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John Funderburg April 6, 2012 Page 6 — accomplish this purpose, an EIR must be detailed, complete, and reflect a good faith effort at full disclosure. CEQA Guidelines § 15 15 1. It must contain facts and analysis, not just an agency's bare conclusions. See Citizens of Goleta Valley v. Bd. of Supervisors, 52 Cal, 3d 553, 568 (1990). In short, the document should provide a sufficient degree of analysis to inform the public about the proposed project's adverse environmental impacts and to allow decision makers to make intelligent judgments about whether or how the project should proceed. CEQA Guidelines § 15151. The NOP fails to provide sufficient information describing the probable environmental effects of the proposed Project. In fact, the document indicates only certain environmental issue areas will be discussed in the EIR. It does not provide any indication of what the County believes to be the probability that the proposed Project will result in various enviromnentat impacts. This approach is acceptable if the County has actually concluded that there is a high probability that the proposed Project will result in potential environmental effects in every issue area listed(land use, traffic, noise, air _ quality and odors, hydrology and water quality, soils and geology, biological resources, public services and utilities, cultural resources, visual quality, and climate change). If this is the case, the EIR prepared by the County should provide an exhaustive and — detailed analysis of the Project's impacts in all of these environmental issue areas. If the County does not, in fact, intend to prepare a full analysis of the Project's potential impacts in all issue areas, it should have made that clear in its NOP. In the absence of such a statement from the County, we can only assume that the EIR will provide an exhaustive and detailed analysis of the Project's impacts in all of the above-listed environmental issue areas. — In order to fully disclose the proposed Project's potential environmental impacts, the County must provide a thorough description of the environmental setting, including the landfill's existing regulatory framework and compliance record. At a minimum, the following information should be provided in the draft EIR; • Specific data regarding surface and ground water quality in the area; • Information regarding the landfill's existing groundwater remediation program, including sampling results for each well, and documentation regarding the status of compliance with all permits, regulatory orders and lawsuits; • Delineation of the Project site pursuant to the Federal Emergency Management Agency Flood Insurance Rate Map; S 1-I UT EN11 FI A LY &--WF1v131--RGI:Rm,