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COMMENTS ON THE DRAFT EIS FOR <br />THE PROPOSED EXPANSION OF THE ANOKA SANITARY LANDFILL <br /> <br />Introduction <br /> <br />The EIS on the proposed vertical expansion of Anoka Sanitary Landfill <br />has been reviewed by the City of Ramsey. The city's comments on the <br />EIS are herein being submitted. <br /> <br />As a general note, our review leaves the City with the impression that <br />the EIS was completed as a supporting document to the Certificate of <br />Need (CON) process rather than as an objective evaluation of impacts <br />and alternatives to the proposed action. The CON application and <br />analysis information which is contained in the EIS is dated and stale <br />relying on the applicant's proposed 1986 expansion capacity rather <br />than the system's needs as reflected two years later. <br /> <br />We also find that the EIS compares impacts of the expansion to a <br />previous condition typical of 1986 rather than comparing the impacts <br />to a severely curtailed operation as presently exists. Thus, many <br />impacts are determined in the EIS to be no greater than presently <br />exist when, in fact, a four to five fold increase in activity would be <br />experienced over 1988 levels. <br /> <br />The EIS throughout, bases its evaluation on a time frame which assumes <br />operations would be completed in approximately two and a half years or <br />1991. However, Waste Management Minnesota, Inc. in their CUP applica- <br />tion with the city of Ramsey is indicating an operating life of at <br />least five years. Thus, the duration of impacts to the Community is <br />likely to be much longer than that portrayed through the EIS. This <br />can be resolved, however, by placing an operational time limit on the <br />proposed expansion through the permitting processes. <br /> <br />Underlying the entire landfill siting and expansion processes, there <br />appears to be some perception at the Metropolitan Council, the County <br />and MPCA that the Community and residents are simply suffering from <br />the NIMBY syndrome. This is not so. The City and its residents have <br />done their share and more to accomodate the region's waste. There <br />simply has to come a time when, like it or not, a landfill must close <br />in conjunction with its permitted life. <br /> <br />Need for Project <br /> <br />The EIS largely depends on the Certificate of Need (CON) application/ <br />analysis conducted in 1986. That process portrayed a near crisis <br />situation with respect to the region's landfill capacity and specifi- <br />cally the need for capacity between 1987-1990. The CON process con- <br />cluded that no feasible or prudent alternatives to expansion exist to <br />serve the region's needs during that time period. <br /> <br />The CON was reissued in January of 1988 at the same capacity as was <br />applied for by W-MMI in 1986 to serve 1987 through 1990 (635 acre- <br />feet). <br /> <br /> <br />