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Neg Dec Tracypterial Recovery&Transfer Station February 29,2008 The Lead Agency failed to consult with the Board, a Responsible Agency,prior to preparation and circulation of this environmental document. Prior to determining whether a negative declaration or environmental impact report is required the Lead Agency shall contact all Responsible Agencies and Trustee Agencies. • Public Resources Code(PRC) Section 21080.3. (a)Prior to determining whether a negative declaration or environmental impact report is required for a project, the lead agency shall consult with all responsible agencies and trustee agencies. Prior to that required consultation,the lead agency may informally contact any of those agencies. If the,Lead Agency had consulted with the Board, as required,prior to the preparation and circulation of this environmental document, Board staff would have met with the Lead Agency and the proponent, if desired, discussed the project and directed them to our internet site, http://w-ww.ciwmb.ca.gov/LEACentral/CEQA/transfer.htm and htlp://www.ciwmb.ca.gov/LEACentral/CEQA/compost.htm for additional information, so an adequate and appropriate environmental document could be prepared. Adequacy of Document For this environmental document to be adequate it would be necessary for the Lead Agency to provide a complete Initial Study and a complete Project Description including description of all operations. This would include an analysis or specific study of air quality and traffic, provisions for the proponent to meet State Minimum Standards for the operation of a Transfer Station/Materials Recovery Facility and Composting Facility, Mitigation Measures etcetera. For more information regarding the specifics of what Board staff is looking for in an environmental document; please go to websites referenced above. Initial Study The Initial Study provided was inadequate because of the failure to provide evidence to support the entries, including entries where there was no impact. Title 14 California Code of Regulations (14CCR) Section 15063(d)(3) An identification of environmental effects by use of a checklist, matrix, or other method,provided that entries on a checklist or other form are briefly explained to indicate that there is some evidence to support the entries. The brief explanation may be either through a narrative or a reference to another information source such as an attached map,photographs, or an earlier EIR or negative declaration. A reference to another document should include,where appropriate, a citation to the page or pages where the information is found. -2- U:\A11stafT\CEQA\2008 DOCS\COLTNTIES\San Joaquin-39\Comment Letters\Neg Dec Tracy MRF&TS1 39-AA-0024 2-29-revised.doc