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Stop the Mega-Dump in Stanislaus County, California!
Call
Stanislaus County Department of Public Works to Object to the Mega-Dump
Plan: (209) 525-4130
The mostly low-income and
Latino residents living on the westside of Stanislaus County, California,
already suffer the discriminatory and disproportionate impacts of numerous
pollution threats to their health and environment.
Last year Greenaction alerted
residents to a dangerous plant by Integrated Environmental Systems and
county officials to import medical waste from around the state to be
burned at the garbage incinerator in Crow's Landing. The incinerator
emits dioxin, the most dangerous toxic chemical known to science, and
many other toxic chemicals and toxic metals.
Together, Greenaction and
the community defeated the plan, but many toxic threats remain.
Residents on the westside
already live near:
- the Ogden-Martin waste-to-energy
garbage incinerator
- the temporarily closed
tire incinerator
- toxic contamination from
a massive tire fire
- large scale pesticide
use in agriculture across the San Joaquin Valley
- the local garbage dump
Now, the County is proposing
to expand the local garbage dump into a mega-dump that would accept
garbage and sewage sludge from across the state, and possibly other
states.
Stanislaus County Department
of Public Works just compelted a "public comment period" on
the proposal, which would turn the westside into a dumping ground for
non-local wastes to be dumped at the proposed mega-dump - even as they
continue to solicit waste to be burned at the garbage incinerator.
Local residents, led by the
Grayson Neighborhood Council, are fighting the mega-dump plan.
Greenaction has accepted
the invitation from the Grayson Neighborhood Council to join the fight.
For
more information, contact:
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No More Environmental Racism Against Low-Income Latino
Residents on the Westside!
The following are Greenaction's
formal comments submitted to the Stanislaus County Department of Public
Works on the project.
January 16, 2001
George Stillman
Stanislaus County Department of Public Works
1010 10th Street
Modesto, CA 95354
COMMENTS ON
FINK ROAD LANDFILL EXPANSION PROPOSAL
At the request
of Stanislaus County community members, Greenaction for Health and Environmental
Justice submits the following comments on the Draft Environmental Impact
Report for the Fink Road Landfill Expansion proposal.
We submit these
comments to document that the Draft EIR is defective and inadequate,
and the proposal to expand the Fink Road landfill should be rejected.
Project Would
Violate Title VI of United States Civil Rights Act of 1964:
Turning the Fink Road landfill into a giant mega-dump that imported
garbage and sewage sludge would have a discriminatory and disproportionate
impact on the low-income Latino residents on the westside of Stanislaus
County closest to the project. The Draft EIR acknowledges that the proposed
landfill expansion would have numerous significant and unavoidable impacts.
As a recipient of federal funds, Stanislaus County is prohibited by
Title VI of the U.S. Civil Rights Act of 1964 from taking actions that
would have a discriminatory or disproportionate impact on low-income
and minority populations. To avoid violating the civil rights of the
low-income Latino residents on the westside, the dump expansion must
be rejected.
Significant
and Unavoidable Impacts Cannot Be Mitigated and Are Not Outweighed by
Other Benefits:
The Draft EIR documents numerous significant and unavoidable impacts
from the proposed landfill expansion, and acknowledges that mitigation
measures are not available for all of these significant impacts. The
Board of Supervisors cannot approve this project despite the significant
and unavoidable impacts as the economic, legal, social, technical or
other benefits cannot possibly outweigh the unavoidable negative impacts.
The proposed dump expansion must be rejected.
Draft EIR Is
Defective Due To Failure to Analyze Cumulative Impacts from the Proposed
Project and Other Nearby Pollution Sources:
The Draft EIR is inadequate as it fails to assess at all the real-life
cumulative impacts that would result from the proposed landfill expansion
combined with the impacts from the nearby waste-to-energy incinerator,
traffic and pollution from vehicles on the interstate, the tire incinerator,
the tire fire pollution, pesticide use and other adjacent impacts.
Defective Description
of Proposed Expansion Site:
The notice issued by Stanislaus County Department of Public Works
to announce the public review for the Draft EIR was vague and defective.
The notice failed to precisely state the location of the proposed expansion,
stating only that the expansion would be "onto a portion of 2,418
acres..." The notice and Draft EIR do not state the precise size
of the proposed expansion, stating only that "approximately 831
acres" would be developed into the landfill and ancillary facilities.
Expansion Would
Threaten Disposal Capacity for Stanislaus County:
The Draft EIR states that a project objective is to "Provide
long-term refuse disposal capacity for the County of Stanislaus to accommodate
increases in landfill disposal needs associated with potential changes
in the waste-to-energy plant operations." Stanislaus County residents
need a guarantee that the county landfill will continue to have the
capacity to dispose of garbage generated within the county. If the landfill
expansion is approved and the Fink Road landfill is allowed to become
a statewide and regional mega-dump for garbage and sewage sludge, then
there is no guarantee whatsoever that disposal capacity for the county
would exist in a few years. Once the floodgates are open to accept waste
from far and wide, as this project intends to do, then the landfill
capacity could be used up by non-local waste. The proposed project thus
contradicts the stated project objective and undermines a needed resource
for County residents and businesses.
Loss of Prime
Farm Land is an Unacceptable Significant and Unavoidable Impact:
The Draft EIR acknowledges that the proposed landfill expansion
would result in the loss of 42.5 acres of prime farm land. This would
be an unavoidable and significant impact from the proposed project that
is unacceptable due to the negative impact on the local economy and
character of the San Joaquin Valley. The Valley is an agricultural heartland
for the state and nation, and is already suffering from the loss of
prime farm land to development. The additional loss of prime farm land,
as documented in the Draft EIR, is unacceptable.
Noise Would
Be A Significant, Unavoidable and Unacceptable Impact:
The Draft EIR acknowledges that the proposed landfill expansion
would result in the unavoidable and significant impact of exceedence
of county noise standards for nearby residences. Unless the nearby residences
are willing to move if properly compensated by the county, this is unacceptable.
The Draft EIR fails to propose any mitigation for this problem and is
thus defective and inadequate.
Negative Impact
on Air Quality Would Be Significant, Unavoidable and Unacceptable:
The Draft EIR acknowledges that "Long term increases in regional
criteria air pollutants would be anticipated with operation of the proposed
project. With implementation of mitigation measures, regional criteria
air pollutants would still exceed annual significance thresholds. Consequently,
long-term increases in criteria air pollutants would be considered significant
and unavoidable."
The Draft EIR also
acknowledges that "on-site fugitive dust and mobile source emissions
are anticipated to increase..." as a result of the dump expansion.
Any increase in such emissions in an area that already suffers poor
air quality is significant and unacceptable. The mitigation measures
proposed are inadequate and vague.
As the San Joaquin
Valley and its residents already suffer from poor air quality and is
already in non-compliance with air quality standards, it is unacceptable
and a threat to public health for the county to even consider a project
that would further deteriorate air quality for residents.
The Draft EIR also
confirms the proposed expansion would result in an increase in Toxic
Air Contaminants. The Draft EIR's claim that the carcinogenic and non-carcinogenic
risks are "below acceptable regulatory standards" is without
basis in fact. No cumulative impact analysis was done, to our knowledge,
to assess the cumulative impact of Toxic Air Contaminants emitted into
the area's air from the proposed expanded landfill, the waste-to-energy
incinerator, the tire incinerator, mobile sources and other stationary
sources. As many Toxic Air Contaminants have a synergistic and cumulative
impact, the claim that there would not be a significant impact from
TAC's is without basis in fact.
The Draft EIR acknowledges
that increases in mobile source emissions associated with the transport
of waste from outside the region are significant and could potentially
conflict with the emissions budgets used the San Joaquin Valley Air
Pollution Control District Air Quality Attainment Plan. The only possible
mitigation for this impact is to reject the expansion of the facility
and importation of waste from outside the region.
Negative Impact
on Visual Resources Would Be An Unacceptable Significant And Unavoidable
Impact:
The Draft EIR states that "...the landfill would be the most
dominant visual feature in the landscape of the vicinity." The
low-income and predominantly Latino communities on the westside are
already negatively impacted by the perception that the westside is the
county's dumping ground for dirty and unwanted projects. The visual
impact of the dump being the largest visual feature would be a significant
negative impact on local residents and their quality of life.
Draft EIR Improperly
Minimizes Impact Of Odors, Litter And Noise:
The Draft EIR improperly states that it is unnecessary to mitigate
the impacts of increased odors, litter and noise on "adjacent landowners."
Landowners are entitled to full mitigation and prevention of these impacts.
In addition, the Draft EIR fails to address the fact that residents
other than landowners are also entitled to mitigation and prevention
of these impacts.
Draft EIR Fails
To Adequately Address Negative Impact On Groundwater Quality:
The Draft EIR fails to acknowledge or address a key fact: all landfills
eventually leak. The bigger the landfill, the bigger the threat to groundwater
quality. The Draft EIR fails to adequately assess the potential impacts
to the County, residents, taxpayers and the environment arising from
possible large scale groundwater contamination that could occur if the
enormous landfill expansion takes place. The Draft EIR underestimates
the threat from leaking liners, and fails to adequately or realistically
address the potential financial costs of a massive cleanup and remediation
of the problem.
The Draft EIR acknowledges
the potential problem: "Increased leachate generation would be
anticipated with expansion of the landfill, increasing the potential
for groundwater contamination. Groundwater contamination could occur
due to a potential failure of the liner and leachate collection and
recover system within the expansion area.
However, the Draft
EIR's failure to address the reality that all landfills eventually leak
and failure to propose adequate mitigation measures is a major defect
in the project. The Draft EIR's suggestion that ongoing monitoring and
"implementation of remediation if necessary" is vague, inadequate,
and would not address a potential widespread groundwater contamination
problem.
As documented in
the Draft EIR, groundwater monitoring systems at the current site "have
periodically detected elevated inorganic and organic compounds"
found at four locations under the existing landfill. The intention to
address detections of groundwater contamination by ongoing monitoring
are inadequate. The county should act to prevent contamination by not
accepting waste from outside the region. Excess landfill gas has also
been detected, and the problem is still being studied. No expansion
should be even considered as long as the existing facility has these
current problems.
Negative Impacts
On Biological Resources Are Unavoidable, Significant And Unacceptable:
The Draft EIR's conclusion that the disturbance of wildlife and
habitat is "less than significant" is contradicted by the
findings within the Draft EIR. The Draft EIR acknowledges that the dump
expansion would "likely reduce the local populations of several
common plant and wildlife species in the project area." The impacts
are unacceptable, unavoidable and significant.
Negative Impacts
On Kit Fox And Owls Are Unavoidable, Significant And Unacceptable:
The Draft EIR acknowledges that the proposed dump expansion would
result in the loss of up to approximately 676 acres that could potentially
provide suitable San Joaquin Kit Fox habitat. The Draft EIR also point
out that deadly rodenticides would be used at the dump, resulting in
potential primary and secondary poisoning of wildlife. The Draft EIR
also acknowledges that there is at least one pair of nesting owls known
to be on the site, and the mitigation measures proposed are inadequate.
As the San Joaquin Valley suffers from ongoing loss of wildlife habitat,
any further loss is unacceptable.
Negative Impacts
From Huge Increase In Truck Traffic Are Unavoidable, Significant And
Unacceptable:
The Draft EIR's analysis of truck traffic is flawed: the impact
of 424 truck trips and 76 cars per day to the site is discussed, but
the Draft EIR fails to analyze the reality that the truck and car trips
would be round-trip, not one way - doubling the real impact of increased
traffic.
Importation
Of Sewage Sludge From Outside The Region Poses Unacceptable Risk:
The plan to allow importation of sewage sludge for disposal at the
Fink Road Landfill threatens the health and environment of Stanislaus
County. Sewage sludge contains toxic contaminants that pose a health
and environmental risk, particularly if dumped in large quantities.
Stanislaus County should not permit a project expansion that would allow
sewage sludge to be shipped here from across the state and country.
Soil Cover Plan
Is Inadequate:
The Draft EIR states that new soil cover would be placed on top
of the garbage at least once a week, and the document incorrectly refers
to this as a "daily soil cover" requirement. A daily soil
cover should be placed on the waste daily, not weekly. We also object
to the proposed use of contaminated soils as cover, as the contaminated
soils themselves should be covered. The Draft EIR fails to define how
often dust control measures would be required.
Please notify us
of any and all opportunities for public comment on the Fink Road Landfill.
Notice should be sent to us as follows:
Greenaction, 915
Cole Street, Box 249, San Francisco, CA 94117.
For health and
environmental justice,
Bradley Angel
Executive Director
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