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Glen Campbell March 30, 2006 Page 7

sensitive receptors (DPEIR at 4.1-16), yet the DPEIR makes no effort to evaluate the project’s effects on them.2

Fifth, where the DPEIR does provide some mitigation for the few significant air quality impacts it does recognize (related to construction), the document makes no assignments, not even tentatively, of responsibility for enforcing them through mitigation monitoring. The DPEIR recognizes only two categories of potentially significant impacts on air quality: Short- term (construction) regional impacts (from a number of construction-related activities and materials) and short-term localized impacts (from construction vehicles which are sources of carcinogenic pollutants and diesel exhaust). (See DPEIR at 4.1-21 through 4.1-23.) With regard to the construction impacts, the DPEIR acknowledges that “a large number of the projects in the [Plan] would involve extensive construction or reconstruction” and that it is “very likely” that some of the projects would be under construction at the same time. (DPEIR at 4.1-21.) Notwithstanding the acknowledged significant air quality impacts the construction activities are expected to produce, there are no monitoring requirements for the list of mitigation measures that the DPEIR says “should be considered” when EIR’s are prepared for the individual projects. Likewise, there are no monitoring requirements incorporated in the mitigation measures to address the emissions from construction equipment. Moreover, Chapter 7, Mitigation Monitoring and Reporting Program, does not indicate any monitoring actions, or responsible implementation agencies for the proposed mitigation measures. (DPEIR at 7-1 through 7-34.)

OCTA is required to “provide that measures to mitigate or avoid significant effects on the environment are fully enforceable through permit conditions, agreements or other measures.” (Pub. Res. Code § 21081.6(b).) The DPEIR should disclose and discuss such mitigation monitoring measures, or at least make tentative assignments of responsibility for enforcing them, so that the public can take these proposed measures into account.3

Finally, given the inadequacies and lack of detail in the air quality impacts analysis it is not appropriate for all future projects contemplated under this Plan to be able to “tier” off of a

2In addition to these failures to address toxic air contaminants, in the chapter on Hazardous Materials, the DPEIR does not examine the indirect effects of the 45 % increase in VMT, such as increased cancer risk from benzene and other petrochemical toxic emissions released from gas stations, increased refinery emission, and the like.

3In addition, the Plan should contemplate, discuss and disclose whether funding for the mitigation measures it will require is or will be available.

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