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Glen Campbell March 30, 2006 Page 9

The public should be able to understand from the DPEIR what implementation of the Plan will mean to their communities and their surroundings in physical terms. “Only through an accurate view of the project may affected outsiders and public decision-makers balance the proposal's benefit against its environmental cost, consider mitigation measures, assess the advantage of terminating the proposal (i.e., the "no project" alternative) and weigh other alternatives in the balance. An accurate, stable and finite project description is the sine qua non of an informative and legally sufficient EIR.” County of Inyo v. City of Los Angeles, (1977) 71

Cal.App.3d 185, 192-193.


The DPEIR Does Not Contain An Adequate Analysis of Alternatives.

The alternatives considered in the DPEIR consist entirely of plans that envision varying degrees of funding, as opposed to plans that envision alternative mixes of various transportation improvements or projects. The four alternatives to the Proposed Plan are:

(i) the No Project (Baseline) Alternative, which “includes projects and programs that have secured funding, have been assessed for their environmental impacts, and have been approved to be implemented” (a small sub-set of the projects in the Proposed Plan) (DPEIR at 5-4,);

(ii) the Constrained Alternative, which is “a set of projects and services that can be completed within the County’s traditional revenue sources for transportation improvements” (a sub-set, larger than the No Project Alternative sub-set, of the same projects that are included in the Proposed Plan) (DPEIR at 5-11, 5-17);

(iii) the Balanced II Alternative, which “includes all of the projects from the Proposed Plan with the exception of the High Occupancy Toll (HOT) projects proposed along [SR 91, including the direct connectors between SR-241 and the SR-91 toll lanes” (DPEIR at 5-29); and

(iv) the “Unconstrained” Alternative, which “includes projects and services that could be implemented . . . if funding was not an issue.” (DPEIR at 5-43.)

It is clear from the alternatives considered that the planners looked only at alternative levels of funding that would allow variable numbers of projects off a master-list of desired projects, and not at alternatives designed to provide alternative levels of environmental impact, or a different master-list of projects. For example, nowhere does the DPEIR consider a potential alternative that changes the balance of spending to focus more on improvements to mass transit services rather than on improvements to freeways and roadways. The decision to focus so much attention on freeway upgrades was pre-determined by the planners’ view that the only solution to

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