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4. "The DEIS states the project is included in the Regional <br />Transportation Plan (RTP) and that therefore it would conform <br />with the proposed SIP revision. The FEIS must describe exactly <br />'stow and where this project was included in the R F and <br />whether the traffic and growth projections used in the DEIS are <br />the same as those used in the RTP. <br />Consistency with the RTP, however, does not guarantee <br />conformity with the 1958 proposed SIP revision. The FHWA <br />should consult with the South Coast Association of Governments <br />and the South Coast Air Quality Management District to apply <br />their newly adopted SIP conformity procedures to this project. <br />These procedures require that the FEIS address issues such as <br />growth - related and corridor -level impacts of the proposed <br />project." <br />.. .=I <br />Page N -17 of the DEIS indicates that "The mobile emission analysis of <br />the area's air quality management plan included in the proposed SIP <br />revision is based on a RTP (and Program) that includes this project. <br />Therefore, it is expected that if a SIP revision is approved in the project <br />area, this project would conform to it." <br />This statement was included, verbatim, at the direction of the U.S. <br />Department of Transportation, Federal Highway Administration, <br />Region Nine, in their October 17, 1988 letter to Mr. Robert K. Best, <br />Director, at Caltran's Sacramento office, concerning the Pre -Draft <br />Environmental Impact Statement. <br />With regard to this project's consistency with the proposed SIP revision, <br />which is based on this regions new AQMP, please refer to Response to <br />EPA, Comment No. 2, above. <br />S. "The technical study for the project by Endo Engineering <br />assumes that traffic volumes would be the same with and without <br />the project. The study concludes that congestion would be <br />reduced and traffic speeds would increase. On this basis, the <br />DEIS predicts that air emissions for carbon monoxide and <br />hydrocarbons would decline with construction of the project. <br />Given that existing levels of services are very poor this may not <br />be an accurate assumption. Without the project, soroe of the <br />future traffic night travel at alternative times, by alternative <br />modes, on alternative routes, or not at all. By assuming the <br />traffic volumes would be identical, the DEIS potentially <br />V -17 <br />