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BILL LOCKYER Attorney General

State of California DEPARTMENT OF JUSTICE

RONALD REAGAN BUILDING 300 SOUTH SPRING STREET, SUITE 1700 LOS ANGELES, CA 90013

Public: (213) 897-2000 Telephone: (213) 897-0628 Facsimile: (213) 897-2802 E-Mail: kathryn.egolf@doj.ca.gov

March 30, 2006

VIA OVERNIGHT MAIL AND U.S. MAIL

Glenn Campbell, Principal Transportation Analyst Orange County Transportation Authority 550 South Main Street P.O. Box 14184 Orange, CA 92863-1584

RE:

Orange County Transportation Authority 2006 Long-Range Transportation Plan Draft Program Environmental Impact Report

Dear Mr. Campbell:

The Attorney General of the State of California submits the following comments regarding the Orange County Transportation Authority (“OCTA”) 2006 Long-Range Transportation Plan (“Plan”) Draft Program Environmental Impact Report (“DPEIR”). The Attorney General provides these comments pursuant to his independent power and duty to protect the natural resources of the State from pollution, impairment, or destruction in furtherance of the public interest. (See Cal. Const., art. V, § 13; Cal. Gov. Code, §§ 12511, 12600-12; D’Amico v. Board of Medical Examiners, 11 Cal.3d 1, 14-15 (1974).) These comments are made on behalf of the Attorney General and not on behalf of any other California agency or office. While these comments focus on some of the primary issues raised by the Draft PEIR, they are not an exhaustive discussion of all issues.

I. Introduction

The Plan is described as being OCTA’s “blueprint” for maintaining and improving Orange County’s transportation network, including freeways, roadways and bus and rail systems through 2030. The Plan focuses much of its attention and planned spending on freeways and roadways, with a much smaller emphasis on public transit. Consequently, the Plan forecasts huge increases (approximately 45%) in vehicle miles traveled (“VMT”) per day in the coming years. The environmental analysis in the DPEIR fails to adequately analyze air quality impacts and contains no analysis at all of the impact of the Plan on climate change, both in violation of the California Environmental Quality Act (“CEQA”), Pub. Resources Code §§ 21000, et seq. Orange County is one of the most populous counties in the State, in one of the worst air quality regions in the country. The environmental and public health concerns raised by the projected

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