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I <br /> I <br /> John h'underburg, Principal Planner <br /> October 30, 2018 <br /> Rage I I <br /> I <br /> Third, the SDEIR provides deficient informat.iun about Forward's historical rezord <br /> of odor complaints. Here,tine document asserts that, over the past three years, tate Air <br /> District received no odor complaints about landfill-related odors. SDEIR at iV.D-23. This <br /> assertion does nest scene w-edible. According to written statements from area residents, <br /> udurs Froin tlrc landfill can be overwhelming. See"Mitteru Statements Regarding ' <br /> Forward Landfill,attached as Exhibit F. Individuals state that they have called the Air <br /> District on multiple occasions. Id. It is important to point out digit the Air District <br /> typically responds to these callers with a perfunctory explanation, stating that nothing can ' <br /> be deme since the landfill has a pennit to operate. Consequently, at soma point, <br /> individuals simply give up and stop calling. Irl. If the Air District were niore responsive, <br /> there is a high likelihood that members of the public would continue to complain about ' <br /> the landfill's odors. <br /> As part of the 2012 DEIR. a survey was conducted to make qualitative <br /> observations related to odor. SDEiR at iV.13-24. However, mother than include an updated <br /> survey, the current SDEIR includes the same data that was collected in 2011. As an Initial <br /> matter,a survey that was conducted seven years ages is not representative of current <br /> 10 conditions.The area surrounding the landfill has changed significantly since 2011. ' <br /> (cont.) Examples of new development include: (1) the Arch Road Industrial Project; (2) the <br /> Arcltuuu Industria! Project; (3) the 1,722-bed California licalth Care Facility; (,o) <br /> the <br /> Northern California Re-Entry ry Facilityand renovation of the former Dcwitt-Nelson Yo <br /> uth <br /> I <br /> Correctional Facility; and(5) tic Tidewater Crossing Project consisting of 2,365 dwelling <br /> units. SDEIR at 111-14. <br /> Aside from the fact that the odor survey is outdated, the SDEIR provides no detail <br /> about the survey protocol tin it is entirely unclear if the survey approach or techniques <br /> were adequate. For example, the survey was conducted over three days in late fall.Yet, <br /> odors rise with ambient air temperature.' The combination of heat and hunlidity allows <br /> bacteria to grow faster and smells to travel farther.Id. 1f the odor survey had been <br /> conducted during hot sumtncr days, odors would likely have Ixetu considerably more <br /> severe. <br /> Fourth,dcspit.: the fact that the landfill expansion would bring sources of odors <br /> closer to sensitive receptors,the SDEiR provides no analysis whatsoever of these <br /> impacts. Both new refuse cells would be on the far east side of the landfill, adjacent to <br /> .Sege Ovooh, that smell! Odors rise with the temperature, NHC' News, July 17, 2013 <br /> available at: haps:;/w►;{w.nbenews,con�/newx/uS-newsloonnlu-Smell-cidrn -rise- <br /> te1nperatu1-e-Il1ta6C 10663511 <br /> SI#U1 l., MMALY <br /> rWLINBERGERr.r <br /> I <br />