Minutes - Council - 10/04/1988 - Special

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COMMENTS ON THE DRAFT EIS FOR THE PROPOSED EXPANSION OF THE ANOKA SANITARY LANDFILL The purpose of the city's review of the Environmental Impact Statement (EIS) for thevmrtical expansion of the landfill is not necessarily to take a position on the landfill expansion issue. Rather, it is to make it's concerns known relative to the quality, adequacy and validity of the information presented in the EIS document. The following comments, therefore, express concerns on those points which the city ~-~--=--~-/~ differs with those expressed in the EIS. It is not the intent to indicate whether the City agrees or disagrees on each aspect or statement of the EIS. We hope that, taken in this context, the tenor of the comments are viewed in a relatively neutral and objective, posture rather as strictly a negative position. city~taff have discussed the comments with Waste Management (WMMI) personnel at their request. While the parties are not necessarily in agreement in all cases, both parties understand the other's concerns. Introduction The EIS on the proposed vertical expansion of Anoka Sanitary Landfill has been reviewed by the City of Ramsey. The City's comments on the EIS are herein being submitted. As a general note, our review leaves the City with the impression that the EIS was completed as a supporting document to the Certificate of Need (CON) process rather than as an objective evaluation of impacts and alternatives to the proposed action. The CON application and analysis information which is contained in the EI$ is dated and stale relying on the applicant's proposed 1986 expansion capacity rather than the system's needs as reflected two years later. We also find that the EIS compares impacts of the expansion to a previous condition typical of 1986 rather than comparing the impacts to a severely curtailed operation as presently exists. Thus, many impacts are determined in the EIS to be no greater than presently exist when, in fact, a four to five fold increase in activity would be experienced over 1988 levels. The EIS throughout, bases its evaluation on a time frame which assumes operations would be completed in approximately two and a half years or 1991. However, Waste Management Minnesota, Inc. in their CUP applica- tion with the~City of Ramsey is indicating an operating life of at least five years. Thus, the duration of impacts to the Community is likely to be much longer than that portrayed through the EIS. This can be resolved, however, by placing an operational time limit on the proposed expansion through the permitting processes. 1