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John hunderburg, Principal Planner October 30, 2018 Page 14 'The SDF1R's disclosure of nearly 40 accidents in a three-year periud on the ' roadways irnnhedibtely surrounding the landfill is disturbing. Despite the high number of accidenls, the SDEIR never underlakes the necessary next analytical step- a description of the factors associated with each of lice accidents. It does not identify the vehicles (bat ' were involved (c,g,. %ybether any of[lie accidents involved heavy-duty trucks and specifictrlly trucks ac:ceming the landlilI), the speeds that the vehicles were traveling prior to the collision(e.g., whether any of the vehicles exceeded posted speed limits); the ' nature of the accidents (e.g., whether the collisions involved left-hrrns,running red-lights, vehicles rear-ended):and the type of ii jiurics(c.g.,whether rninor,major or fatalities'). Nor does the SDEIR disclose how this number of accidents compares to the stale-wide average for similar arterial roadways. The revised El must provide this information. The SDFII? also Moes not analyze the proposed Project's potential to cause an 12 increa.w in accidents due to cars sharing high-speed, two-lane highways with heavy-duty ' (cont.) ovcks.3 instead, the document simply asserts that Austin Road does not appear to have the potential for a traffic collision hotshot. The only support it offers I'm this conclusion Is the assertion that even with the addition of Project traffic,Austin Redd would still be far ' below capacity. SDEIR at IV.13-16, Yet, in 2015, 2016, and 2017, nine vehicular collisions still oecun•ed on Austin Road even through the rotid was operating below its capacity.Clearly, there are abet factors that contributed to this high accident rate tluht ' most be considered. The Project would generate 800 round-trip tnrck nips(a substantial increase from ' the existing approximately 220 round-trip truck tripa daily average). SDEIR at IV.13-9. These heavy-duty trucks would travel along two-lane highways that appear to already experience elevated accident ,.ales The revised FIR must evaluate the Project's potential ' to increase the rate ref accidents on arra roadways and compare this projected accident route with the statewide average foi-similar arterials. Ir the PrQiect would rause an increase ' Although the SDUR does not provide any information about average vehicular speeds on Kingslcy Road, the other roads that have frequent accidents operate at very high ' speeds. The avcmgc travel speed along Austin Road, for example, is above 50 niph. SDEIR at IV,B-1_ The SDEIR does not identify die average travel speed along,Arch Road, instead, it identifies the posted speed limit as 45 mph. SDEIR at IV.B-3. The SDEIR also does not identify the average travel speed alum; Cast French Camp.Road, instead, it identifies the posted speed limit as 55 mph. SDEIR at 1V.B-3, The revised EER must identity the average travel speeds along the roadways used to access the landfill. SHt_11'l:, MIIiA0 1