Public Comment Opportunities on Two Environmental Documents:  Chumash Heritage National Marine Sanctuary DEIS and Tajiguas Landfill Expansion DSEIR

First, the good news:  the National Oceanic and Atmospheric Administration (NOAA) is accepting written public comments on the Draft Environmental Impact Statement (DEIS) for the Chumash Heritage National Marine Sanctuary (CHNMS), the first Tribally-nominated national marine sanctuary designation in the United States. The CHNMS would protect culturally and biologically significant areas off the Gaviota Coast by prohibiting new oil and gas development within the sanctuary boundaries.  The sanctuary designation does not restrict fishing or recreational uses and is expected to have beneficial impacts on the ecosystem and fishery resources, recreation, tourism, and commercial uses of the sanctuary.

The proposed sanctuary area comprises the coastline and waters offshore San Luis Obispo and northern Santa Barbara counties and includes the Santa Lucia Bank, its escarpment, Rodriguez Seamount, Arguello Canyon, and other offshore features and resources to approximately 78 miles offshore.  The draft EIS includes several alternatives for the proposed sanctuary boundary, and NOAA is specifically soliciting public comment on the alternatives to inform its selection of a final preferred alternative.

GCC is joining our Chumash allies in supporting the Initial Boundary Alternative (Figure 3.1), which is most similar to the boundary in the Tribal nomination, and Sub-Alternative 5b (Gaviota Coast Extension) (Figure 3.11) which would extend the sanctuary boundary to include state waters off the eastern Gaviota Coast between Gaviota State Park and the Naples Marine Conservation Area.  GCC is also urging an equitable approach that includes all Tribes in the Collaborative Management of the sanctuary, not only federally recognized Tribes.

Members of the public interested in weighing in before the Wednesday October 25th comment deadline are encouraged to visit the Northern Chumash Tribal Council website which includes much more information about the proposed sanctuary, a petition to sign supporting the sanctuary, and detailed instructions on how to submit comments including sample letters.

The Bad News

Now, the bad news:  County of Santa Barbara Public Works is proposing yet another expansion of the Tajiguas Landfill on the Gaviota Coast, and is accepting public comments on a Draft Supplemental Environmental Impact Report (DSEIR) for the proposal. 

Image of Tajiguas Landfill from DSEIR Cover (23EIR-00001). 

In 2017 the County approved the $150 million dollar Tajiguas Resource Recovery Center (ReSource Center) at Tajiguas Landfill, consisting of a Materials Recovery Facility (MRF) and Anaerobic Digestion Facility (ADF) to achieve a minimum diversion rate of 60% and extend the life of Tajiguas Landfill from 2026 to 2036.  However the Resource Center is only achieving a 31.35% diversion rate, and the Tajiguas Landfill is still projected to fill up by 2026 even with the Resource Center fully operational.  Organic waste processing at the ADF has also caused intolerable nuisance odors and yielded poor-quality compost. 

The proposed Tajiguas Landfill Capacity Increase Project would increase the permitted height, disposal area footprint, and design capacity of the Tajiguas Landfill to extend the estimated closure year to approximately 2038.  In addition, the permitted disposal area footprint would be expanded to the north and east by approximately 14.25 acres, which would increase the total permitted disposal area from 118 acres to 132.25 acres.  The expansion area is presently habitat for protected wildlife species including Crotch’s Bumblebee (Bombus crotchii), California Red-legged frog (Rana draytonii), and rare plants and plant communities including Santa Barbara Honeysuckle and California brittle-bush scrub. 

The DSEIR finds that the expansion is anticipated to result in three significant and unavoidable impacts including construction-related and operational GHG emissions, and impacts to Crotch’s Bumblebee.  The DSEIR also identifies significant but mitigable adverse impacts to California Red-legged frogs and from the removal of Santa Barbara Honeysuckle and California brittle-bush scrub.  

In scoping comments on the Notice of Preparation, GCC urged Public Works to include a detailed discussion of current ReSource Center operations in the DSEIR and identify operational improvements and expanded source separation that could improve diversion and avoid the significant impacts of physically expanding the landfill.  Unfortunately, the DSEIR lacks this critical information, making it inadequate as an informational document. 

We encourage members of the public to comment on the Tajiguas Landfill Capacity Increase Project DSEIR by submitting written comments to Joddi Leipner at by 5PM on Monday November 13, 2023 and/or by providing testimony in person or via Zoom during the public hearing on the DSEIR on Thursday, October 26, 2023, 5:30 p.m. at the Tajiguas Landfill Resource Center Education Room (located at 14470 Calle Real, Goleta CA, 93117).  To register for in-person attendance at the meeting, or to participate remotely through Zoom, please go to  Comments should focus on the adequacy of the DSEIR, not whether the County should or should not approve the Project. 

Suggested talking points on the Tajiguas Landfill Capacity Increase Project DSEIR: 

  • The DSEIR lacks adequate information about baseline operations at the ReSource Center and what waste is currently buried at Tajiguas Landfill.
    • The DSEIR must clearly identify what materials are being landfilled currently and at what volumes, and why those materials are not being diverted. 
  • The DSEIR fails to identify, analyze and avoid or mitigate the Project’s significant cumulative odor and land use incompatibility impacts.
    • The Project’s odor impact will exacerbate the intolerable odors currently experienced by residents of the Arroyo Quemada community and the public recreating near the landfill.
    • Analysis of cumulative odor impacts from all Landfill and ReSource Center activities is required, including how those cumulative odors impact the quality of life for Arroyo Quemada residents and the quality of the recreational experience at Baron Ranch, Arroyo Hondo Preserve, and nearby public beaches. 
  • The DSEIR fails to evaluate alternatives to physical expansion that avoid the Project’s significant adverse impacts to sensitive Gaviota Coast resources.
    • The DSEIR should evaluate an Improved ReSource Center Operations Alternative that improves diversion rates to delay or avoid physical expansion. 
      • Significant improvement from the current 31.35% diversion rate can and must be achieved before any physical expansion moves forward.
      • The DSEIR should detail any barriers to achieving ReSource Center’s promised diversion rate of 60% or better, and include specific actions to overcome those barriers.
    • The DSEIR wrongly dismisses enhanced source separation as a viable alternative. 
      • Commingling organic waste and trash in the brown bin leads to unnecessary contamination that could be reduced by expanding residential food waste collection. 
      • Other jurisdictions have successfully expanded source separation to include residential food waste collection, including the unincorporated Santa Maria and Lompoc Valleys.
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