Transportation and Traffic

The DEIR makes no serious attempt to determine the number of daily truck trips in 1982, and merely adopts what is effectively a guesstimate by the same County Planning Department employee mentioned before. Evidence in the form of court testimony suggests that this employee greatly understated the percentage of Quarry material shipped by barge, with the result being that the percentage shipped by truck is overstated.

The final EIR should address this issue, and come to a far more supportable basis for estimating 1982 truck trips for the purpose of establishing an EIR baseline.

Regarding baseline production levels, which directly impact baseline truck trips, the DEIR arrives at a 1982 estimated production average by averaging 1980 through 1982 production levels. However, failing to include 1979’s production figures in the calculation results in a 15% higher average. There is no good reason to ignore 1979.

A full review of the Merrill report (discussed in the Baseline Determination section), relevant court testimony, and a reasonable application of this informatio, would support truck traffic levels of only about half the 120 truck trips that the DEIR assumes is the baseline.