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Mr. Don Mooney March 29, 2017 Page 2 street is increased from 9 hours per day to 12 hours per day (6 AM to 6 PM proposed; 7 AM to 4 PM currently) and the days per week the trucks operate is increased from 6 to 7 days per week. Truck Totals Cited in the IS/MND and the Staff Report Don't Make Sense The existing composting operation is said to be permitted to import 156,000 tons of raw materials per year and for 50 trucks per day. If the plant operates 6 days per week, 52 weeks per year, it will require 50 import loads per day on 10-ton capacity trucks to process the total of 156,000 tons. But that really means that there will be 50 empty trucks leaving the facility so the importation of raw material in the existing operation really results in 100 truck trips per day on Frewert Road, almost all on the segment between the compost facility and Manthey Road. But this does not yet count the truck trips associated with export of the product (the finished compost) -that factor has never been defined. The applicant now requests use permit to import 182,500 tons of raw materials per year, for 115 trucks per day and to operate 7 days per week. If the plant were to operate 365 days per year, it would require 50 import loads per day using 10-ton trucks and would involve 50 empty trucks per day departing. So what is behind the 115 truck trips per day total. Does it mean the applicant is now counting both the inbound and outbound trip of raw material import trucks and is adding a few more trips a day for export of finished product? Or does it mean that the applicant is recognizing that the plant will really not operate 365 days per year or may operate a limited shift on Sundays so it needs to bring in a few more loads on the other days to reach the annual tonnage? Actually operating only 6 days per week, the facility would require 58 inbound loads in 10-ton trucks to meet the proposed 182,500 ton annual limit so the number 115 looks close to counting both 58 inbound loads and 58 empty departures (total 116). But if that is true, what accounts for the truck trips that remove the product? These things must be explained and have not been addressed adequately. The Issues Have Not Been Addressed Adequately In the Context of the Condition of the Project's Primary Access Roadway Frewert Road extends from Manthey Road 1.25 miles east of the Project site and terminates at the Haven Acres River Club .67 miles west of the Project site. Because the segment of Frewert west of the project terminates nearby without connecting to other roads and services only fronting properties, virtually all of the traffic accessing or departing the Project will be on the section connecting to Manthey. Frewert Road is used as a two-way road. The traveled way on Frewert is generally 20 feet in width and has marked centerline and edge lines and open drainage. A few inches of pavement exist at most locations outside the edge lines but the rest of the shoulder area within the 40 foot right of way is roughly level but generally unimproved. There are no sidewalks. Because there rRsrr1C • 'rk.\N;110 VrA 'ION • A1ANAGLINILN r i311 Lown-Road. Union Citc,CA 94587 tel:510.=189.9477 las:510.4899478