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San Joaquin County Board of Supervisors April 10,2017 Page 4 Input from non-experts,lay testimony,can be substantial evidence when such testimony is credible and does not purport to embody analysis that would require special training. Thus,"statements of area residents who are not environmental experts may qualify as substantial evidence if they are based on relevant person observations or involve `nontechnical issues." (Bowman v. City of Berkeley(2004) 122 Cal.App.4`h 572, 583 (aesthetics); Ocean View Estates Homeowners Association,Inc.v.Montecito Water District(2004) 116 Cal.App.e 396,402 (aesthetics);Mejia v. City of Los Angeles(2005) 130 Cal.App.4te 322(traffic and biology); The Pocket Protectors v. City of Sacramento (2004) 124 Cal App.4"'903,932(land use); Oro Fino Gold Mining Corp v. County of El Dorado (1990)225 Cal.App.3d 872,882(noise); Citizens Association for Sensible Development of Bishop Area v.County of Inyo(1985) 172 Ca1.App.3d 151, 172(traffic).) In the present matter,nearby residents,including Mr.Reedy,have submitted testimony and comments that the increased truck traffic on the narrow 2-lane road will result in significant impacts to traffic and traffic safety. The Project will result in one truck every 3 to 4 minutes that will further degrade the road. The nearby residents' comments are based upon personal knowledge of the current traffic conditions and road conditions. Based upon that personal knowledge the residents are able to comment on the Project's impacts to the traffic and traffic safety. That personal knowledge constitutes substantial evidence supporting a fair argument requiring preparation of an EIR. Additionally,testimony/comments from qualified traffic engineers constitutes substantial evidence that supports a fair argument. (Pub.Resources Code § 21080(e)(1); see also CEQA Guidelines § 15384(b) (Substantial evidence consists of"fact,a reasonable assumption predicated upon fact,or expert opinion supported by fact.") In the present matter,the attached letter from Dan Smith,Smith Engineering&Management, demonstrates that the Project would have potentially significant traffic safety impacts that the IS/MND fails to disclose or mitigate. Mr.Smith opined that: This document states that a road width of 20 feet is considered adequate j only for low-volume roads where meetings and passings are infrequent and truck volume is low. If there really are only 58 trucks per day entering and then,after weighing and unloading,leaving the facility and they are spaced out evenly over the full 12 hours of operation,there will be 12.41 minutes between trucks entering the facility. Given the time it takes to drive the length of Frewert and go through the unloading protocol,there is a high probability that every truck entering the facility will encounter a truck leaving the facility somewhere on Frewert. The facts that truck approaches will be random rather than evenly spaced and that truck traffic will likely be more concentrated in some hours of the day than others make truck meetings even more probable. And the fact that truck trips associated with export of the finished compost may not have been accounted for makes truck meetings yet more likely.Hence,not even considering any other traffic on the road,this simply does not constitute a situation where . ^ 3s