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John Funderburg, Principal Planner ' October 30, 2019 Page 15 12 in accidenl rate, the. ETR must ev=aluate mitigation measures capable of reducing tbesc (cont.) I lll1pflCL1. Adequately Consider Newcasllt' 14nad as an ' 2. The SidEIR Falls to Adeq y Access to the Landfill. 7lle SDEIR evaluates Newcastle Road as an alternative to the existing entrance on ' Austin Road but relies on faulty reasoning for its rejection of this alternative. First,the document suggests that access from Newcastle Road would be infeasible because the ' pavement on the:roadway is weathered and cracked. SDEIR at IV.13-14. The SDEIR asserts that the use of Newcastle Road for landfill access would substantially increase truck ti-affic on that road, whiell would shorten the pavement life considerably. Id. This ' excuse is unavailing. In our letter on the 2012 DEIR, we explicitly requested that the County analyze thin impact that Forward's truck traffic would have on pavement condition. We explained that tyle Project's increase in heavy-duty trucks would cause a ' deterioration in road pavement condition:which would adversely impact the agricultural industry as it uses these same roads fear farm-to-market trims. See Exhibit A at 42,43 (October 24, 2012 letter).The 2012 FEIR dismissed this potential impact,asserting deet ' Forward pays a fee to the County to pay for pavement maintenance. ,See FEiR, Response L44. Clearly, Forward could pay to have Newcastle Road repaved to withstand die landfill's heavy-duty truck traffic and also pay for on-going pavement maintenance. ' 13 Moreover,using Newcastle Road as an alternative access road would likely reduce the amount of pavernent fees as the trip distance froth Nigh%ti.,ay 99 to Newcastle Road is shorter than the distance from Highway 99 to the Austin Road entrance.See SDEiR at Figlrre I 11.C-1. ' The SDEiR's second reason for not using Newcastle as the landfill's main access road is particularly disingenuous. The document states that it would require construction ' of a creek crossing,which could have adverse environmental impacts to the streambed. SDEIR at IV.B-14.Forward has already demonstrated that it has little regard for Littlejohns Creek. As part of a prior project,Forward relocated the North Fork of the ' creek,and the current project calls for the relocation of the Soutli Branch of the South Fork of the creek. SDEIR at 1-1 and Figure II1.0-3. Moreover,the currently proposed creek relocation calls for a bridge crossing. DFIR at 111-7. Clearly, the fact that a creek ' crossing would be required to relocate the landfill's innin entrance to Newcastle Road is not an insurmountable obstncle. Given the high accident tate on Austin Road and [lie fact that[lie main entrhnce to ' the California Health Care Facility Mi on Austin Road near tic landfill, the revised EIR should reconsider providing access to the landfill via Newcastle Road. SHLITI=, MlllAIY ' NXILINBLRGL• R�,r I