ACTION ALERT: Comments are currently being solicited by Metro in response to their issuance of a Draft Environmental Impact Report (DEIR). Comment deadline is Oct. 24, 5 pm.
Submit comments to: email@example.com or by mail to: One Gateway Plaza, Mail Stop 22-9, Los Angeles, CA 90012, Attn: Shine Ling, Development Review Team
This deceptively named program represents a joint initiative between Metro and the City of LA to install 56 full-sized changing digital billboard structures in LA City, 34 of which will be “freeway-facing” and 22 additional structures that will be “non-freeway-facing” (on our City streets) to generate ad revenues to be split between the City and Metro. The City has already entered into a Memorandum of Agreement (MOA) for the development of a TCN with Metro despite the fact that no public hearings have been held by the City, and before the completion of the environmental review under the California Environmental Quality Act.
The program was not considered in the open by Council but instead was presented as a recommendation within an ADDENDUM TO THE 2021-22 SECOND FINANCIAL STATUS REPORT COUNCIL FILE NO. 21-0600-S110 dated December 3, 2021 submitted by CAO Matt Szabo to the City Council Budget and Finance Committee. The TCN was Item number 5 under recommendations from the CAO that the Council, subject to the approval of the Mayor:
“Amend Exhibit H Recommendation H.14 in the 2021-22 Adopted Budget, to authorize the City Administrative Officer to finalize and execute a Memorandum of Agreement (MOA) for the development of a Transportation Communication Network (TCN) Program with the Los Angeles County Metropolitan Transportation Authority (Metro), subject to the City Attorney approval as to form.”
When the TCN program was being considered by the METRO board, those of us who raised concerns with the LA City representatives to the Metro Board were told that we would have ample opportunity to raise questions and concerns when the program came before the City. That has not proven true. The City is attempting to move the approval by avoiding public discourse and consideration. Further, the manner in which Metro is conducting the EIR/CEQA process is a matter of concern. Many of the communities and neighborhood councils directly affected did not receive notification of the Scoping Period for the EIR process. The hearings recently held by Metro on Oct. 6 and 7 to take feedback on the DEIR were not well attended or publicized. It appeared that ONE person participated in the Oct. 6 zoom hearing by asking questions, and 4 people participated in the Oct. 7 hearing. Could it be that referring to the TCN as a “communications network” as opposed to making reference to the fact that it is a digital billboard program, have anything to do with the absence of public involvement?
We urge citizens to submit comments to Metro. Comments submitted in response to a draft EIR are different from those that voice support or opposition to a program although your comment letter may also include comments of opposition.
An EIR is designed to identify the significant impacts of a proposed program on the environment (evaluated according to a list of categories/environmental topics of concern such as aesthetics, land use and planning, historical resources, etc.). Those submitting comments are invited to address whether the DEIR adequately identifies negative impacts (identified by environmental category) and whether they can be mitigated or how they might be mitigated. An EIR is also meant to explore alternatives to the proposed project.
The METRO webpage for the program can be found here.
The DEIR can be found here.
If you go to the PROJECT DESCRIPTION section of the DEIR you will find a chart that lists all of the locations now slated for full-sized changing digital billboard structures in Chapter 2 on pages II-8 to II-9 for Freeway Facing TCN Structures (Table II-1), and on pages II-10 to II-11 for Non-Freeway Facing TCN Structure Locations (Table II-2). Some billboards are single-sided billboards and others are double-sided. The total number of ad faces needs to be clarified.
Some points to raise in comments can be found in this letter, prepared by Scenic America for public comment.
Comments are to be submitted to: firstname.lastname@example.org by Oct. 24, 5 pm.