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Terri Mercer <br /> 10j601 North She <br /> Li <br /> (2. <br /> Se e Ve'-r 7 1 <br /> Mike HugginsI ot_A�J�A <br /> San Joaquin County Public Health Services <br /> Environmental Health Division <br /> 304 E. Weber Avenue, Third Floor <br /> Stockton, CA 95202 <br /> Regarding- 90 day waiver of Notice to Abate, FW Cattle #2 <br /> SJCO Solid Waste Exemption, FW Cattle#2 <br /> Disposal of Solid Waste on Shelton/Wimer Road site <br /> Dear Mr. Huggins: <br /> The purpose of this letter is two-fold: to challenge the validity of the solid waste exemption for <br /> FW Cattle#2, and to register a complaint regarding the development of a landfill on the Wimer <br /> Road site. <br /> A) Solid Waste Exemption <br /> 1) The application for a solid waste exemption clearly states that resource recovery <br /> will occur through cyclic crop rotation type farming and that the waste will be <br /> incorporated into the soil mechanically. Neither has occurred. There is no resource <br /> recovery. Trucks have no "spread" apparatus; the land has not been tilled. <br /> 2) There is no vector control. <br /> 3) Court order mandates that the operator may not operate in such a manner as to <br /> cause vector or odor nuisances. Vector and odor nuisances have been documented. <br /> 4) WQCB letter is not valid, because it was based on the understanding of a small, <br /> minimal, or "reasonable" amount incorporated into the soil, and that cropping would <br /> occur. No waste has been incorporated into the soil (see attached picture SJCO), and there <br /> is no cropping. <br /> 5) Application states that cattle will not be fed cannery waste. See attached picture, <br /> cattle in SJCO spreading area during spread season. <br /> 6) You may not grant an exemption if more than one type of disposoj actvity exists <br /> on the site. Since the disposal of construction/demolition as well as cannery waste are <br /> occurring, the exemption must be revoked. Even with the waiver, the fact of at least two <br /> types of disposal exist. <br /> B) Landfill Development <br /> 1) More than one type of disposal exists on the facility. The facility encompasses the <br /> entire site - not simply the SJCO parcel. A Solid Waste permit is required. <br /> 1 <br />