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CITY OF STOCKTON AZ# OFFICE OF THE CITY MANAGER CITY HALL 425 N. EL DORADO STREET ' r STOCKTON, CA 95202-1997 (209)S37-98211 2 �' 1994 Novemb(20,er ,) 16y l 49 --JMMUri11'r PLANNING San Joaquin County Community Development Department Development Services Division 1810 East Hazelton Avenue Stockton, Ca 95206 Attention: Kerry Sullivan PROPOSED GENERAL PLAN TEXT AMENDMENT GP-94-10 We have reviewed the proposed County General Plan text amendment which would establish a General Plan policy preventing sewage treatment facilities and sewage sludge and effluent disposal area serving uses outside the Delta Primary Zone from locating inside the Delta Primary Zone. While we understand that this proposed policy would not affect property within the incorporated city limits, it is the position of the City of Stockton staff that the public policy implications of this General Plan Amendment have not been thoroughly evaluated, and therefore, it should not be adopted. The language of the proposed amendment is so imprecise that it could prevent the use of recycled water and reuse of fully stabilized wastewater biosolids in these areas. The exclusion of the use of Recycled water in the Delta Primary Zone (as defined by Public Resources Code Section 29728) will not be in the long term best interests of the City of Stockton, Sa.n Joa. ui_ County, the State of California, or the environment of the Delta Primary Zone. Also, the amendment may be in conflict with and preempted by existing State law. The California Water Code in Division 1, Chapter 1, Section 100, states in part as follows: "because of conditions prevailing in this State the general welfare requires that the water resources of the State be put to beneficial use to the fullest extent of which they are capable...". Additionally, Division 1, Chapter 6, Article 2, Section 461, states that " It is hereby declared that the primary interests of the people of the state in the conservation of all available water resources requires the maximum reuse of waste water in the satisfaction of requirements for beneficial uses of water." City staff believes that excluding the beneficial use of recycled water from the Delta Primary Zone where appropriate is not the best use of a water resource and also is in direct conflict with the California Water Code. "ST^-.CKTCN...C aL: -Cr.�Jlr1'S SL;-%:=;1SE SSA =C%-+7"