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1 _ F. I have reviewed the U.C. Cooperative Extension handbook , <br /> 2 entitled Dairy Manure Management Series, which I understand was marked as <br /> 3 Exhibit 36 in the trial in People a. Kimbrough.. <br /> 4 G. , I also requested that the Kimbroughs test the soils at the Dairy t <br /> 5 verify clay content in order to make sure it complies with the 10% clay contert <br /> 6 requirement. Attached hereto as Exhibit 2 is a true and correct copy of a report from <br /> 7 Valley Ag Research showing sufficient clay content. <br /> 8 4. Based on the review described above, I am preparing plans for the <br /> 9 development of two additional retention ponds and other upgrades. Whert <br /> 10 completed, the plans will show existing facilities and how they will be modified. The <br /> 11 new ponds are intended to work in series with the existing pond. New pond No. 1 is <br /> 12 1.1 million cubic feet and new pond No. 2 is also 1.1 million cubic feet. When added <br /> 13 to the cubic foot capacity of the existing pond, which I estimate is approximate) <br /> 14 800,000 cubic feet (using a conservative approach), the aggregate pond capacity at the <br /> 15 Dairy will be approximately 3 million cubic feet. The newly-configured pond system <br /> 16 will operate as follows: new ponds Nos. 1 and 2 will be used as settling ponds <br /> 17 whereby manure solids will be allowed to settle out and the remaining liqui <br /> 18 transferred to the existing pond. The system will be set up so that the Kimbroug s <br /> 19 can alternate use of ponds Nos. 1 and 2 as desired. <br /> 20 5. In designing the newly configured pond system, I have calculated the <br /> 21 capacity which would ordinarily be necessary to contain manure water runoff from <br /> 22 the corral and milking barn for a dairy of this size. In making these calculations, I <br /> 23 have been told by Bruce Kimbrough that there are 620 milking cows, 75 dry cow, , <br /> 24 191 calves and 219 heifers. I have also taken into consideration the regulatory <br /> 25 requirements that the pond have sufficient capacity to contain: (a) a 25-year/24-hour <br /> 26 storm event; (b) all effluent from the corral and milking barn; and (c) rainfall <br /> S27 containment during the rainy season (using a 120 day rain season). The 120-day rain <br /> 28 season criterion is a conservative approach which would yield a large pond capaci <br /> " E 3 <br /> Declaration of Dan R Schack In Support Of Objections to Plaintiffs Proposed Statement of Decision <br />