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4) inconsistency in reviewing incoming truck loads to the site; 5) located in a flood zone; 6) potential impact to endangered species; 7)proposed expansion plans not mentioned; 8)depth to groundwater and potential groundwater contamination; 9) current amendment would meet requirements for a modified solid waste facilities permit not a report of facility information amendment; 10)proposed project site is subject to the Agricultural Resource Management Zone; 11)cumulative impacts when combined with other anticipated development; 12)Williamson Act; 13) project site conflicting with existing or planned land uses and adopted plans. (responses to 12 and 13 will be discussed separately) Increase in landfill activities: The application is to amend the existing Solid Waste Facility Permit Boundaries only and update the landfill gas probe monitoring system. No landfill activities, waste placement, disposal, composting, storage_of equipment, or soil borrowing will occur on the 184 acres. No increase in current permitted daily tonnage or land refuse footprint will occur under this application. Conversion of 184 acres of prime agricultural farmland and growth inducing action: 184 acres of agricultural land is located southwest of the current permitted landfill site. According to the National Resource Conservation Service Land use capability classifications, the current soils classifications symbols for the project site are 180 (Jacktone Clay) and 250 (Stockton Clay), the Storie Index rating is 20 and 25, and the soils have Class III rating if irrigated or Class IV rating if non-irrigated. The 184 acres has been fallow for the last three years, prior to which it was used for growing alfalfa. Returns on the property have been less than $200.00 per acre and does not provide viable grazing land. Prime agricultural land as defined by the GC Section 51201 is any of the following: 1) Land qualifying for a Storie Index rating of 80-100; 2) Land qualifying for a Natural Resource Conservation Service land use capability Class I or Class II rating; 3) Grazing land capable of supporting at least one animal unit per acre; 4)Agricultural land that has returned at least$200.00 per acre for three of the past five years, or will normally return at least$200.00 per acre. Because the 184 acres does not meet any of this criteria this is not considered a conversion of prime agricultural farmland. Additionally, the proposed application is not a growth-inducing action because no increase in permitted tonnage or additional waste placement is requested with this application. Impact on nearby farms and residences from dust, odor and noise: The proposed request is to amend the current facilities waste boundary only and update the landfill gas probe monitoring system no additional landfill activities will occur in the 184 acres. The project area is sparsely populated with residences. The nearest residence is located at 9690 Austin Road and is located approximately 500 feet from the landfill. The dwelling is currently rented by Forward, Inc. and kept vacant. Two residences are located on Lynch Road, approximately 0.5 miles southeast of the site. In addition, two residences with surrounding ancillary structures are located on the east side of Austin Road, approximately one mile north of the main landfill structure. The existing Forward Landfill is currently permitted under Use Permit application UP-00-0007 and methods and procedures are included in the Conditions of Approval and Mitigation Monitoring Plan to reduce the potential impacts from dust, odor and noise. Inconsistency in reviewing incoming truck loads to the site: The proposed request is to amend the current facilities waste boundary only and no additional landfill activities will occur in the 184 acres. No additional increase in truck trips is permitted if this application is approved. The existing Forward Landfill is currently permitted under Use Permit application UP-00-0007. Under the current permitted operation as refuse is being unloaded, landfill staff inspects the loads for recyclable or prohibited materials. Additionally, Forward Landfill's "load-checking program," is designed to mitigate against hazardous waste being placed in the landfill. Landfill operators are trained to recognize and properly segregate and handle hazardous waste. San Joaquin County PA-100.02451Forward,Inc. Community Development Page 4