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I I John Funderburg, Prineilml Planner October 30, 2018 Page y Becatt&e. the SDEIR provides no mechanism for ensuring that Forward would comply with these voluntary procedures and because the document provides uo assurdnce that (he ' ® proeeditres would be efi'ective even if they were irrrplcnrented, the SDEIR lacks the (cont.) evidentiary basis to conclude that litter-relale;d conrautination impacts would be less than ,iSmifteant. I C. The SDEIR Provides Insufficient Information Regarding the Proposed ' teeldon . Project"s impact on Airport. S I ' Municipal solid waste landiilis are known to attract large numbers of Iha7mdou5 wildlife, particularly birds. It is therefore likely that birds,attracted by refuse in the new ' landfill cells, would move into or across the approach or departure airspace for Stockton Airport. IAA Advisory Circular 15015200-3313 Hazardous Wildlife Attrarlants Uri or Near Airports(Advisory Circular), The Advisory Circular iWommends a separation distance of 10,000 feet between wildlife attractants and the airport operations arca.' SDEIR at IV.A-21. The SDEIR asserts that both proposed landfill expunsiun areas are more than 10,000 feet From the end of the riedrest runway and anliort operations arta. Id. However,there is insufficient support for this assertion. Figure I II.0-5 identifies the ' 10,0004001 separation distance as an approxituation. Indeed, the scale of Figure III.0-5 shows that (lie new refuse location. which would place refuse at an elevation of 180-feet 09 in the southern area of the landfill, could be_just 300 feet from the 1 0,O00-four separation ' drslance and in direct f!ighl path of approaching aircraft, while the new refuse location in the northern section of the landfill would be even closer. The SDEIR also relies on the San Joaquin Council of Governments' (acting as the ' Airport Land Use Commission) letter on the Notice of Preparation as Support for the Project's consistency with the Airport Land Use Pian. But this letter merely states that "Forward, Inc,'s plans appear to be t-onsistenl with FAA Advisory Circular 15015200- ' 3313. Specifically, all expansions of landfill operations are located snore than 10,000 feet from the AOA," See June 14, 2018 Letter from T. Yokoyarna to J. FunderbUrg at 2 (emphasis added),included as an appendix to the SDEIR. Given the vagueness of SDEIR ' Figure III.0-5 and the ALUC's state-meat, and the Project's potential to increase bird )hazards at the:Aiq)urt, it is imps ni ive that the geographical extent of the 10,0013-foot separation distance be precisely measured. ' s '1'1rc AOA is detincd as any area of the airport used or intarded to be used for landing,take-off, or maneuvering of aircraft. SDEIR at N.A-21. S1IUIL" MIII,ALY WI_INf4ERC�1-Rr�,+ I I