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Neg Dec Tracoaterial Recovery&Transfer Station February 29,2008 BOARD CEQA REVIEW As a Responsible Agency under CEQA, Board staff's comments on environmental documents are intended to assist the Lead Agency in developing an environmental document that will be as complete and adequate as possible for use by the Lead Agency and all Responsible Agencies. Board staff's comments are intended to help decision-makers 1) identify potential impacts from proposed projects; 2) determine whether any such impacts are significant; and 3) ascertain whether significant impacts can be mitigated to a less than significant level in compliance with the CEQA statutes and guidelines. When performing the initial review of a CEQA document such as a Draft Environmental Impact Report or Negative Declaration during the circulation process, the first analysis Board staff must make is to evaluate whether or not the proposed CEQA document clearly describes all phases of the project and assesses all potential primary and secondary impacts, to the environment and/or public health and safety that could occur, if the proposed project is implemented. When evaluating the adequacy of an environmental document for purposes of SWFP concurrence, Board staff must compare the design and operation of the facility as described in the proposed SWFP with the project as described and evaluated in the environmental document cited for CEQA compliance in the proposed SWFP. In order for Board staff to evaluate and recommend whether or not the environmental document is adequate for use in the Board's permitting process, the proposed project must be described in sufficient detail for Board staff to understand and evaluate the proposed project, the potential environmental impacts,proposed mitigation measures, and findings as presented by the Lead Agency. When the proposed SWFP is received by the Board along with the citation of evidence of CEQA compliance by the LEA,the second analysis performed by Board staff is to evaluate whether or not the CEQA evaluation in the cited environmental document supports the requested specifications, revisions, and/or conditions of the proposed SWFP. For instance, does the environmental document clearly describe and assess the potential air quality, water quality, geological impacts, traffic,noise, dust, vector and other health and safety impacts that can be associated with the proposed solid waste facility or changes in design and/or operation? When this type of information is included and addressed in the environmental document, the SWFP concurrence process is greatly facilitated. After comparison of the cited CEQA document with the proposed SWFP, Board staff makes a recommendation to the Board regarding the adequacy of the CEQA document for the Board's SWFP concurrence purposes. The Board members -4- U:\AIIstaff\CEQA\2008 DOCS\COLJNTIES\San Joaquin-39\Comment Letters\Neg Dec Tracy MRF&TSI 39-AA-0024 2-29-revised.doc