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Glen Campbell March 30, 2006 Page 5

recognizes its obligations to analyze greenhouse gas emissions and their impact on climate change as part of its long term transportation planning.


The DPEIR Does Not Adequately Discuss The Plan’s Impact On Air Quality.

The DPEIR’s discussion of air quality fails to address potentially serious impacts on Orange County and the South Coast air basin. In the DPEIR chapter on air quality the drafters concluded that there would be no significant unavoidable adverse long-term air quality impacts from the Plan (see DPEIR, 4.1-17 through 4.1-20), that the plan would have a neutral effect on air quality (see id.), and that the only potentially significant impacts relate solely to regional and local short term impacts from the construction of individual projects (e.g., construction of individual road widening, or lane building projects anticipated under the Plan). (See id. at 4.1-21 through 4.1-23)1. The DPEIR bases these optimistic conclusions on a comparison of the future, year 2030, emissions under the Plan to the emissions budgets of the federally mandated, local Air Quality Management Plan (AQMP), prepared by the South Coast Air Quality Management District (SCAQMD) and projected for 2030. The DPEIR finds that the Plan’s emissions are within the projected emissions for the AQMP in 2030, and thus there are no significant impacts. The fundamental basis on which all of the DPEIR’s assumptions rests, however, is that by the year 2030, “better fuels” and “improved emission controls” will result in overall emission reductions from vehicles. (See DPEIR at 4.1-18.) There are a number of things wrong with this analysis.

First, the comparison fails to analyze all phases of this 24-year project. The CEQA Guidelines require that an EIR consider “all phases of a project when evaluating its impact on the environment.” (Cal. Code Regs., title 14, §15126.) The huge emission reductions anticipated in the Plan by the year 2030 as an anticipated result of “better fuels” and “improved emission controls” will surely take some time. The DPEIR must look at the all phases of the 24-year project time frame, not just 2030, to discern if the project will have significant impacts on health and air quality. The DPEIR contains no analysis of whether the impacts on air quality in the “in between” years, before all of the “better fuels” and “improved emission controls” have been implemented, will be significant; there is no way to discern, from the information available in the DPEIR what the emissions during those years will be.

Second, there is no detailed comparison of the project with the emissions budgets of the AQMP. The DPEIR states that “[c]umulative impacts were assessed by comparing projected vehicle emissions in 2030 to the emission budgets established in the local AQMP.” (DPEIR at

1These impacts, according to the DPEIR, would be addressed through mitigation measures, but the mitigation measures include no monitoring requirements.

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