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Letter to Attorney General Edmund G. Brown, Jr., continued

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Ronald Douglas Kennedy
otrkennedy@aol.com

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Letter to Attorney General Edmund G. Brown, Jr.
20 pp.; 728 Kb

PART 1:
Exhibits A & 1–12
395 pp.; 15,231 Kb

OR

Separate Files
from PART 1 above:

EXHIBIT A (8 pages, 266 Kb)
ATTORNEY GENERAL OPINION 93-1205, MAY 12, 1994
EXHIBIT 1 (165 pages, 4618 Kb)
IRVINE COAST DEVELOPMENT AGREEMENT 1988
EXHIBIT 2 (93 pages, 2352 Kb)
CERTIFIED LCP DEVELOPMENT PLAN, JANUARY 1982
EXHIBIT 3 (3 pages, 91 Kb)
I
RVINE COAST LCP DEVELOPMENT REQUEST, OCTOBER 28, 1987
EXHIBIT 4 (30 pages, 4908 Kb)
EXECUTIVE SUMMARY; ROAD PHOTO MAP AMENDED REQUEST, MARCH 1987
EXHIBIT 5A (5 pages, 146 Kb)
ORIGINAL GRANT DEED TO COUNTY OF ORANGE FOR LCP, AUGUST 22 1988
EXHIBIT 5B (4 pages, 158 Kb)
AMMENDED GRANT DEED GIVEN TO TCA FREE, MARCH 16, 1993
EXHIBIT 6 (4 pages, 124 Kb)
O.C. EMA TALKS ABOUT CERTIFIED LCP OF APRIL 20, 1988
EXHIBIT 7 (2 pages, 71 Kb)
ADDITIONAL OF SITE MITIGATION EMA REPORT OF CERTIFIED LCP OF 1987
EXHIBIT 8 (17 pages, 552 Kb)
CCC APPLICANT THE IRVINE COMPANY LCP ROAD PERMIT, DECEMBER 9, 1987
EXHIBIT 9 (2 pages, 51 Kb)
PELICAN HILL RD. REPORT, ROBERT BEIN & FROST, 1987
EXHIBIT 10 (9 pages, 189 Kb)
IRVINE COAST MASTER COASTAL DEVELOPMENT, FIRST AMENDMENT, 1989
EXHIBIT 11 (1 page, 33 Kb)
CHUCK DAMM LETTER, 1994; COPIED TO ME FROM RODENY LILYQUIST Esq., 1994
EXHIBIT 12 (6 pages, 195 Kb)
MEMORANDUM FROM CHUCK DAMM REGARDING LCP, DECEMBER 4, 1987
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PART 2:
Exhibit 13—Complete
(Chuck Damm to Coastal Commisioners,
November 19, 1987)
52 pp.; 1,720 Kb

PART 3:
Exhibits 14–36
207 pp.; 5,578 Kb

OR

Separate Files
from PART 3 above:

EXHIBIT 14 (5 pages, 149 Kb)
ASSEMBLYMAN FERGUSON ORIGINAL REQUEST FOR OPINION, DECEMBER 9, 1993
EXHIBIT 15 (1 page, 37 Kb)
A.G. OFFICER Ms. MAISER REQUEST FOR MY DEBATE DOCUMENTS, DECEMBER 8, 1993
EXHIBIT 16 (8 pages, 303 Kb)
JIM TOLEDANO Esq. OPINION; FAX OPINION REPLY, MAY 4, 1994
EXHIBIT 17 (2 pages, 48 Kb)
ASSEMBLYMAN FERGUSON CHANGED REQUEST FOR OPINION, MAY 10, 1994
EXHIBIT 18 (4 pages, 109 Kb)
APPLICANT FOR LCP, THE IRVINE COMPANY OPINION LETTER, APRIL 1, 1994
EXHIBIT 19 (2 pages, 56 Kb)
NEWPORT BEACH CITY MANAGER BOB WYNN OPINION LETTER
EXHIBIT 20 (6 pages, 137 Kb)
RON KENNEDY ROAD & BONDS SOLD OPINION LETTER, JANUARY 8, 1994
EXHIBIT 21 (1 page, 51 Kb)
DAILY PILOT FERGUSON URGES TOLL ROAD INVESTIGATION, DECEMBER 9, 1993
EXHIBIT 22 (1 page, 43 Kb)
DAILY PILOT CONICIALMAM SANSONE TOLD NOT TO MUDY THE WATER, FEBRUARY 26, 1993
EXHIBIT 23 (86 pages, 2287 Kb)
STEPHEN COONTZ ESQ. ORANGE COUNTY RESOLUTIONS, JULY 12, 1996
EXHIBIT 24 (4 pages, 119 Kb)
CCC MARK DEPLAINE FEDRAL CONSISTENCY LETTER TO TCA, FEBRUARY, 1991
EXHIBIT 25 (4 pages, 150 Kb)
TCA EIS FINANCED BY TOLLS, APRIL, 1992
EXHIBIT 26 (2 pages, 62 Kb)
FAST CORRIDOR FACTS TWO MAPS SHOW ROADS AS SEPERAT 7 1, 1990
EXHIBIT 27 (2 pages, 61 Kb)
FAST CORRIDOR FACTS; TWO MAPS SHOW ROADS AS SEPARATE, NOVEMBER 15, 1990
EXHIBIT 28 (8 pages, 288 Kb)
$1,078,692,411.05 TCA TOLL ROAD REVENUE BONDS, MARCH 4,1993
EXHIBIT 29 (16 pages, 424 Kb)
COURT OF APPEAL 4TH DISTRICT, SILLS P.J. JUDGE OPINION, OCT. 12, 1999
EXHIBIT 30 (28 pages, 662 Kb)
NOSSAMAN, GUTHNER, KNOX & ELLIOT, TCA LAWERS OPINION LETTER, MARCH 1994
EXHIBIT 31 (3 pages, 93 Kb)
ORANGE COUNTY COUNSEL OPINION LETTER, MARCH 24, 1994
EXHIBIT 32 (2 pages, 92 Kb)
DAILY PILOT OPENING OF NEWPORT COAST DRIVE, NOVEMBER 16, 1991
EXHIBIT 33 (4 pages, 106 Kb)
A.G. REPLY IN REQUEST OF TCA, LCP APPROVAL, AUGUST 22, 2007
EXHIBIT 34 (8 pages, 154 Kb)
A.G. REPLY IN REQUEST OF TCA; LCP APPROVAL, SEPTEMBER 5, 2007
EXHIBIT 35 (4 pages, 102 Kb)
TCA LAWERS TO WILLIAM WOOLLETT, CEO OF TCA, FEBRUARY 20, 1996
EXHIBIT 36 (5 pages, 119 Kb)
LETTER TO A.G. FOR EARLIER REVIEW OF OPINION, PLUS REPLY "DECLINE"-"NO BASIS UPON WHICH TO REVISIT THE QUESTIONS,'' MAY 10, 2000.
-

Attorney General Reply
plus Additional Letters
coming soon!

page 15. Recreational Access Function." The construction of Pelican Hill Road will provide significant recreational access benefits for inland residents by providing a new access rout from inland residential area to Crystal Cove State Park."--

"the 1987 LCP circulation improvements provided significant relief to the most congested links of the adjacent arterial system ( primarily Pacific Coast Highway and MacArthur Blvd.)"--

" In addition to relieving traffic on Pacific Coast Highway during peak commute hours, the construction of Pelican Hills Road in particular will provide significant recreational access capacity by connecting inland areas directly to Crystal Cove State Park (see EXHIBIT 13 in the EXECUTIVE SUMMARY)"--

" in this way, the construction of Pelican Hill Road not only meets the requirements of Coastal Act Section 30250 but also furthers the policy concerns of Coastal Act Section 30254 both by creating new recreational access capacity directly and by freeing up additional recreation access capacity on Pacific Coast Highway through the inland diversion effect."

This Coastal Commission Staff Report page 1 also calls out Substantive File Documents: # 4 Pelican Hill Road Project Report, prepared by: Robert Bein, William Frost & Associates February, 1987


[ Exhibit 9 ] Pelican Hill Road Project report Robert Bein, William Frost & Associates Febuary, 1987.

page 24. Highway Design Criteria " Segment 2- Alternate A and Segment 3 extend along Bonita Canyon Drive from MacArthur Boulevard to the location of a possible future interchange between the San Joaquin Hills Transportation Corridor and Pelican Hill Road. This portion has been specifically designed to be compatible with the criteria established for the San Joaquin Hills Transportation Corridor, since it is possible that portion of pelican Hill Road project may ultimately be incorporated into the Transportation Corridor. Design criteria for the San Joaquin Hills Transportation Corridor meet the standards established by the California Department of Transportation (Caltrans) for an urban Freeway," ( at this time a free public road is planed only rk)


[ Exhibit 10 ] "The Irvine Coast Planed Community. Master Coastal Development First Amendment."

September 1989. County of Orange. Environmental Management Agency. Land Planning. Coastal Planing Section.

Page 1V-1 " A hierarchy of roadways will ultimately serve The Irvine Coast, including regional freeways and highway networks, subregional arterial highway networks,"

Page 1V- 3 " The construction of Pelican Hill Road is governed by a Coastal Development Permit which has been approved by the County and Coastal Commission with separate environmental documentation. 1 "

Page 1V-22 " Conceptual Roadway Phasing " -" The Irvine Coast LCP addresses the phasing of major infrastructure," - " early completion of Pelican Hill Road to Mac Arthur Boulevard."


[ Exhibit 11 ] California Coastal Commission February 3, 1994. Damm letter copied to me by the Attorneys General Office, Rodney Lilyquist Esq. on June 8, 1998 mailed me a copy of a letter ( hand written note a top "Ron I belive this is the letter we relied upon for foot note 7. Rod".) dated February 3, 1994 from Charles Damm district director California Coastal Commission, to Mr. Benjamin Nolan Public Works Director, city of Newport beach. Mr. Damm states " As I mentioned in our October 1st letter the portion of Newport Coast Drive wear a toll is proposed is not in the coastal zone. As such, we cannot assert jurisdiction based on the toll issue with out a direct tie to the adopted provisions of either the Irvine Coast LCP and/or the Coastal development permit. Our research shows no such tie." Continued...

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