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STATE OF CALIFORNIA Edmund G.Brown Jr., Governor PUBLIC UTILITIES COMMISSION Sas VAN NESS AVENUE SAN FRANCISCO,CA 84102J286 �'~• � �b 5. November 30,2011 John Funderburg Principal Planner San Joaquin County 1810 E.Hazelton Ave. Stockton,CA 95205 Re: Notice of Completion,Final Environmental Impact Report(FEIR) Munn&Perkins Quarry Excavation Permit SCH#2005082001 Dear Mr. Funderburg: As the state agency responsible for rail safety within California,the California Public Utilities Commission(CPUC or Commission)requests this letter be entered into the administrative record for this project at the 12/01/11 scheduled San Joaquin County Planning Commission meeting. Section 3.2 of the Transportation and Traffic section of the FEIR fails to evaluate traffic safety issues at several at-grade railroad crossings in the City of Escalon and City of Riverbank which are along the proposed haul routes for nighttime operations by the Quarry trucks to and from the project site(reference FEIR figure 2-3). The traffic analysis isfatallyflawed since it does not provide any traffic analysis for the existing project conditions,project plus approved and build-out scenario for each local jurisdiction(Cities and County). Without this critical traffic analysis to the at-grade railroad crossings,the level of significance can not be determined regardless of the fact that there are no additional trips by the project and the only change is the expanding operating hours for the Quarry. This is in conflict with section 3.2.2 Significance Criteria,based on CEQA guidelines Appendix G; a project would cause a significant impact on transportation and traffic if it would: "d. substantially increases hazards due to design feature(e.g.,sharp curves or dangerous intersections)or incompatible uses (e.g.,farm equipment)." Since the last approved Quarry Excavation Permit was adopted for the site in 1989 and extended by the County on 3/04/99 for a period of 30 years(2029). The traffic AADT and peak hour volumes have increased on local roadways and highways which include at-grade railroad crossings. This is considered new and significant information according to CEQA and would confirm the inadequacy of the traffic analysis without inclusion of the at-grade railroad crossings. Measures to reduce adverse impacts to rail safety need to be considered in the FEIR mitigation monitoring section.