At present, the Dodger Stadium Express is a popular mode of transportation on game days and would benefit from added investment. However, the report fails to fully and accurately analyze a future bus system that accounts for an electric bus fleet that would create a zero-emission system with potential for serving a larger range of users. The EIR has deemed the bus alternative the Environmentally Superior Alternative with less overall impact to the environment. 

2. Historic and cultural resources and view sheds will be impacted and irreparably harmed by the LA ART Project

It is the Conservancy’s position that historic and cultural resources and view sheds will be significantly impacted by the proposed project.  

If built, the LA ART will obscure the view, setting, and future overall experience of various historic places and spaces, including Union Station, El Pueblo, Los Angeles State Historic Park, and Chinatown. The Conservancy disagrees with the report’s findings and believes there would be significant impacts to numerous historic resources by altering their historic setting and overall feeling. With an imposing new Alameda Station that extends into National Register and Historic-Cultural Monument (HCM) boundaries, visitor’s experiences of Union Station would be dramatically changed.   

While walking Olvera Street, the LA ART’s cables and gondolas would be seen passing by and from within the Avila Adobe on Olvera Street, L.A.’s oldest historic building, the Alameda Station would tower overhead.  These visual impacts mixed with new signage, lighting, noise, and construction would prove detrimental to the overall vitality of the historic resource.  

3. Draft EIR does not adequately address the proposed use and transfer of public rights-of-way and lands, applicable general plans, permitted legal use, and is in conflict with Public Resources Code 5019.59

The Conservancy is concerned by the project’s use of publicly-owned parcels for private use as detailed in the report. Such land would be better suited for affordable housing with its proximity to City services and employment opportunities.  

4. Should the proposed project anticipate federal funding, Section 106 and Section 4(f) would be triggered and additional environmental review would be required

Given the project’s ridership, size, and station encroachment into Union Station and LA State historic Park, it is foreseable that additional government funds will be accessed despite claims to be 100% privately funded. Should that occur additional environmental reviews at the federal level will be triggered. It is common practice for the applicant/developer to submit federal environmental reviews in tandem with CEQA which is not how ARTT is proceding at this time. 

5. Transfer CEQA lead agency authority to the City of Los Angeles

Lastly, the Conservancy believes the City of Los Angeles is better suited to serve as the Project’s lead agency under CEQA as it would be responsible for granting the majority of the Project’s permits.