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San Joaquin County Community Development Department November 1,2018 Page 2 of b I IR be re-circulated to allow a more complete disclosure of the potential environmental consequences of Othis Project for the public., the applicant, and the decision makexs that must render judgment on the (cont.) suitability of this Project at this site. The County should require a 5ubsecrucnl not Supplentental FIR. ' The DSEIR traces the lengthy permitting and environmental review history of the Project. The original Environmental Impact Report for the Forward Landfill was certified in 2003. In 2013,Forward proposed a massive expansion of the landfill, to include a 184 acre parcel(the"Brocchini parcel'"),as well as a 10 acre parcel northeast of the existing landfill and an 11 acre parcel south of the then-existing landfill. This expansion,if approved,would have nearly doubled the capacity of the landfill. Other features of the 2013 Expansion included the relocation of 3,000 feet of Littlejohn Creels and the disposal of cannery waste on site. At that time,a new Draft E[R was prepared and circulated for public review. The 2013 Expansion ' EIR was certified by the Board of Supervisors, but the project itself was rejeeted when the required "override"of the Airport Land Use Plan failed to achieve the requisite 4 votes of the Board. In 2014, Forward proposed a smaller increase in permitted capacity,and a Draft Supplemental EIR was drafted,but was never certified. Forward apparently atrondoned the project. Now, more than 5 years after certification of the 2013 Expansion I;IR, and more than 15 years after the hist project approval, the DSEIR studies a more limited expansion which is similar, but not identical to the abandoned 2014 project. The authors of the DSEIR assert that the use of a "supplemental ETR" is ppmpriate because the changes in the project would not result in impacts which are more significant than those studied in the 2013 Expansion ETR. The ostensible advantage to characterizing this EIR as a ' "supplemental" EIR is that the County is not required to recirculate the original EIR. But CEQA Guidelines Section 15163 limits the use of supplemental E1R's to situations in which "only minor additions or changes would he necessary to make the previous EIR adequately apply to the project in the Ochanged situation " Yet in the DSEIR,the majority of the traffic mitigation measures have been revised. This is true in other chapters of the DSEIR as well. Clearly, in light of the number of new or modified significant effects and revised mitigation measures identified in the DSEIR, this should be a "subsequent",not"supplemental"EIR. The importance of this distinction is self-evident in this case, in which the reader is required to compare the current propmal with that which was proposed in the 2013 Expansion EIR. SJFB's initial internet search of the County's website revealed that the 2013 Expansion EIR was not available for public review, but it was apparently posted in response to public requests. At more than 1,000 pages, the 2013 Expansion EIR is a daunting task for any reader. But the DSLAR's approach leaves it to the reader to correlate and attempt to harmonize the two EIR's. This is unreasonable and inconsistent with CEQA's informational mandate. ' :adding to the confusion is the fact that numerous new projects have been approved in the area, while others have been modified or withdrawn. How this affects the environmental "baseline" is never discussed in DSEIR. Moreover, it is unclear whether, and to what extent, the mitigation measures in the 1 MI 3 Expansion FIR have been,or will be incorporated in the DSEIR,and how they will be implemental should the Project be approved. Since the 2013 Expansion FIR studied a MUCH different project than the current proposed expansion (a project which was denied), the public, like SJFB, is bound to he ' confused, and CEQA's informational function is hindered. For example, the DSEIR's Summary of Impacts and Mitigation Measures at Page II-17 lists Mitigation Measures D.2a and D.2b. Measure D.2a revises the 2013 EIR, while Measure D.2b purports to be the same as the 2013 EIR. But rather-han list