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John Funderburg April 6, 2012 Page 7 • Documentation regarding all accidental releases, explosions or fires at the Forward landfill; — • Specific data regarding the landfill's: (1) existing emissions (criteria air pollutants, toxic air contaminants including asbestos, and odors); and (2) air quality — regulatory compliance record, including its complaint history; and, • Documentation regarding any regulatory non-compliance for the last five years from agencies including the U.S. Environmental Protection Agency, U.S. Army Corps of Engineers, U.S. Fish and Wildlife Service, CalRecycle, California _ Department of Toxic Substances Control, California Department of Water Resources, California Department of Fish& Game, California Regional Water Quality Control Board, Central Valley Regional Water Quality Control Board, _ Central Valley Flood Protection Board, San Joaquin County, and San Joaquin County Unified Air Pollution Control District. In addition to evaluating the proposed Project's environmental impacts, the EIR must also assess the cumulative impacts of the Project when viewed in connection with the effects of past projects, other current projects and probable future projects. — CEQA § 21083(b)(2). A complete cumulative impacts analysis is important because the full environmental impacts of a proposed project such as the expansion of the landfill cannot be gauged in a vacuum. II. The NOP Fails to Identify Any Project Alternatives. An EIR must describe a range of alternatives to the proposed project, and to its location, that would feasibly attain the project's basic objectives while avoiding or substantially lessening the project's significant impacts. Pub. Res. Code § 21100(b)(4); — CEQA Guidelines § 15126.6(a). A proper analysis of alternatives is essential for the County to comply with CEQA's mandate that significant environmental damage be _ avoided or substantially lessened where feasible. Pub. Res. Code § 21002; CEQA Guidelines §§ 15002(a)(3), 15021(a)(2), 15126.6(a); Citizens for Quality Growth v. City of Mount Shasta, 198 Cal. App. 3d 433, 443-45 (1988). As stated in Laurel Heights _ Improvement Association v. Regents of University of California, "[w]ithout meaningful analysis of alternatives in the EIR, neither the courts nor the public can fulfill their proper roles in the CEQA process. . . . [Courts will not] countenance a result that would require blind trust by the public, especially in light of CEQA's fundamental goal that the public be fully informed as to the consequences of action by their public officials." 47 Cal. 3d 376, 404 (1988). — S 1-1 UT F) M 11-1 A Ll' V` V/F INfiERGrlti v