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12 - Environmental Review - Organics Recycling ProgramProtecting our community's health and the environment by providing solid waste and sewer collection services. www.cmsdca.gov Costa Mesa Sanitary District ….an Independent Special District Memorandum T o: B oard of Directors From: Scott Carroll, General Manager Date: January 23, 2014 Subject: Environmental Review – Organics Recycling Program Summary In brief, the project consists of having residents utilize an additional trash container solely for organics, which will be taken to the CR&R anaerobic digestion plant in Perris, California, for advanced recycling. The analysis will conclude that the project will not cause change in the environment but will have positive impacts, which will be the result of raising the diversion or recycling rate from approximately 57% to approximately 75%. Under the California Environmental Quality Act (CEQA), determination must be made as to whether the activity is a project and/or whether it is entitled to an exemption. S ta ff Recommendation That the Board of Directors concurs with finding that the activity is not a “project,” but if it is, that it is entitled to an exemption pursuant to CEQA Guidelines Section 15038. Analysis Not a Project CEQA Guideline 15378 provides that an activity of a public agency is a project if it has the possibility of causing a change in the environment. Under the project proposal, there is no change to the tonnage being collected by CR&R as the organics are currently part of the mixed waste stream placed in the containers; however, the tonnage will now be divided into a two-container system as opposed to the mixed waste containers now being utilized. CR&R estimates that the fleet servicing the District will increase from nine to ten trucks; however, only one truck will increase the total mileage driven in the District because less tonnage will be collected from mixed waste containers now that organics are separated. Nine trucks are not needed to collect mixed waste containers, which means CR&R can shift trucks that were originally collecting mixed waste containers to now collect organic ITEM NO. 12 Board of Directors January 23, 2014 Page 2 of 3 cont ainers. The additional truck route will add 450 miles to the existing total mileage driven of 4,050 within the District’s service area. The environmental impact being reviewed by the District consists of the additional truck route from CR&R within the Di strict’s service area. Routes from Stanton to Perris are considered part of CR&R’s Perris analysis. From a historical perspective, the District progressed from a manual collection system to a semi -automated collection system to a fully automated collecti on system, and the previous fleet of 15 diesel trucks has now become a fleet of nine trucks running on compressed natural gas (CNG). When the organics recycling program is implemented and District organics are transported to CR&R’s anaerobic digestion pla nt in Perris the organics will be converted into renewable natural gas (RNG). RNG will be used to fuel CR&R’s fleet servicing the District’s service area. In the South Coast Air Quality Management District’s evaluation of truck fuels, a clean diesel tru ck emits 95 carbon per unit of energy consumed and CNG emits 75 carbon per unit while RNG emits a -15 (negative 15) carbon per unit, thereby indicating the relative benefit to the environment of utilizing clean burning fuels. Under the City of Costa Mesa’s trash collection program, the District’s program covers single -family residential and small multi -family developments that utilize individual containers while the commercial sector is governed by the City’s non -exclusive franchise permit system. Under t he commercial program, there is technically no limit to the number of haulers working in the City. It is possible under the current commercial program that multiple haulers may serve adjacent businesses causing multiple trips on City streets as opposed to one trip if there was only one hauler. Consequently, at one time or another, the City has presumably already considered the impact of these emission s, noise, and wear and tear on Ci ty streets. Since the entire CR&R fleet servicing the District burns RNG , there is no potential for change in the environment based on vehicle emissions. Having the fleet fueled by RNG and the addition of one RNG trash collection vehicle does not cause a change to the environment, but from the standpoint of the history of the District and the current City commercial trash collection program, this is not a “change in the environment.” In fact, when the positive impacts are considered, the result may possibly even be a benefit to the environment. Exemption for Environmental Be tterment The benefit of diverting 75% of waste from the landfill instead of 50% equates to recycling an additional 10,000 tons of solid waste per year. That is 10,000 tons that does not need to be managed and covered at the landfill by Orange County Wast e & Recycle. This reduction in tonnage will save approximately 7.67 acres of landfill space per year and assists in lengthening the life of the landfill system . The reduction will also assists the District in moving organics out of the landfill, which is being considered in Sacramento. This is also a step toward zero waste, which is not about getting to zero but being on the path to zero. The District and many other agencies as well have a goal for being on the path to zero waste; therefore, the project is entitled to an exemption under CEQA Guideline 15038. Board of Directors January 23, 2014 Page 3 of 3 Conclusion In conclusion, it is recommended the Board of Directors find the proposed modifications to the trash collection program are not subject to the California Environmental Quality Act (CEQA) pursuant to Sections 15060(c)(2) (“the activity will not result in a direct or reasonably foreseeable indirect physical change in the environment”) and 15060(c)(3) (“the activity is not a project as defined in Section 15378”) of the CEQA Guidelines, Calif ornia Code of Regulations, because it has no potential for a change in the environment. Additionally, because the processing of organics will act to protect the environment, a Notice of Exemption should be filed under CEQA Guideline 15038 Strategic Plan Element & Goal This item complies wi t h the objective and strategy of Strategic Element 2 .0, Solid Waste and Strategic Goal No. 2.4, Develop strategies for Zero Waste. Legal Review District Counsel has reviewed and provided his comments to this report. Environmental Review Staff has reviewed the environmental considerations and, based on the District Engineer’s analysis, has determined that there is no possibility of a change in the environment by the adoption of the container program. Although the acti on before the Board is not a “project” under CEQA, staff also believes that it is entitled to a CEQA exemption since implementation of the organics recycling program by ordinance will assure the protection of the environment. As such it is also entitled t o a categorical exemption under CEQA pursuant to Guidelines Section 15038. A notice of exemption will therefore be filed. Financial Review There are no financial impacts for preparing this environmental review. Public Notice Process Copies of this report are on file and will be included with the entire agenda packet for the January 23 , 201 4 Board of Directors regular meeting at District Headquarters and on District’s website. Alternative Actions 1. Do not approve staff’s findings that the activity is not a “project” or entitled to a CEQA exemption and refer the matter back to staff.