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Glen Campbell March 30, 2006 Page 10

increased congestion is to build more freeways. The planners exhibit this view when they explain that “the projections for 2030 indicate that vehicle miles will increase faster than population and employment, mostly due to longer trips or commutes. In short, freeway capacity must grow to meet future freeway travel demand.” (DPEIR at 2-5) This conclusion ignores the obvious alternative viewpoint: some of the increased travel demand might be more properly diverted to mass transit solutions, as opposed to simply concluding that increased freeway capacity is the only solution. Based on a review of the Plan “objectives” to increase mobility, protect transportation resources and enhance the quality of life (see DPEIR at 2-3), other types of alternatives – alternatives that examine variable mixes of modes of transportation as opposed to just variable mixes of dollars – that still met the objectives of planners could have been considered.

Given that the impacts on the environment from the proposed Plan are projected to be significant, such alternatives should have been considered. One of the purposes of the discussion of alternatives in an EIR is to diminish or avoid adverse environmental effects. (See Laurel Heights Improvement Ass’n v. Regents of Univ. of Cal. (1988) 47 Cal.3d 376, 403 [discussion of only three alternatives, where planners claimed they had already ruled out other alternatives as infeasible, was inadequate]; Pub. Res. Code § 21002 [EIR should consider alternatives which would substantially lessen the significant environmental effects].)

C.

The DPEIR Does Not Contain Adequate Discussion of Biological Resource Impacts.

The DPEIR does not quantify the biological resource impacts that it recognizes will be more significant under the proposed Plan than under the No Project alternative. (See DPEIR at 5-6 through 5-7.) Additional detail on the magnitude of direct impacts of the project must be provided for the Proposed Project and all project alternatives. All of the proposed alternatives and the proposed Plan contain lists of the projects they include. The Program EIR should make an attempt to quantify the impacts. Instead, the DPEIR puts off the analysis of the biological resource impacts of all the projects until the EIR for the individual project is prepared. (See DPEIR at 4.2-22.) It is impossible to analyze the difference between alternatives on this subject, when the impacts have not been described.

D.

The Plan And DPEIR Should Include Plans For Improving Air Quality And Reducing Greenhouse Gas Emissions In Its Discussion Of “Environmental Programs.”

The only “environmental program” contemplated under the Plan is a program for

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