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Mr. Kevin Swanson <br /> August 16, 2011 <br /> Page 6 <br /> processing facilities and asphalt plants, which currently supply raw material to the Munn and <br /> Perkins plant_ As the DEIR admits, this raw material is trucked in for processing; if that same <br /> material could be processedat the site where it is produced, significant air emissions reductions <br /> could be achieved, and overall trucking tniles reduced. Similarly,if the asphalt plant could be <br /> located where the raw material is excavated and processed--i.e., a fully integrated facility--, even <br /> more efficiencies and environmental benefits could be realized. The DEIR makes no attempt to 1-19 <br /> evaluate this alternative. Moreover, the DEIR improperly evaluates the Marysville,Table Cont. <br /> Mountain and Clements sites in terms of their proximity to the existing Munn and Perkins .:: <br /> facility---as if that were the locus of all construction activity—rather than in relation to the <br /> potential market for night construction jobs. The DEIR does not disclose whether the two <br /> significant and unavoidable effects of the current proposal (nearby residents waking 100%of the <br /> time, and odor impacts)would occur at the Marysville,Table Mountain and Clements sites, or at <br /> any other site owned or controlled by the applicant. <br /> The DEIR lists, but fails to adequately evaluate,two alternatives the so-called"West Only'' <br /> and "East Only" haul route alternatives. Each makes the puzzling statement that while some <br /> neighbors along the haul route would experience less noise, others could experience an increase 1-20 <br /> in the number of nights with extended operating hours. This makes no sense; there should be the <br /> sarne number of nights, but more of the inbound and outbound trucks would be routed along the <br /> revised haul route_ In any event, there is no attempt to meaningfully evaluate any of the <br /> alternatives. As a result, the DEIR is flawed. <br /> CONCLUSION <br /> The applicant was compelled to prepare an EIR for this project, and for good reason. Yet <br /> the resulting Draft EIR is wholly inadequate, and represents little more than a token effort to <br /> comply with CEQA.'s substantive mandate. The neighborhood has put up with the noise, dust <br /> and odors from plant operations and truck traffic during the daytime hours for more than 50 <br /> years. CEQA demands, and the neighbors deserve, an accurate and robust environmental 1-21 <br /> review. <br /> Very truly yours, <br /> Law Office of Thomas H. Terpstra <br /> Thomas H. Terpstra <br /> Attorney-at-Law <br /> THT:rr <br />