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Draft Supplemental Environmental Impact Report Page VIII-74 Forward Inc.Landfill 2018 Expansion Project The Landfill is still operating under the existing Solid Waste Facility Permit that was in effect at the time of the Odor Survey.The types of wastes and the permit limits for disposal of waste and truck trips have not changed at the Landfill since the survey.The new development that has occurred since the Odor Survey was performed have no effect on potential odors from the landfill and landfill operations. They are potential odor receptors but have not filed any odor complaints per the response to the Public Records Request response(see preceding paragraph). Measuring odors is not an exact science. The Odor Survey was completed by individuals with expertise related to odors at multiple solid waste facilities and wastewater treatment plants,including experience for olfactometers, scentometers, chamber studies and flux studies.The approach and techniques are clearly outlined on Page IV.D-24 of the DSEIR and consist of moving to different locations and recording the odor observations. Furthermore,The Odor Survey was part of the 2013 EIR,which was certified by the San Joaquin County Board of Supervisors as complete and adequate. The proposed refuse area(8.72 acres)to the north is south of currently permitted refuse area and is also south of the existing landfill gas flare, existing landfill gas to energy (LFGTE)plant, and the existing groundwater treatment facility. The proposed refuse area to the north would not bring the facilities mentioned by the commenter closer to the landfill. The Landfill does have an established odor plan.The Forward Landfill Odor Control Management Plan is included in this FSEIR as Attachment 4 to this Response to Comment document. It was also included in the 2013 FEIR. Mitigation Measure IV.D.3 was left in the DSEIR because it was a Mitigation Measure from the 2013 EIR.The Forward Landfill accepts a wide variety of waste materials,including cannery waste from San Joaquin County's canneries. The SJVAPCD Guidance to Conduct Detailed Analysis for Assessing Odor Impacts to Sensitive Receptors(August 2016)4 details how lead agencies should conduct a detailed odor analysis.This Guidance was used in the odor impact analysis of the DSEIR. As stated in the SJVAPCD Guidance and on Page IV.D-23 of the DSEIR: "The District has established the following significance threshold for odor problems: • More than one confirmed complaint per year averaged over a three- year period, or • Three unconfirmed complaints per year averaged over a three-year period." The DSEIR followed SJVAPCD Guidance and the SJVAPCD indicated through a public records request that there were no odor complaint records on file for Forward Landfill since 2015(over the last three years). In addition,odors were not noted as an Area of 4 https://www.valleyair.org/transportation/GAMAQI-Detailed-Analysis-for-Assessing-Odor- Impacts-to-Sensitive-Receptors.pdf