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lower gate movements at the UP driveway relative to October 17`s". Without sufficient <br /> documentation to substantiate these adjustments, these unilateral adjustments and <br /> egregious errors appear to underestimate the true truck and passenger car impacts to this <br /> important interchange. <br /> 5. Based on the above major factors, we continue to maintain that the DEIR should <br /> acknowledge and incorporate payment of the fees identified in the NLTIF program which <br /> was adopted by the City Council on October 18, 2010. The NLTIF underlying objective <br /> analysis was based on sound engineering practices and allocated the true cost of the I-5 / <br /> Roth Road interchange across all new users. The NLTIF program estimated that the <br /> impact fee attributable to the UPRR Intermodal Facility should be approximately $5.5 <br /> million. It appears that the value of the improvements offered in the Final EIR amount to <br /> approximately $235,000, plus possible $1,279,000 if TRANS-9 and TRANS-10 are <br /> constructed by the project proponent. This would leave $4.2 and 5.3 million in <br /> improvements unfunded if the County chooses not to assess this fee, and could seriously <br /> delay or prohibit full construction of the 1-5/Roth Road interchange improvements. <br /> The City of Lathrop continues to support this project; however, our goal is to ensure the <br /> viability and success of not only the UPRR Intermodal Facility, but all projects in the <br /> City of Lathrop, City of Manteca, and San Joaquin County that rely on the I-5 / Roth <br /> Road interchange. Therefore, we recommend that a condition of approval of the UPRR <br /> Intermodal Facility Use Permit is to resolve the Significant and Unavoidable impacts and <br /> Mitigation Measures Trans-8, Trans-9, Trans-10, Trans-15, Trans-16, and Trans-17 by <br /> working cooperatively with the City of Lathrop, SJCOG, and Caltrans to ensure the <br /> viability of the entire area served by the I-5/Roth Road interchange. <br /> We appreciate being provided with the opportunity to comment on the Union Pacific Intermodal <br /> Facility Expansion and Modernization Project and look forward to working with San Joaquin <br /> County Community Development Department on adequately mitigating the impacts of this <br /> project. If you have any questions please call me directly at (209) 941-7298 or email me at <br /> cmullen@ci.lathrop.ca.us. <br /> Sincerely, <br /> Charlie Mullen <br /> Principal Planner <br /> Page 3 of 4 <br />