January 26, 2024
San Benito County Planning Commission
Via e-mail to:
CommissionerRingheden@cosb.us
CommissionerRWay@cosb.us
CommissionerRScagliotti@cosb.us
CommissionerRGibson@cosb.us
CommissionerToledo-Bocanegra@cosb.us
Re: 01/31/24 Agenda Item 6.1, John Smith Road Landfill Expansion GPA and CUP
Dear San Benito County Planning Commission,
The Sierra Club Loma Prieta Chapter advocates for sustainable land use in San Mateo, Santa Clara and San Benito Counties. Regarding the John Smith Road Landfill Expansion General Plan Amendment and Conditional Use Permit coming before the Planning Commission on January 31, 2024, the Sierra Club offers the following comments from an environmental perspective.
- We urge the Planning Commission to listen to the residents of San Benito County who will be subject to substantial impacts from the massive proposed landfill expansion. Most residents have clearly expressed opposition to this project. If the Planning Commission adopts a Use Permit, the Sierra Club recommends specifying maximum permitted daily tonnage of 300 tons per day (EIR Alternative 3) to align with the wishes of the community.
- Landfills are high-impact, high-risk land uses. Landfill operations can have unanticipated impacts on air quality, greenhouse gas emissions, wildlife habitat, transportation, water quality, and water supply. A larger landfill increases the risk and the potential impacts. To minimize risk, the Sierra Club recommends against adopting a Use Permit with maximum permitted daily tonnage above 1,000 tons per day (EIR Alternative 2B). Some specific considerations follow.
- The Environmental Impact Report does attempt to mitigate impacts to meet certain “thresholds of significance,” but the California Environmental Quality Act does not fully address impacts, and does not address future risks such as operational errors, climate change and natural disasters. Adopting a Use Permit with lower tons per day is the conservative, prudent decision to reduce environmental risks.
- The potential impact to water supply is perhaps the biggest risk associated with the proposed 388-acre landfill expansion. The more trash received per day and the larger the landfill footprint, the greater the water usage. With climate change, water supply will be less reliable. Giving so much water to one use could impact future growth and economic development. Adopting a Use Permit with lower tons per day is the conservative, prudent decision for sustainable water supply.
- Fifteen years is a long time to wait for a clean closing of the Class I facility and there is no real guarantee it will happen. The City and County should work together to find another way to clean close the Class I area sooner rather than later.
- To ensure strong mitigation monitoring, the Sierra Club recommends periodic third-party independent compliance review/audit of the Mitigation Monitoring and Reporting Program, at minimum every five years.
- The Sierra Club recommends adding a condition of approval to design lighting to use shielding, lower wavelength lighting, motion detection lighting, etc. to minimize light pollution and trespass to the night sky.
Thank you for considering these comments.
Sincerely,
Katja Irvin, AICP
Guadalupe Group Conservation Chair
Sierra Club Loma Prieta Chapter