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July 18, 2006 Mr. Andres L. Soto Planning Manager City of Colton 659 N. La Cadena Drive Colton, CA 92324 lei*iV€LZO NML NIAL. SERVIUS . PI A1V'_i UNG . iNA URAL RESOD CLS M A<iA(x}IdarLE NrF Subject: Responses to Additional Comments on the Pacific Rail Project Dear Mr. Soto: We are in receipt of a copy of a letter prepared by ENVIRON dated July 12, 2006, regarding "Review of Responses to Comments for the Revised Draft Environmental Impact Report for the Proposed Pacific Rail Industries Metal Shredding Operation." The following are responses to the letter. 1.1 Cumulative Localized Criteria Pollutant Analysis (Response C-32) 1.1.1 Impacts from Other Projects within One Mile of the Facility The commenter asserts that annual modeling of diesel particulate matter (DPM) does not reflect shorter averaging periods (i.e, 1 -hour average). Response: Modeling the dispersion of DPM from other projects illustrated that the projects were located too far from the project site to detect the concentrations at the sensitive receptors. Other averaging periods may have somewhat different dispersion patterns, but the general assumption is that the concentrations will still not be detectible. The finding that the impact of cumulative localized criteria pollutants is not a significant impact does not rely upon the dispersion pattern of DPM alone. Table 2 on page 62 of the Response to Comments on the Revised Draft EIR shows the highest 8 -hour average ambient concentrations of carbon monoxide (CO) and the highest 1 -hour average concentrations of nitrogen dioxide (NO2) that occurred at the nearest monitoring station in 2005 when the list of other projects in the project area were built and operating. Therefore, the data presented in Table 2 shows the cumulative worst-case concentrations monitored in the project area that include the list of other projects. This data show that concentrations of pollutants in the project area are within the ambient air quality standards for those pollutants and that these concentrations have decreased from the highest 8 -hour and 1 -hour average concentrations documented in previous years. Table 3 on page 63 of the Response to Comments on the Revised Draft EIR shows a predicted cumulative localized 1 -hour CO, 8 -hour CO, and 1 -hour NO2 analysis at the project site using the Localized Significance Threshold (LST) Methodology published by SCAQMD. This table Bakersfield Irvine Palm Springs Sacramento Saar Bernardino San Ramon Santa Cruz 661.334.2755 714.5 }8.4100 760.322.8847 916.;383 0944 909.8841255 925.830.2733 831.262.1731 www.brandman.com mba@brandman.com Visalia 559.739.0400 f'