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:

  1. The IS-MND was both prepared and reviewed by the same Plumas County Senior Planner. The Planning Director should have reviewed this document.
  2. 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?
  3. 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.
  4. 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?
  5. 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.
  6. 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:

  1. The IS-MND has many inconsistencies, not reviewed, lacks credibility, and lacks accuracy.
  2. 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.
  3. 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.
  4. 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.

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Special thanks to Feather River Action! for informing us about this project.

Mark Mihevc

Graeagle