The City of Montclair Formal Response to the Metro Gold Line Foothill Extension Construction Authority to a Supplemental Environmental Impact Report

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The City of Montclair submitted to the Metro Gold Line Foothill Extension Construction Authority a Formal Response to a Supplemental Environmental Impact Report (SEIR) that is studying a proposal by the Construction Authority to consider splitting the Gold Line Phase 2B Extension Project from Glendora to Montclair into multiple construction phases, with a future Gold Line station in either La Verne or Pomona North to be designated as the “temporary” terminus. Pursuant to provisions of Assembly Bill 1600 (Torres), the Montclair Transcenter is the designated terminus for the eastern section of the Gold Line light rail system.

Under the Construction Authority proposal, each construction phase would be completed as a separate project, and each project would not move forward until funding is available. Splitting the Phase 2B Project into multiple construction phases would result in a revised extension of Gold Line light rail service to the Montclair Transcenter from the current 2026 operational date, to no sooner than 2028. However, the Construction Authority would need to develop the necessary funding to extend Gold Line light rail service beyond the future La Verne Gold Line Station or future Pomona North Gold Line Station.

In November 2018, the Construction Authority Board of Directors determined that splitting the Phase 2B Project into multiple construction phases was necessitated by the fact that the lowest responsible bid for the Phase 2B Project came in at least $570 million above the $630± million for the entire Phase 2B Project extension from Glendora to Montclair— monies made available to the Construction Authority by the Los Angeles County Metropolitan Transportation Authority (Metro), the California State Transportation Agency (CalSTA) through a Transit and Intercity Rail Capital Program (TIRCP) grant, and the San Bernardino County Transportation Authority (SBCTA)—the latter for the Montclair Segment of the extension project from the Los Angeles County-San Bernardino County line between the cities of Claremont and Montclair, for construction to the Montclair Transcenter along the Metrolink alignment.

In deciding to split the Phase 2B Project into multiple construction phases, and asking the two lowest responsible bidders to re-bid on each of the split projects, with a deadline for submission in June 2019, the Construction Authority is of the opinion that it will be able to more accurately determine the cost of construction of each project phase, and determine its course of action as it relates to funding future construction phases.

The City’s submission to the Construction Authority is intended to serve as a multi-level response to the following two issues:

1. The SEIR and the proposed splitting of the Phase 2B Project into multiple procurement phases, with future Gold Line stations in either La Verne or Pomona serving as a “temporary” terminus until Gold Line light rail service is extended to the Montclair Transcenter in a future procurement phase.

In its Formal Response to this first issue, the City of Montclair respectfully opposed splitting the Phase 2B Extension Project from Glendora to Montclair and, instead, requested the Construction Authority use available Metro funds, CalSTA TIRCP grant funds, and SBCTA funds as a local match to pursue Federal Transit Administration (FTA) Fast Start grants, or other grants, to complete the Phase 2B Project as a single project from Glendora to Montclair.

If the Construction Authority moves forward with multiple construction phases, the City of Montclair respectfully requested the Construction Authority immediately proceed to use available Metro, CalSTA TIRCP, and SBCTA funds reserved for the La Verne to Montclair or Pomona to Montclair construction phase as a local match to pursue FTA Fast Start grants or other grants, to complete the Phase 2B Gold Line Extension Project to the Montclair Transcenter.

The City of Montclair points to Assembly Bill 1600 (Torres)—a 2012 state law that
(1) adds the City of Montclair as an “extension city” and naming the Montclair Transcenter as the Gold Line system’s eastern terminus. AB 1600 also directs the Construction Authority to pursue both state and federal funds to complete construction of Gold Line light rail service to the Montclair Transcenter.

In addition, Montclair maintains that (1) pursuant to San Bernardino County’s Measure I Expenditure Plan, SBCTA is required to participate in the funding for construction of Gold Line light rail service to the Montclair Transcenter; and (2) pursuant to “secondary criteria” provisions contained in the CalSTA TIRCP grant application, the Construction Authority has an obligation to extend the Gold Line to a “disadvantaged community”, as defined by the California Environmental Protection Agency (CalEPA)—both the cities of Pomona and Montclair qualify under CalEPA standards—and must produce greenhouse gas (GHG) emission reductions at sustained levels sufficient to allow for the proposed project to be impactful to the environment.

Further, the City of Montclair notes that in splitting the Phase 2B Extension Project into multiple construction phases and asking the two lowest responsible bidders to rebid each phase, the Construction Authority opens itself to cost increases above- and-beyond what was presented in the original bid packages opened by the Construction Authority in September 2018. Since the bid responses were first assembled in mid-2018, the nation’s economic profile has become decidedly less encouraging—increasing the likelihood that a proposed re-bid process would result in higher cost estimates for each construction phase of a multi-phased Gold Line Extension Project from Glendora to Montclair. The City of Montclair also notes that in light of recent discussions at the national level regarding the proposed construction of a “steel-slat” border wall along the U.S.-Mexico border, the cost of steel, a primary light-rail-system construction material, is likely to increase significantly based on both speculation and supply and demand if Congress agrees to some level of border wall funding. If bid costs for a multi-phased Gold Line Extension Project do come in substantially higher, the Construction Authority will be faced with a dilemma on how to proceed without funds sufficient to build the Extension Project to Pomona North, and perhaps not even to La Verne.

In November 2018, the City of Montclair advocated that the original bid responses be rejected, and the Construction Authority revise its project estimates and seek Federal grants to close the funding gap; however, the Construction Authority elected to proceed with conducting an SEIR to determine the site of a “temporary” terminus, either in La Verne or Pomona.

2. A letter submitted by SBCTA to the Construction Authority, dated on or about December 21, 2018, and entered into the public record regarding the Phase 2B Extension Project and its shared integration into the existing Metrolink San Bernardino Line Alignment.

In its letter to the Construction Authority, SBCTA postulates that Metrolink ridership on the San Bernardino Line would suffer if it is required to share its alignment with Gold Line light rail service from Pomona to Montclair. As evidence, SBCTA points to a 25 percent ridership decline at the Covina Metrolink station following the opening of the two Azusa Gold Line stations (Azusa Downtown Station and Azusa APC/Citrus Station) in March 2016. The obvious purpose of the SBCTA letter is to convince the Construction Authority to terminate Gold Line light rail service at a future Gold Line La Verne Station, or a future Gold Line Pomona North Station if the Construction Authority determines it has funding to extend Gold Line light rail service to the Pomona North Metrolink Station. The SBCTA letter was signed by Representative Pete Aguilar, Assembly Member Eloise Gomez Reyes, County Supervisors Janice Rutherford and Josie Gonzalez, Upland Mayor Debbie Stone, Rancho Cucamonga Mayor Dennis Michael, Fontana Mayor Acquanetta Warren, Rialto Mayor Deborah Robertson and Redlands Mayor Paul Foster.

In its Formal Response to this second issue, the City of Montclair respectfully objected to positions taken in the SBCTA letter suggesting that (1) Gold Line light rail service sharing approximately three miles of Metrolink San Bernardino Line alignment from Pomona to Montclair represents a serious harm to the San Bernardino Line’s ridership; and (2) the Construction Authority, in order to avoid any adverse future impact on Metrolink San Bernardino Line ridership, should reconsider extending Gold Line light rail service to Pomona and/or Claremont and Montclair.

Montclair’s Formal Response also questions SBCTA’s focus on a reported decline in Metrolink ridership out of the Covina Metrolink Station as justification to terminate Gold Line light rail service at, or short of, the Metrolink San Bernardino Line alignment out of the Pomona North Metrolink Station. SBCTA uses the Covina Metrolink Station ridership decline to argue that “rail-to-rail migration” is reducing Metrolink passenger boardings, and that even greater rail-to-rail migration will increase if, and when, Gold Line light rail service integrates with the Metrolink San Bernardino Line at the Pomona North Metrolink Station, and/or beyond to the Montclair Transcenter. In its questioning of SBCTA’s effort to correlate Metrolink ridership decline primarily to rail-to-rail migration, Montclair cites a number of studies that demonstrate Metrolink has been suffering annual ridership decline throughout its system over the past decade, and that there are many other causes for public transit decline that are not associated with the presence of an alternative public transit service. To support its position, Montclair made the following observations:

  • The Gold Line serves the Foothill cities of the San Gabriel Valley, Pasadena and Los Angeles. In contrast, Metrolink is a direct line between Los Angeles’ Union Station and San Bernardino. Together, they are complementary, not competitive, transit services that are vital to accessibility and integration into a larger mobility network designed to serve the needs of transit riders, and provide the greatest level of penetration into a region to promote the connectivity and accessibility that transit is vitally dependent on.
  • Ridership out of the Covina Metrolink station declined, in part, because many of the transit riders previously using the Covina Metrolink station were from neighborhoods closer to the new Azusa Gold Line stations, and found it more convenient to access transit service at the Azusa stations—in effect, these transit riders chose to take advantage of “transit ridership in my backyard” (TRIMBY).
  • The Gold Line light rail trip out of the Azusa stations does not appreciably increase the commute time to Los Angeles’ Union Station, and is certainly more advantageous to Azusa-area transit riders if the destination is Pasadena or other foothill cities in the San Gabriel Valley.
  • Transit riders out of the Azusa area who may be going beyond Los Angeles’ Union Station on Gold Line light rail service are not required to de-board at Union Station or transfer to other transit services.
  • The Gold Line offers a direct route to Pasadena as a destination, whereas Metrolink riders would require a transfer out of Los Angeles’ Union Station to the Gold Line for transit service to Pasadena, adding greater time for a Metrolink commute to Pasadena;
  • Gold Line fares are significantly lower than Metrolink fares;
  • Gold Line service is typically at regular 4 to 7 minute intervals all day long throughout each weekday, versus a varying schedule for Metrolink trains that can operate with 30 minute to one hour or greater arrival and departure intervals, with limited operating hours each day.

 

The City also observes that when SBCTA joined with Metro and the Construction Authority to apply for the CalSTA TIRCP grant in January 2018, the application was filed approximately 22-months after the Azusa Gold Line Stations went operational in March 2016. SBCTA reports that the Covina Metrolink station saw an immediate decline in ridership due to rail-to-rail migration. In fact, Metrolink’s own January 2018 study, “Falling Transit Ridership: California and Southern California”, attributes an ongoing and decade long decline in boardings to personal vehicle ownership. Specifically, the report states:

“In the last ten years transit use in Southern California has fallen significantly….and consider an array of explanations for falling transit use: declining transit service levels, eroding transit service quality, rising fares, falling fuel prices, the growth of Lyft and Uber, the migration of frequent transit users to outlying neighborhoods with less transit service, and rising vehicle ownership….we conclude that the most significant factor is increased motor vehicle access, particularly among low-income households that have traditionally supplied the region with its most frequent and reliable transit users.”

Thus, it is clear that Metrolink boardings began their decline long before the Gold Line Azusa stations went operational. In any event, if ridership decline on the Metrolink San Bernardino Line was an issue, SBCTA failed to address or acknowledge the concern at the time it joined with Metro and the Construction Authority at the time they jointly applied for the TIRCP grant, and only now raises it as part of the SEIR process.

In its Formal Response, the City of Montclair was compelled to ask a question regarding purported public transit-service competition: So what? Generally, competition is considered healthy because it spurs innovation, superior service and products, a range of choices, and greater interest and purchasing momentum among members of the population acquiring the service or product. In other words, competition can end up creating a larger base of riders that may come to appreciate and enjoy the benefits of public transit and use the services on a frequent basis. However, for this outcome to be realized, transit must become an attractive product for users; i.e., it must provide connectivity and accessibility, with an array of choices that allow for integration into the larger mobility network that is emerging and capturing the interest of a commuting public. Just like highway commuters, transit riders require door-to-door service. Public transit should function as the backbone to deliver larger numbers of passengers to connectivity points that offer accessibility to a mobility network that includes buses, other trains, pedestrian walking routes, bicycle paths, shuttle services, ride-hailing/sharing services, taxi services, transit district living, micro-transit to airports and other points, and a range of other choices that truly make transit functional, accommodating, and welcoming.

Finally, the City’s Formal Response discusses the role Montclair has taken in relation to bringing Gold Line light rail service to the Montclair Transcenter.

The deadline to submit the Formal Response was Friday, January 4, 2019. However, because the City of Montclair did not become aware of SBCTA’s transmission of its letter to the Construction Authority until a December 22, 2018, Inland Valley Daily Bulletin article, City staff had little time over the Christmas and New Year’s Holiday period to prepare both a response and secure the support of outside agencies. Nonetheless, Montclair timely submitted its Formal Response and is in the process of asking for support letters from Federal and State legislators throughout the region.

After its submission, the City of Montclair Formal Response became part of the public record and the Construction Authority will be required to respond.
A full copy of the City of Montclair Formal Response to the Supplemental Environmental Impact Report—Gold Line Phase 2B Procurement, dated January 3, 2019. has been
posted to the City’s Internet Homepage at www.cityofmontclair.org

SEIR Montclair Formal Response