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HomeMy WebLinkAbout44-Planning Department DRAFT October 24, 1988 Paul Kielhold, Environmental Analyst ENVIRONMENTAL ANALYSIS TEAM 385 North Arrowhead Avenue San Bernardino, California 92415-0182 Re: San Bernardino County Hazardous Waste Management Plan (HWMP) - Draft Environmental Impact (DEIR) Dear Mr. Kielhold: At their meeting of October 24, the City of San Bernardino coordinated by the Planning Bernardino County HWMP - DEIR. 1988, the Common Council of received a staff report Department concerning the San The following are the City of San Bernardino's comments concerning the Draft E.I.R. 1. The Transportation Section (4.3) contains little or no base datum and traffic volume estimates on which to base the conclusory statement that truck traffic would increase a "small degree." (Page 4-21, section 4.3.2). without this base information, the conclusion that this impact is "less than significant" is not supportable. The cumulative impacts of added truck traffic to already impacted roadways has not been addressed. The City of San Bernardino General Plan Update Technical Backqround Report (1988) places the level of service on portions of Interstate 215 through the City at Levels "E" and "F". Any additional traffic on this route would be a significant impact. In addition, the DEIR (Page 2-10) identifies that significant transportation impacts could result from any spills of hazardous waste on the roadways and cites as a mitigation measure that the majority of transport on traffic-impacted highways does not reduce the risk of a spill incident occurring. On the contrary, it would increase the risk. It should be stated in the EIR that these are unavoidable adverse impacts. Rail transportation of hazardous waste and the resultant impacts have not been adequately addressed. If ENVIRONMENTAL ANALYSIS TEAM Attn: Paul Kielhold, Environmental Analyst October 24, 1988 Page 2 While risks related to specific rail transport routes can be addressed in subsequent project-specific environmental review, there are potential significant impacts for any rail transport that should be identified and discussed in the DEIR. Requiring a study to identify potential risks and corresponding mitigation measures is not, of itself, an acceptable mitigation. A determination of the level of potential impact of rail transport of hazardous waste cannot be made without additional base information. 2. The Public Health and Safety Section states that the County HWMP will reduce hazards from "existing illegal unsafe storage and disposal practices" (Page 2-2) and "lower the amount of hazardous substances released into ground and surface water" (page 2-12), resulting in an overall benefit to the health and safety of the public and to the environment. The DEIR does not, however, address the possibility that because of increased regulation and cost to dispose of hazardous waste, which could result from implementation of the HWMP, illegal dumping could continue and increase. The City believes this possibility should be analyzed. 3. In regards to Table 2-1, Summary of Impacts and Mitigation Measures, the Table does not clearly define the local jurisdictions' role in implementing the HWMP. A closer reading of DEIR indicates that where "Land Management" is listed in the "implemented by" column, each individual City will have responsibility. The city believes this needs to be more clearly shown in the chart. The City of San Bernardino appreciates the opportunity to review the Draft Hazardous Waste Management Plan - Draft Environmental Impact Report and looks forward to reviewing the revised EIR. Sincerely, Evlyn wilcox Mayor EW:TDT:cms ENVIRONMENTAL ANALYSIS TEAM Attn: Paul Kielhold, Environmental Analyst October 24, 1988 Page 3 cc: Michael W. Loehr Interim Director of Planning Ann Larson Senior Planner