Document Palmdale_doc_2eab3739fb

ANTELOPE VALLEY PUBLIC LANDFILL CUP RESPONSE TO COMMENTS/ FINAL EIR (SCH #[PHONE REDACTED]) Prepared for: City of Palmdale Planning Department 38250 Sierra Highway Palmdale, California 93550 Prepared by: EDAW/AECOM 2737 Campus Drive Irvine, California 92612 March 2011 ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL CUP RESPONSE TO COMMENTS/ FINAL EIR SCH #[PHONE REDACTED] Lead Agency: City of Palmdale Planning Department 38250 Sierra Highway Palmdale, California 93550 Contact: Mr. Richard Kite, Assistant Director of Planning (661) 267-5200 Consultant: EDAW/AECOM 2737 Campus Drive Irvine, California 92612 Contact: Ms. Jane Chang, Project Manager (949) 660-8044 March 2011 ---PAGE BREAK--- ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL TABLE OF CONTENTS MARCH 2011 i RESPONSE TO COMMENTS/FINAL EIR TABLE OF CONTENTS Section Page 1.0 INTRODUCTION 1.1 Organization 1.2 Environmental Review Process 1.3 Comment Letters 1.4 Project Summary 1.5 Additional Energy Information 1-31 2.0 DECEMBER 2005 DRAFT EIR COMMENT LETTERS AND RESPONSES 2.1 Written Comments/Responses 2.2 Verbal Comments/Responses 2-51 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS AND RESPONSES 3.1 Written Comments/Responses 4.0 CHANGES TO THE DECEMBER 2005 DRAFT EIR AND MAY 2010 AMENDMENT TO THE DRAFT EIR 4.1 Introduction 4.2 December 2005 Draft EIR Errata Pages 4.3 May 2010 Amendment to the Draft EIR Errata Pages 5.0 MITIGATION MONITORING AND REPORTING PROGRAM (MMRP) 5.1 Introduction 5.2 Basis for the Mitigation Monitoring and Reporting Program 5.3 Resolution of Noncompliance Complaints 5.4 Mitigation Monitoring and Reporting Plan Matrix ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL TABLE OF CONTENTS MARCH 2011 ii RESPONSE TO COMMENTS/FINAL EIR APPENDICES Appendix A Antelope Valley/Palmdale Landfill Gas Flow Letter, Waste Management, September 23, 2010 Appendix B California Clean Energy Committee Appendices, July 3, 2010 (Available at the City of Palmdale) Appendix C Protocols for Surveying and Evaluating Impacts to Special Status Native Plant Populations and Natural Communities, California Department of Fish and Game, November 24, 2009 Appendix D 2009 Solid Waste Disposal Summary Reports by Facilities, County of Los Angeles, July 8, 2010 ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL TABLE OF CONTENTS MARCH 2011 iii RESPONSE TO COMMENTS/FINAL EIR TABLES Table Page 1-1 Project Impact Summary 1-2 Southern California Edison Power Content 1-34 3-1 Antelope Valley Public Landfill Solid Waste Disposal Summary 3-33 3-2 Antelope Valley Public Landfill Solid Waste Disposal Summary 3-78 5-1 Mitigation Monitoring and Reporting Program Matrix ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL TABLE OF CONTENTS MARCH 2011 iv RESPONSE TO COMMENTS/FINAL EIR This page left blank intentionally. ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 1.0 INTRODUCTION MARCH 2011 1-1 RESPONSE TO COMMENTS/FINAL EIR 1.0 INTRODUCTION 1.1 ORGANIZATION This document is the Final Environmental Impact Report (Final EIR) for the Antelope Valley Public Landfill (AVPL) project. It also serves as the Response to Comments on the December 2005 Draft EIR and the May 2010 revised and recirculated sections the “Amendment” to the Draft EIR). This document relies on and references information available in the City’s public record related to the project, Draft EIR and Amendment to the Draft EIR and is an informational document that has been prepared by the City of Palmdale as lead agency under the California Environmental Quality Act (CEQA) (Pub. Resources Code § 21000 et seq.). According to the CEQA Guidelines (Section 15132), a Final EIR must consist of the following elements:  The Draft EIR or a revision of that draft.  Comments and recommendations received on the Draft EIR either verbatim or in summary.  A list of persons, organizations, and public agencies that commented on the Draft EIR.  The responses of the Lead Agency to significant environmental points raised in the review and consultation process.  Any other information added by the Lead Agency. This Final EIR serves to complete the environmental document process required by CEQA and includes the following information: Section 1.0 – Introduction: This section provides an introduction to the Final EIR and a list of comment letters received on the Draft EIR and Amendment to the Draft EIR. Section 2.0 – December 2005 Draft EIR Comment Letters and Responses: This section provides a list of persons commenting on the Draft EIR, copies of the written comments (numerically coded for reference), and the responses to those comments put forth by the City of Palmdale. Section 3.0 – May 2010 Amendment to the Draft EIR Comment Letters and Responses: This section provides a list of persons commenting on the Amendment to the Draft EIR, copies of the written comments (numerically coded for reference), and the responses to those comments put forth by the City of Palmdale. Section 4.0 – Changes to the December 2005 Draft EIR and May 2010 Amendment to the Draft EIR: This section includes all corrections and additions to the December 2005 Draft EIR text ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 1.0 INTRODUCTION MARCH 2011 1-2 RESPONSE TO COMMENTS/FINAL EIR and May 2010 Amendment to the Draft EIR text, including changes made as a result of comments received on either the Draft EIR or the Amendment to the Draft EIR. Any changes in text are indicated by underline/strikeout revision. Section 5.0 – MMRP: This section provides the Mitigation Monitoring and Reporting Program (MMRP) to ensure that the mitigation measures identified in the Draft EIR and Amendment to the Draft EIR are implemented to reduce or avoid the significant adverse environmental impacts of the project. Although not included within the cover of this Final EIR, the Draft EIR and Amendment to the Draft EIR, as issued for public review on December 14, 2005 and May 24, 2010, respectively, are incorporated herein by reference and are revised as shown in Section 4.0. Collectively, this document, and the Draft EIR and Amendment to the Draft EIR, as revised by Section 4.0 herein, constitute the Final EIR. 1.2 ENVIRONMENTAL REVIEW PROCESS The City of Palmdale issued a Notice of Preparation of Draft EIR (NOP) on March 1, 2004, announcing preparation of an environmental document for the proposed Antelope Valley Public Landfill project. The NOP with CEQA Initial Study was sent to various persons, agencies, and organizations that would likely be interested or affected by the proposed project. Additionally, a notice was published notifying agencies and persons about the environmental process, where to review copies of the NOP/IS, and how to participate in the process. A project scoping meeting was held at the City of Palmdale on March 29, 2004 to solicit input and comments from the public. However, no member of the public attended the scoping meeting and no comments were raised at that meeting. A total of ten comment letters, including a letter from SCAG which did not raise any environmental issues, were received during the NOP review period, which began on March 1, 2004 and ended on April 2, 2004. The comments on the NOP were considered by the City, as lead agency, in determining the scope of the issues to be addressed in the environmental document. Upon completion and finalization, the Draft EIR was circulated for review and comment during a 45-day review period, beginning on December 14, 2005 and ending on January 27, 2006. A total of nine comment letters and the OPR transmittal letter were received on the Draft EIR. Subsequent to the preparation of the Draft EIR in December of 2005, the City of Palmdale proposed to widen Tierra Subida Avenue between City Ranch Road and Cactus Drive (City Project Number 482). Since the City Project Number 482 would affect the proposed project site’s existing access at the intersection of City Ranch Road and Tierra Subida Avenue, a sight distance evaluation was conducted (JT Engineering 2010). Based on the sight distance evaluation, the project engineer recommended the construction of a new frontage road ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 1.0 INTRODUCTION MARCH 2011 1-3 RESPONSE TO COMMENTS/FINAL EIR connecting to Tierra Subida at Rayburn Road as the future access to the project site. In addition, with the passing of the California Global Warming Solutions Act of 2006 (Assembly Bill No. 32: California Health and Safety Code Division 25.5, Section 38500, et.seq., or AB 32), the City of Palmdale decided to incorporate a greenhouse gas (GHG) emission and climate change analysis into the Draft EIR. The additional information resulted in the preparation of the Amendment to sections of the Draft EIR. The Amendment to the Draft EIR was circulated for 45-days from May 24, 2010 to July 7, 2010. A total of eight comment letters were received on the Amendment to the Draft EIR. A Planning Commission hearing will be held on April 14, 2011 to take public testimony regarding the EIR prepared for the proposed project and related project Conditional Use Permit (CUP) at which time the Planning Commission will hear additional public comment and possibly take action to certify the EIR and approve the project. The City Council will only consider the project on any appeal after the Planning Commission has either approved or denied the project. 1.3 COMMENT LETTERS During the original public review period on the Draft EIR a total of ten comment letters on the Draft EIR were received by the City of Palmdale. The comment letters were received from: 1. Southern California Association of Governments, Brian Wallace – January 9, 2006. 2. County of Los Angeles, Department of Public Works, Donald Wolfe – January 11, 2006. 3. State of California, Health and Human Services Agency, Department of Health Services, Joseph E. Crisologo – January 11, 2006. 4. California Integrated Waste Management Board, Raymond M. Seamans – January 12, 2006. 5. Steve Schirmbeck, Local Citizen – January 14, 2006. 6. State of California, Public Utilities Commission – January 24, 2006 7. State of California, Business, Transportation and Housing Agency, Department of Transportation, District 7, Cheryl J. Powell – January 24, 2006. 8. County of Los Angeles, Department of Public Works, Donald L. Wolfe – January 26, 2006. 9. California Regional Water Quality Control Board, Lahontan Region – January 27, 2006. 10. State of California, Governor’s Office of Planning and Research, State Clearinghouse and Planning Unit, Terry Roberts – January 30, 2006 The City’s responses to these comment letters are contained in Section 2. During the public review period for the Amendment to the Draft EIR, eight comment letters, including the State Clearinghouse letter, were received by the City of Palmdale. The comment letters were received from: 11. Department of Resources Recycling and Recovery, Raymond M. Seamans – June 10, 2010 12. California Clean Energy Committee, Eugene S. Wilson – July 3, 2010 ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 1.0 INTRODUCTION MARCH 2011 1-4 RESPONSE TO COMMENTS/FINAL EIR 13. California Regional Water Quality Control Board, Lahontan Region, Jan M. Zimmerman – July 7, 2010 14. County of Los Angeles, Department of Public Works, Pat Proano – July 7, 2010 15. State of California, Governor’s Office of Planning and Research, State Clearinghouse and Planning Unit, Scott Morgan – July 8, 2010 16. County of Los Angeles, Department of Public Works, Pat Proano – July 15, 2010 17. County of Los Angeles, Public Health, Gerry Villalobos – August 5, 2010 18. County of Los Angeles, Fire Department – August 11, 2010 1.4 PROJECT SUMMARY The Draft EIR for this project addressed the environmental issues, alternatives, and impacts associated with implementation of the proposed project. As part of the proposal, a new CUP is requested that would be issued by the City of Palmdale. The existing County CUP would be replaced by the City of Palmdale CUP with the City of Palmdale as the lead agency. The proposed CUP includes enlarging the landfill refuse foot print to 125 acres by reconfiguring the two approved landfills into one contiguous disposal area, updating the legal boundary of the entire facility to 185 acres to reflect the current property boundary subsequent to a lot line adjustment approved in 1999, and a proposed increase to the net permitted daily limit to 3,600 tpd of solid waste for disposal in the landfill. The project would also combine the two existing Solid Waste Facility Permit’s (SWFP’s) into one permit issued by the LEA and concurred by the Department of Resources Recycling and Recovery (CalRecycle). The two existing Waste Discharge Requirements (WDR’s) will also be combined into one revised WDR permit covering the entire site and issued by the Lahontan Regional Water Quality Control Board The proposed project will consist of the following components:  Reconfigure the two landfills into one contiguous disposal area of 125 acres, updating the legal boundary to reflect the current property boundary of 185 acres and obtaining one Solid Waste Facility (SWF) and CUP permit for the entire area.  Enlarge the aggregate 114-acre refuse footprint by 11 acres to 125 acres total by incorporating the gap between Landfill I and Landfill II.  A proposed increase in the permitted daily intake of solid waste refuse to be disposed of in the landfill) from 1,800 tons per day (tpd) to 3,600 tpd. These tonnage figures exclude recyclables and materials used for Alternative Daily Cover (ADC) and beneficial use.  Limit the daily intake of TPH regulated soils to a maximum of 15 percent of the permitted daily intake for solid waste. ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 1.0 INTRODUCTION MARCH 2011 1-5 RESPONSE TO COMMENTS/FINAL EIR  Increase the “total” daily intake of refuse and recyclables (including ADC) from a currently permitted 3,564 tpd (assumed “total” intake in 1993 Mitigated Negative Declaration) to a peak of 5,548 tpd (assumed “total” intake for the analysis included in this EIR).  A proposed modification to the maximum height of the combined landfills to 3,200 above mean sea level (msl).  Proposed construction of ancillary facilities, including: two desilting basins; erosion protection along the north bank of Anaverde Creek, acceptable to the City Engineer; a revised site access including construction of a frontage road to connect with City Ranch Road and intersect Tierra Subida at Rayburn Road and create a 4-way signalized intersection and construct the remaining access road along the R-5 dedicated right-of-way; an additional truck scale; a recycling drop-off/transfer center; and the relocation of the existing Southern California Edison’s electric transmission lines and light duty poles to south side of property either “on-site” or “off-site.”  Revise hours of operation for waste acceptance to 6:00 a.m. to 8:00 p.m. for all users. The present permitted operating hours for receipt of refuse are between 6:00 a.m. and 5:00 p.m. for waste haulers and transfer trucks and 8:00 a.m. and 4:45 p.m. for the public.  Installation of a liner, leachate collection and removal system (LCRS), drainage control and surface water management system, groundwater monitoring system, and horizontal gas collectors in the expansion area and remaining combined landfill footprint area. The proposed liner system will be overlapped (per requirements of with existing liners to provide a continuation of environmental protection of groundwater in accordance with state regulations. The Draft EIR was prepared in accordance with CEQA as amended (Public Resource Code Section 21000 et seq.) and the State Guidelines for implementation of CEQA (CEQA Guidelines) as amended (Title 14 of the California Code of Regulations, § 15000 et seq.). The EIR complies with the rules, regulations, and procedures of CEQA Guidelines Section 15080 through 15097 regarding the public review and comment process for an EIR. The EIR analyzed the potentially significant environmental impacts of the proposed project. The potential cumulative impacts, that is, the effects of the proposed project in conjunction with past, present, and reasonably foreseeable future projects in the surrounding area, were also analyzed. The EIR identified alternatives to the proposed project and discussed possible ways to reduce or avoid the potentially significant environmental impacts. The applicant has decided to pursue City staff’s recommendation of the Reduced Project Alternative (the 1,800 TPD disposal option), which is the current CUP-approved tonnage, as the environmentally superior alternative. ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 1.0 INTRODUCTION MARCH 2011 1-6 RESPONSE TO COMMENTS/FINAL EIR For purposes of providing a summary of the Draft EIR/Amendment to the Draft EIR, the project impact summary (Table 1-1 of the Draft EIR/Amendment to the Draft EIR) is included herein, which shows project-specific and cumulative significant impacts, the level of significance, and the mitigation measures recommended in the Draft EIR/Amendment to the Draft EIR. The project summary matrix incorporates the editorial changes to eight mitigation measures (4.1- 1, 4.2-1, 4.2-4, 4.4-4, 4.5-1, 4.6-4, 4.7-1, and 4.8-1); six impacts (4.1-2, 4.3-4, 4.4-1, 4.5-1, 4.5-5, and 4.5-6); and revised air quality mitigation measures (4.2-5 through 4.2-7). However, Section 4.0 of this Final EIR specifically includes the changes in marked text and the errata pages to the December 2005 Draft EIR and May 2010 Amendment to the Draft EIR. ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 1.0 INTRODUCTION * Many of the project impacts are reduced by the project’s required compliance with landfill design and operating regulations, city/agency standards and regulations related to construction/development projects and/or by the incorporation of project design measures as noted in this table. Only the proposed project mitigation measures have been numbered to facilitate the distinction between mitigation measures, regulation compliance, and design measures. MARCH 2011 1-7 RESPONSE TO COMMENTS/FINAL EIR Table 1-1 Project Impact Summary Impact Mitigation Measures/Regulation Compliance/Design Measures * Scope Draft EIR 4.1 Earth Resources Impact 4.1-1 – Surface Fault Rupture Potential for future surface rupture at the AVPL along the trace of the San Andreas Fault Zone. Less than significant with regulation compliance. No mitigation required. Waste containment structures for the proposed landfills expansion are setback from the mapped trace of the San Andreas Fault, as shown in Figure 3-11, Fill Plan C. A setback meets the requirements of Title 27 California Code of Regulations (CCR) for Class III landfills. Impact 4.1-2 – Earthquake Ground Shaking Potential for ground shaking resulting in significant impacts, including leachate migration, slope failure, seismic settlement, damage to drainage facilities, monitoring wells, the new landfill entry road, and other landfill installations. Less than significant with regulation compliance and mitigation. The proposed landfill expansion and all ancillary support facilities will be designed in accordance with CCR, Title 27, Division 2, Seismic Requirements. 4.1-1 Prior to the issuance of the Waste Discharge Requirements (WDR’s) and approval of the Joint Technical Document (JTD) for the project by the Lahontan Regional Water Quality Control Board, the proposed design and supporting engineering analysis of the landfill’s containment structures shall be reviewed and approved by the to ensure the design complies with State regulations pursuant to California Code of Regulations, Title 27, Division 2. The applicant shall demonstrate to satisfaction that the landfill liner and leachate collection system have been designed to preclude failure and will resist the maximum seismic shaking Project Specific ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 1.0 INTRODUCTION * Many of the project impacts are reduced by the project’s required compliance with landfill design and operating regulations, city/agency standards and regulations related to construction/development projects and/or by the incorporation of project design measures as noted in this table. Only the proposed project mitigation measures have been numbered to facilitate the distinction between mitigation measures, regulation compliance, and design measures. MARCH 2011 1-8 RESPONSE TO COMMENTS/FINAL EIR Impact Mitigation Measures/Regulation Compliance/Design Measures * Scope expected at the site based on risk assessment. Further, the design shall demonstrate that the final slopes will be stable under both static and dynamic conditions to protect public health and safety and prevent damage to the facility such that no significant impact to the environment will occur. The liner design, as proposed in Appendix B of the EIR, shall be modified or refined if necessary based on final engineering analysis and review by the to ensure that the approved landfill design will mitigate impacts to a less than significant level. The landfill containment structures shall be constructed as approved by the During on-going landfill construction, geologic mapping of rock and soil exposed in future excavations shall be completed. Information on rock type and any exposed folds, fractures and folds will be collected. Permanent cut slopes shall be observed by a qualified geologist to check for adverse bedding, joint patterns, or other geologic features that may impact the approved landfill design. Where necessary, the permanent cut slopes shall be constructed to ensure their stability. The geologic maps will be included with the construction reports for each portion of the constructed landfill. The reports will be submitted to the LEA and Lahontan 4.1-2 Earth moving operations shall be observed, and the placement of fill shall be tested by a qualified geotechnical engineer during ongoing landfill operations. Observation and testing will ensure fill placements are ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 1.0 INTRODUCTION * Many of the project impacts are reduced by the project’s required compliance with landfill design and operating regulations, city/agency standards and regulations related to construction/development projects and/or by the incorporation of project design measures as noted in this table. Only the proposed project mitigation measures have been numbered to facilitate the distinction between mitigation measures, regulation compliance, and design measures. MARCH 2011 1-9 RESPONSE TO COMMENTS/FINAL EIR Impact Mitigation Measures/Regulation Compliance/Design Measures * Scope consistent with the approved landfill design. Impact 4.1-3 – Liquefaction Potential for liquefaction in the expansion and proposed ancillary facilities areas south of disposal area, where some layers of saturated alluvial soils have been identified. Site specific liquefaction studies by GCE (2000) indicate the potential for liquefaction in the expansion area is low due to high recorded blow counts in the alluvial soils and substantial confining loads under the refuse fill. Site specific liquefaction studies by Gainico (2000 & 2002) concluded that the potential for liquefaction in the ancillary facilities area is low because groundwater is more than 50 feet deep in these areas. Less than significant. No mitigation required. Project Specific Impact 4.1-4 – Expansive Soils Potential for expansive soils in the expansion area where claystone and silty claystone portions of the Anaverde Formation occur. Less than significant with design/ construction measures. Design/construction measures removal of weathered expansive soils, isolation of surface water, and substantial over burden pressure on any remaining expansive soils) will mitigate potential impacts. Project Specific Impact 4.1-5 – Slope Stability Potential for slope failure of the landfill slopes during severe seismic activity. Mitigation Measures 4.1-1 and 4.1-2, above. All slopes and pertinent attendant facilities shall be designed to Project Specific ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 1.0 INTRODUCTION * Many of the project impacts are reduced by the project’s required compliance with landfill design and operating regulations, city/agency standards and regulations related to construction/development projects and/or by the incorporation of project design measures as noted in this table. Only the proposed project mitigation measures have been numbered to facilitate the distinction between mitigation measures, regulation compliance, and design measures. MARCH 2011 1-10 RESPONSE TO COMMENTS/FINAL EIR Impact Mitigation Measures/Regulation Compliance/Design Measures * Scope Less than significant with mitigation and regulation compliance. applicable CCR, Title 27 Division 2, Seismic Requirements and City of Palmdale adopted building code, as applicable. Provision for the repair of the landfill cover system is provided through the Financial Assurance requirements of Section 22210 of CCR, Title 27. Impacts 4.1.6 – Cumulative Potential cumulative earth resources impact. The geotechnical issues discussed above are site-specific and will be limited to within the development boundaries of the project site. Less than significant. No mitigation required. Cumulative impacts 4.2 Air Quality Impact 4.2-1 – Short-term Construction Potential for construction related impacts including the potential for PM-10 significance thresholds to be exceeded. The Mojave Air Basin is non-attainment for PM-10. Less than significant with mitigation and regulation compliance. The landfill will continue to comply with AVAQMD Rule 402 and 403 prohibiting creation of a nuisance from dust. 4.2-1 Because the grading/disturbance of more than 10 acres will cause the daily PM-10 thresholds to be exceeded, construction of landfill ancillary facilities (new frontage road, R-5 access, and the Anaverde Creek erosion protection) shall not exceed 10 acres of grading on any given day. 4.2-2 The internal haul road from the scale house into the landfill shall be incrementally paved with asphalted concrete or equivalent as depicted on Figure 4.2-1. 4.2-3 Because of the potential for fugitive dust emissions from Project Specific ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 1.0 INTRODUCTION * Many of the project impacts are reduced by the project’s required compliance with landfill design and operating regulations, city/agency standards and regulations related to construction/development projects and/or by the incorporation of project design measures as noted in this table. Only the proposed project mitigation measures have been numbered to facilitate the distinction between mitigation measures, regulation compliance, and design measures. MARCH 2011 1-11 RESPONSE TO COMMENTS/FINAL EIR Impact Mitigation Measures/Regulation Compliance/Design Measures * Scope the proposed landfill to cause a public nuisance or exacerbate PM10 non-attainment status within the Antelope Valley, dust generated by project activities shall be kept to a minimum and prevented from dispersing offsite. The project shall comply with all best available control measures of existing AVAQMD Rule 403, or any of its possible near future control measure enhancements. The project size is not sufficient to require preparation and approval of a formal fugitive dust control plan (DCP) as it is less than 100 acres of simultaneous disturbance. However, because of the non- attainment status of the air basin and the cumulative significance of continued elevated levels of PM-10 emissions, a DCP shall be prepared and submitted to the AVAQMD for their review and approval. The elements of such a plan are already part of site operational procedures. The preparation and implementation of a dust control plan is designed to create a CUP compliance evaluation mechanism to further protect the nearest existing and future residents. The elements of such a plan would likely include: a. Water trucks or fixed sprinkler systems shall be used to keep all areas of vehicle movement damp enough to prevent dust from leaving the site. b. Areas to be graded or excavated shall be watered before commencement of the grading or excavation operations. Application of water must penetrate sufficiently to minimize fugitive dust during grading activities. ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 1.0 INTRODUCTION * Many of the project impacts are reduced by the project’s required compliance with landfill design and operating regulations, city/agency standards and regulations related to construction/development projects and/or by the incorporation of project design measures as noted in this table. Only the proposed project mitigation measures have been numbered to facilitate the distinction between mitigation measures, regulation compliance, and design measures. MARCH 2011 1-12 RESPONSE TO COMMENTS/FINAL EIR Impact Mitigation Measures/Regulation Compliance/Design Measures * Scope c. All graded and excavated material, exposed soil areas, and active portions of the landfill, including on- site roadways, shall be treated to prevent fugitive dust. Treatment shall include, but not be limited to, periodic watering, application of environmentally safe soil stabilization materials, and/or roll compaction as appropriate. Watering shall be done as often as necessary to prevent fugitive dust from leaving the landfill site. d. Signs shall be posted on-site limiting traffic to speeds of 15 mph or less on unpaved roads and 25 mph on paved roads. e. During periods of high winds wind speed sufficient to cause fugitive dust to impact adjacent properties), all clearing, grading, earth moving, and excavation operations shall be curtailed to the degree necessary to prevent fugitive dust created by on-site activities and operations from being a nuisance or hazard, either off-site or on-site. Impact 4.2-2 – Long-term Mobile Source Exhaust Emissions Mobile source project related exhaust emissions (see Table 4.2-4) will result from on- and off-site heavy equipment, truck hauling operations, and employee commuting. Less than significant with regulation No mitigation required. The project will continue to comply with California Air Resources Board on- and off-road equipment source control programs and with the California EMFAC emission control program. Project Specific ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 1.0 INTRODUCTION * Many of the project impacts are reduced by the project’s required compliance with landfill design and operating regulations, city/agency standards and regulations related to construction/development projects and/or by the incorporation of project design measures as noted in this table. Only the proposed project mitigation measures have been numbered to facilitate the distinction between mitigation measures, regulation compliance, and design measures. MARCH 2011 1-13 RESPONSE TO COMMENTS/FINAL EIR Impact Mitigation Measures/Regulation Compliance/Design Measures * Scope compliance. Impact 4.2-3 – Long-term Operational Potential for PM-10 emission increases related to excavation hauling, spreading, and compaction of cover material. Less than significant with mitigation and regulation compliance. The landfill will continue to comply with AVAQMD Rules 401, 402, and 403 prohibiting creation of visible emissions and/or a nuisance from dust. Mitigation Measures 4.2-1, 4.2-2, and 4.2-3 above. No additional mitigation measure required. Project Specific Impact 4.2-4 – Long-term Landfill Gas Potential impact related to increased subsurface landfill gas production. Less than significant. No mitigation required. The landfill will continue to comply with AVAQMD Rule 1150.1 and New Source Performance Standards (NSPS) governing control of gaseous emissions from landfills. The LFG collection/disposal system constitutes best available control technology (BACT) and will be expanded as necessary consistent with Title 27 of CCR. Project Specific Impact 4.2-5 – Long-term Odor Potential for additional landfill gas from increased daily tonnage to cause odor. Less than significant with mitigation and design measures/ improvements to ensure regulation compliance. Implementation of project design measures / components landfill gas system), developed consistent with Title 27 and AVAQMD Rules 401 and 402, will reduce the potential odor impacts to less than significant levels. 4.2-4 If an odor nuisance problem should develop, appropriate control measures shall be employed such as applying additional cover material or more frequent application of the cover material to seal the surface, or adjustments to the landfill gas collection system. Project Specific Impact 4.2-6 –GHG Emissions Potential conflict with AB-32 or potential to generate GHG emissions that may have a significant impact on climate The recommended mitigation measures to reduce hauling and disposal related GHG exhaust emissions are: 4.2.5 The applicant shall include the following set of measures Project Specific & Cumulative ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 1.0 INTRODUCTION * Many of the project impacts are reduced by the project’s required compliance with landfill design and operating regulations, city/agency standards and regulations related to construction/development projects and/or by the incorporation of project design measures as noted in this table. Only the proposed project mitigation measures have been numbered to facilitate the distinction between mitigation measures, regulation compliance, and design measures. MARCH 2011 1-14 RESPONSE TO COMMENTS/FINAL EIR Impact Mitigation Measures/Regulation Compliance/Design Measures * Scope change. Less than significant with mitigation. that, working together, will reduce operational greenhouse gas emissions of the project and the project’s potential effects on climate change: • Hauling trucks shall be powered by liquefied natural gas (LNG), Compressed Natural Gas (CNG), or ultra- low sulfur diesel fuel. • Idling of heavy-duty hauling trucks in excess of five minutes, and idling of off-road mobile sources of any type in excess of five minutes shall be prohibited. • When new landfill equipment is purchased by WMI, new commercially available equipment shall be purchased that exceeds California’s emission standards in effect at the time of purchase. • Onsite vehicles and equipment shall be properly maintained by being serviced at least every 90 days and once annually in compliance with Department of Transportation (DOT) requirements. • Operation equipment used for the proposed project shall use clean alternative non-diesel/biodiesel) fuels, or use equipment that has been retro-fitted with diesel particulate reduction traps or equivalent control technology, using equipment certified by CARB. • For the purchase of primary heavy duty, diesel powered landfill equipment at WMI (dozers and compactors), if equipment meeting California’s 2014 ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 1.0 INTRODUCTION * Many of the project impacts are reduced by the project’s required compliance with landfill design and operating regulations, city/agency standards and regulations related to construction/development projects and/or by the incorporation of project design measures as noted in this table. Only the proposed project mitigation measures have been numbered to facilitate the distinction between mitigation measures, regulation compliance, and design measures. MARCH 2011 1-15 RESPONSE TO COMMENTS/FINAL EIR Impact Mitigation Measures/Regulation Compliance/Design Measures * Scope emission standards for off-highway, heavy duty diesel equipment is commercially available before 2014, WMI shall purchase such equipment as older equipment is replaced. 4.2-6 Within one year of project approval, the applicant shall develop, and submit to the City, a Greenhouse Gas Reduction Plan that demonstrates how the AVPL will achieve by 2020 a reduction in annual GHG emissions such that emissions are no greater than 10 percent below 2006 levels and will meet or exceed all regulatory requirements related to GHG control. The Reduction Plan shall include one or more of the following measures, or combination thereof: • Use of alternative fuels, including but not limited to CNG, LNG, B-5 or B-20 Biodiesel in on-site equipment and in heavy duty truck fleets (and as a condition of future contract approvals if third-party haulers are used); • Use of hybrid, LNG, CNG or other similarly effective alternative fuel in hauling trucks; • Use of Best Available Control Technology and BMPs when designating new waste disposal cells by designing any additional gas collectors in bottom liner systems) and to increase gas combustion capacity/improve flare destruction efficiency; • Begin the process of developing, for construction and operation, a landfill gas-to-energy (LFGTE) or landfill gas ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 1.0 INTRODUCTION * Many of the project impacts are reduced by the project’s required compliance with landfill design and operating regulations, city/agency standards and regulations related to construction/development projects and/or by the incorporation of project design measures as noted in this table. Only the proposed project mitigation measures have been numbered to facilitate the distinction between mitigation measures, regulation compliance, and design measures. MARCH 2011 1-16 RESPONSE TO COMMENTS/FINAL EIR Impact Mitigation Measures/Regulation Compliance/Design Measures * Scope to LNG or CNG plant in the future for use in fueling on- and off-road vehicles, operating equipment or for energy use when: for a LFGTE project, the AVPL generates 1,200 scfm of landfill gas at 50 percent or better methane quality consistently for six months; for or CNG plant, the AVPL generates 2,500 scfm at 50 percent or better methane quality consistently for six months; • Increased diversion of organic material from landfill disposal and use as landfill cover material; • Increased recycling and carbon offsets if available through an adopted program the Western Climate Initiative); • The plan shall include cost estimates for GHG reduction measures and identify funding sources. The plan shall include an implementation schedule that demonstrates substantial GHG emission reductions prior to the 2020 deadline, including implementation of “Early action” measures that may be implemented within three years of plan approval. The plan shall include an updated inventory of projected GHG emissions and an updated estimate of GHG emissions in 1990. The plan shall be subject to review and approval by AVAQMD. 4.2-7 Following closure of the landfill, the applicant shall continue to operate, maintain, and monitor the landfill gas collection and treatment system as long as the landfill continues to produce landfill gas, or until it is determined by the AVAQMD to ensure that emissions do not ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 1.0 INTRODUCTION * Many of the project impacts are reduced by the project’s required compliance with landfill design and operating regulations, city/agency standards and regulations related to construction/development projects and/or by the incorporation of project design measures as noted in this table. Only the proposed project mitigation measures have been numbered to facilitate the distinction between mitigation measures, regulation compliance, and design measures. MARCH 2011 1-17 RESPONSE TO COMMENTS/FINAL EIR Impact Mitigation Measures/Regulation Compliance/Design Measures * Scope significantly contribute to additional greenhouse gas emissions. Impact 4.2-7 – Cumulative Potential impact to NOX and PM-10 due to cumulative growth and developments in the surrounding area. The Mojave Air Basin is non-attainment for ozone and PM-10. ROG and NOX are ozone formation precursor compounds. Any increase in emissions, even at below- threshold levels will retard attainment of applicable standards. Significant and unavoidable. Mitigation Measures 4.2-1 through 4.2-3, above. No additional mitigation available. Cumulative 4.3 Hydrology and Water Quality Impact 4.3-1 - Post-Development Hydrology/ Flooding Potential for post-development flows during flooding events not meeting the 85% pre-development attenuation criteria of 226 cfs. Less than significant with design measures/ improvements to meet City requirements. Design improvements included in the Stormwater Management Plan two retention/detention basins) and Surface Water Control Plan shall be implemented so that post-development flows will be reduced to less than 85% of the pre-development flows (peak post-development flow estimated to be 160 cfs). Project Specific Impact 4.3-2 - Scour/Erosion of Creek Potential for erosion at the north bank of the Anaverde Creek. Less than significant with mitigation. 4.3-1 The final design for the Anaverde Creek Scour Protection System shall be developed by a qualified engineer to comply with the City of Palmdale engineering design requirements. The construction of the approved Scour Protection System shall be completed in conjunction with Project Specific ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 1.0 INTRODUCTION * Many of the project impacts are reduced by the project’s required compliance with landfill design and operating regulations, city/agency standards and regulations related to construction/development projects and/or by the incorporation of project design measures as noted in this table. Only the proposed project mitigation measures have been numbered to facilitate the distinction between mitigation measures, regulation compliance, and design measures. MARCH 2011 1-18 RESPONSE TO COMMENTS/FINAL EIR Impact Mitigation Measures/Regulation Compliance/Design Measures * Scope Landfill II and the wedge expansion in accordance with the CUP Conditions of Approval. Impact 4.3-3 - Runoff and Surface Water Quality Potential contamination of the Anaverde Creek and surface water quality. Less than significant with design measures / improvements SMP and SWCP) to ensure regulation compliance. Implementation / construction of the proposed Stormwater Management Plan (SWMP) and Surface Water Control Plan (SWCP) will be developed consistent with all NPDES requirements for the entire site. Potential impacts to surface water quality will be reduced to less than significant levels. Project Specific Impact 4.3-4 - Groundwater Quality Potential for groundwater quality impacts. Less than significant with design measures/ improvements to ensure regulation compliance. Implementation of project design measures / components Leachate Collection and Removal System, Composite Liner System and Groundwater Monitoring System), developed consistent with Title 27 and NPDES requirements, will reduce the potential groundwater quality impacts to less than significant levels. Project Specific Impact 4.3-5 - Cumulative Flooding Potential impact to regional flooding due to cumulative total of developments in the surrounding area. Less than significant with design measures/improvements to meet City requirement. All other cumulative developments must also meet the City’s standard requirement that post-development flows cannot exceed 85% of the pre-development flows. Cumulative Impact 4.3-6 - Cumulative Water Quality Potential impact to regional water quality (related to runoff, scour) due to the All other cumulative developments must comply with City ordinances to reduce urban pollutants, NPDES, and BMPs, which include implementing debris/detention basins and oil- water separation filtration systems (where appropriate) for Cumulative ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 1.0 INTRODUCTION * Many of the project impacts are reduced by the project’s required compliance with landfill design and operating regulations, city/agency standards and regulations related to construction/development projects and/or by the incorporation of project design measures as noted in this table. Only the proposed project mitigation measures have been numbered to facilitate the distinction between mitigation measures, regulation compliance, and design measures. MARCH 2011 1-19 RESPONSE TO COMMENTS/FINAL EIR Impact Mitigation Measures/Regulation Compliance/Design Measures * Scope cumulative total of development in the surrounding area. Less than significant with design measures/ improvements to ensure regulation compliance. stormwater and nuisance flows. 4.4 Biological Resources Impact 4.4-1 – Vegetation and Habitats Removal of existing Joshua and Juniper trees from the proposed expansion zone, 200-foot wide utility corridor, and new frontage road area. Less than significant with mitigation. 4.4-1 Prior to the removal of any Joshua/Juniper trees, the 1998 Desert Vegetation Preservation Plan (see Appendix E-2) prepared by FH&A shall be updated and approved by the City of Palmdale consistent with the City’s Desert Vegetation Ordinance. Project Specific Impact 4.4-2 – Vegetation and Habitats Potential impact related to 1.9 acres of CDFG jurisdictional area if work is performed within jurisdictional areas of Anaverde Creek and potential impact to habitat within Anaverde Creek by future runoff from the landfill. Less than significant with mitigation. 4.4-2 Pursuant to Section 1601 – 1603 of the California Fish and Game Code responsible agencies CDFG and Lahontan shall be notified and permits/approvals shall be obtained prior to any activities within, or encroachment upon delineated bed and bank of the Anaverde Creek along the southern margin of the Landfill property. 4.4-3 Prior to issuance of the landfill’s Waste Discharge Requirements (WDRs), the project engineer shall finalize erosion and siltation control plans and other BMPs, as necessary to prevent graded and cleared areas from being eroded, resulting in the transport of sediment to Anaverde Creek. Project Specific Impact 4.4-3 – Wildlife The removal of the native vegetation from No mitigation required. Project Specific ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 1.0 INTRODUCTION * Many of the project impacts are reduced by the project’s required compliance with landfill design and operating regulations, city/agency standards and regulations related to construction/development projects and/or by the incorporation of project design measures as noted in this table. Only the proposed project mitigation measures have been numbered to facilitate the distinction between mitigation measures, regulation compliance, and design measures. MARCH 2011 1-20 RESPONSE TO COMMENTS/FINAL EIR Impact Mitigation Measures/Regulation Compliance/Design Measures * Scope the project implementation has potential impacts to wildlife. The new roadway alignment will involve the possible removal of an active coyote den, located immediately adjacent to the realignment connection point with the existing City Ranch Road. Less than significant. Although no formal mitigation is required, appropriate displacement techniques to avoid harm to the occupants will be implemented prior to grading. Impact 4.4-4 – Wildlife Implementation of initial vegetation clearing during the breeding season of native birds could result in loss of nest impacts which would be in violation of the Federal Migratory Bird Treaty Act. Less than significant with mitigation. 4.4-4 Landfill expansion actions which directly affect vegetation formations initial vegetation cleaning) shall be initiated outside of the timing of the native bird nesting season (mid-April through mid-August) to avoid disturbing active nests, per provisions of the Migratory Bird Treaty Act and California Fish and Game Code. If initial vegetation disturbance and clearing cannot be performed outside of this window of non-breeding activity, then it shall be preceded by a thorough site/pre-construction surveys in coordination with DFG for active nests by a qualified biologist; nests found shall be flagged, and a perimeter fence installed at an appropriate distance (usually between 50 and 300 feet from the nest, depending upon species and terrain). No work shall be performed within the fenced areas until such time as the nests are determined to be inactive and the fledglings have left the area. Project Specific Impact 4.4-5 – Wildlife Potential impact to wildlife due to vegetation loss and potential peripheral effects (light, noise, movement) from the 4.4-5 Facility design and management practices shall be implemented to reduce the intensity of exterior and security lighting adjacent to habitat areas. Measures such as shielded, downward-directed exterior light Project Specific ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 1.0 INTRODUCTION * Many of the project impacts are reduced by the project’s required compliance with landfill design and operating regulations, city/agency standards and regulations related to construction/development projects and/or by the incorporation of project design measures as noted in this table. Only the proposed project mitigation measures have been numbered to facilitate the distinction between mitigation measures, regulation compliance, and design measures. MARCH 2011 1-21 RESPONSE TO COMMENTS/FINAL EIR Impact Mitigation Measures/Regulation Compliance/Design Measures * Scope landfill onto the adjacent habitats. Less than significant with mitigation. fixtures, use of sodium vapor or similar low-intensity bulbs (other than mercury vapor), shall be utilized. Security and activity lighting shall be directed onto target working face areas, and not into the creek channel. Impact 4.4-6 – Wildlife Corridors The proposed project will be aligned within the same upland area as the existing landfill and ancillary facilities and will not measurably reduce the passage of wildlife through that portion of Anaverde Creek corridor. Less than significant with mitigation. Mitigation Measure 4.4-2 and 4.4-5, above. 4.4-6 The final design of the “off-site” utility pole placement shall be outside of the bed and bank of the channel to permit free passage by the wildlife along the channel. Project Specific Impact 4.4-7 – Cumulative The project, in conjunction with other cumulative developments in the area, will result in cumulative losses of natural upland desert formations, native vegetation, and habitat values along Anaverde Creek and in the displacement effects to agency-listed CEQA-sensitive songbird and small mammal species. Less than significant with mitigation. Mitigation Measures 4.4-1 through 4.4-6, above. No additional mitigation required. Cumulative 4.5 Noise Impact 4.5-1 – Construction Noise Potential for an audible impact to existing residences as a result of landfill ancillary facility construction activities and the realignment of City Ranch Road (R-5 Construction activity for the realignment of City Ranch Road (R-5 access and the new frontage road) shall be limited between the hours of 6:30 a.m. and 8:00 p.m., Monday through Saturday only and excluding legal holidays in compliance with the City’s noise standards within the Municipal Code. Project Specific ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 1.0 INTRODUCTION * Many of the project impacts are reduced by the project’s required compliance with landfill design and operating regulations, city/agency standards and regulations related to construction/development projects and/or by the incorporation of project design measures as noted in this table. Only the proposed project mitigation measures have been numbered to facilitate the distinction between mitigation measures, regulation compliance, and design measures. MARCH 2011 1-22 RESPONSE TO COMMENTS/FINAL EIR Impact Mitigation Measures/Regulation Compliance/Design Measures * Scope access and the new frontage road). Less than significant with mitigation and regulation compliance. 4.5-1 In conjunction with grading permit issuance for construction of new frontage road and the realignment of City Ranch Road (R-5 access) and during grading and construction operations, the following mitigation measures shall be implemented for the project: a. All construction equipment, fixed or mobile, shall be equipped with properly operating and maintained mufflers, to the satisfaction of the City’s Public Works or Building Inspector. b. During construction of the new landfill access road, stationary construction equipment shall be placed such that emitted noise is directed away from sensitive noise receivers, to the extent practical, to the satisfaction of the City’s Public Works or Building Inspector. c. During construction of the new landfill access road and to the satisfaction of the City’s Public Works Inspector or Building Inspector, stockpiling and vehicle staging areas shall be located as far as practical from noise sensitive receptors during construction activities. Impact 4.5-2 - On-Road Hauling Noise Potential for significant off-site traffic noise impacts related to increased hauling trucks. Less than significant. No mitigation required. Project Specific Impact 4.5-3 - Operational Noise The proposed project would not exceed the City of Palmdale Project Specific ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 1.0 INTRODUCTION * Many of the project impacts are reduced by the project’s required compliance with landfill design and operating regulations, city/agency standards and regulations related to construction/development projects and/or by the incorporation of project design measures as noted in this table. Only the proposed project mitigation measures have been numbered to facilitate the distinction between mitigation measures, regulation compliance, and design measures. MARCH 2011 1-23 RESPONSE TO COMMENTS/FINAL EIR Impact Mitigation Measures/Regulation Compliance/Design Measures * Scope Potential for operation noise impacts to existing and future residences as a result of the expanded landfill hours for receipt of refuse and the on-site heavy equipment used in earthmoving activities and the compaction processes. Less than significant with mitigation and regulation compliance. Noise Element or Municipal Code for anticipated site uses. However, because single-event operational noise may be intrusive even if standards are not exceeded, noise protection is recommended as follow. 4.5-2 Operational activities before 6:00 a.m. or after 8:00 p.m. shall be restricted as follows: a. No receipt of refuse or unloading activities shall be conducted during those hours. b. No heavy equipment operation within 1,000 feet of any residence under clear line-of-sight conditions shall take place during those hours. c. No bird repellent activity sound generators shall occur before 7:00 a.m. or after 8:00 p.m. Impact 4.5-4 – Cumulative On-Road Hauling Noise Potential for cumulative noise impacts as a result of expanded landfill truck traffic and future cumulative growth in year 2007. Less than significant. No mitigation required. Cumulative Impact 4.5-5 – Cumulative Construction Noise Potential for cumulative noise impacts as a result of the construction activities for the landfill ancillary facilities and the Construction of the project ancillary facilities and other cumulative developments shall be limited between the hours of 6:30 a.m. and 8:00 p.m., Monday through Saturday only and excluding legal holidays in compliance with the City’s noise standards within the Municipal Code. Cumulative ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 1.0 INTRODUCTION * Many of the project impacts are reduced by the project’s required compliance with landfill design and operating regulations, city/agency standards and regulations related to construction/development projects and/or by the incorporation of project design measures as noted in this table. Only the proposed project mitigation measures have been numbered to facilitate the distinction between mitigation measures, regulation compliance, and design measures. MARCH 2011 1-24 RESPONSE TO COMMENTS/FINAL EIR Impact Mitigation Measures/Regulation Compliance/Design Measures * Scope realignment of City Ranch Road (R-5 access and the new frontage road) in conjunction with the landfill expansion operational activities and construction of projects in the surrounding area. Less than significant with mitigation and regulation compliance. Mitigation measures 4.5-1 and 4.5-2, above. No additional mitigation measure required. 4.6 Aesthetics / Light and Glare Impact 4.6-1 – Scenic Resources/Visual Qualities Potential impacts to scenic resources related to the proposed 11-acre wedge expansion/reconfiguration, 60-foot height increase and new landfill access roadway. Less than significant with mitigation. 4.6-1 Interim vegetative cover shall be established as land filling proceeds to help offset visual impacts prior to application of final cover and vegetation at landfill closure. This interim measure provides that the outer southerly facing slopes shall receive cover material consistent with native species of the surrounding terrain as the phased development continues with application at appropriate intervals but at a minimum of every two to four year. Interim vegetation plant densities/seed mix shall be completed consistent with the baseline study to be conducted prior to the beginning of land filling operations in the expansion area. 4.6-2 Final design of the access roadway shall comply with Policy ER 3.1.2, to the extent feasible, to reduce the visual impact to the existing ridgeline as viewed from Tierra Subida and Rayburn Road. Project Specific Impact 4.6-2 - Litter Potential for significant aesthetic impacts related to litter. Less than significant with mitigation. 4.6-3 During conditions of severe wind, operating hours shall be limited, size of the working face shall be reduced, and completed cells shall be covered. Project Specific ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 1.0 INTRODUCTION * Many of the project impacts are reduced by the project’s required compliance with landfill design and operating regulations, city/agency standards and regulations related to construction/development projects and/or by the incorporation of project design measures as noted in this table. Only the proposed project mitigation measures have been numbered to facilitate the distinction between mitigation measures, regulation compliance, and design measures. MARCH 2011 1-25 RESPONSE TO COMMENTS/FINAL EIR Impact Mitigation Measures/Regulation Compliance/Design Measures * Scope 4.6-4 During landfill operations and after construction activity, personnel shall conduct periodic litter cleanup along, 1) the access roadway(R-5 access) and adjacent land from the scales to Tierra Subida Avenue and 2) properties adjacent to the landfill. The goal is to ensure that stray litter (including litter that is illegally dumped along the landfill access road) is immediately removed when strong winds occur. Impact 4.6-3 – Light and Glare Potential increase in light and glare associated with the new ancillary uses. Potential cumulative light and glare impacts in conjunction with other cumulative developments in the area. Less than significant with mitigation. Mitigation Measure 4.4-5 in Section 4.4 (Biological Resources), above. No additional mitigation measure is required. Project-Specific Cumulative Impact 4.6-4 Cumulative Potential cumulative aesthetic impacts, in conjunction with existing Landfill I, permitted Landfill II, and other cumulative developments in the area. Significant and unavoidable. Mitigation Measures 4.6-1 through 4.6-3, above. No additional mitigation measure is available. Cumulative 4.7 Traffic and Circulation Impact 4.7-1 - Existing Plus Project Volume to Capacity (V/C) Ratios/Roadway Links Potential impact to level of service (LOS) on roadway links in the vicinity of the site. Less than significant. No mitigation required. Project Specific ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 1.0 INTRODUCTION * Many of the project impacts are reduced by the project’s required compliance with landfill design and operating regulations, city/agency standards and regulations related to construction/development projects and/or by the incorporation of project design measures as noted in this table. Only the proposed project mitigation measures have been numbered to facilitate the distinction between mitigation measures, regulation compliance, and design measures. MARCH 2011 1-26 RESPONSE TO COMMENTS/FINAL EIR Impact Mitigation Measures/Regulation Compliance/Design Measures * Scope Impact 4.7-2 - Existing Plus Project Intersection Capacity Utilization (ICU)/Levels of Service (LOS) Potential impact to LOS at intersections in the vicinity of the site. Less than significant. No mitigation required. Project Specific Impact 4.7-3 – Sight Distance Potential for restricted sight distance for southbound vehicles on Tierra Subida Avenue approaching City Ranch Road. Less than significant with mitigation. 4.7-1 The City of Palmdale shall approve the final roadway design for the new landfill access and periodically review traffic operations in the vicinity of the project once the project is constructed to assure that the traffic operations are satisfactory. The future landfill access road alignment shall be along R-5 as a two lane roadway (60-foot right-of-way). R-5 shall intersect a new frontage road. The R-5 access road shall be constructed as a two lane roadway (60-foot right-of-way). The future landfill access road alignment shall also be along the new frontage road that would connect with City Ranch Road and intersect Tierra Subida at Rayburn Road, and create a 4-way signalized intersection, and construction the remaining access road along the R-5 dedicated right-of-way (Figure 4.7-13, Proposed Realignment of City Ranch Road to be Opposite Rayburn Road at Tierra Subida Avenue and 4.7-14, Proposed City Ranch Road Roadway Cross-Section). Project Specific ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 1.0 INTRODUCTION * Many of the project impacts are reduced by the project’s required compliance with landfill design and operating regulations, city/agency standards and regulations related to construction/development projects and/or by the incorporation of project design measures as noted in this table. Only the proposed project mitigation measures have been numbered to facilitate the distinction between mitigation measures, regulation compliance, and design measures. MARCH 2011 1-27 RESPONSE TO COMMENTS/FINAL EIR Impact Mitigation Measures/Regulation Compliance/Design Measures * Scope Preliminary design of the frontage road calls for a 40-foot roadway measured from curb to curb, with an 8-foot sidewalk adjacent to the west curb and a 10-foot- minimum buffer between the east curb and the ultimate location of the west sidewalk of Tierra Subida proper. The new realignment of the landfill access (new frontage road) shall accomplish the following:  Improve sight distance and related operational safety.  Improve horizontal and vertical alignment.  Wider lanes will result at the Tierra Subida Avenue/Rayburn Road intersection than at the existing City Ranch Road intersection.  Improve traffic signal spacing along Tierra Subida Avenue. 4.7-2 The applicant shall construct right-of-way and traffic signal improvements at the intersection of the landfill access road at Rayburn Road (see Figure 4.7-13) in conjunction with Landfill II and the wedge expansion in accordance with the CUP Conditions of Approval. 4.7-3 During landfill operations, worker-rideshare and transit plans shall be encouraged by the landfill operator consistent with the goals of the Air Quality Management Plan. 4.7-4 The applicant shall pay traffic impact fees in accordance with the City Traffic Impact Fee Ordinance. Credits shall be applied consistent with the Ordinance for the improvements (see Mitigation Measure 4.7-2) installed ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 1.0 INTRODUCTION * Many of the project impacts are reduced by the project’s required compliance with landfill design and operating regulations, city/agency standards and regulations related to construction/development projects and/or by the incorporation of project design measures as noted in this table. Only the proposed project mitigation measures have been numbered to facilitate the distinction between mitigation measures, regulation compliance, and design measures. MARCH 2011 1-28 RESPONSE TO COMMENTS/FINAL EIR Impact Mitigation Measures/Regulation Compliance/Design Measures * Scope by the applicant. Impact 4.7-4 – State Route 14 Freeway Potential impact to SR-14 from project and cumulative growth, south of Avenue S. Less than significant. No mitigation required. Project Specific Impact 4.7-5 – Cumulative Year 2007 Volumes to Capacity Ratios Potential impact to LOS for Tierra Subida Avenue between 5th Street West and Rayburn Road for Year 2007 without project and with project traffic conditions. Project’s contribution to cumulative impact is less than significant with mitigation. Cumulative impact remains significant and unavoidable. Mitigation Measures 4.7-1 through 4.7-4, above. This significant cumulative impact will remain until such time that Tierra Subida is widened to its ultimate General Plan designation. Cumulative Impact 4.7-6 – Cumulative Year 2007 Intersection Capacity Utilization (ICU) Potential cumulative impact to LOS for intersections in the vicinity of the site during peak hours for the Year 2007 without project traffic conditions. Potential cumulative impact to LOS for intersections for the Year 2007 with project traffic conditions, during the peak hours for average and peak inflow of material traffic conditions. No mitigation required. Cumulative ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 1.0 INTRODUCTION * Many of the project impacts are reduced by the project’s required compliance with landfill design and operating regulations, city/agency standards and regulations related to construction/development projects and/or by the incorporation of project design measures as noted in this table. Only the proposed project mitigation measures have been numbered to facilitate the distinction between mitigation measures, regulation compliance, and design measures. MARCH 2011 1-29 RESPONSE TO COMMENTS/FINAL EIR Impact Mitigation Measures/Regulation Compliance/Design Measures * Scope Less than significant. 4.8 Risk of Upset and Human Health Impact 4.8-1 Household Hazardous Waste Potential impact related to household hazardous waste and radioactive waste. Less than significant with mitigation. 4.8-1 The permittee shall maintain a comprehensive waste load checking program, which shall include the following: a. All waste hauling vehicles shall be screened at the scales with a radiation detector device acceptable to the Local Enforcement Agency for the presence of radioactive materials. b. Sensors capable of detecting volatile organic compounds, acceptable to the Local Enforcement Agency shall be available and used as directed by the Local Enforcement Agency. c. A remote television monitor or an alternative procedure acceptable to the Local Enforcement Agency shall be maintained at the scales to visually inspect incoming roll- off type loads and open top vehicles. d. The dumping area shall be continuously inspected for hazardous and liquid waste and radioactive waste/materials. This inspection shall be accomplished by equipment operators and spotters who have been trained in an inspection program approved by the Local Enforcement Agency (LEA). The landfill currently complies with the LEA inspection procedures and will continue to comply as required by their SWFP. e. Manual inspection of randomly selected refuse loads Project Specific ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 1.0 INTRODUCTION * Many of the project impacts are reduced by the project’s required compliance with landfill design and operating regulations, city/agency standards and regulations related to construction/development projects and/or by the incorporation of project design measures as noted in this table. Only the proposed project mitigation measures have been numbered to facilitate the distinction between mitigation measures, regulation compliance, and design measures. MARCH 2011 1-30 RESPONSE TO COMMENTS/FINAL EIR Impact Mitigation Measures/Regulation Compliance/Design Measures * Scope shall be conducted. The frequency of inspections shall be as directed by the Local Enforcement Agency. The checking program shall be conducted by personnel trained in accordance with a plan approved by the Local Enforcement Agency. Additionally, as part of the proposed project, the entrance to the facility is equipped with monitors to detect radioactive waste. Impact 4.8-2 Cumulative Potential cumulative impact related to increased household waste. Less than significant with mitigation. Mitigation Measure 4.8-1, above. No additional mitigation measure required. Cumulative ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 1.0 INTRODUCTION MARCH 2011 1-31 RESPONSE TO COMMENTS/FINAL EIR 1.5 ADDITIONAL ENERGY INFORMATION 1.5.1 INTRODUCTION CEQA requires lead agencies to consider the potential energy impacts of proposed projects in their environmental impact reports (EIRs), with particular emphasis on avoiding or reducing inefficient, wasteful, and unnecessary energy consumption. (See Appendix F (Energy Conservation); see also Pub. Resources Code, § 21100(b)(3) (mitigation measures required for significant adverse impacts of a project to consider ability to reduce wasteful, inefficient, and unnecessary consumption of energy).) Amendments to the CEQA Guidelines, effective March 18, 2010, made it clear that any “[p]otentially significant energy implications of a project shall be considered in an EIR to the extent relevant and applicable to the project. (Appendix F As part of this mandate, lead agencies may also consider the extent to which an energy source serving the project has already undergone environmental review that adequately analyzed and mitigated the effects of energy production. (Appendix F The potential for significant energy impacts from the proposed project was considered in the Initial Study originally prepared for the project. (See IS, pp. 42-43 contained in Appendix A-1 of the Draft EIR.) The Initial Study, using a CEQA/Environmental Checklist and Appendix F of the CEQA Guidelines, current at the time the Initial Study was prepared, considered whether the project would result in: the use of substantial amounts of fuel or energy? Or a substantial increase in demands upon existing sources of energy, or require the development of new sources of energy? (IS, pp. 42-43 contained in Appendix A-1 of the Draft EIR.) Reaching “no impact” conclusions, the Initial Study explained that although the refuse footprint would be increased by 11 acres under the project, the daily intake of refuse would not increase over permitted levels within the existing County CUP. Thus, energy demands to transport refuse would not be increased over what was already approved. The Initial Study also recognized the benefits of the on-site LNG fueling station as well as WM’s efforts to convert its hauling fleet to LNG or CNG. For these reasons, the Initial Study concluded that the proposed project would not have a significant impact on the environment from additional energy consumption and that no additional analysis was required in the EIR. In response to comments received on the revised and recirculated “Amendment” to the DEIR, the Final EIR includes additional information on energy. (See Section 3.0, Responses to Comments, specifically responses 12-16 and 12-17.) In addition, the following background and additional information is included in the EIR for the decisionmakers consideration. ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 1.0 INTRODUCTION MARCH 2011 1-32 RESPONSE TO COMMENTS/FINAL EIR 1.5.2 ADDITIONAL ENERGY BACKGROUND/REGULATORY FRAMEWORK Federal Energy Independence and Security Act of 2007 On December 19, 2007, the Energy Independence and Security Act of 2007 (EISA) was signed into law. In addition to setting increased Corporate Average Fuel Economy (CAFE) standards for motor vehicles, the EISA includes other provisions related to energy efficiency: • Renewable Fuel Standard (RFS) (Section 202). • Appliance and Lighting Efficiency Standards (Sections 301–325). • Building Energy Efficiency (Sections 411–441). Additional provisions of the EISA address energy savings in government and public institutions, promoting research for alternative energy, additional research in carbon capture, international energy programs, and the creation of “green jobs”. State Title 24 Energy Efficiency Standards California’s Energy Efficiency Standards for Residential and Non-residential Buildings were established in 1978 in response to a mandate to reduce the State’s energy consumption. These standards are promulgated under CCR, Title 24, Part 6, and are commonly referred to as “Title 24”. The Title 24 standards are periodically updated to reflect new or improved energy efficiency technologies and methods. The 2008 Title 24 standards have been adopted and apply to any project requesting a building permit on or after August 1, 2009. A new development project is required to incorporate the most recent Title 24 standards in effect at the time the building permit application is submitted.1 1.5.3 EXISTING CONDITIONS According to the U.S. Department of Energy, in 2007, California’s total energy consumption— including for electricity generation—was 8,491.5 trillion British thermal units (Btu), representing approximately 8 percent of the United State’s energy consumption (USDOE 2007). The major sources of consumed energy were petroleum (46.5 percent) and natural gas (28.7 percent). Other sources include coal, nuclear electric power, hydroelectric power, geothermal power, and biomass. Approximately 18 percent of this energy was consumed by residential users, 19 1 Please also refer to Section 3.0, Response to Comments, specifically responses 2-16 and 2-17, re: Greenhouse Gas Emissions. ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 1.0 INTRODUCTION MARCH 2011 1-33 RESPONSE TO COMMENTS/FINAL EIR percent by commercial users, 23 percent by industrial users, and 40 percent by the transportation sector. In 2008, the California Energy Commission (CEC) found that California’s major sources of electricity were natural gas (46.5 percent), nuclear (14.9 percent), large hydroelectric (9.6 percent), coal (15.5 percent), and renewable sources (13.5 percent) (CEC 2009). Approximately 73.2 percent of California’s electricity is generated in state; approximately 8.4 percent comes from the Pacific Northwest; and approximately 18.4 percent comes from the Southwest (CEC 2009). As noted above, natural gas represents the largest source of electricity in California, and is the second-largest type of consumed fuel. Petroleum is the most-consumed source of energy in the state, and the transportation sector consumes approximately 40 percent of the State’s energy. The State’s natural gas comes from a variety of places. In 2007, approximately 12.9 percent came from California, 22.1 percent came from Canada, 24.2 percent came from the Rocky Mountains, and 40.8 percent came from the Southwest (CEC 2009). Similarly, the crude oil consumed in California comes from both in-state and out-of-state sources. In 2007, approximately 38.12 percent came from California, 13.41 percent came from Alaska, and 48.46 percent came from foreign countries (CEC 2009). Electricity Electrical service to the AVPL is provided through Southern California Edison (SCE). SCE is an independently owned utility that provides electrical power to a business and residential population of approximately 13 million people within a 50,000-square-mile service area that covers Central, Coastal, and Southern California, including the City of Palmdale and the AVPL. SCE distributes electricity purchased through the California Power Exchange. SCE is regulated by the California Public Utilities Commission (CPUC), which protects customers from overcharge and promotes energy efficiency, system reliability, and financial integrity of utilities. According to the CEC, the SCE service area experienced a peak demand of 19,408 megawatts (MW) in 2000 (CEC 2009). The CEC estimates that electricity consumption and peak demand within SCE’s service territory will continue to grow annually from 2010 to 2018 by 1.26 percent and 1.40 percent, respectively. In 2006, the CEC projected a peak demand in SCE’s service territory of 24,960 megawatts (MW) in 2012 and a net energy load of 125.2 million megawatt hours (MWH). In 2009, the CEC projected a peak energy demand of 24,543 MW in 2015 and a peak energy demand of 25,561 MW in 2018. SCE derives its electricity from a variety of sources, as shown in Table 1-2. Nearly half of its electricity comes from natural gas, with renewable resources constituting another nearly 20 percent. ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 1.0 INTRODUCTION MARCH 2011 1-34 RESPONSE TO COMMENTS/FINAL EIR TABLE 1-2 SOUTHERN CALIFORNIA EDISON POWER CONTENT Energy Resources 2009 SCE Power Mixa (Projected) Eligible Renewable 16% Biomass & Waste 2% Geothermal 9% Small Hydroelectric 1% Solar 1% Wind 3% Coal 10% Large Hydroelectric 5% Natural Gas 51% Nuclear 18% Other Total 100% a 98 percent of SCE System Power Mix is specifically purchased from individual suppliers. Source: SCE. Standard electricity generation rates used by SCE currently exist under tariff schedules General Service (GS-2) and Time-of-Use (TOU), as filed with the CPUC. The primary distribution voltage levels serving the City are 12,000 kilovolts (kV) for commercial and residential uses, 6,900 for residential tract housing, and 4,000 kV for rural residential uses. SCE currently has overhead and underground facilities at various locations that are capable of providing ongoing service to the Project and existing buildings. Propane Gas Four existing propane tanks provide gas service to the AVPL. One tank is used solely for backup of the maintenance building’s fire suppression system. The other tanks provide service to existing buildings at the AVPL. The existing tanks, which are served by a third party contractor, are adequate to provide continued service to the site under the proposed project, which would not result in an increase in buildings requiring additional gas service. The AVPL does not, and will not, have any effect on natural gas supplies. ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 1.0 INTRODUCTION MARCH 2011 1-35 RESPONSE TO COMMENTS/FINAL EIR 1.5.4 THRESHOLDS OF SIGNIFICANCE Appendix G of the CEQA Guidelines, Environmental Checklist Form, serves as a guideline of consequences that are deemed to have a significant effect on the environment. According to the Environmental Checklist, a project may be deemed to have a significant energy effect if it will: a. Result in substantial adverse physical impacts associated with the provision of new or physically altered energy transmission facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable levels of service. b. Conflict with any applicable plan, policy, or regulation of an agency with jurisdiction over the project (including, but not limited to the general plan, specific plan, local coastal program, or zoning ordinance) adopted for the purpose of avoiding or mitigating an environmental effect. 1.5.5 PROJECT IMPACTS Impact Summary A: No Impact/ Less Than Significant Impact. There are existing electrical and propane gas facilities within and adjacent to the Project site to continue serving the Site. SCE has the ability to continue serving the AVPL without adversely affecting their ability to continue serving the Project area. There would be no impact from additional demand for electric or gas services or infrastructure with implementation of the Project or Reduced Alternative as no new buildings requiring heating or air are proposed. Impact Summary B: Less Than Significant. The proposed Project includes an 11 acre expansion of an existing MSW landfill and will not cause a conflict with any applicable plan goals or policies. The 11 acre expansion will provide for an increase in overall landfill capacity. The AVPL is recognized as a long-term waste disposal facility by existing County and City plans, ordinances and General Plan policies. Therefore, the extended landfill operation will not cause conflict with applicable plans, goals, or policies. According to Appendix F (Energy Conservation) of the CEQA Guidelines, moreover, Environmental Impacts may also include, in part: 2. The effects of the project on local and regional energy supplies and on requirements for additional capacity. ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 1.0 INTRODUCTION MARCH 2011 1-36 RESPONSE TO COMMENTS/FINAL EIR As noted above, the proposed project would not require additional electrical or gas supplies and, as explained elsewhere in the EIR, would not cause the need for additional MSW disposal because such waste is already being generated with or without the proposed project. Under the recommended Reduced Project Alternative, moreover, there would be no daily increase in vehicles or waste tonnages over previously approved levels; thus, there is no need for new diesel equipment, vehicles, or the installation of new structures requiring new energy sources. As such, the project will not affect the energy supplies already existing at the site, create a need for substantial additional capacity, or otherwise create an additional burden on local or regional energy supplies 3. The effects of the project on peak and base period demands for electricity and other forms of energy. For the same reasons explained above, neither the proposed project nor the Reduced Project Alternative would affect peak or base period demands. 6. The project’s projected transportation energy use requirements and its overall use of efficient transportation alternatives. By providing the ability to continue disposal of MSW at AVPL, and providing for the logical expansion of the existing landfill to include the 11 acres at issue (thereby increasing the efficiency of construction and closure by eliminating the existing leap frog nature of Landfill I and Landfill II), adoption of the project, or Reduced Project Alternative, would ensure the efficient use of energy, including transportation fuels, from those activities which are already occurring. 1.5.6 MITIGATION MEASURES As noted above, there would be no impact/less than significant impacts from additional demand for electric or gas services or infrastructure with implementation of the Project or Reduced Alternative. In addition, the proposed Project would not cause a conflict with any applicable plan goals or policies. Therefore, no mitigation measures would need to be incorporated into the project. 1.5.7 CONCLUSION Under the recommended environmentally superior Reduced Project Alternative (11-acre expansion with no increase in daily permitted tonnage), moreover, the project would not create any inefficient, wasteful, or unnecessary consumption of energy. This is in part because there will be no increase in the existing permitted levels of operation daily tonnage rate) for disposal. It is also because the MSW disposed of at the AVPL must be disposed of somewhere. If not the AVPL it must be hauled to another site. The proposed project, by nature, does not ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 1.0 INTRODUCTION MARCH 2011 1-37 RESPONSE TO COMMENTS/FINAL EIR cause the need for additional MSW to be disposed of. Thus, energy consumption on a daily, weekly, or annual basis will not change over previously approved and existing levels for AVPL or for purposes of disposal elsewhere. No impact in the form of wasteful, inefficient or unnecessary consumption of energy would occur from approval of the proposed project or the Reduced Project Alternative. ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 1.0 INTRODUCTION MARCH 2011 1-38 RESPONSE TO COMMENTS/FINAL EIR This page left blank intentionally. ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 2.0 DECEMBER 2005 DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 2-1 RESPONSE TO COMMENTS/FINAL EIR 2.0 DECEMBER 2005 DRAFT EIR COMMENT LETTERS AND RESPONSES 2.1 WRITTEN COMMENTS/RESPONSES 2.1.1 INTRODUCTION This section provides responses to the written comments made on the Antelope Valley Public Landfill (AVPL) Draft EIR during the OPR published public review period of December 14, 2005 to January 27, 2006. The comment letters received on the December 2005 Draft EIR are numbered, as listed below, and are included in this section along with the formal responses prepared for the comments. To assist in referencing comments and responses, each specific comment is numbered and refers to a statement or paragraph in the corresponding letter. Where changes to the Draft EIR text result from response to comments, those changes are included in the response and demarcated with revision marks (underline for new text, strike-out for deleted text). Comments which present opinions about the project or which raise issues not directly related to the substance of the Draft EIR are noted without a detailed response. Comment-initiated revisions/clarifications to the EIR text are also provided and are demarcated with revision marks in Section 3.0, Changes to the Draft EIR of this document. 2.1.2 LIST OF COMMENTERS The comment letters received on the December 2005 Draft EIR are listed below (ten letters total). The paragraphs in the letters have been numbered and are referred to in the responses that directly follow the comment letter. Letter Agency/Signatory Date #1 Southern California Association of Governments, Brian Wallace January 9, 2006 #2 County of Los Angeles, Department of Public Works, Donald Wolfe January 11, 2006 #3 State of California, Health and Human Services Agency, Department of Health Services, Joseph E. Crisologo January 11, 2006 #4 California Integrated Waste Management Board, Raymond M. Seamans January 12, 2006 #5 Steve Schirmbeck, Local Citizen January 14, 2006 #6 State of California, Public Utilities Commission January 24, 2006 #7 State of California, Business, Transportation and Housing Agency, Department of Transportation, District 7, Cheryl J. Powell January 24, 2006 #8 County of Los Angeles, Department of Public ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 2.0 DECEMBER 2005 DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 2-2 RESPONSE TO COMMENTS/FINAL EIR Works, Donald L. Wolfe January 26, 2006 #9 California Regional Water Quality Control Board, Lahontan Region January 27, 2006 #10 State of California, Governor’s Office of Planning and Research, State Clearinghouse and Planning Unit January 30, 2006 The letter comments and responses follow. ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 2.0 DECEMBER 2005 DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 2-3 RESPONSE TO COMMENTS/FINAL EIR Letter No. 1 1-1 ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 2.0 DECEMBER 2005 DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 2-4 RESPONSE TO COMMENTS/FINAL EIR Response to Letter No. 1 Southern California Association of Governments – January 9, 2006 Response 1-1 The comment is acknowledged but does not raise any environmental issues; therefore, no response is required. ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 2.0 DECEMBER 2005 DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 2-5 RESPONSE TO COMMENTS/FINAL EIR Letter No. 2 2-1 ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 2.0 DECEMBER 2005 DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 2-6 RESPONSE TO COMMENTS/FINAL EIR Response to Letter No. 2 County of Los Angeles, Department of Public Works – January 11, 2006 Response 2-1 The comment is acknowledged but does not raise any environmental issues; therefore, no response is required. ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 2.0 DECEMBER 2005 DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 2-7 RESPONSE TO COMMENTS/FINAL EIR Letter No. 3 3-1 ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 2.0 DECEMBER 2005 DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 2-8 RESPONSE TO COMMENTS/FINAL EIR Letter No. 3, Continued 3-2 ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 2.0 DECEMBER 2005 DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 2-9 RESPONSE TO COMMENTS/FINAL EIR Letter No. 3, Continued ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 2.0 DECEMBER 2005 DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 2-10 RESPONSE TO COMMENTS/FINAL EIR Response to Letter No. 3 State of California, Health and Human Services Agency, Department of Health Services – January 11, 2006 Response 3-1 The comment regarding compliance with Department’s Criteria for the separation of water mains and non-portable pipelines is acknowledged. The project does not propose construction of a potable water tank. Additionally, as indicated in Section 3.0, Project Description, of the Draft EIR, no potable water facilities are proposed as part of the CUP for this landfill consolidation project. The comment regarding future developments (referred to on page 22 of the Initial Study), such as the Anaverde LLC and Ritter Ranch is acknowledged and has been addressed in the Draft EIR. Consistent with CEQA Guidelines Section 15130, the Draft EIR includes a description of cumulative projects and the scope utilized to analyze the potential impacts from and upon these projects is included within Section 3.5, Related Projects/Cumulative Approach Assumptions. Additionally, the impact of the proposed project on cumulative projects such as the Anaverde and Ritter Ranch is assessed in different sections of the Draft EIR, such as Noise (Section 4.5), Aesthetics (Section 4.6), and other sections, as appropriate. Response 3-2 The comment quotes pages 20, 22, and 23 of the Initial Study document that was prepared to focus the scope of the Draft EIR, which went into circulation on December 14, 2005 through January 27, 2006. The Draft EIR includes detailed information in the Earth Resources (Section 4.1) and Hydrology and Water Quality (Section 4.3) including the review and update of mitigation measures from the previous 1992 certified EIR which was prepared for the approval of Landfill. Please refer to Sections 4.1 and 4.3 of the Draft EIR. Additionally, no “Potential Contaminating Activities” (PCAs) are proposed as part of the project that would impact domestic production wells or any other potential sources of water supply surface water bodies such as maybe the Anaverde Creek.) Pages 4.3-12 through 4.3-17 along with Appendix D of the Draft EIR provide a detailed analysis of potential project impacts on surface water quality. This analysis concludes that the Anaverde Creek is an intermittent stream which flows only during peak flooding events. No evidence of surface water was observed in the reach of the creek south of the Landfill between November 2003 and May 2004. Although no surface water have been observed recently, a “Stormwater Management Plan” (SWMP) has been proposed to prevent contamination of the Anaverde Creek and surface waters. With implementation of the SWMP (see Figures 3-6, Stormwater Management Plan and 4.3-4, Post-Development Surface Water Control Plan and actions listed on page 4.3-14 to 4.3-15 of the Draft EIR), no impacts to surface water quality are anticipated. ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 2.0 DECEMBER 2005 DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 2-11 RESPONSE TO COMMENTS/FINAL EIR Letter No. 4 ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 2.0 DECEMBER 2005 DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 2-12 RESPONSE TO COMMENTS/FINAL EIR Letter No. 4, Continued ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 2.0 DECEMBER 2005 DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 2-13 RESPONSE TO COMMENTS/FINAL EIR Letter No. 4, Continued 4-1 4-2 4-3 ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 2.0 DECEMBER 2005 DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 2-14 RESPONSE TO COMMENTS/FINAL EIR Letter No. 4, Continued 4-4 4-5 4-6 4-7 ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 2.0 DECEMBER 2005 DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 2-15 RESPONSE TO COMMENTS/FINAL EIR Letter No. 4, Continued 4-8 4-9 4-10 4-11 4-12 ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 2.0 DECEMBER 2005 DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 2-16 RESPONSE TO COMMENTS/FINAL EIR Letter No. 4, Continued 4-12 ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 2.0 DECEMBER 2005 DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 2-17 RESPONSE TO COMMENTS/FINAL EIR Letter No. 4, Continued ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 2.0 DECEMBER 2005 DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 2-18 RESPONSE TO COMMENTS/FINAL EIR Response to Letter No. 4 California Integrated Waste Management Board – January 12, 2006 Response 4-1 Statement of Overriding Considerations The comment is acknowledged; consistent with Section 15093 of the CEQA Guidelines, a statement of overriding considerations has been prepared for the project cumulative unavoidable impacts related to Aesthetics, Air Quality, and Traffic. A copy of the statement will be forwarded to CalRecycle (referred to as the Board in 2006) upon finalization by the City of Palmdale. Response 4-2 Hours and Days of Operation The comment is acknowledged and accurately restates the proposed hours of operation. There is no “italicized” text included within the comment for which the Board is seeking a response. Response 4-3 Material Types The comment is acknowledged and accurately restates the proposed material/waste types. Although mentioned in the first full paragraph of page 3 of the Comment Letter there is no “italicized” text specific included within the comment for which the Board is seeking a response. Response 4-4 Landfill Building The comment is acknowledged. Any future structure sited above buried waste or within 1000 feet of buried waste will comply with Title 27 California Code of Regulations (27CCR) Section 21190. Response 4-5 Peak Tonnage The comment is acknowledged and accurately represents the proposed peak tonnages analyzed in the EIR. The peak tonnage of clean soil to be imported to the landfill will vary on a daily/weekly basis; however, it will still be within the 5,548 tpd, not exceeding that limit. ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 2.0 DECEMBER 2005 DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 2-19 RESPONSE TO COMMENTS/FINAL EIR Response 4-6 Recycling Drop-off/Transfer Center The proposed ancillary facility conceptually shown on Figure 1-5 of the Draft EIR would function as a “traditional” buyback recycling or drop-off recycling center for beverage containers. Response 4-7 Alternative Daily Cover The comment is acknowledged. As indicated on page 3-18 of the Draft EIR, “The waste cell is covered daily and compacted with a minimum of 6 inches of clean soil or with approved ADC material. Currently, tarps are approved for ADC use.” The operator is also currently looking at the possible use of green waste as an approved ADC material. As indicated in the EIR, the ADC would not be utilized without prior approval from the LEA. Response 4-8 Environmental Justice The comment is acknowledged. Although mentioned in the first full paragraph of page 3 of the Comment Letter there is no “italicized” text specific included within this comment for which the Board is seeking a response. The operator will review the Strategic Plan and will address the Environmental Justice component as it relates to the project prior to bringing the project to Cal Recycle for concurrence. Response 4-9 Odor Impact Minimization Plan (OIMP) The existing and proposed operation’s compostable material (greenwaste) is currently and will continue to be delivered from two sources: 1) grass clippings from curbside pickup programs, and 2) miscellaneous wood waste and brush. The curbside material (grass) will be utilized as approved alternative daily cover which is subsequently buried the following day. Miscellaneous wood waste and brush is ground and transported off-site, for energy conversion, within no more than 30-days of receipt of the raw material. These current operations which are proposed to continue with the project do not promote a composting character and therefore do not result in odor issues. Response 4-10 Peak Elevation The peak elevation of 3200 feet above sea levels, as indicated in the Draft EIR will include the final cover. ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 2.0 DECEMBER 2005 DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 2-20 RESPONSE TO COMMENTS/FINAL EIR Response 4-11 Mitigation Monitoring and Reporting Program Your comment is acknowledged. As part of the Final EIR, a Mitigation Monitoring and Reporting Program (MMRP) has been prepared in accordance with the CEQA Guidelines and is contained within Section 5.0 of this document. The MMRP was prepared pursuant to State of California Public Resources Code Section 21081.6. The City of Palmdale is the lead agency for the proposed project and, therefore, responsible for administering and implementing the MMRP. The MMRP includes the agencies designated to enforce mitigation measures, as described in the Draft EIR. Response 4-12 Summary The comment is acknowledged and will be forwarded to the decision-makers for their review and consideration. Although mentioned in the first full paragraph of page 3 of the Comment Letter there is no “italicized” text specific included within this comment for which the Board is seeking a response. ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 2.0 DECEMBER 2005 DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 2-21 RESPONSE TO COMMENTS/FINAL EIR Letter No. 5 5-1 5-2 5-3 5-4 5-5 5-6 ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 2.0 DECEMBER 2005 DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 2-22 RESPONSE TO COMMENTS/FINAL EIR Letter No. 5, Continued 5-7 5-8 5-9 ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 2.0 DECEMBER 2005 DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 2-23 RESPONSE TO COMMENTS/FINAL EIR Response to Letter No. 5 Steve Schirmbeck – January 14, 2006 Response 5-1 The comment is acknowledged and will be forwarded to the decision-makers for their review and consideration. With respect to the commentor’s statement regarding “extended noise hours of operation,” Section 4.5 of the Draft EIR provides a detailed analysis of project noise impacts (including operational noise). It should be noted that although the hours for the “receipt of refuse” are proposed to be expanded from 5:00 p.m. to 8:00 p.m. as part of this project, there are no changes proposed for the “landfill operational hours.” Noise associated with the expanded receipt of refuse hours from 6:00 p.m. to 8:00 p.m. traffic noise from delivery of refuse to scales) would fall well below the City of Palmdale Noise Standards. No significant noise impacts associated with the increased receipt of refuse hours are anticipated. If any noise nuisance were to be experienced at any existing or future residential uses, it would be more from single event noise rather than from hourly or daily average. Based upon the analysis of single event noise sources, the proposed project operations would not exceed the City of Palmdale Noise Standards. However, because single event noise sources may be intrusive even if standards are not exceeded, Mitigation Measure 4.5-2 is proposed to ensure noise levels remain at less than significant levels. Mitigation Measure 4.5-2: Operational activities before 6:00 a.m. or after 8:00 p.m. shall be restricted as follows: a. No receipt of refuse or unloading activities shall be conducted during those hours. b. No heavy equipment operation within 1,000 feet of any residence under clear line-of-sight conditions shall take place during those hours. c. No bird repellent activity using sound generators shall occur before 7:00 a.m. or after 8:00 p.m. Please refer to Section 3.3.2 of the Draft EIR which provides information on the “Future Demand and Project Needs.” This section explains the relationship between population growth and existing and future landfill operations and capacity. Lastly, as indicated in Section 4.6 of the Draft EIR, the proposed increase in the landfill’s hours of operation may assist in reducing the amount of incidental dumping which has occurred in the past along the landfill access road. ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 2.0 DECEMBER 2005 DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 2-24 RESPONSE TO COMMENTS/FINAL EIR Response 5-2 The Draft EIR including Technical Appendix G – Traffic Impact Analysis prepared by Kunzman Associates, contains the current daily and peak hourly averages of trucks, including tons per day. Please refer to Tables 4 of the traffic study and 4.7-4 of the Draft EIR – “Project Truck Traffic”; Table 5 of the traffic study– “Traffic Schedule for Antelope Valley Landfill Average and Peak Inflow of Material”; and Tables 6 of the traffic study and 4.7-5 of the Draft EIR – “Project Traffic Generation” for the request information. Response 5-3 As stated above in Response 5-1; the proposed extended hours are for the “Receipt of Refuse” and not bird abatement activity. Mitigation Measure 4.5-2 (see response 5-1 above) actually restricts bird abatement activity beyond what is currently permitted. Response 5-4 The purpose of a traffic impact analysis is to address exactly what the impact will be when the project traffic is added to existing and other approved project’s traffic. The Kunzman Associates traffic study and summary of it contained in Section 4.7 of the Draft EIR addresses these issues. Section 3.5 of the Draft EIR outlines the “Cumulative Project Approach Assumptions” for the analysis. To address cumulative projects, individual projects are accounted for at two levels. One is at the General Plan level where the ultimate land use and the ultimate circulation system are in harmony. At the intermediate level, between now and when individual approved projects are added, each project has to show that its traffic along with other traffic growth can be added to the existing system and that it will operate at acceptable levels. Response 5-5 As discussed in Section 3.0 of the Draft EIR, the AVPL currently has two fully permitted landfills within its property, Landfill I and Landfill II. As shown in Table 3-2 – “Existing/Permitted and Proposed Project Components,” Landfill I has a daily disposal limit of 1,400 tpd with a maximum permitted truck limit of 434 trucks or a total of 868 truck trips per day. Landfill II, which was permitted by the County CUP #98041, has a 1,800 tpd limit for buried waste and has no established limits on daily vehicle traffic. As shown in Table 3-2 and discussed in Section 4.7 of the EIR, the CEQA and supplemental traffic analysis prepared for Landfill II assumed up to 550 trucks or a total of 1,100 truck trips per day. The permitted and proposed average/peak total trip (trucks and cars) figures are shown in Table 4.7-1A. This table provides the total trip figures for what is currently permitted at Landfill II (1,460) versus what is proposed as part of this CUP (1,594). Response 5-6 Please refer to Section 7.2 – Long-Term Implications for the analysis requested in this comment. ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 2.0 DECEMBER 2005 DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 2-25 RESPONSE TO COMMENTS/FINAL EIR Response 5-7 Section 4.6 of the Draft EIR provides a detailed analysis of the visual impacts of the proposed project consistent with the CEQA Guidelines. The EIR analyses how the proposed expansion/reconfiguration project may impact the visual character of the area, and how visually compatible it would be with the surrounding development. With respect to General Plan Policy 3.1.5, which encourages retaining and maintaining the integrity of the natural ridgelines of Ritter Ridge, Portal Ridge, Verde Ridge, the Ana Verde Hills, the Sierra Pelona Mountains, and the lower foothills of the San Gabriel Mountains, the EIR concludes that the project will generally conform to this policy through project design and mitigation requirements. The proposed landfill expansion and access road project will respect the integrity of the natural ridgelines and seek to preserve the aesthetic character of the Antelope Valley. General Plan Objective CD 2.4 is to “Create a sense of arrival to Palmdale at major entrance points to the City, and enhance major focal points at designated locations throughout the City to create a unified sense of place.” The proposed project involves expanding the site by incorporating the gap of unused land between existing Landfills I and II by 11 acres. This proposed 11-acre increase in the landfill footprint would eliminate the valley between Landfills I and II once they are both filled. Thus, a more natural transition between the two landfills would result, and will create a more contiguous visual form consistent with the existing ridgeline. In addition, mitigation measures are included in Section 4.6 Aesthetics/Light & Glare of the Draft EIR to reduce the potential impacts to aesthetics to less than significant levels. Additionally, as indicated in the Draft EIR, Golder Associates worked closely with City staff to select a “reasonable range” of views to be included within the visual simulation analysis which is not required by CEQA. The nine locations which were selected from an array of existing photographic views provide a thorough representation of potentially impacted views for a project of this magnitude an 11-acre expansion, 60-foot height increase and new landfill access road). Based upon the visual simulation analysis, the EIR concluded the following, “It is evident from the visual simulations for permitted Landfill I and II and the proposed expansion/reconfiguration (Figures 4.6-2 through 4.6-10) that the difference between Conditions #2 and #3 (permitted Landfills I and II and the proposed expansion/reconfiguration) is minimal and hardly discernable through the simulations viewed from the north and east at view locations 1 through 5 (Figures 4.6-2 through 4.6-6). Partial views of the landfill can be seen at the closer northerly location 7. The landfill is visible above the existing ridgeline under the permitted and proposed project scenarios (Figure 4.6-8). Although it is difficult to see a difference between the “permitted” and “proposed” landfill conditions, it may be viewed to create a significant visual impact. ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 2.0 DECEMBER 2005 DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 2-26 RESPONSE TO COMMENTS/FINAL EIR The “full view” of Landfills I and II and the “11-acre wedge” expansion area (only visible from the south, looking north, northeast, and northwest at view locations 6, 8, and 9) may be viewed to create a significant visual impact (Figures 4.6-8 through 4.6-10). However, it should be noted that the majority of Landfill I is already constructed and visible from the south. Landfill II is not constructed but permitted and environmentally analyzed in the previous 1992 certified EIR for Landfill II. (Therefore, Landfills I and II will exist regardless of the proposed expansion/reconfiguration. This section of the EIR document analyzes the “project specific” aesthetic impacts emanating from the expansion/reconfiguration, which proposes to fill the 400- foot gap that would exist between the two landfills at build-out and the increase in permitted height of Landfill II by 60-foot. The proposed 11-acre increase in the landfill footprint would eliminate the valley between Landfills I and II once they are both filled. Thus, a more natural transition between the two landfills would result, and this would create a more contiguous visual form consistent with the existing ridgeline. The project also proposes a height increase to the landfill overall. The currently permitted Landfills I and II have a maximum height of El 3,205 and El 3,140, respectively. The proposed project would result in a maximum height of El 3,200. The visual simulations reveal that this height increase is not visible or difficult to see from the eight of the nine viewpoints analyzed. The height increase is visible in Figure 4.6-10 as less of the existing ridgeline is visible from the south in Condition #3 (proposed project with height increase) as compared to Condition #2 (existing and permitted landfill). Mitigation Measure 4.6-1 is proposed to reduce the project-specific aesthetic impacts from the south at view locations 6, 8, and 9 (Figures 4.6-8 through 4.6-10). As required by Mitigation Measure 4.6-1, interim vegetative cover will be applied as land filling proceeds to help offset visual impacts. The application of interim vegetation is not required under existing permits for Landfill I and Landfill II development. This interim measure requires extra effort and expense for preparation of slopes for seeding, provisions for irrigation and continuous maintenance, which would otherwise not be experienced until site closure and application of final cover/vegetation. Although duplicative and more costly, this interim measure will help to mitigate the visual impact associated with development of the already permitted Landfills I and II as well as the proposed landfill expansion project.” Response 5-8 Disposal plans beyond year 2020 have not been formalized. Typically, options available for future disposal of the City’s waste, following the existing landfill reaching capacity, would include additional expansion of existing disposal sites, development of new disposal sites or development of a facility to receive, process, and transport waste to a distant disposal site. Regarding the life expectancy with and without the connecting landfill, Section 7.2 of the Draft EIR discusses the life expectancy of the landfill with and without connecting the landfills and with and without the proposed increase in daily tonnage. If the expansion was not approved but ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 2.0 DECEMBER 2005 DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 2-27 RESPONSE TO COMMENTS/FINAL EIR the daily tonnage increase was approved, the existing/permitted landfill’s life expectancy with an intake of 3,600 tpd would be 7 years. With no wedge expansion and a daily intake of 1,800 tpd, the existing/permitted landfill’s life expectancy would be 14.6 years. Please refer to Table 3-2 in Section 3.0 of the Draft EIR. Response 5-9 Please refer to Response 5-7 above. Section 5.0 of the Draft EIR includes analyses of potential significance for four project alternatives. The Project applicant has decided to pursue City staff’s recommendation of the Reduced Project Alternative (the 1,800 tpd disposal option), which is the current CUP-approved tonnage, as the environmentally superior alternative. Section VI of the CEQA Findings lists eleven (11) project benefits that would be realized with the Reduced Project Alternative’s implementation: The existing Landfill I is near its capacity and the expansion will allow for the continuation of this existing msw disposal service by providing an additional 12.8 million cubic yards of added landfill capacity, thereby saving City residents and businesses the environmental impacts and the economic costs of developing a new landfill or the higher cost of hauling wastes to a more distant landfill outside the area. The Project will upgrade existing access to the landfill via a 2-lane (60-ft right-of-way) meeting City standards. The Project will establish safe signalized ingress and egress from a new intersection at Tierra Subida Ave and Rayburn Rd. The Project will contribute drainage impact fees per City Ordinance. Anaverde Creek slope protection improvements to be done as a condition of the project will reduce sediment impact on City facilities. The Project will extend the useful life of the landfill, thereby roughly doubling the number of years that the City will receive City host fee revenues derived from landfill operations. The wedge expansion would result in an additional 20-25 million dollars in host fees to the City of Palmdale. The Project will provide additional employment associated with the various construction jobs required. The Project implements sustainability principals through the inclusion of mitigation measures requiring energy production by a LFGTE project upon meeting certain threshold criteria, ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 2.0 DECEMBER 2005 DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 2-28 RESPONSE TO COMMENTS/FINAL EIR increased diversion of organic material, increased recycling, and other measures resulting in reductions of GHG emissions (MM 4.2-6). The Project provides a balance between providing essential landfill services, increasing diversion and recycling, protecting the environment, and providing economic development opportunities. The Project will ensure recycling services for its community members while continuing to serve the demand for a diverse range of disposal and recycling services. The applicant will also continue educational programs (such as “Caught Green Handed” and “Ready Set Go Green”) to promote a better understanding in the community of the need to reduce, reuse and recycle by continuing to offer tours, a recycling drop off box, and other programs at the site (such as the Landfill Open House event). Additionally, private tours of the landfill are available upon request. (10) The Project provides for orderly and safe disposal of solid waste generated in the local area, both in the short term and the long term, which is a necessity in a modern society. (11) The Project would allow the project applicant to continue supporting local community endeavors. The AVPLF has historically supported a number of non-profit and community organizations and serves as a resource for residents and businesses throughout the City. Some of the community-based organizations/events that have received financial and in-kind support from the AVPLF include: Antelope Valley Boys and Girls Club, AV High School Teen Builders, the American Legion Post, Highland High school – Relay for Life, Palmdale Chamber of Commerce, Antelope Valley Sheriff’s Boosters, Palmdale Sheriff’s Boosters, Palmdale SAVES Organization, and Palmdale Salute to Youth Foundation. In addition, the AVPLF sponsored illegal dumping cleanup projects for Palmdale High School, the Elks Lodge, and Cornerstone Apostolic Church. Consistent with Section 15093 of the CEQA Guidelines, the Planning Commission for the City of Palmdale is required to adopt a Statement of Overriding Considerations for unavoidable adverse impacts which includes the cumulative effect of the proposed 11-acre wedge expansion and height increase, the existing Landfill I, the permitted Landfill II, and the access roadway upon the existing visual character and the views south of the landfill. Additionally, the Planning Commission will need to balance these substantial social and economic benefits against the unavoidable significant adverse effects of the proposed project. California Administrative Code, Title 14, 15093(a) states: “If the benefits of a proposed project outweigh the unavoidable adverse environmental effects, the adverse environmental effects may be considered ‘acceptable’.” ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 2.0 DECEMBER 2005 DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 2-29 RESPONSE TO COMMENTS/FINAL EIR Letter No. 6 6-1 ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 2.0 DECEMBER 2005 DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 2-30 RESPONSE TO COMMENTS/FINAL EIR Response to Letter No. 6 State of California, Public Utilities Commission – January 24, 2006 Response 6-1 The comment is acknowledged. As indicated on page 38 of the project Initial Study/NOP contained in Appendix A of the Draft EIR, the proposed landfill consolidation project is not located adjacent to or near the Union Pacific Railroad Company right-of-way, and therefore, the project will not involve any rail corridor safety related issues as part of project implementation. ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 2.0 DECEMBER 2005 DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 2-31 RESPONSE TO COMMENTS/FINAL EIR Letter No. 7 7-1 ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 2.0 DECEMBER 2005 DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 2-32 RESPONSE TO COMMENTS/FINAL EIR Response to Letter No. 7 Department of Transportation, District 7 – January 24, 2006 Response 7-1 As indicated by the commentor, the proposed project will not have a significant impact on the freeway system. Specifically, Section 4.7 of the Draft EIR concludes “The State Route 14 Freeway, south of Avenue S, receives a maximum of 10 percent of the project’s traffic (see Figure 4.7-5 and Table 4.7-1A). This includes 70 vehicles per day for average inflow conditions and 97 vehicles per day for peak inflow condition. The SR 14 south of Avenue S has 70,000 vehicles per day per the latest available Caltrans counts, and the added project vehicles represents about a 0.14 percent increase which is insignificant. Per the Los Angeles Congestion Management Program (LACMP) section D.4, 150 added vehicles in the peak hour is considered a significant impact and would trigger future traffic impact analysis. As stated above, the proposed project would add far less than 150 vehicles for the entire day and the project peak hour trips on SR-14 would be even less than the daily figure. Therefore, while the operator will most likely avoid peak commute periods on state highways and excessive or poorly times truck platooning (caravans of trucks), the EIR conclusions do not support a formal requirement for such restrictions. ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 2.0 DECEMBER 2005 DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 2-33 RESPONSE TO COMMENTS/FINAL EIR Letter No. 8 ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 2.0 DECEMBER 2005 DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 2-34 RESPONSE TO COMMENTS/FINAL EIR Letter No. 8, Continued 8-1 8-2 8-3 8-4 8-5 ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 2.0 DECEMBER 2005 DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 2-35 RESPONSE TO COMMENTS/FINAL EIR Letter No. 8, Continued 8-5 ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 2.0 DECEMBER 2005 DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 2-36 RESPONSE TO COMMENTS/FINAL EIR Response to Letter No. 8 County of Los Angeles, Department of Public Works – January 26, 2006 Response 8-1 The comment is acknowledged. The Environmental Programs Division will be contacted for required permit approval and operating permits should the project include the construction, modification, or removal of underground storage tanks and/or Industrial Waste Control System/ facility. Response 8-2 The comment is acknowledged. A Finding of Conformance (FOC) was confirmed in 1995 for the AVPL. The proposed “expansion” would combine the existing two landfill modules of the AVPL by bridging a small 11-acre gap which currently exists between the two permitted sites within the same property boundary. Table 2-1 – “List of Potential Responsible Agencies/Project Approvals” has been modified to include the County Solid Waste Management Committee/Integrated Waste Management Board should a second FOC be required. Please refer to the Errata contained in Section 4.0 of the Final EIR document. Response 8-3 The proposed AVPL expansion serves to fulfill the County’s Disposal Facility Siting criteria by adding more landfill capacity and extending the life (beyond 15 years) of a site that previously received a FOC in 1995. Table 3-2 of the Draft EIR illustrates the site life/remaining capacity with and without the proposed project. Response 8-4 Please refer to Response 3-2 which addresses the concerns regarding the project’s potential Surface Water quality impacts. With respect to groundwater quality impacts; Section 4.3 of the Draft EIR concludes; “The groundwater quality of the small sub-basin containing the existing landfill facility and proposed expansion is of poor quality and non-potable. Water infiltration into the landfill may generate leachate which could have an adverse impact on the existing groundwater. For instance, excess water used for dust-control water could create the potential for leachate formation within the landfill mass. Based on the conclusion that the existing facility and proposed expansion area are hydraulically isolated from adjacent basins, and a leachate collection and removal system are proposed, minimal impacts are anticipated. With the implementation of the LCRS, Composite Liner System, and the Groundwater Monitoring System, no damage to the surrounding water basins will occur from the proposed continued landfill activities and potential impacts will be reduced to a level of insignificance.” Section 4.3 of the Draft EIR and Appendix D also address the project’s potential impacts on the Flood Conveying Capacity of the Ana Verde Creek. The conclusions of the calculations indicate ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 2.0 DECEMBER 2005 DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 2-37 RESPONSE TO COMMENTS/FINAL EIR that the post-development flows without debris basins of 290 cfs do not meet the City of Palmdale’s 85 percent pre-development attenuation criteria of 226 cfs. Without mitigation or design improvements, this could be considered a significant impact. However, two sedimentation/detention basins are proposed to eliminate potential impacts. The post- development (with debris basins) flows of 160 cfs meet the 85 percent pre-development attenuation criteria. Therefore, the project impacts are less than significant and would not have an effect on the flood conveying capacity of the Anaverde Creek. Lastly, the proposed project does not include reclamation efforts nor any proposed irrigation systems. Regarding past comments on the previous Draft EIR, those comments were responded to, in accordance with CEQA requirements, and included in the Final EIR for the Antelope Valley Public Landfill Expansion, dated February 1992. Response 8-5 The comment is acknowledged and will be forwarded to the decision-makers for their review and consideration. ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 2.0 DECEMBER 2005 DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 2-38 RESPONSE TO COMMENTS/FINAL EIR This page left blank intentionally. ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 2.0 DECEMBER 2005 DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 2-39 RESPONSE TO COMMENTS/FINAL EIR Letter No. 9 9-1 9-2 ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 2.0 DECEMBER 2005 DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 2-40 RESPONSE TO COMMENTS/FINAL EIR Letter No. 9, Continued 9-3 9-4 9-5 9-6 9-7 ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 2.0 DECEMBER 2005 DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 2-41 RESPONSE TO COMMENTS/FINAL EIR Response to Letter No. 9 California Regional Water Quality Control Board, Lahontan Region – January 27, 2006 Response 9-1 The Draft EIR includes a discussion of the proposed additions to the existing groundwater monitoring system on page 3-20. Please also refer to page 3-19 and Section 4.3 of the Draft EIR which discuss additional measures to be taken to prevent groundwater contamination including the proposed Leachate Collection and Removal System (LCRS), consistent with the California Code of Regulations. Additionally, current site policies and procedures include a Spill Prevention Control and Countermeasures (SPCC) plan which are actively followed and will continue to be part of the AVPL operating procedures for the expanded landfill, also consistent with existing statutory and regulatory requirements in place for purposes of protecting water quality. Response 9-2 The comment is acknowledged. The statement on page 4.1-10 was a typographical error and is incorrect and not consistent with Figure 4.1-1 nor Appendix B of the Draft EIR. The statement has been removed to correct this error in the Final EIR. Page 4.1-10 has been corrected and included as errata to the Draft EIR in Section 4.0 of this Final EIR document. Response 9-3 City staff and their consultants have worked closely with the to address the concerns presented in this comment. A conference call was held on February 15, 2006 between (Christy Hunter and Cindy Minton), EDAW, the preparer of the Environmental Impact Report (EIR) (Jayna Morgan), Golder, the Engineer for the project (Scott Sumner, P.E.) and the City of Palmdale (Richard Kite) Project Case Planner. Based upon the discussions of the conference call, City staff agreed to draft a follow up letter to Christy Hunter and further clarify Mitigation Measure 4.1-1 of the Draft EIR. Golder Associates also agreed to provide a response which would outline the justification for their Slope Stability Analysis, Liner Design and base grading plans. The formal response prepared by Golder Associates is as follows: A. BACKGROUND To provide some information on Golder, we are a global group of consulting companies, specializing in ground engineering and environmental science. Operating as an employee- owned group since its formation in 1960, Golder Associates has created a unique culture with ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 2.0 DECEMBER 2005 DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 2-42 RESPONSE TO COMMENTS/FINAL EIR pride in ownership and a commitment to providing technically sound and cost-effective consulting and contracting services. In the United States almost 40 percent of our business is to provide engineering and environmental consulting services for landfill and mining operations. Golder Associates has experienced steady growth for more than four decades and has more than 4,500 employees world-wide, including almost 1,000 in the United States. Our growth and diversity of services have paralleled the needs of our clients as they operate in an ever- changing and complex environment. We established our Irvine office in 1995 and have been serving southern California since this time. Additional information on Golder Associates may be found at our web site at www.golder.com. For the AVPL expansion project, our key team members include: • Mr. Scott Sumner, P.E. as Project Manager. Mr. Sumner has a Masters Degree in Geotechnical Engineering and has been designing and constructing landfills for over 20 years. Mr. Sumner has over 15 years of experience designing and constructing solid waste landfills in California. • Mr. Michael Snow, P.E., G.E. as Principal Design Engineer. Mr. Snow provided key input to the design and evaluation of the proposed liner systems and geometric layout of the facility. • Dr. Anthony Augello, P.E. was responsible for evaluation of the landfill’s stability. Dr. Augello has performed stability analysis for numerous landfills in southern California. Dr. Augello’s doctoral work focused on the evaluation of the seismic stability of solid waste landfills. His experience and education have allowed Golder to evaluate seismic stability for this project using the more sophisticated finite element technique. • Dr. Alan Hull, C.E.G. is an internationally recognized authority on evaluation of earthquake hazards and assessment of geologic hazards from active faults. Dr. Hull and others evaluated the site geology and the nearby San Andreas Fault. B. DESIGN APPROACH The design of a landfill provides many unique challenges for engineers and regulatory agencies. Each project is different in that the soil and liner materials used for construction vary, the topography of the natural landscape varies, and the geologic setting can provide additional design considerations. For the AVPL one of the key elements is the site’s proximity to the San Andreas Fault. The southern edge of the waste fill will be approximately 200 feet from the fault. When the maximum magnitude earthquake ( ≈ M w 7.8) occurs on this section of the fault, horizontal fault displacement could be up to 10 to 25 feet over a length of approximately 220 miles (350 km). An earthquake of this magnitude will generate large ground motions adjacent to the fault. Earthquake engineers utilize the lessons learned from past earthquakes to evaluate ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 2.0 DECEMBER 2005 DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 2-43 RESPONSE TO COMMENTS/FINAL EIR the effects of future earthquakes on structures such as landfills. The study of geotechnical earthquake engineering began in earnest in the United States after the 1971 San Fernando earthquake. Over the past number of years design techniques ranging from simple empirical analyses) to relatively complex computer modeling) have been utilized. Most empirical analysis methods tend to provide reasonable, but conservative, estimates of landfill performance for most landfill designs. The Makdisi and Seed (1978) simplified analysis procedure provides conservative results for solid waste landfills. This was recognized by Bob Pyke in his July 6, 1994 letter discussing the results of his two-dimensional dynamic finite element analysis of the landfill. The Makdisi and Seed (1978) analysis method was originally developed for embankment dams. This method was based upon observations of dam performance during earthquakes and a limited number of dynamic finite element analyses. The conservatism in this method results from the significant differences in the geometries between dams and landfills and the lack of data points used to establish the design curves. The design curves developed by Makdisi and Seed (1978) are based on four to five dynamic finite element analyses of an embankment dam. Because of the lack of data, the authors established very conservative bounds on the design curves. This is one of the reasons that this method is still employed today. In addition, in 1978 very little was known about ground motions from large magnitude earthquake events and near source ground motions. The number of recorded motions from large magnitude earthquakes worldwide has increased this understanding considerably. In addition, it is now recognized in seismology that the ground motions within about 6 miles (10 km) of the fault experience near source directivity effects. There are two directivity effects. The first effect is a change in the strength of shaking of the average horizontal component of motion higher ground motions for rupture towards the site and lower ground motions for rupture away from the site). The second effect is systematic differences in the strength of shaking on the two horizontal components of motion oriented perpendicular and parallel to the strike of the fault (Abrahamson, 2000). Fault directivity effects are not included in simplified analysis procedures, but the directivity effects have been incorporated in the dynamic finite element analysis of the landfill through the selection of ground motions. As discussed above, the proximity of the AVPL to the San Andreas Fault makes the use of the simplified analysis techniques overly conservative. Therefore, dynamic finite element analyses of the landfill slopes were performed. Through the use of this computer modeling, we were able to incorporate design features that reduced the amount of anticipated damage to an acceptable level. C. REGULATORY FRAMEWORK In the case of any structure in or near a seismically active area, which is true for most of southern California, there are typical standards established addressing seismically-induced ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 2.0 DECEMBER 2005 DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 2-44 RESPONSE TO COMMENTS/FINAL EIR ground motions for design and construction. For example, the homes within Ritter Ranch (south of the San Andreas Fault) have been designed in accordance with the California Building Code (CBC). Similar standards have been established for landfills in Title 27 of the California Code of Regulations (CCR). CCR Title 27 stipulates that “Class III landfills shall have containment structures which are capable of preventing degradation of waters of the state as a result of waste discharges to the landfills if site characteristics are inadequate.” To this end the landfill’s waste mass and containment systems are being designed to withstand the Maximum Credible Earthquake (MCE). The MCE is the largest earthquake that can occur on a particular fault under the currently know tectonic framework. D. DESIGN RESULTS As required by CCR Title 27, Golder’s analyses included an assessment of the seismic hazards and faulting within 100 km (62 miles) of the site. As expected, the MCE on the San Andreas Fault generates the largest ground motions expected at the site. The peak horizontal ground motions generated at the AVPL are estimated to be approximately 0.89 g (fault normal component) and 0.74g (fault parallel component). Two acceleration time histories were developed for the dynamic finite element analysis to incorporate fault directivity effects. Golder used several commercially available, state-of-the-art, computer models (UTEXAS3, TELSTA, and TELDYN) to model the behavior of the landfill during this level of earthquake shaking. For the AVPL expansion project, Golder developed an iterative approach in designing the geometric layout of the landfill. Initial base grading and fill plans were developed to maximize the amount of waste that could be placed within the expansion area. Initial slope stability analyses indicated that excessive seismically induced permanent displacements along interfaces within the landfill base liner and final cover system may result if the initial plans were constructed. The next iteration included the incorporation of a stability buttress, effectively 60 to 70 feet in height, to provide additional reinforcement at the base of the waste slope. The stability buttress reduced the seismically-induced permanent displacements at the base of the landfill to less than 6-inches. In the final iteration, the final fill grades were flattened to reduce the estimated seismically induced permanent displacements within the final cover system. The final configuration presented in the EIR reflects a design that is predicted to have less than 6-inches of permanent displacement along the base liner system and less than 36-inches of permanent displacement along the cover system following the MCE event. The engineering community and the have accepted 6 inches as the maximum seismically induced permanent displacement that the base liner systems could accommodate without loss of containment. With less than 6-inches of displacement, the liner system is expected to meet the requirements of Title 27 and prevent the degradation of the waters of the state. Because the final soil cover system will be constructed entirely of soil and the cover system can be easily repaired, larger seismically induced ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 2.0 DECEMBER 2005 DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 2-45 RESPONSE TO COMMENTS/FINAL EIR permanent deformations (up to five feet) are typically allowed within soil cover systems. The seismically induced permanent deformations presented in the EIR are consistent with the analyses performed by Bob Pyke in 1994 that estimated approximately four inches of displacement along interfaces within the base liner. SUMMARY While the has expressed concerns over the stability analysis included with the EIR, Golder is confident that these concerns can be resolved. Given the site and its proximity to the San Andreas Fault it is critical that all involved parties have input into the stability evaluations and are all comfortable with the design methodologies and conclusions. Given that the will also need to issue revised Waste Discharge Requirements (WDRs) for the project, they will be given additional opportunity to perform a more complete review, as requested, and seek clarification on inputs to the stability analysis when the Joint Technical Document is submitted. Additionally, a follow up letter from Mr. Richard Kite was prepared and sent to Ms. Hunter on February 22, 2006. A copy of this letter is on file with the City of Palmdale Planning Department. Based on Ms. Hunter’s March 9, 2006 electronic mail response to the February 22, 2006 letter, Mitigation Measure 4.1-1 was further clarified as follows: Prior to the issuance of the Waste Discharge Requirements (WDR’s) and approval of the Joint Technical Document (JTD) for the project by the Lahontan Regional Water Quality Control Board, the proposed design and supporting engineering analysis of the landfill’s containment structures shall be reviewed and approved by the to ensure the design complies with State regulations pursuant to California Code of Regulations, Title 27, Division 2. The applicant shall demonstrate to satisfaction that the landfill liner and leachate collection system have been designed to preclude failure and will resist the maximum seismic shaking expected at the site based on risk assessment. Further, the design shall demonstrate that the final slopes will be stable under both static and dynamic conditions to protect public health and safety and prevent damage to the facility such that no significant impact to the environment will occur. The liner design, as proposed in Appendix B of the EIR, shall be modified or refined if necessary based on final engineering analysis and review by the to ensure that the approved landfill design will mitigate impacts to a less than significant level. The landfill containment structures shall be constructed as approved by the During on-going landfill construction, geologic mapping of rock and soil exposed in future excavations shall be completed. Information on rock type and any exposed folds, fractures and folds will be collected. Permanent cut slopes shall be observed by a qualified geologist to check for adverse bedding, joint patterns, or other geologic features that may impact the approved landfill design. Where necessary, the permanent cut slopes shall be constructed to ensure their stability. The ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 2.0 DECEMBER 2005 DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 2-46 RESPONSE TO COMMENTS/FINAL EIR geologic maps will be included with the construction reports for each portion of the constructed landfill. The reports will be submitted to the LEA and Lahontan This clarification to Mitigation Measure 4.1-1 has been corrected as errata to the Draft EIR. Please refer to Section 4.0 of this Final EIR document. We trust that this collaborative effort adequately addresses the concerns. Response 9-4 The Draft EIR provides a detailed analysis of the potential surface water quality impacts and the measures that will be implemented to prevent potential impacts to the sediment load of the Anaverde Creek. Pages 3-15 through 3-19 (including Figure 3-6) discuss the project’s proposed Drainage Control and Surface Water Management System. Additionally, pages 4.3- 14 and 4.3-15 and Figure 4.3-4 outline the project’s Stormwater Management Plan and Erosion Control Measures to be implemented for stormwater runoff prior to discharge to the Anaverde Creek. Lastly, Section 4.4 of the Draft EIR also addresses this issue. Mitigation Measure 4.4-3 states, “Prior to issuance of the landfill’s Waste Discharge Requirements (WDRs), the project engineer shall finalize erosion and siltation control plans and other BMPs, as necessary to prevent graded and cleared areas from being eroded, resulting in the transport of sediment to Anaverde Creek. Please refer to Section 4.4 of the Draft EIR, specifically page 4.4-8 and Mitigation Measure 4.4- 2 which do note that any streambed alterations will require review by the Lahonton Response 9-5 As stated above in Response 9-1, current site policies and procedures include a Spill Prevention Control and Countermeasures (SPCC) plan which are actively followed and will continue to be part of the AVPL operating procedures for the expanded landfill. Response 9-6 The comment is acknowledged. The error on page 4.3-12 has been corrected as errata to the Draft EIR. Please refer to Section 4.0 of this Final EIR document. Response 9-7 The comment is acknowledged. Additionally, please refer to Response 9-3 above. ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 2.0 DECEMBER 2005 DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 2-47 RESPONSE TO COMMENTS/FINAL EIR Letter No. 10 10-1 ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 2.0 DECEMBER 2005 DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 2-48 RESPONSE TO COMMENTS/FINAL EIR Letter No. 10, Continued ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 2.0 DECEMBER 2005 DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 2-49 RESPONSE TO COMMENTS/FINAL EIR Letter No. 10, Continued ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 2.0 DECEMBER 2005 DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 2-50 RESPONSE TO COMMENTS/FINAL EIR Response to Letter No. 10 State of California, Governor’s Office of Planning and Research, State Clearinghouse and Planning Unit – January 30, 2006 Response 10-1 The comment is acknowledged and will be forwarded to the decision makers for their review and consideration. ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 2.0 DECEMBER 2005 DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 2-51 RESPONSE TO COMMENTS/FINAL EIR 2.2 VERBAL COMMENTS 2.2.1 INTRODUCTION The response letter on the following page was prepared by Waste Management in response to the following verbal comments by Jack and Rose O’Conner on some of the operational elements of the existing landfill.  Noise from the maintenance facility  Third party washing of trucks / Sundays at 7:00 AM  Antelope Valley Environmental Collection Center (AVECC) sign  AVECC semi-annual operations with uninformed personnel The comments were discussed with Waste Management at a meeting on January 4, 2006. Upon receipt of the comments, Waste Management in discussions with the City of Palmdale, prepared and submitted the response letter on the following page to the O’Conners addressing their issues/concerns. Although the comments specifically pertain to the existing landfill operations, because the meeting occurred during the 45-day public review period and these operations would continue with the proposed expansion CUP, the same measures that are currently being implemented to address the concerns will continue to be carried out through the expansion operations. As such, the City determined it was appropriate to include the response letter in this Response to Comments Final EIR document. ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 2.0 DECEMBER 2005 DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 2-52 RESPONSE TO COMMENTS/FINAL EIR Response to Verbal Comments ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 2.0 DECEMBER 2005 DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 2-53 RESPONSE TO COMMENTS/FINAL EIR Response to Verbal Comments ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 2.0 DECEMBER 2005 DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 2-54 RESPONSE TO COMMENTS/FINAL EIR This page left blank intentionally. ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-1 RESPONSE TO COMMENTS/FINAL EIR 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS AND RESPONSES 3.1 WRITTEN COMMENTS/RESPONSES 3.1.1 INTRODUCTION This section provides responses to the written comments made on the Antelope Valley Public Landfill (AVPL) Amendment to the Draft EIR during the OPR published public review period of May 24, 2010 to July 7, 2010. The City of Palmdale accepted comment letters through August 5, 2010. The comment letters received on the May 2010 Amendment to the Draft EIR are numbered in continuation of the December 2005 Draft EIR comment letters. They are listed below, and are included in this section along with the formal responses prepared for the comments. To assist in referencing comments and responses, each specific comment is numbered and refers to a statement or paragraph in the corresponding letter. Where changes to the Amendment to the Draft EIR text result from response to comments, those changes are included in the response and demarcated with revision marks (underline for new text, strike-out for deleted text). Comments which present opinions about the project or which raise issues not directly related to the substance of the Amendment to the Draft EIR are noted without a detailed response. Comment-initiated revisions/clarifications to the EIR text are also provided and are demarcated with revision marks in Section 4.0, Changes to the December 2005 Draft EIR and May 2010 Amendment to the Draft EIR of this document. 3.1.2 LIST OF COMMENTERS The comment letters received on the May 2010 Amendment to the Draft EIR are listed below (#11-18). The comment letters are numbered in continuation of the December 2005 Draft EIR comment letters. The paragraphs in the letters have been numbered and are referred to in the responses that directly follow the comment letter. Letter Agency/Signatory Date #11 Department of Resources Recycling and Recovery Raymond M. Seamans June 10, 2010 #12 California Clean Energy Committee Eugene S. Wilson July 3, 2010 #13 California Regional Water Quality Control Board, Lahontan Region Jan M. Zimmerman July 7, 2010 #14 County of Los Angeles, Department of Public Works Pat Proano July 7, 2010 ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-2 RESPONSE TO COMMENTS/FINAL EIR #15 State Clearinghouse and Planning Unit Scott Morgan July 8, 2010 #16 County of Los Angeles, Department of Public Works Pat Proano July 15, 2010 #17 County of Los Angeles, Public Health Gerry Villalobos August 5, 2010 #18 County of Los Angeles, Fire Department John R. Todd August 11, 2010 The letter comments and responses follow. ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-3 RESPONSE TO COMMENTS/FINAL EIR Letter No. 11 11-1 11-2 11-3 11-4 11-5 ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-4 RESPONSE TO COMMENTS/FINAL EIR Letter No. 11, Continued 11-6 11-7 11-8 11-9 ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-5 RESPONSE TO COMMENTS/FINAL EIR Response to Letter No. 11 Department of Resources Recycling and Recovery – June 10, 2010 Response 11-1 The comment is acknowledged, but does not raise an issue regarding the environmental analysis contained in the Amendment to the Draft EIR; therefore, no response is warranted. Response 11-2 Please refer to Response to Letter No. 4 in Section 2.0, pages 2-18 to 2-20 of this Final EIR for the responses to the January 12, 2006 comment letter. Response 11-3 The comment is acknowledged, but does not raise an issue regarding the environmental analysis contained in the Amendment to the Draft EIR; therefore, no response is warranted. Response 11-4 When available, a copy of the CEQA Findings of Fact and Statement of Overriding Considerations will be forwarded to the Department. Response 11-5 When available, a hard copy of any subsequent environmental documents, including this Final EIR, will be provided to the Department. Response 11-6 The comment is acknowledged, but does not raise an issue regarding the environmental analysis contained in the Amendment to the Draft EIR; therefore, no response is warranted. Response 11-7 A copy of the responses to comments will be provided to the Department when available and at least ten days prior to the City’s consideration for certification. Response 11-8 A required notice will be provided to the Department when available. Response 11-9 The comment is acknowledged, but does not raise an issue regarding the environmental analysis contained in the Amendment to the Draft EIR; therefore, no response is warranted. ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-6 RESPONSE TO COMMENTS/FINAL EIR Response to Protocols for Surveying and Evaluating Impacts to Special Status Native Plant Populations and Natural Communities (see Appendix A of this document) The comment/protocol is acknowledged. Any future surveys will follow the Protocols for Surveying and Evaluating Impact to Special Status Native Plant Populations and Natural Communities. ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-7 RESPONSE TO COMMENTS/FINAL EIR Letter No. 12 12-1 ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-8 RESPONSE TO COMMENTS/FINAL EIR Letter No. 12, Continued 12-1 cont’d 12-2 ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-9 RESPONSE TO COMMENTS/FINAL EIR Letter No. 12, Continued 12-2 cont’d 12-3 12-4 12-5 12-6 ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-10 RESPONSE TO COMMENTS/FINAL EIR Letter No. 12, Continued 12-7 12-8 12-9 12-10 12-11 12-6 cont’d ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-11 RESPONSE TO COMMENTS/FINAL EIR Letter No. 12, Continued 12-12 12-11 cont’d ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-12 RESPONSE TO COMMENTS/FINAL EIR Letter No. 12, Continued 12-12 cont’d 12-13 ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-13 RESPONSE TO COMMENTS/FINAL EIR Letter No. 12, Continued 12-13 cont’d 12-14 ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-14 RESPONSE TO COMMENTS/FINAL EIR Letter No. 12, Continued 12-14 cont’d 12-15 ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-15 RESPONSE TO COMMENTS/FINAL EIR Letter No. 12, Continued 12-16 ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-16 RESPONSE TO COMMENTS/FINAL EIR Letter No. 12, Continued 12-16 Cont’d 12-17 12-18 12-19 12-20 12-21 12-22 ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-17 RESPONSE TO COMMENTS/FINAL EIR Letter No. 12, Continued 12-22 Cont’d 12-23 12-24 12-25 ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-18 RESPONSE TO COMMENTS/FINAL EIR Letter No. 12, Continued 12-26 12-27 12-28 12-29 ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-19 RESPONSE TO COMMENTS/FINAL EIR Letter No. 12, Continued 12-30 12-31 12-32 12-33 12-34 ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-20 RESPONSE TO COMMENTS/FINAL EIR Letter No. 12, Continued 12-35 12-36 12-37 12-38 12-39 ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-21 RESPONSE TO COMMENTS/FINAL EIR Letter No. 12, Continued 12-39 Cont’d 12-40 12-41 12-42 12-43 12-44 ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-22 RESPONSE TO COMMENTS/FINAL EIR Letter No. 12, Continued 12-44 Cont’d 12-45 12-46 12-47 12-48 12-49 12-50 ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-23 RESPONSE TO COMMENTS/FINAL EIR Letter No. 12, Continued 12-50 Cont’d 12-51 12-52 12-53 12-54 ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-24 RESPONSE TO COMMENTS/FINAL EIR Letter No. 12, Continued 12-54 Cont’d 12-55 ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-25 RESPONSE TO COMMENTS/FINAL EIR Letter No. 12, Continued 12-55 cont’d 12-56 ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-26 RESPONSE TO COMMENTS/FINAL EIR Letter No. 12, Continued ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-27 RESPONSE TO COMMENTS/FINAL EIR Letter No. 12, Continued ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-28 RESPONSE TO COMMENTS/FINAL EIR Letter No. 12, Continued ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-29 RESPONSE TO COMMENTS/FINAL EIR Response to Letter No. 12 California Clean Energy Committee – July 3, 2010 Response 12-1 The comment is acknowledged. Please refer to the responses provided in the following pages which address the specific issues raised by the Committee. As requested, the City of Palmdale has added the Committee to the distribution list for all future notices regarding this matter. Response 12-2 – A. Project Description The response below provides clarification to the commentor’s questions raised in the Project Description. CEQA Guidelines Section 15124 requires the following components to be included in a project description: The precise location and boundaries of the proposed project shall be shown on a detailed map, preferably topographic. The location of the project shall also appear on a regional map. A statement of objectives sought by the proposed project. A clearly written statement of objectives will help the lead agency develop a reasonably range of alternatives to evaluate in the EIR and will aid the decision makers in preparing findings or a statement of overriding considerations, if necessary. The statement of objectives should include the underlying purpose of the project. A general description of the project’s technical, economic, and environmental characteristics, considering the principal engineering proposals if any and supporting public service facilities. A statement briefly describing the intended uses of the EIR. This statement shall include, to the extent that the information is known to the Lead Agency, A list of the agencies that are expected to use the EIR in their decision making, and A list of permits and other approvals required to implement the project. A list of related environmental review and consultation requirements required by federal, state, or local laws, regulations, or policies. To the fullest extent possible, the lead agency should integrate CEQA review with these related environmental review and consultation requirements. If a public agency must make more than one decision on a project, all its decisions subject to CEQA should be listed, preferably in the order in which they will occur. On request, the Office of Planning and Research will provide assistance in identifying state permits for a project. ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-30 RESPONSE TO COMMENTS/FINAL EIR The project description contained in the Revised and Recirculated “Amendment” to the Draft EIR complies with the above CEQA requirements. The statements on page 2-5 of the Amendment to the Draft EIR provide a “good faith” explanation of the permitting history for Landfill I consistent with the current City and County permit records. Page 2-5 states, “Landfill I was originally permitted to operate by the Los Angeles County Department of County Engineers Office. Landfill I was permitted prior to the 1972 enactment of CEQA and was grandfathered into the City of Palmdale” The Amendment to the Draft EIR text and Figures 1-3, County Approved Exhibit 1-4, Site Plan, and 1-6, Project Boundaries, illustrate the relationship of Landfill I to Landfill II. The EIR explains the following on page 2-5: “Immediately adjacent and to the west is a 98-acre area comprising the AVPL II (Landfill II), previously located in the unincorporated portion of the County and annexed to the City of Palmdale as of November 21, 2003, under Annexation 1998-01 (western portion, as outlined in Exhibit presented on Figure This statement is accurate. Please refer to Section 2.4 of the Amendment to the Draft EIR, which provides a detailed discussion of project history and prior CEQA documentation. As explained in the EIR, the expansion application originally filed with the County of Los Angeles in 1984 was to expand the existing (Landfill I) into the unincorporated County of Los Angeles area (Landfill II). The proposed 1984 expansion was outside of the City limits at the time, therefore, the County of Los Angeles was the Lead Agency and issued a CUP for Landfill II in 1992 and a CUP modification for Landfill II in 1993. Response 12-3 The comment is acknowledged. The commenter should note that the project applicant is the Antelope Valley Recycling and Disposal Facility, Inc., a subsidiary of Waste Management, Inc., also referred to as the Antelope Valley Public Landfill (AVPF) throughout the EIR. Because the remainder of the comment does not raise an issue regarding the environmental analysis contained in the Amendment to the Draft EIR no additional response is warranted. Response 12-4 As stated on page 2-3 of the Amendment to the Draft EIR, “In accordance with Section 15161 of the State CEQA Guidelines, this document is intended to serve as a “project” EIR that examines the environmental impacts of the specific development project. In this case, several discretionary actions are requested to implement the proposed project.” ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-31 RESPONSE TO COMMENTS/FINAL EIR The commentor mistakes the statement on page 2-6 as defining the type of EIR as a supplemental EIR which is incorrect and not the type of document prepared. The statement to which the commenter refers states: “This EIR prepared for the currently proposed project the proposed City CUP) is a supplement to the 1992 certified EIR for Landfill II and 1993 adopted MND and intends to use those documents for purposes of focusing the current analysis.” (Amendment, p. 2-6.) When read in conjunction with the Draft EIR and Amendment to the Draft EIR, the intent is that the EIR serves as a project EIR which has incorporated by reference the prior environmental analysis prepared for Landfill II. (See Draft EIR, pp. 2-1 thru 2-2 (Purpose of EIR/Incorporation By Reference/ Intended Uses), 2-3 (“this document is intended to serve as a ‘project’ EIR”); see also Amendment, p. 2-3 (same),). Thus, the Amendment did not intend to use the term “supplement” as that term is used under CEQA pursuant to Public Resources Code section 21166 and CEQA Guidelines section 15163. It rather indicates the “project EIR” intended to utilize the prior CEQA documents for focusing the current analysis provided in the Amendment to the Draft EIR. As stated on page 3-1 of the Amendment to the Draft EIR, “For a determination of environmental baseline, which provides the basis for the impact analysis, CEQA Guidelines Section 15125, as interpreted by case law (Fairview Neighbors v. County of Ventura (1999) 70 Cal.App.4th 238, 242-243; [see also Fat v. County of Sacramento (2002) 97 Cal.App.4th 1270, 1278-1280 (upholding use of unauthorized expansion of airport as baseline)], allows using the permitted conditions as environmental baseline for analyzing impacts in an EIR. However, existing operations can be utilized to prepare a “worst case” analysis. In the analysis of traffic impacts for the proposed project, this method of analysis was used to project a more conservative or “worst case” scenario.” Thus, the Draft EIR did not rely solely on existing permitted levels of operation, as the City arguably could have, but rather on actual averaged truck traffic based on accepted tons per day. (See Draft EIR, p. 4.7-6 (using actual truck and traffic counts); see also Amendment, p. 4.7-6 (same).) The baseline reflects actual existing conditions at the time of the NOP consistent with CEQA. Response 12-5 Solid Waste Facility Permit #19-AA-0009 was issued for Landfill I on December 26, 1995. SWFP #19-AA-5624 was issued for Landfill II on June 12, 1997. This information is provided on page 2-5 of the Amendment to the Draft EIR. ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-32 RESPONSE TO COMMENTS/FINAL EIR Response 12-6 According to CEQA Guidelines Section 15125 (Environmental Setting), “an EIR must include a description of the physical environmental conditions in the vicinity of the project, as they exist at the time the notice of preparation is published, or if no notice of preparation is published, at the time environmental analysis is commenced, from both a local and regional perspective. This environmental setting will normally constitute the baseline physical conditions by which a lead agency determines whether an impact is significant. The description of the environmental setting shall be no longer than is necessary to an understanding of the significant effects of the proposed project and its alternatives.” Initial construction of Landfill II began in the summer of 2006, and has been consistent with the County Approved CUP Number 85512-(5), amended CUP No.93041-(5), 1992 Certified EIR (State Clearinghouse Number [PHONE REDACTED]), 1993 Mitigated Negative Declaration (increasing tonnage to 1,800 tons per day), 1995 MND for Alternative Daily Cover, and subsequent permits including WDRs Order No. 6-95-1, dated January 12, 1995, permit from the Landfill II began receiving refuse in April 2007 following the receipt of required permits including, a FOC approved 4/20/95, SWFP #19-AA-5624 issued 6/12/97 and WDR 6-95-1 adopted by on 1/12/95. The LFII interim cell design was initially approved by via 7/21/06 email correspondence. Formal written approval for PhaseVA-1 was issued on 11/20/06 and Phase VA-2 was issued on 2/27/07 by the The receipt of refuse at LFII also began after the completion of all required pre-grading conditions/mitigation outlined in CUP Compliance Matrices on file with the City of Palmdale as provided in May 2007. There has been no unpermitted grading as implied by the commenter. Prior to grading/clearing, Landfill II was issued appropriate clearances/permits by the Regional Water Quality Control Board, LEA, CIWMB, and Department of Fish and Game. A detailed CUP compliance matrix and mitigation monitoring program for Landfill II are on file with the City of Palmdale and the County of Los Angeles. The biological and archaeological surveys contained in the County Certified EIR included the 11-acre parcel between the two landfills. Pre-grading surveys and monitoring were completed consistent with the County’s CUP conditions and are noted in the compliance matrix. The relocation of SCE’s distribution and transmission facilities was conducted by SCE in the summer of 2006. According to SCE, the facilities were relocated on private property per the Public Utility Commission (PUC) standards and requirements. Response 12-7 The proposed project will increase the area for waste disposal by 11 acres as shown on the Figure 1-6, Project Boundaries. The expansion of the 11 acres provides a very efficient addition ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-33 RESPONSE TO COMMENTS/FINAL EIR to the landfill by allowing for placement of waste within the “V”-shape between Landfills I and II, as well as other design efficiencies that were incorporated in the overall larger footprint. As shown in the proposed project base grading and fill plans (Figures 3-9 to 3-11), the expansion would provide an approximate 12.8 million cubic yard increase in the total capacity due to the added disposal area and efficiency gains afforded by the landfill design with the wedge expansions. The estimated waste volumes for the currently permitted and proposed expansion were computed using AutoCAD or similar 3-D models. The computed volumes are supported by substantial evidence in the record and can be independently confirmed. Response 12-8 Please refer to the table below which show the actual percentages of the total Antelope Valley (AV) MSW tonnages received at the AVPL during 2005 (baseline), 2009 (County attachment to comment letter) and 1st quarter 2010 (current). Table 3-1 Antelope Valley Public Landfill Solid Waste Disposal Summary City of Palmdale Tons City of Lancaster Tons AV LA County Unincorporated Tons Total AV Local Area Tons* Total Tons % Outside AV Area Waste** % AV Local Area Waste*** 2005 145,379.00 20,565.00 74,040.00 239,984.00 370,799.00 35% 65% 2009 95,850.36 18,111.28 55,137.29 169,098.93 266,742.98 36% 64% 1st Q 2010 17,792.22 1,949.83 12,175.79 31,917.84 43,177.05 26% 74% * Includes Palmdale, Lancaster, and Unincorporated Antelope Valley Area Tons % Outside AV Area Waste = [(Total Tons-Total AV Area Tons) / Total Tons] x 100 % AV Area Waste = (Total AV Area Tons / Total Tons) x 100 The summary breaks down the Los Angeles County unincorporated area tonnages specific to those originating from the “Antelope Valley,” demonstrating that a majority of the waste stream received at AVPL originates from the local area. The Lancaster Landfill is within approximately 13 miles (25 miles roundtrip) of the AVPL. Clean loads of green and wood material are stockpiled and processed on-site then are shipped to a facility for use as boiler fuel (and not sent to Lancaster). AVPL trucks also bring in curbside greenwaste collected on routes that is used as ADC in the landfill. Although AVPL still receives some of this ADC material, some has also been diverted to Lancaster mainly due to the expansion delays with the City of Palmdale. The recycled waste is often sent to Lancaster because that site has the area and facilities to process such waste at higher volumes, and therefore, can justify the use of more curbside greenwaste for use as daily cover. ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-34 RESPONSE TO COMMENTS/FINAL EIR Page 4.7-7 and Figure 4.7-5 of the Amendment to the Draft EIR describe in detail the existing and future landfill traffic distribution. As indicated in the EIR, the 85 percent local roadway traffic was estimated based upon previously approved traffic studies for the landfill and the field distribution and operations conducted in 2005 (Draft EIR baseline). The results of the traffic impact analysis for SR-14 (please refer to response 7-1 within Section 2.0 and response 16-5 within this section) indicate that a 15 to 20 percent change in the distribution would not have a measurable effect on the impact analysis conclusions. Response 12-9 The baseline used as part of the Draft EIR and revised and re-circulated sections of the Amendment was established at the time of issuance of the Notice of Preparation as is typical under CEQA. (CEQA Guidelines, § 15125.) The commenter’s suggestion to consider the growth projections contained within the 2008 RTP is noted but deemed not to be required for purposes of considering the potential effects of the proposed project against the baseline established in 2004. Response 12-10 Please refer to pages 3-34 and 3-35 of the Amendment to the Draft EIR which indicate that a six percent growth rate projection was utilized for the traffic, air quality, and noise analysis. This growth rate exceeds the commentor’s suggested growth rate of five percent. Response 12-11 The comment is acknowledged. The proposed project components are outlined in detail in Section 3.4 (Description of the Proposed Expansion) of the Amendment to the Draft EIR and Figures 1-4 – Site Plan; 1-5 – Ancillary Facilities Layout Plan; 3-6 – Stormwater Management Plan; 3-7 – Proposed Liner System; and 3-8 to 3-11 – Proposed Base Grading Plan and Fill Plans. The proposed erosion protection alternatives are described in Section 4.3 (Hydrology and Water Quality) and depicted on Figure 4.3-3 – Scour Protection Cross Sections and 4.3-4 – Post-Development Surface Water Control Plan. Proposed traffic mitigation/improvements are illustrated on Figures 4.7-13 – Proposed Realignment of City Ranch Road to be Opposite Rayburn Road at Tierra Subida Avenue and 4.7-14 – Proposed City Ranch Road Roadway Cross-Section. Response 12-12 – B. Current Public Policy on Energy Conservation The comment is acknowledged as are the City General Plan goals and policies summarized by the commenter. As noted by the commenter, the City has been taking action to “encourage” energy conservation. It has also been “promoting” energy audits of existing structures. The proposed project would encourage customers to “recycle to the extent possible.” If the City were to certify the EIR and adopt the proposed project, such action would not be inconsistent with the General Plan goals and policies referenced by the commenter. ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-35 RESPONSE TO COMMENTS/FINAL EIR Furthermore, the Bioenergy Action Plan for California, referenced by the commenter, does not represent a regulatory requirement; rather it is a series of policy objectives to be achieved by California in the coming years. One of the goals of the plan is to facilitate the development of biofuels projects by removing the various obstacles that exist in the state. WMI is fully supportive of this plan, and one of WMI’s staff is on the Executive Board of the California Biomass Collaborative, which helped draft this Plan. The Plan’s successful implementation may make it more possible to develop biofuels projects at landfills, particularly smaller sites like AVPL. The Plan demonstrates the difficulty in creating viable biofuels projects in California. The California Renewable Portfolio Standard (RPS) is a requirement placed on utilities to achieve a certain percentage of their power from renewable sources. It is not a requirement that is to be placed on an individual project; therefore, it is not relevant to the proposed landfill expansion for the AVPL. Certainly if WMI is able to make a landfill gas (LFG) to electricity project viable at AVPL in the future, the power sold by that project would help the utility achieve its RPS goals. With respect to the U.S. EPA’s Landfill Methane Outreach Program, please see Response 12-13 below. Response 12-13 – C. Landfill Gas-to-Energy Technology As explained below, the City and WMI are aware of the various technologies available to recover LFG for beneficial use. Reciprocating engines, gas turbines, microturbines, and LFG to vehicle fuel projects are all in place at landfills across the country, including WMI landfills. However, each of those projects, as well as the projects cited on pages 6 and 7 of the commenter’s letter, were determined feasible prior to implementation. The same is not true for the AVPL as explained below, and are not required at this time under CEQA because adoption of the proposed project or the reduced (1,800 tpd) alternative would not result in a significant impact on the environment from the generation of greenhouse gas emissions (either on a project specific or cumulative basis) with mitigation. As explained throughout the EIR, moreover, the nature of the project (e.g. a disposal msw landfill project) will not cause the “generation” of greenhouse gas emissions such that a significant adverse impact to climate change will occur. The msw will continue to be generated with or without the proposed project. With that said, the City offers the additional responses below, and has modified Mitigation Measure 4.2-6 to further address the commenter’s concerns. Please refer to the Errata contained in Section 4.0 of the Final EIR document. The Los Angeles County Sanitation District landfills Palos Verdes Landfill and Puente Hills Landfill) cited by the commenter are much larger than the proposed AVPL project and produce significantly more LFG, often because they are not in such an arid environment. For example, the Puente Hills Gas-to-Energy facility is a conventional Rankine Cycle Steam Power Plant ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-36 RESPONSE TO COMMENTS/FINAL EIR using LFG as fuel to generate electricity. LFG is fired in the plant’s boilers producing superheated steam. The superheated steam is used to drive the steam turbine/generator to generate electric power. Currently, the Puente Hills Landfill facility produces approximately 46 MW net of electric power. The power is sold to the local utility company, Southern California Edison. Increasing LFG production rates at Puente Hills Landfill provided an opportunity for additional power generation. In 2006, construction was completed on an 8 MW landfill gas-fired internal combustion engine facility at Puente Hills. In order to maximize project value, a direct power line was run from Puente Hills to the San Jose Creek Water Reclamation Plant (WRP), where power from the new facility is used to displace retail power purchases (source: http://lacsd.org/). According to “weather.com,” Palmdale has an average annual rainfall of 7.3 inches per year, and Walnut, where the Spadra Landfill is located, has an average annual rainfall of 17.01 inches per year. The rainfall at the Spadra site is typical for the Los Angeles basin for temperate climates. Rainfall less than 10 inches per year is considered a very arid climate. With over twice the annual rainfall, LFG generation at Spadra will be significantly higher than AVPL since precipitation has a direct affect on LFG generation. As such, the referenced landfills are not comparable to the AVPL when assessing its feasibility for such a LFGTE or project. As noted by the commenter, the U.S. EPA Landfill Methane Outreach Program (LMOP) (see http://www.epa.gov/lmop/) supports the recovery of LFG for beneficial use. WMI is an LMOP partner and actively participates in LMOP’s activities and programs. WMI, for example, now has 124 projects that use landfill gas for alternative energy. This portfolio includes 56 LFGTE plants that WMI has developed, owns, and operates internally, with over 250 engines and turbines producing almost 300 MW of power. WMI continue to grow by 8 to 10 new projects per year. For each project, WMI Renewable Energy Group evaluates the LFG technology most applicable for the landfill, performs a feasibility study of project viability, and manages the project development, construction, and operation. AVPL is included on the list of sites for potential future development of a LFGTE or facility if, as explained below, the LFG flow rates and methane quality at AVPL increase such that a LFGTE or or CNG plant at AVPL becomes feasible. Generally, the first hurdle for a landfill gas project, including those suggested by the commenter, is ensuring that there will be sufficient landfill gas with suitable quality to support the project throughout a life of 20 years or more. Conversely, the first priority of operating a gas collection system is to maintain environmental controls for landfill gas surface emissions, odor, and migration. In some situations, achieving a sufficient quantity and quality of fuel can conflict with operating a well field for compliance, as described below. ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-37 RESPONSE TO COMMENTS/FINAL EIR The flow rates at AVPL have generally exceeded 700 scfm (standard cubic feet per minute) during 2010; however, those rates have varied greatly from a high of 1,080 scfm to, most recently, a low of 671 scfm. Please refer to Appendix B of this document. The gas flow model for AVPL predicts, under current operating conditions, a gradual increase in flow rates which eventually reach roughly 1,200 scfm in 6 to 8 years. Under the recommended 1,800 tpd alternative, moreover, peak production rates of 1,600 scfm are expected. To be technically and economically feasible at the AVPL, a LFGTE project would require a reliable landfill gas flow rate of approximately 1,200 scfm with 50 percent methane quality and low oxygen content. A feasible facility would require approximately 2,500 scfm with 50 percent methane quality and low oxygen. (TC with Paul Pabor, WMI (September 27, 2010).) Gas flows are anticipated to continue to fluctuate in the future under normal operating conditions and well field build-out schedules. A small decrease in flow would result in insufficient fuel for even one engine. Additionally, as recycling and increased diversion of organic waste continues, the methane generation potential of the disposed refuse is anticipated to decrease. These factors increase the uncertainty of the feasibility of such LFG projects at this time, in part, because achieving the required long-term gas flows is not foreseeable. This trend has been documented by CARB as a result of implementing AB 939. In the California’s 1990-2004 Greenhouse Gas Emissions Inventory and 1990 Emissions Level, Technical Support Document for the statewide GHG inventory under AB 32 (CARB, 2009), Table 37 shows the decrease in biodegradable carbon in the waste stream in California, starting in 1995, the first year of compliance for AB 939. CARB attributes this decrease, which continues through the 2004 inventory year, to implementation of increased diversion under AB 939. Decreases in biodegradable carbon in the waste stream have a direct reducing influence on the methane generation potential of that waste. If, as proposed by SB 737 (Chesbro), but recently vetoed by the Governor on September 28, 2010, the Legislature eventually requires a 75 percent increase in diversion of organics for certain sectors multifamily and commercial uses) to landfills for purposes of reducing their methane generating potential, the feasibility of LFGTE and plants at arid landfills such as the AVPL will be further cast into doubt. The quality of the gas is also an issue which generally relates to the percentage of methane. Depending on the site, landfill gas usually consists of about 50 percent to 60 percent methane and the balance of carbon dioxide when it is produced in the landfill. In dry climates such as Palmdale, the percentage of methane is generally less. A gas collection system extracts gas by placing a vacuum on the system of wells and pipes. The vacuum will pull in a small amount of air into the system, which introduces oxygen and nitrogen into the landfill gas mixture, and dilutes the methane content. The vacuum is increased as needed to provide the adequate control level for emissions, migration, and odor. The higher the vacuum, the higher the potential for diluting the methane content, so environmental control measures can be at odds with achieving quality gas. ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-38 RESPONSE TO COMMENTS/FINAL EIR At AVPL, the vacuum level currently needed for adequate environmental control has resulted in a methane content that fluctuates in the low to mid 40 percent range. Please see Appendix B of this document. While some engine vendors allege that only a minimum methane content in the low 40’s is required, WMI has found through experience at other sites that reliability, efficiency, and maintenance is feasible only where the gas is above about 48 percent. This is especially true at dry landfills such as AVPL where the balance between compliance and gas quality is sensitive to the vacuum control, and where WMI is still in the process of tuning the well field for this balance. Thus, additional time is required for the landfill gas flows and quality needed to sustain a LFGTE or plant will be realized at the AVPL, while also continuing to meet existing regulatory requirements for LFG compliance. The California Air Resources Board (CARB), moreover, recently passed the Landfill Methane Rule under AB 32, which will require even more stringent control of surface emissions than currently occurs, which may increase the vacuum needed for compliance. This will further restrict the AVPL’s ability to improve the gas quality. AVPL will continue to operate the well field to meet current and AB32 compliance requirements, while striving to maintain the gas quality to meet the needs of reliable engine performance. The AVPL has only recently reached a methane content of 48 percent. Typically, for a site with marginal gas, WMI look for a 6-month period of sustained flow with good quality gas before committing to a project, as well as a high confidence level that this flow will be sustained in the future. Proceeding now with a minimally sized LFGTE project one engine with a capacity of 1.6 MW and gas flow requirement of 600 scfm) would also not avoid or substantially lessen any of the significant adverse environmental impacts of the proposed project (or of the reduced (1,800 tpd) alternative), and is therefore not required under CEQA. Additionally, the infrastructure costs associated with having to engineer, construct a utility interconnect (of which there is none at AVPL), pay the costs of a utility interconnect fee, construct the electrical transmission infrastructure etc. for such a modest project also render a LFGTE plant at AVPL infeasible at this time. Mitigation Measure 4.2-6 has been revised to reflect this response and the City’s consideration of the comments regarding alternative LFGTE or projects at the AVPL. Mitigation Measure 4.2-6 now requires implementation of a LFGTE or facility at AVPL when landfill gas flow rates and quality achieve the levels needed to support one of the respective projects. Response 12-14 – D. Municipal Solid Waste Power Plants The comment is acknowledged. ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-39 RESPONSE TO COMMENTS/FINAL EIR There are only three remaining “traditional” waste to energy (WTE) plants mass burn) in California (Long Beach (1988), Commerce (1987), and Stanislaus County (1989)). All recent efforts to develop new plants have been unsuccessful in the communities where they were proposed for a variety of permitting issues (source: http://www.energy.ca.gov/biomass/msw.html). As indicated above, the last WTE in California (Stanislaus County) was permitted more than twenty years ago. WMI is very supportive of the WTE technology through its Wheelabrator subsidiary, but developing such a project in California is simply not a feasible option due to the very stringent permitting and environmental review processes in the state and the uncertainties of the feasibility of such a project, including unfavorable economic conditions when compared to the existing solid waste management infrastructure relatively low landfill tipping fees). The other “conversion technologies” (CTs) cited are unproven in large scale applications, and many cannot be developed in a financially sound manner at this time. There are a number of communities evaluating pilot projects using different technologies, but no large scale plant will be coming online in the short term. Many proposed CT projects involving municipal solid waste have already been rejected by municipalities or otherwise failed to develop, including for example projects proposed in the City of Sacramento (plasma arc) and City of Lancaster (anaerobic digestion). WMI is developing a pilot CT project at one of its Oregon landfills that will utilize the plasma arc technology; however, this project and others like are still in the experimental phase and certainly do not support an investment of millions of dollars for a full-scale facility. As such, there are simply not viable alternatives to be considered at this time until it is demonstrated that they are permittable in the state, the technology is proven on a commercial scale, uncertainties regarding environmental impacts are resolved, and financial viability is proven on an actual operating plant in a similar California community to Palmdale. The fact of the matter is that no new large scale thermal CTs, such as pyrolysis, gasification, or plasma arc have ever been installed in California, so the suggestion that the firms developing these technologies have “proven track record” is simply incorrect. Some of the CTs (such as waste gasification, plasma arc, etc.) have not been developed on a commercial scale here in the U.S., and there is limited data available on existing international facilities so as to ascertain what the long-term energy and environmental impacts will be. Further, it is unclear whether these technologies are permittable here in California since most of them entail essentially some form of waste combustion, which has not been permitted in the state for many years due to CEQA and other environmental review issues. Some biological CTs (such as anaerobic digestion) are technologically feasible; however, they can only manage a portion of the MSW waste stream source-separated organics) require extensive pre-processing of the waste, generate residuals that must be managed, and their cost per ton of equivalent tipping fee is much greater than landfilling with estimates ranging from $120 to $150/ton. ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-40 RESPONSE TO COMMENTS/FINAL EIR Response 12-15 – E. Methane Fermentation Technology The comment is acknowledged. Methane fermentation or anaerobic is a technology that is technologically feasible for the organic portion of various waste. However, it has various limitations including a need for source separated organics and significant pre-processing of the waste which are infeasible for large scale projects, such as the proposed project, because of the large volumes of mixed waste required to be processed. Thus, large scale projects using municipal solid waste simply cannot be developed in an economically sound manner. Previous estimates for the technology have been in the range of $120 to $150 per ton equivalent tipping fee, which is simply unattainable in these tough economic times. Response 12-16 – F. Energy Impacts The commenter’s opinion that the project has the potential for significant energy impacts because “LNG does not save energy over diesel fuel to any significant degree” is noted. CEQA requires any potentially significant energy implications of a project to be considered in an EIR to the extent relevant and applicable to the project. (CEQA Guidelines, Appendix F The commenter references information in the EIR regarding WMI’s gradual conversion of its truck fleet to LNG/CNG or other alternative fuels, which is primarily designed to reduce GHG emissions and for cleaner air quality as compared to diesel-fueled vehicles which contribute to criteria air pollutants and toxic emissions diesel particulate). AVPL’s provision of LNG at the site and accessible to the public helps decrease reliance on fossil fuels such as natural gas and fossil fuel derived diesel, thereby offsetting energy use from traditional sources (please refer to Section 1.5, Additional Energy Information, of this Final EIR document). Response 12-17 The commenter claims the proposed increased daily tonnage would result in a considerable increase in energy used for hauling refuse to the site and landfilling larger quantities of msw. Regardless of whether or not the proposed project, or alternative thereof, is approved by the City, msw will continue to be generated in California. That waste will need to be transported to a permitted Class III landfill for disposal. Without the proposed project, msw may need to be transported longer distances to Lancaster Landfill (approx. 25 miles roundtrip) or, if Lancaster cannot accept the waste, to the Chiquita Canyon Landfill (approx. 90 miles roundtrip)), than if the waste were to be disposed of at the AVPL, resulting in more VMT and energy use per year and a corresponding increase in regional CO2 emissions. Therefore, although the project would continue to contribute to energy use and CO2 emissions regionally, the emissions would be similar or less than the net increase in energy use/emissions without the project. ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-41 RESPONSE TO COMMENTS/FINAL EIR A portion of the proposed daily tonnage increase was anticipated to serve large capacity transfer trucks from existing waste transfer stations, rather than by smaller individual packer trucks. These larger trucks can reduce energy use by moving more refuse with fewer overall vehicle miles traveled, thereby resulting in less overall fuel use and fewer emissions. As noted above, increasing the ability of the AVPL to accept more tpd could decrease overall energy use and regional VMTs since the no-project alternative would involve hauling existing waste longer distances in, potentially, smaller waste collection trucks. It should also be noted that staff has decided to recommend approval of the Reduced Project Alternative-Expansion (11-acre) with no increase in daily permitted tonnage (1,800 TPD) which would result in a continuation of existing operations at permitted levels. AVPL/WM is agreeable to staff’s recommendation. Please also refer to Section 5.2.3 (pages 5-12 to 5-14 for a detailed analysis on this alternative) of the Amendment to the Draft EIR; see also Section 1.5, Additional Energy Information, of this Final EIR document addressing the recently revised Appendix F (Energy Conservation) contained within the CEQA Guidelines. These additions do not change the Amendment to the Draft EIR conclusions. Response 12-18 The commenter claims the EIR does not report the baseline average daily vehicle count for the landfill. Please refer to the Amendment to the Draft EIR Traffic Section 4.7 (page 4.7-6 and Table 4.7-3), which do provide the existing baseline traffic conditions. As stated on page 4.2-11, “For purposes of presenting a worst case air quality impact analysis, the existing daily traffic (416 truck trips) and disposal volume (1,372 TPD) were treated as the baseline, and disposal volume was presumed to instantaneously jump to the maximum allowable disposal volume of 5,548 TPD which equates to 1,134 truck trips.” Staff’s recommendation to approve the 1,800 TPD disposal alternative, as the environmentally superior alternative, would eliminate the commenter’s concern that the proposed project would result in significant adverse energy impacts from increased daily tonnages or truck trips. As noted above, the number of trash trucks on the road and the amount of vehicle miles traveled hauling refuse is a regional issue. An individual landfill does not generate a demand for refuse disposal; it accommodates existing demands and is planned to meet future demands based on population growth. Energy consumption from landfilling is minimized if the disposal facility is located close to the source of refuse generation and/or if larger capacity trucks are used for longer haul trips. Each of these scenarios allows for less vehicle miles to be traveled, less fuel consumption, and thus less energy-related impacts. As an additional benefit, reduced haul distances also result in air quality and GHG benefits (reductions) associated the lower fuel consumption. Please also refer to Section 7.1, Growth Inducing Impacts of the Amendment to ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-42 RESPONSE TO COMMENTS/FINAL EIR the Draft EIR for a more detailed discussion of the factors which do not make the project growth inducing. Response 12-19 The commenter claims that the proposed project would result in a 77 percent increase in the volume of landfilled material and consequently a potentially significant energy impact. The commenter’s opinion is noted. Regional energy use for refuse disposal and transport is linked to the capacity at an individual landfill only if the capacity at that landfill is limited and longer driving distances would be required to deliver the waste an alternate site. Such is the case here where adding capacity close to existing active landfill reduces the need for increased out-of-area disposal and hauling, resulting in less energy use. Increasing the landfill capacity without increasing the acceptable daily tonnage will have no significant effect on short-term or annual energy consumption; it will merely allow the landfill to accept the community’s refuse for additional years. Without the capacity increase, the future waste tonnages would have to be disposed of somewhere and will likely require being transported longer haul distances to another landfill, as explained in Response 12-17 above, resulting in an increase in energy use, when the existing capacity is consumed. The provision of local landfill capacity that reduces travel distances and on-going recycling efforts to reduce energy consumption were the basis that allowed the Initial Study to conclude that there was no impact to energy resources requiring an energy impact analysis in this document (please refer to Section 1.5, Additional Energy Information, of this Final EIR document.) Response 12-20 The commenter requests that the EIR quantify the fuel requirements that would be needed for excavating new landfill cells, disposing and compacting msw, excavating or importing daily cover and for related activities. The commenter infers that the EIR needs to engage in a life cycle analysis of all the existing and proposed activities at the AVPL that would require the use of fossil fuels, including the extraction, refining and transport of crude oil to the site which, in the commenter’s opinion, would create a cumulative impact on the environment. According to Section 15130(b) of the State CEQA Guidelines the discussion of cumulative impacts shall reflect the severity of the impacts and their likelihood of occurrence, but the discussion need not provide as great detail as is provided for the effects attributable to the project alone. The discussion should be guided by standards of practicality and reasonableness, and should focus on the cumulative impact to which the identified other projects contribute rather than the attributes of other projects which do not contribute to the cumulative impact. CEQA does not require lead agencies to engage in a speculative life cycle analysis such as that required by the commenter. (See Appendix F (energy implications of a project shall be considered to the extent relevant and applicable to the project); see also Tracy First v. City of Tracy (2009) 177 Cal.App.4th 912 (reasoning that “neither Appendix F, itself, nor any other authority requires that an EIR discuss every possibly energy impact or conservation measure listed in Appendix ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-43 RESPONSE TO COMMENTS/FINAL EIR Please also refer to Table 3-3 and page 3-13 of the Amendment to the Draft EIR which indicates that there will be no significant changes or additions to existing Landfill Equipment and Personnel. Page 4.2-11 of the Amendment to the Draft EIR also notes that the equipment needed to process the increased disposal will not be measurably different from existing on-site, off-road equipment. If the msw is not landfilled at AVPL, it will likely be landfilled elsewhere with similar and possibly greater energy impacts, including increased use of diesel and/or LNG. Please see Response 12-17 for additional details on the impact of increased haul distances for alternative landfill sites. Fuel consumption was calculated, moreover, as part of the greenhouse gas/climate change analysis for the 3,613 TPD project. Please refer to Appendix C-1, AB-32 Compliance Study of the Amendment to the Draft EIR. Vehicle fuel consumption demand for mobile on-road trucks under the proposed project, for example, was calculated in the EIR to increase from 564 gallons per day of diesel fuel plus gasoline to 1,181 gallons of combined fuels. The fuel increase was not linearly proportional to tonnage because the expanded operation was presumed to use higher load factors (tons/mile) than the smaller capacity “packer” truck fleet. For the Reduced Project Alternative, on-road fuel consumption was presumed to be roughly proportional to existing permitted disposal rates because no transfer of refuse to large-load vehicles would occur. Please refer to Appendix C-1, AB-32 Compliance Study of the Amendment to the Draft EIR. The input parameters for the three analyzed scenarios were as follows: Existing 3613 TPD 1800 TPD Surface Street Trucks 1945 ADT 4039 ADT 2552 ADT Freeway Trucks 936 ADT 1944 ADT 1228 ADT Auto & Small Truck (Gas) 1155 ADT 2530 ADT 1515 ADT For assumed fuel efficiencies of 13.75 mpg for self-haul and 6 mpg for heavy diesel, the following fuel consumption would result under the same scenarios: Existing 3613 TPD 1800 TPD Diesel Trucks 480 gal 997 gal 630 gal Self-Haul Gasoline 84 gal 184 gal 110 gal TOTAL Fuel 564 gal 1,181 gal 740 gal The resulting GHG emissions from internal combustion sources, such as diesel or gasoline- fueled engines, were calculated by combining published conversion data from fuel burned to GHG emissions assuming 306 days of allowable maximum disposal. Annual metric tons (MT) of CO2 emissions are calculated as follows: ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-44 RESPONSE TO COMMENTS/FINAL EIR Existing 3613 TPD 1800 TPD On-Road Trucks 1492 MT 3099 MT 1958 MT Self-Haul 233 MT 511 MT 306 MT Off-Road Equipment 1850 MT 2434 MT 2434 MT TOTAL 3575 MT 6044 MT 4698 MT The EIR concluded that neither disposal alternative would cause a significant adverse effect on the environment from either direct or indirect GHG emissions. Approval of the 1,800 tpd Reduced Size Alternative would result in a less than significant increase in fuel used at the site and therefore would not be a significant or wasteful use of energy. If the same refuse were disposed of at another landfill, the fuel consumption and GHG impacts would likely be greater due to increased haul distances (see Response 12-17). Response 12-21 The commenter asserts energy will be required for a new signalized intersection, an additional truck scale, staffing and extended hours of operation and that the energy efficiency of the buildings on site should be evaluated. Energy demands for new intersection signals are within the City’s jurisdiction and are anticipated to be minimal since new regulations require all new traffic lights to be light-emitting diode (LED) versions. Onsite, the largest structures at the AVPL are used for truck maintenance and parts storage and service and are not air conditioned. Maintenance bays are open to the outside with substantial natural light. Thus, no existing on-site structures are believed to be substantial energy consumers or wasters. No new buildings are proposed as part of the project. All existing and any future proposed buildings, if any ever are proposed, would comply with Title 24 of the California Code of Regulations, California’s Building Energy Efficiency Standards, which are meant to promote energy efficiency and reduce the wasteful, inefficient, and unnecessary consumption of energy. (See, e.g., Pub. Resources Code, § 21100, subd. Tracy First v. City of Tracy (2009) 177 Cal.App.4th 912.) Please also refer to the above response regarding no significant changes in Landfill Equipment or personnel. Response 12-22 The commenter requests that the EIR evaluate and implement all feasible ways to recover energy from the waste stream at AVPL. Generally, capturing methane in LFG and combusting it to generate electricity for on-site energy needs or to convert to LNG/CNG reduces energy demands and GHG emissions by: reducing direct methane emissions that may otherwise result ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-45 RESPONSE TO COMMENTS/FINAL EIR from flaring; and by displacing electricity demand and the associated indirect GHG emissions from electricity production. A LFG to energy or LFG to LNG/CNG plant has been considered by the AVPL and determined to be infeasible at this time. This is for two main reasons. First, the existing and anticipated LFG at AVPL is of relatively poor quality, amount and reliability needed to create a viable LFG to energy or LFG to CNG/LNG facility. Second, the anticipated costs of a LFG to energy or LFG to LNG/CNG plant at AVPL would outweigh the expected net return on investment if that energy or LNG/CNG were to be sold. With respect to the first reason, over the last several months, the gas quality at the AVPL has average around 43 percent methane. This level of methane content is not sufficient to meet the minimum requirements for successful engine operation for a LFG to energy plant - where approximately 50 percent methane is required at AVPL. Also because of the very dry climate in the Palmdale area, it is difficult to get the necessary gas production to improve the gas quality (TC with Paul Pabor, WMI (September 27, 2010)) as low precipitation results in reduced gas generation as documented in the U.S. EPA’s landfill gas emissions model (LandGEM). Please refer to Appendix C-1, AB-32 Compliance Study of the Amendment to the Draft EIR. Under low gas production situations, WMI’s substantial operational experience with LFG systems shows that it is more difficult to extract high quality gas without air intrusion when the gas production is low. This is documented throughout the landfill industry where landfills in arid climates have lesser gas quality lower methane concentrations). Examples include landfills throughout the Central Valley of California, Phoenix area, Imperial County, Las Vegas area, etc. Recent existing LFG rates at AVPL have also proven unreliable. LFG rates flux from 1,080 scfm 671scfm. Given the volume fluctuation as well as the marginal quality of the gas at this site to ensure sustainable operation, an LFG to CNG/LNG plant would require at least 1,200 scfm (TC with Paul Pabor, WMI (September 27, 2010)). The California Air Resources Board’s (CARB’s) recent passage of the Landfill Methane Rule under AB 32 is also a factor of consideration. That rule will require more stringent control of landfill surface emissions than currently occurs and therefore even less ability to capture additional methane or improve qas quality for a LFG to energy or LFG to LNG/CNG project. This is because when a LFG system is operated to control surface emission down to very low levels as stipulated in the AB 32 rule, it causes more air intrusion the gas system pulls in more ambient air along with the LFG when it is operated to better control emissions near the surface), which reduces the methane content of the gas. Finally, because recycling and organic diversions are anticipated to continue increasing under pending GHG regulations, the methane generation potential for disposed refuse is expected to decrease, thereby lessening the potential to achieve the higher methane content and gas rates needed. When degradable material is removed from the waste stream, this lowers the methane generation potential of the waste ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-46 RESPONSE TO COMMENTS/FINAL EIR the so called “Lo” term in the LandGEM first order decay equation for methane generation at landfills). This means that the amount of methane produced from an equivalent amount of waste disposed will be less if that waste stream is depleted of its organic and degradable material. This is especially true given staff’s recommendation to approve the Reduced 1,800 tpd alternative. This phenomenon has also already been documented by CARB in their methane generation model inputs used in the statewide GHG inventory under AB 32 as resulting from the implementation of AB 939. CARB’s models inputs (methane generation potential or Lo value) document a decline in the methane generation potential starting in 1990 with the initial implementation of AB 939, with that potential getting lower as diversion rates increased over time. This is only expected to continue reducing methane generation potential as increased diversion occurs beyond the current 50 percent level. Secondly, in addition to investigating the technical feasibility of a LFG to energy or CNG/LNG project at AVPL, WMI/AVPL conducted a preliminary fiscal analysis. This analysis considered the costs of engineering, construction of infrastructure, operations, and utility interconnect and compared those to the potential revenue for sale of the electricity to the local utility, SCE. At the projected sustainable level of gas recovery which is presently 700 to 889 cfm of LFG at approximately 43 percent methane, (analyzed over 10 to 15 years time horizons), no LFG reuse alternative was determined to be feasible at this time. (See also Response 12-13.) Response 12-23 The commenter states that the possibility of the project impacting a valuable clean-energy resource should be carefully evaluated. As reflected in Response 12-22, the potential for converting LFG to energy or an alternative fuel source has been considered at AVPL and is not feasible at this time. Additionally, many other factors must be considered when deeming an energy resource valuable, including the cost of production and its cost-competitiveness with other conventional resources, and indirect potential negative effects to the environment. Many alternative energy projects unfortunately do not produce energy at a cost-competitive rate unless there are additional incentives to off-set the differential. Further, many of the so-called “conversion technologies” (CTs) are unproven as to their technological feasibility, energy consumption, and/or environmental impacts. Some of the CTs (such as waste gasification, plasma arc, etc.) have not been developed on a commercial scale here in the U.S., and there is limited data available on existing international facilities so as to ascertain what the long-term energy and environmental impacts will be. Further, it is unclear whether these technologies are permittable here in California since most of them entail essentially some form of waste combustion, which has not been permitted in the state for over a decade due to CEQA and other environmental concerns. Some CTs (such as anaerobic digestion) are technologically feasible; however, they can only manage a portion of the MSW waste stream previously source-separated organics) and their cost per ton of equivalent tipping fee is much greater than landfilling with estimates ranging from $120 to $150/ton. As such, they are not feasible to ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-47 RESPONSE TO COMMENTS/FINAL EIR consider at this time for AVPL and would represent an unacceptable risk due to the many uncertainties associated with them, including economic non-viability, additional environmental and operational impacts due to pre-processing of the waste for grinding and screening), and additional operational effects resulting for the need to source-separate specific organics. Finally, the site could potentially recover (in the future if LFG rates increase and stabilize) methane to be converted to clean energy when additional material is disposed in the landfill. Each of these other technologies would, however, remove organic waste from the landfill thereby reducing the energy potential of the LFG and contributing to the existing infeasibility of a LFG to energy project at AVPL. See also Response 12-13. Response 12-24 Please see Responses 12-13 and 12-22 through 12-23. Response 12-25 The commenter claims the AVPL is similar in size to the Spadra Landfill which operates a materials recovery and Rankine Cycle Steam Power Plant. AVPL has a recycling program in place to accept and utilize many of the same materials as those recovered at Spadra. Spadra has been closed for ten years and the amount of land available at the AVPL is smaller such that a facility of the Rankine plant would not fit. When Spadra was operational, many recyclable resources were not separated until they had been brought to the landfill where they were recovered and then hauled away again. Presorting through a TS/MRF prior to landfilling is now the standard procedure. This changes the pattern of recycling and recovery potential. Because of improved technologies for waste and LFG management that have developed over the last ten years since Spadra closed, it is anticipated that the AVPL can and will be operated in a more environmentally beneficial manner that many older landfills in Southern California. This includes increased recycling, better pre-sorting of waste, improved load checking programs, better landfill and LFG system designs, more efficient landfill operations, etc. Further, the Rankin cycle engine in use at the Spadra Landfill is an experimental technology that is only being used at a limited number of landfills with mixed results. At the present time, it is not considered a viable option for a commercial LFG to energy project at this time at AVPL, in part, because Spadra produces significantly more LFG than AVLP. According to the Los Angeles County Sanitation Districts’ website Spadra produces approximately 5 MW of power from LFG. Based on site monitoring data for AVLF, the landfill presently only collects enough LFG for a 1.5 to 2 MW plant. This makes various energy recovery options more viable when a project can support as much as 5 MW, and such a project realizes a much greater benefit in the economics of scale than one less than half of its size. Response 12-26 The commenter claims the EIR should evaluate the potential energy savings from recycling as opposed to landfilling. As explained above, recycling and source separation at existing ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-48 RESPONSE TO COMMENTS/FINAL EIR TS/MRFs generally occurs prior to transport and disposal of waste at AVPL. This practice is not expected to change if the proposed project or Reduced Alternative is approved. In fact, under AB 939 and the currently proposed AB 737 (Chesbro), recycling on a statewide level will likely be expanded. AB 737 would, for example, apply to every multi-family dwelling and commercial business in California and direct the state (CalRecycle) to come up with a plan to reach a 75 percent diversion rate by 2020. Recycling is discussed throughout the Amendment to the Draft EIR. (See Figure 1-3; see also pp. 1-6, 1-22, 3-4, 3-9, 3-10, 3-13, 3-30, 4.2-31, 4.6-7, 4.7-1, 4.7-6, 5-9, 5-11, 5-12, 5-21, and 8- Response 12-27 The commenter states that the EIR should evaluate the indirect impacts of accepting additional waste at the site per day and consider feasible mitigation to reduce the quantity of material landfilled. Please refer to Section 7.2 (pages 7-1 and 7-2) of the Amendment to the Draft EIR, which provides an analysis on Long-Term Implications of the Project outlining specifically how long the Wedge Expansion can extend the landfill life. As noted above, City staff is recommending approval of the Reduced Project Alternative – Expansion (11-acre) with no increase in daily permitted tonnage (1,800 TPD). Please refer to Section 5.2.3 (pages 5-12 to 5-14) of the Amendment to the Draft EIR for a detailed analysis on this alternative. Response 12-28 – G. Climate Change Impacts The comment is acknowledged. These are the GHG sources analyzed. Response 12-29 The commenter suggests several measures be required prior to issuance of a CUP. Specifically: Haul truck conversion to natural gas – WMI is investing in the use of alternative transportation fuels CNG/LNG) and engine design to lower the GHG emissions for its entire hauling fleet. WMI has, to date, replaced over 500 diesel-fueled vehicles with natural gas fueled trucks and has retrofitted over 1,100 vehicles with advanced pollution control devices. WM also continues to use a fleet routing software to maximize collection efficiencies and minimize fuel use. Idle reduction – Idling at the fee booth has been reduced through modernized weighing procedures and trucks are required to limit idling in place to no more than five minutes as required by existing state law. Landfill equipment – There are no state GHG emission standards for landfill equipment. The referenced emission standards are for particulate matter and nitrogen oxides. There is a small ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-49 RESPONSE TO COMMENTS/FINAL EIR GHG benefit because newer engines are somewhat more efficient, but the GHG saving is small compared to the overall emissions burden. The AVPL will continue to comply with federal, state and local laws as may be adopted in the future. Biodiesel fuel – Use of biodiesel as a GHG reduction option has been evaluated by a number of experts with mixed results. Some have concluded that when the life cycle of GHG emissions from planting, cultivation, fertilization, harvesting and processing of corn or soy beans (when those or other food sources are used) are considered, biodiesel may actually increase GHG emissions compared to CNG or ultra low sulfur with enhanced filter traps/petroleum-based diesel. CARB came to this conclusion when they considered the carbon intensity of various fuels under AB 32. Ethanol produced from corn or soy beans, for example, were not designated as low carbon fuels due to the energy intensity involved with their production, even though they were displacing fossil fuels. Third party contracts – To the extent future third-party contracts are required to serve the AVPL, the site will negotiate those contracts with the goal of favoring haulers who demonstrate use of alternative or other clean fuels (see Mitigation Measure 4.2-6 in the Amendment to the Draft EIR). See also Response 12-19. LFG recovery –Please see Responses 12-12 and 12-22 for further details. Organic material diversion – WMI already diverts and recycles green waste and wood scrap at AVPL for use as a fuel in the mineral products industry. The complete diversion of organics would require intensive pre-sorting and still require subsequent treatment and disposal of the organic fraction. It would also decrease the LFG production and make it less likely that a LFG beneficial use project would be developed. GHG reduction plan – the Amendment to the DEIR concluded that the direct and cumulative contribution of the AVPL project to climate change would be less than significant. (Amendment, p. 4.2-32.) The EIR reflects the same conclusions of less than significant if the City decided to follow staff’s recommendation to approve the Reduced 1,800 tpd alternative. (Amendment, p. 5- 12.) Nevertheless, given the overall threat of climate change generally, the EIR requires preparation of a complete and enforceable GHG reduction plan. (Amendment, pp. 4.2-30 thru - 31 (MM WMI, moreover, is a member of the California Climate Action Registry and has established company-wide commitments to quantification and reporting of the company’s carbon footprint, as well as commitments to reduce that footprint to the extent feasible. WMI will adapt these company-wide GHG practices to site-specific conditions at the AVPL, if and when they become feasible, which will allow for a reduced carbon footprint for the landfill over time. ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-50 RESPONSE TO COMMENTS/FINAL EIR WMI is committed to recycling as much of the waste-stream as can be diverted and for which there is a market for the recycled material. Construction and demolition debris and green-waste are currently recycled, and an e-waste and household hazardous waste acceptance facility operates on-site. Any substantial increase in recycling would require construction of a materials recovery facility which is currently not planned at AVPL. Furthermore, all recycling is not created equal. Composting, for example, is now known to have significant volatile organic compound (VOC) emissions when its emissions are not collected and controlled. Therefore, uncontrolled composting of organic waste can have more VOC emissions compared to a landfill where the VOCs are collected and destroyed in LFG. So, even though the composting has energy benefits, it also can create adverse environmental effects due to VOC emissions. As such, recycling must be considered on a case-by-case. Response 12-30 – H. Air Quality Impacts The commenter claims the air quality analysis is inconsistent and dated. The analysis was current and correct at the time of the EIR’s preparation. Please refer to above Response 12-4. There have been subsequent changes in the regulatory environment, particularly with regard to ozone. The one-hour federal standard was revoked and replaced with an 8-hour standard. The Antelope Valley is classified as a non-attainment area for the federal 8-hour and the state 1- and 8-hour ozone standards. The ozone attainment plan for the air basin was modified to remove the previous 1-hour attainment goal of 2007 and replaced with an 8-hour attainment goal of 2021. The air basin is designated at being in attainment or unclassified (insufficient data) for every other air pollutant, including for all sizes of particulate matter. The analysis is correct in stating that there is substantial dispersive capacity in the basin for CO and NO2 in that peak background levels are far below their most stringent standards. Response 12-31 As shown in Table 4.2-5 of the Amendment to the Draft EIR, the AVAQMD CEQA significance threshold for NOx is 137 pounds per day. At 123 pounds per day, cumulative NOx increases from all sources of the proposed project will not exceed the threshold and are therefore considered less than significant on a project specific basis. The cumulative contribution of the proposed project, however, in addition to existing operations and reasonably foreseeable future related projects, was concluded to be significant and unavoidable for NOx and ROG. (Amendment, p. 4.2-32.) Response 12-32 The immediate conversion of all diesel equipment and hauling trucks at the AVPL to LNG/CNG as suggested by the commenter is infeasible. (See Responses 2-13 and 2-29). It is also not required by CEQA to avoid or substantially lessen significant adverse impacts of the proposed ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-51 RESPONSE TO COMMENTS/FINAL EIR project or, especially, the Reduced 1,800 tpd Alternative recommended by staff. Fueling onsite heavy duty diesel equipment with CNG/LNG, moreover, is infeasible as such equipment is not yet commercially available as the lack of horsepower needed needed for dozers) has been an issue ((TC with Marty Tufte, WMI (October 1, 2010)). As stated in the Amendment to the Draft EIR, there are no impacts that exceed AVAQMD CEQA significance thresholds, including Appendix G of the revised Guidelines related to GHG emissions. The conversion of the refuse collection fleet to LNG is in progress as new replacement trucks are CNG/LNG fueled. Response 12-33 AVPL does not yet produce LFG in sufficient quantity to make a LFG to motor fuel facility or a LFG to electricity project economically viable due to poor economies of scale and methane content deficiency as detailed previously (Responses 12-12 and 12-22). Again, the comment notes that this is a mitigation measures, but the air quality impact does not exceed the adopted significance thresholds that would require consideration of mitigation. Even if LFG production were to ultimately rise to a level where a beneficial use were to become viable, Federal New Source Performance Standards (NSPS) and California Title 17 and 27 regulations necessitate that a landfill maintain a back-up flare for gas surges, processing equipment outage, etc. Some LFG would be flared even with a beneficial use in place. A bioreactor at the AVPL would not be needed to maximize LFG recovery since recovery is contingent on the types of waste landfilled and the quality of the LFG collection and recovery system. Bioreactors, moreover, require large amounts of liquids which would require additional truck trips to AVPL since liquids are not currently received for at the site for this purpose (even assuming the liquids could be obtained in the amount that would be required). Bioreactors also typically result in large albeit shorter lifespan spikes in air quality emissions because msw breaks down more rapidly than a traditional dry msw landfill. Given the arid nature of the site and the amount of liquids that would be required, and the fact that other additional adverse impacts may result from bioreactor technologies, the AVPL has declined to pursue this suggested alternative. Response 12-34 The existing weigh station/fee booth has a state-of-the-art computerized system to minimize truck waiting times. Landfill equipment is turned off when not engaged in processing waste in accordance with state law. Idling trucks and off-road equipment expend fuel and consume driver and operator time when not in active use that could be productively used elsewhere. These measures are not considered mitigation in that they are part of the project design and existing operations. ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-52 RESPONSE TO COMMENTS/FINAL EIR Response 12-35 – I. Resource Exhaustion and Extraction Impacts The commenter’s opinion that landfilling is far from a perfect solution is noted. The commenter’s suggestion that the EIR must consider all possible alternatives to landfilling as part of the EIR for the proposed project, however, is not required under CEQA. CEQA requires lead agencies to identify and consider in an EIR a “reasonable range” of potentially feasible alternatives that avoid or substantially lessen the significant adverse impacts of a project, and which will attain most of the project objectives.(See California Oak Foundation v. Regents of the Univ. of Ca. (Sept. 3, 2010)___Cal.App.4th____) (upholding University’s analysis of alternatives to stadium project).) In accordance with Section 15126.6(a) of the CEQA Guidelines, the EIR including the Amendment to the Draft EIR provides a range of reasonable alternatives. The Amendment to the Draft EIR, specifically, provides an analysis of four different alternatives as directed by City staff through the planning process (refer to Section 5.0 Alternatives to the Proposed Project of the Amendment to the Draft EIR). Response 12-36 The comment is acknowledged. The AVPL recycles materials that are transferred to the site to the extent they can be economically recovered from the waste stream and for which there is a market. Residential recyclables are curbside pre-sorted and processed as separate waste streams. Any additional recycling in the mixed municipal waste would require construction of a materials recovery facility which is not a currently planned project at the AVPL. The comments regarding the benefits of recycling generally are noted. Response 12-37 Current recycling activities are driven by the character of the waste-stream and the economics of recycling. A number of suggested resources in this comment (construction debris, green- waste, tires, hazardous materials, etc.) are already being extracted and re-used or recycled at the AVPL as explained in the EIR. Additional recycling of the mixed waste is not economically viable at the present time. In California and at the AVPL, under AB 939, 50 percent of the existing waste stream received does not consist of traditional recycling materials. Response 12-38 Recycling activities at the AVPL are described in responses above. AVPL is also the site of the Antelope Valley Environmental Collection Center (AVECC) which is open to the public twice per month for the disposal of electronic waste and for the disposal of household hazardous waste (batteries, oil, paint, etc.). No further response is required. Response 12-39 The commenter’s perception of his site visit and conversation with WM staff is acknowledged. Some recyclables are stockpiled prior to processing such that processing activities are not necessarily in evidence at any specific point in time that an individual may visit the site. Many ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-53 RESPONSE TO COMMENTS/FINAL EIR source-separated recyclables from Palmdale, for example, are collected and sent off-site for further processing. The recycling activity is quite active, but not always necessarily at the AVPL itself. Response 12-40 WMI provides separate containers to customers within its contracted service area for mixed refuse, for recyclable paper and metals and for green-waste. Other services include bulky item pick-up, Christmas tree recycling, landfill vouchers, and periodic extra trash bags, and allowance for bundled extra refuse. The AVECC is open the first and third Saturdays to the public. Scavenging is prohibited as a safety and public health issue, and not to discourage recycling. It is not within the jurisdiction or control of the City of Palmdale to improve recycling in other surrounding jurisdictions. Response 12-41 The comment is acknowledged as is the commenter’s inferred preference that the City and County move toward an almost “zero waste” model. Although some within City staff and the public may philosophically agree that a zero waste goal for the City is desirable, in that the existing waste stream could be handled so as to avoid direct disposal in landfills or through the reduction, reuse or recycling of waste to the extent that no residuals remain unclaimed, such goals, even if they were to be adopted, are infeasible given the existing waste handling methods and facilities available. Such efforts require working collaboratively with other municipalities, the County, AVPL and other landfills, to recommend and implement changes that would help eliminate waste streams and increase recoverable resources. This is something the City and AVPL are not necessarily opposed to doing. Such efforts, however, are larger than the potential effects of the proposed project and therefore would lack a nexus or reasonable relationship to the proposed project if attempted to be required as mitigation. Response 12-42 The comment is acknowledged. See also Response 12-41. The commenter’s suggestion to include a recycling center and conduct source reduction programs are outside the project scope. The AVPL currently engages in public education and outreach. The details surrounding a possible future MRF have yet to be identified sufficient enough to engage in meaningful environmental review of such activities. With current source separation programs in Palmdale, moreover, fewer high value materials arrive in the mixed waste stream at the AVPL. As stated in above response 12-8, recyclable materials collected at AVPL are often sent to Lancaster because that site has the area and facilities to process such waste at higher volumes. Response 12-43 The comment suggesting financial incentives for recycling is acknowledged. Such consideration is outside the scope of this project, however, because such incentives would lack ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-54 RESPONSE TO COMMENTS/FINAL EIR a nexus to the significant impacts of the proposed project and, rather than be proposed on a project-by-project basis, should be implemented by a universal statewide or regional mandate for purposes of consistency and enforceability. Financial incentives for recycling already exist in the Antelope Valley, for example, at several buy-back centers and at numerous reverse CRV vending machines. Disposal fees are also being included in many products (tires, oil, electronics, etc.) to the point where recycling is economically preferred to landfilling. Such financial incentives, however, cannot be implemented by a single landfill operator or a single political jurisdiction. Response 12-44 – J. Landfill Exhaustion Impacts Please refer to above Response 12-4 regarding the proper environmental baseline reflecting the time of issuance of the NOP. The second paragraph of page 2-5 of the Amendment to the Draft EIR refers to the “capacity of Landfill I” not the total “approved” capacity of the AVPL. Consistent with the County approved CUP No. 85512 and Figure 1-3 – County Approved Exhibit of the Amendment to the Draft EIR; the Antelope Valley Public Landfill, Landfill II (AVPL- LF II) began receiving refuse in 2007 following the receipt of required permits including, a FOC approved 4/20/95, SWFP #19-AA-5624 issued 6/12/97 and WDR 6-95-1 adopted by on 1/12/95. The LFII interim cell design was initially approved by via 7/21/06 email correspondence. Formal written approval for PhaseVA-1 was issued on 11/20/06 and Phase VA-2 was issued on 2/27/07 by the The receipt of refuse at LFII in 2007 also began after the completion of all required pre-grading conditions/mitigation outlined in CUP Compliance Matrices on file with the City of Palmdale as provided in May 2007. Submittals of the biennial monitoring reports required under County Conditional Use Permit No. 85512-(5), Part VIII – Monitoring Reports were made in March (draft)/April (Final) 2008 and March (draft)/April (Final) 2010 to the required agency contacts. The reports include detailed information on; cumulative total of all waste deposited, landfill survey information, waste density, rates of waste received, recycled or diverted, interaction with solid waste management plans, complaints/ violations, horticultural monitoring and archaeological and paleontological monitoring. Response 12-45 Please refer to above Response 12-7, which explains the additional capacity numbers and Responses 12-9 and 12-10, which explain the population projections used in the Amendment to the Draft EIR analysis. Section 7.2, Long Term Implications of the Amendment to the Draft EIR, addresses the long-term capacity implications of the project and reduced project alternative. It should be noted that staff is recommending approval of the Reduced (1,800 tpd) Project Alternative, which was found to be environmentally superior to the project. ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-55 RESPONSE TO COMMENTS/FINAL EIR Response 12-46 The comment is acknowledged. The Public Services Element of the General Plan on page PS- 43 states, “Other landfills in the region are starting to reach capacity and thus influencing dumping activities at the Palmdale site. Waste Management operates a landfill in Lancaster and recently indicated that the Lancaster landfill has sufficient capacity to accommodate the City of Lancaster’s growth. In addition, the fee structure for waste disposal influences the decision of private haulers to dump in Palmdale rather than another site. If the fees are comparatively lower, more private haulers and disposal companies may use the Palmdale landfill and fill the site faster. If all other landfills are full, haulers may divert solid wastes to the Palmdale site as long as it continues to accept private haulers.” Based on the project objectives outlined in Section 3.4.1 of the Amendment to the Draft EIR, the Proposed Project and Reduced Project Alternative are consistent with the above General Plan policy. Response 12-47 The commenter’s assertions and opinion are acknowledged. Response 12-48 Please refer to above Response 12-43 regarding financial incentives and Responses 12-54 and 12-55 regarding the “reasonable range” of project alternatives. Response 12-49 Please refer to above Responses 12-23 through 26 regarding recycling and materials and energy recovery. The commenter’s opinions about landfilling are noted. Response 12-50 Please refer to the above responses regarding the external costs of siting a new landfill. If the City approves the Reduced Alternative it would maximize the life of the landfill as requested by the commenter. The proposed project is not in conflict with the proposed permit as opined by the commenter. To provide a worst case analysis, the Amendment to the Draft EIR assumed truck trips and associated impact analysis with a “total” peak tonnage of 5,548 (including refuse and recyclables and ADC). Section 3.0 of the Draft EIR and specifically page 3-10 outlines this peak tonnage as one of the proposed project components. The impact analysis address this peak tonnage throughout the Draft EIR including pages 1-6, 3-10, 3-11, 3-12, 3-30, 4.2-11, 4.2-12, 4.2-22, 4.2-24, 4.5-8, 4.5-9, 4.7-1, 4.7-2, 4.7-13, 4.7-15, 4.7-16, 5-4, 5-13, and 5-14. ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-56 RESPONSE TO COMMENTS/FINAL EIR Response 12-51 – K. Water Quality Impacts As stated in response 9-4, in Section 2.0 of this Final EIR, “The Draft EIR analysis did consider the nature of impacts to water bodies and provides a detailed analysis of the potential surface water quality impacts and the measures that will be implemented to prevent potential impacts to the sediment load of the Anaverde Creek.” Pages 3-15 through 3-19 (including Figure 3-6) discuss the project’s proposed Drainage Control and Surface Water Management System. Additionally, pages 4.3-14 and 4.3-15 and Figure 4.3-4 outline the project’s Stormwater Management Plan and Erosion Control Measures to be implemented for stormwater runoff prior to discharge to the Anaverde Creek. Lastly, Section 4.4 of the Draft EIR also addresses this issue. Mitigation Measure 4.4-3 states, “Prior to issuance of the landfill’s Waste Discharge Requirements (WDRs), the project engineer shall finalize erosion and siltation control plans and other BMPs, as necessary to prevent graded and cleared areas from being eroded, resulting in the transport of sediment to Anaverde Creek.” Considering existing regulations for landfill construction, the location of the project site and the required mitigation measures, no reasonably foreseeable significant adverse impacts on water quality would result from the proposed project to Anaverde Creek or Lake Palmdale. Response 12-52 The comment is acknowledged. However, pursuant to the Amendment to the Draft EIR text and figures, the proposed liner is a 2-foot clay base not 2-inch clay base. Response 12-53 The comment is acknowledged. Section 4.8, Risk of Upset/Human Health of the Amendment to the Draft EIR provides analysis and mitigation to address this issue in accordance with CEQA. Response 12-54 – L. Alternatives Analysis The comments on the top of page 18 of this response letter are the commentor’s opinion and are not accurate based on the analysis contained in the Amendment to the Draft EIR. Based on Section 5.0, Alternatives to the Proposed Project, of the Amendment to the Draft EIR the following alternatives were evaluated and compared for this proposed project: • 5.2.1 No project • 5.2.2 Reduced project (height) • 5.2.3 Reduced project – expansion with no increase in daily permitted tonnage (1,800 tons per day (tpd)) • 5.2.4 Alternative locations/expansions of Lancaster Landfill ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-57 RESPONSE TO COMMENTS/FINAL EIR It is unclear what the commenter means regarding Alternatives A-D as they do not appear to apply to this proposed project. In addition, Section 5.3 and Table 5-3 of the Amendment to the Draft EIR (pages 5-21 and 5-22) discuss the identification of the environmentally superior alternative. According to Section 5.3, the Reduced Project, Expansion with No Increase in Daily Permitted Tonnage (1,800 tpd) Alternative would best represent the environmentally superior alternative while still meeting five of the eight project objectives. According to Table 5-3, the No Project alternative and the Reduced Project alternative would reduce but not avoid all of the significant cumulative unavoidable impacts associated with the project and other projects combined. While the “Reduced Project” alternative would meet five of the eight project objectives, the “No Project” alternative would only meet one of the eight project objectives. Furthermore, similar to the Reduced Project alternative, the No Project alternative does not avoid the cumulative unavoidable traffic and air quality impacts. Response 12-55 CEQA does not require the EIR to include all alternatives to the proposed project as may be suggested. In accordance with Section 15126.6(a) of the CEQA Guidelines, the EIR including the Amendment to the Draft EIR provides a range of reasonable alternative to the proposed project, or to the location of the project, which could feasibly attain the basic objectives of the project. The EIR including the Amendment to the Draft EIR must also evaluate the comparative merits of the alternatives. By providing this range of alternatives, the decision-makers are allowed to take action within the range presented in the EIR. The Amendment to the Draft EIR provided an analysis of four different alternatives as directed by City Staff and the land planning process (refer to Section 5.0 Alternatives to the Proposed Project of the Amendment to the Draft EIR). The CEQA Guidelines Section 15126.6(f) states: The range of alternatives required in an EIR is governed by “rule of reason” that requires the EIR to set forth only those alternative necessary to permit a reasoned choice. The alternatives shall be limited to ones that would avoid or substantially lessen any of the significant effects of the project. Of those alternatives, the EIR need examine in detail only the ones that the lead agency determines could feasibly attain most of the basic objectives of the project. The range of feasible alternatives shall be selected and discussed in a manner to foster meaningful public participation and informed decision- making. 15126.6(f)(3) states: “An EIR need not consider an alternative whose effect cannot be reasonably ascertained and whose implementation is remote and speculative (Residents Ad Hoc Stadium Committee v. Board of Trustees (1979) 89 Cal.App. 3d 274).” In helping to define the range of alternative analysis necessary, the Court in Bowman v. Petaluma (1986) 185 Cal. App. 3d 1065, held that CEQA does not require analysis of every imaginable alternative or mitigation measure; what is required is the production of information sufficient to permit a reasonable choice of alternatives so far as ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-58 RESPONSE TO COMMENTS/FINAL EIR environmental aspects are concerned; i.e., a range of alternatives that adequately represents the spectrum of reasonable alternatives. As noted above, staff is currently recommending approval of the 1,800 TPD disposal alternative (the current CUP-approved tonnage) as the environmentally superior alternative. The “Reduced Project” alternative does reduce but does not completely eliminate the cumulative unavoidable traffic and air quality impacts. Because these unavoidable traffic and air quality impacts are cumulative by nature, they would occur with or without the project. The “No Project” alternative only achieves one of the eight project objectives. Please refer to above responses 12-14 and 12-23 related to solid waste conversion and anerobic digestion facilities. The commenter also suggests including a “Mitigated Alternative” similar to that adopted by Marine County for the Redwood Landfill Project. The commenter paraphrases the alternative adopted for that project, concluding that a similar alternative considered and adopted for the AVPL would maximize the diversion of waste from the landfill and thereby reduce the energy, air quality and resource extraction and other impacts. The Mitigated Alternative referred to by the commenter was not so narrowly focused, however. Although not mentioned, the Mitigated Alternative adopted by Marin County also allowed for: a lateral expansion of 12.5 acres for disposal; 2,310 tpd of total material received, and; approximately 5,621,700 cy of additional total airspace. Adoption of the Mitigated Alternative also extended the site life to 2024. (See SWFP No. 21-AA-0001; see also Redwood Landfill Final EIR, p.2-19 (SCH No. [PHONE REDACTED]) (March 2008).) Staff’s recommendation to adopt the Reduced Project (1,800 tpd) Alternative with the 11 acre wedge expansion is similar to the Mitigated Alternative referenced by the commenter. Under the proposed project and under the Reduced Project Alternative, moreover, the AVPL would continue to maximize diversion of greenwaste, concrete, asphalt, wood waste and other recyclable materials from the landfill as is currently the practice. (See Amendment to the Draft EIR, p. 3-4 (AVPL diverts approximately 3,500 to 8,500 tpd per year).) The Mitigated Alternative suggested by the commenter is substantially similar to the Reduced Project Alternative recommended by staff for the AVPL and would not avoid or substantially lessen any significant adverse impacts of the Reduced Alternative. As stated above, the EIR includes a reasonable range of alternatives as required by CEQA. ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-59 RESPONSE TO COMMENTS/FINAL EIR Response 12-56 The comment which expresses the “view of the commenter” regarding alternatives is acknowledged and responses consistent with the CEQA Guidelines have been provided above. The proposed 11 acre infill is, moreover, not deemed to be a “large-scale” expansion. ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-60 RESPONSE TO COMMENTS/FINAL EIR This page left blank intentionally. ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-61 RESPONSE TO COMMENTS/FINAL EIR Letter No. 13 13-1 13-2 ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-62 RESPONSE TO COMMENTS/FINAL EIR Letter No. 13, Continued 13-3 13-4 13-5 ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-63 RESPONSE TO COMMENTS/FINAL EIR 13-5 Cont’d 13-6 13-7 Letter No. 13, Continued ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-64 RESPONSE TO COMMENTS/FINAL EIR Response to Letter No. 13 California Regional Quality Control Board, Lahontan Region – July 7, 2010 Response 13-1 The comment is acknowledged, but does not raise an issue regarding the environmental analysis contained in the Amendment to the Draft EIR; therefore, no response is warranted. Response 13-2 The comment is acknowledged. This comment letter and the Board’s January 27, 2006 comment letter have been responded to and are hereby incorporated into the Final EIR. Response 13-3 According to CEQA Guidelines Section 15125 (Environmental Setting), “an EIR must include a description of the physical environmental conditions in the vicinity of the project, as they exist at the time the notice of preparation is published, or if no notice of preparation is published, at the time environmental analysis is commenced, from both a local and regional perspective. This environmental setting will normally constitute the baseline physical conditions by which a lead agency determines whether an impact is significant. The description of the environmental setting shall be no longer than is necessary to an understanding of the significant effects of the proposed project and its alternatives.” The construction of Landfill II has been consistent with the County Approved CUP Numbers 85512 and 93041, Certified EIR State Clearinghouse Number [PHONE REDACTED], and subsequent approvals/permits including the WDR 6-95-1, dated January 12, 1995, permit from the The proposed project description has not changed and CEQA does not require lead agency to update the environmental baseline for purposes of an EIR’s analysis. As a policy matter, a few lead agencies would ever complete the CEQA process if updates to the environmental setting were continually required. Response 13-4 The comment is acknowledged. Section 4.3, Hydrology and Water Quality of the Amendment to the Draft EIR has been revised accordingly and the additions to reference the Lahontan Region Basin Plan on pages 4.3-5, 4.3-12, and 4.3-21 are included within Section 4.0 of this Final EIR. The minor additions do not change the EIR conclusions. Response 13-5 Please refer to Response 9-4 in Section 2.0, page 2-44 of this Final EIR. ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-65 RESPONSE TO COMMENTS/FINAL EIR Additionally, the Amendment to the Draft EIR includes a jurisdictional delineation of Anaverde Creek and provides information regarding potential impacts to and mitigation measure for the jurisdictional area’s delineated within the Anaverde Creek. Please refer to pages 4.4-8 (Impact 4.4-2), 4.4-9, and Appendix E of the Amendment to the Draft EIR. Response 13-6 Please refer to Response 3-4 above and Response 9-4 in Section 2.0, page 2-44 of this Final EIR. As explained in the referenced responses, the proposed project will not adversely affect other beneficial uses of the Creek and will be consistent with the Basin Plan. Response 13-7 The comment is acknowledged, but does not raise an issue regarding the environmental analysis contained in the Amendment to the Draft EIR; therefore, no response is warranted. ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-66 RESPONSE TO COMMENTS/FINAL EIR This page left blank intentionally. ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-67 RESPONSE TO COMMENTS/FINAL EIR Letter No. 14 14-1 NOTE: 2009 Solid Waste Disposal Summary Reports by Facilities attachment is included in Appendix D of this document. ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-68 RESPONSE TO COMMENTS/FINAL EIR Letter No. 14, Continued 14-1 Cont’d ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-69 RESPONSE TO COMMENTS/FINAL EIR Letter No. 14, Continued 14-1 Cont’d ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-70 RESPONSE TO COMMENTS/FINAL EIR Letter No. 14, Continued 14-1 Cont’d ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-71 RESPONSE TO COMMENTS/FINAL EIR Response to Letter No. 14 County of Los Angeles, Department of Public Works – July 7, 2010 (Please note this response letter was revised and re-submitted on July 15, 2010.) Response 14-1 The issues/concerns raised in this letter were repeated and expanded in the July 15, 2010 letter included herein as Letter #16. The responses to all comments raised by County’s July 2010 letters are incorporated within Comment Letter #16 responses, below. ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-72 RESPONSE TO COMMENTS/FINAL EIR This page left blank intentionally. ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-73 RESPONSE TO COMMENTS/FINAL EIR Letter No. 15 15-1 ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-74 RESPONSE TO COMMENTS/FINAL EIR Letter No. 15, Continued ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-75 RESPONSE TO COMMENTS/FINAL EIR Response to Letter No. 15 State of California, Governor’s Office of Planning and Research, State Clearinghouse and Planning Unit – July 8, 2010 Response 15-1 The comment is acknowledged, but does not raise an issue regarding the environmental analysis contained in the Amendment to the Draft EIR; therefore, no response is warranted. ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-76 RESPONSE TO COMMENTS/FINAL EIR This page left blank intentionally. ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-77 RESPONSE TO COMMENTS/FINAL EIR Letter No. 16 16-1 16-2 NOTE: 2009 Solid Waste Disposal Summary Reports by Facilities attachment is included in Appendix D of this document. ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-78 RESPONSE TO COMMENTS/FINAL EIR Letter No. 16, Continued 16-2 Cont’d 16-3 16-4 16-5 ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-79 RESPONSE TO COMMENTS/FINAL EIR Letter No. 16, Continued 16-6 16-7 16-8 16-9 ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-80 RESPONSE TO COMMENTS/FINAL EIR Letter No. 16, Continued 16-10 16-11 ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-81 RESPONSE TO COMMENTS/FINAL EIR Letter No. 16, Continued 16-12 ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-82 RESPONSE TO COMMENTS/FINAL EIR Response to Letter No. 16 County of Los Angeles, Department of Public Works – July 15, 2010 [Please note the responses below also address the comments raised in the July 7, 2010 letter by the Department of Public Works (Letter Response 16-1 The comment is acknowledged, but does not raise an issue regarding the environmental analysis contained in the Amendment to the Draft EIR; therefore, no response is warranted. Response 16-2 As stated in Response 8-2 in Section 2.0 of this Final EIR, a Finding of Conformance (FOC) was confirmed in 1995 for the AVPL. The proposed “expansion” would combine the existing two landfill modules of the AVPL by bridging a small 11-acre gap which currently exists between the two permitted sites within the same property boundary. Table 2-1 – “List of Potential Responsible Agencies/Project Approvals” has been modified to include the County Solid Waste Management Committee/Integrated Waste Management Board should a second Finding of Conformance be required. Please refer to the Errata contained in Section 3.0 of this Final EIR. Response 16-3 As stated in Response 8-3 in Section 2.0 of this Final EIR, the proposed AVPL expansion serves to fulfill the County’s Disposal Facility Siting criteria by adding more landfill capacity and extending the life (beyond 15 years) of a site that previously received a FOC approved April 20, 1995. Table 3-2 of the Amendment to the Draft EIR illustrates the site life/remaining capacity with and without the proposed project. Response 16-4 Based on the commentor’s 2009 Solid Waste Disposal Summary Reports by Facilities included in Appendix D of this document, the commentor asserts that only 36 percent of all disposal AVPL waste originated from Palmdale and the Antelope Valley area. In other words, they conclude that 64 percent of waste originated from outside of Palmdale and the Antelope Valley area. Please refer to the table below which show the actual percentages of the total Antelope Valley (AV) tonnages received at the AVPL during 2005 (baseline), 2009 (County attachment to comment letter) and 1st quarter 2010 (current). ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-83 RESPONSE TO COMMENTS/FINAL EIR Table 3-2 Antelope Valley Public Landfill Solid Waste Disposal Summary City of Palmdale Tons City of Lancaster Tons AV LA County Unincorporated Tons Total AV Local Area Tons* Total Tons % Outside AV Area Waste** % AV Local Area Waste*** 2005 145,379.00 20,565.00 74,040.00 239,984.00 370,799.00 35% 65% 2009 95,850.36 18,111.28 55,137.29 169,098.93 266,742.98 36% 64% 1st Q 2010 17,792.22 1,949.83 12,175.79 31,917.84 43,177.05 26% 74% * Includes Palmdale, Lancaster, and Unincorporated Antelope Valley Area Tons % Outside AV Area Waste = [(Total Tons-Total AV Area Tons) / Total Tons] x 100 % AV Area Waste = (Total AV Area Tons / Total Tons) x 100 Table 3-1 breaks down the Los Angeles County unincorporated area tonnages specific to those originating from the “Antelope Valley.” The commentor’s 2009 analysis combined all the County tonnages into one category and considered it to be waste originating “outside” of the Antelope Valley (64 percent out of area). They did not consider the Lancaster or Antelope Valley Unincorporated tonnages to be part of the total Antelope Valley area tonnages. Above Table 3- 1 includes Palmdale, Lancaster, and Unincorporated Antelope Valley area tons, classified as AV Area Tons, and correctly calculates the percentage of “outside” Antelope Valley waste. The commentor’s 36 percent (2009 data) incorrectly included only the City of Palmdale tonnages as the total Antelope Valley area tonnage. Page 4.7-7 and Figure 4.7-5 of the Amendment to the Draft EIR describe in detail the existing and future landfill traffic distribution. As indicated in the EIR, the 85 percent local roadway traffic was estimated based upon previously approved traffic studies for the landfill and the field distribution and operations conducted in 2005 (Draft EIR baseline). The results of the traffic impact analysis for SR-14 (please refer to response 7-1 within Section 2.0 and response 16-5 below) indicate that a 15 to 20 percent change in the distribution would not have a measurable effect on the impact analysis conclusions, even if such change was a reasonably foreseeable result of the proposed project, which it is not. Response 16-5 Based upon the above response 16-4 including Table 3-1, the actual distribution percentages are in line with what was assumed in the EIR. Specifically, Section 4.7 of the Amendment to the Draft EIR concludes, “The SR 14 south of Avenue S has 70,000 vehicles per day per the latest available Caltrans counts, and the added project vehicles represents about a 0.14 percent increase which is insignificant. Per the Los Angeles Congestion Management Program (LACMP) section D.4, 150 added vehicles in the peak hour is considered a significant impact ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-84 RESPONSE TO COMMENTS/FINAL EIR and would trigger future traffic impact analysis. As stated above, the proposed project would add far less than 150 vehicles for the entire day and the project peak hour trips on SR-14 would be even less than the daily figure. Therefore, while the operator will most likely avoid peak commute periods on state highways and excessive or poorly times truck platooning (caravans of trucks), the EIR conclusions do not support a finding of significant adverse impacts to SR-15 or I-5 for which additional mitigation may be required as proposed. This is especially true if the City decides to adopt the Reduced Alternative since there would be no increase over existing permitted levels of operation. The proposed project, moreover, will not result in an overall increase in the number of refuse related truck trips, and related air emissions from those trips, in the region. Those truck trips are already occurring as part of the existing environmental setting and are expected to continue whether or not the proposed project is approved. The proposed project, by nature, will not cause more refuse to be created. Response 16-6 Please refer to page 2-6 of the Amendment to the Draft EIR which indicates that the City of Palmdale adopted a Mitigated Negative Declaration in July 2004 for this joint City/County project. The Antelope Valley Environmental Collection Center was included within the September 2005 Traffic Impact Analysis prepared by Kunzman Associates. Response 16-7 A recycling/drop-off transfer facility is not reasonably foreseeable at this time as the volume of recyclables has dropped given the current market conditions, and no specific information exists as to what levels of operation such a facility would include, the ingress/egress routes or other details. In addition, all of the recyclables currently brought to AVPL are transferred to Lancaster Landfill which has sufficient capacity to handle. It would therefore be speculative to analyze the specific potential impacts of such a facility. No application or other information of this facility has been submitted to the City, and when detailed plans become available, required building permits and CEQA analysis and clearances will be obtained at that time. Response 16-8 As stated in Response 8-1 in Section 2.0 of this Final EIR, the Environmental Program Division will be contacted for required permit approval and operating permits should the project include the construction, modification, or removal of underground storage tanks and/or Industrial Waste Control System/ facility. Response 16-9 The traffic analysis summarized within Section 4.7 was prepared with detailed input from the City of Palmdale. Comments made in responses to the March 1, 2004 NOP were also addressed in the traffic and environmental analysis. Furthermore, Figure 4.7-5 depicts the ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-85 RESPONSE TO COMMENTS/FINAL EIR general traffic distribution and rate used by landfill hauler. Requiring a defined haul route for all trucks within the City is beyond the scope of this proposed project. The City could, however, adopt an ordinance establishing designated truck routes to apply equally to all trucks should it desire. Please also note that the proposed project has not been altered since the initial County of Los Angeles Department of Public Works’ review of the Draft EIR in 2006. The original Los Angeles Department of Public Works’ January 26, 2006 comments are included beginning on page 2-32 of Section 2.0 of this document. Los Angeles Department of Public Works’ Comment 8-5 indicates, “We generally agree with the study that the traffic generated by the project alone, or the cumulative traffic generated by the project and other related projects will not significantly impact the County and County/City intersections in the area. We also agree with the impact the County and County/City intersections in the area. We also agree with the study that the project will not have significant impacts to the Congestion Management Program monitored intersections, arterials, or freeways.” The traffic ICU analysis concludes that “For existing plus project traffic conditions, the intersections in the vicinity of the site are projected to continue to operate at LOS B or better during the peak hours. No significant project traffic impacts are anticipated.” Response 16-10 The comment is acknowledged. When, if ever, a plan for a recycling drop-off/transfer center facility becomes available, liquefaction analyses consistent with the requirements of the California Geological Survey Special Publication 117A would be conducted as part of any future building permit. There are no tentative maps at issue as part of this project. Response 16-11 The Amendment to the Draft EIR addresses each of the Building and Safety issues within Sections 4.1, 4.2, 4.3, and 4.4. Mitigation measures are included to address each item listed in this comment. As stated in response 9-4, in Section 2.0 of this Final EIR, “The Draft EIR provides a detailed analysis of the potential surface water quality impacts and the measures that will be implemented to prevent potential impacts to the sediment load of the Anaverde Creek. Pages 3-15 through 3-19 (including Figure 3-6) discuss the project’s proposed Drainage Control and Surface Water Management System. Additionally, pages 4.3-14 and 4.3-15 and Figure 4.3-4 outline the project’s Stormwater Management Plan and Erosion Control Measures to be implemented for stormwater runoff prior to discharge to the Anaverde Creek. Lastly, Section 4.4 of the Draft EIR also addresses this issue. Mitigation Measure 4.4-3 states, “Prior to issuance ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-86 RESPONSE TO COMMENTS/FINAL EIR of the landfill’s Waste Discharge Requirements (WDRs), the project engineer shall finalize erosion and siltation control plans and other BMPs, as necessary to prevent graded and cleared areas from being eroded, resulting in the transport of sediment to Anaverde Creek.” Response 16-12 The comment is acknowledged. When available, a copy of the Final EIR will be provided to the Department. ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-87 RESPONSE TO COMMENTS/FINAL EIR Letter No. 17 17-1 17-2 ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-88 RESPONSE TO COMMENTS/FINAL EIR Letter No. 17, Continued 17-3 17-5 17-6 17-7 17-8 17-4 ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-89 RESPONSE TO COMMENTS/FINAL EIR Response to Letter No. 17 County of Los Angeles, Public Health – August 5, 2010 Response 17-1 It is unclear why the Technical Appendices Volume I and Volume II were not included on the CD provided to the LEA and we apologize for the mix up. Over 60 CDs were created and distributed to various agencies with the electronic version of the May 2010 Amendment to the Draft EIR. The technical appendices were contained as separate PDF file on the same CD as the May 2010 Amendment to the Draft EIR. The technical appendices were also posted on the City’s website for review during the 45-day review period from May 24, 2010 to July 7, 2010. Response 17-2 Please refer to Figure 1-5, Ancillary Facility Layout Plan, of the Amendment to the Draft EIR, which depicts the waste hauling and collection operation facilities located within the permitted boundary of the landfill. The trucks are parked around the maintenance and equipment bin storage south of the existing maintenance building. Response 17-3 The waste hauling and collection operating trucks have been included within the existing counts and future project impact analysis included in Section 4.7 of the Amendment to the Draft EIR and the Kunzman Associates’ traffic tables. Please refer to Section 4.7, Traffic and Circulation of the Amendment to the Draft EIR (pages 4.7-6 and Table 4.7-3 which include an analysis of the existing truck traffic). Page 4.7-6 states that, “Table 4.7-3 shows actual existing count data on tons per loads and tons per day as well as truck loads in and total trips. Appendix G contains count data for total tonnage and truckloads collected on an hourly basis as well as peak hour and daily in and out volumes.” Page 4.7-6 continues, “there are an average 208 loads per day and 1,372 tpd of deposited material. These 208 loads consist of 142 municipal solid waste loads, pick ups, roll ups, packers, 16 transfer trailer loads, 17 petroleum contaminated soil loads, 23 greenwaste loads, and 10 beneficial use loads. WMI trucks currently average 4.05 tons each for municipal solid waste, 21 tons each for transfer trailers, 25 tons each for petroleum contaminated soil, 0.7 tons each for greenwaste, and average of 8 tons each for others.” Also, please refer to Section 4.7.4, which includes the analysis of future project related traffic. As stated on page 4.7-13, ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-90 RESPONSE TO COMMENTS/FINAL EIR “trip generation rates were determined for daily traffic, morning peak hour inbound and outbound traffic, and evening peak hour inbound and outbound traffic for the proposed land use. Table 4.7-4 shows actual projected data for future truck loads and tonnages as well as the expected change in the existing and future operation. Table 4.7-5 exhibits the traffic generation rates, project peak hour volumes, and project daily traffic volumes.” Response 17-4 Please refer to Section 4.2 (pages 4.2-18 to 4.2-21 of the Amendment to the Draft EIR) which includes an analysis of the potential air quality impact from the waste collection operation. Table 4.2-4B provides a comparison of landfill truck hauling emissions and impacts. Response 17-5 Plans for a recycling/drop-off transfer facility are not known at this time nor have any submittals been made to any agency. Therefore, it would be speculative to analyze the potential effects of such a facility. When detailed plans become available, required building permits and CEQA analysis and clearances will be obtained at that time. Response 17-6 As shown on Figure 1-5 of the Amendment to the Draft EIR, such a facility, if ever proposed, is not expected to impact the truck parking as it would most likely be considered to be located to the southeast of the future facility. Response 17-7 WMI currently employs measures as part of its existing landfill operations to prevent the tracking of soil by vehicles utilizing the site on to public streets. These measures include a rumble grate located before the outbound scales to collect excess soils and weekly street sweeping along the landfill access road. Proposed air quality mitigation measures 4.2-2 and 4.2-3 and traffic mitigation measure 4.7-1 will also assist with the reduction and removal of fugitive dust and offsite tracking potential. Response 17-8 When available, a copy of the Final EIR, which would include any revisions to the Amendment to the Draft EIR, will be submitted to the Department. ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-91 RESPONSE TO COMMENTS/FINAL EIR Letter No. 18 18-1 18-2 18-3 ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-92 RESPONSE TO COMMENTS/FINAL EIR Letter No. 18, Continued 18-4 18-3 Cont’d ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-93 RESPONSE TO COMMENTS/FINAL EIR Response to Letter No. 18 County of Los Angeles, Fire Department – August 11, 2010 Response 18-1 The comment is acknowledged, but does not raise an issue regarding the environmental analysis contained in the Amendment to the Draft EIR; therefore, no response is warranted. Response 18-2 The comment is acknowledged, but does not raise an issue regarding the environmental analysis contained in the Amendment to the Draft EIR; therefore, no response is warranted. Response 18-3 The comment is acknowledged, but does not raise an issue regarding the environmental analysis contained in the Amendment to the Draft EIR; therefore, no response is warranted. Response 18-4 The comment is acknowledged. Both agencies did review/comment on the Amendment to the Draft EIR. Please refer to response letter No. 13 Regional Water Quality Control Board and letter No. 17 Los Angeles County Department of Public Health, Solid waste Program for their comments. ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 3.0 MAY 2010 AMENDMENT TO THE DRAFT EIR COMMENT LETTERS & RESPONSES MARCH 2011 3-94 RESPONSE TO COMMENTS/FINAL EIR This page left blank intentionally. ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 4.0 CHANGES TO THE DECEMBER 2005 DRAFT EIR & MAY 2010 AMENDMENT TO DRAFT EIR MARCH 2011 4-1 RESPONSE TO COMMENTS/FINAL EIR 4.0 CHANGES TO THE DECEMBER 2005 DRAFT EIR AND MAY 2010 AMENDMENT TO THE DRAFT EIR 4.1 INTRODUCTION The text revisions and modifications included in this section have resulted from the comments on the Draft EIR and Amendment to the Draft EIR during the 45-day public review periods (December 14, 2006 through January 27, 2006 and May 24, 2010 through July 7, 2010, respectively). In some instances, recommendations and questions raised in the comments have necessitated revisions to the Draft EIR and Amendment to the Draft EIR text. Where appropriate, the response directs readers to a specific page or pages in the Draft EIR and Amendment to the Draft EIR. Changes made to the Draft EIR and Amendment to the Draft EIR text in response to comments are indicated in strikeout (deletion) and underlined (addition) text. The errata pages/exhibit(s), starting in Section 4.2, reflect these changes and modifications to the Draft EIR and Section 4.3 for Amendment to the Draft EIR. The changes to the original text, which consists of completeness or accuracy edits, are being corrected at this time through errata as well. The changes to the Draft EIR and Amendment to the Draft EIR as they related to issues contained within this section do not affect the overall conclusions of the environmental document relative to significance of impacts. 4.2 DECEMBER 2005 DRAFT EIR ERRATA PAGES In response to correcting a typographical error, paragraph within Impact 4.3-4 in Section 1.0, Table 1-1, page 1-18 is revised as follows: Implementation of project design measures / components Leachate Collection and Removal System, Composite Liner System and Groundwater Monitoring System), developed consistent with Title 27 and NPDES requirements, will reduce the potential groundwater quality impacts, including potential permeability impacts to less than significant levels. In response to comment 8-2 (Letter 8, County of Los Angeles, Department of Public Works, Donald L. Wolfe – January 26, 2006), Table 2-1 – “List of Potential Responsible Agencies/Project Approvals” has been modified to include the County Solid Waste Management Committee/Integrated Waste Management Board should a second Finding of Conformance be required. In response to comment 9-2 (Letter 9, California Regional Water Quality Control Board, Lahontan Region, January 27, 2006), page 4.1-10 in Section 4.1, Earth Resources of the Draft ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 4.0 CHANGES TO THE DECEMBER 2005 DRAFT EIR & MAY 2010 AMENDMENT TO DRAFT EIR MARCH 2011 4-2 RESPONSE TO COMMENTS/FINAL EIR EIR has been modified to correctly reflect the information shown on Figure 4.1-1. The modified page 4.1-10 is included in this section of the Final EIR. Mapping by the State of California (Bryant et al., 2002; California Geological Survey, 2003) indicates that the Alquist-Priolo Earthquake Fault Zone (AP Zone) is within the southwestern part and adjacent to the northeastern boundary of the AVPL site (Figure 4.1-1, Geology and Fault Zones). An AP Zone is a regulatory zone delineated by the State Geologist (Chief of the California Geological Survey) where active faults may pose a surface rupture hazard for structures for human occupancy built within the zone. No AP Zone is present within the 11-acre expansion area. In response to comment 9-3 (Letter 9, California Regional Water Quality Control Board, Lahontan Region, January 27, 2006), Mitigation Measure 4.1-1 in Section 1.0, Table 1-1, page 1-12; Section 4.1, page 4.1-14; and Section 8.0, page 8-5 of the Draft EIR is revised as follows: Prior to the issuance of the Waste Discharge Requirements (WDR’s) and approval of the Joint Technical Document (JTD) for the project by the Lahontan Regional Water Quality Control Board, the proposed design and supporting engineering analysis of the landfill’s containment structures shall be reviewed and approved by the to ensure the design complies with State regulations pursuant to California Code of Regulations, Title 27, Division 2. The applicant shall demonstrate to satisfaction that the landfill liner and leachate collection system have been designed to preclude failure and will resist the maximum seismic shaking expected at the site based on risk assessment. Further, the design shall demonstrate that the final slopes will be stable under both static and dynamic conditions to protect public health and safety and prevent damage to the facility such that no significant impact to the environment will occur. The liner design, as proposed in Appendix B of the EIR, shall be modified or refined if necessary based on final engineering analysis and review by the to ensure that the approved landfill design will mitigate impacts to a less than significant level. The landfill containment structures shall be constructed as approved by the During on-going landfill construction, Ggeologic mapping of rock and soil exposed in future excavations shall be completed during ongoing landfill construction. Information on rock type and any exposed folds, fractures and folds will be collected. Permanent cut slopes shall be observed by a qualified geologist to check for adverse bedding, joint patterns, or other geologic features that may impact the approved landfill design. Where necessary, the permanent cut slopes shall be constructed to ensure their stability. The geologic maps will be included with the construction reports for each portion of the constructed landfill. The reports will be submitted to the LEA and Lahontan In response to correcting a typographical error, Mitigation Measure 4.2-4 in Section 1.0, Table 1-1, page 1-17; Section 4.2, page 4.2-22; and Section 8.0, page 8-6 of the Draft EIR is revised as follows: ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 4.0 CHANGES TO THE DECEMBER 2005 DRAFT EIR & MAY 2010 AMENDMENT TO DRAFT EIR MARCH 2011 4-3 RESPONSE TO COMMENTS/FINAL EIR If an odor nuisance problem should develop, appropriate control measures shall be employed such as applying additional cover material or more frequent application of the cover material to seal the surface, or adjustments to the vacuum pressure on wells, or disposal equipment landfill gas collection system. In response to comment 9-6 (Letter 9, California Regional Water Quality Control Board, Lahontan Region, January 27, 2006), the following revision has occurred to the text on page 4.3-12 to correct the sentence. Final design of scour protection must comply with the requirements of the City of Palmdale and California Department of Fish and Game, if applicable, requirements as well as maintain some flexibility given the proximity to geologic faulting. In response to correcting a typographical error, Impact 4.3-4 in Section 1.0, Table 1-1, page 1- 18 and Section 4.3, page 4.3-19 of the Draft EIR is revised as follows: Impact 4.3-4 Potential for groundwater quality impacts, including permeability. In response to correcting a typographical error, second paragraph in Section 4.3, page 4.3-21 of the Draft EIR is revised as follows: Project design measures / components Leachate Collection and Removal System, Composite Liner System and Groundwater Monitoring System), developed consistent with Title 27 and NPDES requirements shall be implemented so that the potential groundwater quality impacts, including potential permeability impacts are less than significant. In response to correcting a typographical error, last paragraph in Section 4.3, page 4.3-21 of the Draft EIR is revised as follows: Implementation / construction of the proposed SMP as depicted on Figure 3-4, Stormwater Management Plan and the proposed SWCP depicted on Figure 4.3-4, Post-Development Surface Water Control Plan will reduce potential runoff and surface water quality impacts to less than significant levels. As concluded in the 1992 certified EIR for Landfill II, the proposed project will not alter the groundwater level and no significant impacts to groundwater fluctuation are anticipated. With the implementation of project design measures / components Leachate Collection and Removal System, Composite Liner System and Groundwater Monitoring System) the potential groundwater quality including potential permeability impacts will be reduced to less than significant levels. In response to correcting a typographical error, Mitigation Measure 4.6-4 in Section1.0, Table 1- 1, page 1-25; Section 4.6, page 4.6-8; and Section 8.0, page 8-9 of the Draft EIR is revised as follows: ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 4.0 CHANGES TO THE DECEMBER 2005 DRAFT EIR & MAY 2010 AMENDMENT TO DRAFT EIR MARCH 2011 4-4 RESPONSE TO COMMENTS/FINAL EIR During landfill operations and after construction activities, personnel members shall conduct periodic litter cleanup along, 1) the access roadway(R-5 access) and adjacent land from the scales to Tierra Subida Avenue and 2) adjacent properties adjacent to the landfill. The goal is to ensure that stray litter (including litter that is illegally dumped along the landfill access road) is immediately removed when strong winds occur. In response to correcting a typographical error, third bulleted item in Section 8.0, page 8-4 is revised as follows:  Hydrology and Water Quality  Post development flows during flooding events (project specific)  Erosion at the north bank of the Anaverde Creek (project specific)  Contamination of the Anaverde Creek and surface water quality (project specific)  Groundwater quality impacts and permeability (project specific)  Regional flooding (cumulative)  Regional water quality (related to runoff, scour) (cumulative) 4.3 MAY 2010 AMENDMENT TO THE DRAFT EIR ERRATA PAGES In response to correcting a typographical error, Impact 4.4-7 in Section 1.0, Table 1-1, page 1- 27 of the Amendment to the Draft EIR is revised as follows: The project, in conjunction with other cumulative developments in the area, will result in cumulative losses of natural upland desert formations, native vegetation, and habitat values along Anaverde Creek and which may result in the displacement effects to agency-listed CEQA-sensitive songbird and small mammal species. In response to correcting a typographical error, Mitigation Measure 4.4-6 in Section 1.0, Table 1-1, page 1-27; Section 4.4.6, page 4.4-12; and Section 8.3.2, page 8-9 of the Amendment to the Draft EIR is revised as follows: The final design of the “off-site” utility pole placement shall be outside of the bed and bank of the channel to permit free passage by wildlife along the channel. In response to providing clarification for cumulative GHG level of significance conclusion, the first paragraph on page 4.2-28 of the Amendment to the Draft EIR is revised as follows: The proposed project will not conflict with AB-32 or create potential adverse effects of global warming. The project complies with all existing GHG control requirements for landfills. The 25,000 MT/year proposed mandatory reporting threshold would not be exceeded. It would similarly not cause the 10,000 MT/year threshold of the CARB Market Advisory Committee to be exceeded, and therefore, would not be considered “substantial” in a CEQA sense. Nevertheless, because of the globally cumulative nature of ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 4.0 CHANGES TO THE DECEMBER 2005 DRAFT EIR & MAY 2010 AMENDMENT TO DRAFT EIR MARCH 2011 4-5 RESPONSE TO COMMENTS/FINAL EIR anthropogenic GHG emissions and suspected global warming, any reasonably available additional control measures should be implemented on a project basis. Implementation of Mitigation Measures 4.2-5 through 4.2-7 would reduce the project’s cumulative contribution to GHG/global warming to the extent feasible. With the adoption of the Mitigation Measures 4.2-5 through 4.2-7, the proposed Project is anticipated to result in little, if any, additional GHG emissions. Where a proposed project would add no, or very little, incremental contribution whatever to a significant cumulative impact, the increment cannot be cumulatively considerable. (See CEQA Guidelines, § 15130, subd.(a)(1).) The cumulative contribution of the proposed Project to global climate change is therefore considered less than cumulatively considerable and therefore less than cumulatively significant. In response to providing clarification for cumulative GHG level of significance conclusion, the fifth paragraph on page 4.2-32 of the Amendment to the Draft EIR is revised as follows: Although GHG/global warming-related significant impacts are not anticipated, Mitigation Measures 4.2- 5 through 4.2-7 are proposed to reduce the project’s cumulative contribution to GHG/global warming to the extent feasible. With the adoption of the above Mitigation Measures 4.2-5 through 4.2-7, the proposed Project is anticipated to result in little, if any, additional GHG emissions. Where a proposed project would add no, or very little incremental contribution whatever to a significant cumulative impact, the increment cannot be cumulatively considerable. (See CEQA Guidelines, § 15130, subd.(a)(1).) The cumulative contribution of the proposed Project to global climate change is therefore considered less than cumulatively considerable and therefore less than cumulatively significant. In response to providing clarification for GHG mitigation measure, Mitigation Measure 4.2-5 on page 1-19, page 4.2-30, and page 8-7 of the Amendment to the Draft EIR is revised as follows: The recommended mitigation measures to reduce hauling and disposal related GHG exhaust emissions are: 4.2-5 The applicant project shall include the following set of measures that, working together, will reduce operational greenhouse gas emissions of the project and the project’s potential effects on climate change of global warming: • Hauling trucks shall be powered by liquefied natural gas (LNG), Compressed Natural Gas (CNG) or ultra-low sulfur diesel fuel. • Idling of heavy-duty hauling trucks in excess of five minutes, and idling of off-road mobile sources of any type in excess of five ten minutes shall be prohibited. • When new landfill equipment is purchased by WMI, new commercially available equipment shall be purchased that meets or exceeds California’s emission standards in effect at the time of purchase. ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 4.0 CHANGES TO THE DECEMBER 2005 DRAFT EIR & MAY 2010 AMENDMENT TO DRAFT EIR MARCH 2011 4-6 RESPONSE TO COMMENTS/FINAL EIR • Onsite vehicles and equipment shall be properly maintained by being serviced at least every 90 days and once annually in compliance with Department of Transportation (DOT) requirements. • Operation equipment used for the proposed project shall use clean alternative non- diesel/biodiesel) fuels, or use equipment that has been retro-fitted with diesel particulate reduction traps or equivalent control technology, using equipment certified by CARB. Such equipment is now subject to CARB’s new regulation to control PM emissions from off-road diesel engines. • For the purchase of primary heavy duty, diesel powered landfill equipment at AVPL (dozers and compactors), if equipment meeting California’s 2014 emission standards for off- highway, heavy duty diesel equipment is commercially available before 2014, WMI shall purchase such equipment as older equipment is replaced. In response to comment 12-13 (Letter 12, California Clean Energy Committee, July 3, 2010), Mitigation Measure 4.2-6 on page 1-21, page 4.2-30, and page 8-7 of the Amendment to the Draft EIR is revised as follows: 4.2-6 Within one three years of project approval, the applicant shall develop, and submit to the City, a Greenhouse Gas Reduction Plan that demonstrates how the WMIAVPL will achieve by 2020 a reduction in annual GHG emissions such that emissions are no greater than 10 percent below 2006 levels and will meet or exceed all regulatory requirements related to GHG control. The Reduction Plan shall include one or more of the following measures, or combination thereof: • Use of alternative fuels, including but not limited to CNG, LNG, B-5 or B-20 Biodiesel in on- site equipment and in heavy duty truck fleets (and as a condition of future contract approvals if third-party haulers are used); • Use of hybrid, LNG, CNG or other similarly effective alternative fuel in hauling trucks; • Use of Best Available Control Technology and BMPs when designating new waste disposal cells by designing any additional gas collectors in bottom liner systems) and to increase gas combustion capacity/improve flare destruction efficiency; • Reconsider the feasibility of gas-to-energy production capacity in the future for use in fueling vehicles, operating equipment or energy conversion Begin the process of developing, for construction and operation, a landfill gas-to-energy (LFGTE) or landfill gas to LNG or CNG plant in the future for use in fueling on- and off-road vehicles, operating equipment or for energy use when: for a LFGTE project, the AVPL generates 1,200 scfm of landfill gas at ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 4.0 CHANGES TO THE DECEMBER 2005 DRAFT EIR & MAY 2010 AMENDMENT TO DRAFT EIR MARCH 2011 4-7 RESPONSE TO COMMENTS/FINAL EIR 50 percent or better methane quality consistently for six months; for or CNG plant, the AVPL generates 2,500 scfm at 50 percent or better methane quality consistently for six months ; • Increased diversion of organic material from landfill disposal and use as landfill cover material; • Increased recycling and carbon offsets if available through an adopted program the Western Climate Initiative) ; • The plan shall include cost estimates for GHG reduction measures and identify funding sources. The plan shall include an implementation schedule that demonstrates substantial GHG emission reductions prior to the 2020 deadline, including implementation of “Early action” measures that may be implemented within three years of plan approval. The plan shall include an updated inventory of projected GHG emissions and an updated estimate of GHG emissions in 1990. The plan shall be subject to review and approval by AVAQMD. • Increase waste diversion of recyclable materials In response to providing clarification for GHG mitigation measure, Mitigation Measure 4.2-7 on page 1-22, page 4.2-37, and page 8-8 of the Amendment to the Draft EIR is revised as follows: 4.2-7 Following closure of the landfill, the applicant shall continue to operate, maintain, and monitor the landfill gas collection and treatment system as long as the landfill continues to produce landfill gas, or until it is determined by the AVCAQMD to ensure that emissions do not significantly contribute to no longer constitute a considerable contribution to additional greenhouse gas emissions, whichever comes first. In response to comment 13-4 (Letter 13, California Regional Water Quality Control Board, Lahontan Region, July 7, 2010), the paragraph under SURFACE WATER QUALITY in Section 4.3, page 4.3-5 of the Amendment to the Draft EIR is revised as follows: The Anaverde Creek is the nearest surface drainage/surface water feature to the project site., and according to the Lahontan Region Basin Plan, it is considered minor surface water. Anaverde Creek lies adjacent to the site, but is separated from the proposed landfill use area by several dirt roadways or excavated basins with marginal roadway berms. This reach of the creek is narrow and rocky, with steeply incised banks, both sides of which have been filled or otherwise disturbed for much of its length. Although the creek channel shows signs of seasonal high-water flows, the persistent drought conditions of the past several decades likely have reduced the frequency with which it carries runoff, and there was no evidence of surface water between November, 2003 and May, 2004. As reported in the 1992 certified EIR for Landfill II, samples collected in March 1991 showed TDS concentrations of 258 ppm which is ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 4.0 CHANGES TO THE DECEMBER 2005 DRAFT EIR & MAY 2010 AMENDMENT TO DRAFT EIR MARCH 2011 4-8 RESPONSE TO COMMENTS/FINAL EIR considered good by the Federal Drinking Water Standards. There is currently construction of residential housing upstream of the proposed project, within the remaining portions of the watershed. There have been little to no changes in the watershed and therefore no changes in the surface water quality would be expected at this time. In response to comment 13-4 (Letter 13, California Regional Water Quality Control Board, Lahontan Region, July 7, 2010), the last paragraph on page 4.3-12 of the Amendment to the Draft EIR is revised as follows: As indicated previously, the nearest surface water is Anaverde Creek located approximately 300 feet south-southwest of the active landfill site. The Anaverde Creek is considered a minor surface water in the Lahontan Region Basin Plan. As indicated in the 1992 certified EIR for Landfill II, Anaverde Creek water collected during the March 1991 sampling event showed TDS concentrations of 258 ppm which is considered good quality by the Federal Drinking Water Standards. The Anaverde Creek is an intermittent stream which flows only during peak flood. No evidence of surface water was observed in the reach of the creek south of the Landfill between November 2003 and May 2004. Although no surface water have been observed recently, a “Stormwater Management Plan” has been proposed to prevent contamination of the Anaverde Creek and surface waters. With implementation of “Proposed Stormwater Management Plan” (see Figures 3-4, Stormwater Management Plan in Section 3.0 and 4.3-4, Post-Development Surface Water Control Plan) and implementation of the actions described below, no impact to surface water quality are anticipated. In response to comment 13-4 (Letter 13, California Regional Water Quality Control Board, Lahontan Region, July 7, 2010), the second paragraph on page 4.3-21 of the Amendment to the Draft EIR is revised as follows: Implementation/construction of the proposed Stormwater Management Plan (SWMP) and Surface Water Control Plan (SWCP) developed consistent with NPDES and the Lahontan Region Basin Plan requirements shall occur so that surface water quality impacts are less than significant. In response to correcting typographical error, Mitigation Measure 4.4-4 on page 1-26, page 4.4- 12, page 8-9 of the Amendment to the Draft EIR is revised as follows: 4.4-4 Landfill expansion actions which directly affect vegetation formations initial vegetation cleaning) shall be initiated outside of the timing of the native bird nesting season (mid-April through mid-August) to avoid disturbing active nests, per provisions of the Migratory Bird Treaty Act and California Fish and Game Code. If initial vegetation disturbance and clearing cannot be performed outside of this window of non-breeding activity, then it shall be preceded by a thorough site/pre-construction surveys in coordination with DFG survey for active nests by a qualified biologist; nests found shall be flagged, and a perimeter fence installed at an appropriate distance (usually between 50 and 300 feet from the nest, depending upon species and terrain). No ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 4.0 CHANGES TO THE DECEMBER 2005 DRAFT EIR & MAY 2010 AMENDMENT TO DRAFT EIR MARCH 2011 4-9 RESPONSE TO COMMENTS/FINAL EIR work shall be performed within the fenced areas until such time as the nests are determined to be inactive and the fledglings have left the area. In response to correcting a typographical error, Impact 4.4-7 in Section 4.4.5, page 4.4-10 of the Amendment to the Draft EIR is revised as follows: The project, in conjunction with other cumulative developments in the area, will result in cumulative losses of natural upland desert formations, native vegetation, and habitat values along Anaverde Creek and which may result in the displacement effects to CEQA-sensitive songbird and small mammal species. In response to correcting typographical error, Mitigation Measure 4.8-1 on page 1-35, page 4.8- 4, and page 8-11 of the Amendment to the Draft EIR is revised as follows: 4.8-1 The permittee shall establish and maintain a comprehensive waste load checking program, which shall include the following: a. All waste hauling vehicles shall be screened at the scales with a radiation detector device acceptable to the Local Enforcement Agency for the presence of radioactive materials. In response to correcting typographical error, the second bulleted item on page 8-4 of the Amendment to the Draft EIR is revised as follows: • Air Quality  Short-term construction impacts – PM-10 (project specific)  Long-term operational impacts – PM-10 (project specific)  Long-term odor (project specific)  GHG Emissions (project specific & cumulative) In response to providing clarification for cumulative GHG level of significance conclusion, the third paragraph on page 5-12 of the Amendment to the Draft EIR is revised as follows: The 1,800 TPD alternative would not cause the most stringent candidate significance threshold of 10,000 MT/year to be exceeded, and it would not interfere with programs, plans and policies to reduce GHG emissions to mandated levels. The GHG impact of the 1,800 TPD alternative is considered less than significant. The mitigation measure would still be required to reduce the project’s contribution to cumulative impact to less than significant. ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 4.0 CHANGES TO THE DECEMBER 2005 DRAFT EIR & MAY 2010 AMENDMENT TO DRAFT EIR MARCH 2011 4-10 RESPONSE TO COMMENTS/FINAL EIR This page left blank intentionally. ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 5.0 MMRP MARCH 2011 5-1 RESPONSE TO COMMENTS/FINAL EIR 5.0 MITIGATION MONITORING AND REPORTING PROGRAM (MMRP) 5.1 Introduction This Mitigation Monitoring and Reporting Program (MMRP) has been prepared pursuant to State of California Public Resources Code Section 21081.6, which requires adoption of a MMRP for projects in which the Lead Agency has required changes or adopted mitigation to avoid significant environmental effects. The City of Palmdale is the lead agency for the proposed Antelope Valley Public Landfill CUP project and, therefore, responsible for administering and implementing the MMRP. The decision-makers must define specific reporting and/or monitoring requirements to be enforced during project implementation prior to final approval of the proposed project. The primary purpose of the MMRP is to ensure that the mitigation measures identified in the Antelope Valley Public Landfill EIR are implemented to reduce or avoid identified environmental effects. The purpose of discussing the MMRP in the Final EIR is to reiterate to the reader the mitigation responsibilities of the Lead Agency in implementing the proposed project. The mitigation measures listed in the MMRP are required by law or regulation and will be adopted by the City as the primary project approval. Certain elements of the project will be adopted or approved by other entities, as indicated in the MMRP matrix. Mitigation is defined by the California Environmental Quality Act (CEQA) as a measure which:  Avoids the impact altogether by not taking a certain action or parts of an action.  Minimizes impacts by limiting the degree or magnitude of the action and its implementation.  Rectifies the impact by repairing, rehabilitating, or restoring the impacted environment.  Reduces or eliminates the impact over time by preservation and maintenance activities during the life of the project.  Compensates for the impacts by replacing or providing substitute resources or environments. Mitigation measures provided in this MMRP were initially identified in Section 4.0, Environmental Analysis of the Draft EIR, as feasible and effective in mitigating project-related environmental impacts. Some of the mitigation measures are modified as a result of the public review processes. ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 5.0 MMRP MARCH 2011 5-2 RESPONSE TO COMMENTS/FINAL EIR 5.2 Basis for the Mitigation Monitoring and Reporting Program The legal basis for the development and implementation of the MMRP lies within CEQA (including the California Public Resources Code). Sections 21002 and 21002.1 of the California Public Resources Code state:  Public agencies are not to approve projects as proposed if there are feasible alternatives or feasible mitigation measures available that would substantially lessen the significant environmental effects of such projects; and  Each public agency shall mitigate or avoid the significant effects on the environment of projects that it carries out or approves whenever it is feasible to do so. Section 21081.6 of the California Public Resources Code further requires that: the public agency shall adopt a reporting or monitoring program for the changes made to the project or conditions of project approval, adopted in order to mitigate or avoid significant effects on the environment. The reporting or monitoring program shall be designed to ensure compliance during project implementation. The monitoring program must be adopted when a public agency makes its findings under CEQA so that the program can be made a condition of project approval in order to mitigate significant effects on the environment. The program must be designed to ensure compliance with mitigation measures during project implementation to mitigate or avoid significant environmental effects. Mitigation Monitoring Program Procedures The MMRP for the proposed project will be in place through all phases of the project, including design, prior to construction, during construction, and during operation. The City of Palmdale shall have primary responsibility for administering the MMRP activities to staff, consultants, or contractors. The City has the responsibility of ensuring that monitoring is documented through periodic reports and that deficiencies are corrected. The City’s designated environmental monitor will track and document compliance with mitigation measures, note any problems that may result, and take appropriate action to remedy problems. Specific responsibilities of the City include:  Coordination of all mitigation monitoring activities.  Management of the preparation, approval, and filing of monitoring or permit compliance reports.  Maintenance of records concerning the status of all approved mitigation measures. ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 5.0 MMRP MARCH 2011 5-3 RESPONSE TO COMMENTS/FINAL EIR  Assure quality control of field monitoring personnel.  Coordinate with other agencies regarding compliance with mitigation or permit requirements.  Review and recommend acceptance and certification of implementation documentation.  Act as a contact for interested parties and surrounding property owners who wish to register complaints and observations of unsafe conditions and environmental violations; verify any such actions; and develop any necessary corrective actions. 5.3 Resolution of Noncompliance Complaints Any person or agency may file a complaint that states noncompliance with the mitigation measures that were adopted as part of the approval process for the Antelope Valley Public Landfill CUP project. The complaint shall be directed to the City of Palmdale in written form providing detailed information on the purported violation. The City shall conduct an investigation and determine the validity of the complaint. If noncompliance with a mitigation measure is verified, the City shall take the necessary action(s) to remedy the violation. The complaint shall receive written confirmation indicating the results of the investigation or the final corrective action that was implemented in response to the specific noncompliance issue. 5.4 Mitigation Monitoring and Reporting Plan Matrix The MMRP is organized in a matrix format. The first column identifies the mitigation measure numbers. The second column identifies the mitigation measures. The third column, entitled “Time Frame for Implementation,” refers to when monitoring will occur. The fourth column, entitled “Responsible Monitoring Agency,” refers to the agency responsible for ensuring that the mitigation measure is implemented. The fifth column, entitled “Verification of Compliance,” has a sub-column for Initials, Date and Remarks. This last column will be used by the lead agency to document the person who verified the implementation of the mitigation measure, the date on which this verification occurred, and any other notable remarks. ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 5.0 MMRP MARCH 2011 5-4 RESPONSE TO COMMENTS/FINAL EIR This page left blank intentionally. ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 5.0 MMRP MARCH 2011 5-5 RESPONSE TO COMMENTS/FINAL EIR Table 5-1 Mitigation Monitoring and Reporting Program Matrix No. Mitigation Measure Time Frame for Implementation Responsible Monitoring Agency Verification of Compliance Initials Date Remarks Earth Resources 4.1-1 Prior to the issuance of the Waste Discharge Requirements (WDR’s) and approval of the Joint Technical Document (JTD) for the project by the Lahontan Regional Water Quality Control Board, the proposed design and supporting engineering analysis of the landfill’s containment structures shall be reviewed and approved by the to ensure the design complies with State regulations pursuant to California Code of Regulations, Title 27, Division 2. The applicant shall demonstrate to satisfaction that the landfill liner and leachate collection system have been designed to preclude failure and will resist the maximum seismic shaking expected at the site Prior to Issuance of WDRs City of Palmdale Public works Department; LEA; and the Lahontan ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 5.0 MMRP MARCH 2011 5-6 RESPONSE TO COMMENTS/FINAL EIR No. Mitigation Measure Time Frame for Implementation Responsible Monitoring Agency Verification of Compliance Initials Date Remarks based on risk assessment. Further, the design shall demonstrate that the final slopes will be stable under both static and dynamic conditions to protect public health and safety and prevent damage to the facility such that no significant impact to the environment will occur. The liner design, as proposed in Appendix B of the EIR, shall be modified or refined if necessary based on final engineering analysis and review by the to ensure that the approved landfill design will mitigate impacts to a less than significant level. The landfill containment structures shall be constructed as approved by the During on-going landfill construction, geologic mapping of rock and soil exposed in future During landfill construction and operations ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 5.0 MMRP MARCH 2011 5-7 RESPONSE TO COMMENTS/FINAL EIR No. Mitigation Measure Time Frame for Implementation Responsible Monitoring Agency Verification of Compliance Initials Date Remarks excavations shall be completed. Information on rock type and any exposed folds, fractures and folds will be collected. Permanent cut slopes shall be observed by a qualified geologist to check for adverse bedding, joint patterns, or other geologic features that may impact the approved landfill design. Where necessary, the permanent cut slopes shall be constructed to ensure their stability. The geologic maps will be included with the construction reports for each portion of the constructed landfill. The reports will be submitted to the LEA and Lahontan 4.1-2 Earth moving operations shall be observed, and the placement of fill shall be tested by a qualified geotechnical engineer during ongoing landfill operations. Observation and testing will During landfill operations City of Palmdale Public Works Department and the LEA ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 5.0 MMRP MARCH 2011 5-8 RESPONSE TO COMMENTS/FINAL EIR No. Mitigation Measure Time Frame for Implementation Responsible Monitoring Agency Verification of Compliance Initials Date Remarks ensure fill placements are consistent with the approved landfill design. Air Quality 4.2-1 Because the grading/disturbance of more than 10 acres will cause the daily PM-10 thresholds to be exceeded, construction of landfill ancillary facilities (new frontage road, R-5 access, and the Anaverde Creek erosion protection) shall not exceed 10 acres of grading on any given day. During grading and operations City of Palmdale Planning Department 4.2-2 The internal haul road from the scale house into the landfill shall be incrementally paved with asphalted concrete or equivalent as depicted on Figure 4.2-1. During grading and operations City of Palmdale Planning Department 4.2-3 Because of the potential for fugitive dust emissions from the During grading and operations City of Palmdale Planning ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 5.0 MMRP MARCH 2011 5-9 RESPONSE TO COMMENTS/FINAL EIR No. Mitigation Measure Time Frame for Implementation Responsible Monitoring Agency Verification of Compliance Initials Date Remarks proposed landfill to cause a public nuisance or exacerbate PM10 non-attainment status within the Antelope Valley, dust generated by project activities shall be kept to a minimum and prevented from dispersing offsite. The project shall comply with all best available control measures of existing AVAQMD Rule 403, or any of its possible near future control measure enhancements. The project size is not sufficient to require preparation and approval of a formal fugitive dust control plan (DCP) as it is less than 100 acres of simultaneous disturbance. However, because of the non-attainment status of the air basin and the cumulative significance of continued elevated levels of PM-10 emissions, a DCP shall be prepared and submitted to the AVAQMD for their review and approval. The elements of such Department and the AVAQMD ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 5.0 MMRP MARCH 2011 5-10 RESPONSE TO COMMENTS/FINAL EIR No. Mitigation Measure Time Frame for Implementation Responsible Monitoring Agency Verification of Compliance Initials Date Remarks a plan are already part of site operational procedures. The preparation and implementation of a dust control plan is designed to create a CUP compliance evaluation mechanism to further protect the nearest existing and future residents. The elements of such a plan would likely include: a. Water trucks or fixed sprinkler systems shall be used to keep all areas of vehicle movement damp enough to prevent dust from leaving the site. b. Areas to be graded or excavated shall be watered before commencement of the grading or excavation operations. Application of water must penetrate sufficiently to minimize fugitive dust during grading activities. c. All graded and excavated material, exposed soil areas, During grading and operations During grading and excavation During grading and excavation City of Palmdale Planning Department and the LEA City of Palmdale Planning Department and the LEA City of Palmdale Planning ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 5.0 MMRP MARCH 2011 5-11 RESPONSE TO COMMENTS/FINAL EIR No. Mitigation Measure Time Frame for Implementation Responsible Monitoring Agency Verification of Compliance Initials Date Remarks and active portions of the landfill, including on-site roadways, shall be treated to prevent fugitive dust. Treatment shall include, but not be limited to, periodic watering, application of environmentally safe soil stabilization materials, and/or roll compaction as appropriate. Watering shall be done as often as necessary to prevent fugitive dust from leaving the landfill site. d. Signs shall be posted on-site limiting traffic to speeds of 15 mph or less on unpaved roads and 25 mph on paved roads. e. During periods of high winds wind speed sufficient to cause fugitive dust to impact adjacent properties), all clearing, grading, earth moving, and excavation operations shall be curtailed to the degree necessary to prevent fugitive dust created During grading and operations During grading, excavation, and operations Department and the LEA City of Palmdale Planning Department and the LEA City of Palmdale Planning Department and the LEA ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 5.0 MMRP MARCH 2011 5-12 RESPONSE TO COMMENTS/FINAL EIR No. Mitigation Measure Time Frame for Implementation Responsible Monitoring Agency Verification of Compliance Initials Date Remarks by on-site activities and operations from being a nuisance or hazard, either off- site or on-site. 4.2-4 If an odor nuisance problem should develop, appropriate control measures shall be employed such as applying additional cover material or more frequent application of the cover material to seal the surface, or adjustments to the landfill gas collection system. During landfill operations City of Palmdale Planning Department and the LEA 4.2-5 The applicant shall include the following set of measures that, working together, will reduce operational greenhouse gas emissions of the project and the project’s potential effects on climate change: • Hauling trucks shall be powered by liquefied natural gas (LNG), Compressed Natural Gas (CNG), or ultra- low sulfur diesel fuel. During grading, excavation, and operations City of Palmdale Planning Department and the LEA ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 5.0 MMRP MARCH 2011 5-13 RESPONSE TO COMMENTS/FINAL EIR No. Mitigation Measure Time Frame for Implementation Responsible Monitoring Agency Verification of Compliance Initials Date Remarks • Idling of heavy-duty hauling, trucks in excess of five minutes, and idling of off-road mobile sources of any type in excess of five minutes shall be prohibited. • When new landfill equipment is purchased by WMI, new commercially available equipment shall be purchased that exceeds California’s emission standards in effect at the time of purchase. • Onsite vehicles and equipment shall be properly maintained by being serviced at least every 90 days and once annually in compliance with Department of Transportation (DOT) requirements. • Operation equipment used for the proposed project shall use clean alternative non- diesel/biodiesel) fuels, or use equipment that has been ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 5.0 MMRP MARCH 2011 5-14 RESPONSE TO COMMENTS/FINAL EIR No. Mitigation Measure Time Frame for Implementation Responsible Monitoring Agency Verification of Compliance Initials Date Remarks retro-fitted with diesel particulate reduction traps or equivalent control technology, using equipment certified by CARB. • For the purchase of primary heavy duty, diesel powered landfill equipment at WMI (dozers and compactors), if equipment meeting California’s 2014 emission standards for off-highway, heavy duty diesel equipment is commercially available before 2014, WMI shall purchase such equipment as older equipment is replaced. 4.2-6 Within one year of project approval, the applicant shall develop, and submit to the City, a Greenhouse Gas Reduction Plan that demonstrates how the AVPL will achieve by 2020 a reduction in annual GHG emissions such that emissions are no greater than 10 Within one year of project approval City of Palmdale Planning Department and the LEA ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 5.0 MMRP MARCH 2011 5-15 RESPONSE TO COMMENTS/FINAL EIR No. Mitigation Measure Time Frame for Implementation Responsible Monitoring Agency Verification of Compliance Initials Date Remarks percent below 2006 levels and will meet or exceed all regulatory requirements related to GHG control. The Reduction Plan shall include one or more of the following measures, or combination thereof: • Use of alternative fuels, including but not limited to CNG, LNG, B-5 or B-20 Biodiesel in on-site equipment and in heavy duty truck fleets (and as a condition of future contract approvals if third-party haulers are used); • Use of hybrid, LNG, CNG or other similarly effective alternative fuel in hauling trucks; • Use of Best Available Control Technology and BMPs when designating new waste disposal cells by ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 5.0 MMRP MARCH 2011 5-16 RESPONSE TO COMMENTS/FINAL EIR No. Mitigation Measure Time Frame for Implementation Responsible Monitoring Agency Verification of Compliance Initials Date Remarks designing any additional gas collectors in bottom liner systems) and to increase gas combustion capacity/improve flare destruction efficiency; • Begin the process of developing, for construction and operation, a landfill gas- to-energy (LFGTE) or landfill gas to LNG or CNG plant in the future for use in fueling on- and off-road vehicles, operating equipment or for energy use when: for a LFGTE project, the AVPL generates 1,200 scfm of landfill gas at 50 percent or better methane quality consistently for six months; for or CNG plant, the AVPL generates 2,500 scfm at 50 percent or better methane quality consistently for six months; ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 5.0 MMRP MARCH 2011 5-17 RESPONSE TO COMMENTS/FINAL EIR No. Mitigation Measure Time Frame for Implementation Responsible Monitoring Agency Verification of Compliance Initials Date Remarks • Increased diversion of organic material from landfill disposal and use as landfill cover material; • Increased recycling and carbon offsets if available through an adopted program the Western Climate Initiative); • The plan shall include cost estimates for GHG reduction measures and identify funding sources. The plan shall include an implementation schedule that demonstrates substantial GHG emission reductions prior to the 2020 deadline, including implementation of “Early action” measures that may be implemented within three years of plan approval. The plan shall include an updated inventory of ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 5.0 MMRP MARCH 2011 5-18 RESPONSE TO COMMENTS/FINAL EIR No. Mitigation Measure Time Frame for Implementation Responsible Monitoring Agency Verification of Compliance Initials Date Remarks projected GHG emissions and an updated estimate of GHG emissions in 1990. The plan shall be subject to review and approval by AVAQMD. 4.2-7 Following closure of the landfill, the applicant shall continue to operate, maintain, and monitor the landfill gas collection and treatment system as long as the landfill continues to produce landfill gas, or until it is determined by the AVAQMD to ensure that emissions do not significantly contribute to additional greenhouse gas emissions. After the closure of the landfill City of Palmdale Planning Department and the LEA Hydrology and Water Quality 4.3-1 The final design for the Anaverde Creek Scour Protection System shall be developed by a qualified engineer to comply with the City of Palmdale engineering design Upon project approval in accordance with CUP conditions City of Palmdale Public Works Department ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 5.0 MMRP MARCH 2011 5-19 RESPONSE TO COMMENTS/FINAL EIR No. Mitigation Measure Time Frame for Implementation Responsible Monitoring Agency Verification of Compliance Initials Date Remarks requirements. The construction of the approved Scour Protection System shall be completed in conjunction with Landfill II and the wedge expansion in accordance with the CUP Conditions of Approval. Biological Resources 4.4-1 Prior to the removal of any Joshua/Juniper trees, the 1998 Desert Vegetation Preservation Plan (see Appendix E-2) prepared by FH&A shall be updated and approved by the City of Palmdale consistent with the City’s Desert Vegetation Ordinance. Prior to removal of any Joshua/Juniper trees City of Palmdale Planning Department 4.4-2 Pursuant to Section 1601 – 1603 of the California Fish and Game Code responsible agencies CDFG and Lahontan shall be notified and permits/approvals shall be obtained prior to any activities Prior to grading of the 1.9 acres of CDFG delineated area City of Palmdale Planning Department ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 5.0 MMRP MARCH 2011 5-20 RESPONSE TO COMMENTS/FINAL EIR No. Mitigation Measure Time Frame for Implementation Responsible Monitoring Agency Verification of Compliance Initials Date Remarks within, or encroachment upon delineated bed and bank of the Anaverde Creek along the southern margin of the Landfill property. 4.4-3 Prior to issuance of the landfill’s Waste Discharge Requirements (WDRs), the project engineer shall finalize erosion and siltation control plans and other BMPs, as necessary to prevent graded and cleared areas from being eroded, resulting in the transport of sediment to Anaverde Creek. Prior to issuance of the WDRs City of Palmdale Planning Department and Lahontan 4.4-4 Landfill expansion actions which directly affect vegetation formations initial vegetation clearing) shall be initiated outside of the timing of the native bird nesting season (mid-April through mid-August) to avoid disturbing active nests, per provisions of the Migratory Bird Prior to initial vegetation clearing City of Palmdale Planning Department ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 5.0 MMRP MARCH 2011 5-21 RESPONSE TO COMMENTS/FINAL EIR No. Mitigation Measure Time Frame for Implementation Responsible Monitoring Agency Verification of Compliance Initials Date Remarks Treaty Act and California Fish and Game Code. If initial vegetation disturbance and clearing cannot be performed outside of this window of non- breeding activity, then it shall be preceded by a thorough site/pre- construction surveys in coordination with DFG for active nests by a qualified biologist; nests found shall be flagged, and a perimeter fence installed at an appropriate distance (usually between 50 and 300 feet from the nest, depending upon species and terrain). No work shall be performed within the fenced areas until such time as the nests are determined to be inactive and the fledglings have left the area. 4.4-5 Facility design and management practices shall be implemented to reduce the intensity of exterior and security lighting adjacent to During landfill activities and operation City of Palmdale Planning Department ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 5.0 MMRP MARCH 2011 5-22 RESPONSE TO COMMENTS/FINAL EIR No. Mitigation Measure Time Frame for Implementation Responsible Monitoring Agency Verification of Compliance Initials Date Remarks habitat areas. Measures such as shielded, downward-directed exterior light fixtures, use of sodium vapor or similar low- intensity bulbs (other than mercury vapor), shall be utilized. Security and activity lighting shall be directed onto target working face areas, and not into the creek channel. 4.4-6 The final design of the “off-site” utility pole placement shall be outside of the bed and bank of the channel to permit free passage by the wildlife along the channel. Prior to site plan approval for utility poles City of Palmdale Planning Department This mitigation measure has been satisfied. Noise 4.5-1 In conjunction with grading permit issuance for the construction of new frontage road and the realignment of City Ranch Road (R-5 access) and during grading and construction operations, the following mitigation measures ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 5.0 MMRP MARCH 2011 5-23 RESPONSE TO COMMENTS/FINAL EIR No. Mitigation Measure Time Frame for Implementation Responsible Monitoring Agency Verification of Compliance Initials Date Remarks shall be implemented for the project: a. All construction equipment, fixed or mobile, shall be equipped with properly operating and maintained mufflers, to the satisfaction of the City’s Public Works or Building Inspector. b. During construction of the new landfill access road, stationary construction equipment shall be placed such that emitted noise is directed away from sensitive noise receivers, to the extent practical, to the satisfaction of the City’s Public Works or Building Inspector. c. During construction of the new landfill access road and to the satisfaction of the City’s Public Works Inspector During grading and construction During grading and construction During grading and construction City of Palmdale Public Works Department City of Palmdale Public Works Department City of Palmdale Public Works Department ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 5.0 MMRP MARCH 2011 5-24 RESPONSE TO COMMENTS/FINAL EIR No. Mitigation Measure Time Frame for Implementation Responsible Monitoring Agency Verification of Compliance Initials Date Remarks or Building Inspector, stockpiling and vehicle staging areas shall be located as far as practical from noise sensitive receptors during construction activities. 4.5-2 Operational activities before 6:00 a.m. or after 8:00 p.m. shall be restricted as follows: a. No receipt of refuse or unloading activities shall be conducted during those hours. b. No heavy equipment operation within 1,000 feet of any residence under clear line-of-sight conditions shall take place during those hours. c. No bird repellent activity sound generators shall occur During landfill operations During landfill operations During landfill operations City of Palmdale Planning Department City of Palmdale Planning Department City of Palmdale Planning ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 5.0 MMRP MARCH 2011 5-25 RESPONSE TO COMMENTS/FINAL EIR No. Mitigation Measure Time Frame for Implementation Responsible Monitoring Agency Verification of Compliance Initials Date Remarks before 7:00 a.m. or after 8:00 p.m. Department Aesthetics / Light and Glare 4.6-1 Interim vegetative cover shall be established as land filling proceeds to help offset visual impacts prior to application of final cover and vegetation at landfill closure. This interim measure provides that the outer southerly facing slopes shall receive cover material consistent with native species of the surrounding terrain as the phased development continues with application at appropriate intervals but at a minimum of every two to four years. Interim vegetation plant densities/seed mix shall be completed consistent with the baseline study to be conducted prior to the beginning of land filling operations in the expansion area. During the phased landfill development; at appropriate intervals but at a minimum of every 2 to 4 years, prior to application of final cover and vegetation at landfill closure City of Palmdale Planning Department ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 5.0 MMRP MARCH 2011 5-26 RESPONSE TO COMMENTS/FINAL EIR No. Mitigation Measure Time Frame for Implementation Responsible Monitoring Agency Verification of Compliance Initials Date Remarks 4.6-2 Final design of the access roadway shall comply with Policy ER 3.1.2, to the extent feasible, to reduce the visual impact to the existing ridgeline as viewed from Tierra Subida and Rayburn Road. Prior to site plan approval for the new access roadway City of Palmdale Planning Department 4.6-3 During conditions of severe wind, operating hours shall be limited, size of the working face shall be reduced, and completed cells shall be covered. During landfill operations City of Palmdale Planning Department 4.6-4 During landfill operations and after construction activity, personnel shall conduct periodic litter cleanup along, 1) the access roadway (R-5 access) and adjacent land from the scales to Tierra Subida Avenue and 2) properties adjacent to the landfill. The goal is to ensure that stray litter (including litter that is illegally dumped along the landfill access road) is During landfill operations City of Palmdale Planning Department ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 5.0 MMRP MARCH 2011 5-27 RESPONSE TO COMMENTS/FINAL EIR No. Mitigation Measure Time Frame for Implementation Responsible Monitoring Agency Verification of Compliance Initials Date Remarks immediately removed when strong winds occur. Traffic and Circulation 4.7-1 The City of Palmdale shall approve the final roadway design for the new landfill access and periodically review traffic operations in the vicinity of the project once the project is constructed to assure that the traffic operations are satisfactory. The future landfill access road alignment shall be along R-5 as a two lane roadway (60-foot right-of-way). R-5 shall intersect a new frontage road. The R-5 access road shall be constructed as a two lane roadway (60-foot right-of-way). The future landfill access road alignment shall also be along the new frontage road that would Upon site plan approval for the new access roadway and during landfill operations City of Palmdale Public Works Department ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 5.0 MMRP MARCH 2011 5-28 RESPONSE TO COMMENTS/FINAL EIR No. Mitigation Measure Time Frame for Implementation Responsible Monitoring Agency Verification of Compliance Initials Date Remarks connect with City Ranch Road and intersect Tierra Subida at Rayburn Road, and create a 4- way signalized intersection, and construct the remaining access road along the R-5 dedicated right-of-way (Figures 4.7-13, Proposed Realignment of City Ranch Road to be Opposite Rayburn Road at Tierra Subida Avenue and 4.7-14, Proposed City Ranch Road Roadway Cross-Section). Preliminary design of the frontage road calls for a 40-foot roadway measured from curb to curb, with an 8-foot sidewalk adjacent to the west curb and a 10-foot-minimum buffer between the east curb and the ultimate location of the west sidewalk of Tierra Subida proper. The new realignment of the landfill access (new frontage road) shall accomplish the following: ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 5.0 MMRP MARCH 2011 5-29 RESPONSE TO COMMENTS/FINAL EIR No. Mitigation Measure Time Frame for Implementation Responsible Monitoring Agency Verification of Compliance Initials Date Remarks  Improve sight distance and related operational safety.  Improve horizontal and vertical alignment.  Wider lanes will result at the Tierra Subida Avenue/Rayburn Road intersection than at the existing City Ranch Road intersection.  Improve traffic signal spacing along Tierra Subida Avenue. 4.7-2 The applicant shall construct right-of-way and traffic signal improvements at the intersection of the landfill access road at Rayburn Road (see Figure 4.7- 13) in conjunction with Landfill II and the wedge expansion in accordance with the CUP Conditions of Approval. Upon project approval in accordance with CUP conditions City of Palmdale Public Works Department 4.7-3 During landfill operations, worker- During landfill City of Palmdale ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 5.0 MMRP MARCH 2011 5-30 RESPONSE TO COMMENTS/FINAL EIR No. Mitigation Measure Time Frame for Implementation Responsible Monitoring Agency Verification of Compliance Initials Date Remarks rideshare and transit plans shall be encouraged by the landfill operator consistent with the goals of the Air Quality Management Plan. operations Public Works Department 4.7-4 The applicant shall pay traffic impact fees in accordance with the City Traffic Impact Fee Ordinance. Credits shall be applied consistent with the Ordinance for the improvements (see Mitigation Measure 4.7-2) installed by the applicant. Upon project approval City of Palmdale Public Works Department Risk of Upset and Human Health 4.8-1 The permittee shall maintain a comprehensive waste load checking program, which shall include the following: a. All waste hauling vehicles shall be screened at the scales with a radiation detector device acceptable to the Local Enforcement During landfill operations City of Palmdale Public Works Department and the LEA ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 5.0 MMRP MARCH 2011 5-31 RESPONSE TO COMMENTS/FINAL EIR No. Mitigation Measure Time Frame for Implementation Responsible Monitoring Agency Verification of Compliance Initials Date Remarks Agency for the presence of radioactive materials. b. Sensors capable of detecting volatile organic compounds, acceptable to the Local Enforcement Agency shall be available and used as directed by the Local Enforcement Agency. c. A remote television monitor or an alternative procedure acceptable to the Local Enforcement Agency shall be maintained at the scales to visually inspect incoming roll- off type loads and open top vehicles. d. The dumping area shall be continuously inspected for hazardous and liquid waste and radioactive waste/materials. This inspection shall be During landfill operations During landfill operations During landfill operations City of Palmdale Public Works Department and the LEA City of Palmdale Public Works Department and the LEA City of Palmdale Public Works Department and the LEA ---PAGE BREAK--- ANTELOPE VALLEY PUBLIC LANDFILL 5.0 MMRP MARCH 2011 5-32 RESPONSE TO COMMENTS/FINAL EIR No. Mitigation Measure Time Frame for Implementation Responsible Monitoring Agency Verification of Compliance Initials Date Remarks accomplished by equipment operators and spotters who have been trained in an inspection program approved by the Local Enforcement Agency (LEA). The landfill currently complies with the LEA inspection procedures and will continue to comply as required by their SWFP. e. Manual inspection of randomly selected refuse loads shall be conducted. The frequency of inspections shall be as directed by the Local Enforcement Agency. The checking program shall be conducted by personnel trained in accordance with a plan approved by the Local Enforcement Agency. During landfill operations City of Palmdale Public Works Department and the LEA ---PAGE BREAK--- APPENDIX A ANTELOPE VALLEY/PALMDALE LANDFILL GAS FLOW LETTER Waste Management September 23, 2010 ---PAGE BREAK--- PALMDALE LANDFILL 1200 W. City Ranch Road Palmdale, CA 93551 (661) 947-7197 September 23, 2010 Attn: Jane Chang AECOM 2737 Campus Drive Irvine, CA 92612 Re: Antelope Valley / Palmdale Landfill Gas Flow Dear Ms. Chang: Please see table below tracking gas flow at the Antelope Valley Palmdale Landfill from January 6, 2010 through September 1, 2010: Methane Carbon Dioxide Oxygen Balance Gas (Nitrogen) Total Flow 1/6/2010 8:10 44 38.3 0.4 17.3 949 No Adj. Made 1/13/2010 15:15 43.8 37.8 0.4 18 975 No Adj. Made 1/20/2010 8:22 44.5 38.5 0.4 16.6 996 No Adj. Made 1/21/2010 9:52 45.8 38.1 0.6 15.5 1002 1/28/2010 12:08 43.1 38.2 0.5 18.2 1058 2/2/2010 8:45 43.3 38.2 0.4 18.1 1036 No Adj. Made 2/4/2010 12:47 45 39.3 0.4 15.3 1031 2/10/2010 14:06 44.3 39 0.6 16.1 1044 2/17/2010 13:57 45.6 39.7 0.3 14.4 1080 2/24/2010 14:14 45.6 38.3 0.6 15.5 1044 3/3/2010 12:56 45.8 39.3 0.6 14.3 1052 2/24/2010 12:30 3/10/2010 14:55 45.3 38.2 0.6 15.9 1068 3/17/2010 9:26 44.8 39.3 0.6 15.3 780 3/17/2010 9:30 3/24/2010 8:31 45.2 38.9 0.5 15.4 752 No Adj. Made 4/1/2010 15:01 45.7 39.4 0.4 14.5 758 4/7/2010 9:13 44.7 39 0.5 15.8 660 4/12/2010 14:10 44.2 37.2 0.7 17.9 710 4/12/2010 15:24 47.6 40.4 0.4 11.6 840 Inc. Flow/Vac. 4/13/2010 11:40 46.8 39.5 0.5 13.2 952 4/14/2010 8:27 46.3 39.3 0.7 13.7 908 4/16/2010 13:44 42.2 37.9 0.6 19.3 992 4/21/2010 15:56 45.4 39.1 0.6 14.9 1006 4/22/2010 7:52 45.3 39.9 0.4 14.4 978 4/28/2010 12:18 44.3 39.4 0.3 16 1006 No Adj. Made 5/3/2010 13:12 39 37.3 0.4 23.3 1033 No Adj. Made 5/3/2010 14:38 39.4 38 0.2 22.4 1048 Inc. Flow/Vac. 5/5/2010 9:24 40.5 38.2 0.4 20.9 991 No Adj. Made 5/7/2010 13:13 40.1 38 0.4 21.5 923 No Adj. Made 5/13/2010 9:27 41.3 37.8 0.3 20.6 888 5/19/2010 15:16 42 38.4 0.3 19.3 826 5/21/2010 13:41 42.8 38.8 0.3 18.1 868 5/25/2010 8:37 42.5 37.8 0.2 19.5 889 ---PAGE BREAK--- September 23, 2010 Page 2 5/26/2010 8:34 42.8 37.9 0.2 19.1 874 6/2/2010 9:04 41 38.5 0.2 20.3 884 No Adj. Made 6/3/2010 8:55 42.3 38.5 0 19.2 830 6/9/2010 8:42 42.3 38.6 0.2 18.9 818 6/14/2010 7:15 41.8 37.5 0.3 20.4 820 6/24/2010 9:10 43.2 38.1 0.5 18.2 856 6/30/2010 10:03 43.9 38.8 0 17.3 843 6/3/2010 9:00 7/7/2010 8:31 42.5 38.1 0.5 18.9 825 7/8/2010 7:30 7/14/2010 10:10 42.8 38.9 0.2 18.1 839 7/21/2010 8:18 43.7 38.8 0.2 17.3 757 No Adj. Made 7/28/2010 8:22 42.3 37.8 0.7 19.2 770 No Adj. Made 8/3/2010 10:28 43.3 38.2 0.4 18.1 780 8/3/2010 10:30 8/10/2010 8:37 44.2 38.9 0.2 16.7 769 No Adj. Made 8/17/2010 9:38 44.7 38.6 0.5 16.2 712 8/24/2010 12:07 45.7 37.6 0.9 15.8 712 8/25/2010 8:22 45.7 38.7 0.7 14.9 684 9/1/2010 9:28 46.2 38.8 0.7 14.3 671 No Adj. Made Averages 43.77 38.55 0.43 17.26 889.53 If you have any questions or if we provide you with additional information, please contact me at [PHONE REDACTED]. Sincerely, Dave Bearden WASTE MANAGEMENT West Group Manager Gas Operations DB/MSH ---PAGE BREAK--- APPENDIX B CALIFORNIA CLEAN ENERGY COMMITTEE APPENDICES California Clean Energy Committee July 3, 2010 (Available at the City of Palmdale Planning Department) ---PAGE BREAK--- APPENDIX C PROTOCOLS FOR SURVEYING AND EVALUATING IMPACTS TO SPECIAL STATUS NATIVE PLANT POPULATIONS AND NATURAL COMMUNITIES California Department of Fish and Game November 24, 2009 ---PAGE BREAK--- ---PAGE BREAK--- ---PAGE BREAK--- ---PAGE BREAK--- ---PAGE BREAK--- ---PAGE BREAK--- ---PAGE BREAK--- ---PAGE BREAK--- ---PAGE BREAK--- ---PAGE BREAK--- APPENDIX D 2009 SOLID WASTE DISPOSAL SUMMARY REPORTS BY FACILITIES County of Los Angeles July 8, 2010 ---PAGE BREAK--- Solid Waste Disposal Summary Reports by Facilities (Including Out-of-County Imports) By All Jurisdictions Reporting Period: January 2009 to December 2009 Antelope Valley Public Landfill #2 (TONS) Azusa Land Reclamation (TONS) Calabasas Landfill (TONS) Chiquita Canyon Landfill (TONS) City of Burbank Landfill #3 (TONS) Commerce Refuse-to-Energy Facility (TONS) Lancaster Landfill (TONS) Pebbly Beach Landfill (TONS) Puente Hills Landfill (TONS) San Clemente Landfill (TONS) Savage Canyon Landfill (TONS) Scholl Canyon Landfill (TONS) Southeast Resource Recovery Facility (TONS) Sunshine Canyon City/County Landfill (TONS) Total ALAMEDA COUNTY ALAMEDA 55.22 55.22 ALAMEDA COUNTY 59.74 59.74 BERKELEY 46.10 46.10 DUBLIN 227.99 227.99 FREMONT 224.18 224.18 HAYWARD 154.23 154.23 LIVERMORE 91.81 91.81 NEWARK 81.89 81.89 OAKLAND 120.95 120.95 PLEASANTON 47.13 47.13 SAN LEANDRO 97.80 97.80 UNION CITY 155.40 155.40 Jurisdiction County Printed on: 7/8/2010 Page 1 of 33 ---PAGE BREAK--- Solid Waste Disposal Summary Reports by Facilities (Including Out-of-County Imports) By All Jurisdictions Reporting Period: January 2009 to December 2009 Antelope Valley Public Landfill #2 (TONS) Azusa Land Reclamation (TONS) Calabasas Landfill (TONS) Chiquita Canyon Landfill (TONS) City of Burbank Landfill #3 (TONS) Commerce Refuse-to-Energy Facility (TONS) Lancaster Landfill (TONS) Pebbly Beach Landfill (TONS) Puente Hills Landfill (TONS) San Clemente Landfill (TONS) Savage Canyon Landfill (TONS) Scholl Canyon Landfill (TONS) Southeast Resource Recovery Facility (TONS) Sunshine Canyon City/County Landfill (TONS) Total ALAMEDA COUNTY Total 1,362.44 1,362.44 AMADOR COUNTY AMADOR COUNTY 17.15 17.15 JACKSON 31.26 31.26 Total 48.41 48.41 BUTTE COUNTY CHICO 77.81 77.81 OROVILLE 23.50 23.50 PARADISE 11.00 11.00 Total 112.31 112.31 CALAVERAS COUNTY CALAVERAS COUNTY 1.78 1.78 Total 1.78 1.78 CONTRA COSTA COUNTY ANTIOCH 158.10 158.10 BRENTWOOD 0.94 0.94 CONCORD 238.12 238.12 Printed on: 7/8/2010 Page 2 of 33 ---PAGE BREAK--- Solid Waste Disposal Summary Reports by Facilities (Including Out-of-County Imports) By All Jurisdictions Reporting Period: January 2009 to December 2009 Antelope Valley Public Landfill #2 (TONS) Azusa Land Reclamation (TONS) Calabasas Landfill (TONS) Chiquita Canyon Landfill (TONS) City of Burbank Landfill #3 (TONS) Commerce Refuse-to-Energy Facility (TONS) Lancaster Landfill (TONS) Pebbly Beach Landfill (TONS) Puente Hills Landfill (TONS) San Clemente Landfill (TONS) Savage Canyon Landfill (TONS) Scholl Canyon Landfill (TONS) Southeast Resource Recovery Facility (TONS) Sunshine Canyon City/County Landfill (TONS) Total CONTRA COSTA COUNTY CONTRA COSTA COUNTY 15.25 0.49 15.74 DANVILLE 39.85 39.85 EL CERRITO 17.09 17.09 LAFAYETTE 49.33 49.33 MARTINEZ 12.12 12.12 PINOLE 57.09 57.09 PITTSBURG 70.38 70.38 PLEASANT HILL 49.43 49.43 RICHMOND 96.09 96.09 SAN RAMON 124.50 124.50 WALNUT CREEK 136.88 136.88 Total 1,064.23 0.49 0.94 1,065.66 EL DORADO COUNTY EL DORADO COUNTY 90.62 90.62 Printed on: 7/8/2010 Page 3 of 33 ---PAGE BREAK--- Solid Waste Disposal Summary Reports by Facilities (Including Out-of-County Imports) By All Jurisdictions Reporting Period: January 2009 to December 2009 Antelope Valley Public Landfill #2 (TONS) Azusa Land Reclamation (TONS) Calabasas Landfill (TONS) Chiquita Canyon Landfill (TONS) City of Burbank Landfill #3 (TONS) Commerce Refuse-to-Energy Facility (TONS) Lancaster Landfill (TONS) Pebbly Beach Landfill (TONS) Puente Hills Landfill (TONS) San Clemente Landfill (TONS) Savage Canyon Landfill (TONS) Scholl Canyon Landfill (TONS) Southeast Resource Recovery Facility (TONS) Sunshine Canyon City/County Landfill (TONS) Total EL DORADO COUNTY PLACERVILLE 54.36 54.36 Total 144.98 144.98 FRESNO COUNTY CLOVIS 192.84 192.84 FRESNO 443.04 443.04 SELMA 15.66 15.66 Total 651.54 651.54 IMPERIAL COUNTY BRAWLEY 33.98 33.98 CALEXICO 35.96 35.96 EL CENTRO 158.39 158.39 IMPERIAL 47.83 47.83 Total 276.16 276.16 KERN COUNTY BAKERSFIELD 1.31 632.80 1.67 635.78 CALIFORNIA CITY 3.42 3.42 Printed on: 7/8/2010 Page 4 of 33 ---PAGE BREAK--- Solid Waste Disposal Summary Reports by Facilities (Including Out-of-County Imports) By All Jurisdictions Reporting Period: January 2009 to December 2009 Antelope Valley Public Landfill #2 (TONS) Azusa Land Reclamation (TONS) Calabasas Landfill (TONS) Chiquita Canyon Landfill (TONS) City of Burbank Landfill #3 (TONS) Commerce Refuse-to-Energy Facility (TONS) Lancaster Landfill (TONS) Pebbly Beach Landfill (TONS) Puente Hills Landfill (TONS) San Clemente Landfill (TONS) Savage Canyon Landfill (TONS) Scholl Canyon Landfill (TONS) Southeast Resource Recovery Facility (TONS) Sunshine Canyon City/County Landfill (TONS) Total KERN COUNTY DELANO 0.21 0.21 KERN COUNTY 48.22 19.18 13,232.30 13,299.70 RIDGECREST 3.42 3.42 TEHACHAPI 11.71 11.71 Total 49.53 652.19 13,252.52 13,954.24 KINGS COUNTY HANFORD 46.89 46.89 LEMOORE 11.50 11.50 Total 58.39 58.39 LAKE COUNTY CLEARLAKE 0.49 0.49 LAKE COUNTY 1.01 1.01 Total 1.50 1.50 LOS ANGELES COUNTY AGOURA HILLS 6,936.84 44.87 4.27 4.67 318.02 27.15 7,335.82 ALHAMBRA 211.16 238.13 3.83 5.67 21,405.58 3,458.77 25,323.14 Printed on: 7/8/2010 Page 5 of 33 ---PAGE BREAK--- Solid Waste Disposal Summary Reports by Facilities (Including Out-of-County Imports) By All Jurisdictions Reporting Period: January 2009 to December 2009 Antelope Valley Public Landfill #2 (TONS) Azusa Land Reclamation (TONS) Calabasas Landfill (TONS) Chiquita Canyon Landfill (TONS) City of Burbank Landfill #3 (TONS) Commerce Refuse-to-Energy Facility (TONS) Lancaster Landfill (TONS) Pebbly Beach Landfill (TONS) Puente Hills Landfill (TONS) San Clemente Landfill (TONS) Savage Canyon Landfill (TONS) Scholl Canyon Landfill (TONS) Southeast Resource Recovery Facility (TONS) Sunshine Canyon City/County Landfill (TONS) Total LOS ANGELES COUNTY ARCADIA 2,006.72 2,585.93 2,567.98 97.28 28,188.18 3,406.59 5,092.20 43,944.88 ARTESIA 87.64 11.24 1,020.95 84.28 2,208.44 3,412.55 AVALON 14.28 3,197.94 212.31 3,424.53 AZUSA 7,839.68 27.38 56.49 10.51 33,059.76 247.86 48.81 41,290.49 BALDWIN PARK 1,016.59 4.59 1,468.50 142.64 19,074.66 1,328.56 3.00 23,038.54 BELL 11.65 1,386.19 906.64 1.33 3,081.31 4,059.14 5,332.23 14,778.49 BELL GARDENS 52.70 531.53 162.24 4.40 25,946.75 19.85 72.37 4,233.78 31,023.62 BELLFLOWER 83.66 264.96 18.53 20,903.87 513.51 11,530.30 1,261.16 34,575.99 BEVERLY HILLS 86.08 29,979.07 0.72 116.72 9,306.18 34.42 39,523.19 BRADBURY 9.09 3,984.26 1.08 3,994.43 BURBANK 193.13 23,898.98 37,711.46 34.02 1,791.53 11,444.79 47.97 12,347.01 87,468.89 CALABASAS 26.26 34,599.28 701.33 1.67 6.77 162.55 58.67 35,556.53 Printed on: 7/8/2010 Page 6 of 33 ---PAGE BREAK--- Solid Waste Disposal Summary Reports by Facilities (Including Out-of-County Imports) By All Jurisdictions Reporting Period: January 2009 to December 2009 Antelope Valley Public Landfill #2 (TONS) Azusa Land Reclamation (TONS) Calabasas Landfill (TONS) Chiquita Canyon Landfill (TONS) City of Burbank Landfill #3 (TONS) Commerce Refuse-to-Energy Facility (TONS) Lancaster Landfill (TONS) Pebbly Beach Landfill (TONS) Puente Hills Landfill (TONS) San Clemente Landfill (TONS) Savage Canyon Landfill (TONS) Scholl Canyon Landfill (TONS) Southeast Resource Recovery Facility (TONS) Sunshine Canyon City/County Landfill (TONS) Total LOS ANGELES COUNTY CARSON 848.38 292.98 605.77 163.38 2,327.58 163,587.86 0.37 2,392.54 170,218.86 CERRITOS 184.27 2.67 2,863.65 1.13 15,654.84 4,300.83 133.87 23,141.26 CLAREMONT 47.28 5.71 0.09 48.69 3,446.74 3,548.51 COMMERCE 29,400.23 59.82 2,429.79 7,754.85 110.54 52,146.25 11,668.00 103,569.48 COMPTON 737.76 10,662.96 979.10 14.41 19,475.26 15,828.73 49,080.95 96,779.17 COVINA 139.81 113.47 1,981.96 4.98 38,146.14 208.26 228.38 40,823.00 CUDAHY 104.23 1,921.54 123.10 1,612.58 25.78 8,119.98 11,907.21 CULVER CITY 99.61 29,931.91 0.01 633.61 14,990.02 4,250.28 710.92 50,616.36 DIAMOND BAR 61.23 3.84 15.04 18,936.87 1.69 19,018.67 DOWNEY 222.59 30.49 5,628.62 9.79 55,998.74 163.29 62,053.52 DUARTE 276.51 4.15 25.14 184.09 18,977.33 4.43 19,471.65 EL MONTE 3,261.53 30.44 116.99 17.65 89,634.39 51.64 93,112.64 Printed on: 7/8/2010 Page 7 of 33 ---PAGE BREAK--- Solid Waste Disposal Summary Reports by Facilities (Including Out-of-County Imports) By All Jurisdictions Reporting Period: January 2009 to December 2009 Antelope Valley Public Landfill #2 (TONS) Azusa Land Reclamation (TONS) Calabasas Landfill (TONS) Chiquita Canyon Landfill (TONS) City of Burbank Landfill #3 (TONS) Commerce Refuse-to-Energy Facility (TONS) Lancaster Landfill (TONS) Pebbly Beach Landfill (TONS) Puente Hills Landfill (TONS) San Clemente Landfill (TONS) Savage Canyon Landfill (TONS) Scholl Canyon Landfill (TONS) Southeast Resource Recovery Facility (TONS) Sunshine Canyon City/County Landfill (TONS) Total LOS ANGELES COUNTY EL SEGUNDO 86.99 3,763.18 492.68 190.30 10,755.98 7.80 14,637.61 29,934.54 GARDENA 120.72 2,825.01 3,287.47 249.82 66,915.60 7.66 6,997.89 80,404.17 GLENDALE 1,297.00 11,213.23 83.26 1,751.65 21,924.54 115,263.38 12,790.16 164,323.22 GLENDORA 371.14 6.63 38.05 33.01 35,762.70 36,211.53 HAWAIIAN GARDENS 28.28 0.61 3.53 1,179.21 874.63 2,086.26 HAWTHORNE 123.99 2,469.03 164.40 7.74 8,151.75 13,119.84 46,210.14 70,246.89 HERMOSA BEACH 1.44 3,218.31 1,194.21 1,728.33 9,752.63 15,894.92 HIDDEN HILLS 1,588.78 24.85 0.07 6.84 5.48 1,626.02 HUNTINGTON PARK 50.62 4,170.16 0.36 9.06 12,427.01 5,986.44 18,957.65 41,601.30 INDUSTRY 534.21 725.09 84.56 165.56 96,400.33 1,377.31 99,287.06 INGLEWOOD 458.52 253.69 2.23 84.71 6,002.80 249.82 780.30 7,832.07 IRWINDALE 5,423.97 187.60 186.40 56.30 32,194.66 42.64 3.07 38,094.64 Printed on: 7/8/2010 Page 8 of 33 ---PAGE BREAK--- Solid Waste Disposal Summary Reports by Facilities (Including Out-of-County Imports) By All Jurisdictions Reporting Period: January 2009 to December 2009 Antelope Valley Public Landfill #2 (TONS) Azusa Land Reclamation (TONS) Calabasas Landfill (TONS) Chiquita Canyon Landfill (TONS) City of Burbank Landfill #3 (TONS) Commerce Refuse-to-Energy Facility (TONS) Lancaster Landfill (TONS) Pebbly Beach Landfill (TONS) Puente Hills Landfill (TONS) San Clemente Landfill (TONS) Savage Canyon Landfill (TONS) Scholl Canyon Landfill (TONS) Southeast Resource Recovery Facility (TONS) Sunshine Canyon City/County Landfill (TONS) Total LOS ANGELES COUNTY LA CANADA FLINTRIDGE 50.81 2,933.55 178.67 300.06 1,216.13 2,951.28 1,912.39 9,079.56 18,622.45 LA HABRA HEIGHTS 8.07 4,458.22 4,466.29 LA MIRADA 201.17 0.82 146.28 8,452.81 0.43 1,731.84 10,533.35 LA PUENTE 1,059.30 68.74 0.97 38,602.02 2.12 39,733.15 LA VERNE 55.27 4.55 3.64 4,600.22 1.02 4,664.70 LAKEWOOD 130.31 47.53 17.20 12.84 4,563.10 42,140.62 2,445.27 49,356.87 LANCASTER 18,111.28 303.25 5.40 94,745.72 935.64 42.52 114,143.81 LAWNDALE 221.37 2,620.28 0.17 12.01 2,360.38 4,298.20 8,847.84 18,360.25 LOMITA 121.34 31.88 395.07 6.62 3,478.47 9,051.94 895.76 13,981.08 LONG BEACH 2,949.06 6,615.23 542.14 1,496.19 77,859.01 208,718.22 65,432.83 363,612.68 LOS ANGELES 1,779.68 15,618.68 170,053.47 285,403.69 27,679.24 107,564.15 205,346.66 926.59 31,581.19 1,608,156.96 2,454,110.31 LOS ANGELES COUNTY 57,491.07 625.62 20,214.98 68,290.37 932.27 12,770.55 433,545.33 337.00 4,050.68 24,565.62 384.65 174,580.40 797,788.54 Printed on: 7/8/2010 Page 9 of 33 ---PAGE BREAK--- Solid Waste Disposal Summary Reports by Facilities (Including Out-of-County Imports) By All Jurisdictions Reporting Period: January 2009 to December 2009 Antelope Valley Public Landfill #2 (TONS) Azusa Land Reclamation (TONS) Calabasas Landfill (TONS) Chiquita Canyon Landfill (TONS) City of Burbank Landfill #3 (TONS) Commerce Refuse-to-Energy Facility (TONS) Lancaster Landfill (TONS) Pebbly Beach Landfill (TONS) Puente Hills Landfill (TONS) San Clemente Landfill (TONS) Savage Canyon Landfill (TONS) Scholl Canyon Landfill (TONS) Southeast Resource Recovery Facility (TONS) Sunshine Canyon City/County Landfill (TONS) Total LOS ANGELES COUNTY LYNWOOD 298.61 321.85 5.50 7.81 7,088.98 9,324.90 10,555.60 27,603.25 MALIBU 20.14 22,026.21 171.81 50.71 802.17 213.77 23,284.81 MANHATTAN BEACH 151.68 896.22 28.29 23.31 7,871.08 1,844.72 499.64 11,314.94 MAYWOOD 31.11 728.39 942.27 1.14 3,882.55 665.55 9,704.45 15,955.46 MONROVIA 1,961.87 571.79 550.69 4.41 28,742.18 1,634.78 2,836.23 36,301.95 MONTEBELLO 183.87 2,732.65 708.27 27.05 57,637.19 118.50 4,720.39 66,127.92 MONTEREY PARK 104.66 5,001.31 244.51 196.29 35,962.04 201.23 542.65 42,252.69 NORWALK 103.19 91.28 67.05 10.71 8,953.85 2,584.76 4,948.78 10,859.67 27,619.29 PALMDALE 95,850.36 277.00 39.27 8,559.92 15.72 45.61 104,787.88 PALOS VERDES ESTATES 2.87 663.54 10.58 9.46 9,051.32 214.47 856.00 10,808.24 PARAMOUNT 85.65 359.32 580.23 149.75 5,119.33 3,356.11 838.01 10,488.40 PASADENA 2.01 628.00 4,936.02 1,581.78 500.67 29,835.17 106,974.40 7,258.52 7,554.31 159,270.88 Printed on: 7/8/2010 Page 10 of 33 ---PAGE BREAK--- Solid Waste Disposal Summary Reports by Facilities (Including Out-of-County Imports) By All Jurisdictions Reporting Period: January 2009 to December 2009 Antelope Valley Public Landfill #2 (TONS) Azusa Land Reclamation (TONS) Calabasas Landfill (TONS) Chiquita Canyon Landfill (TONS) City of Burbank Landfill #3 (TONS) Commerce Refuse-to-Energy Facility (TONS) Lancaster Landfill (TONS) Pebbly Beach Landfill (TONS) Puente Hills Landfill (TONS) San Clemente Landfill (TONS) Savage Canyon Landfill (TONS) Scholl Canyon Landfill (TONS) Southeast Resource Recovery Facility (TONS) Sunshine Canyon City/County Landfill (TONS) Total LOS ANGELES COUNTY PICO RIVERA 303.39 42.29 1,922.83 4.18 59,799.35 356.46 62,428.50 POMONA 848.28 50.13 135.06 2.65 83,798.54 460.19 85,294.85 RANCHO PALOS VERDES 103.01 275.34 0.50 46.31 2,687.03 1,627.32 2,810.13 7,549.64 REDONDO BEACH 0.11 486.54 5,256.81 5.53 41.32 7,020.64 13,377.84 13,238.35 39,427.14 ROLLING HILLS 5.83 84.27 0.67 3.68 1,290.82 2,052.45 3,437.72 ROLLING HILLS ESTATES 57.70 17.07 1,944.81 1,366.62 3,386.20 ROSEMEAD 284.54 3,483.09 3,745.44 2.70 12,882.55 1,206.36 22,423.04 44,027.72 SAN DIMAS 136.30 3.02 2.45 7,211.48 7,353.25 SAN FERNANDO 78.60 14,632.73 55.33 101.74 3,373.86 1,009.47 19,251.73 SAN GABRIEL 113.39 3,101.08 2,013.11 3.71 24,805.62 1,339.92 56.12 31,432.95 SAN MARINO 49.11 1,441.76 121.58 83.08 8,629.82 1,155.92 205.68 11.12 11,698.07 SANTA CLARITA 26,666.63 656.78 94,325.56 0.04 981.74 314.55 3,264.92 126,210.22 Printed on: 7/8/2010 Page 11 of 33 ---PAGE BREAK--- Solid Waste Disposal Summary Reports by Facilities (Including Out-of-County Imports) By All Jurisdictions Reporting Period: January 2009 to December 2009 Antelope Valley Public Landfill #2 (TONS) Azusa Land Reclamation (TONS) Calabasas Landfill (TONS) Chiquita Canyon Landfill (TONS) City of Burbank Landfill #3 (TONS) Commerce Refuse-to-Energy Facility (TONS) Lancaster Landfill (TONS) Pebbly Beach Landfill (TONS) Puente Hills Landfill (TONS) San Clemente Landfill (TONS) Savage Canyon Landfill (TONS) Scholl Canyon Landfill (TONS) Southeast Resource Recovery Facility (TONS) Sunshine Canyon City/County Landfill (TONS) Total LOS ANGELES COUNTY SANTA FE SPRINGS 18,727.29 2,570.89 1,754.87 35,028.36 16,923.87 11.96 7,353.58 82,370.82 SANTA MONICA 469.89 6,721.86 15,616.30 826.32 73,242.75 2,208.57 2,096.46 101,182.15 SIERRA MADRE 1.67 123.74 659.66 0.99 3,813.51 3,270.40 516.66 8,386.63 SIGNAL HILL 11,539.58 404.52 4.02 2.97 431.72 5,019.36 2,810.35 20,212.52 SOUTH EL MONTE 380.25 3,923.55 22.41 27,572.76 342.77 3.44 32,245.18 SOUTH GATE 179.03 32.96 2,882.76 276.64 57,039.51 1,132.17 87.35 61,630.42 SOUTH PASADENA 2,342.36 439.49 2.81 10,842.09 2,283.09 583.96 6.70 16,500.50 TEMPLE CITY 45.43 2,892.66 37.58 0.44 22,423.85 4.80 25,404.76 TORRANCE 285.78 662.76 5,786.80 223.08 287.66 25,009.27 19,343.01 75,939.23 127,537.59 VERNON 35,508.22 81.77 5,094.64 2,265.36 1,439.99 54,125.56 18.61 71,586.58 170,120.73 WALNUT 438.84 5.04 2.87 12.73 7,380.73 7,840.21 WEST COVINA 251.86 276.40 77.02 16.18 63,746.68 10.19 64,378.33 Printed on: 7/8/2010 Page 12 of 33 ---PAGE BREAK--- Solid Waste Disposal Summary Reports by Facilities (Including Out-of-County Imports) By All Jurisdictions Reporting Period: January 2009 to December 2009 Antelope Valley Public Landfill #2 (TONS) Azusa Land Reclamation (TONS) Calabasas Landfill (TONS) Chiquita Canyon Landfill (TONS) City of Burbank Landfill #3 (TONS) Commerce Refuse-to-Energy Facility (TONS) Lancaster Landfill (TONS) Pebbly Beach Landfill (TONS) Puente Hills Landfill (TONS) San Clemente Landfill (TONS) Savage Canyon Landfill (TONS) Scholl Canyon Landfill (TONS) Southeast Resource Recovery Facility (TONS) Sunshine Canyon City/County Landfill (TONS) Total LOS ANGELES COUNTY WEST HOLLYWOOD 7.27 3,763.23 32.23 437.55 20,582.40 3,166.18 27,988.86 WESTLAKE VILLAGE 56.10 4,138.93 95.51 0.63 3.76 9.42 4,304.35 WHITTIER 674.89 851.46 73.06 33.46 54,177.03 50,927.93 3,119.51 109,857.34 Total 265,943.75 87,390.37 259,558.49 674,368.63 37,711.46 95,888.96 239,285.66 3,197.94 2,612,978.13 337.00 75,021.03 257,390.68 441,122.81 2,352,946.70 7,403,141.61 MADERA COUNTY MADERA 24.29 24.29 MADERA COUNTY 60.90 60.90 Total 85.19 85.19 MARIN COUNTY CORTE MADERA 14.54 14.54 NOVATO 125.25 125.25 SAN RAFAEL 91.02 91.02 Total 230.81 230.81 MERCED COUNTY DOS PALOS 1.68 1.68 LOS BANOS 28.38 28.38 Printed on: 7/8/2010 Page 13 of 33 ---PAGE BREAK--- Solid Waste Disposal Summary Reports by Facilities (Including Out-of-County Imports) By All Jurisdictions Reporting Period: January 2009 to December 2009 Antelope Valley Public Landfill #2 (TONS) Azusa Land Reclamation (TONS) Calabasas Landfill (TONS) Chiquita Canyon Landfill (TONS) City of Burbank Landfill #3 (TONS) Commerce Refuse-to-Energy Facility (TONS) Lancaster Landfill (TONS) Pebbly Beach Landfill (TONS) Puente Hills Landfill (TONS) San Clemente Landfill (TONS) Savage Canyon Landfill (TONS) Scholl Canyon Landfill (TONS) Southeast Resource Recovery Facility (TONS) Sunshine Canyon City/County Landfill (TONS) Total MERCED COUNTY MERCED 100.70 100.70 Total 130.76 130.76 MODOC COUNTY ALTURAS 18.58 18.58 Total 18.58 18.58 MONTEREY COUNTY DEL REY OAKS 0.38 0.38 MONTEREY 1.25 1.25 SALINAS 178.87 178.87 SEASIDE 54.92 54.92 Total 235.42 235.42 NAPA COUNTY NAPA 149.61 149.61 Total 149.61 149.61 NEVADA COUNTY GRASS VALLEY 65.60 65.60 Total 65.60 65.60 NOT ASSIGNED ALABAMA STATE 24.91 24.91 Printed on: 7/8/2010 Page 14 of 33 ---PAGE BREAK--- Solid Waste Disposal Summary Reports by Facilities (Including Out-of-County Imports) By All Jurisdictions Reporting Period: January 2009 to December 2009 Antelope Valley Public Landfill #2 (TONS) Azusa Land Reclamation (TONS) Calabasas Landfill (TONS) Chiquita Canyon Landfill (TONS) City of Burbank Landfill #3 (TONS) Commerce Refuse-to-Energy Facility (TONS) Lancaster Landfill (TONS) Pebbly Beach Landfill (TONS) Puente Hills Landfill (TONS) San Clemente Landfill (TONS) Savage Canyon Landfill (TONS) Scholl Canyon Landfill (TONS) Southeast Resource Recovery Facility (TONS) Sunshine Canyon City/County Landfill (TONS) Total NOT ASSIGNED INDIANA STATE 12.02 12.02 Total 36.93 36.93 ORANGE COUNTY ALISO VIEJO 44.75 44.75 ANAHEIM 593.07 67.80 7.46 5.02 28.19 13.34 714.88 BREA 181.67 25.54 4.42 10.25 221.88 BUENA PARK 152.07 2.03 25.21 190.48 5.65 375.44 COSTA MESA 680.46 63.62 17.08 82.46 3,397.06 7.76 4,248.44 CYPRESS 128.78 30.32 0.53 1.21 7.42 60.79 229.05 DANA POINT 1.37 6.78 8.15 FOUNTAIN VALLEY 203.95 203.95 FULLERTON 653.65 12.43 821.07 2.07 149.75 35.33 1,674.30 GARDEN GROVE 372.62 20.30 144.82 0.65 348.74 19.83 906.96 HUNTINGTON BEACH 592.52 38.09 5.43 4.11 32.45 73.00 745.60 Printed on: 7/8/2010 Page 15 of 33 ---PAGE BREAK--- Solid Waste Disposal Summary Reports by Facilities (Including Out-of-County Imports) By All Jurisdictions Reporting Period: January 2009 to December 2009 Antelope Valley Public Landfill #2 (TONS) Azusa Land Reclamation (TONS) Calabasas Landfill (TONS) Chiquita Canyon Landfill (TONS) City of Burbank Landfill #3 (TONS) Commerce Refuse-to-Energy Facility (TONS) Lancaster Landfill (TONS) Pebbly Beach Landfill (TONS) Puente Hills Landfill (TONS) San Clemente Landfill (TONS) Savage Canyon Landfill (TONS) Scholl Canyon Landfill (TONS) Southeast Resource Recovery Facility (TONS) Sunshine Canyon City/County Landfill (TONS) Total ORANGE COUNTY IRVINE 20.53 1,565.65 274.60 0.12 24.96 21.23 117.76 3.90 2,028.75 LA HABRA 158.31 9.27 6.72 10.86 27.25 428.21 9.50 650.12 LA PALMA 0.01 3.59 0.01 0.93 4.54 LAGUNA BEACH 8.48 12.48 20.96 LAGUNA HILLS 92.14 20.32 112.46 LAGUNA NIGUEL 137.37 137.37 LAKE FOREST 165.01 165.01 LOS ALAMITOS 38.85 20.82 1.37 9.61 153.75 64.08 288.48 MISSION VIEJO 243.40 0.05 8.34 4,534.06 4,785.85 NEWPORT BEACH 21.95 1.13 0.07 0.91 3.31 7,809.48 1.63 7,838.48 ORANGE 535.41 177.75 3.74 24.16 10,407.47 19.46 11,167.99 ORANGE COUNTY 91.12 90.84 1.09 1.02 7.13 579.61 770.81 Printed on: 7/8/2010 Page 16 of 33 ---PAGE BREAK--- Solid Waste Disposal Summary Reports by Facilities (Including Out-of-County Imports) By All Jurisdictions Reporting Period: January 2009 to December 2009 Antelope Valley Public Landfill #2 (TONS) Azusa Land Reclamation (TONS) Calabasas Landfill (TONS) Chiquita Canyon Landfill (TONS) City of Burbank Landfill #3 (TONS) Commerce Refuse-to-Energy Facility (TONS) Lancaster Landfill (TONS) Pebbly Beach Landfill (TONS) Puente Hills Landfill (TONS) San Clemente Landfill (TONS) Savage Canyon Landfill (TONS) Scholl Canyon Landfill (TONS) Southeast Resource Recovery Facility (TONS) Sunshine Canyon City/County Landfill (TONS) Total ORANGE COUNTY PLACENTIA 10.46 10.46 RANCHO SANTA MARGARITA 0.04 10.21 10.25 SAN CLEMENTE 95.90 95.90 SAN JUAN CAPISTRANO 121.72 18.85 3.88 144.45 SANTA ANA 1,398.36 41.19 245.62 55.54 2,476.92 83.10 4,300.73 SEAL BEACH 118.17 27.32 292.73 370.27 67.98 876.47 STANTON 181.27 7.29 4.65 9.57 202.78 TUSTIN 242.69 2.81 2.09 146.38 393.97 WESTMINSTER 148.22 5.49 0.16 3.12 156.99 YORBA LINDA 195.16 25.56 126.19 346.91 Total 20.53 9,174.56 914.94 1,628.71 55.66 1,656.38 27.25 29,936.63 468.47 43,883.13 PLACER COUNTY AUBURN 23.54 23.54 LINCOLN 21.11 21.11 Printed on: 7/8/2010 Page 17 of 33 ---PAGE BREAK--- Solid Waste Disposal Summary Reports by Facilities (Including Out-of-County Imports) By All Jurisdictions Reporting Period: January 2009 to December 2009 Antelope Valley Public Landfill #2 (TONS) Azusa Land Reclamation (TONS) Calabasas Landfill (TONS) Chiquita Canyon Landfill (TONS) City of Burbank Landfill #3 (TONS) Commerce Refuse-to-Energy Facility (TONS) Lancaster Landfill (TONS) Pebbly Beach Landfill (TONS) Puente Hills Landfill (TONS) San Clemente Landfill (TONS) Savage Canyon Landfill (TONS) Scholl Canyon Landfill (TONS) Southeast Resource Recovery Facility (TONS) Sunshine Canyon City/County Landfill (TONS) Total PLACER COUNTY ROCKLIN 30.03 30.03 ROSEVILLE 337.66 337.66 Total 412.34 412.34 RIVERSIDE COUNTY BANNING 171.04 1.12 172.16 BEAUMONT 123.89 123.89 245.41 245.41 CALIMESA 3.63 3.63 CATHEDRAL CITY 166.09 166.09 COACHELLA 21.61 229.96 0.47 252.04 CORONA 11.90 723.66 0.96 0.37 2,119.52 2,856.41 DESERT HOT SPRINGS 7.24 7.24 HEMET 163.48 163.48 INDIAN WELLS 27.79 27.79 Printed on: 7/8/2010 Page 18 of 33 ---PAGE BREAK--- Solid Waste Disposal Summary Reports by Facilities (Including Out-of-County Imports) By All Jurisdictions Reporting Period: January 2009 to December 2009 Antelope Valley Public Landfill #2 (TONS) Azusa Land Reclamation (TONS) Calabasas Landfill (TONS) Chiquita Canyon Landfill (TONS) City of Burbank Landfill #3 (TONS) Commerce Refuse-to-Energy Facility (TONS) Lancaster Landfill (TONS) Pebbly Beach Landfill (TONS) Puente Hills Landfill (TONS) San Clemente Landfill (TONS) Savage Canyon Landfill (TONS) Scholl Canyon Landfill (TONS) Southeast Resource Recovery Facility (TONS) Sunshine Canyon City/County Landfill (TONS) Total RIVERSIDE COUNTY INDIO 275.07 275.07 LA QUINTA 71.31 0.28 71.59 LAKE ELSINORE 151.93 151.93 MORENO VALLEY 498.16 58.73 556.89 MURRIETA 192.00 0.82 192.82 NORCO 254.19 0.09 654.08 908.36 PALM DESERT 202.84 202.84 PALM SPRINGS 73.26 73.26 PERRIS 298.42 7.06 305.48 RANCHO MIRAGE 6.53 6.53 RIVERSIDE 1,242.41 0.30 719.04 3,546.99 5,508.74 RIVERSIDE COUNTY 462.36 69.58 1.94 1.46 1.30 667.95 1,204.59 Printed on: 7/8/2010 Page 19 of 33 ---PAGE BREAK--- Solid Waste Disposal Summary Reports by Facilities (Including Out-of-County Imports) By All Jurisdictions Reporting Period: January 2009 to December 2009 Antelope Valley Public Landfill #2 (TONS) Azusa Land Reclamation (TONS) Calabasas Landfill (TONS) Chiquita Canyon Landfill (TONS) City of Burbank Landfill #3 (TONS) Commerce Refuse-to-Energy Facility (TONS) Lancaster Landfill (TONS) Pebbly Beach Landfill (TONS) Puente Hills Landfill (TONS) San Clemente Landfill (TONS) Savage Canyon Landfill (TONS) Scholl Canyon Landfill (TONS) Southeast Resource Recovery Facility (TONS) Sunshine Canyon City/County Landfill (TONS) Total RIVERSIDE COUNTY SAN JACINTO 34.05 303.10 337.15 TEMECULA 359.59 12.25 3.53 375.37 Total 474.26 5,383.18 3.20 963.99 363.13 7,001.00 14,188.76 SACRAMENTO COUNTY CITRUS HEIGHTS 88.84 88.84 ELK GROVE 125.47 0.97 126.44 FOLSOM 210.08 210.08 SACRAMENTO 699.70 3.02 702.72 SACRAMENTO COUNTY 146.60 146.60 Total 1,270.69 3.02 0.97 1,274.68 SAN BERNARDINO COUNTY ADELANTO 0.55 1.19 1.87 0.38 0.94 4.93 APPLE VALLEY 444.39 444.39 BARSTOW 109.79 230.92 1.22 341.93 BIG BEAR LAKE 32.68 32.68 Printed on: 7/8/2010 Page 20 of 33 ---PAGE BREAK--- Solid Waste Disposal Summary Reports by Facilities (Including Out-of-County Imports) By All Jurisdictions Reporting Period: January 2009 to December 2009 Antelope Valley Public Landfill #2 (TONS) Azusa Land Reclamation (TONS) Calabasas Landfill (TONS) Chiquita Canyon Landfill (TONS) City of Burbank Landfill #3 (TONS) Commerce Refuse-to-Energy Facility (TONS) Lancaster Landfill (TONS) Pebbly Beach Landfill (TONS) Puente Hills Landfill (TONS) San Clemente Landfill (TONS) Savage Canyon Landfill (TONS) Scholl Canyon Landfill (TONS) Southeast Resource Recovery Facility (TONS) Sunshine Canyon City/County Landfill (TONS) Total SAN BERNARDINO COUNTY CHINO 360.10 278.84 5,147.38 83.65 20.89 5,890.86 CHINO HILLS 221.98 7.06 790.16 1,019.20 COLTON 132.43 1.02 19.84 153.29 FONTANA 1,368.52 11.73 470.39 731.03 1,889.26 4,470.93 GRAND TERRACE 90.32 5.70 96.02 HESPERIA 27.48 231.56 32.34 291.38 HIGHLAND 48.55 4.00 0.96 53.51 LOMA LINDA 4.75 6.58 0.95 12.28 MONTCLAIR 251.69 0.79 4,732.22 4,984.70 NEEDLES 14.88 14.88 ONTARIO 1,361.66 1.67 164.71 0.40 3,220.41 10.04 4,758.89 RANCHO CUCAMONGA 705.04 0.84 12.58 308.94 1,027.40 Printed on: 7/8/2010 Page 21 of 33 ---PAGE BREAK--- Solid Waste Disposal Summary Reports by Facilities (Including Out-of-County Imports) By All Jurisdictions Reporting Period: January 2009 to December 2009 Antelope Valley Public Landfill #2 (TONS) Azusa Land Reclamation (TONS) Calabasas Landfill (TONS) Chiquita Canyon Landfill (TONS) City of Burbank Landfill #3 (TONS) Commerce Refuse-to-Energy Facility (TONS) Lancaster Landfill (TONS) Pebbly Beach Landfill (TONS) Puente Hills Landfill (TONS) San Clemente Landfill (TONS) Savage Canyon Landfill (TONS) Scholl Canyon Landfill (TONS) Southeast Resource Recovery Facility (TONS) Sunshine Canyon City/County Landfill (TONS) Total SAN BERNARDINO COUNTY REDLANDS 29.02 173.89 1.24 2,653.90 2,858.05 RIALTO 68.88 59.23 157.22 285.33 SAN BERNARDINO 16.39 1,140.74 42.08 5.29 225.91 1,430.41 SAN BERNARDINO COUNTY 10.64 5,466.91 1.91 17.91 22.33 517.73 6,037.43 TWENTYNINE PALMS 76.59 76.59 UPLAND 151.66 312.03 463.69 VICTORVILLE 2.81 269.13 78.72 22.91 20.43 394.00 YUCAIPA 2.06 242.53 160.17 1,865.20 2,269.96 YUCCA VALLEY 39.39 39.39 Total 86.89 12,768.78 16.15 1,617.42 87.92 16,352.02 6,492.01 30.93 37,452.12 SAN DIEGO COUNTY CARLSBAD 139.84 1.10 140.94 CHULA VISTA 235.63 235.63 CORONADO 8.89 8.89 Printed on: 7/8/2010 Page 22 of 33 ---PAGE BREAK--- Solid Waste Disposal Summary Reports by Facilities (Including Out-of-County Imports) By All Jurisdictions Reporting Period: January 2009 to December 2009 Antelope Valley Public Landfill #2 (TONS) Azusa Land Reclamation (TONS) Calabasas Landfill (TONS) Chiquita Canyon Landfill (TONS) City of Burbank Landfill #3 (TONS) Commerce Refuse-to-Energy Facility (TONS) Lancaster Landfill (TONS) Pebbly Beach Landfill (TONS) Puente Hills Landfill (TONS) San Clemente Landfill (TONS) Savage Canyon Landfill (TONS) Scholl Canyon Landfill (TONS) Southeast Resource Recovery Facility (TONS) Sunshine Canyon City/County Landfill (TONS) Total SAN DIEGO COUNTY EL CAJON 252.68 0.02 252.70 ENCINITAS 145.76 145.76 ESCONDIDO 427.72 427.72 IMPERIAL BEACH 59.99 59.99 LA MESA 130.92 130.92 NATIONAL CITY 119.55 119.55 OCEANSIDE 427.23 24.38 451.61 POWAY 186.62 186.62 SAN DIEGO 1,584.25 132.27 1.95 1,718.47 SAN DIEGO COUNTY 360.20 6.91 18.69 385.80 SAN MARCOS 150.09 150.09 SANTEE 162.66 162.66 Printed on: 7/8/2010 Page 23 of 33 ---PAGE BREAK--- Solid Waste Disposal Summary Reports by Facilities (Including Out-of-County Imports) By All Jurisdictions Reporting Period: January 2009 to December 2009 Antelope Valley Public Landfill #2 (TONS) Azusa Land Reclamation (TONS) Calabasas Landfill (TONS) Chiquita Canyon Landfill (TONS) City of Burbank Landfill #3 (TONS) Commerce Refuse-to-Energy Facility (TONS) Lancaster Landfill (TONS) Pebbly Beach Landfill (TONS) Puente Hills Landfill (TONS) San Clemente Landfill (TONS) Savage Canyon Landfill (TONS) Scholl Canyon Landfill (TONS) Southeast Resource Recovery Facility (TONS) Sunshine Canyon City/County Landfill (TONS) Total SAN DIEGO COUNTY SOLANA BEACH 111.90 111.90 VISTA 204.80 204.80 Total 4,708.73 163.56 1.12 20.64 4,894.05 SAN FRANCISCO COUNTY SAN FRANCISCO 319.29 319.29 Total 319.29 319.29 SAN JOAQUIN COUNTY ESCALON 2.16 2.16 LATHROP 5.45 5.45 LODI 41.87 41.87 MANTECA 44.59 44.59 STOCKTON 353.92 353.92 TRACY 135.77 135.77 Total 583.76 583.76 SAN LUIS OBISPO COUNTY ARROYO GRANDE 19.41 26.59 46.00 Printed on: 7/8/2010 Page 24 of 33 ---PAGE BREAK--- Solid Waste Disposal Summary Reports by Facilities (Including Out-of-County Imports) By All Jurisdictions Reporting Period: January 2009 to December 2009 Antelope Valley Public Landfill #2 (TONS) Azusa Land Reclamation (TONS) Calabasas Landfill (TONS) Chiquita Canyon Landfill (TONS) City of Burbank Landfill #3 (TONS) Commerce Refuse-to-Energy Facility (TONS) Lancaster Landfill (TONS) Pebbly Beach Landfill (TONS) Puente Hills Landfill (TONS) San Clemente Landfill (TONS) Savage Canyon Landfill (TONS) Scholl Canyon Landfill (TONS) Southeast Resource Recovery Facility (TONS) Sunshine Canyon City/County Landfill (TONS) Total SAN LUIS OBISPO COUNTY PASO ROBLES 75.34 75.34 SAN LUIS OBISPO 88.82 88.82 Total 19.41 164.16 26.59 210.16 SAN MATEO COUNTY BELMONT 49.36 49.36 BURLINGAME 4.17 4.17 COLMA 13.09 13.09 DALY CITY 63.11 63.11 HALF MOON BAY 22.27 22.27 MILLBRAE 17.52 17.52 REDWOOD CITY 210.93 210.93 SAN BRUNO 108.73 108.73 SAN CARLOS 17.54 17.54 SAN MATEO 141.50 141.50 Printed on: 7/8/2010 Page 25 of 33 ---PAGE BREAK--- Solid Waste Disposal Summary Reports by Facilities (Including Out-of-County Imports) By All Jurisdictions Reporting Period: January 2009 to December 2009 Antelope Valley Public Landfill #2 (TONS) Azusa Land Reclamation (TONS) Calabasas Landfill (TONS) Chiquita Canyon Landfill (TONS) City of Burbank Landfill #3 (TONS) Commerce Refuse-to-Energy Facility (TONS) Lancaster Landfill (TONS) Pebbly Beach Landfill (TONS) Puente Hills Landfill (TONS) San Clemente Landfill (TONS) Savage Canyon Landfill (TONS) Scholl Canyon Landfill (TONS) Southeast Resource Recovery Facility (TONS) Sunshine Canyon City/County Landfill (TONS) Total SAN MATEO COUNTY SOUTH SAN FRANCISCO 157.95 157.95 Total 806.17 806.17 SANTA BARBARA COUNTY BUELLTON 12.46 12.46 GOLETA 161.97 161.97 LOMPOC 64.30 64.30 SANTA BARBARA 237.22 237.22 SANTA MARIA 186.10 186.10 Total 12.46 649.59 662.05 SANTA CLARA COUNTY CAMPBELL 162.25 162.25 CUPERTINO 64.76 64.76 GILROY 157.16 157.16 LOS GATOS 56.01 56.01 MILPITAS 53.82 53.82 Printed on: 7/8/2010 Page 26 of 33 ---PAGE BREAK--- Solid Waste Disposal Summary Reports by Facilities (Including Out-of-County Imports) By All Jurisdictions Reporting Period: January 2009 to December 2009 Antelope Valley Public Landfill #2 (TONS) Azusa Land Reclamation (TONS) Calabasas Landfill (TONS) Chiquita Canyon Landfill (TONS) City of Burbank Landfill #3 (TONS) Commerce Refuse-to-Energy Facility (TONS) Lancaster Landfill (TONS) Pebbly Beach Landfill (TONS) Puente Hills Landfill (TONS) San Clemente Landfill (TONS) Savage Canyon Landfill (TONS) Scholl Canyon Landfill (TONS) Southeast Resource Recovery Facility (TONS) Sunshine Canyon City/County Landfill (TONS) Total SANTA CLARA COUNTY MOUNTAIN VIEW 304.41 304.41 PALO ALTO 1.38 1.38 SAN JOSE 825.44 825.44 SANTA CLARA 148.40 148.40 SUNNYVALE 69.24 0.38 69.62 Total 1,842.87 0.38 1,843.25 SANTA CRUZ COUNTY CAPITOLA 17.62 17.62 SANTA CRUZ 181.59 181.59 WATSONVILLE 18.14 18.14 Total 217.35 217.35 SOLANO COUNTY DIXON 9.37 9.37 FAIRFIELD 174.87 174.87 VACAVILLE 174.03 174.03 Printed on: 7/8/2010 Page 27 of 33 ---PAGE BREAK--- Solid Waste Disposal Summary Reports by Facilities (Including Out-of-County Imports) By All Jurisdictions Reporting Period: January 2009 to December 2009 Antelope Valley Public Landfill #2 (TONS) Azusa Land Reclamation (TONS) Calabasas Landfill (TONS) Chiquita Canyon Landfill (TONS) City of Burbank Landfill #3 (TONS) Commerce Refuse-to-Energy Facility (TONS) Lancaster Landfill (TONS) Pebbly Beach Landfill (TONS) Puente Hills Landfill (TONS) San Clemente Landfill (TONS) Savage Canyon Landfill (TONS) Scholl Canyon Landfill (TONS) Southeast Resource Recovery Facility (TONS) Sunshine Canyon City/County Landfill (TONS) Total SOLANO COUNTY VALLEJO 138.14 138.14 Total 496.41 496.41 SONOMA COUNTY COTATI 15.45 15.45 HEALDSBURG 21.56 21.56 PETALUMA 75.84 75.84 ROHNERT PARK 104.81 104.81 SANTA ROSA 296.41 296.41 SEBASTOPOL 18.81 18.81 SONOMA 23.44 23.44 SONOMA COUNTY 13.43 13.43 WINDSOR 15.18 15.18 Total 584.93 584.93 STANISLAUS COUNTY CERES 12.66 12.66 Printed on: 7/8/2010 Page 28 of 33 ---PAGE BREAK--- Solid Waste Disposal Summary Reports by Facilities (Including Out-of-County Imports) By All Jurisdictions Reporting Period: January 2009 to December 2009 Antelope Valley Public Landfill #2 (TONS) Azusa Land Reclamation (TONS) Calabasas Landfill (TONS) Chiquita Canyon Landfill (TONS) City of Burbank Landfill #3 (TONS) Commerce Refuse-to-Energy Facility (TONS) Lancaster Landfill (TONS) Pebbly Beach Landfill (TONS) Puente Hills Landfill (TONS) San Clemente Landfill (TONS) Savage Canyon Landfill (TONS) Scholl Canyon Landfill (TONS) Southeast Resource Recovery Facility (TONS) Sunshine Canyon City/County Landfill (TONS) Total STANISLAUS COUNTY MODESTO 205.93 205.93 PATTERSON 13.09 13.09 STANISLAUS COUNTY 0.62 0.62 TURLOCK 108.91 108.91 Total 341.21 341.21 STATE ARIZONA STATE 1,838.19 1,838.19 COLORADO STATE 3.32 3.32 HAWAII STATE 112.77 112.77 ILLINOIS STATE 15.09 15.09 MONTANA STATE 7.96 7.96 NEVADA STATE 545.00 545.00 NEW MEXICO STATE 438.36 438.36 OREGON STATE 148.21 148.21 Printed on: 7/8/2010 Page 29 of 33 ---PAGE BREAK--- Solid Waste Disposal Summary Reports by Facilities (Including Out-of-County Imports) By All Jurisdictions Reporting Period: January 2009 to December 2009 Antelope Valley Public Landfill #2 (TONS) Azusa Land Reclamation (TONS) Calabasas Landfill (TONS) Chiquita Canyon Landfill (TONS) City of Burbank Landfill #3 (TONS) Commerce Refuse-to-Energy Facility (TONS) Lancaster Landfill (TONS) Pebbly Beach Landfill (TONS) Puente Hills Landfill (TONS) San Clemente Landfill (TONS) Savage Canyon Landfill (TONS) Scholl Canyon Landfill (TONS) Southeast Resource Recovery Facility (TONS) Sunshine Canyon City/County Landfill (TONS) Total STATE TEXAS STATE 11.76 11.76 UTAH STATE 6.11 6.11 Total 3,126.77 3,126.77 SUTTER COUNTY YUBA CITY 60.52 60.52 Total 60.52 60.52 TULARE COUNTY CONSOLIDATED WASTE MANAGEMENT AUTHORITY 2,922.47 2,922.47 DINUBA 12.08 12.08 EXETER 40.91 40.91 FARMERSVILLE 88.56 88.56 PORTERVILLE 66.38 66.38 TULARE 36.29 36.29 TULARE COUNTY 9,085.98 9,085.98 VISALIA 116.85 116.85 Printed on: 7/8/2010 Page 30 of 33 ---PAGE BREAK--- Solid Waste Disposal Summary Reports by Facilities (Including Out-of-County Imports) By All Jurisdictions Reporting Period: January 2009 to December 2009 Antelope Valley Public Landfill #2 (TONS) Azusa Land Reclamation (TONS) Calabasas Landfill (TONS) Chiquita Canyon Landfill (TONS) City of Burbank Landfill #3 (TONS) Commerce Refuse-to-Energy Facility (TONS) Lancaster Landfill (TONS) Pebbly Beach Landfill (TONS) Puente Hills Landfill (TONS) San Clemente Landfill (TONS) Savage Canyon Landfill (TONS) Scholl Canyon Landfill (TONS) Southeast Resource Recovery Facility (TONS) Sunshine Canyon City/County Landfill (TONS) Total TULARE COUNTY Total 231.60 12,137.92 12,369.52 TUOLUMNE COUNTY SONORA 17.94 17.94 TUOLUMNE COUNTY 0.57 0.57 Total 18.51 18.51 VENTURA COUNTY CAMARILLO 179.36 25.52 204.88 FILLMORE 19.70 147.62 167.32 MOORPARK 1.69 1.69 OJAI 173.90 173.90 OXNARD 258.39 74.87 333.26 PORT HUENEME 6.52 13.26 19.78 SANTA PAULA 5.68 396.02 401.70 SIMI VALLEY 67.59 262.32 98.55 1.09 11.46 441.01 THOUSAND OAKS 37.42 275.54 9,712.84 16.97 0.28 0.05 5.44 10,048.54 Printed on: 7/8/2010 Page 31 of 33 ---PAGE BREAK--- ---PAGE BREAK--- Solid Waste Disposal Summary Reports by Facilities (Including Out-of-County Imports) By All Jurisdictions Reporting Period: January 2009 to December 2009 Antelope Valley Public Landfill #2 (TONS) Azusa Land Reclamation (TONS) Calabasas Landfill (TONS) Chiquita Canyon Landfill (TONS) City of Burbank Landfill #3 (TONS) Commerce Refuse-to-Energy Facility (TONS) Lancaster Landfill (TONS) Pebbly Beach Landfill (TONS) Puente Hills Landfill (TONS) San Clemente Landfill (TONS) Savage Canyon Landfill (TONS) Scholl Canyon Landfill (TONS) Southeast Resource Recovery Facility (TONS) Sunshine Canyon City/County Landfill (TONS) Total VENTURA COUNTY VENTURA 31.14 237.75 82.15 351.04 VENTURA COUNTY 7.93 4,575.83 11,394.54 0.03 215.17 49.79 16,243.29 Total 136.15 1,254.88 14,288.67 12,410.14 0.03 14.63 215.22 66.69 28,386.41 YOLO COUNTY DAVIS 20.83 20.83 WEST SACRAMENTO 17.98 17.98 WOODLAND 92.68 92.68 Total 131.49 131.49 YUBA COUNTY MARYSVILLE 14.03 14.03 Total 14.03 14.03 Total 266,742.98 137,279.02 273,847.16 687,713.06 37,711.46 100,265.69 253,089.07 3,197.94 2,638,223.39 337.00 75,048.28 257,390.68 489,689.37 2,353,513.73 7,574,048.83 Printed on: 7/8/2010 Page 32 of 33 ---PAGE BREAK--- Solid Waste Disposal Summary Reports by Facilities (Including Out-of-County Imports) By All Jurisdictions Reporting Period: January 2009 to December 2009 Report last updated on May 27, 2010, up to 4th Quarter 2009 data. Report 16 1. Solid waste quantities listed above are reported to the County of Los Angeles Department of Public Works by permitted solid waste facility operators located in Los Angeles County pursuant to the California Public Resources Code, Section 41821.5, and the California Code of Regulations, Sections 18800-18813. The County of Los Angeles Department of Public Works is not responsible for the accuracy of the data reported by the solid waste facility operators. Questions regarding this report may be directed to the County of Los Angeles Department of Public Works at (800) 320-1771, Monday through Thursday 7:00 A. M. to 5:30 P.M. Questions regarding specific data listed from a facility should be directed to the receiving facility. 2. Pursuant to CCR Section 18720, permitted Solid Waste Facility is defined as “a solid waste facility for which there exists a Solid Waste Facility Permit issued by the local enforcement agency and concurred by the California Integrated Waste Management Board, or which is permitted under the regulatory scheme of the another state.” 3. Facilities located outside of Los Angeles County that received waste generated from jurisdictions located within Los Angeles County will report that waste to the county in which the receiving facility is located. Subsequently, that county will forward the information to the appropriate jurisdictions. 4. The reported information was compiled without any assessment, modification, or alteration based on data provided to this office by the operators of the solid waste facilities located in the Los Angeles County. Printed on: 7/8/2010 Page 33 of 33