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Mr. Kevin Swanson August 16, 2011 Page 3 c) Inexplicably, the Project Description fails to disclose the number, location and proximity of offsite rural residences. Figure 2-2, according to Section 2.5, is supposed to depict neighboring residences. It does not. The most important issue relating to extended night operations is its impact on neighboring residents. Indeed, it 1-7 was the potential for land use conflicts, coupled with expert testimony as to noise impacts, which drove the need for an EIR for this project in the first place. Given that, failing to include the number, location and proximity of offsite rural residences renders the DEIR inadequate as an informational document. d) The Project Description is accurate in one important respect; namely,the fact that the Munn and Perkins project is no longer an actual quarry excavation, but rather, a mere assembly plant where offsite raw aggregate material is trucked in, processed, crushed and manufactured into products including asphalt. Rather than moving the processing facilities and asphalt plant, which would require costly air emissions upgrades,Munn and Perkins continues the wasteful and inefficient practice of importing offsite raw 1-$ materials,thereby doubling(at least)the number of trucks, vehicle miles and emissions to which their neighbors are now subjected. Thus, from a policy and environmental standpoint,the standard industry maxim that quarry excavations and processing facilities must be located where"Mother Nature"put the material is utterly inapplicable. The DEIR should evaluate the additional impacts associated with importing increasing amounts of material for night operations. e) The Project Objectives are impermissibly narrow, in an obvious attempt to limit the I 1-9 DEIR's subsequent discussion of mitigation measures and project alternatives. f) There is no mitigation measure or proposed condition of approval to ensure that the ! 1-10 maximum permitted air pollution limits identified on page 2-2 are not exceeded. I g) On page 2-6 of the DEIR,the author makes a generic reference to the fact that the County Public Works Department has requested additional lighting for nighttime traffic safety. There is no diagram, schematic or discussion of the nature, intensity or location of this additional lighting. Chapter 3.1 merely references the County 1-11 Development Title, but contains no further analysis. The DEIR should include this information in sufficient detail to assure the public that the lighting will be effective and won't result in additional environmental effects to neighboring properties. Traffic:Impacts are Inadequately Evaluated. The environmental "baseline" is represented by the existing maximum traffic which can be generated during existing approved operating hours. This is, incidentally, acknowledged in Munn and Perkins' March 2, 1999 letter to the undersigned, in which Project Coordinator Carol Vierra stated: "The plant design limits 1-12 operations and allow a maximum hourly production. Once capacity is met,we simply cannot produce anymore." Ms. Vierra was correct on that point. But if the County now allows that same maximum hourly production to occur during both daytime and nighttime hours, the cumulative traffic is increased dramatically. This increase in traffic, which may or may not be