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i <br /> i <br /> Jolm Funderburg, Principal Planner <br /> October 30, 2018 <br /> Page 2 <br /> I. The SDKIR Fails to Comply With CEQA. <br /> ' A. The SDEIR's Analysis of the Project's Water Quality Impacts rails to <br /> Satisfy the Requirements of CEQA. <br /> I. Groundwater <br /> CEQA requires that an EIR be detailed, complete, and reflect a good faith effort at <br /> full disclosure. The document should Provide a sufficient degree of analysis to inform the <br /> public about the proposed project's adverse environmental impacts and to allow <br /> dccisiunnmkers to snake inlelligent judgments. Id.Consistent with this requirement,the <br /> infnrmation regarding the project's impacts must be"painstakingly ferreted out" <br /> Ern�irom►�c�►rtul Planning and Information Comned of Ifrsiern El 60rado Coui►n>». <br /> Coamly of rl Dorodo(1982) 131 Cal. App. 3d 350, 357(finding an EIR for a general. plan <br /> =amendment inadequate where the document did not make.clear the effect on the physical <br /> environment). Here, the SDEIR acknowledges that the t'roject would have the potential <br /> Lo impact groundwater duality, but it fails to provide the facts or analysis needed to <br /> support the detenvination that that these impacts will not he significant, See SDEIR <br /> InIpact G-6 at IV.6-21. <br /> O As we explained in our letter on the prior Landoll Expansion Project,groundwater <br /> ' 1 is particularly vullcrable to contamination because"ground waters have little or no <br /> assimilative capacity, due to their slow migration rate, lacic of aeration, lower biological <br /> activity,tend laminar flaw patterns."See S1v W October 24, 2012 tetter on Forward <br /> Landfill Expansion Project DEIR(Baseline Environmental Consulting Rcport. <br /> rMuchnlent C, excerpt ftom The Water Quality Control Plan(Basin Plan)at IV-6.00), <br /> :attached as Exhibit A.1 According to the Baseline Consulting Report, any small amount <br /> ' �ifmsirnilative capacity in the vicinity of the Totward landfill has long been used up by <br /> historic and on-going releases of volatile organic cUmpvunds (VOCs), predominantly at <br /> the Austin Road Unit, but also at the Forward I_dnit, Exhibit A (Hmeline Consulting <br /> Iteport at R). Since groundwater in the area is already compromised due to years of <br /> contamination on the Project site(SDEIR at I V.(i-X), tolerance is very low for any <br /> additional degraclation, no mutter how incremental, f sere, the proper question is not the <br /> ' relative amount of contamination resulting from the Project, but whether any additional <br /> imot nt of contamination should be considered significant in light of existing conditions. <br /> Because the 2018 SDEIR does not resolve the myriad deficiencies of the 2012 Landfill <br /> Expansion Project DEIR, this firm's October 24, 2018 letter is hereby incorporated by <br /> reference into this letter. <br /> SIIUTE, MII-IALY <br /> TLINhL"RGt:Rr k <br /> i <br />