47. RESPONSES TO COMMENTS FROM ALICIA HERNANDEZ, DATED MAY 9, 2011.

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2 Waste Management Material Recovery Facility Transfer Station and Household Hazardous Waste Facility Environmental Impact Report 47. RESPONSES TO COMMENTS FROM ALICIA HERNANDEZ, DATED MAY 9, This comment is acknowledged. The commenter does not raise new environmental information or directly challenge information provided in the Draft EIR. The City of Azusa decision makers will consider all comments on the proposed project. No further response is necessary. Final June Response to Comments

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30 Waste Management Material Recovery Facility Transfer Station and Household Hazardous Waste Facility Environmental Impact Report 48. RESPONSES TO COMMENTS FROM CHRIS BRUNY, DATED MAY 9, This comment is acknowledged. As discussed in the Draft EIR, implementation of the proposed project would result in less than significant noise and hazardous materials related impacts upon implementation of recommended Mitigation Measures. Significant and unavoidable impacts pertaining to air quality emissions (specifically NO X emissions) and traffic would result. Refer to Response 5-3 regarding significant and unavoidable traffic impacts. If the City of Azusa approves the project, the City shall be required to make findings in accordance with CEQA Guidelines Section and adopt a Statement of Overriding Considerations in accordance with CEQA Guidelines Section The City of Azusa decision makers will consider all comments on the proposed project Throughout the Draft EIR, sources are cited where information was obtained. Further, sources are cited in Section 12.0, Bibliography. As discussed on page 5.7-2, Water Demand and Existing Facilities, existing water supply information was obtained from the 2005 Water Master Plan Update (dated December 2005), as well as written correspondence from Chet Anderson of the Azusa Light & Water Department (conducted on September 28, 201), the City of Azusa General Plan EIR (dated 2004) and follow up correspondence from the City of Azusa Water Department, conducted on November 30, 2010, and the Azusa General Plan Update Analysis of Existing Conditions and Trends Document (dated December 2001). Further, per Section of the CEQA Guidelines, the discussion of cumulative impacts shall reflect the severity of the impacts and their likelihood of occurrence, but the discussion need not provide as great detail as is provided for the effects attributable to the project alone. The discussion should be guided by standards of practicality and reasonableness, and should focus on the cumulative impact to which the identified other projects contribute rather than the attributes of other projects which do not contribute to the cumulative impact. Per the cumulative water demand analysis, provided on page of the Draft EIR, the main source of water for the region is the Main Basin. SGVMWD has indicated that the Main Basin is expected to have adequate water supply through The City of Azusa General Plan EIR considered water demand impacts for the City through 2025, these considerations included anticipated growth and other limiting factors that would effect water supply to the City. The Azusa General Plan notes that the City has an adequate water supply to serve anticipated growth until Future projects would be required to be evaluated by the responsible agency to determine the extent of impacts on existing water facilities in the region. Additionally, developers may also be required to contribute fees based on the project s proportional demand for new resources. Therefore, overall cumulative impacts to water facilities would be less than significant Per Section of the CEQA Guidelines, the information contained in an EIR shall include summarized technical data sufficient to permit full assessment of significant environmental impacts by reviewing agencies and members of the public. Placement of highly technical and specialized analysis and data in the body of an EIR should be avoided through inclusion of supporting information and analyses as appendices to the main body of the EIR. Appendices to the EIR may be prepared in volumes separate from the basic EIR document, but shall be readily available for public examination and shall be submitted to all clearinghouses which assist in public review. Final June Response to Comments

31 Waste Management Material Recovery Facility Transfer Station and Household Hazardous Waste Facility Environmental Impact Report 48-4 Refer to Response 5-7 regarding environmental justice. Further, specific project impacts to the public using the day laborer site have been included within each applicable topic area of the Draft EIR The Commentor suggests that all of the proposed project features are not illustrator on one exhibit. CEQA Guidelines Section only requires that a map detailing the precise location and boundaries of the project as well as a regional map be provided. Exhibit 3-1, Regional Vicinity, of the Draft EIR illustrates the regional location of the project site and Exhibit 3-2, Site Vicinity, of the Draft EIR outlines the exact project site boundaries. Exhibits 3-3 through 3-5, depict the different portions of the proposed project, including the MRF/TS, entrance, scale area, household hazardous waste facility, and proposed parking area (which also depicts the relocated day laborer site. These site plans depict the proposed project features. Due to the scale of the project, the site plans are provided on multiple exhibits in order to improve legibility. The full scale drawings can be reviewed at the City of Azusa Economic and Community Development Department public counter Refer to Response Although Section 3.0, Project Description, notes that the MRF/TS would operate seven days per week, operational truck activity (collection trucks) would occur five days per week. The analysis includes emissions associated with seven days per week operations of the project site. Operational GHG emissions are not understated. Refer to Response The traffic impact analysis considers the worst case scenario of traffic on the roads in order to determine if the existing infrastructure can support that load, and if not, what improvements would need to be made in order to minimize these impacts. The weekend traffic with implementation of the proposed project would not exceed the projected a.m. and p.m. peak hour weekday trips. Thus, implementation of recommended Mitigation Measures for the analyzed a.m. and p.m. weekday trips would also mitigate any additional project related traffic on the weekends. It should be noted that the HHWF is no longer part of the project approvals Refer to Response Project implementation would not result in the modification to the function of the day laborer site. Specific project impacts to the public using the day laborer site have been included within each applicable topic area of the Draft EIR The day laborer site would be relocated prior to construction of the project. Further, the new day laborer site would be constructed prior to demolition of the existing day laborer site Refer to Response 5-39 regarding the proposed relocation of the day laborer s site. There are no required City of Irwindale easements as part of the proposed project. Refer to Response 5-39 regarding traffic hazards associated with the day laborer site Refer to Response Refer to Responses 5-19 and Landscaping and aesthetics are an inherently subjective topic; however, it can generally be said that the Applicant has proposed a quality design that would not result in an adverse impact to aesthetics, especially given the industrial nature of Final June Response to Comments

32 Waste Management Material Recovery Facility Transfer Station and Household Hazardous Waste Facility Environmental Impact Report the surrounding area. Further information on the landscaping and design of the building can be obtained by viewing the project application at City Hall Refer to Response The Draft EIR includes an analysis of the agreements and project components contained within the Development Agreement At most, the HHWF would operate on the weekend. However, one Sunday a month is anticipated. However, at this time the HHWF is no longer part of the proposed application, and is not anticipated to be constructed as part of the MRF As depicted on Exhibit 3-3, Material Recovery Facility/Transfer Station, of the Draft EIR, the proposed maintenance shop would be located within the eastern portion of the proposed MRF/TS and maintenance equipment associated with the proposed MRF, excluding heavy equipment) would be stored in this room Refer to Responses 5-5 and As discussed on page , 2 nd paragraph, the project site is located in the South Portion of the West End Industrial District (District); refer to Azusa General Plan Figure CD-2, Urban Form Diagram. The project proposes an industrial development (i.e., MRF/TS and HHWF) that involves state-of-the-art recycling facilities. Project implementation would further the City s objective to provide industrial high-tech opportunities for companies within the District. The project proposes a MRF/TS and HHWF in the West End Industrial District and would supply jobs to approximately 75 persons (69 jobs for the MRF/TS and 6 jobs for the HHWF). Therefore, project implementation would further the City s vision for the District to attract new firms that supply jobs. CEQA requires analysis to compare the existing baseline conditions to the proposed project, rather than to what is allowed at the project site. Implementation of the proposed project would create more jobs that what is currently at the project site. Refer to Response 5-1 regarding traffic related impacts The Staff Report and Resolution will include findings discussing that the Variance is permitted per the Azusa Municipal Code The Transfer Station is a function of the Recycling Facility, which is allowed under the definition of a Processing Facility per the Azusa Municipal Code The Irwindale MRF was considered within the cumulative impact analyses per each topic area. With regard to traffic calculations, it appears that the trip generation presented in the Irwindale MRF EIR underestimated the number of trips by using a Light Industrial trip generation rate. The traffic analysis contained in the Draft EIR utilized a more conservative trip generation estimate to more accurately reflect any potential impacts This text has been updated accordingly in the Errata. Final June Response to Comments

33 Waste Management Material Recovery Facility Transfer Station and Household Hazardous Waste Facility Environmental Impact Report The proposed trucks would follow the City of Azusa s and City of Irwindale s approved truck haul routes. Further, the majority of trucks would not travel in the vicinity of sensitive viewers. Thus, the actual number of increased trucks, as perceived from sensitive viewers would not be considered significant compared to the existing conditions This sentence has been revised in the Errata as follows: The scoping document acknowledged that the courses of action for incorporating impact standards of the City of Irwindale (for those study intersections partially or fully maintained by that City). Page goes on to provide the City of Irwindale s impact standards Refer to Response The trip generation rates for the project were conservatively derived; therefore, precluding the need to include a 10 percent buffer. This footnote has been removed per the Errata Refer to Response Refer to Response Refer to Response Refer to Response The transfer trucks would not travel south or west of the Irwindale Avenue/Arrow Highway intersection. Rather the transfer trucks would travel north along Irwindale Avenue to access I-210. Only a nominal amount of employee vehicles and route trucks would travel through the intersection of Irwindale Avenue/Arrow Highway. Only a maximum of nine percent of route trucks (or 23 trucks) and 15 percent of employee trips (or 6 employees) would be accessing these areas (to the west and south of the intersection of Irwindale Avenue/Arrow Highway). Based on the thresholds used as part of this analysis, an intersection is considered if the project contributes 50 trips or more to the location. Thus, other intersections located further west and south of the intersection of Irwindale Avenue/Arrow Highway are not required Refer to Response Refer to Response Refer to Response Refer to Response Refer to Response The recommended Mitigation Measures are feasible and would reduce the project s traffic impacts. However, it is noted that Mitigation Measures TRA-1 and TRA-3 would require approval by the City of Irwindale. Further, the Draft EIR considers potential secondary impacts associated with construction of these traffic improvements, which have been Final June Response to Comments

34 Waste Management Material Recovery Facility Transfer Station and Household Hazardous Waste Facility Environmental Impact Report determined to result in less than significant secondary impacts. A precise engineering of the traffic improvements is not necessary, nor required under CEQA, in order to support the finding of the post-mitigation level of an impact s significance Specific land acquisition requirements for implementation of recommended traffic mitigation measures would be determined during the permitting phase of each improvement. These land acquisition requirements would be minor slivers of land along the roadways and would not result in any impacts to the structures located at these properties or the function of each property Roadway design associated with implementation of Mitigation Measures TRA-1 and TRA-3 would be consistent with city design standards and requirements. Therefore, a safety hazard would not result with implementation of the recommended traffic mitigation Refer to Responses and Refer to Responses and Further, per the City of Azusa s parking requirements per the Azusa Municipal Code, the existing businesses maintain their own parking needs on each respective private property. The parking being removed along Vincent Avenue would only be 18 public parking spaces. As no public land uses are located within the vicinity of these removed spaces, impacts in this regard would be less than significant Although page 58 of the Traffic Impact Study states that the improvement could likely be implemented, the text was clarified in the Draft EIR to say that This Mitigation Measure would be implemented without widening or major construction work within the intersection, based upon a further review of the intersection geometry Refer to Response Refer to Response Refer to Response Refer to Response Locations that may contain a high concentration of these sensitive population groups are called sensitive receptors and include residential areas, hospitals, day-care facilities, elder-care facilities, elementary schools, and parks. Sensitive receptor locations are defined as locations with sensitive populations (children under 14, elderly over 65, and people with cardiovascular and chronic respiratory diseases) and places where other people can be located for a 24 hour period. Other land uses such as industrial, commercial, or retail are not considered sensitive. As a result, the project would not impact any day laborers in proximity to the site Mitigation Measure AQ-2 is provided to ensure compliance with SCAQMD rules and regulations, including Rule 403. Table 1 of SCAQMD Rule 403 provides Best Available Control Measures (BACM) for high wind conditions (exceeding 25 miles per hour) during construction and earthwork activities. These measures include requirements for watering, trackout controls, temporary coverings, and chemical stabilizers to stabilize disturbed Final June Response to Comments

35 Waste Management Material Recovery Facility Transfer Station and Household Hazardous Waste Facility Environmental Impact Report surfaces so dust may not exceed 20 percent opacity beyond the property line. Therefore, implementation of Mitigation Measure AQ-2 would ensure that fugitive dust emissions would not exceed SCAQMD thresholds, and impacts to nearby populations would be less than significant. Impacts from asbestos are addressed in Section 5.9, Hazards and Hazardous Materials of the Draft EIR. Section 5.9 includes Mitigation Measure HAZ-1, which requires compliance with the National Emission Standards for Hazardous Air Pollutants (NESHAP). NESHAP requires building owners to conduct an asbestos survey to determine the presence of asbestos containing materials prior to the commencement of any remedial work, including demolition. Therefore, the additional mitigation suggested in the comment is not required. Also, refer to Response regarding day laborers Refer to Response 48-48, above. Mitigation Measure AQ-2 provides numerous dust control measures and also requires compliance with SCAQMD Rule 403. As described in Response 48-48, Rule 403 requires implementation of control measures to prevent, reduce, or mitigate fugitive dust emissions and includes a performance standard that prohibits visible emissions from crossing any property line Refer to Response and above. Compliance with SCAQMD Rule 403 is already required by Mitigation Measure AQ-2, which shall be monitored by onsite staff and enforced. As stated above, Rule 403 prohibits dust exceeding 20 percent opacity beyond the property line Waste Management is the most appropriate source for the percentage of alternatively fueled vehicles in its fleet as this type of information would be considered proprietary. Independent verification is not required As noted in Response 48-51, Waste Management is the most appropriate source to provide the percentage of its collection that use alternative fuels. The commenter does not suggest an alternate method of collecting this information that would more accurate or that could verify this information. In January 2009, the SCAQMD conducted a survey of public and private waste haulers for the development of amendments to SCAQMD Rule 1193 (SCAQMD, Final Staff Report, Proposed Amended Rule 1193 Clean On-Road Residential and Commercial Refuse Collection Vehicles, July 2010). This survey showed that 67 percent of all municipal waste collection trucks were diesel fueled and the remaining 33 percent were alternatively fueled (CNG, LNG and Dual Fuel). While this would indicate that there are possibly fewer alternatively fueled vehicles than assumed for the analysis, it turns out that assuming more alternatively fueled third party collection trucks for both the project and no project cases results in a slightly greater net increase in emissions for each criteria pollutant due to the project. In other words, the percentages of alternatively fueled used in the assessment is a more worst-case assessment than if the SCAQMD suggested percentages were used. This is because the project results in a reduction in VMT from third party collection trucks, as shown in Table of the Draft EIR. This results in a reduction in the net emissions from third party collection trucks independent of the assumption of the percentage of alternatively fueled trucks. When one assumes that more of these trucks are more polluting diesel trucks, the total emissions under Final June Response to Comments

36 Waste Management Material Recovery Facility Transfer Station and Household Hazardous Waste Facility Environmental Impact Report the no project and with project scenarios both increase but the no project emissions increase more than the with a higher percentage of diesel trucks. The project s impact is measured based on the net change in emissions and the net change in emissions from third party trucks is reduced. The opposite occurs when one assumes that more these trucks are alternatively fueled and emit fewer pollutants. In summary, the emissions for both the project and no project cases are lower with a higher percentage of alternatively fueled trucks. The emissions from third party collection trucks with more alternatively fueled trucks go down more for the no project case than for the proposed project. The result is that the net change in emissions is higher when a higher percentage of alternatively fueled trucks is assumed. Also note that the SCAQMD survey was taken approximately two years ago, three years before the project opening, and five years before the first year of full operation. It is likely that the percentage of alternatively fueled vehicles has increased since the time of the SCAQMD survey. Therefore, the results of the analysis and the basis for the significance determination, the net increase in emissions, is minimally affected by the assumption of percentage of third party collection trucks that are alternatively fueled and the specific assumption would not affect the significance findings For purposes of the analysis, pilot ignition vehicles were assumed to be consistent with the definition from SCAQMD Rule 1193 reproduced below. PILOT IGNITION HEAVY-DUTY VEHICLE means a heavy-duty vehicle equipped with an engine designed to operate using an alternative fuel as defined in paragraph (c)(1), except that diesel fuel is used for pilot ignition at an average ratio of no more than one part diesel fuel to ten parts total fuel on an energy equivalent basis. The engine shall not operate or idle solely on diesel fuel at any time. (Rule 1193(c)(10).) Furthermore, Rule 1193(c)(1) states: ALTERNATIVE-FUEL HEAVY-DUTY VEHICLE means a heavy-duty vehicle or engine that uses compressed or liquefied natural gas, liquefied petroleum gas, methanol, electricity, fuel cells, or other advanced technologies that do not rely on diesel fuel As discussed on page 37 of Appendix 15.4, Air Quality Assessment,, EPA s SCREEN3 model was used to estimate particulate concentrations in the vicinity of the project during construction. The SCREEN3 model predicts that the maximum one-hour particulate concentrations would occur 735 feet from the edge of the facility. This distance represents the maximum exposed worker receptor, including day laborers, as concentrations nearer to the facility would be expected to be lower based on the SCREEN3 modeling. The concentrations, cancer risk, and hazard index presented in Table of the Draft EIR represent the upper limits due to the worst-case estimates of diesel particulate matter emissions and dispersion (refer to page of the Draft EIR). Note that SCREEN3 is a screening level model and provides conservative estimates of pollutant concentrations. Predicted concentrations along with cancer risks and hazard indices would be lower if a more detailed model was used for the analysis. Final June Response to Comments

37 Waste Management Material Recovery Facility Transfer Station and Household Hazardous Waste Facility Environmental Impact Report The correct values are presented in Table (refer to page of the Draft EIR) and Tables 11 and 12 of Appendix 15.4 and these values were used to calculate the truck emissions. The VMT values shown for the transfer trucks in Table A-1 of Appendix 15.4 are not correct. For without project conditions 20 municipal solid waste trips at 25.6 miles/trip = 522 miles and 5 recyclable 56.9 miles/trip = 309 miles which sum to a total of 831 miles. For the with project conditions 99 municipal solid waste trips at 100 miles per trip = 9,878 miles, 35 recyclable 77.9 miles per trip = 2,712 miles, and 8 green waste trips at miles per trip = 1,369 miles for a total of 13,959 miles. No new impacts or significant effects would result Refer to Response The HHWF would operate one weekend per month and would generate a nominal amount of emissions. Further, per discussions at the public hearing, conducted on March 30, 2011, the HHWF is no longer part of the project application currently before the City Refer to Response Refer to Response An analysis of potential health risks from exposure to vehicle emissions to HHWF works during operation of the project is not warranted due to low level of emissions from alternatively fueled vehicles. Approximately 45 percent of the trucks visiting the site will be alternatively fueled on opening day and SCAQMD Rule 1193 effectively requires that almost all waste collection and transfer trucks to be alternatively fueled by 2020 (cancer risks are measured over a 70 year exposure) The Draft EIR properly identified the closest sensitive receptors to the project site based on SCAQMD criteria and guidance. Additionally, the site plans provided in the Draft EIR are reduced from their original size and not to scale (as noted on the Draft EIR exhibits). The full scale drawings are available for review at the City of Azusa Economic and Community Development Department public counter Refer to Response The day laborer waiting area is not considered a sensitive land use. Additionally, the proposed project has been designed to include longer drive aisles to reduce vehicle queuing and prevent odors from traveling beyond the site boundaries. Additionally, solid waste collection trucks are typically sealed to prevent odors; refer to Response The proposed project would include an Odor Management Plan (OMP) and numerous odor reduction project design features Refer to Response The project includes an OMP in compliance with SCAQMD Rule 410. Odor impacts would be less than significant Carbon monoxide (CO) hotspots occur at intersections with high traffic volumes where queuing occurs for long periods of time. Traffic volumes at the project intersections with the worst Level of Service (LOS) would not have traffic volumes that exceed the traffic volumes of the four worst-case intersections in the South Coast Air Basin either on a per lane basis or total traffic. Further, these intersections do not have any characteristics that would result in higher CO concentrations than the worst-case intersections. Therefore, an exceedance of Final June Response to Comments

38 Waste Management Material Recovery Facility Transfer Station and Household Hazardous Waste Facility Environmental Impact Report the CO air quality standard would not occur at any of these intersections and impacts would be less than significant Refer to Response As indicated above, the CO hotspot analysis in the Draft EIR indicated that the project study intersections would have traffic volumes lower than levels would have the potential to create an impact. Therefore, even when considering that heavy trucks produce more CO emissions than cars when idling or moving at 5 miles per hour, CO emissions would not have the potential to exceed the ambient air quality standards based on the project traffic volumes at the study intersections. Additionally, it should be noted that the project would be subject to SCAQMD Rule 1193, which requires alternatively fueled transfer trucks, thereby reducing operational emissions As discussed in the Draft EIR, guidance for qualitative particulate hot-spots from the Federal Highways Administration (FHWA) states that roads with an average daily truck volume of 10,000 or less does not have the potential to result in a hot-spot 3 ( refer to page of the Draft EIR). This screening level volume accounts for potentially maximally impacted receptors located adjacent to the roadway. In 2035, approximately 1,600 trucks (700 project, and 900 non project) are anticipated on Irwindale Boulevard between Gladstone Street and I-210 in 2035). (Draft EIR, page ) This is less than one-fifth of the minimum number of trucks that could be expected to result in a particulate hot-spot based on FHWA guidance. While the comment is correct that there will be a larger percentage increase of trucks along Irwindale Avenue than along I-210, the percentage increase in trucks is only a part of the significance determination. For a hotspot to occur, the project must cause or contribute to a new exceedance of the particulate ambient air quality standard or increase the frequency or severity of any existing exceedance particulate ambient air quality standard. Based on FHWA guidance, it is highly unlikely that there will be an exceedance of the particulate ambient air quality standard along Irwindale Avenue Refer to Response Refer to Response Mitigation Measure AQ-3 has been revised in the Errata so that alternative fuels would need to be consistent with SCAQMD Rule Refer to Response The emissions inventories conservatively assume that third party vehicles would not utilize alternative fueled vehicles. The percentage of trucks using alternative fuels was only applied to Waste Management Trucks. Therefore, revisions to the Draft EIR are not necessary Refer to Response The GHG emissions inventory prepared for the project accurately depicts the emissions of the project. No corrections are required for the percentage of alternatively fueled trucks or the HHWF. 3 United States Environmental Protection Agency & Federal Highway Administration, Transportation Conformity Guidance for Qualitative Hot-spot Analyses in PM2.5 and PM10 Nonattainment and Maintenance Areas EPA420-B , March Final June Response to Comments

39 Waste Management Material Recovery Facility Transfer Station and Household Hazardous Waste Facility Environmental Impact Report The GHG analysis within Section 5.5 of the Draft EIR determined that GHG emissions from the project would be less than significant. Therefore, mitigation measures are not required. The analysis identified various project design features that the Applicant is proposing to incorporate into the project. The project design features are voluntarily proposed by the Applicant and are not required to reduce impacts to a less than significant level. Therefore, it is not necessary to make the language enforceable Refer to Response The comment refers to a project design feature proposed by the applicant. Project impacts would be less than significant. This project design feature is not required to reduce project impacts to a less than significant level Refer to Responses and Refer to Responses and Refer to Responses and Refer to Responses and Truck trips from solid waste collection and transfer trucks would occur regardless of whether the project is implemented or not. Solid waste would still be required to be collected and transported to a facility. The analysis provides a conservative review of the operational emissions for the proposed project. With the project, materials that would be delivered to landfills or other transfer/recovery facilities would be re-directed to the project. The project would not create any new collection truck trips but would change the distances that the collection trucks would travel. Additionally, CEQA Guidelines Section 15125(a) indicates that projects at buildout should be compared to the baseline existing conditions at the time the NOP was issued. The impact of the project is measured relative to the change in pollutant emissions compared to the no project conditions As described in Section 5.5, off-site GHG reduction was considered, but found to be infeasible. For any off-site GHG reduction measures to be considered mitigation for the purposes of a CEQA document they must be fully enforceable through permit conditions, agreements, or other legally binding instrument. While the project Applicant has undertaken projects that result in the reduction of GHG emissions, none of these projects satisfy the criteria to allow them to be considered a GHG reduction for this project. Additionally, GHG impacts relative to the proposed project would be considered less than significant. Therefore, additional off-site mitigation for cumulative impacts wound not be required Refer to Responses 48-6 and The travel lengths assumed for each type of truck trips used to calculate GHG emissions are the same as those provided in Air Quality Appendix 15.4 used to calculate the air emissions inventories. Inclusion of VMTs for trips outside the South Coast Air Basin and outside the State is not necessary as they are not new trips. Such trips would occur regardless of project implementation. Final June Response to Comments

40 Waste Management Material Recovery Facility Transfer Station and Household Hazardous Waste Facility Environmental Impact Report Refer to Responses Traffic impacts have been properly analyzed within the Draft EIR. Therefore, the Draft EIR is not required to be revised Refer to Response Noise measurements were taken near sensitive land uses in the project area. The day laborer facility is not considered a sensitive land use. Therefore, noise measurements at this location are not required Refer to Response The statement in the Appendix 15.6 and Section 5.6 of the Draft EIR are accurate. The day laborer facility is not considered a sensitive land use Refer to Response Refer to Response The day laborer facility is not considered a sensitive land use. Additionally, as indicated in Section 5.6 of the Draft EIR, ground-borne vibration would be generated primarily during site clearing and grading activities on-site and by off-site haultruck travel. Vibration levels from construction equipment would be as high as inchper-second PPV at a distance of 25 feet, which is less than the 0.2 inch-per-second PPV significance threshold Section 5.6 of the Draft EIR analyzed project construction impacts in accordance with noise limits defined in the City of Azusa Noise Ordinance (which is more stringent than the City of Irwindale). Additionally, the impact analysis identified measures that would ensure construction related noise impacts remain less than significant to the nearest residential area This potential impact has been mitigated to a less than significant level with implementation of Mitigation Measure N-2. This Mitigation Measure is not a deferral, as it sets a performance standard for the interior noise levels of the MRF/TS offices to be at or below 45 dba CNEL Refer to Response Transients refers to the general public accessing the project site at any given time. As described on Table 5.7-1, Estimated Water Demand, evaporative cooling, dust-control measures, and landscaping requirements were considered as part of the projects estimated water demand It is noted that the estimated water demand in Table 5.7-1, Estimated Water Demand, does not account for project compliance with Title 24 and Title 20 of the California Administrative Code, which relates to water conservation. Projected water demand also does not include suggested conservation measures specifically outlined by Azusa Light & Water. Therefore, Table presents a worst case scenario of anticipated water demand, and actual water demand may be reduced. It is noted that the Draft EIR omitted the calculations for the project s weekend water demand. Table and the associated analysis have been updated in the Errata to reflect the project s weekend operations, which has resulted in a nominal change in the project s resultant water demand from acre-feet/year to acrefeet/year (or from 12,157 gallons per day to 39,645 gallons per day). The project would still be able to be served by Azusa Light & Water and no new water facilities would be required. As discussed in the Draft EIR, the Applicant would still be required to contribute fees based on the project s proportional demand for new resources, to be calculated by the directory of utilities, per Municipal Code Chapter 78, Utilities, Article VI, Water, Division 5, System Final June Response to Comments

41 Waste Management Material Recovery Facility Transfer Station and Household Hazardous Waste Facility Environmental Impact Report Development Fee. As stated in the Draft EIR, with payment of such fees, operation of the project would result in a less than significant impact of water supply. This clarification to the Draft EIR does not constitute significant new information pursuant to Section of the CEQA Guidelines Pages and state the following: ALW has implemented a number of water conservation measures. These measures include a Drought Resistant Landscape Rebate Program (DRiP), as well as an informational water conservation website encouraging City residents to implement Smart Controllers to reduce over watering. The ALW website also lists other conservation tips such as checking for toilet, pipe, and faucet leaks, turning off water when not in use, water lawns in early morning or late afternoon hours, plant drought resistant plants, use a timer to turn off sprinklers, etc. Project impacts pertaining to water supply would be less than significant. As stated in Table 5.5-8, Project Consistency with GHG Emissions Reductions Strategies, page , if available, recycled water would be used for landscape irrigation. Utilization of recycled water by the project would only further reduce these impacts The estimated water demand is depicted in the Draft EIR has been updated in the Errata per Response These estimated wastewater flows have been overestimated, as they do not reflect water conservation measures. Overall wastewater generation would be approximately 90 percent of the total water demand. This would be 35,681 gallons/day (39,645 [water use in gallons per day] x 0.90), rather than the 43,200 gallons/day noted in the Draft EIR. This has been corrected in the Errata. It should be noted that this clarification to the Draft EIR does not constitute significant new information pursuant to Section of the CEQA Guidelines Refer to Response Implementation of the required the County Fire Code would ensure that the project include fire extinguishers, as well as other fire emergency measures. Implementation of the County Fire Code would reduce potential impacts to less than significant levels in this regard and no additional Mitigation Measures are required Refer to Response As indicated in the Appendix 15.7, Utility Correspondence, there is adequate water supply for the project. Based on correspondence from the ALW the project does not require SB 610 and SB 221 compliance. Additionally, per ALW, no new water facilities or additions to existing infrastructure are required. Further, the proposed project would be consistent with the recently adopted Urban Water Management Plan 2010 (July 2011) Refer to Response As discussed on page , 1 st paragraph, cumulative projects proposed within the City would increase demand on existing wastewater facilities. The Azusa Sewer Master Plan maps the City and Los Angeles County Sanitation District (LACSD) sewer pipelines within the City boundaries. Wastewater is conveyed and treated at the San Jose Creek Water Reclamation Plant and the Joint Water Pollution Control Plant, which process capacities of 100 and 350 mgd, respectively. Currently, the San Jose Creek Water Final June Response to Comments

42 Waste Management Material Recovery Facility Transfer Station and Household Hazardous Waste Facility Environmental Impact Report Reclamation Plant processes an effluent flow of 87.5 mgd and the Joint Water Pollution Control Plant treated an effluent flow of 284 mgd. The existing wastewater treatment plant capacity is designed to accommodate the average and peak amounts of wastewater generated in the community through the year Cumulative project s compliance with Azusa Public Works regulations and the City s Municipal Code would ensure the project would have less than significant impacts on the existing sewer system. Developers may also be required to contribute fees, on a project-by-project basis, for demand of new resources. Therefore, overall cumulative project impacts to wastewater facilities would be less than significant Mitigation Measures HAZ-1 and HAZ-2 are not deferring mitigation associated with potential asbestos and lead, as these Mitigation Measures include performance standards and remediation associated with these materials is required by State law. Standard practice during construction includes ensuring construction workers safety is not compromised. Mitigation Measures HAZ-5 also addresses construction worker safety. Additionally, demolition and grading activities are precluded during periods of high winds, pursuant to SCAQMD Rule Mitigation Measures HAZ-1 through HAZ-6 include performance standards to ensure that potential impacts are reduced to less than significant levels Refer to Responses 5-16 and The areas of the project site that would be excavated near the landfill are the queuing area of the site along Gladstone Street and the bale storage area. These areas would not contain habitable structures and would not expose day laborers to methane hazards. Further, the existing landfill contains an extraction system to prevent methane from migrating out of the landfill. A network of sensors monitors the performance of this system Refer to Responses 5-16, 5-18, and There would be no health risk impacts to workers in the vicinity or potential for explosions. Vapor intrusion typically affects ground floor levels from soils directly underlying the structure. Additionally, implementation of Mitigation Measure HAZ-6 would require proper ventilation which would reduce any potential vapor intrusion impacts to less than significant levels Refer to Response The existing day labor site adjoins Gladstone Street. Relocation of day labor site would result in further setbacks from Gladstone which would reduce existing safety hazards. Additionally, existing emergency response would remain which would ensure impacts would be less than significant Every future project (cumulative projects) would be subject to State and Federal regulations, which would ensure potential impacts are reduced to less than significant levels. Refer to Response Refer to Response Refer to Response Final June Response to Comments

43 Waste Management Material Recovery Facility Transfer Station and Household Hazardous Waste Facility Environmental Impact Report Refer to Response The day laborer site would not underlie the historic landfill area. Thus, the relocated shelter is not subject to impacts from the off-site historic landfill Truck traffic would be increased at the project site. However, the overall traffic in the region would remain the same, as these trucks would just be diverted from landfills to the proposed MRF. Height increases would result due to the type of use proposed, not as a result of increased persons per square foot at the project site. Further, the project would only temporarily store materials outdoors (up to 48 hours) and this would not contribute to growth-inducing impacts. The proposed project would not include greater site coverage, compared to what is currently allowed at the site. The proposed project would not result in significant and unavoidable impacts to greenhouse gas emissions and noise. Refer to Response 5-3 regarding traffic related impacts. Refer to Response 43-1 for a discussion of air quality related impacts. Refer to Response regarding the City s policy on encouraging high-quality business activity Per CEQA Guidelines Section , because an EIR must identify ways to mitigate or avoid the significant effects that a project may have on the environment (Public Resources Code Section ), the discussion of alternatives shall focus on alternatives to the project or its location which are capable of avoiding or substantially lessening any significant effects of the project, even if these alternatives would impede to some degree the attainment of the project objectives, or would be more costly. The relocated day laborer site would not result in any significant and unavoidable impacts. Nor would this relocation result in any Mitigation Measures. The intent of the alternatives analysis is to lessen significant and unavoidable impacts. Thus, the day laborer site would not add any information to this analysis that which would change the findings of the environmentally superior alternative as presented in the Draft EIR Per CEQA Guidelines Section , an EIR shall describe a range of reasonable alternatives to the project, or to the location of the project, which would feasibly attain most of the basic objectives of the project but would avoid or substantially lessen any of the significant effects of the project, and evaluate the comparative merits of the alternatives. An EIR is not required to consider alternatives which are infeasible. The intent of the alternatives analysis is to consider feasible alternatives to the proposed project that would reduce significant and unavoidable impacts. The figures in the Reduced Tonnage Alternative allow the Reduced Tonnage Alternative to remain a feasible build option, while attempting to indirectly reduce traffic related and air quality related environmental impacts The Irwindale MRF is not constructed and the environmental analysis must consider impacts at baseline conditions (conditions at the time of the NOP). Thus, it is likely that the waste would continue to go to another landfill, or to another MRF (currently operating) at a greater distance. Final June Response to Comments

44 Waste Management Material Recovery Facility Transfer Station and Household Hazardous Waste Facility Environmental Impact Report A reduced operations at the project would not necessarily require a reduction in building footprint. Further, a reduced building footprint under this alternative would not avoid or substantially lessen the significant and unavoidable impacts of the project, because this would result in nominally fewer construction impacts The reduction would only result in the reduction of loader operators (i.e., resulting in only a reduction of two employees) Refer to Response Page 7-31, 1 st paragraph, 4 th sentence, states that the approximately 22-acre Alternative site is located at 1001 North Todd Avenue (APN ), northwest of the intersection of West 10th Street and North Todd Avenue. Per CEQA Guidelines Section , the EIR shall include sufficient information about each alternative to allow meaningful evaluation, analysis, and comparison with the proposed project. A matrix displaying the major characteristics and significant environmental effects of each alternative may be used to summarize the comparison. The Draft EIR includes a comparative matrix for each alternative analyzed, including Table 7-4, Comparison of Proposed Project and Alternative Site Alternative, on page Based on the location of the alternative site, proposed building heights, and proximity to the San Gabriel River Bike Trail, it is anticipated that public views to the alternative site would be altered. As stated on page 7-33 of the draft EIR, the existing views of the San Gabriel Mountains experienced from recreational users along the San Gabriel River Bike Trail as well as motorists using the northbound travel lane of North Todd Avenue would be altered with implementation of this Alternative. Views from recreational users at the Azusa Greens Public Golf Course are not affected as a result of existing mature vegetation along the perimeter of the golf course. The proposed MRF/TS at the alternative site would be required to undergo the City s design review process, similar to the proposed project. The Alternative Site Alternative would be neither environmentally superior nor inferior to the proposed project regarding aesthetics/light and glare impacts Refer to Response Refer to Response Per the CEQA Guidelines Section , an EIR shall describe a range of reasonable alternatives to the project, or to the location of the project, which would feasibly attain most of the basic objectives of the project but would avoid or substantially lessen any of the significant effects of the project, and evaluate the comparative merits of the alternatives. An EIR need not consider every conceivable alternative to a project. Rather it must consider a reasonable range of potentially feasible alternatives that will foster informed decision making and public participation. An EIR is not required to consider alternatives which are infeasible. The lead agency is responsible for selecting a range of project alternatives for examination and must publicly disclose its reasoning for selecting those alternatives. Final June Response to Comments

45 Waste Management Material Recovery Facility Transfer Station and Household Hazardous Waste Facility Environmental Impact Report There is no ironclad rule governing the nature or scope of the alternatives to be discussed other than the rule of reason. (CEQA Guidelines, , subd. (a).) The rule of reason requires the EIR to set forth only those alternatives necessary to permit a reasoned choice and to examine in detail only the ones that the lead agency determines could feasibly attain most of the basic objectives of the project. (In re Bay-Delta Programmatic Environmental Impact Report (2008) 43 Cal.4th 1143, 1163, citing CEQA Guidelines, , subd. (f).) Feasible means capable of being accomplished in a successful manner within a reasonable period of time, taking into account economic, environmental, social, legal, and technological factors. The concept of feasibility also encompasses the question of whether a particular alternative or mitigation measure promotes the underlying goals and objectives of a project. (Sierra Club v. County of Napa (2004) 121 Cal.App.4th 1490, ) Moreover, feasibility under CEQA encompasses desirability to the extent that desirability is based on a reasonable balancing of the relevant economic, environmental, social, legal, and technological factors. (City of Del Mar v. City of San Diego (1982) 133 Cal.App.3d 410, 417.) For the lead agency s selection of a reasonable range of alternatives, CEQA establishes no categorical legal imperative for the scope of alternatives, with exception of the no project alternative. (CEQA Guidelines, ; Citizens of Goleta Valley v. Bd. of Supervisors (1990) 52 Cal.3d 553, 566.) The determination of a reasonable range is entirely dependent on the project s circumstances. (Ibid.) The EIR for the project analyzes five alternatives: 1) No Project/No Development Alternative; 2) No Green Waste Facility Alternative; 3) Reduced Tonnage Alternative; 4) No Household Hazardous Waste Facility Alternative; and 5) Alternative Site Alternative. The EIR s alternatives represent a reasonable range of alternatives that are capable of avoiding or substantially lessening the project s significant environmental effects. No other potentially feasible alternatives were identified as available for additional analysis, including alternatives that were considered but rejected from further analysis (page 7-41 of the Draft EIR) Refer to Response 5-3 regarding traffic impacts. Final June Response to Comments