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Caroll Mortensen January 13, 2012 Page 5 In addition, both the SWFP Revision and the Landfill Expansion Project contemplate changes in landfill operations, including an increase in the number and frequency of truck trips that would access the landfill. See 2010 DEIR at I-1. While the 2010 DEIR acknowledges that the Landfill Expansion Project would increase daily truck traffic from 620 to 960 daily vehicles2, it never discloses that Forward also proposes to allow trucking operations on Sundays. Nor does the SWFP ND acknowledge Forward's plan to increase the number of daily round -trips to 960. By purposely omitting reference to these critical landfill operational components, the lead agency has vastly underestimated the Project's environmental impacts. Moreover, by considering the SWFP Revision prior to, and in isolation of, the Landfill Expansion Project, the LEA has improperly segmented environmental review. Consequently, Calrecycle should deny the SWFP Revision until such time as an EIR is prepared that analyzes the environmental impacts from the complete Landfill Expansion Project. Only then can the public and decision -makers be adequately informed about the environmental repercussions of all proposed landfill activities and meaningfully consider alternatives and mitigation measures to address the Project's adverse environmental impacts. Inasmuch as a revised DEIR for the Expansion Project is imminent, we believe it prudent to await the completion of the environmental review process for the Expansion Project. II. AN EIR MUST BE PREPARED THAT ANALYZES THE POTENTIALLY SIGNIFICANT EFFECTS OF THE PROPOSED PROJECT. An agency must prepare an EIR for a proposed project whenever substantial evidence in the administrative record supports a "fair argument" that the project may have significant impacts on the environment. Guidelines §§ 15064(a)(1), (f)(1). A fair argument clearly can be made that the Project, which will result in the loss of 184 acres of agricultural lands and increase operations on days the facility does not currently operate, will have potentially significant environmental impacts. For the reasons discussed below, an EIR is required. A. The SWFP Revision Will Have Potentially Significant Impacts on the Region's Agricultural Resources. 2 These are round -trips, not one-way trips. One-way trips would increase from 1,260 to 1,920. SHUTE MIHALY --WEINBERGERu-P