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John Funderburg April 6,2012 ' Page 3 The Project evaluated in the 2010 EIR proposed substantial modifications to the existing landfill's operations and procedures. These changes included solidification of non-hazardous higher liquid content wastes,an increase in the amount of beneficial reuse materials and a change in permitting terms regarding the same, an increase in the permitted number of daily vehicles,and lowering the base grade on the currently permitted landfill site. 2010 EIR at III-2. Although the NOP does not identify these Project operations and procedures as being included in the revised Project,it is unclear whether they are no longer being proposed or whether they were simply omitted from the NOP. The prior Project also included expansion of the existing landfill gas-to- energy plant (LFGTE) at the landfill site (Id. at III-34),yet the NOP does not explain whether the current Project also includes additional electricity generation with landfill gas. Inasmuch as the existing LFGTE plant is permitted to operate only until April 30, 2013,does the applicant intend to expand the plant? If not,would this plant be shut down? All of these Project details must be clearly identified and described. We understand the County prepared an initial study/negative declaration in August 2011 for a new LFGTE plant and that the County may have already approved this project. Inasmuch as Forward was contemplating increasing its LFGTE capacity as part of the prior Project,why did the County not wait to process the LFGTE facility in the context of the current Project? Clearly,as the 2010 EIR makes clear,the LFGTE and the landfill expansion Project are related actions and their environmental effects must be collectively evaluated. CEQA prohibits piecemealed review of these projects. In addition to the concerns identified above,it is apparent that the only way the public and agencies can understand the proposed Project is for the revised NOP and EIR to clearly identify and describe the landfill's existing operations. To this end,the County should provide information including but not limited to the following: • Description of the methodology, and the documentation,used to determine the assumption that under, average fill rates,the landfill would close in 2021. This documentation must distinguish between Class II and Class III disposal demand and in-county and out-of-county demand. This same information should be provided for the proposed Project's expected landfill closure date of 2039;1 1 In order to avoid confusion,it will be important for the revised NOP and the draft EIR to consistently reference landfill waste and materials in either tons or cubic yards,or both. ' SHUTE, MIHALY �;\VEINBERGERLLP