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<br /> <br /> <br />There is a bias which appears to underlie the EIS discussion of <br />alternatives. It is evident on page 23 \o;ith the fOl.lo\..'ing 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 port,ion of the region, any reductions in use rate at the <br />other fills in the system will tend to expand the Anoka landfill <br />"ratershed 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 otherlandfi11s 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 Sununary of Alternatives, nearly everyone of the <br />eight conseguences listed are either incorrect, already have occurred <br />or will occur regardless of the proposed expansion. <br /> <br />The hydrogeologic issues addressed in the tIS have been largely <br />addressed through the Feasibility Study and Remedial Investigation <br />reguiredby the consent order between \<.'MMI and MPCA as well as the <br />Detailed Analysis"Report. That process was conducted independently of <br />the vertical expansion issue and 'VY'MMI \o.'ill be reguiredto undertake <br />the clean UD actions whether the landfill is exuanded 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 />WMMI'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 Inay penetrate the synthetic liner. Obviously, the <br />impact of the groundwater recovery and treatment system on the <br />drawdown of the water table and waterqua1ity remain concerns. <br /> <br />Leachate <br /> <br />Page 76 indicates that the steeper slopes are projected to decrease <br />the rate of percolation with the proposed final cover by eight to 10 <br />percent over the same cover at currently approved grades. TheEIS <br />further indicates "that a net increase in the volume of leachate <br />generated during the implementation of the vertical expansion will <br />occur". This hardly seerr.s prudent when compared to other <br />alternatives. The tIS indicates that the planned flow barrier system <br />should take care of these volumes with a lifetime net reduction. <br /> <br />4 <br /> <br />5D <br />