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City of Ok �- Community Development Department 390 Towne Centre Dr.—Lathrop, CA 95330 Phone (209)941-7290—Fax(209)941-7268 www.ci.lathroP.ca.us November 1, 2012 San Joaquin County Planning Commission 1601 East Hazelton Avenue Stockton, CA 95205 Subject: City of Lathrop Comments on the San Joaquin County Environmental Impact Report No. PA-0900185 and Use Permit Application No. PA-0900184 for the Union Pacific Intermodal Facility Expansion and Modernization Project; south side of Roth Road; (SCH No. 2010082016). Dear Honorable Chairman and Commissioners; The City of Lathrop has reviewed the Environmental Impact Report (consisting of the Final and Draft EIR) for the Union Pacific (UP) Internodal Facility Expansion and Modernization Project in San Joaquin County, and wishes to continue to provide comments and raise concerns on the project EIR. The City of Lathrop supports this project; however, the project does need to appropriately mitigate its impacts upon our community. We continue to be most concerned with transportation impacts and will therefore, focus on this impact. The City of Lathrop has previously submitted formal written comments and concerns to the San Joaquin County Community Development Department on November 3, 2012, August 10, 2010 and September 15, 2009, which are contained in the subject EIR documents,but the project transportation impacts have not been adequately addressed or mitigated and continue to be a concern to the City of Lathrop. Our primary concerns are documented below: 1. We continue to have major concerns that the proposed expansion of project added trips from 930 daily trips after Phase One construction to approximately 3,062 daily trips at Full Build out, are not appropriately mitigated at the Interstate 5 /Roth Road interchange. And of the 3,062 daily trips, with 2,836 trips are by truck (92.6%) and only 226 trips are by passenger car (7.4%), the proposed project would further exacerbate significant and unavoidable impacts and unacceptable interchange operations. 2. The Mitigated Intersection Analysis beginning on F-858 of Appendix F, does not provide a complete picture of the project's transportation impacts along Roth Road. According to CEQA, in order to fully disclose the potential impacts of the project, the traffic analysis should include sufficient information to make a determination. And while the Synchro analysis used in the EIR provides both vehicle delay and queuing information, Page 1 of 4