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Mr, Kevin Swanson August 16, 2011 1'age 4 greater than daytime peak hour levels, is not evaluated in the DEIR. Other flaws in the analysisI 1-12 are as follows: Cont. (a) The DEIR states the anticipated trip generation (from Figure 2-3) for extended operating hours on page 3.2-8, but fails to explain whether(a)these are maximum hourly trips,(b)how they were derived, and(c) if they do represent maximum hourly trips, how these supposed "maximum" limits will be enforced. Now is the number of 1-13 trips between 9.00-10:00 p.m. magically reduced (from 66 one way trips during that .. hour)by more than half(to 26 one way trips per hour)between 10:00 p.m. and 5:00 a.m.? Since each night paving contract is different,how can anyone be assured that most of the trucks will be running during the first hour? (b) Moreover, there is no discussion in the DEIR as to increased traffic safety risks associated with night operations. When the parcel to the northeast was approved by the County for sand production, traffic safety was such a concern that an underground 1-14 conveyor was required. The DEIR should include an analysis of the increased traffic safety risks associated with very slow, loaded trucks operating on a winding, rural road in nearly total darkness. Air Ouality Impacts are Inade uatel Evaluated. As with traffic and noise impacts, the DEIR wrongly assumes that extended operations are not really "extended", in that maximum daily limits will not be exceeded. First, there is no assurance that this is the case. Second, and 1-15 more importantly, there is no evidence that public works projects which require night operations are merely replacing an equivalent number of existing, daytime jobs. In truth, allowing extended operating hours at night will greatly increase impacts, and these impacts are never evaluated in the DEIR. In terms of odor impacts, according to Impact 3.3.1,dispersion modeling was conducted at "the nearest known residential receptors". The DEIR fails to disclose the location of these receptors, leaving the public in the dark. Many of my clients have complained about the 1-16 overwhelming odors associated with asphalt plant operations; indeed, the DEIR admits (a) that the plant does not meet minimum required buffer distances from known receptors, and(b) that the significant odor impacts of the project cannot be mitigated. Moreover, other than a general reference to the possible use of undisclosed"additives"(Mitigation Measure 3.3.1),there is no serious attempt in the DEIR to identify or address odor mitigation measures. Finally,the process by which rubberized asphalt is produced has never been explained or evaluated in any environmental document for this project. I have attached a color photograph which was recently taken during a time when rubberized asphalt was being produced. The "smoke" coming out of 1-17 the orange smokestack is steam; however the smoke coming out above two grey storage tanks is burning rubber smoke which causes the odor and irritation problems. In the evening, when there is little air movement and an inversion layer, this smoke does not disperse, leaving residents to deal with smoke and odors. The DEIR should evaluate and propose meaningful mitigation for these impacts. Noise Impacts are Inadequately Evaluated and Mitiltated. Prior to the preparation of 1-18 the DEIR, the County and the Applicant, ignoring years of noise, odor and land use complaints, proposed to adopt a Negative Declaration for this application. My clients commissioned a peer