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10 Mr. Harry Riddle August 25, 1981 San Joaquin County ale 2 This is especially important since throughout the report professional judgments are made with respect to the various identified impacts of the project. It is not possible to weigh the judgments without some knowledge as to the qualifications as those making them. Energy Considerations, page viii: As noted further herein, the Dra, EIR in discussing the potential for resource recovery fails to take iw consideration the resource recovery faces being developed for ti City of Lodi by its franchisee. The report is seriously deficient in il discussion of energy considerations by failing to integrate tt consideration of the proposed site with the current status of 0 operations of the City of Lodi, which need to be analysed thoroughly . conjunction with the proposal. In fact, as stated further herein, th ey is no current discussion of viable alternatives to this proposal . T� economic analysis which the EIR appears to rely upon (to wit, The Sol Waste Management Plan for San Joaquin County produced by Metcalf & Ed( in June of 1979) ensures that the Draft EIR is based upon stale dati Our information is that the economic data, including fuel costs and oth( energy considerations, which appear in the Metcalf & Eddy report, is z least 3-4 years out of date. It is no secret that significant changes economic conditions and energy markets have occurred in the interim. Vegetation, page 7: The last paragraph of this section indicates th deep7rooting plants could not be re-established upon completion of t landfill operations. The subject site in its present condition suitable to a high degree of agricultural development to vineyards a perhaps other deep rooted permanent crops, as illustrated by the prese development of many of the surrounding properties. Thus, it appears th the development of the landfill operations will permanently deny th I highly productive agricultural land of its agricutural potential, a fa not clearly stated in the report and inconsistent with the County poli to preserve its productive agricultural land base. I General Plan and Zoningpage 8: The EIR fails to note that the proposed use is inconsistent with both the General Plan and the current zoning. It also fails to note the statewide policy enunciated in Government Code Section 59212 that no public agency shall acquire prime agricultural land covered under a Land Conservation Contract for any public improvement if there is other land in or outside the agricultural preserve on which it is legally feasible to locate the public facility. Although subsequent sections of the Government Code may allow the County to negate this policy, the general statewide policy contained in Section 59212 should at least be brought to the attention of the decision makers with respect to this project.