Application 06-12-005 et al.

Exhibit

Date: August , 2008

PREPARED TESTIMONY

OF

JAMING ARKANGEL

Q: Please state your name, professional position, employer, and business

address.

A: My name is Jaming Arkangel. I am an officer with the Los Angeles School

Police Department. My business address is 1330 West Pico Boulevard, Los Angeles,

California, 90015.

Q: On whose behalf are you providing testimony today?

A: I am testifying on behalf of the Los Angeles Unified School District.

Q: What is the purpose of your testimony?

A: The purpose of my testimony is to describe the current student safety concerns at

Dorsey High School, to discuss the law enforcement challenges that will be posed by the

rail crossing planned for Farmdale Avenue and Exposition Boulevard, and to review how

alternative proposals for the crossing would improve my ability to enforce laws and keep

students safe.

Q: Where are you currently assigned?

A: I am currently one of two officers assigned to Dorsey High School.

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Q: How long have you been assigned to Dorsey?

A: For four and a half years.

Q: Prior to your assignment to Dorsey, what was your assignment?

A: I was assigned to an early morning patrol shift. I patrolled a wide range of areas

for emergencies or criminal activity between 9:30 p.m. and 7:30 a.m. I began that

position three months after my probationary period with the department ended. Before

joining the department, I was a Community Service Officer at California State University

at Northridge.

Q: What kind of training do you have in law enforcement?

A: I am a graduate of California State University, Northridge, with a degree in

Criminlogy. I attended the Los Angeles County Sheriff’s Academy, and attend in-service

training on different law enforcement topics as required by the California Commission on

Peace Officer Standards and Training.

Q: What are your duties as a Los Angeles School Police Officer?

A: My job is to enforce the law and keep students safe and secure. I investigate

crimes and make arrests. I also work with community organizations, such as Community

Build, which provides “eyes and ears” for students walking to and from school. I attend

community meeting so that I am kept abreast of problems in the community as they

develop.

Q: What geographic area do you work in?

A: I am assigned to Dorsey High School, but I am authorized to travel anywhere

within the Los Angeles Unified School District as part of my duties. I generally patrol

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within a two mile radius of Dorsey High School. I am often called to other nearby

schools when there are incidents.

Q: Aside from nearby schools, what off-site locations near Dorsey do you patrol

most frequently?

A: I patrol places where students congregate, including the neighboring park, the

burrito stand at Farmdale Avenue and Jefferson Avenue, the McDonalds on La Brea, and

the 7-11 on Martin Luther King Jr. Boulevard. I also regularly respond to calls from

other businesses reporting thefts or that students have rushed the store. Drug usage

outside businesses is another regular complaint requiring my response.

Q: What hours do you work at Dorsey?

A: I arrive at 7:30 a.m. and leave about an hour after dismissal, just after 4:00 p.m.

Q: How would you describe the neighborhoods around Dorsey High School?

A: The area suffers from gangs and violence, and students at Dorsey are among the

gang members. Students and other gang members frequently fight in the area around the

school. For instance, the side streets just north of campus, between Jefferson and

Exposition, are full of industrial and commercial buildings, and have little foot traffic.

Students frequently fight in this area. Gang members and other individuals also target

students for robberies and drug dealing. I frequently get reports from students that they

have been robbed for their cell phones or iPods.

Q: In your work as an officer for the Los Angeles School Police, have you

developed an understanding of the behavior of students at Dorsey High School?

A: Yes.

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Q: Are you familiar with the plans to install an at-grade crossing, with a

pedestrian plaza, at the intersection of Farmdale Avenue and Exposition Boulevard,

adjacent to the campus of Dorsey High School?

A: Yes.

Q: Based on your knowledge of the behavior of Dorsey students, and on your

familiarity with the crossing design, do you have any concerns about the proposed

crossing?

A: Yes.

Q: What are your concerns?

A: Based on student behavior that I have observed over the past four and a half years,

I am very concerned about the potential for students to engage in risky behavior that will

result in a deadly accident with the train. Every day, students crossing the street seem to

deliberately block cars in the intersections. I frequently must use my loudspeaker to get

students to move out of the street. Students seem to assume that drivers will stop for

them. I have seen students step into Rodeo Road to jaywalk with only a brief glance at

the cars coming nearest them. They continue crossing that four-lane road without further

looking. Students do not readily follow the rules when crossing the street, so I fear the

behavior of students when faced with crossing gates.

I am concerned that students will jump the gates and try to beat the train, or try to

run across the tracks as the gates are closing. Students engage in risky behavior without

regard for the consequences of their actions. I come across students who are under the

influence of alcohol and marijuana or a narcotic frequently, sometimes two or three times

a day. Students under the influence of drugs or alcohol frequently exercise poor

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judgment in determining whether it is safe to cross the tracks. I am also concerned with

students’ tendency to push others and the likelihood that they might push another person

in front of an on-coming train in a fight or gang-related incident.

The “holding pen” also concerns me. I believe students will try to find a way

around being corralled into this area. I am also concerned that the close quarters will

encourage robberies and fighting. When there is a high concentration of students in one

place, such as at dismissal, it takes very little to start a fight. As an example, one day at

dismissal a student was taking pictures of other students and a big fight broke out as a

result. I already have to call for backup officers from others schools on occasion at

dismissal and lunchtime due to the large fights that occur when big groups of students are

in a place at one time. I am concerned that such large fights will occur even more

routinely when students are forced to congregate in such a small area. Even worse than

fighting would be a drive-by shooting. Feuding between gangs in the area sometimes

results in a drive-by shooting, and the large number of students crammed into a small

area such as the “holding pen” would be an attractive target.

I am also concerned about being able to respond quickly to crimes and fights

taking place on the far side of the tracks. Currently, the corner of Exposition and

Farmdale opposite the school is a hot spot for student fighting. When the trains are

coming through, my ability to reach that location will be decreased. Students will be

aware of this, and use this location for fights more often.

Q: Do you feel that you have an adequate number of adults to ensure safety and

adequately supervise students at this point?

A: No. We are stretched thin.

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Q: Would you be able to post security officers or other monitors in any

additional locations in the future when the light rail is operating?

A: Not without losing essential coverage in other areas, or without the addition of

officers or staff.

Q: Would a pedestrian overpass over the tracks address any of your concerns

about the light rail crossing at Farmdale?

A: As long as students were not able to easily access the tracks just outside of

campus, where they congregate in such large numbers, my concerns about students

jumping the gates, trying to beat the train, or fighting and pushing one another in front of

the train would be addressed. If there were no need for students to be forced to wait in

the “holding pen,” I believe there would be less violence and fewer robberies during the

dismissal period. The overpass would have to be fully enclosed so that students could not

throw objects or other students over the top.

The overpass might have an advantage from a law enforcement perspective

because we would be able to take advantage of its good view of the area. Particularly

with the addition of extra personnel, the overpass could be useful for law enforcement

activity.

Q: How would your ability to respond to emergencies be affected if Farmdale

were closed to vehicular traffic at Exposition Boulevard?

A: I would be concerned about getting to the far side of Exposition or to areas

just north of Exposition, such as the burrito stand at Jefferson and Farmdale, where I am

frequently called to locate truants or intervene in student fights. In order to access these

areas, I would have to drive to Buckingham and cross the tracks there. I am concerned

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about the delay that would add to my response time. Nevertheless, my concern about the

dangers created by the proposed design of the Expo crossing lead me to conclude that if

the trains will be traveling at ground level, then a pedestrian overpass and closing

Farmdale is essential, despite my concern for my more difficult access north of

Exposition.

Q: Would a light rail overcrossing, where the train is on elevated tracks, address

your concerns?

A: If the train were to run above the street on elevated tracks and allow for vehicles

to travel freely through the intersection of Exposition and Farmdale, I believe that I

would be able to respond quickly to crimes or fights on the other side of Exposition, and

that students would be kept well away from the tracks in the area where they most

frequently congregate in large numbers. If the tracks were constructed on a solid

embankment, however, I would be unable to see students or others on the far side of the

embankment, creating a serious security risk. The tracks would have to be constructed on

posts so that the line of sight across the tracks is as unrestricted as possible.

Q: Does this conclude your testimony?

A: Yes, it does.