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Glen Campbell March 30, 2006 Page 11

augmenting urban runoff treatment and mitigation to create a “coordinated high-quality urban runoff program.” (DPEIR at 2-11.) As discussed in detail above, the impacts of the Plan on greenhouse gas emissions and the cumulative impacts of those emissions on climate change, warrant close examination in this DPEIR. Likewise, a plan like this one which places so much of its emphasis for transportation planning and spending on automobile and truck travel versus mass transit will likely result in greater emissions of criteria pollutants and toxic air contaminants than would an alternative that focuses on improving mass transit and reducing vehicular miles traveled. Given these considerations, the state of air quality in the South Coast air basin and the severe impacts climate change can inflict on the citizens of Orange County, it would be a responsible and reasonable planning measure to include some “environmental program” aimed at reducing the air quality and climate impacts of the proposed Plan. As mentioned in above, there are some easily implemented steps that might be considered, such as the purchase of mitigation credits. There are also programs that might encourage greater use of alternative technologies and fuels (e.g., electric and hybrid vehicles) or that might add incentives for increased use of public transit (enhanced employer managed discount programs that reward use of transit when compared with parking costs) that could be explored. This long term plan is an opportunity for OCTA to take a truly “visionary” role in shaping the transportation and environmental landscape of Orange County for the next quarter century. We hope that the opportunity will not be missed.

V. Conclusion

If you or your staff have questions regarding these comments, please contact me at 213- 897-0628.



KATHRYN W. EGOLF Deputy Attorney General


BILL LOCKYER Attorney General

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