APPLICATION FOR APPROVAL OF PROPOSED CONECUH WOODS SOLID WASTE MANAGEMENT FACILITY CONECUH COUNTY, ALABAMA

Presented To: Conecuh County Commission P.O. Box 347 Evergreen, Alabama 36401

Prepared By: Conecuh Woods LLC and SCS Engineers

January 10, 2011 File No. 09211001.00 _____________________ Raymond J. Dever, P.E. AL License No. 28022

TABLE OF CONTENTS Section 1 Page

Introduction ....................................................................................................................1-1 1.1 Background 1-1 1.1.1 Purpose ...................................................................................................1-1 1.1.2 Intent ......................................................................................................1-1 1.1.3 Facility Location ....................................................................................1-2 1.1.4 Siting Criteria .........................................................................................1-2 1.1.5 Existing Conditions................................................................................1-4 1.1.5.1 Property Use ................................................................................1-4 1.1.5.2 Roads ...........................................................................................1-4 1.1.5.3 Environmental and Topographic Features ..................................1-4 1.2 Overview of Proposed Facility .......................................................................1-6 1.2.1 Facility Size ...........................................................................................1-6 1.2.2 Overall Developments and Buffer Zones ..............................................1-6 1.2.3 Daily Capacity .......................................................................................1-8 1.2.4 Projected Site Life..................................................................................1-8 1.2.5 Service Area .........................................................................................1-11 1.2.6 Height of Filled Disposal Cells ............................................................1-11 1.2.7 Receipt of Waste ..................................................................................1-11 1.2.7.1 Methods .....................................................................................1-11 1.2.7.2 Anticipated Traffic Volume ......................................................1-11 1.2.7.3 Traffic Controls .........................................................................1-11 1.2.8 Major Operational Features .................................................................1-12 1.2.8.1 Cell Construction .......................................................................1-12 1.2.8.2 Protective Bottom Lining System .............................................1-12 1.2.9 Placement of Waste..............................................................................1-15 1.2.10 Leachate Management .........................................................................1-16 1.2.11 Stormwater Management .....................................................................1-17 1.2.12 Landfill Gas Controls...........................................................................1-17 1.2.13 Subsurface Environmental Monitoring Programs ...............................1-18 1.2.13.1 Groundwater ..............................................................................1-18 1.2.13.2 Subsurface Combustible Gases .................................................1-18 General Siting Requirements and Exclusionary Guidelines ..........................................2-1 2.1 Introduction 2-1 2.1.1 General Siting Requirements .................................................................2-1 2.1.1.1 Public Health and Safety .............................................................2-1 i

TABLE OF CONTENTS (Contd) Section Page

2.1.1.2 Accessibility ................................................................................2-2 2.1.1.3 Drainage and Soils.......................................................................2-4 2.1.1.4 Proximity to Groundwater and Surface Water ............................2-4 2.1.1.5 Potential for Subsidence ..............................................................2-6 2.1.1.6 Hauling Distance .........................................................................2-6 2.1.1.7 Adjacent Land Use ......................................................................2-7 Additional Siting Considerations ...................................................................................3-1 3.1 Introduction 3-1 3.2 Additional Siting Considerations ....................................................................3-1 3.2.1 Consistency with Land Use Planning ....................................................3-1 3.2.2 Accessibility from Major Roadways Aand Thoroughfares ...................3-3 3.2.3 Proximity to Major Generators of Solid Waste .....................................3-3 3.2.4 Availability of Suitable Earthen Cover Material ...................................3-3 3.2.5 Proximity to Utility Tie-Ins ...................................................................3-4 3.2.6 Proximity to Police, Fire, Medical, and Emergency Services ...............3-4 3.2.7 Social and Economic Resources ............................................................3-4 3.2.8 Environmentally Sensitive Resources....................................................3-4 3.2.8.1 Vegetation/Trees .........................................................................3-4 3.2.8.2 Aquifers .......................................................................................3-5 3.2.8.3 Wells ............................................................................................3-5 3.2.8.4 Streams or Creeks ........................................................................3-7 3.2.8.5 Endangered Species and Wildlife................................................3-7 3.2.9 Proximity to Airports, Floodplains, Wetlands, Fault Areas, Seismic Zones, and Unstable Areas ....................................................................3-9 3.2.9.1 Airports ........................................................................................3-9 3.2.9.2 Flood Plains and Wetlands ..........................................................3-9 3.2.9.3 Fault, Seismic Zone or Unstable Area.......................................3-11 3.2.10 Site Large Enough to Accommodate Communitys Wastes................3-11 3.2.11 Site Budgetary Considerations .............................................................3-13 3.2.11.1 Site Development and Long Term Operation Budgetary Considerations ...........................................................................3-13 3.2.11.2 Closure, Post-Closure Care, and Possible Remediation Costs ..3-13 3.2.12 Consistency with Solid Waste Management Plan ...............................3-14 Specific Requirements and Considerations ...................................................................4-1 4.1 Consideration #1: Consistency with Solid Waste Management Plan ..........4-1 4.2 Consideration #2: Relationship to Planned or Existing Development & Major Transportation Arteries & State Roads ................4-1 4.3 Consideration #3: Relationship to Industries and Solid Waste Generators .4-2 ii

TABLE OF CONTENTS (Contd) Section 4.4 4.5 Page Consideration #4: Costs and Availability of Public Services ......................4-3 Consideration #5: Impact on Public Health And Safety ..............................4-3 4.5.1 Transportation Safety .............................................................................4-4 4.5.1.1 Road Traffic ................................................................................4-4 4.5.1.2 Overview .....................................................................................4-4 4.5.1.3 Current Amount of Traffic ..........................................................4-5 4.5.1.4 Future Traffic Volume.................................................................4-8 4.5.1.5 Rail Traffic ................................................................................4-12 4.6 Consideration #6: Social and Economic Impacts Including Property Value .............................................................................4-12 4.6.1 Nearby Homes .....................................................................................4-12 4.6.2 Traffic Impacts .....................................................................................4-12 4.6.3 Land Use ..............................................................................................4-15 4.6.4 Buffer Zones ........................................................................................4-15 4.6.5 Facility Entrance ..................................................................................4-15 4.6.6 Site Screening ......................................................................................4-17 4.6.7 Property Values ....................................................................................4-17 4.6.8 Cultural Resources and Sensitive Land Uses.......................................4-20 4.6.9 Historical and Archeological Resources ..............................................4-20 4.6.10 Natural Resources ................................................................................4-20 4.6.11 Operations ............................................................................................4-20 4.6.12 Site Security .........................................................................................4-21 4.6.13 Litter .....................................................................................................4-21 4.6.14 Rodents ................................................................................................4-21 4.6.15 Birds .....................................................................................................4-21 4.6.16 Noise ....................................................................................................4-21 4.6.17 Dust ......................................................................................................4-22 4.6.18 Odor .....................................................................................................4-22 4.6.18.1 Overview ...................................................................................4-22 4.6.18.2 Sources of Odor .........................................................................4-23 4.6.18.3 Odor Prevention and Control ....................................................4-23 4.6.18.4 Summary ...................................................................................4-24 4.6.19 Rail Access...........................................................................................4-25 4.6.19.1 Overview ...................................................................................4-25 4.6.19.2 Site Activities ............................................................................4-25 4.6.20 Impact on Attracting Other Industry ....................................................4-26

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TABLE OF CONTENTS (Contd) Section Page

4.6.21 Community Benefits to Civic and Charitable Organizations and Special Events ......................................................................................4-26 4.6.22 Economic Impacts ................................................................................4-26 Comparative Evaluation Criteria for Proposed Facilities ..............................................5-1 5.1 Introduction ....................................................................................................5-1 5.2 Specific Criterion ............................................................................................5-1 5.2.1 Criterion #1: Consistency with Solid Waste Management Plans .........5-1 5.2.1.1 Conecuh County Solid Waste Management Plan Update September 2004 ...........................................................................5-1 5.2.1.2 Solid Waste Needs Assessment For Region VI: Alabama Tombigbee Region Dated November 16, 2003 ...........................5-3 5.2.2 Criterion #2: Proximity to Major Solid Waste Producers .....................5-6 5.2.3 Criterion #3: Accessibility to Major Transportation Arteries and State Roads ................................................................5-7 5.2.4 Criterion #4: Condition of Local Access Routes ..................................5-9 5.2.4.1 Interstate 65 (I-65) .......................................................................5-9 5.2.4.2 State Highway 41 (Hwy 41) ........................................................5-9 5.2.4.3 Federal Highway 84 (Hwy 84) ..................................................5-10 5.2.5 Criterion #5: Existing Traffic on Local Access Roads .......................5-10 5.2.5.1 Hwy 41 ......................................................................................5-11 5.2.5.2 Hwy 84 ......................................................................................5-11 5.2.6 Criterion #6: Households Within One Mile ........................................5-11 5.2.7 Criterion #7: Households Along Local Access Roads ........................5-12 5.2.8 Criterion #8: Sensitive Land Uses Within One Mile ..........................5-13 5.2.9 Criterion #9: Cost and Availability of Public Services .......................5-15 5.2.9.1 Potable Water ............................................................................5-15 5.2.9.2 Wastewater Disposal .................................................................5-15 5.2.9.3 Electric Power ...........................................................................5-15 5.2.9.4 Cost of Improvements ...............................................................5-16 5.2.10 Criterion #10: Police, Fire and Hospitals ............................................5-16 5.2.11 Criterion #11: Impact on Local Economy and Property Values .........5-18 5.2.12 Criterion #12: Cost Per Ton-Mile of Solid Waste Transportation ......5-20 5.2.13 Criterion #13: Host Community Benefits ...........................................5-20 5.2.14 Criterion #14: Host Community Economic Considerations ...............5-22 5.2.14.1 Job Creation ...............................................................................5-22 5.2.14.1.1. Initial Construction Phase ................................................. 5-22 5.2.14.1.2. Initial Operating Phase ...................................................... 5-23 5.2.14.1.3. Main Operating Phase ....................................................... 5-25 iv

TABLE OF CONTENTS (Contd) Section Page 5.2.14.2 Local Community Revenues .....................................................5-27 5.2.14.2.1. Real Estate Taxes .............................................................. 5-27 5.2.14.2.2. Development Fee............................................................... 5-27 5.2.14.2.3. Host Fee............................................................................. 5-27 5.2.14.3 Economic Multiplier Effect .......................................................5-29

FIGURES Figure No. Page

1-1. Location of Proposed Conecuh Woods Project .................................................................1-3 1-2. Aerial Photograph of Proposed Conecuh Woods Facility Boundary ................................1-5 1-3. Disposal Cell Relative to Overall Property .......................................................................1-7 1-4. Proposed Facility Elements ...............................................................................................1-9 1-5. Disposal Cell Section Indicating Basic Features .............................................................1-13 1-6. Disposal Cell Bottom Protective Lining System .............................................................1-14 2-1. Roads, Railroads and Highways ........................................................................................2-3 2-2. Soils Map ...........................................................................................................................2-5 2-3. Land Use Map ...................................................................................................................2-8 3-1. Geology Map .....................................................................................................................3-6 3-2. Red Hills Salamander Habitat ...........................................................................................3-8 3-3. Airport Distance ..............................................................................................................3-10 3-4. Known Faults and Recorded Quakes...............................................................................3-12 4-1. Widening & Transition Lanes Concept .............................................................................4-6 4-2. Approximate Locations of Traffic Counts.........................................................................4-7 4-3. Projected Access Route Usage ........................................................................................4-14 4-4. Proposed Entrance ............................................................................................................4-16 4-5. Visual Geometry of Proposed Screening Measures ........................................................4-18 5-1. Municipal Solid Waste Landfills Permitted to Accept Waste from Multiple Counties ....5-5 5-2. Site Location Relative to Larger Cities .............................................................................5-8 5-3. Schools, Churches, and Hospitals....................................................................................5-14 5-4. Emergency Facilities and Hospitals ................................................................................5-17 TABLES Table 1-1. 4-1. 4-2. 5-1. 5-2. 5-3. 5-4. 5-5. 5-6. Page

Conceptual Facility Life Estimate ...................................................................................1-10 Estimated Number of Waste Vehicles and Trips at Conecuh Woods Facility ..................4-9 Estimated Change in AAADTs at Conecuh Woods Facility ...........................................4-10 Local Schools, Churches, and Hospitals .........................................................................5-13 Estimated Direct Employment Resulting from Initial Infrastructure Construction Phase...........................................................................................................5-24 Estimated Direct Employment Resulting from Initial Operating Phase..........................5-25 Estimated Direct Employment Resulting from Long-Term Operations .........................5-26 Projected Waste Flow and Annual Host Fee ...................................................................5-28 Summary of Total Projected Community Economic Benefits ........................................5-30

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APPENDICES A B C D E Alabama Department of Environmental Management Permit Requirements Conecuh County Solid Waste Management Plan September 2004 Property Boundary Map and Legal Description Section 22-27-8 (Financial Assurance) of the State of Alabama Solid Waste Disposal Act Alabama Tombigbee Regional Commission Solid Waste Needs Assessment November 16, 2003

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SECTION 1 INTRODUCTION 1.1 1.1.1 BACKGROUND Purpose

Conecuh Woods LLC is proposing to construct and operate a modern non-hazardous solid waste sanitary disposal facility in Conecuh County, Alabama. The facility will be designed and operated to meet or exceed all applicable Alabama Department of Environmental Management (ADEM) and United States Environmental Protection Agency (EPA) rules and regulations. The ADEM regulations are reproduced in Appendix A. This application is submitted to the Conecuh County Commission for approval of the proposed location for use as a non-hazardous solid waste sanitary disposal facility in accordance with the approved Conecuh County Solid Waste Management Plan Update of September 2004 (CCSWMP) and all ADEM and EPA rules and regulations. A copy of the CCSWMP is provided in Appendix B. 1.1.2 Intent

It is the intent to show in this application that this facility would: ensure the continued availability of an environmentally sound disposal option for non-hazardous wastes for the residents and businesses of Conecuh County and the Alabama Tombigbee Region counties on a priority or guaranteed basis, and the State of Alabama generally, for the life of the facility; and, provide a new source of revenue for Conecuh County in the form of host fees; and, ensure that the financial and economic benefits of siting a regional disposal facility will accrue to the benefit of Conecuh County, its residents and businesses; and, provide that the private operator, not Conecuh County or its residents and businesses, bear the cost and liability of developing and operating the solid waste disposal facility; and, promote the health, welfare, safety and economic well-being of the residents of Conecuh County.

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1.1.3

Facility Location

The facility is proposed to be located on property in an unincorporated part of Conecuh County on State Highway 41 (Hwy 41) approximately six miles north of the Interstate 65 (I-65) and Hwy 41 interchange. The northern boundary of the property is approximately one mile south of the southern edge of the town of Repton. The property fronts on the west side of Hwy 41 as depicted in Figure 1-1. A property boundary map and description are provided in Appendix C. The property has been carefully selected and the facility carefully planned to mitigate and minimize the potential impacts on both the residents of Conecuh County and the environment; as well as successfully address the siting criteria listed in the CCSWMP. The property has been strategically sited to provide the residents and businesses of Conecuh County, the counties of the Alabama Tombigbee Region, and the State of Alabama with a reliable and environmentally sound waste disposal alternative; and the Gulf Coast region with a reliable and environmentally sound non-hazardous hurricane debris disposal facility for many years to come. 1.1.4 Siting Criteria

Careful analysis was given to the siting of the property to meet not only the federal and state siting requirements, but also to minimize and mitigate many of the potential impacts typically associated with the location and operation of solid waste disposal facilities. Section 2 through Section 5 of this application provide detailed responses to the siting, design, environmental and socio-economic factors required by the CCSWMP and ADEM. For example, the size of the property allows for the design of large buffer zones, up to 1/4 and 1/2 mile in some instances. These buffer zones are well in excess of those required by ADEM or employed at typical disposal facilities. Perhaps no other single on-site criteria is as important to the mitigation of as many different potential impacts as buffer zones; and references to the value of these buffer zones with respect to specific criteria are made throughout this application. Many other critical siting criteria are referenced throughout this application along with the manner in which the specific location, unique property characteristics and considered design of this facility serve to minimize and mitigate potential impacts to the residents of the Town of Repton and Conecuh County specifically and of Alabama generally, and to the natural environment.

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Figure 1-1. Location of Proposed Conecuh Woods Project

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1.1.5

Existing Conditions

1.1.5.1 Property Use -The property, like much of the immediate surrounding area, has been for many years and continues to be operated as a large scale commercial timber growing plantation. Most of the property has been and continues to be periodically harvested or clear cut to maximize pulp wood and lumber production. Figure 1-2 is a 1998 aerial photograph of the property showing the tree cover and lighter shaded irregular areas where the trees have been harvested in a clear cut. Also visible in the aerial photograph are numerous unpaved roads on the property that are used primarily by the logging companies. The condition of the property as of January 2007 appeared substantially similar to the 1998 photograph. 1.1.5.2 Roads -Access to the property is from Hwy 41, a lightly traveled two lane paved state highway designed for through truck traffic. Approximately six miles south of the property Hwy 41 intersects I-65 where there are on and off ramps for both north and south bound traffic at the interstate interchange. Hwy 41 continues north past the property to the Town of Repton, where it junctions with U.S. Highway 84 (Hwy 84). Hwy 84 heads west toward Monroeville and east toward Evergreen. In Evergreen, approximately 12 miles east of Repton, Hwy 84 intersects I-65 where there are on and off ramps for both north and south bound traffic at the interchange. Hwy 84 is also a two lane light to moderately traveled paved principal federal highway designed for through truck traffic. 1.1.5.3 Environmental and Topographic Features -Escambia Creek serves as the western boundary of the property. Several tributaries or drains of Escambia Creek also initiate in the southeastern and northwestern areas of the property. Some of these drains do not flow all year long and only contain water in the rainy season. Some parts of the property along Escambia Creek and its tributaries are part of the 100-year floodplain and also contain areas designated as wetlands. These features are discussed in more detail in Section 2 General Siting Requirements and Exclusionary Guidelines. The majority of the property is gently rolling with land surface elevations varying from about elevation 250 feet above mean sea level (msl) adjacent to Escambia Creek, rising to an average of approximately elevation 300 feet msl in the interior of the property and rising again to elevation 320 feet msl to 350 feet msl along Hwy 41. Some of the small hilltops in the interior rise to an elevation of about 330 to 340 feet msl. From north to south the property drops from an elevation of about 350 feet msl to an elevation of about 300 feet msl.

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Figure 1-2. Aerial Photograph of Proposed Conecuh Woods Facility Boundary

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1.2 1.2.1

OVERVIEW OF PROPOSED FACILITY Facility Size

The initial development area of about 250 acres will consist of basic infrastructure including an entrance facility, scalehouse, administrative offices, garage, workshop, borrow pit for soil cover, stormwater drainage, access roads, leachate pumping and storage facilities, and a roughly 60acre lined waste disposal area. 1.2.2 Overall Developments and Buffer Zones

Over 3,500 acres of the total 5,075 acre property will be devoted to buffer zones and ancillary uses to support a maximum of 1,550 acres of disposal area as shown on Figure 1-3. The total disposal area would be comprised of main disposal cells, which would then be broken down further into smaller cell areas that would be developed, filled with waste in a planned, sequential manner and then closed as appropriate over the operational life of the facility. All disposal cells will be located outside of the 100-year floodplain of Escambia Creek and the surrounding buffer zone where it exists on the property. The disposal cell design criteria will incorporate minimizing the impact on wetlands when feasible; and mitigating with approved measures any impact on identified wetlands. Conceptual design setback distances or buffer zones for the development of disposal cells from the property boundaries and 100-year flood plain of Escambia Creek are as follows: Eastern property boundary: 1,300 foot ( 1/4 mile) to 2,600 foot ( 1/2 mile) buffer zone from Hwy 41 Southern property boundary: 200 foot minimum buffer zone Western property boundary and 100 year flood plain of Escambia Creek (main body): 650 foot ( 1/8 mile) to 5,200 foot ( 1 mile) buffer zone Northern property boundary: 2,000 foot buffer zone 100 Year Floodplain of perennial tributaries of Escambia Creek: 200 foot minimum buffer zone These significant buffer zones provide protection well beyond the standard 100 foot disposal area setback required by ADEM and as described in more detail throughout this application serve to mitigate and minimize many of the potential impacts that may be associated with solid waste disposal facilities.

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Figure 1-3. Disposal Cell Relative to Overall Property

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The temporary storage and treatment of stormwater runoff from areas outside of the disposal cells will be managed by retention ponds. These ponds will be constructed along the lower elevations on the western part of the property. Once the natural runoff water has been treated and meets state quality standards for sedimentation it will be released in a controlled manner back into the existing surface water systems. Other necessary ancillary features to the disposal cells to be developed such as temporary access roads and storm water conveyance channels are not shown on the conceptual plan at this time. Soil for the daily cover of the waste will be obtained from borrow pits constructed on the property. Preliminary estimates indicate up to approximately 500 acres could be devoted to borrow areas. The major elements discussed above are presented in Figure 1-4. 1.2.3 Daily Capacity

The daily capacity of the facility will initially be relatively low, likely in the range of approximately 300 to 500 tons per day (tpd). Then ideally over the next few years capacity will increase in a fairly steady manner to approximately 700 to 1,000 tpd. It is anticipated that the daily capacity could grow to 5,000 tpd within approximately 10 years, and ultimately peak at 10,000 tpd. 1.2.4 Projected Site Life

The projected site life is based on many factors including the actual footprint area and configuration of the disposal cells, the annual throughput of waste, the final slope and height of the filled disposal cells, the effectiveness of daily compaction of the waste, and the consolidation of the filled disposal cells over time. It is anticipated that the total disposal capacity for an aggregate footprint of 1,550 acres with a waste height from land surface of about 250 feet would be a minimum of approximately 153 million tons, and could be significantly more depending on the final design and configuration of the actual disposal cells. Table 1-1 is an assessment of the projected site life with assumed initial inflows of 250 tpd increasing over time to 10,000 tpd. The table indicates that for this hypothetical waste inflow schedule and proposed cell areas, the total capacity of the facility would be reached in approximately 63 years.

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Figure 1-4. Proposed Facility Elements

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TABLE 1-1. CONCEPTUAL FACILITY LIFE ESTIMATE

Waste Inflow (Tons Per Day)* 250 500 750 1,000 1,500 2,000 2,500 3,000 3,500 4,000 4,500 5,000 5,500 6,000 6,500 7,000 7,500 8,000 8,500 9,000 9,500 10,000 10,000 10,000 10,000 10,000 10,000 10,000 10,000 10,000 10,000 10,000 10,000 10,000 10,000 10,000 10,000 Year 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30** 35 40 45 50 55 60 63 Cumulative Annual Waste Inflow(Tons) 72,000 216,000 431,000 717,000 1,146,000 1,718,000 2,433,000 3,291,000 4,292,000 5,436,000 6,723,000 8,153,000 9,726,000 11,442,000 13,301,000 15,303,000 17,448,000 19,736,000 22,167,000 24,741,000 27,458,000 30,318,000 33,178,000 36,038,000 38,898,000 41,758,000 44,618,000 47,478,000 50,338,000 53,198,000 67,498,000 81,798,000 96,098,000 110,398,000 124,698,000 138,998,000 153,298,000

* Assumes the daily tonnage is on average over 5-1/2 days per week (286 days per year). ** For years not shown, the tonnage is assumed to be constant at 10,000 tpd to the end of the projected life of the facility. The capacity of the facility could be increased beyond this by converting one of the internal

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borrow pits after borrow operations have concluded into waste disposal cells. This area, as much as 300 acres, could add a minimum of another 10 years of disposal capacity at a constant inflow rate of 10,000 tpd. Other basic options for potentially extending the facility life that will be developed in more detail in the final engineering report would include optimizing the design, layout and size of the waste cells and the required storm water retention areas. The sizes of the storm water retention areas at this conceptual stage are approximate and in the final design they will be optimized in size to potentially provide additional space for disposal and possibly further extend the life of the facility. 1.2.5 Service Area

The facility is proposed to have a service area limited to states east of the Mississippi River and Louisiana. 1.2.6 Height of Filled Disposal Cells

The final height of the filled disposal cells has not been established. It is anticipated that with the footprint area available for the disposal cells, the filled disposal cell height could reach a typical height of 250 to 300 feet above normal land surface. A preliminary concept of filled disposal cell screening measures and visibility from Hwy 41 has been developed and is presented in Section 4 Consideration #6 under Site Screening along with a description of the provisions made to minimize the visual impacts of the facility. 1.2.7 Receipt of Waste

1.2.7.1 Methods -Waste will be brought to the facility using vehicles specifically designed for waste hauling including covered tractor trailer trucks, covered roll-off container trucks, and to a lesser extent, municipal refuse trucks. As the waste inflow grows, it is anticipated that a significant portion of the waste will also be received by enclosed railroad container car. 1.2.7.2 Anticipated Traffic Volume -Estimates of the amount of truck traffic that will use the facility have been developed and are discussed in detail in Section 4 Consideration #5 under Transportation Safety. 1.2.7.3 Traffic Controls -An assessment of the existing roads and traffic controls in the area of the property was conducted and is also described in Section 4 Consideration #5 under Transportation Safety. Supplemental traffic controls will be provided if additional traffic volume, road condition, and traffic control analysis warrant them. A concept sketch is also provided in Section 4 Consideration #5 of proposed future improvements to widen and add dedicated turning and acceleration/de-acceleration lanes for Hwy 41 at the entrance to the facility.

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1.2.8

Major Operational Features

Figure 1-5 shows the main disposal cell-related features as discussed in more detail in this section. 1.2.8.1 Cell Construction -Waste received at the facility will be deposited in discrete disposal cells specifically constructed to prevent the waste from contacting the ground, to contain the waste to a specific area, and to allow the operator to manage all of the other operating elements of the facility efficiently including the grading and compaction of waste, traffic flow, placement of daily cover soil, management of storm water, and construction of temporary access roads. Initially upon opening the facility will have one cell available for waste disposal. As the daily disposal inflow increases over time and as the initial cell approaches capacity, additional cells will be constructed in a planned sequential manner in order to have adequate capacity available for the incoming waste stream. Typically these sub-cells will cover an area that provides at least one or more years of disposal capacity before the next sub-cell in sequence is constructed. One or more of these sub-cells would be combined into the main cells as indicated on Figure 1-4. 1.2.8.2 Protective Bottom Lining System -All cells designated for waste disposal will be constructed with a composite protective bottom lining system designed, engineered and constructed to meet or exceed all applicable ADEM and EPA standards. The protective bottom lining system will be composed of engineered materials that have been manufactured to meet or exceed stringent quality controls published by nationally recognized standards institutes and ADEM. The manufactured layers are then assembled into a complete system in the field using techniques and equipment designed for this specific function. The entire assembly process is controlled by the application of quality assurance standards mandated by ADEM regulations. Figure 1-6 shows a cross section of a proposed protective bottom lining system for the disposal cells. Prior to the installation of any bottom lining material, the foundation system is prepared. The foundation will provide a firm support structure for the liner system and distribute the weight of the waste to limit the overall differential settlement of the underlying soil. The foundation is prepared by removing all unsuitable soil, backfilling the excavation if needed with an engineered backfill soil, then leveling and compacting this soil to a dense base with specialized equipment. The base of the composite protective bottom lining system shall be a minimum of five feet above the seasonal highwater table as required by ADEM regulations.

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Figure 1-5. Disposal Cell Section Indicating Basic Features

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Figure 1-6. Disposal Cell Bottom Protective Lining System

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The lining system is composed of a, 60-mil high density polyethylene (HDPE) geomembrane liner and either a two foot thick compacted clay liner or one layer of a geosynthetic clay liner (GCL). The GCL may be substituted for the two-foot thick natural clay liner called for in the ADEM regulations that allow substitute liners that provide an equivalent level of protection and have a permeability of no more than 1 x 10-7 centimeters per second (cm/sec). The primary 60-mil liner may be protected by a geonet, a triple-layer geosynthetic material, consisting of a high-flow geomembrane core sandwiched between two protective layers of geotextile fabric. The geonet lays directly over the primary liner and serves as an additional protective barrier to prevent any waste material from coming into contact with the primary HDPE lining. The geonets primary function is to collect and convey leachate to one or more storage sumps where it is continually drained out of the disposal cell and into the main storage tanks. The leachate storage sumps are lined in a similar manner as the disposal cells. The primary 60-mil liner is overlain by a permeable sand layer approximately 24 inches thick that also is intended to provide some redundancy as a back-up leachate collection zone and an additional protective safeguard for the liner system. The bottom liner system may also be designed to handle the greater volume of leachate that would be produced should the operator decide that recirculation of leachate back into the disposal cell is a viable alternative to off-site leachate disposal. This application contains one proposed bottom liner system that currently meets or exceeds all EPA and ADEM requirements. The actual bottom liner system will comply with site conditions, regulatory changes, evolving technologies, and company and industry practices. At a minimum, the bottom liner system shall meet or exceed an applicable EPA or ADEM standards. 1.2.9 Placement of Waste

The placement of waste will be conducted in a controlled manner in accordance with the facility development plans to be approved by ADEM. A main cell is divided up into smaller sub-cells in order to efficiently manage the waste flow. Within a sub-cell the waste is deposited in a relatively narrow area designated as the working face typically to one acre in size at any given time. Once the waste is deposited at the working face, one or more compactor machines will begin the grading and compaction functions. The waste is typically formed across the working face into a lift about 10 feet high as the delivery of waste proceeds through the day. The working face is kept as small as practical to expose only the waste being deposited and compacted for that day. The compactors work the waste into place forming a gradual slope in order to increase their compactive forces. At the end of each day, the operator will cover the new waste with a minimum 6-inch thick layer of compacted soil, or an approved alternative daily cover material,

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to reduce the production of odors and prevent contact by vectors. As waste disposal continues and a lift is completed, the operators move the location of the working face and begin to construct another lift. The sloped areas are used to facilitate constructing lifts atop one another that confine the waste deposit to as small an area as practical within a sub-cell in order to reduce the production of leachate and other vectors. It is common to build up areas within a series of sub-cells to a height at which disposal activities may cease temporarily for as long as six months. This is typically done in order to develop the facility in a sequential and efficient manner. These temporarily dormant areas are covered with soil and other natural materials known as intermediate cover to minimize erosion until filling activities are resumed. The application of intermediate cover assists in reducing the production of leachate and in the efficient collection of landfill gas which helps to minimize odor production. This process of filling, temporarily covering, and filling again, will be repeated many times over the life of a cell. Once a portion or all of the sub-cells within a main cell have reached the maximum permitted height and are configured to the final approved slopes, they will be covered with a final cap system. The final cap system is designed to contain the waste in the disposal cell and to prevent the infiltration of rainwater into the disposal cell thereby minimizing the production of leachate and to make capture of landfill gas more effective so that it cannot become a potential odor or safety hazard. 1.2.10 Leachate Management

Leachate is any liquid including stormwater that comes into contact with exposed waste in the disposal cell. Modern solid waste disposal facilities have independent collection systems to handle and keep the natural stormwater on the site, which does not come into contact with any waste, separate from the leachate. These systems are designed and constructed to prevent the leachate from coming into contact with the stormwater. As with any development, the stormwater is collected and released into the natural environment in a controlled manner to minimize its impact. The leachate is separately collected and stored for treatment as wastewater at an ADEM approved facility. Leachate management is based on an engineered system to efficiently collect the leachate and have it safely conveyed for final disposal. As discussed previously in Section 1.2.8.2, leachate is continuously collected in the leachate sumps by the leachate collection system, which is an integral part of the protective bottom lining system. The leachate collection system consists of the protective sand and drainage layer, the leachate collection pipe network, and may include a geonet component as shown on Figure 1-6. The leachate sumps are equipped with pumps that automatically pump the leachate out through a permanent pipeline to the main leachate storage tanks.

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Initially, leachate disposal may be accomplished at either a municipal or private waste water treatment plant. The leachate will be transferred from the main storage tanks at the property and loaded into tank trucks on a scheduled basis and taken off-site to a permitted facility for treatment to state and federal standards. As the site develops, there are other potential options for leachate disposal. One option involves recirculating some or all of the leachate back into the disposal cell through a series of engineered permanent dosing pipelines or trenches. Leachate recirculated in a controlled process has certain additional environmental benefits, including re-use rather than disposal of leachate and more rapid and controlled decomposition of the waste in the disposal cells. 1.2.11 Stormwater Management

Currently, all of the stormwater runoff that is generated at the property finds its way into Escambia Creek, either by discharging directly to the main fork along the western edge of the property or to a tributary on the property and then into the main fork. The facility will have a storm water management system designed to collect and manage the natural stormwater runoff generated on-site outside the areas of active waste disposal. The independent stormwater management system will be engineered and constructed to keep the stormwater from coming into contact with waste or leachate. The features of the stormwater management system are sized to manage, at a minimum, the volume of runoff generated from what is known as the design storm. The design storm is dictated by ADEM regulations and simulates the maximum rate and total amount of runoff from a relatively severe storm. The runoff collected from all storms will be temporarily stored in on-site retention / treatment ponds. The retention ponds are engineered to provide the requisite holding capacity and treatment of the water to meet state standards for siltation. The ponds are also used to release the treated water back into the existing surface water systems at a controlled rate that is no greater than the rate that existed at the property prior to development. The area occupied by the retention ponds is coordinated with the disposal cell construction schedule so that the required holding capacity is available and expanded as required. 1.2.12 Landfill Gas Controls

Landfill gas (LFG) and odor controls will be installed, as necessary, to reduce the production of odors and to prevent the potential for subsurface migration of LFG beyond the property boundaries in accordance with ADEM regulations, as well as for possible beneficial reuse. LFG controls include the collection of gas with an engineered permanent system generally composed of the following main components: A network of vertical extraction wells installed at a pre-planned depth and pattern over the facility that is sequenced with the development of the sub-cells.

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Horizontal collection trenches that are installed relatively early in the filling stages and then periodically as the waste height increases A collection pipeline interconnecting these wells and trenches. A vacuum pump station that exerts a vacuum on the pipeline, extraction well and trench network in order to draw LFG as it is produced from the interior of the disposal cells into the pipeline system. Initially, this gas can be burned off with a flare to continuously combust the collected LFG. As the rate of LFG production increases and more LFG is collected, it may become feasible and economically viable to use the collected gas as an alternative renewable energy source that has additional environmental benefits. The LFG could be used to power certain basic industries or businesses, provide heat for greenhouse & aquaculture operations, produce electric power either for re-use at the facility, supplement the power grid, or to produce alternative vehicle fuels. There are now more than 500 such LFG re-use projects in the U.S. A good example in Alabama of a beneficial re-use of LFG is the construction of a new Jenkins Brick manufacturing plant near the Veolia Star Ridge landfill in Moody (Clair County) Alabama. The plant will use the LFG to fire its kiln and boilers. 1.2.13 Subsurface Environmental Monitoring Programs

In addition to the other measures taken to protect the environment as detailed throughout this section and this application, the owner/operator of the facility will conduct on-going monitoring of the groundwater and subsurface combustible gas as required by ADEM. 1.2.13.1 Groundwater -The facility will have a groundwater monitoring network including monitoring wells installed prior to construction of the disposal cells. This network will be designed based on the results of a hydro-geological investigation of the property conducted in accordance with ADEM regulations and the proposed development features of the property. 1.2.13.2 Subsurface Combustible Gases -The facility will have a subsurface combustible gas monitoring plan prepared in accordance with ADEM regulations. If combustible gas is detected, and it is believed to come from the facility, then follow-up actions in accordance with the plan to mitigate the source of the gas will be initiated.

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SECTION 2 GENERAL SITING REQUIREMENTS AND EXCLUSIONARY GUIDELINES 2.1 INTRODUCTION

Article III Section 11.0 of the Conecuh County Solid Waste Management Plan Update of September 2004 (the CCSWMP) is titled Siting for Solid Waste Disposal Facilities Within Conecuh County. Article III Section 11.1 of the CCSWMP contains general factors to be considered in siting a solid waste facility to balance the need for environmentally sound waste disposal capacity with the concerns of local citizens and municipalities. The general siting factors from pages III.11-1 through III.11-2 of the CCSWMP are reproduced below for reference along with the specific responses provided on behalf of the Conecuh Woods facility for consideration by the Conecuh County Commission. 2.1.1 GENERAL SITING REQUIREMENTS

2.1.1.1 Public Health and Safety -Response: The facility is not anticipated to pose a nuisance or to compromise public health and safety. There are many factors that have been considered in the siting, planning, design and operation of the facility that play a role in ensuring that Conecuh Woods will not compromise the public health and safety and to minimize off-site nuisance potential including: Establishing significant buffer zones. Perhaps no other single criteria is as important to the mitigation of as many different off-site impacts as buffer zones. An important siting criteria of this facility is the size of the property which, as mentioned throughout this application in the context of more detailed impact analyses, allows for the design of buffer zones up to 2,500% or more than the 100 foot ADEM required minimums. Buffer zones have been shown to effectively minimize and mitigate many of the off-site impacts that may be associated with solid waste disposal facilities. Providing a natural screening buffer of trees along Hwy 41 to effectively block most of the view of the facility. A waste disposal cell buffer zone from Hwy 41 of up to 1/4 mile to 1/2 mile. Providing upgrades at the appropriate time to Hwy 41 at the facility entrance including new, dedicated acceleration/deceleration lanes and turn lanes, to 2-1

separate site traffic from through traffic and allow through traffic to continue unimpeded and safely past the site entrance when traffic conditions warrant. The disposal facility will be surrounded by a security fence to discourage unauthorized access. Operating the facility in accordance with the standards promulgated by ADEM and the EPA. Having an operating plan for actively managing the facility for preventing fugitive dust and odors and controlling different vectors including rodents and birds so that potential off-site nuisances are minimized and the public health and safety are not adversely affected. Monitoring for the presence of subsurface landfill gas outside the disposal area and initiating gas management activities and systems to control odors and to prevent migration of subsurface gas away from the disposal areas. Preserving the quality of the existing surface water systems by separately capturing all storm water runoff from the property and treating it to meet ADEM standards for sedimentation before releasing it back to the existing surface water systems. Protecting the groundwater by use of a composite protective bottom lining system, independent leachate collection system and final cap system all engineered to meet or exceed ADEM and EPA design standards as described in Section 1 and Section 4.6.10. 2.1.1.2 Accessibility -Response: The property has excellent accessibility being located approximately six miles north of I-65 directly on Hwy 41. The vast majority of traffic using the site will come from I-65 and then north on Hwy 41 as shown on Figure 2-1. The facility may also potentially accept shipments of waste that are brought to the site by the existing railroad system from the south. The railroad runs along the east side of the property.

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Figure 2-1. Roads, Railroads and Highways

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2.1.1.3 Drainage and Soils -Response: The kind of soils on the upland parts of the property are classified as well-drained soil that has a loamy or clayey subsoil (i.e., the Malbis-Gritney-Fuqua), formed in loamy, clayey, and sandy marine sediments as shown on Figure 2-2. Within and adjacent to Escambia Creek and its tributaries are sandy loams (i.e., Bibb or Almore Fine) and a gravelly loamy fine sand (i.e., the Troup-Gritney). The terrain on the property is slightly hilly and gently rolling, which combined with the soil type provides natural drainage. The current use of the property as a commercial pine tree plantation, with a recognized intolerance for poorly drained soils, confirms that the property is well drained. 2.1.1.4 Proximity to Groundwater and Surface Water -Response: Groundwater is believed to be within 25 feet of land surface, on average, across the property. The proposed bottom elevation of the individual solid waste disposal cells will be based on measurements of the groundwater table fluctuations made in piezometers to be installed at the property and review of available records from the State. The proposed cell bottom elevations will provide a vertical separation from the seasonal high groundwater table elevation of at least five feet in accordance with ADEM standards. The disposal areas will be designed to segregate stormwater from the disposal area to avoid mixing stormwater with waste or leachate. Stormwater that comes into contact with the waste is considered leachate and is classified as a wastewater that requires separate treatment. The leachate collection system described in detail in Section 1 will be designed to efficiently and safely remove liquid from the disposal area. The facility will have its own separate storm water management system that will collect natural or normal runoff generated on-site outside of the operating disposal areas. Stormwater that exits the site will be controlled by applying best management practices to reduce erosion and siltation. This is done by providing treatment in basins and controlling discharge velocities and quantities. Generally, for a design storm event the volume per unit of time for the discharge of stormwater after development is limited to be the same or less than would have occurred naturally before development.

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Figure 2-2. Soils Map

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The minimum proposed setback of a disposal area to the main fork of Escambia Creek is approximately 650 feet from the floodplain boundary. There also is a proposed minimum setback of disposal areas to tributaries of Escambia Creek of approximately 200 feet. Stormwater retention areas and soil borrow areas are a minimum of approximately 200 feet from the floodplain of Escambia Creek or its tributaries. 2.1.1.5 Potential for Subsidence -Response: There is no known unusual natural potential for subsidence of the ground within the property. Historically the area has not had notable seismic activity. The general geology under the property consists of a sandy loam and clay sediments underlain by limestone. This type of geologic setting is generally suitable from a stability perspective for use as a solid waste disposal facility. SCS expects some relatively slow and uniform consolidation of the sandy loamy clayey layer under the disposal cells as filled. 2.1.1.6 Hauling Distance -Response: Hauling distances are typically assessed in the context of a large metropolitan area that generates a large quantity of waste such that it made economic sense to develop disposal facilities located within a reasonable haul distance from the municipal area to minimize the hauling costs. That round trip haul distance varies but is recognized as about 35 miles for municipal trucks. For many large metropolitan areas with limited disposal capacity and little if any future expansion potential at their disposal facilities, the economics of hauling regionally and nationally have been favorable to longer hauls to larger facilities located further from the waste source. Waste is commonly hauled long distances in over-the-road tractor trailer trucks and by railroad. The state of Alabama has existing landfills that provide waste disposal on a long-haul regional scale. Often times regional and national scale waste disposal occurs in less populated regions where ample tracts of suitable land are available to serve those areas for a longer time. The proposed facility is based in part on this type of long-haul model. Hauling distance still is meaningful to the proposed facility, however, it has been enhanced to be more applicable to a regional and national scale. Please see Section 5 Criterion #12 for additional analysis of the hauling distances and costs of solid waste transportation to the facility.

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2.1.1.7 Adjacent Land Use -Response: The land use adjacent to the property is primarily commercial timber plantation periodically harvested or clear cut to maximize production as shown on Figure 2-3. There are also a few homes northeast of the property and several clusters of a few homes south of the property along Hwy 41. Given the historical land uses in the area, which are not anticipated to change in the foreseeable future, and particularly with the establishment of the significant buffer zones and the other siting, design and operation guidelines outlined in this application, the use of the property as a modern non-hazardous solid waste sanitary disposal facility is compatible with the surrounding land use as commercial timber plantations sparsely populated with rural residences.

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Figure 2-3. Land Use Map

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SECTION 3 ADDITIONAL SITING CONSIDERATIONS 3.1 INTRODUCTION

Article III Section 11.0 of the Conecuh County Solid Waste Management Plan Update of September 2004 (the CCSWMP) is titled Siting for Solid WasteDisposal Facilities Within Conecuh County. The CCSWMP suggests that, according to EPA guidelines and regulations, there are additional considerations that should be key factors when locating solid waste facilities. These additional key location considerations from pages III.11-1 through III.11-2 of the CCSWMP are reproduced below for reference along with the specific responses on behalf of the Conecuh Woods facility for consideration by the Conecuh County Commission. 3.2 3.2.1 ADDITIONAL SITING CONSIDERATIONS Consistency with Land Use Planning

A solid waste processing/disposal facility or recycling center must be consistent with the overall land-use planning in the area (zoning). Response: Although Conecuh County has no formal master plan, it can be inferred that, like many rural counties, the County shares the goals of preserving its rural character by managing growth, preserving open space and avoiding sprawl while maintaining or developing a healthy financial condition to enable continued delivery of vital services to residents over the long term. To achieve these goals similar counties have sought to establish new sources of revenue while recruiting new business or supporting established businesses with minimal infrastructure needs and service demands. In this context, the proposed facility is consistent with a typical rural county master plan. The facility would provide a significant new revenue stream from a business with minimal infrastructure and service needs with a minimal impact on the majority of county residents. Conecuh County can use the new revenue to strengthen its financial position, help to ensure continued delivery to residents of critical or desirable services, further other county goals and objectives or make additional investments in infrastructure including even the purchase of lands for preservation of open space or key natural resources. Further, the anticipated post-closure use of the property as passive recreation or green space will preserve open space in the future. 3-1

More specifically, notwithstanding the fact that there is no zoning or other formal land use planning in unincorporated Conecuh County, the proposed solid waste disposal facility is consistent with the overall current and anticipated future land uses in the area. The property is immediately surrounded predominantly by commercial timber plantations periodically harvested or clear cut to maximize production. The use of the property as a solid waste disposal facility is not anticipated to have any negative impact on the surrounding property use as commercial timber plantations. Furthermore, where there are municipal zoning districts in Alabama, solid waste disposal facilities may fall under a Conservation zone due in part to the preferred separation from more densely populated areas or intensive land uses and the limited need for the provision of municipal utilities and services. The location of the property and the surrounding land use as commercial timber plantations are generally consistent with a typical Conservation zone. Moving outward beyond the immediately adjacent land uses, the property is generally located in a sparsely populated rural area. Of the 5,791 households in Conecuh County (CCSWMP page III.7-4) less than 1%, or approximately 55 households, were observed along the 10.5 mile stretch of Hwy 41 from I-65 to Hwy 84; which represents an approximate average of five households per mile. It is generally preferable to site solid waste disposal facilities in rural areas away from more densely populated areas and more intensive land uses in part to minimize the potential impacts on roads not designed for through truck traffic and to provide for the establishment of buffer zones between the facility and more intensive land uses. This site is located on Hwy 41 which is a lightly traveled but well maintained state highway designed for through truck traffic. In fact, a significant proportion of the observed traffic on Hwy 41 is through truck traffic. Given the property location off the interstate highway with direct access on a lightly traveled state highway designed for through truck traffic, and with the significant buffer zones and other siting, design and operations guidelines all as described throughout this application, the use of the property as a modern non-hazardous solid waste sanitary disposal facility is consistent with the surrounding land uses as predominantly commercial timber plantations sparsely populated with rural residences. These land uses are not anticipated to change significantly for the foreseeable future. Therefore, the use of the property as a solid waste disposal facility is consistent with the overall current and anticipated future land use in this area of unincorporated Conecuh County along Hwy 41 north of I-65.

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3.2.2

Accessibility from Major Roadways and Thoroughfares

The site must be accessible from major roadways or thoroughfares. Response: The property is easily accessible from I-65 via Hwy 41 as shown on Figure 2-1. The majority of the site traffic will be coming from I-65 and then north on Hwy 41 approximately six miles to the facility. I-65 is a four lane controlled access divided interstate highway with on and off ramps for both northbound and southbound traffic at the Hwy 41 interchange. The property is easily accessible from Hwy 41 due to the extensive frontage it has directly on Hwy 41. Hwy 41 is classified as a through state highway. The property is also accessible from Hwy 84 directly via Hwy 41. Hwy 84 is classified as a principal federal highway. 3.2.3 Proximity to Major Generators of Solid Waste

The site should be in close proximity to existing or proposed major generators of solid waste or recyclable materials. Response: Please see the detailed response in Section 5 Criterion #2. 3.2.4 Availability of Suitable Earthen Cover Material

If earthen cover material is required, the site should have an adequate quantity of cover material that is easily handled and compacted. Response: The site is believed to contain an adequate quantity of soil suitable for use as both daily cover and final cover. According to the Conecuh County Soil survey, the site contains a deposit of well-drained clayey or loamy soil formed in clayey, loamy and marine sediments as shown on Figure 2-2. Conceptual estimates indicate that 25-30 million cubic yards of soil will be required as cover for a total aggregate disposal area of no more than 1,550 acres. To meet that requirement, approximately 500 acres on site will be initially dedicated for use as soil borrow area.

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The operator also will assess the economic feasibility of using alternative daily cover (ADC) materials. ADC can reduce the need for on-site or imported soil and increase the life of the facility. If ADC is proven economically feasible and is approved for use by ADEM, the borrow pit areas would be reduced accordingly. 3.2.5 Proximity to Utility Tie-Ins

The site should be in close proximity to utility tie-ins. Response: Please see the detailed response in Section 5 Criterion #9. 3.2.6 Proximity to Police, Fire, Medical, and Emergency Services

The site should be in reasonable proximity to police, fire, medical and emergency response services. Response: Please see the detailed response in Section 5 Criterion #10. 3.2.7 Social and Economic Resources

The site must be chosen with regard for the sensitivities of the communitys residents including the social and economic impacts of the proposed facility. Response: Please see the detailed response in Section 4 Consideration #6. 3.2.8 Environmentally Sensitive Resources

The site must be located in an area where the facilitys operation will not detrimentally affect environmentally sensitive resources. Response: The site was specifically located with the premise that with the appropriate design, construction and operational features, environmentally sensitive resources would not be detrimentally affected as follows: 3.2.8.1 Vegetation/Trees -The majority of the property is not in its natural state and is planted and logged as a commercial pine tree plantation to maximize timber yields. The harvesting of these trees as needed to

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provide for the facility development will not disrupt a natural system or be significantly different than the normal periodic tree harvesting that occurs on the property. 3.2.8.2 Aquifers -The majority of the property overlies the northern edge of a sand and gravel aquifer, also known as the Miocene-Pliocene aquifer. This aquifer consists of sand, shell and marl, with lenses of silt, clay and gravel and is less than 400 feet thick in the region. Within this aquifer is a deposit called the Citronelle Formation, which is mostly a fine to coarse grained sand, poorly sorted, that may contain hardpan that can retard groundwater movement. This is an important water-yielding formation in the upper part of the sand and gravel aquifer, however, it is found only in the southern part of the site occupying a small area of perhaps 5% of the property as shown on Figure 3-1. In areas where the Citronelle is absent, the lower zone of the sand and gravel aquifer is the major water-yielding unit and consists of undifferentiated coarse sand and gravel. On the far western flank of the property, along Escambia Creek, are alluvial, coastal, and low terrace deposits consisting of undifferentiated silt, sand, and gravel with some clay. Water yields are variable in this unit. The sand and gravel aquifer in the vicinity of the property is directly underlain by the Upper Floridan Aquifer, a thick sequence of limestone and dolomite. The Floridan Aquifer is not the primary source of drinking water in this region, and in any event no large scale groundwater withdraws are anticipated. Depth to the groundwater table varies in the region, from a few feet in low-lying areas to up to 50 feet deep under hills and ridges. See Section 4.6.10 for some of the measures planned to protect surface and groundwater resources. 3.2.8.3 Wells -The closest community potable water supply well is located more than one mile north of the site in Repton. Regional groundwater flow direction is north-to-south, so this community well is hydraulically upgradient to the property; therefore the proposed facility could not have any effect on this well. The only other water wells observed in the vicinity of the site were with a few homes and one commercial property either to the north or east of the site. These wells are also hydraulically upgradient to the property, and therefore the proposed facility could not have any effect on these wells either.

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Figure 3-1. Geology Map

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3.2.8.4 Streams or Creeks -The ADEM and EPA regulations for the design, construction, operation, and monitoring of solid waste disposal facilities are very specific and protective of the environment. The storm water runoff from this facility is not anticipated to affect Escambia Creek. The facility will have its own separate storm water drainage system that will collect all naturally occurring runoff generated on-site outside of the operating disposal area. Erosion and siltation from stormwater runoff will be prevented by applying best management practices. After the required period to allow settling out of suspended materials in the retention ponds, the water will be released back to the existing surface water systems at controlled quantities and discharge rates limited to be the same or less for defined storm events as existed on-site in its natural state prior to any development. See Section 4.6.10 for some of the measures planned to protect surface and groundwater resources. 3.2.8.5 Endangered Species and Wildlife -The state has identified five animals on the endangered species list that may be found in Conecuh County: the bald eagle, gray bat, wood stork, gopher tortoise, and red hills salamander. The red hills salamander is a particularly important species because it is not known to exist outside of a small region in central Alabama. The red hills salamander is known to only inhabit a geologic formation known as the Red Hills. Figure 3-2 shows the known extent of this geologic formation, the southern boundary of which is more than 10 miles north of the site. Based on this information, it would appear that the red hills salamander habitat would not be affected by this development. As part of ADEM permitting requirements, a specific study will be conducted to determine if any endangered species exist on or adjacent to the property. Depending on the results, a plan will be developed with ADEM to avoid or minimize to the extent feasible conflicts with endangered species. One of the components of the facility design will be to minimize disruption to wildlife patterns. An assessment will be conducted of the type and numbers of protected wildlife using the property and their habitat. Depending on the findings of this study, the layout and operation of the facility will take into consideration the protective measures required by ADEM to preserve existing wildlife patterns. It should be noted that given the commercial logging nature of the property and its history of being periodically clear cut, it is unlikely that there exists undisturbed habitat on the site.

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Figure 3-2. Red Hills Salamander Habitat

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3.2.9

Proximity to Airports, Floodplains, Wetlands, Fault Areas, Seismic Zones, and Unstable Areas

The site must consider regulations regarding proximity to airports, floodplains, wetlands, fault areas, seismic zones and unstable areas, if applicable. Response: The site was located with consideration to ADEM and EPA regulations and exclusionary guidelines regarding proximity to airports, floodplains, wetlands, fault areas, seismic zones and unstable areas as follows: 3.2.9.1 Airports -The two closest airports are in Monroeville and Belleville, over 6 miles and 12 miles from the site respectively as shown on Figure 3-3. This separation meets the Federal Aviation Administration (FAA) guideline of a minimum 6mile separation of a new municipal solid waste disposal facility from smaller federally-funded airports. Based on the plat records of Monroe County, the property boundary is 6.3 miles from the Monroe County airport boundary as shown on Figure 3-3. 3.2.9.2 Flood Plains and Wetlands -Although floodplain and wetland areas exist on the property as shown on Figure 1-4, no disposal cells will be constructed within any floodplain. Other elements of the facility not used for waste disposal, such as soil fill for a stormwater retention pond dike, or access road, may be located in a floodplain due to design considerations. In such an event, compensatory flood plain storage volume equal to or greater than what was taken will be provided in the form of excavated water retention areas. The current conceptual design does not have a floodplain incursion, however, confirmation with ADEM of the actual extent of the floodplain is recommended and based on this, there may be changes to the final site design and setback from the floodplain of some non-waste disposal elements.

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Figure 3-3. Airport Distance

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The facility will also be designed with the intent of minimizing the filling of and impacts on jurisdictional wetlands. If wetlands are impacted, there are approved mitigation techniques that could be employed including creation of new wetlands, acquisition of credits from a mitigation bank, or acquisition of additional property with comparable wetlands that could be preserved with a conservation easement. There is not anticipated to be a significant impact on existing wetlands once the facility is operational. 3.2.9.3 Fault, Seismic Zone or Unstable Area -The site is not located in a seismically active or unstable area according to published geological information. Figure 3-4 shows the approximate extent and location of known faults and dikes, and the occurrence and magnitude of historic quakes. The nearest known fault is more than 25 miles from the site. 3.2.10 Site Large Enough to Accommodate Communitys Wastes

The solid waste processing/disposal site should be large enough to accommodate the communitys wastes for a reasonable time (10 to 30 years). Response: The total waste disposal area is anticipated to be up to a maximum of 1,550 acres, which would be large enough to accommodate the communitys wastes for more than 30 years. The proposed facility will be large enough to accommodate for more than 30 years not only the waste from Conecuh County and the Alabama Tombigbee Region counties on a guaranteed capacity basis, but also, as has been the trend with other privately-owned disposal facilities in Alabama, a significant quantity of waste received from other regions of Alabama and outside the state as well. In the event that the facility does make use of the railroad capabilities of the site with the attendant environmental and economic benefits as discussed in the responses to Section 4 Consideration #5 under Transportation Safety and Section 5 Criterion #12 Cost per Ton Mile to Transport, the associated rail infrastructure investment required to be made by the Owner/Operator must be amortized over a long period of typically 50 years or more. This site was selected in part due to its size because it can therefore accommodate the longer lifespan needed to justify the investment in rail infrastructure. Table 1-1 in Section 1 contains an assessment of hypothetical waste flow and projected facility life.

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Figure 3-4. Known Faults and Recorded Quakes

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3.2.11

Site Budgetary Considerations

The site chosen should be able to satisfy budgetary constraints, including site development and long-term operation. If applicable, closure, post-closure care, and possible remediation costs should also be considered. Response: The budgetary requirements for site development and long-term operation have been carefully considered as have the closure, post-closure care and possible remediation costs. 3.2.11.1 Site Development and Long Term Operation Budgetary Considerations -This site was specifically selected in part due to the many positive physical characteristics of the property that allow for the economically feasible development of the site as a non-hazardous solid waste disposal facility. An additional siting consideration was the size of the property, which allows not only for the economically feasible development of the site, but also for the large disposal capacity potential required for long-term operation. An additional siting consideration is the location of the property with excellent interstate access and direct rail access. Taken together, the interstate and rail access afford long term economical access to major sources of waste generation, which is a critical component of a successful longterm operation. The site is well positioned for long-term economical operation given these site specific factors of location, excellent interstate access, direct rail access, and disposal capacity. 3.2.11.2 Closure, Post-Closure Care, and Possible Remediation Costs -Pursuant to state and federal solid waste regulations, ample reserves will be allotted for the financial assurance of the proper closure and post-closure care of the facility as well as for possible corrective actions. In 2005, after the September 2004 CCSWMP was written and approved, the State of Alabama adopted a financial assurance provision as part of the Solid Waste Disposal Act to require that any owner or operator of a municipal solid waste disposal facility, prior to issuance of a permit, provide and maintain an appropriate financial assurance in the form of either a bond or an insurance policy throughout the life of the facility and for a minimum of 30 years following final closure of all disposal areas, for the closure, post closure care and necessary corrective actions in accordance with all ADEM and EPA regulations (please see the Financial Assurances Act Section 22-27-8 in Appendix D).

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3.2.12

Consistency with Solid Waste Management Plan

Consideration should also be given to the consistency of a proposed facility with the Countys solid waste needs as identified in the Solid Waste Management Plan (SWMP) and in the regional planning councils Needs Assessment, if available. Response: Please see the detailed response in Section 5 Criterion #1.

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SECTION 4 SPECIFIC REQUIREMENTS AND CONSIDERATIONS Article III Section 11.0 of the Conecuh County Solid Waste Management Plan Update of September 2004 (the CCSWMP) is titled Siting for Solid WasteDisposal Facilities Within Conecuh County. Section 11.1.1 Specific Requirements and Considerations of the CCSWMP states that the local jurisdiction is charged with determining if each of the following six specific considerations have been addressed in a logical and complete manner when considering future facilities. These six specific requirements and considerations are the same as those contained in Section 22-27-48 of the Alabama Code. The six specific requirements and considerations from pages III.11-2 through III.11-4 of the CCSWMP are reproduced below for reference along with the specific responses provided on behalf of the Conecuh Woods facility for consideration by the Conecuh County Commission. 4.1 Consideration #1:

Consistency with Solid Waste Management Plan The consistency of the proposal with the jurisdictions solid waste management need as identified in its SWMP. Response: Please see the detailed response in Section 5 Criterion #1. 4.2 Consideration #2:

Relationship to Planned or Existing Development & Major Transportation Arteries & State Roads The relationship of the proposal to local planned or existing development or the absence thereof, to major transportation arteries and to existing state primary and secondary roads. Response: The facility is well located relative to local planned development. The site is six miles directly north on Hwy 41 from the Coastal Gateway Economic Development Authority industrial site located at the Hwy 41 and I-65 interchange.

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The facility is well located relative to local existing development. The site is convenient to the three municipalities in Conecuh County including the City of Evergreen and the Evergreen Industrial Park just up I-65 as well as the commercial development along the I-65 corridor. The facility is also well located relative to the absence of local planned residential development in the area. The site is located in a sparsely populated rural area with no known planned or anticipated significant residential development. The facility is almost ideally located relative to major transportation arteries and existing state primary and secondary roads. The site is located with direct rail access. The site has excellent access to I-65 six miles to the south on Hwy 41. I-65 is a four lane controlled access divided interstate highway with entrance and exit ramps for both northbound and southbound traffic at the Hwy 41 interchange. The site has excellent access to and direct frontage on Hwy 41. Hwy 41 is classified as a through state highway. The property is also accessible from Hwy 84 less than two miles to the north directly via Hwy 41. Hwy 84 is classified as a principal federal highway. Under this consideration the CCSWMP notes that the proximity of a proposed solid waste project to existing or planned major transportation routes is crucial (page III.11-2). Also under this consideration the CCSWMP notes that Landfills are best located in rural areas, hidden from view of the general public, yet not too far from major arteries and primary state roads so haul and collector trucks can have adequate access. Safety of the motoring public should be a major consideration in siting planned facilities (page III.11-3). This facility was specifically located in a rural area with direct, safe and convenient access to Hwy 41 and I-65 in order to match as closely as possible the ideal characteristics of this consideration. 4.3 Consideration #3:

Relationship to Industries and Solid Waste Generators The location of a proposed facility in relationship to existing industries in the state, that generate large volumes of solid waste, or the relationship to the areas projected for development of industries that will generate solid waste. Response: Please see the detailed response to Section 5 Criterion #2.

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4.4

Consideration #4:

Costs and Availability of Public Services Costs and availability of public services, facilities and improvements required to support a proposed facility and protect public health, safety and the environment. Response: Please see the detailed response in Section 5 Criterion #9 regarding the costs and availability of public services and improvements required to support the proposed facility. In summary, the public services and facilities are available to support the facility and any improvements required to be made shall be made at the expense of the owner/operator and not the County. Further, please see the detailed response in Section 4 Consideration #5 as well as Section 5 Criterion #4 regarding the current conditions that exist, the analyses performed and the provisions made with regard to transportation safety. In summary, the transportation infrastructure is in place to support the facility. Hwy 41 and Hwy 84 have adequate capacity to absorb the projected additional traffic from this facility operating at full capacity. These projections include an allowance for expected growth of the local, nonlandfill related traffic in the area. SCS suggests that in the future, if conditions warrant, Hwy 41 be widened and acceleration/deceleration lanes be added at the facility entrance to allow through-traffic to continue unimpeded. These improvements are further detailed in Section 4 Consideration #5. These improvements will also be made at the expense of the owner/operator and not the County. 4.5 Consideration #5:

Impact on Public Health and Safety The impact of a proposed facility on public safety and provisions made to minimize the impact on public health and safety. Response: The proposed facility has been specifically sited, designed and is planned to be operated to have little negative affect on public health and safety. In fact, it is anticipated that the facility may have significant positive impacts on public health and safety by not only providing a long term, environmentally sound non-hazardous solid waste sanitary disposal facility; but, with the anticipated revenues that the facility will generate for the community as detailed in Section 5 Criterion #14, Conecuh County may be able to make

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significant improvements that will benefit public health and safety that would not have otherwise been made. In addition to the wastewater, stormwater, leachate control and treatment programs and subsurface environmental monitoring programs detailed in Section 1 and referenced throughout this application, and in addition to the other siting, design and operations guidelines and safeguards detailed elsewhere in this application to address erosion control, to protect surface, groundwater, air and water resources, and to provide access control, the following analyses and provisions have been made to address transportation safety. Please see also the detailed response to Section 4 Consideration #6 which identifies some of the perceived nuisance aspects of solid waste sanitary disposal facilities that typically concern the public and regulatory officials; and also outlines some of the provisions incorporated into the siting, design and operation of this facility to minimize and mitigate those potential impacts. 4.5.1 Transportation Safety

4.5.1.1 Road Traffic -SCS has performed a preliminary traffic assessment to evaluate (i) the current traffic conditions on the roads in the area, (ii) the projected additional traffic from the facility at different operating levels, and (iii) the impact on the roads in the area of the additional projected traffic from the facility. SCS traffic assessment included field observations made by SCS in 2006 and review of 2005 traffic volume statistics, also known as traffic counts, as compiled by ADOT. The 2005 statistics represent the most recent statistics available from ADOT at the time SCS performed the assessment. 4.5.1.2 Overview -SCS concludes that the current traffic load on Hwy 41 is light. SCS concludes that the current traffic load on Hwy 84 is light to moderate. It is SCS conclusion that the maximum traffic impact on Hwy 41 from this facility operating at full design capacity would represent only about 14% of that highways capacity. Similarly, the maximum traffic impact on Hwy 84 would be less than 5% of the current traffic volume on that highway. Traffic increases would occur incrementally over the years. Assuming site operations commence in year 2014, these maximum impacts are not projected to be reached before the year 2026. SCS believes its preliminary predicted traffic load to be conservative. A formal traffic survey using the refined traffic figures is recommended to be conducted as part of the final submittal to ADEM. 4-4

The current structural and pavement condition of Hwy 41 appears sound. The current structural and pavement condition of Hwy 84 appears to be sound east of Repton, and sound west of Repton as well, but with some noticeable cracks toward the center of each lane. Hwy 41 is a through state highway designed for heavy truck traffic. Hwy 84 is a principal federal highway designed for heavy truck traffic. Both Hwy 41 and Hwy 84 are currently used by several types of heavy trucks, including gravel haulers, log trucks and bulk tankers. At some time in the future, perhaps when the facility is operating at 2,500 tpd or when conditions warrant, Hwy 41 should be widened and dedicated turn lanes installed at the facility entrance as shown on Figure 4-1 so that traffic flow may continue unimpeded. It is anticipated that the vast majority of the non-local traffic to the facility will come from I-65 up Hwy 41 to the site. It is anticipated that Hwy 41 will handle about 80% of the additional traffic to be generated by the site. The remaining 20% will be handled by Hwy 84. Other local routes will likely be used only for local collection vehicles as is current practice. 4.5.1.3 Current Amount of Traffic -The ADOT traffic counts indicate in general that Hwy 41 is the least used of the major access routes to the property. The 2005 annual average daily traffic (AADT) was from about 2,000 to 2,700. Hwy 84 had a 2005 AADT of from about 3,000 to 3,700 east of Repton, and up to about 6,900 west of Repton. These AADTs are summarized in Figure 4-2. AADTs are measured over 24 hours and are the total of all lanes, in both directions. For further analysis, if we assume that 65 % of the total AADT occurs during the peak times between 7 AM to 9 AM, 11 AM to 1 PM and 5 PM to 7 PM (a total of six hours), then an AADT of 2,700 for Hwy 41 breaks down on average to about five counts per minute during peak travel times. SCS considers this a light traffic load.

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Figure 4-1. Widening & Transition Lanes Concept

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Figure 4-2. Approximate Locations of Traffic Counts

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For the balance of hours outside these peak times (i.e., off-peak times referring to the 10 hours in the 16 hour period from 6 AM to 10 PM excluding the six previously defined peak period hours) and based on the assumption that there is very little traffic between the hours of 10 PM and 6 AM, then the off-peak vehicle count for Hwy 41 on average drops to less than two vehicles per minute. Hwy 84 coming into the Hwy 41 junction from the west had a maximum AADT of 6,900. Using the same peak period calculations method as for Hwy 41, this is equivalent to less than 13 vehicles per minute on average during peak travel times. SCS considers this a light to moderate load. For the off-peak times, it would equate to about four vehicles per minute on average. This is considered a light load. Hwy 84 coming into the Hwy 41 junction from the east had a maximum AADT of 3,700. This is equivalent to less than seven vehicles per minute on average during peak times. This is considered a light load. For the off peak times it would equate to approximately two vehicles per minute on average. 4.5.1.4 Future Traffic Volume -Future traffic volume would include additional traffic generated from the growth of the towns in the region, new large industries, and traffic using the proposed facility. It is proposed that the waste throughput within the first three to five years would increase steadily to 1,000 tpd. These waste shipments are all presumed to be brought by truck. Then, over a period of another 5 to 7 years, the throughput is proposed to increase to a total of 5,000 tpd. For the purpose of analyzing maximum traffic impacts, we will project this throughput will all be delivered by truck. Further volume increases above about 5,000 tpd are projected to only be realized by shipments brought in on the railroad. Consequently, additional truck traffic would not be anticipated. In order to estimate the amount of additional traffic that could be generated, the number of vehicles that would be utilized to deliver the waste was determined at the projected maximum throughput capacity of 5,000 tpd by truck. This information is summarized in Table 4-1, and allocated among four types of waste-hauling vehicles including: transfer trailers, roll-off boxes, garbage trucks, and miscellaneous small pull-behind trailers. SCS experience suggests that the percentage of each vehicle type could break down as follows: Transfer Trailers 51 % Roll-Off Boxes 35 % Garbage Trucks 13 % Other Small Trailers 1 %

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TABLE 4-1. ESTIMATED NUMBER OF WASTE VEHICLES AND TRIPS AT CONECUH WOODS FACILITY Density of Waste in Vehicle (lbs./c.y.) 400 470 600 300 Totals

Vehicle Container and Capacity in c.y. Roll-Off Box, 20 c.y. Transfer Trailer, 95 c.y. Garbage Truck, 12 c.y. Miscellaneous Trailers, 5 c.y.

Vehicle Capacity lbs. or (tons) 8,000 (4 tons) 44,000 (22 tons) 7,200 (3.6 tons) 1,500 (0.75 tons)

Percent of All Vehicles (%) 35 51 13 1 100

Tons per day Contribution

No. of vehicles arriving per day 438 116 181 67 802

Total Trips per day 876 232 362 134 1,604

1,750 2,550 650 50 5,000

The maximum projected total daily weight of waste hauled by each vehicle type was determined by multiplying the estimated percent vehicle type by 5,000 tpd. The load weight capacity for each vehicle was determined based on an estimated typical density of waste for each vehicle type and the volume capacity of the vehicle. Then, the total daily weight of waste hauled by each vehicle type was divided by the vehicle load weight capacity to determine the projected number of each type of vehicle arriving per day at the facility. Finally, the total number of arriving vehicles is doubled to take into consideration the return trip by the vehicle back to its place of origin. The far right hand column in Table 4-1 provides the estimated trips per day for each vehicle type with a projected total of 1,604 trips per day generated to and from the facility if operating at 100% of design capacity. Table 4-2 was created to assess the change these additional trips would make on the current AADTs on the main access routes to the site and how it would impact their design level of service. Table 4-2 indicates the percent change in the AADT on Hwy 41 and Hwy 84, under three throughput capacity conditions: 1,000 tpd, 3,000 tpd, and 5,000 tpd. In the far left column of Table 4-2 are the AADTs for each road as recorded for 2005 by ADOT. The potential sources of waste indicate that Hwy 41 could carry up to approximately 80% of the total additional number of vehicles and Hwy 84 the remaining 20%.

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Applying this breakdown would indicate that at the maximum 5,000 tpd throughput anticipated to be delivered by truck, the number of additional trips on Hwy 41 would be approximately 1,283 and on Hwy 84 approximately 321. This corresponds to a percentage increase over the 2005 AADTs of approximately 48% for Hwy 41 and 5% for Hwy 84. This represents the maximum impact anticipated given that further increase in throughput capacity would likely be through the use of railroad deliveries and therefore would not increase traffic on these roads. For the lower throughputs of 3,000 tpd and 1,000 tpd, a straight ratio was applied to the changes in AADTs calculated at the 5,000 tpd limit, to determine the AADTs at the lower throughputs. The additional AADTs projected to be generated by the facility are provided in Table 4-2. TABLE 4-2. ESTIMATED CHANGE IN AADTS AT CONECUH WOODS FACILITY

Projected Daily Waste Throughput (tons per day) Road / Current AADT C.R. 41 257 2,700 S.R. 84 64 6,900 (1) Represents the projected increase in AADT as a result of the facility operations at different throughputs. (2) Represents the % change of the projected increase in AADT as compared to current AADT. Design references in the Highway Capacity Design Manual for calculation of roadway design capacity were reviewed by SCS to make a preliminary evaluation of Hwy 41 and Hwy 84. SCS preliminary calculations indicate that the maximum design capacity of Hwy 41 is approximately 1,600 passenger car equivalents per hour total, both lanes combined. If we assume a worse-case condition that all the traffic occurs in the 6-hour peak period, then the AADT equivalent to this capacity becomes about 9,600 (i.e., 1,600 x 6) passenger car equivalents. Similarly for Hwy 84, SCS preliminary calculations indicate that the maximum design capacity is approximately 2,000 passenger car equivalents per hour total, both lanes combined. For this 4-10 <1 193 3 321 5 10 770 29 1,283 48 1,000 AADT Chg. (1) % Chg.(2) AADT Chg.(1) 3,000 % Chg. (2) 5,000 (year 12) AADT % Chg.(2) Chg.(1)

road, because it is a principal federal highway between the cities of Evergreen and Monroeville, we will assume all the traffic occurs in an 8-hour peak period, so that the AADT equivalent to this capacity becomes about 16,000 (2,000 x 8) passenger car equivalents. The estimated design capacity expressed as the AADT was then compared to the projected AADT changes over the years due to the additional site traffic. SCS also included a factor for the anticipated growth in local non-facility related traffic. This factor was based on review of AADTs recorded by ADOT for the last few years up to 2005. A local growth factor in the AADT of 3% per year for Hwy 41 and 4% per year for Hwy 84 were used. Comparing the estimated design capacity of each highway to the projected increase in AADT due to the facility traffic load we can summarize these changes as follows: Highway 41: Assessing the capacity of Hwy 41 using the method applied earlier in this section considers that 65% of the projected AADT of 5,134 would occur in a 6-hour peak period resulting in 3,338 peak period trips, or about 10 trips per minute. This is still considered to be a light to moderate traffic load. At the maximum projected truck delivered throughput of 5,000 tpd (year 12), the projected AADT, including traffic from the site and all other sources was estimated to be 5,134. Based on the conservative Hwy 41 capacity of 9,600 AADT, this represents only about 53% of the roads capacity which would indicate that the road has adequate capacity to absorb the projected traffic increases and growth. Highway 84: Assessing the capacity of Hwy 84 using the same method applied earlier in this section considers that 65% of the projected AADT of 11,369 would occur in a 6-hour peak period resulting in 7,389 peak period trips, or about 20 cars per minute. This is still considered to be a moderate traffic load. Further, if we were to assess the impacts of additional Hwy 84 traffic to be split 50% coming from the direction of Evergreen east of the Hwy 41 junction and 50% coming from the direction of Monroeville west of the Hwy 41 junction, then the respective increases in the projected AADT would be 161 trips per day in each direction, or an increase of 5% over the current (2005) AADT of 3,700 to the east, and an increase of 3% over the current (2005) AADT of 6,900 to the west. At the maximum projected truck-delivered throughput of 5,000 tpd (year 12), the projected AADT including traffic from the facility and all other sources was estimated to be 11,369. Based on the conservative Hwy 84 capacity of 16,000 AADT, this represents only about 71% of the roads maximum capacity which would indicate that the road has adequate capacity to absorb the projected traffic increases and growth. Even if we consider a case where Hwy 84 would carry up to 40% of the site traffic, the percentage of the roads maximum capacity used would be only increased to about 73%.

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4.5.1.5 Rail Traffic -Moreover, a key siting consideration of this facility relative to transportation safety is the direct rail access. Rail hauling is safer and mitigates many of the off-site impacts associated with truck traffic including highway safety, traffic congestion, road and bridge wear and tear, traffic noise and air quality by removing up to four trucks from the road for every rail car used. Rail hauling is also more environmentally friendly because it uses up to 90% less fuel per ton of waste moved and creates up to 90% fewer greenhouse gases in so doing when compared to overthe-road trucks. For Conecuh County and for Alabama, this means that many of the off-site impacts normally associated with the truck traffic generated for a given volume of solid waste required to make a disposal facility economically feasible to operate can be mitigated in part by the use of rail hauling. 4.6 Consideration #6:

Social and Economic Impacts Including Property Value The social and economic impacts of a proposed facility on the affected community, including changes in property values, and social or community perception. Response: The social and economic impacts of the proposed facility have been carefully considered; and care has been taken to assess many of the potential impacts and incorporate significant provisions and measures into the siting analysis, design criteria and proposed operating guidelines of the facility in order to minimize any negative impacts on the affected community. In addition, SCS has identified and separately assessed 22 different potential impacts or aspects regarding the facility in response to this consideration; as well as developed specific responses and provisions to each as follows: 4.6.1 Nearby Homes

A radius of one mile around the site perimeter yields an area of approximately 16 square miles. SCS conducted a drive-by survey in late October 2006 and observed 19 households in this 16 square mile area. This equates to an average of just over one household per square mile. 4.6.2 Traffic Impacts

The site was specifically selected to minimize traffic impacts by locating the facility with primary access on a lightly traveled through state highway (Hwy 41) with direct interstate access 4-12

(I-65). Secondary access would be from a principal federal highway (Hwy 84). The projected access route usages are shown on Figure 4-3. The property is located on Highway 41 north of Range and south of Repton. The vast majority of all non-local traffic will be coming north on Hwy 41 from I-65 to the south and turning off Hwy 41 at the site entrance several miles south of Repton. Highway 41: Hwy 41 is currently operating at approximately 28% of design capacity. The maximum projected traffic impact from the facility when operating at 100% of design capacity would be an additional 14% of Hwy 41 design capacity. Traffic increases would occur incrementally over the years with the maximum traffic impacts not projected to be reached before the year 2026. Highway 84: The maximum projected traffic with the facility operating at 100% of design capacity, if all of the projected Hwy 84 traffic were to head west from the Hwy 41 junction, would represent less than a 5% increase over the current traffic load on that portion of Hwy 84. If the projected facility traffic on Hwy 84 were to split at the Hwy 41 junction, with half of the traffic heading east toward Evergreen and half heading west to Monroeville, then Hwy 84 eastbound would experience a less than 5% increase over the current traffic load, and Hwy 84 westbound would experience less than a 3% increase of the current traffic load. Again, these projected traffic increases would occur incrementally over the years with the maximum traffic impacts not projected to be reached before the year 2026. Please see Section 4, Consideration #5 for a more detailed analysis of the traffic information on which the above conclusions were based.

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Figure 4-3. Projected Access Route Usage

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4.6.3

Land Use

The site is located directly on a state highway designed for through truck traffic six miles north of the Hwy 41 interchange with I-65. The predominant land use in the area is for commercial timber plantations which are periodically harvested or clear cut to maximize production. This sparsely populated area of Conecuh County has about 55 households along the 10.5 mile stretch of Hwy 41 from I-65 to Hwy 84 which represents an approximate average of five households per mile. Other than the Town of Repton, with a population of approximately 300 residents one mile north of the property, there are no intensive residential or commercial land uses in the area. Given the property location off the interstate highway with direct access on a lightly traveled state highway designed for through truck traffic, and with the significant buffer zones and other siting, design and operations guidelines all as described throughout this application, the use of the property as a modern non-hazardous solid waste disposal facility is consistent with the surrounding land uses as predominantly commercial timber plantations sparsely populated with rural residences. Please see Section 3.2.1, Consistency with Land Use Planning for additional information. 4.6.4 Buffer Zones

An important siting criteria is the size of the property which allows for the incorporation in the facility design of buffer zones up to 2,500% or more than the 100-foot ADEM required minimum set back to disposal areas. The site is designed to have significant buffer zones to the disposal areas, particularly along the Hwy 41 eastern property boundary (ranging from approximately 1/4 mile to 1/2 mile or 12 to 25 times the ADEM requirement) and the northern property boundary (approximately 2,000 feet or 20 times the ADEM requirement). As referenced throughout this application, there may be no other single on-site criteria more important to the mitigation of as many different off-site impacts than the dedication of significant buffer zones. This specific consideration is a key component of this sites selection and design criteria to minimize potential affects to local residents and the community. 4.6.5 Facility Entrance

The facility will have a well-landscaped entry and a curved access road to present an attractive entrance to the community and the general public along Hwy 41 as shown on Figure 4-4.

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Figure 4-4. Proposed Entrance

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4.6.6

Site Screening

A natural screening tree buffer zone of a minimum of 200 feet deep will be preserved around the entire perimeter of the property. Along the Hwy 41 frontage, a large swath of the mixed pine and hardwood tree area will also be preserved, where the tallest trees in the stand currently range from 20 to 40 in height. A 6 to 8-foot high earthen berm may also be constructed parallel to Hwy 41 in the area where the property had been recently logged. The berm would then be planted in a mixture of pine trees and shrubs. Taken together, these measures will provide a substantial natural screen and significantly reduce the visual impact of the facility to the community and to passersby on Hwy 41. Figure 4-5 is a scale depiction that shows the approximate visual geometry and relationship from a vantage point 6 feet above Hwy 41 to the leading edge of the disposal cell slope at varying setback distances. This depiction includes the effect of the above-described natural topography and screening measures. The figure indicates that the top of the disposal cells at a proposed height of 250 feet above the natural ground level would project a relatively insignificant distance above the tree line at the current tree height. By the time the disposal cells reach capacity, the trees will have grown significantly in height and will provide additional visual buffering of the filled disposal cells. The setbacks may be decreased in the actual formal engineering submittal to ADEM pending completion of additional site investigations to establish the limits of surface waters on and adjacent to the property and other potential specific design considerations. Furthermore, with the exception of internal access roads and the working face, unpaved areas will be grassed or mulched to prevent exposure of the soil, erosion and dust as well as to minimize visual impacts. 4.6.7 Property Values

Some public concern is usually voiced that close proximity to solid waste facilities may impact housing prices and property values. It is noteworthy that in more and more cases, in more densely populated settings, expensive home developments are being built in close proximity to operating landfills. This suggests that a properly sited and operated modern landfill can be compatible with its host communitys physical and economic environment. Modern highly engineered sanitary disposal facilities permitted and constructed under current environmental regulations and operated under best management practices have been found to contribute to healthy property values, primarily through the substantial community benefits and improved civic services paid for by the local governmental revenues generated by host fees, property and business taxes.

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Figure 4-5. Visual Geometry of Proposed Screening Measures

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As economic development projects, disposal facilities also create jobs, provide reliable and less expensive waste disposal, renewable energy generation and infrastructure improvements, all usually without costly tax incentives. There are numerous academic studies that indicate a well run modern solid waste disposal facility has no negative impact on property values, particularly in rural areas. There are also, however, some studies that suggest certain solid waste facilities may have a minor adverse effect on some surrounding residential properties within a well defined area around the facility. Most studies conclude that property value impact analyses cannot be universally applied; and, like real estate itself, are inherently local and highly dependent on the local market and specific property location, characteristics and circumstances. Consequently, property values and impact analyses are best addressed in a specific and local context. For example, as discussed throughout this application, appropriate buffer zones are an important consideration in reducing the potential for a negative impact on nearby residents and surrounding property values. The size of this property is a critical siting criteria because it allows for the dedication of buffer zones to disposal cells in key areas of up to 2,500% of the 100 foot ADEM setback requirement. Among other considerations, the attractive entrance (Section 4.6.5), site specific screening measures (Section 4.6.6), facility commitment to litter clean up (Section 4.6.13) and odor control (Section 4.6.18) also serve to moderate potential impacts which could affect community perceptions and property values. Relative traffic impacts are another important consideration in reducing the potential for an adverse effect on property values. A critical siting consideration is that this facility has been specifically located off an interstate highway on a lightly traveled state highway designed for through truck traffic in order to minimize the traffic impact that the facility would have, even when operating at full design capacity (Section 4.6.2). It is also important that this facility has been located in an area where the current and anticipated primary land use is for commercial timber plantations sparsely populated with rural residences. Specifically, in the approximately 16 square mile area within one mile of the sites perimeter, 19 households were observed. This equates to an average of just over one household per square mile (Section 5.2.6). The CCSWMP notes that the proximity of a proposed solid waste project to existing or planned major transportation routes is critical (page III.11-2); and that Landfills are best located in rural areas, hidden from view of the general public, yet not too far from major arteries and primary state roads so haul and collector trucks can have adequate access (page III.11-3). The facility was specifically located in a rural area with direct, safe and convenient access to Hwy 41 and I-65 in order to match as closely as possible the ideal characteristics of this consideration of the CCSWMP.

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Based on (1) extensive corporate experience with numerous other solid waste disposal facilities, (2) the siting considerations, design criteria and operations procedures as referenced throughout this application, (3) the substantial buffer zones and screening measures as outlined, (4) the facility location on and adequate capacity of the major access highways to the property, and (5) the fact that the surrounding property use is for commercial timber plantations with sparsely populated with rural residences, SCS is of the opinion that the facility would not likely have a statistically measurable negative impact on surrounding property values. 4.6.8 Cultural Resources and Sensitive Land Uses

There are two churches, no schools and no hospitals within one mile of the property. 4.6.9 Historical and Archeological Resources

There is one small cemetery on the northern portion of the eastern property boundary along Hwy 41. The design of the facility will incorporate a 100-foot wide buffer zone to remain undeveloped surrounding Morris Cemetery. The closest disposal cell will be more than of a mile from the cemetery. Additionally, as part of the ADEM permit process, a required specific historical and archeological resource study will be conducted. Depending on the results of the study, a plan will be developed to preserve and protect, or minimize to the extent feasible, any disruption to any other significant historical or archeological resources discovered on the property. 4.6.10 Natural Resources

The property consists of mostly previously disturbed land that has not been in its natural or indigenous state for many years due to its use as an actively logged commercial timber plantation repeatedly harvested and clear cut to maximize production. Consequently, it is unlikely that any indigenous natural resources exist that would be significantly affected by the development of the site. Escambia Creek on the western boundary of the property is a significant resource. The conceptual design of this facility incorporates a composite protective bottom lining system (Section 1.2.8.2), a leachate collection and management system (Section 1.2.10), a stormwater management system (Section 1.2.11), a groundwater monitoring system (Section 1.2.13.1) and a minimum 650-foot buffer from the main creek 100-year flood plain and 200-foot minimum buffer from the 100 year flood plain of a perennial tributary of the creek to any of the disposal cells to protect Escambia Creek and the groundwater. 4.6.11 Operations

The facility will be designed and operated in accordance with the standards promulgated by ADEM and the EPA along with certain design and operational commitments as detailed in this application. The collective effect of these measures will be to minimize the social impacts particularly on nearby residents and the Town of Repton.

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4.6.12

Site Security

The main entrance will have a scale house with an attendant in part to promote site security. The disposal facility will be surrounded by a fence to discourage unauthorized access. Exterior security lighting will be provided in certain key areas such as access points and near the on-site buildings. 4.6.13 Litter

Along the over 10 miles of Hwy 41 from I-65 to the Repton town line, the operator will provide for litter to be picked up on a regular basis. The operator shall also require all loads to be covered and may impose a 100% surcharge on any uncovered loads to help defray the costs of litter cleanup and to reduce litter impacts. 4.6.14 Rodents

Rodents are not normally a problem at a well-run sanitary disposal facility. Standard operating procedures, such as detailed below relative to odor management, include covering the waste on a daily basis with a minimum of a 6-inch thick compacted soil layer or an approved alternative daily cover. This practice discourages rodents from using the waste as a food source and habitat. 4.6.15 Birds

Birds may be attracted to certain parts of the facility, primarily the working face, because of the presence of uncovered organic materials. The operator shall follow a waste filling sequence plan to keep the area of exposed waste material as small as practical on a daily basis. Again, standard operating procedures, such as detailed below relative to odor management, include covering the waste completely on a daily basis. The effects of these standard operating procedures is such that birds do not ordinarily create an off-site impact. 4.6.16 Noise

The facility will employ several operational practices to curtail excessive noise. These measures will include: There will be posted speed limits within the facility. Equipment maintenance and repair will be conducted inside buildings designed for this purpose. A dedicated de-acceleration and turning lane may be constructed in the future in both directions on Hwy 41 for truck traffic to reduce vehicle idling and to efficiently route trucks off of Hwy 41. Buffer zones and setbacks of up to 25 times the ADEM requirements.

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Given the size of the buffer zones and the operational practices it is anticipated that the facility will not create an off-site noise impact. 4.6.17 Dust

The size of the property allows for the design of buffer zones up to 25 times the 100 foot ADEM required minimum set back to disposal areas. Buffer zones have a direct and potentially significant mitigating effect on potential dust impacts by providing area for dispersion and settling inside the property. Dust generation also will be mitigated through operational activities conducted on a routine basis including: The main access road from Hwy 41 to the scalehouse will be paved. The temporary access roads leading from the scalehouse to the operating cells will be periodically wetted down in the dry season to suppress dust. With the exception of temporary internal access roads and the working face, unpaved areas will be grassed or mulched to prevent exposure of the soil, erosion and dust and to minimize visual impacts. Maintaining an on-site station to monitor wind direction and precipitation so that dust controls can be tailored to site conditions. A truck tire washing operation will also be available for use during wet weather operations to reduce the potential for trucks to carry mud out of the facility. Existing stands of trees along property lines will be preserved to the extent possible and compatible with the site modifications. Given the size of the buffer zones and these operational practices, it is anticipated that the facility will not be a significant source of off-site fugitive dust. 4.6.18 Odor

4.6.18.1 Overview -Solid waste disposal facilities can generate odor. Off-site odor impact is always a key concern for nearby residents. Although some people may associate these odors with potential health impacts, there are no scientific studies that have concluded that odor from a properly operating solid waste sanitary disposal facility has resulted in health problems for nearby residents. As with property values, it is noteworthy that in more and more cases, in more densely populated settings, expensive home developments are being built in close proximity to operating landfills. This suggests that a properly sited and operated modern landfill can be compatible with nearby residential land uses.

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4.6.18.2 Sources of Odor -Solid waste disposal facility odors are caused primarily by landfill gas (LFG), but may also be caused by wastes at the working face or by leachate. 4.6.18.3 Odor Prevention and Control -With considered siting and design criteria, proper management, and the implementation of available operational practices, odors can be prevented, minimized, managed and contained such that off-site odors are not anticipated to impact local residents. As in the case of other potential impacts, the size of the property allows for buffer zones of up to 2,500% the 100 foot ADEM required minimum set back. Buffer zones help to mitigate odor by providing area within the property for dilution, notwithstanding the following operations procedures designed to prevent, minimize, manage and contain odor: Timely installation and expansion of a LFG and odor control system as described in Section 1.1.12 consistent with the fill sequence as detailed in Section 1 including the following main components: Horizontal LFG collection trenches that can be installed within the first few months of the initial waste filling activity. The trenches are hooked into a pipeline that is connected to a main vacuum blower station. The blower station creates a continuous vacuum in the trenches so that the landfill gases and odors are drawn out of the waste and into the collection system. The LFG is continuously pumped by the blower station to a flare and combusted. Horizontal trenches are typically installed into the waste and close to the active filling area so that the odor is captured below the waste surface before it has an opportunity to be released into the air. As the disposal volume increases, trenches are added vertically, typically about every 30 feet and are expanded laterally to provide complete coverage of the disposal cell. Vertical LFG collection wells are installed to supplement and tie together the horizontal trenches when the filling of waste ceases temporarily or permanently. The wells are hooked into the main vacuum pipeline to draw out the gas and pump it to the flare for combustion. When operated correctly the combination of horizontal odor trenches and vertical extraction wells function as a system that has been proven at other disposal facilities to be effective in preventing off-site odor impacts.

Sufficient personnel and equipment will be available to cover waste promptly and efficiently once it is received.

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The actual working face for disposal of waste on a daily basis will be kept as small as practical, typically from 1/4 acre to no more than about 1 acre in size (see Figure 1-3 for a scale depiction of the working face). Waste at the working face will be covered with a minimum of six inches of compacted soil or an ADEM approved alternative daily cover at the end of every workday. The timely and proper installation and maintenance of the leachate collection system as described in Section 1.2.10 also serves to minimize the potential for leachate as an odor source. Since the amount of water coming into contact with waste increases the production of leachate, the stormwater management system as described in Section 1.2.11 serves to reduce the amount of leachate and reduce that potential odor source. The facility will develop and implement an odor management plan that will include specific operational practices to prevent, minimize, manage and control odor. The operator will maintain an on-site weather station to monitor wind speed and direction, humidity, temperature and precipitation so that operations may be planned accordingly, and so that any potential odor complaint can be placed in context, and a targeted response can be initiated. Specific responses to an odor complaint may include verifying the source of the odor based on wind and weather conditions, checking the daily cover of the working face, checking the grass cover for erosion, or the application of odorneutralizing products made from 99% water, soap and essential oils. 4.6.18.4 Summary -SCS experience suggests that odors can be effectively controlled. This facility, with properly designed and timely constructed LFG and leachate management systems along with a commitment from ownership to operate and maintain these systems on a best management practices basis, will significantly reduce the potential for off-site odor impacts to nearby residents. By way of example, in Florida and elsewhere SCS has observed new homes and neighborhoods being built and coexisting near municipal solid waste disposal sites with smaller buffer zones than those proposed here. These sites employ a variety of proactive, practical measures in active odor management, many of which are outlined above and will be employed by the operator of this site to successfully prevent, minimize, manage and control off-site odor.

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4.6.19

Rail Access

4.6.19.1 Overview -Another key siting component is the direct rail access to the property. Rail hauling of waste is more environmentally sound than trucking because it uses up to 90% less fuel per ton of waste moved and creates up to 90% fewer greenhouse gases in so doing. Rail hauling is also safer and mitigates many of the off site impacts associated with truck traffic including highway safety, traffic congestion, road and bridge wear and tear and air quality. For Conecuh County and for Alabama, this means that many of the off site impacts normally associated with the truck traffic generated for a given volume of waste required to make a disposal facility economically feasible to operate can be mitigated by the use of rail hauling. Looking toward the future, as traffic on the roads and the cost of fuel both increase, and as the population becomes ever more conscious of the public safety and environmental costs associated with long haul trucking, rail hauling of waste is likely to become a more integral part of the waste transportation and disposal solution due to the significantly lower costs in terms of safety, the environment and economics. 4.6.19.2 Site Activities -The use of rail haul at the property will be operated to minimize the impact on the neighboring communities and the environment as follows: Municipal solid waste is delivered to the property either in specially designed rail cars or in intermodal containers designed to properly contain the solid waste and prevent odors or leakage. Flat cars are designed to hold up to four, 45-foot intermodal containers stacked two high. These flat cars may be joined to another train or assembled into a single train routed to the disposal destination. At the disposal site, the rail cars may pull into a transfer area or building specifically designed for the unloading operation. The containers are removed from the rail cars, placed onto specially designed trucks or trailers, and transported to the working face where they are tipped either by the trailer chassis or by a large mechanized tipping unit. Finally, the empty containers are reloaded onto flat cars and returned. If the refuse is transported in a rail car, unloading differs only slightly: a special tipper usually inverts the entire car. The refuse is reloaded into a transfer truck and moved to the working face for disposal. To capture odors that occur during the unloading at the rail siding, standard odor controls may be employed inside the transfer station to capture or eliminate the odor at the source. The station may use a combination of water misters to minimize fugitive dust, deodorants that are atomized and sprayed into the air over the unloading areas, and ventilation equipment that collects air in the unloading areas and exhausts the air through filters to clean it of the odor before it is discharged. 4-25

4.6.20

Impact on Attracting Other Industry

Modern landfill gas (LFG) projects collect landfill gas and create renewable energy in an environmentally friendly manner that can significantly cut greenhouse gas emissions, and that can either be used to attract and power a specific industry or sold back into the power grid. For example, Jenkins Brick Company decided to locate their new manufacturing facility near the Veolia Star Ridge landfill in Moody (St. Clair County) Alabama to take advantage of LFG. Alabama Electric Cooperative has also actively started participating in the development of green power derived from LFG. There are over 500 LFG re-use projects currently operating in the U.S. The renewable and environmentally friendly energy that could be generated from this project in Conecuh County along with the promise of reliable waste disposal with minimal transportation costs could be used as competitive advantages to help develop the Coastal Gateway Economic Department Authority industrial site located six miles down Hwy 41 at the intersection with I-65 (and located within two miles of Timberlands) and to attract other industry to the area. Conecuh Woods will dedicate up to 500 acres on-site for the development of LFG industries or other economic development. In addition, a portion of the host fee revenue generated as detailed in Section 5, Criterion #14, Economic Considerations could be used to attract, compete for and offer incentives to other businesses or industries to locate in Conecuh County. 4.6.21 Community Benefits to Civic and Charitable Organizations and Special Events

Similar to experiences of other local communities where companies act as good corporate citizens, it is anticipated that the owner/operator will be supportive of a wide range of local civic and charitable organizations as well as the schools and special community events as further detailed in Section 5 Criterion #13. 4.6.22 Economic Impacts

For a review of the projected economic impacts of the facility, including the creation of jobs, the anticipated local community revenues to be generated and the total impact of the project on the Conecuh County economy including an analysis of the multiplier effect, please see the detailed answer in Section 5 Criterion #14 of this application.

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SECTION 5 COMPARATIVE EVALUATION CRITERIA FOR PROPOSED FACILITIES 5.1 INTRODUCTION

Article III Section 12.0 of the Conecuh County Solid Waste Management Plan Update of September 2004 (the CCSWMP) is titled Approval Protocol for Solid Waste Facilities. Article III Section 12.0 of the CCSWMP describes the manner and specific criteria by which the Conecuh County Commission shall consider approval of proposed solid waste facilities in unincorporated Conecuh County. Article III Section 12.3 Comparative Evaluation Criteria For Proposed Facilities of the CCSWMP describes the method by which the Conecuh County Commission shall evaluate proposed solid waste facilities by using up to 14 specific criteria and scoring the proposed facility by using a point system (pages III.12-1 through III.12-4). The Conecuh County Commission or its designated agent for evaluation shall rate the proposal for each applicable criterion on a scale of 1 to 4 (1= Poor 2= Satisfactory 3=Good 4=Excellent). Any proposal must receive an average rating of 2 points (Satisfactory) per criterion in order to gain approval. The 14 specific criteria from pages III.12-1 through III.12-4 of the CCSWMP are reproduced below for reference along with the specific responses provided on behalf of the Conecuh Woods facility for consideration by the Conecuh County Commission. 5.2 5.2.1 SPECIFIC CRITERION Criterion #1: Consistency with Solid Waste Management Plans

The consistency of the proposed facility with the Countys solid waste management needs as identified in the SWMP Update or the Regional Planning Commissions Solid Waste Needs Assessment, if available. Response: The proposed Conecuh Woods facility is consistent with both the Conecuh County Solid Waste Management Plan Update, dated September 2004 and the Solid Waste Needs Assessment for Region VI: Alabama Tombigbee Region, dated November 16, 2003. 5.2.1.1 Conecuh County Solid Waste Management Plan Update September 2004 -The CCSWMP concludes that notwithstanding the reported disposal capacity at four of the six distant municipal solid waste landfills throughout Alabama that are permitted to serve Conecuh

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County, it would be unrealistic to consider utilizing the distant landfills due to transportation costs (page III .7-2). A copy of the CCSWMP is provided in Appendix B. Further, notwithstanding that there appears to be sufficient disposal capacity at the Timberlands facility in nearby Escambia County for the planning period of the CCSWMP, the report concludes that: a jurisdiction within the County may decide it would be advantageous to site a landfill in Conecuh County due to collection, transportation and/or disposal costs. Therefore, the option to site a future landfill (either MSW, Industrial, or C/D) shall remain available to the jurisdiction throughout the planning period of this Update. If the jurisdiction decides to pursue this option, the guidelines and procedures of this Solid Waste Management Plan shall be followed (page III.7-2 and page III.7-3). General siting criteria are listed in Section 7.8 of the CCSWMP under Protection of Air, Water and Natural Resources as follows (page III.7-5): State and Federal Regulations regarding the siting, design, construction and operation of solid waste processing and disposal facilities are in place to protect air, water and natural resources. These Regulations which safeguard against health, safety and environmental concerns involve: Buffer zones Minimum separation from groundwater Storm water run-on/run-off Liners, if applicable Leachate collection systems, if applicable Daily cover of solid waste These siting criteria are directly considered and successfully addressed generally in Section 1 and in more detail throughout this application. Conecuh County is currently using a disposal facility outside the jurisdiction in part because the solid waste generation rate for Conecuh County falls below the EPA suggested minimum needed for economical operation of full-scale Subtitle D solid waste disposal facilities (page III.10-1). This is similar to the experience of many jurisdictions both in Alabama and nationwide where, since the advent of the Subtitle D regulations, the costs of compliance have forced the closure of old, unlined dumps and instituted a new class of modern lined sanitary waste disposal facilities that require a certain minimum waste volume to merit the required investment in infrastructure required to fully protect the environment. Consequently, new Subtitle D disposal sites are frequently developed as regional facilities, as would the proposed Conecuh Woods facility. Article III of the CCSWMP stipulates certain U.S. EPA guidelines and regulations in Section 11.0 Siting for Solid Waste Processing or Disposal Facilities or Recycling Facilities Within Conecuh County (page III.11-1).

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Section 2 General Siting Criteria of this application takes the general criteria listed in Section 11.1 of the CCSWMP (page III.11-1) and reproduces them into this application along with the project specific responses on behalf of the Conecuh Woods facility for consideration by the Conecuh County Commission. Section 3 Other Location Considerations of this application takes the six additional specific siting considerations based on EPA guidelines and regulations as listed in Section 11.1 of the CCSWMP (pages III.11-1 and III.11-2) and reproduces them into this application along with the project specific responses on behalf of the Conecuh Woods facility for consideration by the Conecuh County Commission. Section 4 Specific Requirements and Considerations of this application takes the additional specific siting considerations listed in Section 11.1.1 of the CCSWMP (pages III.11-2 through III.11-4) and reproduces them into this application along with the project specific responses on behalf of the Conecuh Woods facility for consideration by the Conecuh County Commission. These particular requirements and considerations are the same as contained in Section 22-27-48 of the Alabama Code. Article III Section 12.0 Approval Protocol for Solid Waste Facilities in Section 12.1 of the CCSWMP (page III.12-1) states that The Conecuh County Commission shall consider approval of proposed solid waste facilities in unincorporated Conecuh County. This application is for property located in unincorporated Conecuh County. Article III Section 12.3 of the CCSWMP Comparative Evaluation Criteria for Proposed Facilities describes the method by which the Conecuh County Commission shall evaluate proposed solid waste facilities using up to 14 specific criteria to be scored using a point system (pages III.12-1 through III.12-4). The 14 criteria have been reproduced into this Section 5 of the application along with the project specific responses on behalf of the Conecuh Woods facility listed below each criterion for consideration by the Conecuh County Commission. The Conecuh County Commission or its designated agent for evaluation shall rate the proposal on each specific item on a scale of 1 to 4 (1= Poor 2= Satisfactory 3=Good 4=Excellent). Any proposal must receive an average rating of 2 (Satisfactory) in order to gain approval. In the event of competing proposals, the proposal with the higher score receives approval. Finally, Article III Section 13.2 of the CCSWMP Public Participation For Proposed Facilities or Contracts describes the required public participation, related notice provisions and other mechanisms for considering a proposed solid waste facility in Conecuh County. 5.2.1.2 Solid Waste Needs Assessment for Region VI: Alabama Tombigbee Region Dated November 16, 2003 -The proposed facility and location are also consistent with the Solid Waste Needs Assessment for Region VI: Alabama Tombigbee Region (the Report) dated November 16, 2003. A copy of the Report is provided in Appendix E.

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Specifically, the Report states on page 7 that a high percentage of solid waste is being transported great distances to out-of-region and out-of-state landfills. So, a majority of the counties in the region are dependent on facilities over which they have no control. Further, One aspect of disposal which is creating growing concerns for local governments is the cost of transportation and disposal. And, that even with a new landfill there is no guarantee that capacity would be available only to region counties. The conclusion of the Report states on page 7 that Virtually every city and county governing body in the State of Alabama finds itself facing the critical issue of solid waste. Moreover on page 8 the report continues, the findings of the initial study in 1989 have come true with county landfills which existed in virtually every Region 6 county at that time having been maxed out and closed at great expense to many of these counties. Meanwhile, counties and local governments find ever increasing shrinking capacity and escalating costs to disposal of their solid waste. As of November 16, 2003, there was one Subtitle D facility located in the region in Choctaw County, and the Report concluded on page 5 that a Subtitle D landfill more centrally located would impact expenses and provide additional future capacity to member counties. Since the Report, Subtitle D facilities have received local approval in Perry County and Washington County. The proposed facility in Conecuh County is well located within the southern part of the Alabama Tombigbee Region given the location of the other three facilities in Choctaw County and Washington County to the west and Perry County to the north as shown on Figure 5-1. These locations, taken together, would serve to minimize the costs of solid waste transportation for counties within the Alabama-Tombigbee Region. A facility in Conecuh County would provide additional competition to the other disposal facilities in the area that might serve to moderate gate fees and reduce the costs of disposal for Alabama-Tombigbee Region counties. A facility in Conecuh County would reduce the haul length for some of the member counties that would help to moderate their disposal costs.

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Figure 5-1. Municipal Solid Waste Landfills Permitted to Accept Waste from Multiple Counties

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Finally, the proposed facility is large enough so that the owner/operator would be willing to seek a mutually agreeable solution to providing member counties with a preferred or guaranteed capacity assurance for the life of the facility. Summary: The Conecuh County Solid Waste Management Plan Update of September 2004 specifically states that the option to site a future landfill shall remain available to the jurisdiction throughout the planning period of this Update. Furthermore, the proposed facility is consistent with both the Conecuh County Solid Waste Management Plan Update of September 2004 and the Solid Waste Needs Assessment for Region VI: Alabama Tombigbee Region dated November 16, 2003 in terms of need and in terms of meeting all the siting requirements and considerations required for approval by the Conecuh County Commission. 5.2.2 Criterion #2: Proximity to Major Solid Waste Producers

The facilitys proximity to existing or proposed major solid waste producers. Response: This facility is anticipated to receive waste from many potential sources including locally within Conecuh County, regionally within the Alabama Tombigbee Region and throughout Alabama generally, as well as from outside Alabama. Within Conecuh County, the site is well located just six miles north of the I-65 and Hwy 41 interchange. This interchange is also the location of the Coastal Gateway Economic Development Authority industrial site. The site is also convenient to and offers highway access to the existing development along I-65; as well as to any future commercial or industrial growth along the I-65 corridor. Within Alabama, the site is well located along the I-65 corridor midway between the Hyundai manufacturing complex and other industries around Montgomery, and the Airbus North American Engineering Facility and many other industries around Mobile. Nationally, non-hazardous solid waste has been shipped inter-county as well as interstate for many years using both over-the-road tractor trailers and the railroads. Because of the excellent interstate access and direct rail access to the site, there exists the ability to serve more distant, densely populated areas and major population centers. Within Alabama and the southeastern region of the United States, the site is centrally located within 200 miles of at least eight growing cities with populations over 100,000 including Mobile,

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Montgomery, and Birmingham in Alabama as well as Pensacola, Florida; Tallahassee, Florida; Columbus, Georgia; Jackson, Mississippi; and New Orleans, Louisiana. There also exist approximately 20 cities within 200 miles of the site with a population of more than 25,000 and more than 50 cities with a population of more than 25,000 within 300 miles of the site as shown on Figure 5-2. With respect to hurricane preparedness and as an emergency disposal facility for non-hazardous storm debris for Alabama and potentially the entire gulf coast region, the site is well located for both truck access just six miles from I-65 on Hwy 41, and more uniquely, by direct rail access. This site could serve as an important resource for future storm events by accepting nonhazardous storm debris in an environmentally sound manner and relieving the pressure on smaller municipal disposal facilities throughout the south. Summary: The Conecuh Woods facility is well located offering excellent access to existing and future major solid waste sources. 5.2.3 Criterion #3: Accessibility to Major Transportation Arteries and State Roads

The facilitys accessibility to existing or proposed major transportation arteries or state primary and secondary roads. Response: The facility is almost ideally located relative to major transportation arteries and existing state primary and secondary roads. The site has excellent access to I-65 six miles to the south on Hwy 41. I-65 is a four lane controlled access divided interstate highway with entrance and exit ramps for both northbound and southbound traffic at the Hwy 41 interchange. The site has excellent access to and direct frontage on Hwy 41. Hwy 41 is classified as a through state highway. The property is also accessible from Hwy 84 approximately two miles to the north directly via Hwy 41. Hwy 84 is classified as a principal federal highway. The site also has direct rail access on the Alabama Railroad that interlines with CSX in Flomaton, Alabama.

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Figure 5-2. Site Location Relative to Larger Cities

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Summary: The Conecuh Woods facility has excellent accessibility to major transportation arteries including the interstate highway system and the railroad as well as existing state primary and secondary roads. 5.2.4 Criterion #4: Condition of Local Access Routes

The number of lanes and condition of pavement on local access routes. Response: The primary local access route anticipated to be used by up to 80% of the site traffic is Hwy 41 from I-65. Hwy 84 is anticipated to be a secondary local access route for much of the balance of the site traffic. A civil engineer from SCS made a visual assessment of these primary local access routes on October 18, 2006. A summary of the observations follows: 5.2.4.1 Interstate 65 (I-65) -The interstate is a four lane controlled access divided highway with entrance and exit ramps for north and south bound traffic at the Hwy 41 interchange. The highway and the access ramps appear to be sound and in good condition. 5.2.4.2 State Highway 41 (Hwy 41) -The vast majority of traffic coming to the site is expected to come from I-65, exit at the Hwy 41 interchange and travel north on Hwy 41 approximately six miles to the site. Hwy 41 is classified as a through state highway. Hwy 41 is a 2-lane asphalt paved highway between I-65 and Hwy 84. The condition of the asphalt surface is sound and in good condition. The traffic on the highway is relatively light and is composed of a significant percentage of logging and other hauling trucks that loaded can weigh up to the interstate highway legal limit of 80,000 pounds. Hwy 41 is an interchange with entrance and exit ramps for both north and south bound traffic on I-65.

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5.2.4.3 Federal Highway 84 (Hwy 84) -Lesser amounts of traffic will come from Hwy 84 exiting in Repton and traveling south along Hwy 41 to the site. Hwy 84 is classified as a principal federal highway. Hwy 84 is a 2-lane asphalt paved highway north of the site between Monroeville to the west and Evergreen and I-65 to the east. Hwy 84 is an interchange with entrance and exit ramps for both north and south bound traffic on I-65 in Evergreen. The condition of the pavement is sound and in good condition from the Hwy 41 junction east to the interchange with I-65. Traffic volume is relatively light on this section. There is a flashing yellow light at the intersection with Hwy 41. The condition of the pavement from Hwy 41 west to Monroeville is sound and in mostly good condition; however, there are stretches in fair to good condition where the pavement has noticeable surface cracks toward the center of each lane. These cracks do not appear to hamper the highways capacity to carry heavy trucks. Preliminary survey work has begun on the future expansion project of Hwy 84 to a four lane highway. Summary: The local access routes all appear to be sound with pavement in mostly good condition. Hwy 41 is a two lane state highway designed for through truck traffic. Highway 84 is a principal federal highway designed for through truck traffic I-65 is a four lane controlled access divided interstate highway in good condition. 5.2.5 Criterion #5: Existing Traffic on Local Access Roads

The amount of existing traffic on local access routes, with larger amounts of traffic resulting in a lower point assignment. Response: SCS has performed a preliminary traffic assessment to assess (i) the current traffic conditions on the local access routes, (ii) the projected additional traffic from the facility at different operating levels, and (iii) the impact on the local access routes of the additional maximum projected traffic from the facility if operating at full capacity. The information for this response was summarized from the detailed traffic analysis contained in Section 4 Consideration #5 under Transportation Safety.

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The traffic assessment was based on 2006 field observations by SCS and 2005 traffic data, which represent the most recent statistics available from the Alabama Department of Transportation at the time that SCS performed the assessment. 5.2.5.1 Hwy 41 -It is projected that Hwy 41 will handle the vast majority of non-local traffic using the facility. Hwy 41 is also the least used of the major local access routes to the property. The annual average daily traffic (AADT) for Hwy 41 was from about 2,000 to 2,700. SCS analysis indicates that this breaks down into an average of about five vehicles per minute during peak traffic hours and less than two vehicles per minute during the off peak hours. This is considered to be a light traffic load for a through state highway. 5.2.5.2 Hwy 84 -Hwy 84 had an AADT of from about 3,000 to 3,700 east of Repton, and up to about 6,900 west of Repton. SCS analysis indicates that an AADT of 6,900 for Hwy 84 heading west from Repton toward Monroeville breaks down into an average of less than 13 vehicles per minute during peak traffic hours, and about four vehicles per minute during the off peak hours. This is considered to be a light to moderate traffic load for a principal federal highway. An AADT of 3,700 for Hwy 84 heading east from Repton toward Evergreen breaks down to an average of less than seven vehicles per minute during peak hours and an average of just over two vehicles per minute during the off peak hours. These are considered light traffic loads for a principal federal highway. Summary: The existing traffic on Hwy 41, the main local access route, is light. The existing traffic on Hwy 84 heading west from the Hwy 41 junction is light to moderate. The existing traffic on Hwy 84 heading east from the Hwy 41 junction is light. 5.2.6 Criterion #6: Households Within One Mile

The number of households within one mile radius of the proposed facility, with fewer households resulting in a higher point assignment. Response:

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A radius of one mile around the site perimeter yields an area of approximately 16 square miles. SCS conducted a drive-by survey in late October 2006 and observed 19 households in this 16 square mile area. This equates to an average of just over one household per square mile. Summary: Of the 5,791 households in Conecuh County identified in the CCSWMP (page III. 7-4), 19 were observed in the 16 square mile area within one mile of the property. This equates to an average of just over one household per square mile. 5.2.7 Criterion #7: Households Along Local Access Roads

The number of households along local access routes. Response: SCS conducted a drive by survey in late October 2006 to determine the location and number of households along local access routes. The survey accounted for homes that were within 250 feet of the roadway. Hwy 41 will be the primary local access route for non-local traffic destined for the facility. Hwy 41 will carry traffic from I-65 to the site, which will constitute the vast majority of the traffic projected to use the facility. Hwy 41 has approximately 55 households over the 10.5-mile stretch from I-65 to Hwy 84. This is an average of approximately five households per mile. Hwy 84, west of the Hwy 41 junction, will be the secondary local access route for non-local traffic destined for the facility. Based on a field survey conducted in October 2006, review of 2005 ADOT traffic data, and a detailed traffic pattern analysis, SCS projects that the maximum additional site traffic on Hwy 84 with the facility operating at 100% of design capacity will be 3% to 5% of the existing traffic. Traffic increases will occur incrementally; and the maximum 3% to 5% traffic increase is not expected to be reached prior to the year 2026 (assuming the facility initiates operations in year 2014). SCS also notes that preliminary survey work has begun on the future expansion project of Hwy 84 to a four lane highway. There are approximately 12 households along the 2 mile stretch of Hwy 84 from Hwy 41 west to the Monroe County line. It is not anticipated that other local roads or highways will be used by non-local traffic accessing the facility. Section 4.6.2 contains additional information on the traffic assessments and conclusions referenced here.

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Summary: Of the 5,791 households in Conecuh County identified in the CCSWMP (page III.7-4), there are approximately five households per mile along Hwy 41, the main local access route from I-65 to the facility. There are approximately 12 households along the secondary local access route of Hwy 84 west of the Hwy 41 junction to the Monroe County line. 5.2.8 Criterion #8: Sensitive Land Uses Within One Mile

The number of sensitive land uses (schools, churches, hospitals, etc.) within one mile radius of the proposed facility. Response: The schools, churches and hospitals within a one-mile radius of the proposed facility are shown in Figure 5-3 and are shown in the table following Figure 5-3. TABLE 5-1. LOCAL SCHOOLS, CHURCHES, AND HOSPITALS Use Schools Churches Hospitals Summary: There are two churches, no schools, and no hospitals within a one mile radius of the property. Total Number 0 2 0

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Figure 5-3. Schools, Churches, and Hospitals

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5.2.9

Criterion #9: Cost And Availability of Public Services

The cost and availability of public services and improvements required to support the proposed facility (i.e., water, sewer, electricity, etc.). Response: The proposed development will require relatively little in the way of public services and improvements for support. 5.2.9.1 Potable Water -Potable water needs typically are not high at a solid waste disposal facility. Potable water is only required by employees in the scalehouse, administrative offices and maintenance facilities for washing/showering and drinking purposes. There is a water main located on Hwy 41 that terminates less than one mile from the property. If the line has capacity, the operator could negotiate with the town to fund the extension of the line to the property. Alternatively, the operator could provide their own potable water supply well on the property. 5.2.9.2 Wastewater Disposal -It is anticipated that the facility will utilize on-site sewage treatment and disposal systems (i.e., septic tank and drainfield system) for disposal of waste water. Typically, waste water in relatively small quantities will be generated from employees in the scalehouse, administrative offices and the maintenance facilities. 5.2.9.3 Electric Power -Power demands for the facility are relatively small and no greater than that required by a small commercial business. Power demands consist of interior lighting and appliances for the scalehouse and administrative offices, typical repair shop lighting and equipment, exterior security lighting and ancillary features such as septic system pumps and water well pumps. Electric power is available along Hwy 41 and could be extended by agreement with the utility company to service the facility.

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5.2.9.4 Cost of Improvements -Article III Section 11.1.1(4) of the CCSWMP states that The costs of these improvements and who will pay are very important (page III.11-4). The Owner/Operator will be funding all of these improvements; plus the costs of all of the other specific improvements detailed throughout this application to preserve and protect the public health, safety and environment. Consequently, Conecuh County will not be responsible for funding any of the improvements. Summary: The public services required to support the facility are available to the property. The costs of any improvements will be paid by the owner/operator and not Conecuh County. 5.2.10 Criterion #10: Police, Fire and Hospitals

The availability of police, fire, medical and emergency response services. Response: The site is in reasonable proximity to emergency services. The Conecuh County Sheriffs Department typically responds to calls in unincorporated parts of the County. The Town of Repton has a fire department within two miles of the site. Although fires are not common at properly managed non-hazardous solid waste disposal facilities, they have occurred. In general, such fires are smothered with soil, rather than doused with water. Therefore, no unique capabilities are required from a fire department to respond to a fire at this facility. Equipment fires and structure fires could occur; however, these can be handled utilizing typical fire department capabilities. In addition, the City of Evergreen Fire Department is located within about 25 miles of the site. There are hospitals located in Monroeville approximately 10 miles away and in Evergreen approximately 25 miles away as shown in Figure 5-4. Summary: Law enforcement, fire, medical and emergency response services are potentially available to the facility.

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Figure 5-4. Emergency Facilities and Hospitals

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5.2.11

Criterion #11: Impact on Local Economy and Property Values

The perceptions of the facilitys impact on the local economy and local property values. Response: The project represents a host of economic benefits that could have a substantial positive impact on the economy of Conecuh County. For an analysis of the projected economic impact of the facility on the local economy, please see the responses to Section 5 Criterion #13 Host Community Benefits and Section 5 Criterion #14 Host Community Economic Considerations. Some public concern is usually voiced that close proximity to solid waste facilities may impact housing prices and property values. It is noteworthy that in more and more cases, in more densely populated settings, expensive home developments are being built in close proximity to operating landfills. This suggests that a properly sited and operated modern landfill can be compatible with its host communitys physical and economic environment. Modern highly engineered sanitary disposal facilities permitted and constructed under current environmental regulations and operated under best management practices have been found to contribute to healthy property values, primarily through the substantial community benefits and improved civic services paid for by the local governmental revenues generated by host fees, property and business taxes. As economic development projects, disposal facilities also create jobs, provide reliable and less expensive waste disposal, renewable energy generation and infrastructure improvements, all usually without costly tax incentives. There are numerous academic studies that indicate a well run modern solid waste disposal facility has no negative impact on property values, particularly in rural areas. There are also, however, some studies that suggest certain solid waste facilities may have a minor adverse effect on residential properties within a well defined area around the facility. Most studies conclude that property value impact analyses cannot be universally applied; and, like real estate itself, are inherently local and highly dependent on the local market and specific property location, characteristics and circumstances. Consequently, property values and impact analyses are best addressed in a specific and local context. For example, as discussed throughout this application, appropriate buffer zones are an important consideration in reducing the potential for a negative impact on nearby residents and surrounding property values. The size of this property is a critical siting criteria because it allows for the dedication of buffer zones to disposal cells in key areas of up to 2500% of the 100 foot ADEM setback requirement.

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Among other considerations, the attractive entrance (Section 4.6.5), site specific screening measures (Section 4.6.6), facility commitment to litter clean up (Section 4.6.13) and odor control (Section 4.6.18) also serve to moderate potential impacts which could affect community perceptions and property values. Relative traffic impacts are another important consideration in reducing the potential for an adverse effect on property values. A critical siting consideration is that this facility has been specifically located off an interstate highway on a lightly traveled state highway designed for through truck traffic in order to minimize the traffic impact that the facility would have, even when operating at full design capacity (Section 4.6.2). It is also important that this facility has been located in an area where the current and anticipated primary land use is for commercial timber plantations sparsely populated with rural residences. Specifically, in the approximately 16 square mile area within one mile of the sites perimeter, 19 households were observed. This equates to an average of just over one household per square mile (Section 5.2.6). The CCSWMP notes that the proximity of a proposed solid waste project to existing or planned major transportation routes is critical (page III.11-2); and that Landfills are best located in rural areas, hidden from view of the general public, yet not too far from major arteries and primary state roads so haul and collector trucks can have adequate access (page III.11-3). The facility was specifically located in a rural area with direct, safe and convenient access to Hwy 41 and I-65 in order to match as closely as possible the ideal characteristics of this consideration of the CCSWMP. Summary: The project represents a host of economic benefits that could have a substantial positive impact on the Conecuh County economy. Based on (1) extensive corporate experience with numerous other solid waste disposal facilities, (2) the siting considerations, design criteria and operations procedures as referenced throughout this application, (3) the substantial buffer zones and screening measures as outlined, (4) the facility location on and adequate capacity of the major access highways to the property, and (5) the fact that the surrounding property use is for commercial timber plantations with sparsely populated with rural residences, SCS is of the opinion that the facility would likely not have a statistically measurable negative impact on surrounding property values.

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5.2.12

Criterion #12: Cost Per Ton-Mile of Solid Waste Transportation

The cost per ton-mile of solid waste transportation to the proposed facility. Response: In one national study, it was found that it could cost 50 cents per ton per mile to haul collected waste in municipal collection trucks. Consequently, in municipalities and counties without disposal facilities, industry practice is to transport wastes in larger vehicles with some sort of waste compaction to reduce transportation costs through economies of scale. Within Conecuh County, the property is well located and easily accessible from I-65 and Hwy 41 and therefore the cost per ton of solid waste transportation to the facility would be competitive with most any other feasible location within Conecuh County. Within the Alabama-Tombigbee Regional Commission ten county area (including Choctaw, Clarke, Conecuh, Dallas, Marengo, Monroe, Perry, Sumter, Washington and Wilcox counties) the property is well located in the southern part of the region given the location of the other three facilities in Choctaw County and Washington County to the west and in Perry County to the north. These locations, taken together, would minimize the costs of solid waste transportation on a per ton-mile basis within the Alabama-Tombigbee Regional Commission area. Within the State of Alabama, the property is well located along the I-65 corridor between Montgomery and Mobile to minimize solid waste transportation costs on a per ton-mile basis for the southern half of the State. Moreover, with the property having direct rail access, the environmental, safety and economic transportation costs of moving solid waste on a per ton-mile basis can be reduced significantly, in some cases up to 90%, over the cost of transporting waste in garbage trucks and long haul trailers. Looking toward the future, as traffic on the roads and the cost of fuel both increase, and as the population becomes ever more conscious of the public safety and environmental costs associated with long haul trucking, rail hauling of waste is likely to become a more integral part of the waste transportation and disposal solution due to the significantly lower costs in terms of safety, the environment and economics on a per ton-mile basis. Summary: The property is well located with excellent interstate and rail access to minimize current and future solid waste transportation costs per ton mile not only in terms of dollars and cents but also in terms of public safety and the environment. 5.2.13 Criterion #13: Host Community Benefits

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Host Community Benefits Response: In addition to the significant positive economic impacts on the local economy that can occur with the development of a modern regional solid waste disposal facility, as detailed in the response in Section 5 Criterion #14, there are other benefits which typically accrue to the host community. Job creation is closely related to the economic stimulus that the proposed facility may have on the host community. It is anticipated that this facility will create 10-15 permanent jobs in the near term, and 25-50 permanent jobs in the longer term. Job creation is also discussed in more detail in Section 5 Criterion #14. It is also important to note that modern solid waste disposal facilities are becoming attractive to new commercial and industrial development both in Alabama and nationwide. Modern LFG projects collect landfill gas and create renewable energy in an environmentally friendly manner that can significantly cut greenhouse gas emissions, and that can either be used to attract and power a specific industry or sold back into the power grid. For example, Jenkins Brick Company decided to locate their new manufacturing facility near the Veolia Star Ridge landfill in Moody (St. Clair County) Alabama to take advantage of LFG. Alabama Electric Cooperative has also actively started participating in the development of green power derived from LFG. The LFG from this facility, coupled with a reliable, secure and convenient non-hazardous waste disposal option with minimal transportation costs, could provide competitive advantages for Conecuh County and organizations such as the Coastal Gateway Economic Development Authority industrial site in attracting future businesses. Conecuh Woods will also dedicate up to 500 acres on-site for the development of LFG industries or other economic development, which could spur future green collar jobs for residents and additional tax base and revenues for the County. In addition, a portion of the host fee revenue generated as detailed in Section 5, Criterion #14 could be used to attract, compete for and offer incentives to other businesses or industries to locate in Conecuh County. Conecuh County will benefit from having guaranteed capacity at a secure, environmentally safe disposal alternative for the solid waste generated in the community for the life of the facility. Transportation costs, which can be a significant portion of the total disposal costs, will be kept to a minimum by siting a facility within the county borders. As referenced in both the Conecuh County Solid Waste Management Plan Update of September 2004 (CCSWMP) and the Solid Waste Needs Assessment for Region VI: Alabama Tombigbee Region dated November 16, 2003, transportation costs and guaranteed capacity assurance are of growing concern to many local governments.

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Further, a small portion of the revenues described in Section 5 Criterion #14 to be generated by this facility for the local governments in the form of taxes or other fees may be earmarked to further the goals of the CCSWMP, such as implementing required recycling programs referenced in Article III Section 4.0 or the abatement or removal of illegal dumps referenced in Article III Section 5.0 which, as in many rural counties, have historically been a problem for Conecuh County. Finally, most solid waste disposal facility owner/operators are supportive of a wide variety of local charitable and civic organizations including various youth groups, scouting programs, local sports teams and leagues, volunteer fire and rescue organizations, other special interest and special needs groups and volunteer organizations. Most solid waste facility owners and operators are also long term supporters of the local schools and special community events. Summary: The Conecuh Woods project represents a host of community benefits to Conecuh County beyond jobs creation, increased governmental revenues and an economic stimulus including competitive economic advantages in attracting other industry, a guaranteed capacity solid waste disposal option with minimal transportation costs, the opportunity to further other goals of the CCSWMP including recycling and illegal dump abatement programs, and long term support of local charitable and civic organizations, community schools and special events. 5.2.14 Criterion #14: Host Community Economic Considerations

Host community economic considerations. Response: Properly sited, constructed and operated regional modern solid waste sanitary disposal facilities can become environmentally sound economic development projects with long-term economic benefits for the host communities including job creation, revenue generation, and a substantial economic stimulus to the local economy. 5.2.14.1 Job Creation -The project would provide three phases of jobs creation including (1) the two-year initial infrastructure construction phase, (2) the five to ten year initial operating phase, and (3) the main operating phase of 50 years or more. 5.2.14.1.1. Initial Construction Phase

The initial two-year construction phase will include the development of about 250 acres of basic infrastructure including an entranceway from Hwy 41, scalehouse, administrative offices, garage, 5-22

workshop, borrow pit for soil cover, stormwater drainage, access roads, leachate pumping and storage facilities and a disposal cell. Additional cells will be planned and constructed in a sequential manner to provide one or more years of disposal capacity before the next sub cell in sequence is constructed. As illustrated in Table 5-2, there are a variety of jobs projected during the initial construction phase of the project. As the work typically proceeds on such projects, staffing levels will be variable ranging from as low as 15 during low activity periods to as high as 200 during peak construction periods. Consequently, the estimated staffing level of 59 should be considered an average throughout the projected two-year construction window. Using employment and wage estimates developed by the U.S. Department of Labor for the City of Mobile, the nearest metropolitan statistical area in Alabama, an average annual direct payroll of approximately $1.4 million for initial infrastructure construction is estimated for this project. 5.2.14.1.2. Initial Operating Phase

During the initial five to ten year phase of the on-site operations the facility is anticipated to create employment opportunities for onsite staff and supplemented, if necessary, by subcontractors. As shown in Table 5-3, these jobs will include employment for a variety of different labor categories such as managers, office administrators, gate attendants, heavy equipment operators, construction workers, mechanics, and landscapers. Based on initial estimates of operating conditions, it is anticipated that during this time the facility will provide direct full time employment for approximately 16 people with an average annual direct payroll of approximately $515,000.

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TABLE 5-2. ESTIMATED DIRECT EMPLOYMENT RESULTING FROM INITIAL INFRASTRUCTURE CONSTRUCTION PHASE Labor Classification Number Estimated Annual Salary ($2007) 1

Office General Manager Project Manager Estimator Project Engineer Civil Engineering Technician Bookkeeper/Payroll Clerk Secretary File Clerk Subtotal Field Supervisors Heavy Equipment Operators Laborers Subtotal Trades Electrician Carpenter Pipelayers Helpers Subtotal TOTALS
1

1 1 1 1 1 1 2 2 10 2 10 19 31 2 4 4 8 18 59

63,940 59,400 49,210 40,400 24,670 23,880 52,700 33,460 347,660 84,320 261,700 328,510 674,530 66,080 97,640 90,400 140,880 395,000 $1,417,190

Per Capita Personal Income for Alabama Counties, Metros and Micros, 2000-2004, U.S. Department of Commerce, Bureau of Economic Analysis, April 25, 2006.

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TABLE 5-3. ESTIMATED DIRECT EMPLOYMENT RESULTING FROM INITIAL OPERATING PHASE Labor Classification Landfill Operations Manager Office Administrator Receptionist Gate Attendants/Scale Operators Trained Equipment Operators Landfill Equipment Operators Borrow Equipment Operators Landfill Gas Equipment Operator Leachate Tanker Operators Spotter Waste Inspector Construction Manager/Engineer Mechanic Landscape/Debris Crew TOTALS Number 1 1 1 1 2 2 1 1 1 1 1 1 1 1 16 Estimated Annual Salary ($2007)1 85,510 38,790 18,350 21,620 53,332 53,332 26,666 32,980 30,180 21,170 21,170 65,280 29,950 16,666 514,996

Per Capita Personal Income for Alabama Counties, Metros and Micros, 2000-2004, U.S. Department of Commerce, Bureau of Economic Analysis, April 25, 2006.

5.2.14.1.3.

Main Operating Phase

During the main operating phase the facility is anticipated to create employment opportunities for both on-site staff and subcontractors. As shown in Table 5-4, these jobs will include employment for a variety of different labor categories such as managers, office administrators, accountants/bookkeepers, environmental engineers/hydrogeologists, receptionists, gate attendants, heavy equipment operators, constructions workers, mechanics, and landscapers.

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TABLE 5-4. ESTIMATED DIRECT EMPLOYMENT RESULTING FROM LONGTERM OPERATIONS

Labor Classification Landfill 1 Landfill District Manager Landfill Operations Manager Office Administrator Accountant/Bookkeeper Receptionist Gate Attendants/Scale Operators Trained Equipment Operators Landfill Equipment Operators Borrow Equipment Operators Landfill Gas Equipment Operator Leachate Tanker Operators Spotter Waste Inspector Construction Manager/Engineer Mechanic Landscape/Debris Crew Subtotal Outside Vendors Local Solid Waste Collection Hauler 2 Operations Manager Bookkeeper/Accountant/Office Manager Solid Waste Collector Mechanic Subtotal 3 Transfer Station Operations Supervisor Equipment Operator Subtotal TOTALS Sources: SCS files of various landfill operating plans Notes: Several of these labor classifications may be outsourced by the operator. 2 Assumes local hauler has less than 1,000 accounts and services routes using rear-loader trucks. 3 Open top loading station less than 250 ton per day throughput capacity. 4 U.S. Department of Labor, Bureau of Labor Statistics, "2000 Metropolitan Area Occupational Employment and Wage Estimates", Mobile, AL
1

Number 1 1 1 1 1 3 5 6 3 1 2 2 1 1 2 3 34

Estimated Annual Salary ($2007) 4 130,938 85,510 38,790 26,550 18,350 64,830 134,853 161,820 80,910 32,980 60,360 42,340 21,170 65,280 59,900 50,820 1,075,401

1 1 6 1 9 1 6 7 50

63,940 26,550 485,460 29,950 605,900 47,950 161,820 209,770 $1,891,071

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Based on the ultimate operations plan, the operator may decide to include all of these employees as part of the onsite team or subcontract some of the work to private companies in Conecuh County. In any event, it is anticipated that operation of the facility and related collection and hauling functions will eventually provide direct permanent employment for 25 50 people with an average annual payroll of up to approximately $1.9 million. The majority of these jobs would be at significantly higher salaries than the per capita personal income for Conecuh County of $21,066 as most recently reported by the U.S. Department of Commerce, Bureau of Economic Analysis.1 5.2.14.2 Local Community Revenues -5.2.14.2.1. Real Estate Taxes

The facility is expected to generate additional real and personal property tax revenue above what the site currently generates as timberland. The increase in annual real and personal property taxes is estimated to be $50,000 which would total $3,150,000 over the projected 63 year life of the facility. 5.2.14.2.2. Development Fee

The owner will pay a development fee of $1.25 million to Conecuh County in five annual $250,000 installments commencing within 30 days of the start-up of landfill operations. 5.2.14.2.3. Host Fee

In addition, similar to the experiences of other modern private disposal facilities in Alabama, it is anticipated that for Conecuh County the proposed project will provide significant local revenues in the form of host fees. Host fees are an agreed upon fee paid to the host jurisdiction(s) placed on every ton of waste received at the facility. Consequently, the more waste received by the facility, the more host fees are generated for the host government(s). The host fee of $1.25 per ton with a 10% increase every 10 years is projected to generate more than $290 million in host fee revenue for Conecuh County as shown in Table 5-5 Projected Annual Waste Flow and Host Fee. By agreement with the Conecuh County Commission, a portion of the host fee (not to exceed an initial amount of $0.25 per ton) may be dedicated or earmarked by the Commission to target specific community needs and goals, including the clean-up of illegal dumps, promoting recycling, payment of disposal charges for the drop-off at the facility by County residents of a reasonable amount of personal household garbage, other community projects, scholarships, and other specific programs.

Per Capita Personal Income for Alabama Counties, Metros and Micros, 2000-2004, U.S. Department of Commerce, Bureau of Economic Analysis, April 25, 2006.

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In addition, once the facility reaches the 2,500 tpd operating level, the facility will match the Conecuh County Commission up to an additional $.20 per ton specifically for the implementation of either public or private County residential garbage services. TABLE 5-5. PROJECTED WASTE FLOW AND ANNUAL HOST FEE CONECUH WOODS, CONECUH COUNTY, ALABAMA
Year 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 TPD 250 500 750 1,000 1,500 2,000 2,500 3,000 3,500 4,000 4,500 5,000 5,500 6,000 6,500 7,000 7,500 8,000 8,500 9,000 9,500 10,000 10,000 10,000 10,000 10,000 10,000 10,000 10,000 10,000 10,000 10,000 10,000 10,000 10,000 10,000 10,000 10,000 Host Fee (per Ton) $1.25 $1.25 $1.25 $1.25 $1.25 $1.25 $1.25 $1.45 $1.45 $1.45 $1.60 $1.60 $1.60 $1.60 $1.60 $1.60 $1.60 $1.60 $1.60 $1.60 $1.76 $1.76 $1.76 $1.76 $1.76 $1.76 $1.76 $1.76 $1.76 $1.76 $1.94 $1.94 $1.94 $1.94 $1.94 $1.94 $1.94 $1.94 Annual Host Fee $89,375 $178,750 $268,125 $357,500 $536,250 $715,000 $893,750 $1,244,100 $1,451,450 $1,658,800 $2,059,200 $2,288,000 $2,516,800 $2,745,600 $2,974,400 $3,203,200 $3,432,000 $3,660,800 $3,889,600 $4,118,400 $5,270,980 $5,548,400 $5,548,400 $5,548,400 $5,548,400 $5,548,400 $5,548,400 $5,548,400 $5,548,400 $5,548,400 $5,005,000 $5,005,000 $5,005,000 $5,005,000 $5,005,000 $5,005,000 $5,005,000 $5,005,000 Development Fee $250,000 $250,000 $250,000 $250,000 $250,000 Cumulative Total $339,375 $768,125 $1,286,250 $1,893,750 $2,680,000 $3,395,000 $4,288,750 $5,532,850 $6,984,300 $8,643,100 $10,702,300 $12,990,300 $15,507,100 $18,252,700 $21,227,100 $24,430,300 $27,862,300 $31,523,100 $35,412,700 $39,531,100 $44,802,080 $50,350,480 $55,898,880 $61,447,280 $66,995,680 $72,544,080 $78,092,480 $83,640,880 $89,189,280 $94,737,680 $99,742,680 $104,747,680 $109,752,680 $114,757,680 $119,762,680 $124,767,680 $129,772,680 $134,777,680

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Year 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63

TPD 10,000 10,000 10,000 10,000 10,000 10,000 10,000 10,000 10,000 10,000 10,000 10,000 10,000 10,000 10,000 10,000 10,000 10,000 10,000 10,000 10,000 10,000 10,000 10,000 10,000

Host Fee (per Ton) $1.94 $1.94 $2.13 $2.13 $2.13 $2.13 $2.13 $2.13 $2.13 $2.13 $2.13 $2.13 $2.34 $2.34 $2.34 $2.34 $2.34 $2.34 $2.34 $2.34 $2.34 $2.34 $2.57 $2.57 $2.57

Annual Host Fee $5,005,000 $5,005,000 $6,091,800 $6,091,800 $6,091,800 $6,091,800 $6,091,800 $6,091,800 $6,091,800 $6,091,800 $6,091,800 $6,091,800 $6,692,400 $6,692,400 $6,692,400 $6,692,400 $6,692,400 $6,692,400 $6,692,400 $6,692,400 $6,692,400 $6,692,400 $7,350,200 $7,350,200 $7,350,200

Development Fee

Cumulative Total $139,782,680 $144,787,680 $150,879,480 $156,971,280 $163,063,080 $169,154,880 $175,246,680 $181,338,480 $187,430,280 $193,522,080 $199,613,880 $205,705,680 $212,398,080 $219,090,480 $225,782,880 $232,475,280 $239,167,680 $245,860,080 $252,552,480 $259,244,880 $265,937,280 $272,629,680 $279,979,880 $287,330,080 $294,680,280

Note: Based on 286 operating days per year (from prior report). 5.2.14.3 Economic Multiplier Effect -Economists typically consider the reverberation or recycling of money spent in an economy due to a new stimulus as what is commonly termed the economic multiplier effect. For example, each dollar spent on new wages to an employee at the facility may then be spent by that employee to pay for typical household expenses such as housing, food, medical, transportation or other expenses, and so becomes an additional dollar of revenue for another business in Conecuh County. Similarly, each dollar paid by the facility to other businesses for goods or services is an additional dollar of revenue to that business that may be used to pay employees, taxes, or for other goods and services from other businesses. And, each dollar paid to the local government in the form of additional real estate taxes or host fees may be spent by that government for wages, goods or services, and that then represents an additional dollar of revenue for another business. Consequently, each dollar spent as part of a new economic stimulus generates additional spending, which then multiplies the effect of the initial dollar spent and increases the total project

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value to the local economy. Past economic studies in Alabama have recommended using an economic multiplier of from three to seven times to measure this economic multiplier effect.2 In other words, a dollar spent could turn over as much as seven times, which is believed by many economists to be a fairly accurate measure of the impact spending on a new project has on a community. For the Conecuh Woods project, SCS has assumed the most conservative suggested economic multiplier of three. Also in the interests of making conservative projections, SCS has excluded from the jobs creation, economic benefits analysis and the economic multiplier calculation the millions of dollars in on-going construction activity that will take place at the facility over the years. Although some of those funds will be spent on out-of-county contractors, even they will spend some money in-county for food, lodging, supplies, and fuel and so will provide substantial additional economic benefit to Conecuh County businesses. The economic impacts to the local economy have been summarized and projected over the estimated 63-year operating life of the project in Table 5-6. TABLE 5-6. SUMMARY OF TOTAL PROJECTED COMMUNITY ECONOMIC BENEFITS3 DESCRIPTION
Payroll: Initial Construction Phase Initial Operations Phase Main Operating Phase Real Estate Taxes Development Fees Host Fees Direct Economic Impact Economic Multiplier of 3.0 Total Economic Impact ** $2,834,380 $5,149,960 $100,226,763 $3,150,000 $1,250,000 $293,430,280 $406,041,383 x3 $1,218,124,149

AMOUNT

** Total Economic Impact equals the product of Direct Economic Impact times the Economic Multiplier. For example, see Dr. Bill Wilkes, The Economic Impact of Athens State University of North Alabama, Athens State University, September 2002. . 3 Calculated in $ 2010 without escalators
2

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Summary: By combining a source of green energy from landfill gas and up to 500 acres of land with interstate and rail access, Conecuh Woods represents an opportunity for Conecuh County to participate in the green economy of the future and benefit from a second round of economic development with additional jobs and tax revenues from the development of an on-site business park. Assessing only the solid waste operations over a projected 63 year life of the facility, Conecuh Woods offers potential economic benefits to Conecuh County including: 1. 2. 3. 15 to 50 permanent jobs with up to a $500,000 to $2 million annual payroll. Over $295 million in total additional local governmental real estate taxes, development fees and host fees. Over $1 billion total economic impact.

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APPENDIX A ALABAMA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT PERMIT REQUIREMENTS

APPENDIX B CONECUH COUNTY SOLID WASTE MANAGEMENT PLAN SEPTEMBER 2004

APPENDIX C PROPERTY BOUNDARY MAP AND LEGAL DESCRIPTION

APPENDIX D SECTION 22-27-8 (FINANCIAL ASSURANCE) OF THE STATE OF ALABAMA SOLID WASTE DISPOSAL ACT

APPENDIX E ALABAMA TOMBIGBEE REGIONAL COMMISSION SOLID WASTE NEEDS ASSESSMENT NOVEMBER 16, 2003