent hotel]), and to

pay severance damages for the impact of the taking on the remainder of the respective AffectedProperties (see, e.g., Metropolitan Water Dist. of So. California v. Campus Crusade for Christ,

Inc. (2007) 41 Cal.4th 954 [temporary severance damages resulting from the construction of a

public project are compensable if the construction interferes with the property owners actualintended use of the property]). The potential impacts on the tenants and visitors to the City


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National Plaza and Towers, Citigroup Center, Westin Bonaventure Hotel and Suites and the

California Club could be very substantial unless the impacts of the cut and cover construction aretruly mitigated. Use of the TCE for anything other than preserving vehicular and pedestrianaccess and for separating pedestrians on the sidewalks from the street work by K-rails and fences

along the specific areas of the property lines of the Affected Properties would potentially disrupt

the ability of tenants and visitors to use the stores, restaurants, offices, parking and parkinggarages in the Affected Properties in a normal fashion, as a result of impaired access, noise and

vibration from work that is contemplated immediately adjacent to those properties.

Any such disruption to the tenants will give rise to claims by those tenants that such

disruption has caused them to incur damages. Moreover, prospective new tenants will likely

consider several years of disruption and inconvenience to be a major impediment to entering into

leases at the Affected Properties. Downtown office space is currently extremely competitive andlessees have a wide range of choices. It is possible, even likely, that any disruptive work

adjacent to or on the Affected Properties will cause potential lessees to divert to other spaces inthe area or to leave the Downtown market instead of leasing at the Affected Properties.

The impairment of the Affected Property Owners existing leases and the loss of even

one or two new leases for any Affected Property Owner could reasonably cause tens of millions

of dollars in damages to that Affected Property Owner, all of which would be compensable as

severance damages by the taking of the TCEs, if such easements permit any obstruction orimpairment of access to the Affected Properties by tenants or visitors. Such severance damages

would add substantially to the cost of the Regional Connector Project, and unnecessarily so,

since use of the TBM method would obviate the need for TCEs altogether.

Of particular concern to the Westin Bonaventure Hotel and Suites and The California

Club are the significant disruption, noise and vibration impacts that the cut and cover method

will create, since those impacts will in turn create substantial adverse economic effects on theirbusinesses. The Westin Bonaventure Hotel and Suites, as its name implies, provides lodging to

sensitive receptors as its core business; The California Club also provides lodging as well as club

and restaurant facilities. The substantial business losses both Affected Property Owners will

suffer, and for which they will be entitled to be compensated, would be substantially reduced ifthe TBM method, rather than cut and cover method, were employed.

6. LACMTA Should Incorporate TBM Into The Final Blocks Of The Project,As Required By CEQA.

The fact that the Financial District, the area of the Project with the most impacts and

economic risk, is the only area of the main line of the Project not to be mitigated by the use of

the TBM is simply inexplicable from a policy and practical standpoint. The alleged excuses fornot utilizing TBM for the remaining three blocks in the Financial District are so devoid of factual

support that it appears LACMTA, perceiving itself to be short of funds and under purely political

pressures to invest its resources elsewhere, simply contrived some cobbled-together reasons why


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tunneling could not be used in the Financial District blatantly ignoring the economic exigencies

and the clear violations of CEQA involved.

Even if the cost of tunneling could be greater than cut and cover and on full analysis it

is not clear it would be CEQA does not allow LACMTA to cause the public and AffectedProperty Owners to bear the substantial consequences of its unwillingness to mitigate the

Project's impacts. (See, e.g., Citizens of Goleta Valley v. Bd. of Supervisors (1988) 197

Cal.App.3d 1167, 1181 ["The fact that an alternative may be more expensive or less profitable isnot sufficient to show that the alternative is financially infeasible. What is required is evidence

that the additional costs or lost profitability are sufficiently severe as to render it impractical to

proceed with the project."].) LACMTA still has the opportunity to avoid these substantial

impacts and the risk and delays of CEQA violations by incorporating TBM into the remaining

blocks of the Project. The Affected Property Owners are willing to work with LACMTA to findways to make TBM effective and affordable. What they are not willing to do and what CEQA

does not require them to do is to shoulder a huge economic burden of adverse project impactswhen there are feasible methods that can be incorporated in the Project to avoid these impacts.

We hope LACMTA, on further consideration, will reach the same conclusion. We look

forward to additional discussions toward this end.

[Signatures follow on next page]


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Sincerely,

GILCHRIST & RUTTERProfessional Corporation

Robert I. McMurry

Attorneys for Thomas Properties Group, Inc.

DLA PIPER LLP (US)

Ryan Leaderman

Attorneys for Hines

CHRISTOPHER SUTTON LAW OFFICES

Christopher SuttonAttorneys for The Westin Bonaventure Hotel

and Suites

HILL FARRER & BURRILL, L.L.P.

Kevin Brogan

Attorneys for The California Club


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cc:Los Angeles County Metropolitan Transit Authority Board of Directors

Antonio R. Villaraigosa, Mayor, City of Los Angeles

Michael D. Antonovich, Los Angeles County Supervisor, 5 th District

Diane DuBois, Vice Mayor, LakewoodJohn Fasana, City Council Member, Duarte

Jos Huizar, City Council Member, Los Angeles

Richard Katz, City of Los AngelesDon Knabe, Los Angeles County Supervisor, 4th District

Gloria Molina, Los Angeles County Supervisor, 1st District

Ara Najarian, Mayor, City of Glendale

Pam OConnor, City Council Member, Santa MonicaMark Ridley-Thomas, Los Angeles County Supervisor, 2nd District

Mel Wilson, City of Los Angeles

Zev Yaroslavsky, Los Angeles County Supervisor, 3rd

DistrictMichael Miles

Arthur T. Leahy, Chief Executive Officer, Metro

Martha Welborne, Executive Director, Countywide Planning, MetroJan C. Perry, City Council Member, Los Angeles

Regional Connector Letter

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