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The assessment does not take into account the impact of the restricted <br />crossing at the Mississippi River bridge, its impacts on alternative <br />routes or landfill destinations imposed by the bridge restrictions <br />and, therefore, distorts the actual costs of waste hauling when <br />comparing alternatives to the expansion. <br /> <br />There is a bias which appears to underlie the EIS discussion of <br />alternatives. It is evident on page 23 with the following paragraph: <br /> <br />"Shifts of capacity within the Metropolitan system are likely to <br />occur. These shifts have no bearing, however, on total need for <br />capacity within the system. Furthermore, the shift underway <br />during 1986 (the Flying Cloud restriction on disposal) raises the <br />likelihood of more need to dispose of waste at the Anoka <br />landfill. Since this is the only landfill located in the <br />northern portion of the region, any reductions in use rate at the <br />other fills in the system will tend to expand the Anoka landfill <br />watershed further south." <br /> <br />It would also be just as accurate to state: <br /> <br />"Any reductions in use rate at Anoka Landfill will tend to expand the <br />watersheds of other landfills to the north and east (as appropriate)." <br /> <br />This bias towards providing additional capacity at Anoka underlies the <br />entire expansion application, regardless of need, of alternatives to <br />the proposed action, or of environmental concerns. <br /> <br />On page 25 under the Summary of Alternatives, nearly every one of the <br />eight consequences listed are either incorrect, already have occurred <br />or will occur regardless of the proposed expansion. <br /> <br />The hydrogeologic issues addressed in the EIS have been largely <br />addressed through the Feasibility Study and Remedial Investigation <br />required by the consent order between WM/~I and MPCA as well as the <br />Detailed Analysis Report. That process was conducted independently of <br />the vertical expansion issue and WMMI will be required to undertake <br />the clean up actions whether the landfill is expanded or not. The <br />City raised concerns at appropriate times over the course of those <br />study periods. Of particular concern, however, is the impact of <br />WM/~I's proposed ski hill development on the integrity of the final <br />cover. This is particularly important where support apparatus would <br />be installed which may penetrate the synthetic liner. Obviously, the <br />impact of the groundwater recovery and treatment system on the <br />drawdown of the water table remains a concern. <br /> <br />3 <br /> <br /> <br />