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It
CI\ / OF SAN BERNARDk..40 - REQULJT FOR COUNCIL AC...ON
Date:
October 7, 1988
Comments on the San Bernardino
County Hazardous Waste Management
Plan - Draft Environmental Impact
Report
Mayor and Council Meeting of
October 24, 1988, 2:00 p.m.
From:
Michael W. Loehr
Interim Director of ~il.OM'K. Ii'ject:
Planning \968 oct \ 2 PM '2: 21
Dept:
Synopsis of Previous Council action:
On September 29, 1988 the Environmental Review Committee reviewed
and commented on the CHWMP-DEIR.
Recommended motion:
That the Mayor and Council authorize the Mayor to direct staff to
prepare a letter of comment for the Mayor's signature .and submit it
to the County of San Bernardino.
~~
Michael W. Loehr
Contact person:
Michael W. Loehr
Phone: 384-5057
Supporting data attached: Staff Report
Ward:
City-wide
FUNDING REQUIREMENTS:
Amount:
tJh-
Source: (Acct. No.)
(Acct. DescriPtion)
Finance:
Council Notes:
75-0262
Agenda Item No.
1/1
.
CITi OF SAN BERNARDlh4 - REQUE~( FOR COUNCIL AC1...:)N
STAFF REPORT
To: Mayor & Common Council - Meeting of October 24, 1988
Re: Comments on the San Bernardino county Hazardous Waste
Management Plan (HWMP) Draft Environmental Impact Report
(DEIR)
In accordance with AB 2948 (Tanner, 1988)
with Health and Safety Code Section 25135,
Bernardino County Draft HWMP was prepared
conjunction with an advisory committee and
Review Group.
and in compliance
etseq., the San
by County staff in
a city and Agency
The Environmental Analysis section of the San Bernardino
County Office of planning, acting as lead agency and in
compliance with the provisions of the California
Environmental Quality Act (CEQA), has prepared a Draft
Environmental Impact Report for the County HWMP.
The City of San Bernardino Planning Department, as a
responsible agency, received and responded to a Notice of
Preparation of an Environmental Impact Report for the San
Bernardino County HWMP in January of 1988.
On September 14, 1988, the Planning Department received a
copy of the Draft EIR and a request from James E. Robbins,
Acting City Administrator, to review the document and prepare
a summary for the Council.
The Draft EIR was prepared as a Program EIR under the
requirements of CEQA, a Program EIR is one that is prepared
for a series of actions that can be construed as one large
project, where the actions are related either as logical
parts in the chain of contemplated actions or in connection
with the issuance of rules, regulations, plans or other
general criteria to govern the conduct of a continuing
program. The program EIR focuses only on the evaluation of
the County HWMP's policies, the overall facilities needs
assessment, and siting criteria. It does not address the
impacts of specific project facilities. As specific project
facilities are proposed and designed to fulfill the goals and
policies of the HWMP, additional environmental review will be
required.
In addition to the Planning Department, the Public Works,
Public Services, Fire and Water Departments were requested to
review the portions of the DEIR which were applicable to
their operations. The Environmental Review Committee (ERC)
also reviewed and discussed the DEIR at their meeting on
September 29, 1988.
~..(1;>54
..
Re: Comments on the San Bernardino county Hazardous Waste
Management Plan Draft Environmental Impact Report (DEIR)
october 24, 1988
The following is a summary of the comments pertaining to the
Draft EIR which were received:
Public Services
No additional comments
Public Works
DEIR is adequate
DEIR is adequate
Water Department
Fire Department
Environmental Review
Committee
Concerns with lack of
estimates of increased traffic
volumes and analysis of the
effect of the various programs
upon those estimates and
increased spill hazards.
No additional comments
The Planning Department shares the Fire Department's concerns
in regards to the lack of base datum and traffic volume
estimates on which the conclusory statement that truck
traffic would increase a "small degree" was based. 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
(pg. 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 is to occur on major highways. Requiring
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. 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
Re: Comments on the San Bernardino County Hazardous Waste
Management Plan Draft Environmental Impact Report (DEIR)
October 24, 1988
determination of the level of
transport of hazardous waste
additional base information.
potential
cannot
impact
be made
of rail
without
The DEIR states that the County HWMP will reduce hazards from
"existing illegal unsafe storage and disposal practices" (pg.
2-2) and "lower the amount of hazardous substances released
into ground and surface waters" (pg. 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. Staff believes this possibility should be
analyzed.
Finally, the Planning Department feels that Table 2-1,
Summary of Impacts and Mitigation Measures, does not clearly
define the local jurisdictions and 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. Staff believes
this needs to be more clearly shown in the chart.
RECOMMENDATION
It is recommended that the Mayor and Council direct staff to
prepare a letter delineating the above concerns and submit it
to the Environmental Analysis section of the San Bernardino
Office of planning.
prepared by: Tricia D. Thrasher, Planner I
For: Michael W. Loehr,
Interim Director of Planning
TOT: cms
10/6/88
doc.m&ccagenda.
comments. waste