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Sao Joaquin County Community Development Department November 1.2018 Page 3 of b the 2013 E1R's version of Measure D.2a, thus allowing for easy comparison, the DSEIR leaves it to the Oreader to(a) locate the 2013 Expansion EIR and(b)perform the comparison between the two measures. (cont.) 11iis"hide the ball"approach is perpetuated throughout the DSEIR. The Proiect Description is inadequate. ' A complete and accurate project description is a necessary clement of an adequate DSEIR. "The project description must contain sufficient specific information about the project to allow the public and reviewing agencies to evaluate and review its environmental impacts." Dry Creek Citizens Coalition v. County of Tulare(1999)70 Ca1.App.4'1'20, 26. "An accurate, stable and finite project description is the sine qua non of an informative and legally sufficient EIR." County of Inyo v. City of Las Angeles(1977) O71 Cal.App.3d 185,193. `°A curtailed, enigmatic or unstable project description draws a rod herring across the path of public input." Id.at 198. CEQA Guidelines§ 15124 directs that an UR should include information"needed for evaluation and review of the environmental impact." A project description that omits any"integral part of the project" is inadequate. Diy Creek, supra,citing Santiago County Water District v. County of Drangc (1981) 118 Cal.App.3d 818, 829. Against this backdrop, the Project Description section of the DSEIR is inaccurate,inconsistent and incomplete in the following areas; a. CEQA requires that an EIR articulate the objectives of the project,so that project alternatives can be evaluated for their ability to achieve the basic objectives. Here,the Project Objectives, Ofound at page 111-7 and I11-11, are so narrowly defined as to be meaningless, and improperly exclude 4 many otherwise feasible options and available sites from consideration. As written, the objectives predetermine that no other sites are available which meet the Project objectives. This is a violation of CBQA. ' b. The DSEIR is remarkably incurious concerning future expansion($) of the Stockton Airport. It is well known that the Airport intends to expand and will bring airfield operations O (including, but not limited to, expansion of air freight facilities,closer to the landfill and thus, within the 10,[)00 foot separation distance described in the DSEIR. Yea the DSEIR makes no effort to describe or analyze this potential effect. C. The DSEIR also fails to acknowledge that previous mitigation measures and/or ' conditions of approval dealing with litter-related Impacts, food safety and related effects have consistently failed to protea nearby farming operations. 'llie fact that existing litter control measures have been unsuccessful should be included in the Project Description as part of the environmental hoschne, it © should then be carried forth in the impacts section of the DSUR, and more stringent mitigation measures should be developed and analyzed to address the issue. Instead, the DSEIR perpetuates the myth that prior "voluntary' measures have reduced litter-related impacts to less than significant levels. SJFB members in the vicinity of the landfill tell a drdmatically different story, which, unlike the DSEIR, is supported by substantial evidence. d. Finally,the Project Description fails to describe what,if anything,will become of the 184 acre"Broechini Parcel",which figured prominently in the 2013 Expansion EIR,and which would have been added to the Project had the 2013 Expansion been approved. This raises serious concerns that Othe applicant is breaking the larger, less palatable project that was rejected in 2013 into a more politically tenable series of smaller"sub-projects". Politics aside, this is a classic case of'"piece-mealing",which of course is expressly prohibited under CEQA. Absent evidenoe that the applicant has divested itself of the Broochini Parcel, or has otherwise irrevocably committed (i.e. through a Development Agrocment or