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July 5, 2006 Mr. Chandler Martin, Associate Planner — Page 4 TRAFFIC The Traffic Comment highlights the DEIR's transportation and circulation analysis major error _ in relying on obsolete and questionable traffic data. DEIR relies upon baseline information that appears to be as much as four years old, based on traffic counts that date back to the post- September 11, 2001 recession. As Smith points out, this analysis should be corrected with 2006 information, which is highly likely to demonstrate that the Project will have greater impacts on traffic than are disclosed by the DEIR. Also, like Fox and Pless, Smith notes the failure of the DEIR to consider the cumulative impact that would result if both the Project and the pending expansion proposal for West Coast A-3 Aggregates' Valley Rock quarry are approved. This also demonstrates a failure to disclose. Further, the questions raised by Fox and Pless regarding the actual production levels that might be permitted under the DEIR (see Air Quality Report, Comment IV) apply with equal force to the traffic analysis. To the extent that the DEIR's traffic analysis is based on production levels that may be greatly exceeded under the approval being sought, the traffic _ analysis fails to disclose the likely impacts of the Project. As with the air quality section, the transportation and circulation section of the DEIR requires significant revisions to provide adequate disclosure under CEQA. Conclusion The Project will have numerous highly significant impacts that are not adequately disclosed, analyzed, or mitigated in the DEIR. Based on the severity of the DEIR's errors and omissions, the DEIR should be supplemented to address the issues identified above and re-circulated to allow for public review. Without these revisions, the DEIR is inadequate under CEQA and should be relied upon by the Planning Commission for approval of the Project. Aa The residents will have little opportunity for recourse once this permit and its conditions of approval are approved. Accordingly, the Planning Commission must carefully analyze all proposed mitigation measures and make them part of the permit's conditions of approval before approving this Project. Thank you for considering our comments. Sincerely, A — Theodore Franklin TF/x Enclosures — 1131801426524