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11 <br />TE M I HALY <br />. &--WEINBERGERLP <br />396 HAYES STREET, SAN FRANCISCO, CA 94102 <br />T: (415) S52-7272 F: (41 S) 552-5816 <br />www.smwiaw.com <br />December 23, 2013 <br />Via E -Mail and FedEx <br />Mr. Ross Atkinson <br />Regional Water Quality Control Board <br />Central Valley Region <br />11020 Sun Center Drive, Suite #200 <br />Rancho Cordova, CA 95670 <br />E-mail: Ross.Atkinson@waterboards.ca.gov <br />PETER R. MIL)ANICH <br />Attorney <br />miljanich@smwlaw.com <br />Re: Waste Discharge Requirements for Forward Landfill <br />Dear Mr. Atkinson: <br />On behalf of Clean San Joaquin—a coalition of citizens, farmers, aviators, <br />business leaders, and conservationists concerned with the adverse environmental <br />consequences associated with the operation of the Forward Landfill -we submit these <br />comments regarding the proposed Waste Discharge Requirements Tentative Order for the <br />Forward Landfill ("WDRs"). Clean San Joaquin requests that the Regional Water <br />Quality Control Board ("Water Board") prohibit disposal of cannery rinse water into the <br />compost facility and require Forward Landfill to implement additional measures to <br />mitigate the significant effects of the Landfill's proposed cannery waste operations. <br />These additional mitigation measures are referenced in the May 2013 Final <br />Environmental Impact Report ("FEIR") for the Forward Landfill's proposed expansion <br />project, on which the WDRs rely, but are not included in the proposed WDRs. These <br />mitigation measures are critical to ensure that the adverse impacts from the Landfill's <br />cannery waste operations do not harm the environment and those who live and work <br />nearby. <br />I. Forward Landfill's Cannery Waste Operations Have the Potential to Harm <br />the Landfill's Neighbors and Threaten the Environment. <br />Numerous agricultural operations and nearly 50 residences are located <br />within one mile of Forward Landfill's borders, and a large correctional facility lies just <br />