Two Public hearings will be held for the Campo Landfill Draft Supplemental EIS (DSEIS)
The entire document can be found at www.campodseis.com. The Federal Register Notice is available at http://edocket.access.gpo.gov/2010/pdf/2010-4113.pdf. Hard copies of the DSEIS are reportedly available at the Campo, Pine Valley and Alpine libraries. Compact disc copies are available. Print copies are also available for approximately $250 including the appendices. Call John Rydzik at 916-978-6051. Mr. Rydzik is the Chief of the Division of Environmental and Cultural Resource Management and Safety, Pacific Region, Bureau of Indian Affairs.
Come and speak out about your concerns at the two local public hearings:
Tuesday, April 13, 6-9 PM at the Campo Tribal Center, 36190 Church Road, Campo
Wednesday, April 14, 6-9 PM Mountain Empire High School, 3305 Buckman Springs Road, Pine Valley
The 75-day comment period ends May 12, 2010. Written comments need to include the "Campo Landfill DSEIS" reference and need to arrive at the address below by May 12th:
Dale Risling, Acting Regional Director
Pacific Regional Office, Bureau of Indian Affairs
2800 Cottage Way, Sacramento, CA 95825
Comments can also be emailed by the May 12 deadline to:
Landfill proponents say the DSEIS and new landfill liner design answer all the questions and eliminate the potential for groundwater contamination. They do not. We have hired experts to review the new document and project design. They tell us that all liners eventually fail. We will provide their reports when completed.
The extra investigative work that was requested in the previous environmental review of the proposed Campo Landfill by numerous agencies and experts, to determine groundwater connections to adjacent off-reservation wells, was never completed. See comments below. In this groundwater dependent area with a highly fractured rock aquifer, monitoring for contamination is difficult if not infeasible. Once contaminated, we will have to pay to prove the landfill caused the contamination of our wells and then be required to sue the federal government and / or owners of the buried waste. It will be a very expensive nightmare. At the same time, we were advised by attorneys in a meeting with a previous Secretary of the Interior that, once contaminated, the tribe could sue the Feds for violating their trust responsibilities by approving a landfill, at the tribe's request, that resulted in the contamination of their water supply!
Important quotes from previous comments on the Campo Landfill project
Remember that the geology of the site has not changed:
Dr. David Huntley, SDSU Dept. of Geological Sciences (1993 letter to San Diego Regional Water Board). Dr. Huntley was a consultant to Mid-American, the Campo Landfill developer at the time:
"Using numbers in the Dames & Moore study, contaminants in the fractured-rock system underlying the Campo Landfill will have traveled 16,500 feet in [a] 165 day period. Given the proximity of nearby wells, and the lack of an alternative drinking water supply this should be a real concern to the community."
"If this site is approved as a landfill site, we must pray that there is no breach of the liner, as contaminants will move vertically down into both the weathered and fractured tonalite, and will then move laterally through fractures in unknown directions at unknown rates".
The US Environmental Protection Agency (comments on 1992 Final EIS):
"...compliance with the groundwater monitoring and corrective action provisions of the Federal solid waste disposal facility criteria (40 CFR Part 258) could prove difficult or infeasible in the geologic setting of the proposed landfill"
US Army Corps of Engineers (Final EIS & Record of Decision & Memo to Dept of Interior 9-11-92):
"The Sacramento District is concerned about the completion of the additional work that the attached comments request. We understand that in order to complete the EIS on schedule, this work will not be completed within the next few weeks / months. During our conference call, we discussed with you and representatives of SAIC that this work will become part of the requirements of the ROD. We are concerned that there is a potential that the additional drilling and pumping / drawdown tests will bring some technical data that could impact this project. We recommend that the BIA consider retaining the authority to review the and accept the monitoring plan/ design for this project if the ROD is signed."
"The developer would prefer the Corps comments to be "pro-project" and has considered the Corps comments on the Draft EIS to be out of scope and adverse to the project. Given the role of the independent technical consultant with the BIA asked the Corps to perform, we believe it would be inappropriate and inconsistent with this role to sanitize the Corp comments.
State Board of Registration for Geologists and Geophysicists (1993 Response to 1992 complaint):
"...fracture systems on and near the site have not yet been located sufficiently to allow installation of an effective monitoring system..."
California Integrated Waste Management Board staff (comments on 1992 Final EIS):
"Staff remains concerned that the proposed ground water monitoring program may not be adequate to detect contaminant migration in the event that the liner leaks, especially when the groundwater down gradient is presently used for domestic and agriculture purposes...Potential impacts remain undetermined."
Alan Waltner, attorney for Backcountry Against Dumps (comments on 1992 Final EIS):
"The EIS fails to analyze the potential environmental impacts of groundwater contamination resulting from liner failure, even though these impacts could reasonably be evaluated as potential high impact consequences of the project"
"...inappropriate pressure has apparently been applied on the United States Army Corps of Engineers, which is providing assistance to the BIA, to come to technical conclusions that are more "pro-project" than the Corp could otherwise reach."
Ted Smith, Professional Geologist (comments on 1992 Final EIS):
"[The landfill developers] do not know enough about the fracture system to place monitoring wells that would insure detection of groundwater degradation. They are misleading the public...It has been shown in both the study phase and the review phase that the project is flawed and the process should be stopped."
Dr. Victor M. Ponce, SDSU Dept of Engineering: Impact of the Campo Landfill on the Hydrology of the Tierra Del Sol Watershed, Reference Study, May 2006 (http://ponce.sdsu.edu/tierra_del_sol_study.html):
"In fractured-rock aquifers, a leachate plume will move preferentially along the fractures. Advection is likely to be the predominant physical mechanism, with travel times from capture zone to nearby wells measured in days, rather than in years, as would be the case in more traditional diffusion-dominated settings. Given the complexity of the fractured-rock system, the probability that leachate plumes will be missed by the system of monitoring wells is high. Thus, placing a major landfill on top of a fractured-rock aquifer such as Tierra del Sol's significantly compromises the health and welfare of the local population on both sides of the U.S.-Mexico border. Moreover, Tierra del Sol is part of the federally designated Campo-Cottonwood Creek Sole Source Aquifer, i.e., it has been determined that, should this aquifer become contaminated, there are no reasonably available alternative sources of drinking water."
With estimated fractured-rock solute velocities comparable to the hydraulic conductivity of medium-sized gravel, estimated at 1 cm/s (864 m/day), advection-dominated travel times from capture zone to nearby wells in the Tierra del Sol watershed, a distance of about 600 m (2,000 ft), could be reached in less than 1 day.
The potential for such a fast hydraulic connection is supported by accounts from local property owners, who describe the effects on their wells from extensive drilling, borehole washing, packer testing and other activities conducted on the landfill site in the early 1990s. Within a short time after the tests, water pumped from local wells was contaminated with sand and well-drilling debris. According to eyewitness accounts, the sand appeared (or disappeared) with concurrent activity (or nonactivity) on the landfill wells, suggesting the existence of an effective hydraulic connection between the landfill site and private domestic local wells.
The long-stalled Draft Supplemental Environmental Impact Statement is now posted at the project website at: www.campoDSEIS.com. Two public hearings are scheduled locally (see above). We need folks to send in written comments and to attend those hearings. Speak out against the importation of urban waste for disposal over our only water source.
The Campo Landfill Supplemental Environmental Impact Statement (SEIS): Due to the new information and various changes since the original EIS was approved back in 1993, the National Environmental Policy Act requires that a Supplemental EIS addressing those changes be prepared and circulated for comment. Areas of concern addressed in the Final EIS include: land resources, water resources, cultural resources, air quality, living resources, socio-economics, transportation, land use, resource use patterns, noise, and other values. The Notice of Intent for the SEIS was printed in the Federal Register on November 8, 2005.
New landfill lease approved by Campo Band: On December 12, 2004 the Campo Band approved a new sublease between BLT Enterprises, Inc., of Oxnard, and Muht Hei, Inc., the Campo Band's business entity. The sublease lease allows BLT to develop and operate the Campo Landfill, once all other approvals are in place. The lease area covers 1,150 acres with approximately 600 acres for the landfill. This information was reported in the San Diego Union-Tribune on December 15, 2004 and in the Notice of Intent for a Supplemental EIS in the November 8, 2005 edition of the Federal Register. BLT's Bernie Huberman also confirmed it.
The Campo Band: The Campo Band claims several hundred members. The Campo Reservation covers 15,580 acres. Their businesses include the Golden Acorn Casino at I-8 at Crestwood, Campo Materials, and the 50 MW Kumeyaay Wind energy facility. The first phase of the wind farm includes twenty-five 2 MW turbines which stand over 300 feet tall. The line of towering turbines runs along the Tecate Divide, north of I-8. In June 2009 it was announced that approximately 80 to 100 more industrial wind turbines are planned in partnership with San Diego Gas & Electric and Invenergy for a 160 MW project. We have been told time and again that there is ongoing internal opposition to the Campo Landfill from tribal members that don't want to turn their ancestral lands into a stinking garbage dump that will put their families and others at risk. We hope the opponents outnumber the proponents and the tribe will vote strongly to overturn any previous approvals, rejecting the project once and for all. See the Campo Kumeyaay Nations website at: http://www.campo-nsn.gov/
BLT Enterprises, Inc: The Campo Landfill will be the first landfill development project for this private company that runs recycling and trash transfer stations in Sacramento, Los Angeles and the Fremont area. See the BLT website at: http://blt-enterprises.com/home.html. Our research, conversations, and meetings with them have not raised our confidence levels regarding their ability to build a landfill, state-of-the-art or not, that will not eventually leak into and contaminate our federally designated Campo/Cottonwood Sole Source Aquifer and our wells that draw water from it. BLT has disregarded our warnings that the huge landfill poses an unacceptable threat to the area's groundwater and other resources. They have also disregarded our warnings that they will no doubt end up spending millions before they have to walk away with nothing, just as Mid-American Waste Systems and others have in the past. Mid-American spent over $36 million before they were defaulted on their contract by the tribe. We were honest with them. They should have listened.
Federal approval of new lease is required: The Bureau of Indian Affairs (BIA) and/or the Department of Interior will be required to approve the new landfill sub-lease. At this point, we believe that decision will be made at the regional office of the BIA. It is BAD's position that no lease should be approved for a landfill which poses such an unmitigable threat to our federally-designated sole source aquifer, especially when the waste will be imported from urban areas that rely on imported water sources, via trucks, which will increase traffic at I-8 and Crestwood Road and negatively impact air quality.
Federal Air Permit for Campo is no longer required: The United States Environmental Protection Agency, Region 9, renewed the previously required Air Permit for the Campo Landfill twice after initial approval in the mid 1990's. In the late 1990's the permit was transferred from Mid-American Waste Systems to the Campo tribe. BAD appealed the Air Permit approval with little success. It expired in July 2004. The last time we checked, the US Environmental Protection Agency had determined, with apparent help from BLT, the new landfill developer, that the air permit would no longer be required due to a reported change in air quality. Concerns were later relayed to us that the only change to air quality was the new and controversial way it was being measured - reportedly resulting in benefits to those being regulated.
Is there a need for the Campo Landfill? Where will the trash come from? The trash contracts that BLT, or other operator, will need to make this project economically feasible have not been disclosed and may not materialize. We believe that trash will not come from San Diego County or the City of San Diego. The city has its own disposal facility at the Miramar Landfill, which is currently undergoing an upward expansion. Allied Waste purchased the County-owned landfill system in 1997 and is in the process of a major expansion at Sycamore Landfill in Santee. The expanded landfill will reportedly be able to accommodate County-generated waste for 30 years.
The County, all the incorporated cities, and the state approved the County’s regional Integrated Waste Management Summary and Siting Element in 2005. The Campo Landfill was purposely excluded from those plans— after BAD and Supervisor Jacob objected to its unwarranted inclusion. The County can meet its 15-year disposal capacity that is required by the State, without the Campo Landfill. Other landfill projects are under review at Gregory Canyon in North County and a new site in Otay Mesa was announced in 2009. The Gregory Canyon Landfill is also the subject of intense opposition and litigation. Both the City and the County of Los Angeles have previously said they have no plans or agreements with BLT to dispose their waste at Campo. This leads to several big questions:
- What is the need for this landfill?
- Who will commit to send their trash here?
- Will the Campo Landfill import mostly sludge and special waste?
Alternatives to the Campo Landfill: Long-hauling waste from urban areas to be buried over our rural sole-source aquifer is an extremely bad idea and wastes a variety of non-renewable resources. The new awareness of greenhouse gas production and the need to change our ways to be more sustainable is refocusing attention on reduced packaging, reusable bags, and producing products that are more easily recycled and reused. The ideal situation would be achieving true and sustainable zero waste goals where all of society's cast-offs are transformed into reusable materials, compost, and/or non-polluting forms of energy. Composting reinvigorates depleted soils, reduces water requirements, and helps prevent erosion. Cities and counties are beginning to adopt zero waste goals and increase their recycling rates. The state of Florida recently adopted the 75% goal for recycling. Average citizens and businesses have learned that increased recycling can drastically reduce waste disposal costs and promotes a sense of doing good for the community and the environment in general. For Zero Waste information go to: http://www.zerowaste.ca.gov/ and http://www.grrn.org/zerowaste/zerowaste_faq.html
County staff has determined that even with a 75% recycling rate, no new landfills will be needed in San Diego County's foreseeable future. Legislation is in the works again this year to increase California's mandated recycling rate to 75%. Until then, existing recycling and composting facilities, and existing and expanded landfills throughout the County, can and should handle the waste generated in the region. There is no need to long haul it to our rural groundwater-dependent area for burial over our only water supply.
Waste can also be digested or ground and formed into pellets for use as biofuel. While some organizations oppose transforming waste into fuel, several projects have been announced over the last few years:
Bull Moose Energy's 20 MW contract with SDG&E for renewable biomass energy, funded with $60 million from Morgan Stanley. This project is reportedly still undergoing environmental review.
Envirepel is another company that reports to have 115 MW of renewable energy projects under construction or in various stages of development in San Diego County at business parks, rural agricultural areas and metropolitan landfill sites. Their systems reportedly convert solid fuels into useable thermal energy at 96% conversion efficiency from almost any biomass source including green waste, sludge, plastics, municipal solid waste, wood and other organics. See: http://www.envirepel.com/.
Enertech is recycling biosolids (sewage sludge) for five municipalities at the new Rialto Slurrycarb Facility, converting sludge into a renewable fuel solid that is an alternative to coal and other fossil fuels. At full capacity it will reportedly produce over 60,000 tons of E-Fuel per year. For more information go to: http://enertech.com/facilities/index.html.
These technologies most likely have a down side as well, especially if they do not or cannot properly control the toxic emissions and byproducts from their facilities. However, some of these processes appear to have the potential to reduce the need for new landfills while generating renewable energy near the urban use core where the majority of waste is produced and where the majority of energy is needed and consumed.