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Kerry Sullivan <br /> November 9, 1993 <br /> Page 3 <br /> impacts p is cane be mitigated to a level of insignificance <br /> as required by CEQA: Article 10, Section 15151 of CEQA <br /> states : <br /> "An EIR should be prepared with a sufficient ' <br /> degree ofanalysis to provide decision-makers with <br /> information which enables them to make a decision <br /> which intelligentlytakes account of environmental <br /> consequences. " <br /> In order for an environmental document to be considered <br /> adequate by CIWMB staff for the processing of a SWFP, the <br /> potential significant environmental impacts associated with <br /> the proposed project' s implementation must be identified <br /> clearly in the EIR and discussed in relative detail, <br /> including identification of significant/adverse <br /> environmental impacts which cannot be mitigated which may <br /> require a written finding(s) of overriding considerations. <br /> Article 9, Section 15126 of the CEQA Guidelines states : <br /> "Direct and indirect significant effects ects of the project <br /> on theenvironment 'shall be 'clearly identified and <br /> described, giving due consideration to bath the short- <br /> term and long-germ effects. " <br /> CIWMB staff requests that an EIR be a self supporting <br /> document containing all information and data and/or specific <br /> references to support project suppositions and declarations.. <br /> CIWMB staff offer the following comments to be addressed in the <br /> Final Environmental Impact Report (FEIR) : , <br /> Compost Facility <br /> The DEIR was circulated to gain approval for construction of the <br /> TMRF. However, the operation of a compost' facility and possible <br /> impacts associated with it were not adequately discussed for the <br /> purpose of CIWMB approval of ;a SWFP. <br /> The project proposes the composting of yard wastes. Heavy metals <br /> and 'pesticide residues may be contained in yard wastes. <br /> Potential impacts to air, water, human health and safety, and <br /> others associated with composting were not adequately addressed. <br /> NOTE: Regulations pertaining to ;green composting 'facilities <br /> (Title 14, California Code of Regulations' (CCR) , Chapter <br /> 3 . 1, Composting Facilities Permitting Procedures and <br /> Enforcement) were promulgated on July 15, 1993, and should <br />