You are putting the cart before the horse. Air quality is mandated by law. Transportation plans must conform to air quality requirements, not vice versa. You quote the federal Clean Air Act as including highways among indirect sources, and hence coming under the purview of indirect source controls. Please elaborate on this.
Guidance is needed here.
The AB471 discussion is irrelevant, if it isn't funded yet, particularly since its overwhelming emphasis is on highway expansion . These are inappropriate. Only trip and VMT reduction should be used, as these are the most directly related to emissions. The bibliography is incomplete without the only research on the environmental effects of freeway expansion, that of Professor Jeff Kenworthy and his associates. Thank you for the opportunity to comment on this important document, which can significantly affect the success of the Clean Air Act.