Asamblea de Poder Popular de Gonzales; 
Bronwyn Moreno; 
Juan A. Perea; 
Cecilia Davila 
Complainants, 
v. 
Salinas Valley Solid Waste Authority, 
Respondents. 
COMPLAINT UNDER CALIFORNIA 
GOVERNMENT CODE ¤ 11135 
I. INTRODUCTION 
This is a civil rights complaint by Asamblea de Poder Popular de Gonzales (hereinafter 
ÒAsamblea,Ó) a community organization in Gonzales, California, and by Gonzales residents 
Bronwyn Moreno, Juan A. Perea and Cecilia Davila under Section 11135 of the California 
Government Code1 against the Salinas Valley Solid Waste Authority (ÒSVSWAÓ) for 
discriminating against Latinos/Hispanics (ÒLatinosÓ) and Spanish speakers based on race, 
national origin, and ethnic group identification. 
As a recipient of State grants, SVSWA is subject to California Government Code Section 
11135 and its prohibition against discrimination. 
Gonzales is a predominantly Latino/Hispanic, Spanish-speaking community -- 
approximately 88.1 percent of residents are Latino/Hispanic (ÒLatinoÓ), and 74.6 percent speak 
Spanish at home; of the Spanish speakers, approximately 54.5 percent spoke English less than 
Òvery wellÓ and 25.8 percent did not speak English at all. Approximately 39.1 percent of 
residents are foreign born, of whom 95 percent are Spanish speakers; of the foreign-born Spanish 
speakers, 89.8 percent speak English Òless than very wellÓ and 47.2 percent speak English Ònot at 
allÓ. 
Complainants allege that SVSWA violated the Section 11135 prohibition on 
1 California Government Code 11135(a) provides, ÒNo person in the State of California shall, on the basis of race, 
national origin, ethnic group identification, religion, age, sex, sexual orientation, color, or disability, be unlawfully 
denied full and equal access to the benefits of, or be unlawfully subjected to discrimination under, any program or 
activity that is conducted, operated, or administered by the state or by any state agency, is funded directly by the 
state, or receives any financial assistance from the state.Ó 

Asamblea de Poder Popular de Gonzales Ð Ca. Gov. Code ¤11135 Complaint against SVSWA 2 
discrimination because: 
A. SVSWAÕs decision to select Gonzales, without adequate consultation with its 
residents, as the site of a proposed Òconversion technologyÓ facility, and to select 
PlascoÕs plasma arc gasification waste incineration project for advanced stages of 
consideration, has had and continues to have discriminatory and adverse impacts on 
Latinos because the project would emit hazardous and criteria air pollutants into the 
environment of Gonzales, a predominantly Latino community, as well as have other 
significant negative impacts; 
B. SVSWA acted intentionally to create this adverse impact on Latinos in Gonzales, 
because it acted improperly to assure selection of the Plasco project, including 
through systematically limiting public notification and comment in violation of civil 
rights and public notice requirements, providing or facilitating misinformation about 
the project, failing to adequately consider or intentionally ignoring negative 
information about the health and environmental effects of the project, and exercising 
bias in favor of Plasco; and 
C. SVSWA unlawfully and intentionally discriminated against, and continues to 
discriminate against, Latino and Spanish-speaking residents of Gonzales, through 
implementation of discriminatory procedures, including in the site selection, 
technology review, and the CEQA Environmental Review Process, which resulted in 
and continues to result in unequal access to participation. 
The SVSWAÕs actions had and continue to have discriminatory impact on Latinos and 
Spanish speakers, as well as constitute intentional discrimination against them Ñ both grounds 
for ¤ 11135 action. 
These actions exacerbate disproportionate adverse impact on Gonzales residents that 
already exists due to the fact that Gonzales, despite being a small community of only around 
8187 residents, have been forced to bear an excessive and disproportionate share of the regionÕs 

Asamblea de Poder Popular de Gonzales Ð Ca. Gov. Code ¤11135 Complaint against SVSWA 3 
environmental dangers and contamination by hosting the Johnson Canyon Landfill and a 
hazardous waste collection facility. This has already resulted and continues to result in emission 
of hazardous pollutants and particulates in the air from diesel trucks, air and land emissions from 
the landfill, and threats to the groundwater. 
Residents will be forced to bear an even greater proportion of this burden if the 
SVSWAÕs proposal to have the Canadian company Plasco build a plasma arc gasification 
garbage plant in Gonzales is implemented. The project is based on a dangerous, experimental 
technology that would emit a wide range of hazardous and criteria pollutants into the 
environment of Gonzales and would result in regional waste disposal continuing in Gonzales for 
decades to come. 
II. THE COMPLAINANTS 
Complainant Asamblea de Poder Popular de Gonzales (ÒAsambleaÓ) is an unincorporated 
association of residents in Gonzales, California. Asamblea advocates for the well-being of the 
community, including environmental health and justice. Founded in 2006, its mission is to 
ÒWork to better the health and well-being of the farmworkers, their families, and the 
communities where they reside, through development of leadership and formation of strategic 
alliances.Ó2 
Complainant Bronwyn Moreno and Cecilia Davila are Latina residents of Gonzales. 
Complainant Juan A. Perea is a Latino resident of Gonzales, who is a Spanish speaker who 
speaks virtually no English. He has lived there for 17 years. Bronwyn Moreno has lived in 
Gonzales for 3 years, and Cecilia Davis for 51 years. 
Asamblea and other residents of Gonzales have been concerned about waste disposal and 
other projects within Gonzales that impact their health and environment. They have deep 
concerns about the SVSWA selection of Gonzales as the site for a new waste management 
2 Spanish Original of AsambleaÕs mission: ÒTrabajando para mejorar la salud y el bienestar de los campesinos, sus 
familias y las comunidades donde residen por medio del desarrollo de liderazgo y la formacion del alianzas 
estrategicas.Ó 

Asamblea de Poder Popular de Gonzales Ð Ca. Gov. Code ¤11135 Complaint against SVSWA 4 
facility based on Òconversion technologyÓ, and approval for advanced consideration of the 
Plasco plasma arc gasification waste incineration proposal. They are concerned both about the 
health and other threats posed by the proposed facility, and by the systematic exclusion of 
Latino, Spanish-speaking residents from meaningful participation in the decision-making 
process. 
Asamblea and many other Gonzales residents only learned of the plasma arc garbage 
plant proposed for their community in late 2010 from Greenaction for Health and Environmental 
Justice (ÒGreenaction), a non-profit organization whose volunteers and staff conducted outreach 
in Gonzales to alert residents of the SVSWA consideration of the proposed Plasco project and 
the fact that SVSWA picked Gonzales for the project. Since learning of the Plasco plasma arc 
gasification project, Asamblea and its members, as well as other Latino residents of Gonzales, 
have sought to participate in the decision-making process but have been systematically denied 
full and equal access by SVSWA to public participation opportunities. 
Complainant Asamblea de Poder Popular de Gonzales brings this Civil Rights Complaint 
on behalf of its membership who are Latino residents of the City of Gonzales, located in Salinas 
Valley, within Monterey County, California. Gonzales residents Moreno, Perea and Davila join 
in the civil rights complaint as Latino residents who have been disproportionately harmed and 
discriminated against by SVSWA in this process. 
III. THE SALINAS VALLEY SOLID WASTE AUTHORITY 
The Salinas Valley Solid Waste Authority (SVSWA) is Òa joint powers agency made up 
of the following local governments: Monterey County (eastern half of the unincorporated 
county), and the cities of Gonzales, Greenfield, King City, Salinas, and Soledad.Ó 3 It is the 
agency responsible for solid waste disposal of these local governments.4 
The SVSWA is the government agency responsible for the discriminatory actions which 
are the subject of this complaint Ð it picked the Johnson Canyon Landfill immediately adjacent to 
3 SVSWA website, accessed February 14, 2012, at http://svswa.org/about.cfm 
4 Id. 

Asamblea de Poder Popular de Gonzales Ð Ca. Gov. Code ¤11135 Complaint against SVSWA 5 
Gonzales as the location for the proposed project, selected the Plasco project for advanced 
consideration in Gonzales, serves as the lead agency for the project, and is conducting the 
administrative processes which have denied Latinos and Spanish speakers equality of 
opportunity to participate in the decision-making processes. 
SVSWA has a Board of Directors which consists of nine elected officials, only one of 
whom is from Gonzales, compared to three officials from the City of Salinas and two members 
from the County of Monterey.5 It has a staff that is headed by Executive Director Patrick 
Matthews; its administrative offices are located in Salinas.6 
The SVSWA is subject to the California Government Code 11135(a), which applies to 
Òany program or activity that is conducted, operated, or administered by the state or by any state 
agency, is funded directly by the state, or receives any financial assistance from the stateÓ, 
because the SVWA receives substantial state financial assistance from CalRecycle and the 
Department of Conservation. For instance, the SVSWA has received $60,864.00 from 
CalRecycle (TCA8-10-40) for the period July 1, 2011 to September 30, 2012, as well as other 
financial assistance from the Department of Conservation.7 
IV. RIPENESS 
This complaint is timely filed because the SVSWAÕs pattern and practice of 
discrimination against Gonzales residents is ongoing, including discriminatory actions that took 
place on February 22, 2012 at the SVSWA Scoping Meeting. 
Among its most recent actions, the SVSWA discriminated against Latinos and Spanish 
speakers in preparation for and during a highly controversial CEQA scoping meeting held on 
February 22, 2012 to take public comment on the ÒInitial StudyÓ for the Environmental Impact 
Report planned for the Plasco project. At that meeting, SVSWA violated the civil rights of 
5 SVSWA website, ÒBoard of DirectorsÓ, last accessed February 15, 2012, available at 
http://svswa.org/board_of_directors.cfm. 
6 SVSWA website, ÒContact UsÓ, at http://www.svswa.org/contact.cfm, last accessed February 14, 2012. 
7 See Exhibit 1. ÒSummary of Current & Previous State and Federal Grants as of February 2012Ó, received from the 
Salinas Valley Solid Waste Authority on 2 February 2012 in response to a California Records Act Request by 
Greenaction. 

Asamblea de Poder Popular de Gonzales Ð Ca. Gov. Code ¤11135 Complaint against SVSWA 6 
Latino and Spanish-speaking residents by acts including: 
. Failing to translate key documents into Spanish (including the Initial Study on the project 
that would provide the basis for the EIR and CEQA process, and is the basis for comments 
during the 30 day public comment period); 
. Giving unequal notice to Spanish and English speakers (including that SVSWA excluded 
Spanish speakers from the initial notice for the February 22, 2012 scoping meeting, so that 
they eventually were notified only 1 week before the meeting, compared to English 
speaking residents who received notice over two and a half weeks prior to the meeting, 
and Plasco who received over one month prior notice), 
. Refusing to provide adequate interpretation services between English and Spanish, by first 
failing to provide sufficient numbers of interpretation headsets for simultaneous 
translation, and subsequently, after agreeing at the beginning of the meeting to provide 
consecutive translation, repeatedly refusing to do so. 
. Appearing to not intend to receive or record comments by Latino Spanish speakers on an 
equal basis as English speakers at the scoping meeting, as the meeting was conducted in 
English and was initially set up to provide only English to Spanish interpretation, and not 
Spanish to English interpretation, even though key officials including Patrick Matthews, 
Executive Director of SVSWA and the court reporter who was transcribing the 
proceeding, did not speak Spanish. 
. Knowingly scheduling the scoping meeting on Ash Wednesday, the beginning of Lent, 
very important religious observances in a town where the majority of residents are 
Catholic, and the fact that the time of the scoping meeting (6:30pm) was in direct conflict 
with religious services in Gonzales (5:30 and 7:00 pm.) 
These process and notification defects had adverse discriminatory impact against Latinos 
and Spanish speakers, making it impossible for Spanish speaking residents of Gonzales to 
meaningfully participate in the February 22, 2012 meeting. Many were so outraged that 

Asamblea de Poder Popular de Gonzales Ð Ca. Gov. Code ¤11135 Complaint against SVSWA 7 
approximately 100 out of 120 residents walked out of the meeting. This constitutes 
discriminatory acts prohibited by Section 11135, undertaken within the statutory period. 
Other violations will be detailed in the next sections. 
V. STATEMENT OF FACTS 
A. The Community 
Gonzales is a small city located in Salinas Valley within Monterey County, California. 
According to the 2010 U.S. Census, there are approximately 8187 residents, 88.1 percent of 
whom are Hispanic or Latino, with 84.3 percent being of Mexican heritage.8 According to the 
2006-2010 American Community Survey 5-year estimates, a vast majority of residents are 
Spanish speakers - 74.6 percent of residents speak Spanish at home9; of these persons, 54.5 
percent spoke English Òless than Ôvery wellÕ Ó, and 25.8 percent spoke English Ònot at allÓ. 10 
Thus approximately 40.6 percent of the total population of Gonzales were Spanish speakers who 
spoke English less than Òvery wellÓ, and 19.2 percent of the total population of Gonzales were 
Spanish speakers who did not speak English at all.11 
39.1 percent of the residents in Gonzales are foreign born.12 Of the foreign born, 
approximately 95 percent are Spanish speakers, and of them, approximately 89.8 percent speaks 
8 U.S. Census Bureau, ÒProfile of General Population and Housing Characteristics: 2010Ó for Gonzales City, 
California, from 
http://factfinder2.census.gov/faces/tableservices/jsf/pages/productview.xhtml?pid=DEC_10_DP_DPDP1&prodType 
=table (last visited February 3, 2012). 
9 ÒSelected Social Characteristics in the United StatesÓ for Gonzales, 2006-2010 American Community Survey 5- 
Year Estimates, at 
http://factfinder2.census.gov/faces/tableservices/jsf/pages/productview.xhtml?pid=ACS_10_5YR_DP02&prodType 
=table, last visited February 14, 2012. 
10 According to ÒNativity by Language Spoken at Home by Ability to Speak English for Populations 5 Years and 
OverÓ for Gonzales, CA, 2006-2010 American Community Survey 5 year Estimates, of 7293 persons surveyed: 
5440 persons were Spanish speaking (2500 native born persons, and 2940 foreign born persons). Of these, 54.5% of 
spoke English less than Òvery wellÓ (2960 out of 5440 persons). There were approximately 25.8% of Spanish 
speakers in Gonzales spoke English Ònot at allÓ (1402 persons out of 5440 persons)(15 native born persons and 1387 
foreign born persons spoke English Ònot at allÓ.) 19%were Spanish speakers who spoke English Ònot at allÓ (1387 
out of 7293 persons). 
11 Ibid. 40.6% of Gonzales residents spoke English Òless than very wellÓ (2960 out of 7293 persons). 19.2% of 
Gonzales residents spoke English Ònot at allÓ (1402 persons out of 7293 persons) 
12 ÒSelected Social Characteristics in the United StatesÓ supra note 9. 

Asamblea de Poder Popular de Gonzales Ð Ca. Gov. Code ¤11135 Complaint against SVSWA 8 
English less than Òvery wellÓ and 47.2 percent speaks English Ònot at allÓ.13 Thus of all foreignborn 
persons in Gonzales, 85.5 percent were Spanish speakers who speak English less than Òvery 
wellÓ, and 44.9 percent were Spanish speakers who speak English Ònot at allÓ. 14 
In contrast, only 55.4 percent of the residents of Monterey County as a whole are 
Hispanic or Latino.15 Only 52 percent of Monterey County residents speak a language other than 
English at home; only 44.8 per cent of Monterey County residents speak Spanish at home, and of 
these, only 24.9 per cent speak English Òless than Ôvery wellÕÓ16. Only 30.8 percent of Monterey 
County residents are foreign born.17 Of the foreign born in Monterey County, only 76.5 percent 
are Spanish speakers, approximately 81.4 percent of whom speak English less than Òvery wellÓ, 
and 33 percent speak English Ònot at allÓ. Of all foreign born persons in Monterey County, only 
63 percent were Spanish speakers who speak English less than Òvery wellÓ and only 25 percent 
speak English Ònot at allÓ. Only approximately 8.2 percent of all Monterey County residents 
speak English Ònot at allÓ.18 
13 According to ÒNativity by Language Spoken at Home by Ability to Speak EnglishÓ for Gonzales, supra note 10: 
there were 3087 foreign born persons in Gonzales. 2940 out of 3087 foreign-born persons in Gonzales were Spanish 
speakers (thus 95% of foreign-born persons were Spanish speakers.) Of those, only 301 of them spoke English 
Òvery wellÓ. The remainder - 2639 persons -- were Spanish speakers who spoke English less than very well. (Thus 
89.8% of Spanish speakers spoke English Òless than Ôvery wellÕÓ (2639 out of 2940 persons), and 47.2% spoke 
English Ònot at allÓ (1387 out of 2940 persons). 
14 According to ÒNativity by Language Spoken at Home by Ability to Speak EnglishÓ for Gonzales, supra note 10, 
85.5% of all foreign born people in Gonzales were Spanish speakers who spoke English less than very well (2639 
out of 3087 persons) and 44.9% were foreign born Spanish speakers who spoke English Ònot at allÓ (1387 out of 
3087 persons). 
15 U.S. Census Bureau, ÒProfile of General Population and Housing Characteristics: 2010Ó for Monterey County, 
California, from 
http://factfinder2.census.gov/faces/tableservices/jsf/pages/productview.xhtml?pid=DEC_10_DP_DPDP1&prodType 
=table (last visited February 3, 2012). 
16 ÒSelected Social Characteristics in the United StatesÓ for Monterey County, 2010 American Community Survey 
1-Year Estimates. 
17 Id. 
18 According to ÒNativity by Language Spoken at Home by Ability to Speak English for Populations 5 Years and 
OverÓ for Monterey County, 2006-2010 American Community Survey 1 year Estimates, there were 122,084 foreign 
born persons in Monterey, and 93,362 of them were Spanish speakers (thus 76.5% of foreign-born persons were 
Spanish speakers.) Of the foreign born Spanish speakers, 17,338 of them spoke English Òvery wellÓ. The remainder 
Ð 76,024 persons -- were Spanish speakers who spoke English less than very well. Thus 81.4% of foreign-born 
Spanish speakers spoke English less than very well (76,924 persons out of 93,362 persons). 33.2% of foreign-born 
Spanish speakers spoke English Ònot at allÓ (30,926 out of 93,362 persons). 63% of all foreign born persons were 
Spanish speakers who spoke English less than very well (76,924 persons out of 122,084 persons), and 25.3% of all 
foreign-born persons in Monterey were Spanish speakers who spoke English Ònot at allÓ (30,926 out of 122,084 
persons). 8.2% of Monterey County residents spoke English Ònot at allÓ (30,926 out of 374,891 persons). 

Asamblea de Poder Popular de Gonzales Ð Ca. Gov. Code ¤11135 Complaint against SVSWA 9 
Gonzales is economically depressed, with the Latino population being particularly 
affected. The per capita income for Gonzales residents is only $16,212,19 compared to $24,95020 
in Monterey County21 and $27,353 for California as a whole22. For Hispanics and Latinos in 
Gonzales, the per capita income is even lower Ð it was estimated as only $14,603. 23 
Of those affiliated with a religious congregation, an estimated 77 percent of Gonzales 
residents are Catholic.24 
B. The Salinas Valley Solid Waste Authority 
The Salinas Valley Solid Waste Authority (SVSWA), formed in 1997, is a joint powers 
agency made up of the cities of Gonzales, Greenfield, King City, Salinas, and Soledad as well as 
the eastern half of unincorporated Monterey County.25 It is the agency responsible for solid 
waste disposal of these local governments. 
Its stated mission is ÒTo manage Salinas Valley solid waste as a resource, promoting 
sustainable, environmentally sound and cost effective practices through an integrated system of 
waste reduction, reuse, recycling, innovative technology, customer service and education." 26 
It is the SVSWA that controls the future landfill siting or expansion.27 It apparently owns 
four landfills, but of these, only the Johnson Canyon landfill in Gonzales is still operating. 28 
19 ÒSelected Economic CharacteristicsÓ for Gonzales, 2006-2010 American Community Survey 5-Year Estimates, 
last accessed February 14, 2012, at 
http://factfinder2.census.gov/faces/tableservices/jsf/pages/productview.xhtml?pid=ACS_10_5YR_DP03&prodType 
=table 
20 Selected Economic Characteristics (for Monterey County), 2010 American Community Survey1-Year Estimates, 
http://factfinder2.census.gov/faces/tableservices/jsf/pages/productview.xhtml?pid=ACS_10_1YR_DP03&prodType 
=tablelast accessed February 15, 2012, 2012. 
21 Id. 
22 Id. (for California) 
23 ÒPer Capita Income in the Past 12 Months (In 2010 Inflation Adjusted Dollars)(Hispanic or Latino)Ó (for 
Gonzales), 2006-2010 American Community Survey 5-Year Estimates, last accessed February 14, 2012, available a 
http://factfinder2.census.gov/faces/tableservices/jsf/pages/productview.xhtml?pid=ACS_10_5YR_B19301I&prodTy 
pe=table 
24 City-data.com, citing Jones, Dale E., et al., 2002. Congregations and Membership in the United States 2000, at 
http://www.city-data.com/city/Gonzales-California.html, last accessed 22 February 2012. 
25 SVSWA website, accessed February 14, 2012, at http://svswa.org/about.cfm 
26 Id. 
27 Id. 
28 Id. 

Asamblea de Poder Popular de Gonzales Ð Ca. Gov. Code ¤11135 Complaint against SVSWA 10 
SVSWA has a Board of Directors which consists of 9 elected officials, only 1 of whom is 
from Gonzales, compared to 3 officials from the City of Salinas and 2 members from the County 
of Monterey.29 It has a staff that is headed by Executive Director Patrick Matthews; its 
administrative offices are located in Salinas.30 
The SVSWA has an operating budget of $15 million. 78.5 percent of its revenue is 
derived from tipping fees (amount charged per ton for solid waste delivered to the landfill for 
disposal.) 14.23 percent is from out-of-area waste. 5.77 percent is from investment earnings, and 
1.5 from grants and other revenue.31 
C. The Backdrop of Environmental Racism, and History of Disproportionate 
Burdens on Latinos in Gonzales for Waste Disposal of the Region 
The phenomenon of disproportionately siting polluting industries and facilities in 
ÒminorityÓ communities is well documented -- studies done by EPA and other organizations have 
documented from at least the early 1990Õs that Latinos and people of color bear a significantly 
disproportionate share of the countryÕs environmental dangers.32 This has often been called 
Òenvironmental racismÓ. A 2010 study confirms the continuance of this phenomenon: ÒWhether 
this pattern results from deliberate intent to discriminate, or results from decisions related to 
economic status (pollution is concentrated in poor and thus less politically powerful areas, and 
race in the U.S. is statistically correlated with income), people of color bear a disproportionate 
burden of environmental pollution and face disproportionate obstacles in effective enforcement 
of environmental laws or cleanup of pollution that threatens their health.Ó33 
29 SVSWA website, ÒBoard of DirectorsÓ, supra note 5 
30 SVSWA website, ÒContact UsÓ, supra note 6. 
31 Salinas Valley Waste Authority Handbook, page 5-2, available for download at http://svswa.org/about.cfm, last 
accessed 25 February 2012. 
32 U.S. E.P.A., Environmental Equity: Reducing Risk for All Communities, Vol. 1, EPA 230-R-008, at 12 (June 
1992); Commission for Racial Justice, United Church of Christ, Toxic Wastes and Race in the United States (1987); 
Luke W. Cole, ÒEmpowerment as a Means to Environmental Protection: The Need for Environmental Poverty 
LawÓ, 19 Ecology L.Q. 619, 622-28 (1992). 
33 Steven Bonorris, ed., Environmental Justice for All (Fourth Edition), February 15, 2010, citing Luke W. Cole & 
Sheila R. Foster, From the Ground Up: Environmental Racism and the Rise of the Environmental Justice Movement, 
Appendix A (NYU Press, 2001). 

Asamblea de Poder Popular de Gonzales Ð Ca. Gov. Code ¤11135 Complaint against SVSWA 11 
The City of Gonzales fits this pattern. Gonzales, whose population is approximately 88.1 
percent Latino (supra note 8), has long borne a disproportionate burden of the solid waste 
disposal in the region, because it is the site of a Johnson Canyon Sanitary Landfill, a regional 
landfill that receives a large amount of solid waste from cities throughout surrounding areas, 
despite Gonzales itself being a small town that produces a very small proportion of the garbage. 
Johnson Canyon Sanitary Landfill is the only functioning landfill operated by SVSWA. 
According to CalRecycle, in 2009 Gonzales sent only 5,646 tons of waste to the Johnson Canyon 
landfill, while Salinas sent 67,523 tons (close to 12 times more than Gonzales). The SVSWA 
allows garbage to be sent to Johnson Canyon landfill even from jurisdictions from outside the 
entire Salinas Valley (and thus outside the jurisdiction of the SVSWA) Ð for instance in 2009 
Gilroy sent 19,479 tons (close to 3.5 times more than Gonzales), and unincorporated jurisdictions 
in Santa Clara County sent 12,935 tons (close to 2.3 times more than Gonzales).34 
Because the population of Gonzales has a higher percentage of Latinos compared to the 
rest of Monterey County (88.1% of the population in Gonzales is Latino, while only 55.4% of 
the population in Monterey County as a whole is Latino, see supra Section V.A. Statement of 
Facts, The Community), this also means that Latinos are bearing a disproportionate share of the 
burden of solid waste disposal of the region. 
This type of disproportionate impact on Latinos (and other communities of color) fits a 
common pattern in California (and elsewhere.) That discriminatory sitings are not unintentional 
is strongly suggested by documents like the Cerrell Report, a study commissioned by the 
California Waste Management Board to analyze the political difficulties in siting Waste-to- 
Energy projects. The Cerrell Report implicitly advised companies and governmental entities to 
site such projects in communities in low socioeconomic strata because they are relatively less 
able to resist, stating that ÒAll socioeconomic groupings tend to resent the nearby siting of major 
facilities, but the middle and upper-socioeconomic strata possess better resources to affectuate 
34 CalRecycle, ÒActive Landfills Profile for Johnson Canyon Sanitary Landfill (27-AA-0005)Ó, at 
http://www.calrecycle.ca.gov/Profiles/Facility/Landfill/LFProfile2.asp?COID=27&FACID=27-AA-0005, last 
accessed 21 February 2012. 

Asamblea de Poder Popular de Gonzales Ð Ca. Gov. Code ¤11135 Complaint against SVSWA 12 
their opposition. Middle and higher-socioeconomic strata neighborhoods should not fall at least 
within the one-mile and five-mile radii of the proposed site.Ó 35 
D. SVSWA promotion of new ÒConversion TechnologyÓ projects for waste 
management, and the selection of the Plasco Plasma Arc Gasification Proposal for 
advancement to the Environmental Impact Report stage (February 2005 to January 20, 
2011) 
In February 2005, the Board of Directors of the Salinas Valley Solid Waste Authority 
(SVSWA) began investigating alternatives to landfill disposal of solid waste. It approved a goal 
to achieve 75% Diversion from Landfills by 2015, and started to research emerging 
technologies.36 
From April to November 2006, the Board discussed long term waste management 
scenarios, including ÒIntensive Source Reduction, Recycling and Education Programs,Ó Ònoncombustion 
Conversion TechnologyÓ, and combustion based waste-to-energy technology. It also 
discussed options for siting a Òconversion technology projectÓ, including evaluating use of the 
Crazy Horse and Johnson Canyon Landfills, use of the Marina Landfill, and development of a 
new landfill along Highway 198. 37 
In December 26, 2006, the Board approved the final elements of the Long Term Waste 
Management Report, in which it approved use of the Crazy Horse and Johnson Canyon landfills 
(exploration of Long Valley sites as future landfills were suspended), and a non-combustion 
based Òconversion technologyÓ, and Intensive Source Reduction, Recycling and Education 
Programs.38 
35 J. Stephen Powell, Cerrell Associates, Political Difficulties Facing Waste-to-Energy Conversion Plant SitingsÓ, 
Report by Cerell Associates prepared for California Waste Management Board, p. 42-43. Emphasis added. 
36 SVSWA website, ÒAbout the Salinas Valley Solid Waste AuthorityÓ at http://svswa.org/about.cfm, last accessed 
25 February 2012. 
37 Annual chronologies available on SVSWA website, from the ÒHistoryÓ box on the page entitled, ÒSalinas Valley 
Solid Waste Authority History of Diversion Services Incorporating the Long Term Waste Management Report, 
Short Term Goals and the Conversion Technology CommissionÓ, at http://svswa.org/conversion_technology.cfm 
38 Id. 

Asamblea de Poder Popular de Gonzales Ð Ca. Gov. Code ¤11135 Complaint against SVSWA 13 
On March 15, 2007, the Board established a four-member Conversion Technology 
Commission (CTC) to explore non-combustion based Òconversion technologiesÓ in accordance 
with the Long Term Waste Management plan.39 The goal of the Conversion Technology 
Commission was to Òidentify the best and most effective Òconversion technologiesÓ applicable to 
Salinas ValleyÓ. 40 
The SVSWA defines conversation technologies as Òsophisticated processes capable of 
converting post-recycled residual solid waste into renewable energy, green fuels, and other 
beneficial products.Ó41 It considers that the following can be considered to be conversion 
technologies: Òbiological processes such as aerobic and anaerobic digestion; thermal processes 
including gasification, pyrolysis, and plasma gasification; and chemical processes, such as 
fermentation, acid hydrolysis, and distillation.Ó42 However, environmental and environmental 
justice groups have pointed out that there has never been a plasma arc plant anywhere in the 
world that has generated significant energy, so they challenge the term Òconversion technology.Ó 
On January 17, 2008, SVSWA issued a Statement of Qualifications calling for 
applications by vendors interested in submitting a proposal for the ÒJohnson Canyon Resource 
Management ParkÓ. 43 
In May 15, 2008, the Board approved a short list of four selected vendors, and released 
Request for Proposals to them. 44 
After receiving proposals responding to the RFPs (August 2008), the CTC met to 
determine criteria for evaluation of the proposals (June 1, 2009) and ranked the proposals 
(August 2009).45 Of the submissions received, the SVSWA reviewed three proposals extensively 
39 Id. 
40 SVSWA, ÒSalinas Valley Solid Waste Authority History of Diversion Services Incorporating the Long Term 
Waste Management Report, Short Term Goals and the Conversion Technology CommissionÓ, at 
http://svswa.org/conversion_technology.cfm (last accessed 3 February 2012), and SVSWA Annual Report 2010 Ð 
2011, page 16 Ð 17, available for download from http://svswa.org/ 
41 SVSWA, ÒAuthority FactsÓ, downloadable from http://svswa.org/conversion_technology.cfm from the ÒQ&AÓ 
box, last accessed February 25, 2012. 
42 Id. 
43 See SVSWA annual chronologies, supra note 37. 
44 Id. 
45 Id. 

Asamblea de Poder Popular de Gonzales Ð Ca. Gov. Code ¤11135 Complaint against SVSWA 14 
and ranked them based on these goals and objectives: ÒMaximize diversion; Comparable gate 
fees; Reduce impact on climate change; Organics composting or Anaerobic digestion; Education 
Center; Separate, recycle or reuse materials; Financially self-sustaining; Public-Private 
partnership.Ó46 
In November 2009, SVSWA approved the start of negotiation with two Òtop rankedÓ 
vendors, Plasco Energy and Urbaser S.A. to define proposed projects.47 
SVSWA held its first ÒStakeholdersÕ MeetingÓ on the proposed projects on February 10, 
2010, and also held a public workshop at Gonzales Council Chamber. 48 SVSWA subsequently 
made various presentations on the proposed projects in 2010.49 
On January 5, 2011, the Conversion Technology Commission met to review projects to 
be selected for CEQA review.50 
On January 20, 2011, the SVSWA Board held a meeting to debate and make a decision 
on the proposal by the staff to approve the Plasco gasification project to move forward to an 
Environmental Impact Review. Members of the Conversion Technology Commission and 
representatives of Plasco and Urbaser were invited to make presentations, and 20 persons (5 
Gonzales residents and various persons representing organizations) commented on the proposal. 
Within the official Minutes for this meeting, very little of the substance of comments by 
community members and organizations is included. Virtually none of the substance of comments 
in opposition of the project, including information about health and environmental risks of the 
plasma arc gasification and misrepresentations were included in the minutes.51 The SVSWA staff 
46 SVSWA, Annual Report 2010-2011, page 17, available on www.svswa.org 
47 See SVSWA annual chronologies, supra note 37. 
48 Id. 
49 SVSWA made presentations to: San Juan Bautista Rotary (March 11, 2010); California Biomass Collaborative 
(May 10, 2010); National Conversion Technologies (August 19, 2010); Growers Shippers Association (August 24, 
2010). See Chronologies, supra note 37. 
50 See Chronologies supra note 37. 
51 Minutes of January 20, 2011 meeting of the SVSWA Board of Directors, available for download at 
www.svswa.org (in Agenda packet for February 2011 meeting.) 

Asamblea de Poder Popular de Gonzales Ð Ca. Gov. Code ¤11135 Complaint against SVSWA 15 
presentation on January 20, 2011 included clearly incorrect statements about the Plasco 
technology, its emissions and energy generation.52 
The Board voted 6-3 to approve PlascoÕs plasma arc gasification technology to advance 
to the Environmental Impact Report stage. 
F. Plasco and the plasma arc gasification waste incineration proposal 
Plasco is a Canadian company that operated a pilot plasma arc plant in Ottawa, Canada 
that had dozens of exceedences of pollution limits and failed to generate significant energy. 
The Plasco project that has been selected by the SVSWA for advanced consideration is 
based on plasma arc gasification, an experimental and two-stage incineration technology. 
PlascoÕs plasma arc technology first heats garbage, creating ÒsyngasÓ that is then incinerated, 
resulting in the emissions of air pollutants. 
Critics consider this a dangerous technology that will cause significant adverse impacts 
on the health and environment, because it will produce toxic emissions. There have been no 
successful commercial plasma arc waste treatment facilities in the world, and the only two 
commercial plasma arc waste treatment plants that existed in the U.S. closed after leaving 
stockpiles of untreated wastes and were unable to operate successfully. A report issued by 
Greenaction for Health and Environmental Justice and the Global Alliance for Incinerator 
Alternatives in June 2006 detailed the severe problems at the ATG plasma arc plant in Richland, 
Washington and the Hawaii Medical Vitrification Facility (the Hawaii facility subsequently 
closed).53 
Other points of contention include claims that the proposed plasma arc gasification 
facility will generate significant energy (critics allege that there is no demonstrable proof of this, 
and PlascoÕs test facility in Ottawa has never demonstrated such results), as well as PlascoÕs 
52 See Exhibit 2. Greenaction for Health and Environmental Justice, Untrue Statements and Key Omissions by the 
Salinas Valley Waste Authority in their Presentation to SVSWA Board Members Urging Approval of Moving 
Forward with Proposed Plasma Arc FacilityÓ, February 4, 2011. 
53 See Greenaction, Incinerators in Disguise Case Studies of Gasification, Pyrolysis, and Plasma in Europe, Asia, 
and the United States, at http://greenaction.org/incinerators/documents/IncineratorsInDisguiseReportJune2006.pdf 

Asamblea de Poder Popular de Gonzales Ð Ca. Gov. Code ¤11135 Complaint against SVSWA 16 
track record (according to the Ottawa, Canada Ministry of the Environment, Plasco had dozens 
of exceedences of pollution limits at their pilot facility.)54 
It is allege that SVSWA has known or should have known of these problems, yet failed 
to fully divulge the truth about the problems with PlascoÕs pilot facility, and their inability to 
generate significant energy and the failure of other plasma arc plants in the US. 55 
G. Environmental Impact Review process of the proposed Plasco plasma arc gasification 
project (January 20, 2011 to present) 
At its January 20, 2011 meeting, the SVSWA Board of Directors approved the Plasco 
plasma arc gasification proposal to advance to the Environmental Impact Report stage. 
The Environmental Impact Report is an assessment that is conducted by a consultant on 
the environmental and other impacts of a proposed project. It is part of the environmental review 
and permit process under the California Environmental Quality Act (CEQA). 
On March 8, 2011, SVSWA organized a public meeting at Gonzales High School to 
inform residents about the Plasco project. 
On May 11, 2011, the SVSWA issued a Request for Proposals for the CEQA consultant 
to be selected to conduct the Environmental Impact Report process. It formed a Review 
Committee to evaluate the proposals, consisting of staff, HDR engineer, and a retired city 
planner from Gonzales. The Review Committee evaluated proposals received and selected 
Environmental Science Associates (ESA).56 
On September 15, 2011, the SVSWA Board approved a Funding Agreement with Plasco 
for reimbursement by the company to the SVSWA for the cost of the Environmental Impact 
Report (estimated at $821,000.)57 
54 See Exhibit 2, Untrue Statements, supra note 52 
55 See Exhibit 2, Untrue Statements, supra note 52 
56 SVSWA, Report to Board of Directors: Monthly Progress Report on Environmental Review of Proposed 
Conversion Technologies in Accordance with California Environmental Quality Act, September 15, 2011. This 
document is contained within the Agenda Packet for the October 2011 meeting of the Board, which is available for 
download at http://svswa.org/board_of_directors.cfm. 
57 Id., Monthly Progress Report of December 15, 2011. This document is contained within the Agenda Packet for the 
January 19, 2012 meeting of the Board, which is available for download at http://svswa.org/board_of_directors.cfm. 

Asamblea de Poder Popular de Gonzales Ð Ca. Gov. Code ¤11135 Complaint against SVSWA 17 
On February 3, 2012, Gonzales community members received, with their utility bill, a 
notice in English and Spanish regarding for scoping meetings to solicit public comment on the 
issues that should be addressed within the EIR that the SVSWA is planning. The English notice 
listed scoping meetings for February 22 and February 28, but the Spanish notice listed only the 
February 28 scoping meeting.58 
Around February 6, 2012, the SVSWA issued the Plasco Salinas valley ÒInitial StudyÓ, a 
56-page document prepared by Environmental Science Associates to Òto encourage comments on 
what should be analyzed in the EIRÓ by residents and governments. 
The Initial Study provided some (though not all) information about potential significant 
adverse health and environmental risks of the Plasco project Ð it stated that the Plasco project has 
Òpotentially significant impactÓ in the following dimensions: 
. Emit toxic air contaminants from the flare and gas engine generators59 
. Generate diesel particulate matter, which has been classified by the California Air 
Resources Board as a toxic air contaminant for cancer risk60 
. Generate greenhouse gases from transportation, on-site uses, and generation of 
electricity61; 
. Transport various hazardous materials to and from the project site during 
construction, and during operation, emit airborne pollutants and other waste 
products that could contain hazardous chemicals62 
The Initial Study stated that the Plasco plasma arc gasification proposal had significant 
risk of violating air quality standards (page 2-3), conflicting with existing air quality plans (page 
2-3), having substantial adverse impact on special-status plants and animals species known to be 
present in the site, including the California tiger salamander (a state and federally listed 
58 See Exhibit 3(a) & 3(b), SVSWA, ÒPublic Information and Public Participation Opportunities Regarding a 
Proposal by Salinas Valley Solid Waste Authority to Develop a Plasma Arc Gasification Facility at the Johnson 
Canyon LandfillÓ (no identifiable date, but received by community members on February 3, 2012) (in English and 
Spanish) 
59 Environmental Science Associates (ESA), Initial Study (on Plasco Salinas Valley), page 2-4. 
60 Id. 
61 Id. at page 2-11. 
62 Id. at page 2-14. 

Asamblea de Poder Popular de Gonzales Ð Ca. Gov. Code ¤11135 Complaint against SVSWA 18 
threatened species), western spade foot toad, burrowing owl, vernal pool fairy shrimp, and others 
(Page 2-5); and could result in water quality degradation (page 2-18). Further, the Initial Study 
stated that the proposal has risk of exposing people substantial adverse effects including risk of 
loss, injury or death linked to seismic-related ground failure, because it is in close proximity to 
the San Andreas fault (page 2-9). 
On February 15, 2012, Asamblea and Greenaction sent an email to SVSWA to request 
cancellation of the meeting because of unequal notice and the conflict of the February 22, 2012 
scoping meeting with the Catholic religious observances for Ash Wednesday (beginning of 
Lent).63 
Around February 15, 2012, Gonzales residents received the notices in English and 
Spanish regarding the scoping meetings. This time, the Spanish notice listed both the February 
22 and 28 scoping meetings.64 
On February 16, 2012, 28th District Assemblymember Luis A. Alejo sent a letter to 
SVSWA requesting cancellation of the February 22 and 28, 2012 scoping meetings, because of 
concerns about transparency and failure to properly inform Spanish speakers.65 
On February 16, 2012, Susan Warner of SVSWA responded to Asamblea and 
GreenactionÕs request for cancellation, denying the request to cancel the meetings due to the 
serious notice and scheduling problems. 66 
On February 22, 2012, SVSWA held the Òscoping meetingÓ. This meeting was highly 
controversial and 100 of the 120 members of the community present walked out. 
H. February 22, 2012 scoping meeting 
63 See Exhibit 4 Letter from Asamblea Poder Popular de Gonzales & Greenaction to SVSWA of 15 February 2012. 
64 See Exhibit 5(A) & 5(B), Notice from SVSWA received by Gonzales residents on February 15, 2012 (containing 
similar information from the notice that arrived February 3, 2012, but with revised Spanish information that listed 
both the February 22 and 28, 2012 scoping meetings.) (A-ENGLISH; B-SPANISH) 
65 Exhibit 6. Letter from Assemblymember of 28th District Luis Alejo, on ÒSalinas Valley Solid Waste AuthorityÕs 
Failure of Appropriate Notice on CEQA Process to Gonzales City ResidentsÓ (requesting cancellation of scoping 
meetings), February 16, 2012. 
66 Exhibit 7. Copy of Email Response from Susan Warner, Diversion Manager of SVSWA, responding to Asamblea 
and Greenaction letter of February 15, 2012 which requested cancellation of the February 22 and 28, 2012 scoping 
meetings. 

Asamblea de Poder Popular de Gonzales Ð Ca. Gov. Code ¤11135 Complaint against SVSWA 19 
Because of the discrimination apparent prior to the scoping meeting (unequal and 
inadequate notice, failure to translate key documents, and conflict with Ash Wednesday and 
Lent), Asamblea had already sent a request on February 15, 2012 for SVSWA cancel the 
February 22 (and February 28) 2012 scoping meeting. 
Upon refusal by the SVSWA, Asamblea organized a protest an hour before the scoping 
meeting on February 22, which was attended by approximately 60 persons. 
Upon the start of the scoping meeting, Asamblea again requested cancellation of the 
scoping meeting, expressing concern regarding the additional discrimination against Latinos and 
Spanish-speakers that became apparent at the meeting itself (including the translation headsets 
had run out so a number of limited English Latinos were not able to understand the proceedings, 
no simultaneous Spanish to English translation was being provided even though key SVSWA 
officials and others in attendance did not speak Spanish, and the transcriptionist of the 
proceedings did not speak Spanish). The facilitator of the scoping meeting (Candace Ingram) 
stated that the scoping meeting would proceed, saying that consecutive translation would be 
provided between English to Spanish and Spanish to English, but later refused to allow time for 
the consecutive translation, which led to the walk out of approximately 100 out of the 120 
residents attending the scoping meeting, and refusal of many who remained to give testimony 
because of the improperness of the proceedings. 
According to Asamblea and other community members, there was severe discrimination 
at the meeting against Latinos and Spanish-speakers as well as Catholics in the meeting 
procedures, including: 
. That SVSWA failed to translate key documents into Spanish (including the Initial Study 
on the project that would provide the basis for discussion at the meeting); 
. That SVSWA gave unequal notice given to Spanish and English speakers (including that 
SVSWA excluded Spanish speakers from the initial notice for the scoping meeting, so that 
they eventually were notified only 1 week before the meeting, compared to English 
speaking residents who received notice over two and a half weeks prior to the meeting, 

Asamblea de Poder Popular de Gonzales Ð Ca. Gov. Code ¤11135 Complaint against SVSWA 20 
and Plasco who received over one month prior notice), 
. That SVSWA refused to provide adequate interpretation services from English to Spanish, 
by first failing to provide sufficient numbers of interpretation headsets for simultaneous, 
and subsequently, after agreeing at the beginning of the meeting to provide consecutive 
translation, refusing to do so. 
. That SVSWA obviously did not intend to receive or record comments by Latino Spanish 
speakers on an equal basis as English speakers at the scoping meeting, as the meeting was 
conducted in English and was initially set up to provide only English to Spanish 
interpretation, and not Spanish to English interpretation, even though key officials 
including Patrick Matthews, Executive Director of SVSWA, Paul Miller from ESA (the 
company that was chosen by SVSWA to conduct the Environmental Impact Assessment 
for the project) as well as the transcriptionist who was transcribing the proceeding, did not 
speak Spanish. 
. That SVSWA knowingly scheduled the scoping meeting on Ash Wednesday, the 
beginning of Lent, a very important religious observance in a town where the majority of 
residents are Catholic, and the fact that the time of the scoping meeting was in direct 
conflict with religious services in Gonzales (5:30 and 7:00 pm.) 
VI. ARGUMENT 
Discrimination against people on the basis of race, national origin and/or ethnic group 
identification is prohibited under Cal. Gov. Code ¤11135(a), which provides: 
No person in the State of California shall, on the basis of race, national 
origin, ethnic group identification, religion, age, sex, sexual orientation, 
color, or disability, be unlawfully denied full and equal access to the benefits 
of, or be unlawfully subjected to discrimination under, any program or 
activity that . . . is funded directly by the state, or receives any financial 
assistance from the state. Cal. Gov. Code ¤ 11135(a) (West 2007) (emphasis 
added). 
SVSWA receives substantial state financial assistance. For instance, the 

Asamblea de Poder Popular de Gonzales Ð Ca. Gov. Code ¤11135 Complaint against SVSWA 21 
SVSWA received $60,864.00 from CalRecycle (TCA8-10-40) for the period July 1, 
2011 to September 30, 2012 as well as other financial assistance from the 
Department of Conservation.67 
The SVSWAÕs decisions and procedures violate the authorityÕs duty to administer all 
programs and activities in a nondiscriminatory manner. These violations include both actions that 
have caused and will cause significant adverse impact on Latinos and Spanish speakers in 
Gonzales on the basis of race, national origin, and ethnic group identification, as well as acts that 
constitute intentional discrimination against them on protected characteristics, all of which are 
prohibited by ¤11135(a). 
Specifically, 
A. SVSWAÕs decision to select Gonzales, without adequate consultation with its 
residents, as the site of a proposed Òconversion technologyÓ facility and to select 
PlascoÕs plasma arc gasification waste incineration project for advanced stages of 
consideration, has had and continues to have discriminatory and adverse impact on 
Latinos because the project would emit hazardous and criteria pollutants into the 
environment of Gonzales, as well as have other significant negative impacts; 
B. SVSWA intentionally acted to create this adverse effect on Latinos in Gonzales, 
because it acted improperly to pick Gonzales for the project site and assure selection 
of the Plasco project, including through systematically limiting public notification and 
comment in violation of civil rights laws and public notice requirements, providing or 
facilitating misinformation about the project, failing to adequately consider or 
intentionally ignoring negative information on the negative health and environmental 
effects of the project, failing to adequately consider the health and environmental 
effects of the project, and exercising bias in favor of Plasco; and 
67 See Exhibit 1, supra note 7. 

Asamblea de Poder Popular de Gonzales Ð Ca. Gov. Code ¤11135 Complaint against SVSWA 22 
C. The SVSWA unlawfully and intentionally discriminated against Latino and Spanishspeaking 
residents of Gonzales by implementing discriminatory procedures during the 
site selection, technology review and the CEQA Environmental Review Process, 
which resulted in unequal access to participation. 
These acts violate Cal. Gov. Code ¤11135(a), and the SVSWA must take all appropriate 
action to end SVSWAÕs state civil rights law violations. 
A. SVSWAÕs Decision To Select Gonzales, Without Adequate Consultation With Its 
Residents, As The Site Of A Proposed ÒConversion TechnologyÓ Facility And To Select 
PlascoÕs Plasma Arc Gasification Waste Incineration Project For Advanced Stages Of 
Consideration, Has Had And Continues To Have Discriminatory And Adverse Impact On 
Latinos Because The Project Would Emit Hazardous And Criteria Pollutants Into The 
Environment Of Gonzales, As Well As Have Other Significant Negative Impacts 
At its January 20, 2011 meeting, the Board of Directors of SVSWA adopted a decision to 
select PlascoÕs plasma arc gasification project to advance to the California Environmental 
Quality Act (CEQA) environmental review process. 
The CEQA process including the preparation of an Environmental Impact Report (EIR) is 
a crucial and vitally important part of the environmental review and permitting process, and a 
proposed project that is selected to move forward to do an EIR has already gone through multiple 
preliminary screenings including site selection, review of the statement of qualifications of many 
vendors, and selection of a company to move the process forward with to environmental review 
under CEQA. It is well established that once a proposed project reaches this stage, it is almost 
never ultimately rejected even though it may have significant environmental and health impacts 
because EIRs almost never issue a negative assessment on a proposed project, or, even when 
some negative environmental impacts are identified in the EIR, it will state that those impacts 
can be adequately mitigated even if it is unlikely to be true. This is in part because EIRÕs are 

Asamblea de Poder Popular de Gonzales Ð Ca. Gov. Code ¤11135 Complaint against SVSWA 23 
usually paid for by the company putting forth the proposal, who has an interest in receiving 
approval for the project, as is the case with SVSWA and Plasco. 
In the case of the PlascoÕs proposal for plasma arc gasification in Gonzales, the SVSWA 
Board of Directors signed a Financial Agreement with Plasco in September 15, 2011 for the 
company to reimburse the SVSWA for the cost of the EIR, which a Review Committee of 
SVSWA decided would be conducted by Environmental Science Associates (ESA), a company 
based in Sacramento. Based on past history, the Plasco project is very likely to be issued a 
favorable Environmental Impact Report, and advance toward final approval. 
Unfortunately, the Plasco proposal, if implemented, will likely have adverse health, 
environmental and economic impacts, with a disproportionate burden falling on Latino 
populations in Gonzales, California. The Plasco plasma arc gasification project is based on a 
dangerous experimental and two-stage incineration technology. PlascoÕs plasma arc technology 
first heats garbage, creating ÒsyngasÓ that is then incinerated, resulting in the emissions of air 
pollutants as was confirmed at their pilot plant in Canada where they had dozens of pollution 
exceedences. 
The SVSWA has failed to adequately consider these adverse impacts into its decisionmaking, 
and has in fact on various occasions willfully ignored or even actively denied that they 
exist (this will be detailed in the next section.) However, even the ÒPlasco Salinas Valley Initial 
StudyÓ of February 2012 prepared by ESA in order to start the EIR process, provided some 
(though not all) information about significant adverse health and environmental effects of the 
Plasco project Ð it stated that the Plasco project would: 
. Emit toxic air contaminants from the flare and gas engine generators 
. Generate diesel particulate matter, which has been classified by the California Air 
Resources Board as a toxic air contaminant for cancer risk 
. Generate greenhouse gases from transportation, on-site uses, and generation of 
electricity; 

Asamblea de Poder Popular de Gonzales Ð Ca. Gov. Code ¤11135 Complaint against SVSWA 24 
. Transport various hazardous materials to and from the project site during 
construction, and during operation, emit airborne pollutants and other waste 
products that could contain hazardous chemicals68 
The Initial Study acknowledged that the proposal thus had significant risk of violating air 
quality standards (page 2-3), conflicting with existing air quality plans (page 2-3), having 
substantial adverse impact on special-status plants and animals species known to be present in 
the site, including the California tiger salamander (a state and federally listed threatened species), 
western spade foot toad, burrowing owl, vernal pool fairy shrimp, and others (Page 2-5); and 
could result in water quality degradation (page 2-18). Further, the Initial Study states that the 
proposal has risk of exposing people substantial adverse effects including risk of loss, injury or 
death linked to seismic-related ground failure, because it is in close proximity to the San Andreas 
fault (page 2-9). 
Thus the Plasco proposal could adversely affect the health and environment of Gonzales 
residents. Pollutants in the environment can also affect the agricultural sector in the region, 
which is an important employer for residents. All these would disproportionately affect Latinos, 
because Gonzales is predominantly Latino, and has a higher proportion Latinos than the rest of 
Monterey County. (See Section V.A. Statement of Facts, The Community) 
B. SVSWA intentionally acted to create this adverse effect on Latinos in Gonzales, 
because it acted improperly to pick Gonzales for the project site, and to assure 
selection of the Plasco project, including through systematically limiting public 
notification and comment in violation of civil rights laws and public notice 
requirements, providing or facilitating misinformation about the project, failing 
to adequately consider or intentionally ignoring information on the negative 
health and environmental effects of the project, failing to adequately consider 
68 Supra notes 59 to 62. 

Asamblea de Poder Popular de Gonzales Ð Ca. Gov. Code ¤11135 Complaint against SVSWA 25 
the health and environmental effects of the project, and exercising bias in favor 
of Plasco 
The selection of the Plasco plasma arc gasification proposal, which would have 
significant adverse effects on Gonzales residents, is not accidental. The SVSWA staff, led by 
Executive Director Patrick Matthews, has demonstrated a pattern of bias in favor of the proposal, 
that has included improper acts such as systematically limiting public notification and input in 
violation of the civil rights laws and public notification requirements, providing or facilitating 
misinformation about the project, and failing to adequately consider or willfully ignoring 
information about adverse impacts of the project on residents, while exercising bias in favor of 
Plasco. 
1. Systematic limitation of public notification and input on the Plasco project 
The SVSWA has acted systematically to limit public notification and input on the Plasco 
project. Among other acts, the SVSWA Board made decisions, all without adequate notification 
and comment, of important decisions including the selection of Gonzales as the site for a new 
Òconversion technologyÓ waste management project, without making efforts to make Gonzales 
residents aware of the project and to allow them meaningful opportunity for public comment; 
made a series of important decisions on the project without adequately informing residents about 
those decisions and giving them notice for opportunities for public comment; and when residents 
became aware of the project and expressed concerns, failed to assure adequate recording of the 
objections made to the project. 
a. SVSWA chose the Johnson Landfill Site in Gonzales, without making Gonzales 
residents aware of the project and giving them opportunity for meaningful public comment. The 
Board had started exploration of possible Òconversion technologyÓ projects for waste 
management in 2005, and since then have made decisions in its meetings that clearly 
significantly impact Gonzales residents. It already decided in 2006 to site the future Òconversion 

Asamblea de Poder Popular de Gonzales Ð Ca. Gov. Code ¤11135 Complaint against SVSWA 26 
technologyÓ in Gonzales at the Johnson Canyon landfill. This was done without efforts to make 
the Gonzales residents aware of the project, and allowing meaningful opportunity for public 
comment. SVSWA failed to conduct public outreach to inform them about proposals and about 
opportunities for public comment, and failed to translate notices, meetings or documents into 
Spanish. Thus, most residents in Gonzales had no idea that the Johnson Canyon landfill, which is 
very close to the city center of Gonzales (it is just 2 miles from a school in Gonzales) was 
proposed for and selected as the site for a new waste management project. The earliest that 
Asamblea and most community residents heard of these developments was late 2010, when 
Greenaction and Salinas Valley residents organized volunteers to go door to door in Gonzales. 
Many others did not hear about the Plasco project until the first public meeting organized by 
SVSWA at Gonzales High School on March 8, 2011, long after SVSWA had already selected 
Gonzales as the site of new waste management facility. 
The taking by a governmental authority of decisions that will have significant impacts on 
a community, in virtual secrecy without informing its residents and without public discussion, 
goes against principles of democracy, justice and governmental transparency and accountability. 
For instance, the California Brown Act (Ca. Gov. Code 54950-54963) which is aimed at 
transparency of local governmental authorities provides, 
ÒIn enacting this chapter, the Legislature finds and declares that the public commissions, 
boards and councils and the other public agencies in this State exist to aid in the conduct 
of the people's business. It is the intent of the law that their actions be taken openly and 
that their deliberations be conducted openly. The people of this State do not yield their 
sovereignty to the agencies which serve them. The people, in delegating authority, do not 
give their public servants the right to decide what is good for the people to know and 
what is not good for them to know. The people insist on remaining informed so that they 
may retain control over the instruments they have created.Ó Ca. Gov. Code Section 
54950. 

Asamblea de Poder Popular de Gonzales Ð Ca. Gov. Code ¤11135 Complaint against SVSWA 27 
When a governmental authority makes decisions that have disparate adverse effects on 
the health and environment of a low-income and/or community of color, in a process where there 
is no meaningful participation of the community, civil rights and environmental justice concerns 
are triggered.69 This has clearly been the case with SVSWA actions towards Gonzales. 
b. SVSWA made numerous decisions which led to the selection of the Plasco project for 
advanced stages of consideration, without informing Gonzales residents of opportunity for public 
comment. Subsequent to selecting Johnson Canyon landfill area in Gonzales as the project site in 
a non-transparent manner, the SVSWA and its bodies made numerous decisions about the future 
Òconversion technologyÓ project, which eventually led to the selection on January 20, 2011 of the 
Plasco project for advanced stages of consideration, all without informing Gonzales residents of 
opportunity for public comment. 
Among the important decisions that SVSWA has taken from 2006 to January 20, 2011 
without public input are: that the SVSWA Board created the Conversion Technology 
Commission (CTC) in 2007, the CTC and the Board made critical decisions and 
recommendations including the screening and selection of vendors, drafting of the Request for 
Proposals, the development of the criteria for evaluation of the proposals received, and selection 
of finalists from the proposals received, and the Board approved these recommendations.70 
Throughout this process, very little public information was provided to the residents of 
Gonzales on this process, and thus they had virtually no opportunity for participation and public 
comment until very advanced stages of the process. According to SVSWAÕs own information, it 
69 See for instance, Executive Order No. 12898 (59 Fed. Reg. 7629 (Feb. 16, 1994), and U.S. Department of Justice, 
Department of Justice Guidance Concerning Environmental Justice, 1995. 
70 According to the chronology in the SVSWA website, the Board created the Conversion Technology Commission 
in 2007. The Board appears to have made a decision in December 26, 2006 that Johnson Canyon and Crazy Horse 
landfill sites would be used. A Statement of Qualifications calling for applications by vendors interested in 
submitting a proposal for the ÒJohnson Canyon Resource Management ParkÓ was issued last December 2007 or 
early 2008. In May 15, 2008, the Board approved a short list of four selected vendors, and released Request for 
Proposals to them. After receiving proposals responding to the RFPs (August 2008), the CTC met to determine 
criteria for evaluation of the proposals (June 1, 2009) and ranked the proposals (August 2009). The SVSWA Board 
approved the start of negotiations with two vendors (Plasco and Urbaser) on November 9, 2009. 

Asamblea de Poder Popular de Gonzales Ð Ca. Gov. Code ¤11135 Complaint against SVSWA 28 
held its first ÒStakeholdersÕ MeetingÓ only in February 10, 2010.71 Subsequently, it reportedly 
made 4 presentations about the project in 2010, but these were only to small groups and were not 
public hearings. 72 The first large public meeting it held was only on March 8, 2011. Detailed 
information on the discussions and decisions of the Board on this process are available on the 
SVSWA website only from 2010, and documents related to the Conversion Technology 
Commission are available only from 2008.73 As stated above, Asamblea de Poder Popular de 
Gonzales, though it started operating in 2006, did not hear about this process until late 2010, 
when Greenaction and Salinas Valley residents organized volunteers to go door to door in 
Gonzales. 
Members of Asamblea and many community members were extremely alarmed when 
they learned of the prospect of a new waste disposal facility in Gonzales, a small city that already 
bears a disproportionate burden of waste management in the region. See supra Section V.C. The 
Backdrop of Environmental Racism, and History of Disproportionate Burdens on Latinos in 
Gonzales for Waste Disposal of the Region. Residents were especially concerned about the likely 
negative health, environmental and economic impacts. They attended the SVSWA Board 
meetings January 20, 2011 to express their concerns, but by this time, the Board had already long 
selected Gonzales as the project site, had narrowed the potential vendors, had developed a 
Request for Proposals and determined the criteria for evaluation, and had narrowed the proposals 
to two. On January 5, 2011, the Conversion Technology Commission had already made a 
determination on which proposal it would recommend. In the January 20, 2011 Board meeting, 
despite comments from community members about the lack of information that had been given 
to the community about the process, that more community members should be informed, and 
71 See Chronologies supra note 37. The SVSWA also made a presentation to the Gonzales City Council on the status 
of Johnson Canyon Resource Management Park on September 21, 2009, but this cannot be considered opportunity 
for public information and comment. 
72 SVSWA made presentations to: San Juan Bautista Rotary (March 11, 2010); California Biomass Collaborative 
(May 10, 2010); National Conversion Technologies (August 19, 2010); Growers Shippers Association (August 24, 
2010). 
73 See SVSWA website, www.svswa.org 

Asamblea de Poder Popular de Gonzales Ð Ca. Gov. Code ¤11135 Complaint against SVSWA 29 
concerns about the potential negative impacts, the SVSWA Board proceeded to select the Plasco 
proposal to proceed to the CEQA review and Environmental Impact Report stage. 
In accordance with civil rights laws, principles of environmental justice recognized by 
state and federal agencies and many regional agencies, and requirements of the California Brown 
Act, community members had a right to notice and to participation and comment in all meetings 
of the SVSWA including its Board and committees from the beginning of this process.74 Yet 
community members were not informed in any meaningful way, including that notice given (if 
any) about the meetings and discussion was not posted anywhere that seems to have caught the 
attention of community members, and they do not appear to have been provided in Spanish, 
despite the fact that approximately 74.6 percent of Gonzales residents speak Spanish at home, 
and of the Spanish speakers, 54.5 percent speak English less than Òvery wellÓ, and approximately 
25.8 did not speak English at all. See supra Section V.A. Statement of Facts, The Community. 
Lack of Spanish translation excluded an even greater proportion of foreign-born residents -- for 
foreign born residents of Gonzales, who comprise around 39.1 percent of the community, 95 
percent are Spanish speakers, 89.8 percent of whom speak English less than Òvery wellÓ and 47.2 
percent speak English Ònot at allÓ. See supra Section V.A. Statement of Facts, The Community. 
The lack of notice by the SVSWA becomes even more stark after January 20, 2011, when 
at least 111 Gonzales residents submitted written requests to the SVSWA to be informed about 
upcoming opportunities for public comment. 69 residents (62.1 percent) submitted the requests in 
English, and 42 residents (37.8 percent) submitted the requests in Spanish. 75 
Despite these requests, SVSWA continued to fail to adequately notify residents. For over 
one year it did not mail any notices to the 111 requesting residents of upcoming SVSWA Board 
74 The California Brown Act (Cal. Gov. Code ¤¤ 54950-54962) requires that ÒAll meetings of the legislative body of 
a local agency shall be open and public, and all persons shall be permitted to attend any meeting of the legislative 
body of a local agency, except as otherwise provided...Ó Cal. Gov. Code ¤54953(a). The Brown Act requires 
transparency at meetings of local agencies, such as the SVSWA, including providing publication of agendas for 
meetings, mailing notifications of the agenda when requested, and allowing for public attendance and comment. 
75 See Exhibit 8(A). (Partial) List of Gonzales, Ca. Residents Who Submitted Written Requests To Salinas Valley 
Solid Waste Authority On 20 January 2011 For Notice For ÒAny And All Opportunities For Public Comment On 
Waste Treatment Technologies And/Or Facilities Being Considered Or Proposed For The Salinas ValleyÓ and 
Sample Request in English (8B) and Spanish (8C) 

Asamblea de Poder Popular de Gonzales Ð Ca. Gov. Code ¤11135 Complaint against SVSWA 30 
meetings, which pursuant to the Brown Act must always integrate opportunity for public 
comment76, and it failed to post notification on the Board meetings on the website in Spanish. 
Further, the SVSWA formed a Review Committee in May 2011 to draft a Request for Proposals 
to select the company to conduct the environmental review. The Review Committee drafted the 
Request for Proposals, analyzed proposals received, and selected Environmental Science 
Associates (ESA), all without adequately informing Gonzales residents or giving them 
opportunity for public comment. 77 
In 2012, when the SVSWA organized and scheduled the Òscoping meetingsÓ for 
February 22nd and 28th for the purpose of soliciting comment on the ÒInitial StudyÓ for the 
CEQA review process, there were many flaws in the notification process, including that it 
omitted the February 22nd meeting from the initial notice to Spanish speakers (when the English 
notice listed both the February 22nd and 28th meetings). Though it sent a correction to Spanish 
speakers later, this did not remedy the situation because the disparate notices had caused 
confusion among residents, and Spanish speakers ended up getting much less notice than English 
speakers. This also constituted discrimination based on race, ethnic identification and nationality 
prohibited by Section 11135. More acts of discrimination will be detailed in the next section. 
c. Lack of Meaningful Opportunities for Public Participation and Comment. Further, it is 
clear that the opportunities for public comment were not meaningful at all. There is a strong 
appearance that SVSWA is not actually interested in receiving or giving consideration to public 
comment. In addition to making decisions contrary to opinions and requests submitted, SVSWA 
has at least on two occasions, failed to assure adequate recording of comments public comments 
expressing opposition to the project. 
After community members found out about the Plasco proposal, a number attended the 
SVSWA board meeting of January 20, 2011 at which the Plasco proposal was approved to 
advance to the CEQA environmental review process, including conducting an Environmental 
76 See supra note 74. 
77 See Monthly Progress Report September 15, 2011, supra 56. 

Asamblea de Poder Popular de Gonzales Ð Ca. Gov. Code ¤11135 Complaint against SVSWA 31 
Impact Report. Subsequently, community members have continued to attend Board Meetings in 
which the Plasco proposal has been on the agenda. 
At the January 20, 2012 Board Meeting, at least 20 persons and 5 residents of Gonzales 
attended and gave comments, in which at least 8 persons spoke about the need for more 
community outreach, at least 12 persons spoke for the need for further study of the project before 
approving the Plasco proposal to start the CEQA process, and at least 1 person spoke against the 
proposal. Board Vice President Fernando Armenta requested a postponement of 60 to 90 days 
because he felt the process has not been inclusive, regardless of city council and stakeholder 
meetings. 78 Yet SVSWA Board still voted 6-3 to approve the Plasco proposal to advance to the 
next stage of review, the CEQA process including the preparation of an Environmental Impact 
Report, which is funded by the proposing company and almost always issues favorable results 
for the company seeking permit approval. 
Even more shockingly, SVSWA has so far, in important occasions for public comment on 
the Plasco proposal, failed to adequately record public comments. In the January 20, 2011 Board 
meeting in which the Plasco proposal was selected, the minutes of the meeting did not record the 
substance of most public comments, including those made critiquing the safety of the 
technology, and alleging that Plasco made key misrepresentations about the project. For instance, 
Greenaction for Health and Environmental Justice, a San-Francisco based environmental justice 
organization working at the invitation of Gonzales residents, gave technical comments about how 
the information provided by the SVSWA was misleading and about PlascoÕs record of pollution 
excesses. Yet the substance of these comments are not reflected in the minutes Ð they merely 
note that Greenaction ÒSpoke in Opposition of the Proposed Project.Ó 79 
At the February 22, 2012 scoping meeting held in Gonzales High School, one cause of 
outrage for the community was that they discovered that SVSWA executive director Patrick 
Matthews, Paul Miller the representative of ESA (the company contracted to conduct the 
Environmental Impact Report), and the transcriptionist did not speak Spanish, and had not taken 
78 Minutes of January 20, 2011 meeting of the SVSWA Board of Directors, supra note 51. 
79 Minutes of January 20, 2011 meeting of the SVSWA Board of Directors, supra note 51. 

Asamblea de Poder Popular de Gonzales Ð Ca. Gov. Code ¤11135 Complaint against SVSWA 32 
interpretation headsets. Thus none of those people were prepared to understand comments made 
in Spanish, and those comments would not be recorded. After demands to cancel the meeting 
were denied, SVSWA stated it would provide consecutive translation of the discussions, because 
the meeting was obviously not set up to allow for simultaneous translation between English and 
Spanish, but subsequently refused to do so. This led to approximately 100 out of 120 residents to 
walk out of the meeting, and many that remained to refuse to give their testimony at that meeting 
in protest. 
All these actions indicate that SVSWAÕs systematic limitation of public participation and 
comment in the process that selected the Plasco project. 
2. Misinformation and omissions by SVSWA regarding plasma arc technology, its combustion 
processes, emissions, health effects, and potential for energy generation 
SVSWA has also acted intentionally to create a disproportionate impact on residents in 
Gonzales through selection of the Plasco project for environmental review, because it 
systematically provided or facilitated misinformation about the project in order to make it appear 
more attractive to the Board of Directors and the public. 
The starkest example of this was at the January 20, 2011 meeting of the SVSWA Board, 
in which board members heard a lengthy presentation by the staff of the SVSWA that urged the 
Board to vote in favor of selecting the Plasco project to move forward to the CEQA process and 
Environmental Impact Report stage. After hearing the staff presentation, the Board voted 6-3 in 
favor of the staffÕs recommendation. Unfortunately, the SVSWA staff presentations included 
statements that were clearly untrue and which they knew or should have known were untrue, and 
also omitted key facts regarding the technology, emissions, health and environmental effects, 
potential for energy generation, and PlascoÕs track record. These include: 
a. Misinformation that the Plasco plasma arc gasification project is based on a technology 
that does not involve combustion, and does not produce toxic emissions. The SVSWA has 
consistently issued information that was misleading, in order to paint plasma arc gasification 

Asamblea de Poder Popular de Gonzales Ð Ca. Gov. Code ¤11135 Complaint against SVSWA 33 
technology as a technology that does not use combustion, and produces no emissions, and 
therefore would not present any risks to health. SVSWA staff acted improperly by accepting 
these false claims and repeating them to the Board and to the public. For instance: 
. PlascoÕs proposal and subsequent materials and description of the project does not 
make clear in an understandable way that plasma arc gasification technology has two 
steps Ð heating of the waste into ÒsyngasÓ, and then combustion of the syngas. The 
information tends to skip over the details of the second process. 
. At the January 20, 2012 meeting of the Board of Directors, the speaker introduced by 
Patrick Matthews during the staff presentation to talk about economic development 
said Ònothing comes outÓ (there would be no emissions) from the proposed Plasco 
facility. This is simply, clearly not true as PlascoÕs own website confirms. SVSWA 
knew or should have known of this. Plasco clearly knew the statement was untrue, but 
said nothing. 
. A member of the CTC spoke as part of the staff presentation and claimed that the 
CTC was not recommending companies that emit toxics into the environment. This 
statement was incorrect, because Plasco (and Urbaser, the other company being 
considered) would have toxic emissions. 
. SVSWAÕs Director Patrick Matthews publicly denounced Greenaction for claiming 
that there would be a stack for emissions at a Plasco facility, and he alleged such a 
statement was false. In fact, Plasco now admits there would be not one, but two flare 
stacks, each 32 feet tall, at a facility if it was built in Gonzales. These stacks would 
have emissions of pollutants during start up and shut down of operations of the 
plasma arc facility. 
. In the proposal submitted by Plasco to SVSWA in 2008, the drawing of the proposed 
facility shows no stack for emissions. In photos of the Plasco pilot plasma arc facility 

Asamblea de Poder Popular de Gonzales Ð Ca. Gov. Code ¤11135 Complaint against SVSWA 34 
in Ottawa, Canada displayed by Plasco at the SVSWAÕs February 22, 2012 Scoping 
Meeting, 95% of the stack is cropped out.80 
b. Failure by SVSWA to disclose environmental exceedences by Plasco at its test facility 
in Canada. Plasco has had dozens of instances of emissions exceeding regulatory limits for total 
organic compounds, NOx and sulpher dioxide, yet SVSWA failed to disclose this information 
during the Board meetings. The violations include: 
. In July 2008, a test found sulpher dioxide emissions at the plantÕs flare to have 
exceeded the allowable limit 
. On two occasions in January 2008, organic matter exceeded the maximum limit 
. Activated carbon bed bypass non-compliance occurred February 1, 2009, 3 dates in 
December 2008, and five days in January 2009 
. According to the Ministry of the Environment, in 2009 Plasco had dozens of 
exceedences; 
. In 2010, Plasco had excess NOx emissions that exceeded regulatory limits 
. According to the Ontario WHAT, Canada Ministry of Environment in 2010, 
PlascoÕs Ottawa facility Òis strugglingÓ with smog-causing emissions, and has not 
yet proven it can be successful. 
c. Misrepresentation about the potential of Plasco to generate electricity, and thus qualify 
as a conversion technology. Further, misrepresentations about the potential of the Plasco project 
to generate electricity have been made by ESA and SVSWA. During the staff presentation at the 
SVSWA Board meeting on January 20, 2011, SVSWAÕs consultant Michael Greenberg from 
HDR told the SVSWA Board that Plasco generates twice as much electricity as Urbaser, a claim 
that was untrue and had no basis in actual reality. When Greenaction questioned consultant 
Michael Greenberg of HDR following the HDR portion of the staff presentation, he admitted that 
80 See Exhibit 9. Plasco, Drawing of proposed facility, submitted in 2008 to SVSWA in response to Request for 
Proposals. Source: Conversion Technology Commission, Agenda Packet for October 29, 2008. 

Asamblea de Poder Popular de Gonzales Ð Ca. Gov. Code ¤11135 Complaint against SVSWA 35 
his statement about PlascoÕs supposed energy generation (1) was merely a Òdesign conceptÓ 
without actual experience generating that much electricity, and (2) that HDR was surprised that 
Plasco was not generating as much electricity as they expected. Unfortunately, HDR and 
SVSWA staff failed to divulge to the Board the truth about the lack of significant energy 
generation, leaving the impression that Plasco actually generates a lot of electricity when in fact 
that is simply untrue.81 
All this misinformation created by misrepresentations made or permitted by SVSWA, 
made the Board much more likely to select the Plasco project. When the SVSWA Board of 
Directors launched the exploration of ÒConversion TechnologiesÓ in 2005, it mandated that the 
SVSWA search for alternatives to landfills by looking for Ònon-combustionÓ conversion 
technologies.82 Thus the characterization of the Plasco project as a non-combusution technology 
that produces no emissions, and generates energy, was important. Unfortunately, the Plasco 
project would have emissions and Plasco has not succeeded in their goal of significant energy 
generation at their pilot plant. 
3. The SVSWA has exercised insufficient concern for adverse effects on residents, while 
exercising improper bias and favoritism toward Plasco 
The SVSWA has not, and does not plan to, give proper consideration to the health 
impacts of the Plasco plasma gasification proposal, which would disproportionately affect Latino 
residents in Gonzales, California. 
The SVSWA Board had heard testimony about the misleading information about the 
Plasco project, including that it involved combustion, and would emit pollution into the air, at its 
January 20, 2011 meeting. Yet it decided to go ahead and approve the Plasco project. 
The SVSWA, in its efforts to explore conversion technologies, issued a Statement of 
Qualifications and Request for Proposals. The list of criteria that the SVSWA adopted to evaluate 
the submissions did not include consideration for the impact and risks to the health of residents 
81 Exhibit 2. Greenaction, ÒUntrue Statements and Key Omissions by the Salinas Valley Waste AuthorityÓ, supra 
note 52. 
82 See Chronologies supra note 37 and other SVSWA materials. 

Asamblea de Poder Popular de Gonzales Ð Ca. Gov. Code ¤11135 Complaint against SVSWA 36 
and the effect on the environment as a whole. A clear example is that the official criteria adopted 
to evaluate and rank proposals submitted in response to the Request for Proposals, did not 
include consideration of impact on health and environment for Gonzales residents (or of other 
areas.) Rather, it only listed the following as criteria: ÒMaximize diversion; Comparable gate 
fees; Reduce impact on climate change; Organics composting or Anaerobic digestion; Education 
Center; Separate, recycle or reuse materials; Financially self-sustaining; Public-Private 
partnership.Ó 83 It did not integrate for instance, Òhealth and environmental impacts on 
surrounding communityÓ into the list. 
Meanwhile, the SVSWA has demonstrated an improper bias and favoritism toward 
Plasco. In addition to putting incomplete and misleading statements into the public record that 
favored the Plasco project, there were other instances of unequal advantages being given to 
Plasco. For instance, the SVSWA apparently informed Plasco of the dates of the scoping 
meetings of February 2012 by at least mid-January, yet Gonzales residents only received notice 
on February 3rd and/or February 15th. See supra notes 58 and 64 and accompanying text. 
C. The SVSWA unlawfully and intentionally discriminated against the Latino and Spanishspeaking 
residents of Gonzales through language discrimination and flawed and unequal 
notification which resulted in unequal access to participation in processes related to the 
proposed Plasco plasma arc gasification project 
The SVSWA intentionally discriminated against Latino and Spanish speaking residents in 
Gonzales by systematically limiting their participation in the decision-making process despite 
their protected status under California Government Code ¤ 11135(a). 
¤ 11135 prohibits not only discrimination based on race, but also national origin and 
ethnic identification. This protects language minorities, such as Spanish speakers, from unfair 
exclusion of the benefits afforded to non-minorities. 
83 SVSWA Annual Report 2010-2011, supra note 40, at 17. 

Asamblea de Poder Popular de Gonzales Ð Ca. Gov. Code ¤11135 Complaint against SVSWA 37 
SVSWA discriminated against Latinos and Spanish speakers, including many foreignborn 
persons, including in failing to provide Spanish translations of key documents necessary to 
participate in the public comment process related to the Plasco proposal, as well as failing to 
make its website accessible to Spanish speakers; failing to provide adequate interpretation 
between English and Spanish at public meetings; failing to organize its meetings to be able to 
receive and records comments in Spanish; and failing to give equal notice and opportunity for 
Spanish speakers to participate in public meetings. 
Failing to provide make information available in Spanish and allow for discussion 
between Spanish and English clearly has the effect of disproportionately disadvantaging and 
excluding Latino residents in Gonzales. As detailed in Section V.A, Gonzales is a predominantly 
Latino/Hispanic town (88.1 percent of residents are Latino), and 74.6 percent of residents speak 
Spanish at home. Of the Spanish speakers, approximately 54.5 percent speak English Òless than 
Ôvery wellÕ Ó, and 25.8 percent speak English Ònot at allÓ. Foreign-born residents of Gonzales are 
even more disproportionately affected by lack of Spanish translation -- 95 percent of foreign born 
residents of Gonzales are Spanish speakers, of whom approximately 89.8 percent speaks English 
less than Òvery wellÓ and 47.2 percent speak English Ònot at allÓ. 39.1 percent of the residents in 
Gonzales are foreign born. See supra Section V.A. Statement of Facts, The Community. 
Because the information related to the Plasco project is very technical, it is impossible for 
a person that does not speak English very well or does not speak English at all to be able to 
understand most documents and participate meaningfully in the entire process, unless translations 
are provided for notice, written documents and oral proceedings. Thus, failure to provide such 
translations in Spanish effectively excludes a significant proportion of the Gonzales community 
from meaningful participation in the government review and public participation process related 
to the Plasco plasma arc gasification (and any Òconversion technologyÓ) proposal. This 
constitutes discrimination based on race, ethnic identification and nationality that violates 
Section 11135. 

Asamblea de Poder Popular de Gonzales Ð Ca. Gov. Code ¤11135 Complaint against SVSWA 38 
SVSWA also violated Section 11135 by giving unequal opportunity and notice for 
opportunities of public participation to Spanish speaking residents. 
1. Failing to provide Spanish translations of key information 
While SVSWA has provided Spanish translation of a handful (approximately six) of 
documents related to the Plasco plasma arc gasification proposal84, it has not provided and 
continues to fail to provide Spanish translation of key documents required for meaningful 
participation in the process. For instance, key documents required for meaningful participation in 
the current CEQA/Environmental Impact Report process (the purpose of which is to identify the 
issues that should be analyzed in the EIR) have not been translated into Spanish, including: 
o SVSWAÕs ÒPlasco Salinas Valley Notice of PreparationÓ, which gives notice of the 
undertaking of the EIR; 
o SVSWAÕs Plasco Salinas Valley Initial Study, a 56-page document that gives detail 
on the proposed plan for the EIR, which Òis provided to other governmental agencies 
and for the public to encourage comments on what should be analyzed in the EIRÓ85. 
The Initial Study document is the key document for the CEQA process to date, and the 
SVSWAÕs failure to translate this 56-page document effectively and unequivocally prevents 
Spanish-speaking residents and Limited English Speaking residents from participating equally in 
the process. 
The notice for the February 22, 2012 meeting directed people to the SVSWA website, 
and the Spanish version of the Initial Study was not available as of the date of filing of this 
complaint.86 
84 The SVSWA has provided English and Spanish versions of the following documents: ÒAuthority FactsÓ, a 4-page 
fact sheet about the SVSWA; Scoping Meeting Notice dated 1/30/2012 (community members received this in the 
mail with their utility bill around February 3, 2012, though there was a controversy because the initial Spanish that 
was sent omitted the February 22, 2012 scoping meeting, while the English listed the February 22 and 28 scoping 
meetings); SVSWA Staff Report to the Board of 12/15/11; SVSWA Staff Report to the Board of 11/17/11; SVSWA 
Staff Report to the City of Gonzales of 9/19/11; SVSWA Press Release 9/19/11. 
85 See Exhibit 3, SVSWA notice received by residents on February 3, 2011, supra note 58. 

Asamblea de Poder Popular de Gonzales Ð Ca. Gov. Code ¤11135 Complaint against SVSWA 39 
At the February 22, 2012 scoping meeting, the SVSWA had copies of the slides for 
Powerpoint presentation which was translated into Spanish. However, this document had only 
very general information about the Initial Study, and would not make it possible to read or 
key permit document, the Initial Study. 
The Public Comment card, which a member of the public is supposed to fill out to mail 
his or her comments to the SVSWA about issues that should be addressed in the EIR, was made 
available in Spanish at the February 22, 2012 scoping meeting, but is not available on the 
SVSWA website as of the date of this complaint. 
(Further, there are also problems with access by Spanish speakers to documents on the 
website, which will be discussed below.) 
All this clearly restricts the ability of Spanish speakers to participate equally and 
meaningfully in the commenting process for the EIR, and constitutes systemic exclusion of 
Spanish speakers from meaningful participation in the process. Both the English and Spanish 
notices for the scoping meetings state that there would be a 30 day comment period to submit 
comments on what should be analyzed in the EIR , and that the Notice of Preparation and Initial 
Study would be made available around February 6, 201287. The English version of these 
documents was made available around that date, but Spanish versions have never been provided 
as of the date of this complaint. Yet SVSWA set the deadline for comment as March 7, 2012. 
Further, other key documents that have not and are not being provided in Spanish include: 
¥ Notice and agendas for upcoming board meetings 
¥ Documents to be discussed at SVSWA Board Meetings, related to the Plasco proposal 
86 In English: ÒA copy of the Notice of Preparation and Initial Study can be obtained from the AuthorityÕs website at 
www.svswa.org, Gonzales City Hall or Monterey County Library at 851 Fifth Street.Ó In Spanish, ÒUna copia del 
Aviso de Preparaci—n y Estudio Inicial se puede obtener en www.svswa.org, City Hall o Libreria del Condado de 
Monterey ubicada en 851 de la Calle 5. From scoping meeting notices received February 3, 2012, supra note 58. 
87 Both the English and Spanish notice states that the Notice of Preparation and the Initial Study would be made 
available around February 6, 2012, and there would be a 30 day comment period. From scoping meeting notices 
received February 3, 2012, supra note 58. The English version of these documents was made available on the 
SVSWA website as stated, but the Spanish versions were not. 

Asamblea de Poder Popular de Gonzales Ð Ca. Gov. Code ¤11135 Complaint against SVSWA 40 
¥ Minutes of Board meetings 
As detailed in Section VI.B. above, the SVSWA staff and Board have been making 
decisions that have and will significantly affect Gonzales residents since at least 2006, when it 
decided to site the new Òconversion technologyÓ facility at Johnson Canyon landfill. Upcoming 
Board meetings will do the same. 
It is an aggregious violation of civil rights for a governmental entity to fail to provide 
Spanish translation of information related to its acts that can have a significant adverse affect on 
the residents, in a community where 74.6% speak Spanish at home, and approximately 40.6 
percent of the population are Spanish speakers who spoke English less than Òvery wellÓ, and 19.2 
percent do not speak English at all. See supra Section V.A. Statement of Facts, The Community. 
This constitutes discrimination based on race and cultural identity; further, the lack of Spanish 
translation has an even more discriminatory effect on the foreign born Ð 85.5 percent of foreign 
born residents are Spanish speakers that speak English Òless than very wellÓ, and 44.9 percent 
speak English Ònot at allÓ. See supra Section V.A. Statement of Facts, The Community. 
SVSWA must translate documents that are necessary for equal opportunity of 
participation by all Gonzales residents in current and upcoming public comment opportunities. 
Within the EIR process, there should have been translation of the Notice of Preparation and the 
Initial Study that is required to participate meaningfully in the current public comment process 
on the Environmental Impact Report (which SVSWA has scheduled to close on March 7, 2012) 
as well as translation (and issuance) of the notice and agenda of meetings of the SVSWA Board 
that address issues that relate to the Plasco project, and the relevant documents that the Board 
will be discussing. 
2. Failure to make the SVSWA website accessible in Spanish 
SVSWA clearly uses its website as one of the principal distributors of information to the 
public. As stated above, the notice on the February 22 and 28, 2012 scoping meetings directed 
persons to the website to download the Notice of Preparation for the EIR, and the Initial Study. 

Asamblea de Poder Popular de Gonzales Ð Ca. Gov. Code ¤11135 Complaint against SVSWA 41 
Further, the notice stated, ÒFor more information on the CEQA process, visit the Authority 
website at www.svswa.org or call (831) 776 3000.Ó 88 
However, as of the date of this complaint, the SVSWA website is inaccessible to limited 
English speakers and monolingual Spanish speakers, because the entire website and its 
navigation menus are in English. Thus a limited English or monolingual Spanish speaker would 
not even be able to know how to navigate to the six documents that are made available in 
Spanish. Websites that properly intend to provide information to limited English speakers always 
have a link in the home page that makes clear what other languages are available, and then has 
navigation options in those languages. 
3. Failing to provide adequate interpretation in Spanish at key public meetings. 
Further, the SVSWA failed to provide adequate interpretation services at meetings 
discussing the Plasco plasma arc gasification proposal. 
According to Asamblea which sought to attend all meetings of the SVSWA Board of 
Directors since at least March 2011, if it became aware that Plasco was on the agenda, only two 
of the meetings have provided Spanish interpretation, the meeting of September 15, 2011 and the 
meeting of January 19, 2012. At all meetings that Asamblea has attended of the SVSWA Board 
of Directors, no written materials were provided in Spanish. 
At the February 22, 2012 scoping meeting, English to Spanish interpretation was 
supposed to be provided, but SVSWA did not provide a sufficient number of headsets. SVSWA 
appeared to have only between 30 and 50 headsets, when approximately 120 residents attended 
the meeting, and at least some limited English speakers and monolingual Spanish speakers, and 
limited or non-Spanish speakers (including SVSWA Executive Director Patrick Matthews, ESA 
representative Paul Miller, and the court reporter doing the transcription of the proceedings), did 
not receive headsets. 
SVSWA knowingly and intentionally refused to provide adequate interpretation at the 
88 From scoping meeting notices received February 3, 2012, supra note 58. 

Asamblea de Poder Popular de Gonzales Ð Ca. Gov. Code ¤11135 Complaint against SVSWA 42 
scoping meeting on February 22, 2012. At the start of that meeting, members of Asamblea and 
other residents pointed out to the facilitator and SVSWA officials that interpretation headsets had 
run out, and requested cancellation of the meeting because limited English Spanish and 
monolingual Spanish speakers would not be able to understand, and, because many English 
speakers also did not have headsets. Patrick Matthews, SVSWA Executive Director, was asked 
publicly at the meeting asked by a community member whether he spoke Spanish, and he stated 
he did not. A resident stated at the meeting that he asked the court reporter whether she spoke 
Spanish and she did not. Neither had headsets. Paul Miller from ESA also did not have a headset 
and it is suspected that he does not speak Spanish. There were also other limited Spanish 
speakers and monolingual Spanish speakers that did not get translation headsets because they ran 
out. 
Asamblea and other residents protested vociferously for approximately 20 minutes and 
repeatedly requested cancellation of the meeting, but Candace Ingram, the facilitator selected by 
SVSWA, and SVSWA officials, refused. Ingram stated that the meeting will proceed, but at one 
point stated that consecutive translation will be provided. Some consecutive translation was 
provided, but this was sporadic, and the presentation made by SVSWA Executive Director 
Patrick Matthews was not translated into Spanish through consecutive interpretation, and when 
residents pointed this out, SVSWA said that the meeting will proceed regardless, and did not 
provide consecutive translation of most subsequent discussions. This led to the walk out in 
protest of approximately 100 to 120 residents who had been in attendance, and the refusal to give 
testimony by a number of persons that remained. 
This entire fiasco clearly had the effect of limiting meaningful participation by Spanish 
speakers in the discussions about the environmental review process for the Plasco plasma arc 
gasification proposal. Aside from the Spanish speakers being denied equal opportunity to 
participate at the February 22, 2012 scoping meeting, the overall impression that these processes 
were not welcoming or meaningful for Spanish speakers may discourage Spanish speakers (and 
Latinos) from seeking to participate in future opportunities. 

Asamblea de Poder Popular de Gonzales Ð Ca. Gov. Code ¤11135 Complaint against SVSWA 43 
4. Failing to institute procedures that would allow for genuine participation of Latinos and 
Spanish speakers, by assuring that comments can be received in Spanish. 
Astoundingly, at the February 22, 2012 scoping meeting, the SVSWA did not even 
appear to genuinely intend to receive or record comments by Latino Spanish speakers, as the 
meeting was conducted in English and was initially set up to provide only English to Spanish 
interpretation, and not Spanish to English interpretation. 
Shockingly, key officials including Patrick Matthews, Executive Director of SVSWA did 
not speak Spanish but made no effort to take an interpretation headset, even though he arrived 
early to the meeting. Further, the court reporter who was transcribing the proceedings also did 
not speak Spanish but was not given an interpretation headset, so obviously could not understand 
or transcribe comments made by Spanish speakers, including requests at the beginning of the 
meeting to cancel the meeting because of inadequate translation. It is suspected that Paul Miller 
from ESA (the company that was chosen by SVSWA to conduct the Environmental Impact 
Assessment for the project) also did not speak Spanish, though he also did not have a headset. 
Obviously, the participation by Spanish speakers in the meeting would not be 
meaningful, if their comments would neither heard by the authority with decision making power, 
nor recorded so they could be accessible to anyone else. 
As noted above, residents pointed these flaws out at the beginning of the meeting, and 
requested cancellation of the meeting. SVSWA refused to do so. 
5. Failure to provide equal notice and equal opportunity for Spanish speakers to participation in 
public comment processes 
For the reasons stated above, SVSWA has denied equal opportunity to Spanish speakers 
to participate in discussions related to conversion technology and the Plasco plasma arc 
gasification proposal. SVSWA has consistently failed to provide adequate notice to Spanish 
speakers about upcoming meetings where public comment could be made. As discussed above, 

Asamblea de Poder Popular de Gonzales Ð Ca. Gov. Code ¤11135 Complaint against SVSWA 44 
SVSWA has made very few efforts generally to notify Gonzales residents of public opportunities 
for comment on the conversion technology discussions and the Plasco project, including those 
residents who submitted written requests for notice on January 20, 2011. 
Of the notices and documents issued, very few were translated into Spanish, and Spanish 
speakers systematically have had (and currently have) unequal notice and access to information 
about almost all meetings and opportunities for public comment. 
Even written notices provided by the SVSWA has had many flaws and inequalities. For 
the scoping meetings for February 22 and 28, 2012, SVSWAÕs ÒnoticeÓ in English and Spanish 
was flawed and unequal, resulting in inequality for Spanish speakers. Gonzales residents 
received a notice of these meetings, in English and Spanish, in the mail with their utility bill on 
February 3, 2012. However, the English and Spanish notices were not the same-- the ÒNoticeÓ in 
English notified residents who read English about both the February 22 and 28 scoping meetings, 
yet the Spanish language ÒNoticeÓ only mentioned the February 28 scoping meeting. Regardless 
of whether this failure to notify Spanish speaking residents about the February 22nd Scoping 
Meeting was intentional or accidental, it constituted unequal and improper and discriminatory 
notice. Gonzales residents did subsequently receive a revised notice (on February 15, 2012), in 
which the Spanish copies now listed both the February 22 and February 28 meetings. This did 
not remedy the inequality, however, as it caused confusion in the community, and had disparate 
adverse impacts Ð Spanish speakers ended up having only about one week of notice to prepare 
for the scoping meeting, while English speakers had 19 days. 
Because of this defect, on February 15, 2012 Asamblea and Greenaction sent a letter to 
the SVSWA by email and calling for the cancellation of both meetings due to the defective and 
unequal notices (and also due to the fact that SVSWA scheduled the February 22, 2012 Scoping 
Meeting on an important Catholic religious observance, Ash Wednesday and the beginning of 
Lent.)89 
On February 16, 2012, Susan Warner of SVSWA responded with an email rejecting the 
89 See Exhibit 4. Letter from Asamblea Poder Popular de Gonzales & Greenaction to SVSWA, see supra note 63. 

Asamblea de Poder Popular de Gonzales Ð Ca. Gov. Code ¤11135 Complaint against SVSWA 45 
request for canceling the Scoping Meetings due to the notification issue, though she 
acknowledged the discrepancy and called it ÒregrettableÕ.90 SVSWAÕs response also 
acknowledged the fact that they were aware that key religious observances would occur in 
Gonzales at the same time as the Scoping Meeting on February 22nd (religious services were 
scheduled for 5:30 and 7:00 in the evening, while the scoping meeting was scheduled for 
6:30pm.) Despite acknowledging these problems, SVSWA decided to proceed with the scoping 
meetings even though it is clear many residents would have to attend their important religious 
observance instead of the scoping meeting. 
For all these reasons, SVSWA instituted a pattern of practices, some of which were 
knowing and intentional, that limited the opportunities available to Spanish speakers to 
participate equally and meaningfully in the decision-making process. Thus the SVSWA has 
violated Section 11135 by intentionally discriminating against Gonzales residents on the basis of 
their race, ethnic identification and national origin, thus denying the people most affected by the 
proposed project the ability to fully participate. This far exceeds the showing of disparate impact 
necessary to find a violation of ¤ 11135. 
VII. REMEDIES 
For all the reasons above, SVSWA violated Section 11135 by engaging in discrimination 
based on race, ethnic identification, and nationality. 
Complainant requests that the State of California Attorney General conduct an 
investigation to determine whether the Salinas Valley Solid Waste Authority violated California 
Government Code section 11135 due to the violations and discriminatory actions described in 
this complaint. 
90 Exhibit 7. Copy of Email Response from Susan Warner, Diversion Manager of SVSWA, of February 16, 2012, 
supra note 66. 

Asamblea de Poder Popular de Gonzales Ð Ca. Gov. Code ¤11135 Complaint against SVSWA 46 
In order to provide effective remedies for the discrimination set forth in this Complaint, 
the State of California should require as a condition of continuing to provide state financial 
assistance to the SVSWA that the Authority: 
(1) Immediately cease the CEQA review of the Plasco proposal, that was selected through 
improper procedures, and is currently being conducted in a discriminatory and biased manner, 
including the EIR process that is being conducted by a vendor that was chosen in a closed 
process that Gonzales residents were effectively and systematically excluded from; 
(2) Reverse its decision of January 20, 2011 to select the Plasco plasma gasification project, 
and begin the entire ÒConversion TechnologyÓ review process from the beginning with full 
opportunities for meaningful participation of all residents, including examination of varied 
options for locations to site conversion technology projects; 
(3) Require that all Gonzales and Salinas Valley residents receive equal and adequate notice, 
in English and Spanish, for all future meetings on any waste disposal, waste management and/or 
waste treatment projects being considered, reviewed or evaluated by the SVSWA, including but 
not limited to the proposed Plasco Plasma Gasification project; this includes meetings of the 
SVSWA Board at which the Plasco proposal, or any other discussion affecting Gonzales, will be 
discussed. Residents who request it should also receive the agenda and documents for discussion 
for these meetings, 
(4) Cease language discrimination by: 
. Translating all key documents related to the discussions on Òconversion technologiesÓ 
that would affect Gonzales and all communities in the Salinas Valley into Spanish, 
including documents such as ÒNotices of PreparationÓ and Ò Initial StudiesÓ, and 
notices and agendas for meetings of the SVSWA board and documents to be 
discussed that are relevant to the Plasco project or any other issue that affects 
Gonzales or other Latino, Spanish-speaking communities in the SVSWA jurisdiction; 
SVSWA Board minutes; and other relevant documents from other bodies that are 

Asamblea de Poder Popular de Gonzales Ð Ca. Gov. Code ¤11135 Complaint against SVSWA 47 
critical for meaningful participation by Spanish speakers on the Òconversion 
technologyÓ discussions; 
(5) For any official comment period, assure that Spanish speakers have equal time to submit 
comments as English speakers, counting the date that Spanish translation of the required 
documents are made available to the public; 
(6) Translate the SVSWA website into Spanish, or as a minimum provide navigation tools 
for Spanish speakers to be able to find the Spanish documents on the website. During the period 
that this has not completed, SVSWA should provide a Spanish speaking contact to the 
community, through which residents can ask for Spanish copies of documents. 
(7) Provide simultaneous translation between English and Spanish for all participants in 
public meetings that are open to public participation and comment on the Plasco proposal (and 
other projects that will affect Gonzales and the Salinas Valley), including relevant scoping 
meetings, meetings of the SVSWA Board, and other meetings. This should assure both that 
Spanish speakers can understand English, and English speakers can understand Spanish; 
(8) Ensure that the comments made by the public, in both English and Spanish, through 
comment periods, public meetings of the SVSWA and other relevant bodies, are recorded 
adequately and faithfully, so that it serves as a meaningful and accurate record of the comments; 
(9) Cease siting waste management and other polluting facilities in a discriminatory fashion 
that disproportionately affect communities of color and immigrants, such as Gonzales. 
(10) Respect environmental justice principles, and develop a SVSWA Environmental Justice 
Policy in compliance with state and federal environmental justice principles, in consultation with 
communities within the SVSWA jurisdiction; 
(11) Assure full compliance with the Brown Act in providing transparency in proceedings, 
notification, copies of documents. 
(12) Provide complainants with copies of all correspondence to or from the SVSWA 
throughout the course of the investigation, deliberation and disposition of this Complaint. 

Asamblea de Poder Popular de Gonzales Ð Ca. Gov. Code ¤11135 Complaint against SVSWA 49 
Asamblea Poder Popular de Gonzales Complaint Against Salinas Valley Solid Waste Authority 
Under Ca. Gov. Code Sect. 11135 
February 28, 2012 
LIST OF EXHIBITS 
EXHIBIT 1. ÒSummary of Current & Previous State and Federal Grants as of February 2012Ó, 
received from the Salinas Valley Solid Waste Authority on 2 February 2012 in response to a 
California Records Act Request by Greenaction 
EXHIBIT 2. Greenaction for Health and Environmental Justice, ÒUntrue Statements and Key 
Omissions by the Salinas Valley Waste Authority in their Presentation to SVSWA Board Members 
Urging Approval of Moving Forward With the Proposed Plasma Arc FacilityÓ, February 4, 2011 
EXHIBIT 3(A) & 3(B). SVSWA, ÒPublic Information and Public Participation Opportunities 
Regarding a Proposal by Salinas Valley Solid Waste Authority to Develop a Plasma Arc Gasification 
Facility at the Johnson Canyon LandfillÓ (no identifiable date on the text, but community members 
received it with their utility bill on February 3, 2012) (A Ð ENGLISH; B Ð SPANISH) 
EXHIBIT 4. Letter from Asamblea Poder Popular de Gonzales & Greenaction for Health and 
Environmental Justice on ÒFatal Defects in SVSWA Notice of Scoping Meeting & Request to Cancel 
Scoping Meetings of February 22 and 28, 2012Ó, February 15, 2012 
EXHIBIT 5(A) & 5(B). Notice from SVSWA received by Gonzales residents on February 15, 2012 
(containing similar information from the notice that arrived February 3, 2012, but with revised 
Spanish information that listed both the February 22 and 28, 2012 scoping meetings.) (A-ENGLISH; 
B-SPANISH) 
EXHIBIT 6. Letter from Assemblymember of 28th District Luis Alejo, on ÒSalinas Valley Solid 
Waste AuthorityÕs Failure of Appropriate Notice on CEQA Process to Gonzales City ResidentsÓ 
(requesting cancellation of scoping meetings), February 16, 2012. 
EXHIBIT 7. Copy of Email Response from Susan Warner, Diversion Manager of SVSWA, 
responding to Asamblea and Greenaction letter of February 15, 2012 which requested cancellation of 
the February 22 and 28, 2012 scoping meetings. 
EXHIBIT 8(A), 8(B) & 8(C). 
8(A) (Partial) List of ÒGonzales, Ca. Residents Who Submitted Written Requests To Salinas Valley 
Solid Waste Authority On 20 January 2011 For Notice For ÔAny And All Opportunities For Public 
Comment On Waste Treatment Technologies And/Or Facilities Being Considered Or Proposed For 
The Salinas ValleyÕÓ; and 
8(B) - Sample Request in English and 
8(C) Ð Sample Request in Spanish 
EXHIBIT 9. Plasco, Drawing of proposed facility, submitted in 2008 to SVSWA in response to 
Request for Proposals. Source: Conversion Technology Commission, Agenda Packet for October 29, 
2008