Standard&Poor's Ratings Services affirmed its 'BBB-' rating and underlying rating (SPUR), with a stable outlook, on the Foothill/Eastern Transportation Corridor Agency (F/ETCA), Calif.'s toll road revenue bonds. In our opinion, specific credit concerns include: High debt levels and a debt service schedule increasing by a 4.4% average annual rate through 2040; Recent negative operational performance, with traffic down 5.7% in fiscal 2010 and down 0.7% through April 2011 from a year earlier; and Uncertainty regarding the Foothill South toll road extension project, delayed after recent regulatory decisions, which may require substantial additional debt. We believe these concerns are partially mitigated by a service area with high wealth levels, high traffic on free highways, and a population that is