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Glen Campbell March 30, 2006 Page 8

document as deficient as this DPEIR.4 The DPEIR states “[t]he lead agencies for individual projects may use this PEIR as the basis of their regional and cumulative analysis.” (DPEIR at 2- 13.) The deficient analysis of the air quality impacts would make any meaningful project-level analysis of regional and cumulative of air quality impacts for an individual project nearly impossible. For example, it is possible that a project-level EIR could be prepared next year for a project such as a lane-addition to a freeway. Based on “tiering” from this DPEIR, the planners of such a project would have only the conclusory statements regarding air quality impacts in the year 2030 from this DPEIR upon which to base cumulative and regional impacts analyses in their EIR, whereas the new hypothetical freeway lane might be operational in 2009. There would be no analysis of the cumulative and regional impacts of that project for years 2009 through 2029. While this example pertains only to the air quality analysis, the other failings of the DPEIR discussed below also contribute to the inappropriateness of allowing future project level EIR’s to “tier” off of this deficient CEQA document.


The DPEIR Contains Many Other Inadequacies.

In addition to the failure of the DPEIR to adequately address air quality, and to address greenhouse gas emissions impacts at all, the DPEIR is inadequate in a number of other areas.


The DPEIR Does Not Contain An Adequate Description of the Project

Chapter 2 of the DPEIR, is titled “Project Description” and it does contain a list of the projects that the Plan envisions. The description, however, is lacking. The list of projects contemplated under the plan includes one-line, bullet-point descriptions of various freeway and interchange improvements, lane additions and ramp construction projects that will make up the improvements to freeways under the Plan. (There are also one-line, bullet-point descriptions of the other planned projects.) Despite the fact that the primary focus of projects and spending under the Plan is on freeway construction projects, however, the Project Description does not contain any maps or visual drawings of the Plan’s contemplated improvements. It is very difficult to ascertain what the impacts on the ground will be from the brief descriptions of the planned projects. Guidelines indicating areas of disturbance, or footprints, for planned projects should be included. From the descriptions in the DPEIR, an understanding of the true impact of the Plan is not possible.

4“‘Tiering’ or ‘tier’ means the coverage of general matters and environmental effects in an [EIR] prepared for a policy, plan, program or ordinance followed by narrower or site-specific [EIRs] which incorporate by reference the discussion in any prior EIR . . .” (Pub. Res. Code §§ 21068.5.)

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