A landfill proposed for ground west of Marana constitutes "an inappropriate land use in a sensitive flood area," Pima County Administrator Chuck Huckelberry indicates in an April 6 memorandum to the Pima County Supervisors.
While the county can tell its concerns to the Town of Marana regarding the landfill, "a decision regarding this land use proposal remains in the exclusive control of the town," Huckelberry writes. "If the proposed landfill site is located in the county and if the county was involved in the decision-making process, our recommendation would be to reject the proposal."
Huckelberry's summary, and an accompanying document that compares the Marana site with the approved Durham Regional Landfill in southern Pinal County, was due for presentation to the supervisors on Tuesday. On Tuesday night, the Marana Town Council was slated to hold an annexation hearing on 1,200 acres of land that includes the proposed Marana Regional Landfill parcel.
With that Marana annexation process proceeding, "it is likely Pima County will have little, if any, influence on the decision to approve the proposed regional solid waste facility other than to indicate it is an inappropriate land use in a sensitive flood area," Huckelberry said.
In a comparison of the Durham Regional and Marana Regional landfill sites, the county analysis indicates the Marana site is within a Federal Emergency Management Agency special flood hazard area, which means "FEMA floodplain requirements must be addressed." The site contains "field-verified riparian habitat" that must be avoided "unless reasonable justification for impacts can be provided."
Huckelberry writes "the most questionable technical feature of the landfill location is its adjacency to major watercourses." Arizona law precludes location of major solid waste facilities within one-half mile of a major watercourse, in this case the Brawley Wash, with a 100-year flood discharge value of 25,000 cubic feet of water per second, according to the memorandum.
"This site is upstream and immediately adjacent to such a watercourse; it is separated by a divided drainage course," Huckelberry writes.
Michael Racy, the consultant representing DKL Holdings, the company that wants to build the Marana Regional Landfill, said Monday DKL's engineering company, "a firm with as much experience with landfills as anyone, is comfortable we can meet that permitting requirement" regarding the floodplain.
"That's a requirement of getting a solid waste facility permit," Racy said. "If we can't satisfy it, it can't go forward.
"We've been in consultation with the town and the county for months on that, but ultimately it's the Arizona Department of Environmental Quality and FEMA that determine if we satisfy it or not," Racy said.
The county document expresses concern on the height of the Marana landfill: "approximately 230 feet above the average ground level … more than five times the height of the existing Tangerine Landfill," and half the height of the remaining Twin Peaks summit.
Racy said the current plan calls for a 50-year landfill topping at 195 feet above the current "reference" elevation west of Marana.
"Our facility, at 30-35 years out based on projections, will be around 100 feet," Racy said. "That's a height somewhat consistent" with the City of Tucson's Los Reales landfill, "and taller than Tangerine, but not enormously so."
The county has concerns with the pace of approval for a landfill in Marana. Approval of the Durham Regional Landfill by Pinal County took more than 18 months.
"It would appear the Marana Regional Landfill … may take less than six months," its analysis shows. "It would appear the Marana Regional Landfill is on a fast-track approval process. Action by the Marana Planning and Zoning Commission to approve the project without further technical input and information, which was suggested at their public hearing, would seem to confirm such."
"It's not on a fast track," Racy replies. "Enormous technical information was presented at the planning commission. To date, there has been not a single comment that there has been any lack of quality in any of the engineering reports or studies."
Racy said DKL Holdings "spent months before filing the specific plan doing an enormous amount of engineering and technical review to ensure we did have that detail. It was included in the specific plan, as is customary, and we have followed the absolutely normal, customary time frame, which has been longer than all the required statutory notice periods."
Is the Marana site moving faster than the Durham Regional Landfill site?
"Yes," Racy said. "Durham was in the shadow of a state park in a remote location with no infrastructure to access it, which I'm assuming gave rise to all sorts of questions that are not comparable to this project. Similarly, Durham took a year to submit their second submittal after receiving comments on their first submittal. We took 10 days, because we were thorough, because we were prepared, not that anything was rushed, but because we had already done the work."
In their March 30 report to Huckelberry, Pima County Department of Environmental Quality director Ursula Kramer and planning official Arlan Colton indicate the Marana site is one-half mile south of a Tucson Water well that serves 250 customers. That well is "not in a downgradient direction" from the landfill site, according to the county's analysis. A second area, with two Tucson Water Wells serving 3,100 customers, is two miles west of the site "and is directly downgradient."
The Marana site is 200 feet above groundwater, with a water table rising at a rate of about four feet a year, according to the county report.
"We have very slow water migration, and our depth to groundwater is in the same ballpark, 200-300 feet, which is enormously over any regulatory requirement," Racy said.
Huckelberry's memo suggests Marana has not addressed "the site development conditions that can and will be imposed … if the site is approved.
"Pinal County spent 18 months in a public process in determining the acceptability of the proposed Durham Landfill site, and then imposed very significant and stringent site development standards and requirements," the memo reads, "including offsite mitigation and financial contributions to Pinal County through a development agreement.
"It is unclear if these standards and requirements will be imposed on the developer of the Marana Regional Landfill," it continues.
Pinal County would receive fees of $1.25 per ton for the first five years, rising to $2.50 per ton in years 41 through 50, for trash deposited at the Durham Regional Landfill, according to a Pima County comparison. Pinal County estimates fees could amount to $25 million over the life of the project.
A host fee for the Marana Regional Landfill is being negotiated, Racy said. Its initial fee is "a figure in the same range" as the Pinal number, he said. "It's subject to the overall, final approval of the project," with variables yet to be determined and in fact influencing the final numbers.
"That's one of the reasons this is moving along," Racy said. "The developer is very, very experienced in solid waste, and the engineering firm is very, very experienced."
Pima County residents near the landfill site continue to express their concerns to the Marana Town Council. At last week's meeting, residents Joan Travis-Triumph, Jens T. Hill, Richard Swartz, Charles Goddard Jr., and Steve Storzer told the governing board of worries regarding drinking water contamination and flooding potential.
Rep. Grijalva urges landfill delay
Rep. Raul Grijalva has expressed his concerns with a proposal to develop a commercial landfill on property currently west of Marana, urging town officials to "take the necessary time to conduct a proper assessment of the environmental, health, and safety impacts."
In a March 24 letter to Marana Mayor Ed Honea — referred to as "Monea" in the Grijalva piece — and Town Manager Gilbert Davidson, the representative from Arizona's Seventh Congressional District points out the Avra Valley site is "located on Tucson's largest aquifer," with rising water levels and "a substantial potential for contamination."
The landfill site could also be in a floodplain, the Democrat writes, and he raises concerns about the effects of a landfill on Marana Regional Airport, which is some 2-1/2 miles away.
The Marana Town Council considers an annexation application Tuesday night for 1,200 acres of land immediately west of the town limits. Developer DKL Holdings proposes the landfill for a portion of that ground.
"Given the large number of concerns with this project, I urge the city of Marana to delay further action on the landfill until the potential environmental, safety, and health consequences have been fully researched and deliberated," the Congressman concludes.
Grijalva copied his letter to the Pima County Board of Supervisors and county administrator Chuck Huckelberry. It was not copied to the Marana Town Council.