SENECA — The Final Environmental Impact Statement for the proposed expansion of the Ontario County Landfill is so inadequate that it should be scrapped.

That sums up the opinion of the town of Seneca, host of the 389-acre landfill, as expressed in comments on the FEIS by consulting attorney Alan J. Knauf of Rochester.

The county and Casella Waste Services, operator of the landfill, plan to seek a permit to deposit trash in a 43.5-acre section of the existing landfill, plus acquire a privately-owned 40-acre parcel to the south to use for soil cover.

Knauf concluded seven pages of comments by saying a new Draft Environmental Impact Statement (DEIS) should be prepared and the State Environmental Quality Review Act (SEQRA) process done over “so that a complete analysis of alternatives and environmental impacts is subjected to public comment.’’

The only two comments filed by the Oct. 4 deadline were from the town of Seneca and Seneca resident Katie Bennett Roll.

“For many reasons, the FEIS has both substantive and procedural deficiencies and does not satisfy the requirements of the SEQRA,’’ Knauf wrote.

“These flaws fail to satisfy the requirements of literal or strict compliance with the SEQRA process,’’ he added.

Knauf noted several deficiencies, including:

• ALTERNATIVES: The county was required to examine alternative sites for the additional landfill capacity, as well as a smaller scale or magnitude alternative waste technologies, Knauf said.

“While the FEIS gave lip service to alternatives, it did not seriously examine that in a sufficient level of detail so they could be intelligently evaluated by the ultimate decision makers,’’ he wrote.

He said the FEIS should also have examined alternative sites for the proposed 40-acre soil borrow area south of the landfill. He also said the report did not review the alternative of construction of a sewer line to Canandaigua to manage leachate, which would minimize on-site lagoon storage and eliminate leachate trucking.

• STATE PRIORITIES: Knauf said the state’s new solid waste priorities say landfilling is the fourth and last priority for solid waste disposal.

Knauf said Ontario County only provides 8.8 percent of the waste taken to the landfill so the expansion “is clearly not necessary to serve county residents.’’

“The county cannot make the necessary findings that the expansion will avoid or mitigate environmental impacts,’’ Knauf said. “Rather, the expansion will only make it easier to landfill waste and result in less waste recycling and less utilization of waste for energy production.’’

• SEGMENTATION: Knauf notes that the county has not completed a landfill master plan, as required, but is relying on a county solid waste master plan.

He said that plan relies on continued use of the landfill.

“The town is concerned that the plan may be to convert the planned new borrow area to a future landfill expansion at a later date or to pile the landfill higher than 1,025 feet,’’ Knauf said.

He also said the county has not yet prepared its applications to the state for a new solid waste permit or a new air permit.

“This also constitutes illegal segmentation since it is improper to defer analysis of environmental impacts for later study,’’ he said.

• MITIGATION: The FEIS, according to Knauf, “fails to fully assess measures necessary to mitigate impacts, including severe odors, visual impacts, noise, landfill gas and loss of agricultural lands.’’ All of that violates the SEQRA process, he said.

• IMPACT ANALYSIS: The FEIS must contain a statement and evaluation of the potential significant adverse environmental impacts at a level of detail that reflects the severity of the impacts and the reasonable likelihood of their occurrence, Knauf said.

Knauf said the FEIS fails to remedy various impacts, including odors, dust and noise. He called the FEIS comments on the need for the soil borrow area “nonsensical.’’

• ZONING: Knauf said the town zoning code does not allow establishment of the new soil borrow area. He rejected the claim in the FEIS that the expansion is exempt from local zoning.

• AGRICULTURAL LAND: The FEIS fails to adequately analyze the loss of 40 acres of prime agricultural land for use as the borrow area, contrary to the town’s comprehensive plan, Knauf said.

“Not only does the FEIS fail to study alternative borrow sites or adequately consider the need for the borrow area in light of the current volume of Beneficial Use Determined materials, but it fails to offer mitigation measures such as the creation of new farmland to compensate for the loss,’’ Knauf said.

He said the plan also does not mention deed restrictions that can be enforced by the town to ensure that this land is never used for waste disposal.

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