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Mr.Mr.Griffin , October 5,2006 Page 2 of 5 The project is located on the south side of W.Frewert Road, 1.3 miles west of S.Manthey Road,west of Lathrop. The project site is 31.4 acres with a General Plan designation of AIG and Zoning of AG-40. Board Staff's Comments In the opinion of Board staff,the environmental document(ED), as circulated,does not contain sufficient information, as required in CCR Title 14, CEQA Guidelines Sections 15063, 15064, or 15071 for Responsible Agencies to make meaningful comments regarding their areas of authority or expertise. In order for a Responsible Agency to make meaningful comments,the Responsible Agency must be able to fully understand and evaluate the scope, setting,and potential effects of a given project. This allows Responsible Agency to determine their responsibilities and authority in approval, implementation, and mitigation of the project. This cannot be done with information in the current ED. Due to a lack of information in the ED,Board staff is unable to determine at this time whether or not the CIWMB will be a Responsible Agency for the approval of this project or subsequent related activities in the project area. Board staff comments and questions at this time are intended to assist the Lead Agency in the preparation of an ED and/or Initial Study(IS)that is more helpful to Responsible Agencies in the discharge of their responsibilities under CEQA Statutes and Guidelines. The environmental document should detail all provisions in order to indicate the ability of the facility to meet State Minimum Standards for environmental protection(14 CCR§ 17000 et. seq.). Some considerations include: Days and Hours of O eration The ED should be very specific regarding the days and hours of operation. Clearly identify the days and hours the facility is open to the public,the days and hours of waste receipt, the days and hours of waste processing, and the days and hours of other site activities. Peak Tonnage The issuance of a Solid Waste Facilities Permit(SWFP)will require that peak daily tonnage received be proposed and analyzed in the ED. All material, except equipment and supplies, which pass over the scale, must be analyzed for in the environmental document. Traffic and Related Transportation System Irn acts The issuance of a SWFP will require that peak daily vehicle counts be proposed and analyzed in the ED. This includes refuse trucks, self-haul vehicles and employee vehicles. Typically, one vehicle trip equals two vehicles(1-inbound& 1-outbound); specify in the ED the peak daily vehicle count anticipated to access the site. On site traffic circulation and the cumulative effect of traffic for the proposed project should also be discussed in detail in the ED. Air Quality Local and regional impacts on air quality from vehicles, trucks, and equipment emission sources accessing the facility should be analyzed in detail,including emissions from equipment handling waste materials and potential dust generation during operations. Dust particulates (PM10) and ozone precursors may be of particular concern if the regional air basin is `non-attainment' for PM10 and ozone precursors. If the proposed project is located within a `non-attainment'air basin, cumulative impacts affecting the projected federal `attainment' dates may be significant and unavoidable. Composting feedstocks may create potentially significant odor problems. Composting piles, feedstock, storage and active compost product can develop pockets of high moisture content that can cause odor problems when the oxygen supply has been deprived and the microorganisms' metabolism starts the anaerobic digestion of organic material. Measures must be taken to mitigate this potential for odor generation. i