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Summary <br /> <br />The EIS is based largely on supporting a project for which the justi- <br />fication for need is dated. A number of "crisis" situations that had <br />been portrayed as occuring in the CO~ process have been shown to be <br />incorrect. The rate increases imp=sad by W~SMI and the restrictions on <br />the Hwy. 169 Mississippi bridge crossing have served to illustrate <br />over much of the past year just ho~ 'adverse" the impacts of closure <br />are. The EIS completely fails to a~.~ess the expansion in this light. <br /> <br />As indicated in the City's original position statement commenting on <br />the EAW scoping decision, the City believes that a valid assessment <br />would consider the type, the magnitm~e, and duration of impacts. It <br />has also been the City's position ~h~t the EIS evaluation baseline <br />should consider a closed landfill versus expansion, rather than <br />comparing an expansion with an opera~ion that last existed at a <br />similar level in 1986. <br /> <br />Most importantly, the EIS addresses m time frame which assumes <br />completion of the landfill operati~_~ inclusive of final cover by <br />1991. If, in fact, the EIS is to be considered adequate, approval <br />should only be contingent on a time limited capacity combined with a <br />volume based capacity. As the City is aware, as MC is aware, and all <br />other parties are aware, simply app_-oving a requested capacity <br />initiated by an applicant has abso!~cely no relationship to the <br />duration of any associated impacts since that capacity, historically, <br />has stretched well beyond any proje~ed closings. <br /> <br />Sincerely, <br /> <br />CiTY OF <br /> <br />David Hartlay, City Administrator <br /> <br />cc: ~a','ne "=~ - So!i~ ;{as%a <br /> <br />Fi!e: -~3.9: !1-26 <br /> <br /> <br />