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Summary <br /> <br />The ElS is ]~s~{ largely on supporting a project for which the justi- <br />fication fo: ]]eed J.s dated. A number of "crisis" situations that had <br />been portraye~i ~:~ occuring in the CON process have been shown to be <br />incorrect. '~'t~ rate increases imposed by WMMI and the restrictions on <br />the Hwy. 169 Hi~sissippi bridge crossing have served to illustrate <br />over much ef tl~ past year just how "adverse" the impacts of closure <br />are. The Ni!3 ~a~pletely fails to address the expansion in this light. <br /> <br />As indicate~[ J.~ the city's original position statement commenting on <br />the EAW scop'h~q decision, the City believes that a valid assessment <br />would conside]" ~he type, the magnitude, and duration of impacts. It <br />has also been the City's position that the EIS evaluation baseline <br />should cons~:~}- a closed landfill versus expansion, rather than <br />comparing a~ c.x}~ansion with an operation that last existed at a <br />similar level .i~, 1986. <br /> <br />Most imporhan{.]T~ the EIS addresses a time frame which assumes <br />completion o~ hhe landfill operations inclusive of final cover by <br />1991. If, An ?~ct, the ElS is to be considered adequate, approval <br />should only be ~xmti_ngent on a time limited capacity combined with a <br />volume bas{:~ ca[,acity. As the City is aware, as MC is aware, and all <br />other partie~ are aware, simply approving a requested capacity <br />initiated bV an applicant has absolutely no relationship to the <br />duration of ~ny associated impacts since that capacity, historically, <br />has stretch~d we~]. beyond any projected closings. <br /> <br />Sincerely, <br /> <br />CITY OF RA/h }]5 <br /> <br />cc: Wayne N~i~',','~,,, , HC -- Solid Waste <br /> <br />File: RA9; i! -2: <br /> <br />10 <br /> <br /> <br />