CYNTHIA A. HARDING, M.P.H.

Interim Director

JEFFREY D. GUNZENHAUSER, M.D., M.P.H.

Interim Health Officer

ANGELO J. BELLOMO, REHS, QEP

Director of Environmental Health

5050 Commerce Drive

Baldwin Park, California 91706
TEL (626) 430-5100 FAX (626) 813-3000

BOARD OF SUPERVISORS
Hilda L. Solis
First District
Mark Ridley-Thomas
Second District
Sheila Kuehl
Third District
Don Knabe
Fourth District
Michael D. Antonovich
Fifth District

www.publichealth.lacounty.gov

August 5, 2015
Mr. Garrett Damrath
Chief Environmental Planner
Caltrans District 7
Division of Environmental Planning
100 S. Main Street, MS-16A
Los Angeles, CA 90012
SUBJECT:

REVIEW OF STATE ROUTE 710 NORTH PROJECT DRAFT EIR/EIS BY THE LOS
ANGELES COUNTY DEPARTMENT OF PUBLIC HEALTH

Dear Mr. Damrath,

The Los Angeles County Department of Public Health (DPH) Bureau of Toxicology and Environmental Assessment
is submitting this comment letter on the SR-710 DEIR/EIS. DPH has reviewed the DEIR/EIS for potential health
impacts that may arise from this transportation project. Our review reveals a number of deficiencies that must
be addressed in order to ensure the protection of the publics health.
1) Environmental exposures
a) The DEIR/EIS does not adequately address the production of airborne emissions and noise that may be
produced by this project. Particulate pollution from fibers, coarse particles, fine particles, and
ultrafine particles from both construction and operation have notable impacts on cardiovascular,
respiratory, and neurological health. The DEIR/EIS should include measures specifically to mitigate
exposures to particulate pollution.
b) Excavation during construction may lead to the liberation of radon gas, a known human carcinogen
which is formed in soil. The DEIR/EIS does not adequately address the risk of radon exposure during
construction, and provides no surveillance for radon after project completion.
c) The DEIR/EIS does not adequately address dust suppression measures to prevent the transmission of
Valley Fever and other soil-borne infectious diseases.
Cyrus Rangan, M.D., F.A.A.P., F.A.C.M.T., Director Bureau of Toxicology & Environmental Assessment
695 South Vermont Avenue South Tower-14th Floor Los Angeles, CA 90005 TEL (213) 738-3220 FAX (213) 252-4503

d) The DEIR/EIS does not adequately address the production of noise and vibrations, from construction,
traffic, and ventilation/maintenance systems, which present significant short and long-term health
risks. Ground vibrations present additional risks, such as amplification of radon migration; and
damage to structures such as older housing, historical buildings, and unique facilities such as
laboratories.
2) Worker health and safety
The DEIR/EIS should implement a comprehensive plan to protect the health and safety of workers during
construction and operation of the project. Construction and maintenance workers are at risk for
numerous exposures such as asbestos, radon, air & soil emissions, noise, and vibrations. A worker safety
plan should be prepared, with review and input from the appropriate state regulatory agencies, to
mitigate potential hazards to site workers and the public.
3) Impacts on human health
The DEIR should include a broader and more balanced analysis of all of the the health benefits and
negative impacts of the project on both workers and community members, with consideration of relevant
published scientific and medical research. Potential disease impacts from this project include cancer;
cardiovascular disease; asthma and other respiratory diseases, impaired child lung development; adverse
pregnancy outcomes such as birth defects and low-birth-weight births; obesity and diabetes; and
neurological disease. Automobile-oriented transportation projects often limit active transportation
modalities such as walking and bicycling, and raise the risk of injuries to pedestrians and cyclists. Further
analysis should be directed to the impact of this project on active transportation and injury risks. The
DEIR/EIS should analyze the baseline health status of the surrounding communities, including
identification of vulnerable populations, such as children, pregnant females, seniors, and people with
disabilities; and assess the impact of the project on the rates of acute and chronic diseases.
4) Impacts on communities
The DEIR/EIS includes a community impact assessment but does not adequately address how these
impacts may affect the health of the residents of the impacted communities. For example, changes in the
community that reduce opportunities for physical activity, reduce access to healthy food options, or
reduce access to medical clinics or hospitals all could adversely impact health. In addition, changes to the
community that reduce community cohesion and increase social isolation could also profoundly impact
health in negative ways. The DEIR/EIS should include an assessment of how the projects impacts on the
overall character of the community will in turn impact community health, and provide recommendations
for how these health impacts can be minimized.
For further questions, please contact Cyrus Rangan M.D. at (213) 738-3220.

Sincerely,

Cyrus Rangan M.D., FAAP, FACMT

Director, Bureau of Toxicology and Environmental Assessment
Los Angeles County Department of Public Health

Cyrus Rangan, M.D., F.A.A.P., F.A.C.M.T., Director Bureau of Toxicology & Environmental Assessment
695 South Vermont Avenue South Tower-14th Floor Los Angeles, CA 90005 TEL (213) 738-3220 FAX (213) 252-4503