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6,680 tons per day (tpd), six days/week and 1,200 tpd, five days/week, respectively, for a total of 7,880 tpd. The combined tonnage limit stated in the EIR equates to 46,080 tons per week(tpw)for a seven-day week with a maximum daily tonnage of 8,668 tpd. Historically, these tonnage limits were considered refuse tonnage limits and the former Forward and Austin Road landfills operated under this premise. The basis for this interpretation was California Integrated Waste Management Board's(CIWMB) LEA Advisory#25 "What Tonnage Amounts Handled on Site Count for Purposes of the Limits in the Permit"(see Attachment A). LEA Advisory#25 states: "The tonnage counted does not include material used for daily cover." This Advisory has since been recently rescinded. However, the C&D regulations promulgated by the CIWMB in 2003, clearly exclude clean soil and rock from the definition of inert debris. In fact,the Board's"Regulations Implementation Guidance for LEAs - Questions and Answers: Construction and Demolition and Inert Debris Transfer/Processing Regulations" (see Attachment B, last updated June 9, 2005) states that: "The CIWMB has provided no such guidance as it is believed that solid waste statutes, regulations, and supporting documents clearly indicate that there is no intent to regulate clean soil and rock (emphasis added" Thus,cover materials have not historically been counted as part of permitted tonnage caps and as recently as June 2005, the Board has reiterated that clean soils and rock are not materials regulated by the Board. The question as to whether the tonnage limits presented in the EIR refer to a refuse tonnage or total tonnage can be answered based on the various analyses performed in support of the Ea The environmental analyses for which tonnage is a key factor are transportation and circulation, air quality,and public health and safety. In all of the above listed analyses, the site fife/landfill closure date is also a key component of the analysis. The tonnage limits for the landfill are directly related to the site lifeAandfill closure date. The following sections provide a discussion of the portions of the Project Description and environmental analyses that are influenced by tonnage and closure date, as they relate to refuse or total tonnage assumptions. CLOSURE DATE IN PROJECT DESCRIPTION The anticipated closure date for the consolidated Forward Landfill is 2020 (ref: EIR pg. 52). This closure date is based on calculations presented in the Final Draft Joint Technical Document. The calculations state that the closure date of 2020 is based on a daily permitted refuse inflow rate of 7,880 tpd. The amount of daily cover, which includes AD and importe soi, is a separate qua- ty t tis added to the amount of refuse to estimate the site life/closure date. If the Forward Landfill's daily tonnage limits were based on a total tonnage, the amount of refus—e'at could be acre ted at the siteeach a`3 ywou�d3ecrease, resulting in an increase site life and a closure date beyond 2020. The site life/closure date reference in the Final Draft Joint Technical Document is included as Attachment C. TRANSPORTATION AND CIRCULATION The estimated vehicle count was based on combining the former Forward and Austin Road Landfill vehicle count limits. The former Forward Landfill was limited to 435 one-way vehicle trips per day. There was no specified vehicle limit for the former Austin Road Page 2