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Legal Document
PDF downloads:

BLM- ESCMP Volker protest1-7-08.pdf

ESJ-County Scoping comments 3-27-09.pdf

CNF - hunter -Sunrise 7-09.pdf

Volker- letter to CNF- Sunrise Powerlink 7-9-09.pdf

ECO Sub - Volker protest 9-14-09[1].pdf

Volker-Forest Plan ruling and Sunrise 10-8-09.pdf

Volker_BLM & FWS_10-8-09[1].pdf

ESJ-Filner oppostion letter 11-6-09.pdf

ESJ-Volker to Pell DEIS scoping 11-18-09.pdf

Volker to SWRCB-Sunrise 12-14-09.pdf

Private landfill developer: BLT Enterprises is the current developer and proposed operator for the Campo Landfill. BLT is a recycling company that has never built or run a landfill before. See their homepage at: A sublease agreement between BLT and a tribal chartered corporation, Muht Hei, Inc., to construct, operate, and close the Campo Landfill, was authorized by a tribal vote on December 12, 2004. Find more on Muht-Hei at:

Size of the leased area: The entire lease area encompasses 1,150 acres. The landfill footprint is a reported 493 acres. The lease area abuts approximately 24 private properties on the east, south and southwest, and is in close proximity to several tribal residences to the northwest.

A new 300 acre well field is proposed for a projected 14 new water wells to provide the estimated 37,000 to 72,000 gallons of groundwater per day needed to construct and operate the proposed landfill. Most of the well field is located outside the official Leased Area which raises concerns on whether or not it is covered under this NEPA environmental review process and future monitoring and mitigation requirements. These new project wells could negatively impact water quality and quantity at wells serving adjacent tribal and off-reservation properties.

Proposed daily disposal rate and waste source: 3,000 tons per day can be accepted at Campo. The annual disposal is rate 1,095,000 tons per year. However, no waste stream or source has been identified. BLT has indicated a "build it and they will come" attitude. BAD's research, through the Public Records Act and direct communications, confirms that no cities in the San Diego County region are either considering or negotiating to send their waste to the Campo Landfill. The fact that neither the local cities, or the major waste haulers, plan to dispose of their solid waste at this facility, raises concerns that BLT will focus on bringing in special waste and sewage sludge. Special waste and sewage sludge contain much more dangerous components representing much more risk to priceless groundwater resources and air quality.

Total physical capacity: 43.7 million cubic yards or 29.5 million tons.

Estimated site life: 31.5 years of active life is estimated. Once closed, the landfill will continue to stew and spew noxious gases and toxic liquids into our air and water for many decades into the future—long after our lifetime.

Transport of unidentified waste sources will be exclusively by truck instead of by rail. The use of rail haul is no longer included. All waste will now be long-hauled from unidentified waste generation areas via trucks which increases greatly green house gas emissions. The waste would most likely come from areas that rely on imported water sources for burial over our only source of water.

Access road: Waste haulers will be directed to use I-8 to Church Road (BIA 10). Church Road between Historic Rt. 80 and Hwy 94 is already paved, but needs to be partially re-engineered and upgraded to accommodate the heavy truck traffic that it was not originally designed to handle. A loop diversion to bypass the entrances to the Campo Education Center (with day care) and the Campo tribal administration buildings, will need to be designed and constructed. The diversion will do nothing to stop the increased truck exhaust emissions, traffic impacts, and noise for tribal businesses and residents both on and off the reservation. BIA 10 south of Hwy 94 is currently a dirt road. This section will need to be engineered and paved with a new crossing at Campo Creek. The DSEIS proposes a less expensive Arizona crossing with a culvert. The previously approved bridge is no longer under consideration. The Army Corps of Engineers will have a say in this and other surface water issues once they determine they have jurisdiction.

The recycling and composting components are no longer included.
BLT, The private developer whose main business is recycling, has opted to remove the recycling and composting aspects of this project. Without a recycling component, where will the waste be screened to pull out hazardous materials that are supposed to be denied disposal here?

The Property Value Protection Agreement is no longer being offered to impacted property owners. The previous Record of Decision for the Final EIS included a voluntary 20-year agreement, with Mid-American Waste Systems, to purchase impacted properties at fair market value plus 10%. The agreement included preliminary well testing, ongoing monitoring, and if the landfill contaminated the water, an alternate source of water would be provided equal to the historic use of the property. The alternate source of water was never identified or certified, but the previous agreement offered some form mitigation that is now lacking. There does not appear to be any enforceable mitigation offered to impacted tribal members either.

Landfill location impacts federally designated Campo/Cottonwood Creek Sole Source Aquifer: The landfill lease area is on a hillside at the headwaters for Lower Campo Creek at the southern end of the Campo Reservation and is abutted on three sides by private property. Surface and groundwater flow in many directions. The proposed landfill site is south of Highway 94, west of Tierra Del Sol Road, 1/4 mile north of the Mexican border near ejido Jardines Del Rincon. It is adjacent to BIA Route 10 that runs north/south from the Campo Tribal Hall to the Southwest Powerlink near the Mexican Border. The site is approximately 70 miles east of San Diego. Most notable is the fact that this landfill for noxious garbage, sewage sludge and special waste will be located atop our federally designated Campo/Cottonwood Creek Sole Source Aquifer. This is where all of our well water comes from. BAD applied for and was granted the Sole Source Aquifer designation in 1992. The designation was not granted until 1995—after the feds approved the landfill EIS. The Boulevard/Campo area has no access to imported water now and none is expected in the future. Our area is highly fractured bedrock which is incredibly susceptible to contamination and extremely difficult, if not totally infeasible, to monitor for problems. The unconfined nature of our fractured bedrock aquifer means that the direction and flow of contamination from the area cannot be determined and can travel very long distances, at rapid rates in unknown directions, without being intercepted or detected by limited monitoring wells and equipment. Once contaminated, it would be virtually impossible to clean up or replace. Both the US Environmental Protection Agency and the Army Corps of Engineers have expressed similar concerns with this landfill site. Other professionals, and staff for various agencies, have also expressed serious concerns over negative impacts to groundwater quality. See the history page for more details.

Campo Landfill designed to Hazardous Waste Landfill standards: A dual liner system is proposed with a leachate collection and removal system. An underlying leak detection system is also proposed. The current developer, BLT Enterprises, has applied for site-specific waivers to change several aspects of the landfill design, including a reduction in the clay liner from 20 feet to 5 feet, a change in the daily cover, a change in the final landfill cover, a waiver for placing the landfill in an earthquake zone, and more. The USEPA will make the final call on those waiver requests and whether or not they comply with the National Environmental Policy Act (NEPA) regulations. The waiver requests are included as part of the Supplemental Environmental Impact Statement—something that BLT reportedly did not want to happen.

The United States Environmental Protection Agency admits that all liners eventually leak due to damage, failed seams, flaws, stress, and deterioration. When this one fails it will leak into our highly fractured bedrock aquifer and into our wells, springs, and streams. According to Dr. David Huntley, Professor of Geologic Sciences at San Diego State University, contaminants will then travel through water-bearing fractures to private domestic wells, some as close as 1,800 feet, at unknown rates and in unknown directions. Dr. Huntley, who studied the landfill as a paid consultant for Mid-American Waste Systems, the previous developer, wrote letters warning that contamination could travel at a rapid rate, reaching some off-site wells in a matter of days. BAD has hired experts to challenge the proposed liner system.

Noxious air emissions will also result in the flaring of methane gases generated by the stinking rotten garbage, sewage sludge, and the transport of waste to the site. The Final Environmental Impact Statement claims the site will be a Class III (municipal solid waste) landfill but it will be designed to Class I (hazardous waste) standards. Although tribal leaders in the past, most notably Michael Connolly, Ralph Goff and H. Paul Cuero, Jr., have claimed this will not become a hazardous materials disposal site, one has to wonder just exactly what types of waste will ultimately be accepted. If contracts for municipal waste do not come to fruition, will the landfill morph into a disposal site specializing in sewage sludge and/or other types of more hazardous industrial waste? In November 2002, Campo Resource Recovery (Bryan Harrison and Ralph Petruzzo) sent out a request for proposals specifically stating that the Campo Landfill is currently permitted for 3,000 tons per day of MSW, bio-solids and special waste. MSW stands for Municipal Solid Waste and bio-solids is a nice way of saying sewage sludge. The North American Free Trade Agreement (NAFTA) also requires that US companies, doing business in Mexico, export their more hazardous materials to the US for disposal. There are allegations, and some documentation, that a hazardous materials disposal site already exists on the Cahuilla Reservation without a proper lease or permits and despite several Cease and Desist Orders from the Bureau of Indian Affairs. This information comes from trusted tribal sources on other San Diego County reservations that have taken action to close the site, and raises concerns for the proposed Campo Landfill.

Types of waste that could be accepted: Municipal garbage, sewage sludge, petroleum contaminated soils, dead animals, shredded auto fluff, and small amounts of hazardous waste that slip in with regular waste such as batteries, paint, used motor oils, household cleaning products and insecticides. Sewage sludge contains what are referred to as emerging contaminants, which include pharmaceuticals and other chemicals that go undetected and unregulated in the filtration process. These contaminants can cause serious health impacts, endocrine disruption, and various cancers. All these items co-mingle and create a toxic soup that is called leachate. It is this contaminated liquid that poses a very real threat to our domestic wells and the health and well being of impacted families and livestock. The decomposition of waste also generates copious amounts of methane, a green house gas which is 20 times more damaging to the atmosphere than carbon dioxide, which gets the most attention during climate change discussions.

Leachate Ponds: Leachate ponds will be constructed to hold the contaminated liquid produced by the decomposing waste and sewage sludge. The leachate will reportedly be recirculated through the landfill on a regular basis including through dust suppression on dirt roads within in the landfill footprint. Concerns have been raised that the leachate ponds are not properly designed or located, they are too close to the proposed well field, they will be prone to overflow during wet years and significant storm events, and evaporation of the leachate from the ponds and the on-site use of lechate will add to project related air quality impacts.

What's Happening Now | Who is BAD and how can you help? | Description of the new Campo Landfill
History of the Campo Landfill | Contact Elected Representatives | Sunrise Powerlink and Industrial Wind Energy
Local, State, and Federal Issues
| Recycling Resource Guide