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intersection level of service was the only criteria used for determining project impacts and mitigation. Due to the limited spacing between the Roth Road intersections and number of truck trips, vehicle queuing should also be used in making the determination of the operational benefits of the proposed isolated improvements. In addition, the lack of Synchro queuing information in Section 4.2 Transportation and Traffic was also commented on by the City of Manteca and Caltrans District 10. Based on this critical issue about the adequacy of the technical analysis, Table 3 of the DEIR Appendix F.12 was prepared and identified the queuing impacts at the Roth Road at-grade crossing. The FEIR states that "the estimated queues would extend 4,750 feet, and only 720 feet short of the I-5 / Roth Road interchange". If this type of analysis was completed for the closely spaced I-5 Roth Road intersections, the planning level sketches provided in Appendix E would not mitigate project impacts or restore acceptable level of service conditions. 3. In both Appendix D and Appendix E, the FEIR states that "the actual fair share costs for identified mitigations will be contingent upon detailed engineering cost assessment during the implementation process" and "these estimates are intended for general planning purposes only, and as such, are subject to change based on final engineering design'. Therefore, we have provided for the record and incorporated into the North Lathrop Transportation Impact Fee (NLT1F) program our recent experience working in cooperation with the California Department of Transportation (Caltrans District 10 — Stockton) on the I-5 / Louise Avenue and I-5 / Lathrop Road interchanges to define the required improvements. The projected cost of $28.5 million is also based on PS&E design costs associated with the tight diamond (east side) and Type L-9 (west side) interchange at 1-5 /Louise Avenue. One key element of the interchange design is the need to relocate the intersection of Harlan Road / Roth Road when it is signalized. This specific topic was discussed at the meeting on March 28, 2012, and is based on existing signalized intersections at Lathrop Road / Harlan Road and Louise Avenue / Harlan Road. It should be noted that at both locations, the City of Lathrop was required to relocate the intersection farther east due to its proximity to the northbound off-ramps to Interstate 5 before they could be signalized. Therefore, the significant and unavoidable Trans-10 impact cannot be mitigated by the installation of a traffic signal at its current location. 4. The trip snaking characteristics of the UPRR Project continues to be a major area of concern in terms of its impact to the I-5 / Roth Road interchange. This includes data in Table 1 and Table 2 of the DEIR Appendix F.2 stating "adjusting volumes downward from traffic counts to reflect average truck volumes" for Existing Conditions and changing the DEIR statement "Based on weekly comparison of UP Gate movements between 12/1/2009 and 12/1/2010, 38 out of 52 weeks (or 73 percent) recorder higher Page 2 of 4