Letter to the Editor: Inconsistencies with the proposed asphalt plant planning documents
Here are some of the issues and inconsistencies regarding the proposed Portola Asphalt Plant and the April 2023 ‘Initial Study/Mitigated Negative Declaration’ (IS-MND) document:
- The IS-MND was both prepared and reviewed by the same Plumas County Senior Planner. The Planning Director should have reviewed this document.
- The Caltrans Route 70 project description estimates it will take 360 working days between May 2023 thru Nov 2025. That is an average of 120 days per year. The IS-MND states that the plant will operate 20 days and 40 days for Year 1 and Year 2 respectively. Where is Year 3 data?
- The IS-MND (pg. 6) states a maximum of 150 asphalt truck round-trips per day with an estimated 2000 truck trips in Year 1 and 4000 trips Year 2. Since the plant will operate 20 days and 40 days in Years 1 and 2, the maximum truck trips could be 3000 and 6000 truck trips for Years 1 and 2. This must be considered for traffic and air pollution mitigation calculations.
- The IS-MND (pg. 6) states that ‘water will be supplied by the local utility district’. Yet on page 53, the IS-MND states that water will be diverted from the Middle Fork Feather River. Which is it?
- The increased truck traffic from the plant to/from highway 70 equates to a truck entering/exiting every 4 minutes (150 trips per 10 hour day). Additionally, the access roadway crossing the above-grade railroad tracks limits visibility in both directions. These adverse conditions increase the chance of traffic accidents.
- The IS-MND (pg. 16) states that the Air Quality Technical Report is included in ‘Appendix B’, but it isn’t. I had to request a copy from the County Planning Department.
The report states that there would be a ‘maximum of 100 round truck trips per day’ for Year 1 and 2. Their air analysis was based on this figure of 100 truck trips that is inconsistent with the IS-MND’s 150 trips. This would lead to lower air pollution numbers. Therefore, the Air Quality Report is underestimating the air pollution impact. And where are the Year 3 numbers?
I am against the Portola Asphalt Plant for the following reasons:
- The IS-MND has many inconsistencies, not reviewed, lacks credibility, and lacks accuracy.
- Asphalt plants are notorious polluting enterprises. The plant is located right on the Feather River – a major clean water source for California. Toxic pollutants will be deposited in the river and the riparian areas.
- The air pollution from the plant and trucks will have detrimental impacts to Portola and surrounding area’s air quality and quality of life in general.
- Vehicle and truck accidents are more likely to occur.
Final thoughts: Where is the Year 3 data? And do you really think that this plant will cease operations after year 3? If nothing else, a full environmental impact report is warranted.
Special thanks to Feather River Action! for informing us about this project.
Mark Mihevc
Graeagle