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STATE OF CALIFORNIA - GRAY DAVIS.Governor DEPARTMENT OF FOOD AND AGRICULTURE WILLIAM MILL)J.LYONS,JR.,Secretary 1220 N Street, Room 452 Sacramento, CA 95814 Phone: (916) 653-5658 Fax: (916) 657-5017 January 29, 2003 _ JAS 0 2003 Ms. Leanne Mueller CcmmUi tyUEV e/oPm0nt UePt San Joaquin County 1810 East Hazelton Avenue Stockton, CA 95205 Dear Ms. Mueller: Subject: Notice of Preparation (NOP) of a Draft Environmental Impact Report (DEIR) for PA-0200065 (sand and gravel mine) - SCH #2002122122 The California Department of Food and Agriculture (CDFA) has reviewed the NOP for the proposed sand and gravel quarry (PA-0200065). CDFA's mission is to protect and promote California agriculture, including the natural resources upon which agriculture depends. From this perspective, we offer the following suggestions for your preparation of the DEIR. The proposed project is a 60-year mining and reclamation plan for 688 acres near Vernalis in Southwestern San Joaquin County and northern Stanislaus County. The site is mapped as Prime Farmland and Farmland of Statewide Importance by the California Department of Conservation. California Land Conservation (Williamson) Act protects two parcels of unspecified acreage within the project site. The initial study accompanying the NOP acknowledges that the loss of farmland as a result of the project will be a significant environmental impact. The document goes on to discuss partial mitigation of the impact through the payment of an agricultural mitigation fee. We concur with the initial assessment that the project will significantly impact agricultural land. We also agree that the use of mitigation fees can help to offset the impact, but only if the fees are used to create new farmland of equal quality or increase the protection or productivity of existing farmland. Towards that end, we recommend the use of mitigation fees for the acquisition of agricultural land conservation easements on equal quality, and at least equal quantity land as that converted or impaired by the project. This strategy is particularly applicable to mitigating the cumulative impacts of a project by removing agricultural land from the pool of available agricultural land for future conversion. We recommend that the DEIR document the project's agricultural setting by using information from the San Joaquin County Soil Survey, the California Department of Conservation's Farmland Mapping and Monitoring Program, and the San Joaquin County Agricultural Commissioner's Annual Crop Reports. The setting should also include tabular and map information on the presence of Williamson Act protected lands.