Application 06-12-005 et al.

Exhibit

Date: August , 2008

PREPARED TESTIMONY

OF

VERONIQUE WILLS

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

A: My name is Veronique Wills. I am Principal of Foshay Learning Center, and my

employer is the Los Angeles Unified School District. My business address is James A. Foshay

Learning Center, 3751 South Harvard Boulevard, Los Angeles, California, 90018.

Q: On whose behalf are you providing this testimony?

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 student body at Foshay Learning Center,

to discuss the uses of the Foshay campus, and to explain the safety concerns I have with the

proposed crossings in the vicinity of my school.

Q: What is your educational and professional background?

A: I have been Principal of Foshay Learning Center for close to seven years. Prior to that, I

spent 10 years as an assistant principal at Foshay. Before I came to Foshay, I taught for 10 years

at Wilmington Middle School, for six years in special education and four years in math. Before

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teaching in California, I was a teacher in Chelsea, Michigan for three years, working with

learning disabled students.

I am a graduate of University of California at Santa Barbara, where I received a B.A. in

psychology. I have an M.A. in Emotional Disturbances and a teaching credential from Eastern

Michigan State University. I obtained my administrative credentials from California State

University Dominguez Hills, and have completed some doctoral work at University of Southern

California in the education leadership program.

Q: What are your duties in your current position?

A: My primary jobs are to foster student achievement and to maintain a safe campus. I

create social and learning opportunities for students and try to build a healthy community around

the school. In order to do that, I have to ensure student safety both on campus and as students

travel to and from the school. Of course, I also manage the day-to-day operations of the school

and make certain that our school runs smoothly. I supervise 6 assistant principals and 300

employees, 150 of whom are teachers.

Q: Please describe the student body at Foshay.

A: This is a K through 12 school, though most of our students are in middle school. We

have about 185 elementary school students in our “Village” campus, and about 650 high school

students. There are over 2500 middle school students at Foshay. The middle school students are

on three “tracks” so that only two tracks attend school at any one time. We are a year-round

school, so at any time of year there are approximately 2000 students attending Foshay.

Our students are 78 percent Latino and 20 percent black. Thirty-seven percent of our

students are English language learners. Even for our students who are proficient in English,

many have parents who speak exclusively Spanish. This is a low income area. Ninety percent of

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our students qualify for the federal free lunch program. This is also a violent area plagued by

problems with gangs. We screen our entering sixth grade students for post-traumatic stress

syndrome because we find that so many have been exposed to violent events that effect their

ability to learn. Approximately 10 percent of our students are in foster care. We have roughly

400 special education students.

Q: What is the daily schedule at Foshay?

A: The elementary and secondary schools are on different schedules. The secondary schools

start at 7:20 a.m., with a dismissal bell at 3:18 p.m. Elementary school begins at 8:30 a.m. and

dismisses at 2:45 p.m. For students in secondary school, we offer an intersession that students

may attend when their “track” is not in school. It is our version of summer school. Intersession

runs from 7:30 a.m. to 11:50 a.m. Students also arrive starting as early as 6:00 a.m. for our

before school daycare center, Stone Soup.

Q: Are there any other reasons that students or other people come to your campus?

A: We have a health clinic located on our campus for the community to use. It is open every

day from 8 a.m. to 5 p.m., and on Saturday for limited hours. The clinic stays open during our

school vacations. We also have a number of students who come to Foshay between 6:30 and

7:30 a.m. to board a bus and travel to other schools. On Thursdays, these students return as early

as 1:30 p.m., and students return as late as 6:00 p.m. We also have a Saturday School that brings

200 to 400 students to campus from 8:00 a.m. to 12:05 p.m. on Saturday. Parents are also very

frequent visitors to Foshay. There are from 10 to 15 parent-teacher conferences each day, and 10

to 15 parents come each day to address administrative issues or pick students up early. In

addition, we have a Parent Center where parents can take ESL and technology classes or attend

parent workshops. There are probably 10 to 20 parents at school each day for these events. In

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total, I’d estimate that there are anywhere from 30 to 60 parents visiting campus daily, outside of

routine trips at arrival and dismissal.

Q; How do students get to and from Foshay?

A: Most students either walk or are dropped off by their parents. A large number of students

— more than 100 — take the public bus that stops at Western and Exposition. With the

beginning of construction of the Expo rail project, our drop offs and pick ups have become very

difficult. Parents are dropping their children in the middle of Harvard and even on Exposition.

In the afternoon, we have staff outside to supervise parent pick ups, but it is very difficult to keep

traffic moving on Harvard.

We have two buses for special education students, used by about 15 students.

Of students who walk to school, approximately 400 use a pedestrian tunnel that crosses

underneath Exposition at Harvard. We call this the Harvard tunnel. There are about 1,000

students who cross Exposition either at Western or Denker. Many students cross Exposition at

Western because the shops on the southwest corner are popular student hangouts.

Q: Do you make any efforts to inform students or parents about the safest routes for

their students to take to school?

A: Yes. We provide parents a flyer showing the legal ways to pick up their children, and we

send parents a map showing the approved routes for walking to school. We do not do any formal

training with the students themselves on this subject.

Q: Can you tell us more about the tunnel, starting with what you know of its previous

use?

A: Yes. The tunnel was open 24 hours a day some years ago. It became very dangerous and

the City of Los Angeles closed the tunnel due to vandalism and drug use. When I arrived at

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Foshay in 1992, the tunnel had been closed for some time. In looking for a safer alternative for

our students to cross Exposition, we were able to arrange with the City to open the tunnel for

limited hours. When we opened the tunnel for the first time, it was disgusting. It was full of

urine and other unhealthy material. We restored and painted the tunnel, using the help of our

parent volunteers, and today we, together our parent volunteers, manage the tunnel’s operation.

We have a key to the tunnel and keep it locked except for periods just before the morning bell

and just after dismissal, for a total of about one hour a day, when it is open for student use with

our supervision.

Q: Who supervises the students using the tunnel?

A: The tunnel is entirely supervised by volunteers, primarily parents of students. In the

morning, the tunnel is supervised by parent volunteers, and in the afternoon it is supervised by

volunteers from the Safe Passages component of the L.A. Bridges program and by the staff of

Foshay. (The L.A. Bridges program is a partnership with the City of Los Angeles for gang

prevention and early intervention, and Safe Passages is a program that helps provide students

with safe routes to and from school by creating a visible adult presence — with trained

volunteers — near impacted middle school campuses.) We have three to five people keeping

watch at any one shift. We post people on either end of the tunnel and sometimes in the middle

of the tunnel, depending on how many volunteers we have available.

Q: What hours is the tunnel open?

A: The tunnel is open from about 7:00 to 7:30 a.m., and 3:15 to about 3:40 p.m.

Q: Given the schedules you just described, would you say that students are coming and

going from campus at hours when the tunnel is not open?

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A: Yes. Students come to and leave the campus at many hours when the tunnel is not open.

We simply do not have the manpower to keep the tunnel open for longer than we do.

Q: Would you be able to open the tunnel at all hours of the day?

A: No. The tunnel cannot be kept open unless there is someone there to supervise it. If we

kept the tunnel open at all times without supervision, it would attract vagrants, drug dealers, gang

members, and vandals. It is likely that the lights in the tunnel would be knocked out

periodically, leaving the tunnel in darkness. When we first opened the tunnel, we had to

persuade students to use the tunnel because they were scared to go down there. If the tunnel

were open 24 hours a day without full-time supervision, students would again cease using the

tunnel. It would also be impossible to get volunteers to supervise the tunnel during limited

hours, because those volunteers would be afraid of what they might find when they arrived at the

tunnel. We currently do not publicize the existence of the tunnel beyond our student body

because we want to ensure that its use is limited to students and parents in order to maintain it in

a clean and safe condition.

Q: Is the tunnel accessible to people with disabilities who are confined to a wheelchair?

A: No. Currently, there are no students with disabilities, but some of our parents have

disabilities. These individuals cannot use the tunnel. If we have any students with mobility

limitations in the future, the tunnel would be inaccessible to those students.

Q: During your time at Foshay, have there been any accidents involving students going

to or from school?

A: Yes, there have been a number of accidents during my years at Foshay, some of them

quite serious. A student was hit by a car while crossing Exposition during the rain at a time

when the tunnel was closed. He got caught by the car and was dragged for a distance. It took

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him months to recover. Another bad incident occurred when a person was making a right turn

off of Harvard onto Exposition. The driver hit several students, and teachers were able to save

one student only by lifting the car off the student. That student was injured for life. Another

serious accident happened when some intersession students, leaving campus when the tunnel was

not open, were crossing at Denker and Exposition. One student was hit by a truck making an

illegal turn. The truck dragged her along the gravel and her face was shredded, requiring serious

medical attention.

Q: Do you have any crossing guards?

A: We have one crossing guard, for the intersection Harvard and 37th, near the elementary

school.

Q: What concerns do you have about how your students might behave when the rail

line is operational?

A: I am very concerned about my middle school students. I call the age from 10 to 13 the “I

dare you” age. Students at this age are not as aware of the consequences of their actions and

may engage in unsafe behavior. Currently, my middle schoolers will pretend to push their

friends in front of on-coming buses, and throw rocks at passing cars. I think that students in this

age range are likely to try to beat the train or try to touch the train as it passes.

Many of my students wear iPods and headphones, and are distracted and don’t pay

attention to traffic. Although the students will listen to a crossing guard, if there is no one at an

intersection (which is the case for most of the intersections near Foshay), students often forget to

look for traffic and step into the street.

I am also concerned about security of our students. With the construction on Exposition

Boulevard it has become difficult to monitor what is going on across the street, and using the

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tunnel to get to conflicts requires us to go out of sight temporarily, which is detrimental to

controlling campus safety. Having a line of sight and access to activity on the far side of

Exposition has been very important in maintaining safety near our school.

Q: What are your concerns about the proposal to maintain the Harvard tunnel and run

the Expo light rail above it?

A: I am concerned about where my students will cross in the hours that the tunnel is not

open. As I just discussed, students come to and go from this campus at many hours when we

cannot have the tunnel open. Student or parents with limited mobility or in wheelchairs would

be unable to use the tunnel, even if it were open. Students have told me that they will be scared

to use the tunnel when the train is operating, due to the noise and vibration from the train, as well

as a fear that the tunnel will collapse from the train or that in an earthquake the tunnel and train

will collapse upon them. I am concerned about students being forced to use the other at-grade

crossings in the area because I do not think the at-grade crossings provide adequate student

safety.

Q: Would the at-grade crossing at Western and Exposition be used by students when

the tunnel is not open?

Yes. That crossing, and the crossing at Denker and Exposition, are the only options for students

to cross when the tunnel is not open.

Q: Are you familiar with the proposed at-grade crossing at Western and Exposition?

A: Yes.

Q: Do you have concerns about students using that crossing when the tunnel at

Harvard is not open?

A: Yes, I do.

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Q: What are your concerns?

A: I am very concerned that there will be no pedestrian or automobile gates at that crossing.

I am particularly concerned about the lack of pedestrian gates. My students would obey the

gates, but the warning signs will not be adequate to demonstrate to students that a train is

approaching. This is particularly true with students who are not English speakers or for our

special education students. I am also concerned that there will not be fences to keep students off

of the tracks when crossing the intersection.

Expo staff told me that trains would slow when approaching intersections and the station,

but on the tour I took of the Gold Line, I observed four trains arriving at the station near Arroyo

Seco school, and only one of the trains approached slowly. The other trains stopped abruptly

when reaching the station. Expo explained to me that it is the driver’s discretion how soon to

slow down when the train is to come to a stop. I am concerned that trains will race through the

intersection at Western.

Q: How would a pedestrian overcrossing address your concerns?

A: A pedestrian overcrossing could be open 24 hours a day without the need for additional

supervision at all times. Supervision would be required during peak usage at arrival and

dismissal, but the overcrossing could remain open at other times of day without creating an

undue safety risk. As long as the overcrossing were fenced on all sides, including the top, I

believe it would be safe for those who come to our campus even when it could not be supervised.

An overcrossing could be constructed to accommodate an elevator or ramps for those in

wheelchairs. An elevator would need some supervision or controlled access, however.

Q: Would an overcrossing reduce student use of the nearby intersections like Western

and Denker?

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A: In my opinion it would, because it is located very conveniently to the campus. When

students need to come or go from the campus when the tunnel is not open, they are forced to go

to Western or Denker, which means additional walking. With an overpass, these students could

cross at Harvard. Although students would likely continue to use the other intersections, an

overpass would draw students away from these intersections. We would instruct students that

using the overcrossing is the safest way to cross.

Q: Have any parents expressed concerns to you about the proposed crossings near

Foshay Learning Center?

A: Yes, I have spoken with numerous parents about their concerns. Many concerned parents

attended the recent workshop at Foshay as well.

Q: Does this complete your testimony?

A: Yes, it does.

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