Laserfiche WebLink
"Impacts from this analysis may be considered underestimated (i.e., other <br />reasonable assumptions or methods may show higher concentrations) due to a <br />number of factors. These factors include: <br />The modeling did not include any background (i. e., local) traffic. counts, but only <br />the two levels of GCC" traffic provided in the Roadrunner TIA. Concentrations will <br />increase with additional background counts. <br />Average traffic levels were assumed to occur daily throughout the year. On days <br />with higher than average traffic, model results may show increased <br />concentrations. <br />While we might propose to use the adjust u* model option (described later in the <br />report) if performing regulatory modeling for an industrial client, there is no <br />guarantee that this option would be approved by the regulating agency. The <br />adjust u* option generally predicts lower concentrations, and was a model <br />senting included in this analysis." Report at 2. <br />SIGNIFICANCE OF THESE FINDINGS <br />The public health consequences of these findings are set out fairly dearly in the EPA <br />publications provided by Mr. Garman. <br />We are sure that responsible County (and company) officials will take these findings very <br />seriously and act promptly to address them by, at a minimurn: <br />Conducting such further and additional testing as is necessary to ensure that the <br />problem is fully understood and the health of local residents protected; <br />a In the long run, to identify alternatives to the current pattern of truck transport of coal <br />on CR 120; <br />41 In the short run, to restrict the truck traffic on CR 120 to a level that is demonstrably <br />safe. We hope to evaluate, for example, whether the level of truck traffic in existence on <br />August 5, 2015 would —with adequate controls and mitigation measures — reduce PM10 <br />to a level where the NAAQS would not be violated. <br />We very much hope that the County will take this information on board and consider it <br />seriously in your decision process. We would request that this formally be made part of the <br />record in this land use proceeding. <br />