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. .i(~t'Z~.r~.:,.. COMMENTS ON THE DRAFT EIS FOR THE PROPOSED EXPANSION OF THE .hNOKA SANITARY LhNDFILL The purpose of the city's review of the Environmental Impact Statement (ElS) for the vertical expansion of the landfill is not necessa.rily to take a posi.tion on the landfill expansion issue. Ra.ther, it is to make it's concerns known relative to the quality, adequacy and validity of the information presented in the EIS document. The follO\oling comments, therefore, express concerns on those points which the' city GUb~+--M:iA~.differs with those expressed in the EIS. It is not the intent to indicate whether the City agrees or disagrees on eaeh 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. C~t).,i4. c- ; I 11 ~ , CitYAsta.ff have'discussed the comments with Wa.ste Management (W..Hl) personnel at theirreguest. While the parties are no.t.necessarily in agreement in all cases, both parties understand the other's concerns. Introductio.n The EIS on the proposed vertical expansion of Anoka Sani'tary 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 ir.pression 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 ~o the proposed action. The CON application and analysis infonnationwhich is contained in the EIS is da~ed and stale relying on the applicant's proposed 1986 expansioncapac:"-~y ra~her 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 ~he 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 inactivity '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 ConmlUn:"-ty 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