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4. Martinez has already completed the design of the OWTS (dry well system) and has determined that 33 new wells are required. EHD Comments: During the meeting, it was discussed that the Percolation rates are required for this site due to the high repair rate. See comment#3 above and attached letter from EHD dated October 29, 2019. 5. Martinez also asked what alternatives the County proposed to a dry well system if the percolation rate did indeed reveal the same rate previously (60mpi) arrived at after three (3) separate tests? The County responded with stating that the Owner could install a Modular Decentralized Wastewater Treatment System. Martinez pointed out that the system is cost approximately $400,000 and that the requirement would bankrupt the Shady Rest Owner. Central Valley Septic also mentioned that a modular system does not currently exists anywhere in Stanislaus County. The installation of modular unit would an extraordinary hardship and put the Shady Rest out of business. EHD Comments: Consistent with San Joaquin County's Local Agency Management Plan (LAMP) approved by the Regional Water Quality Control Board, OWTS's in Mobile Home Parks are evaluated during times of repair to determine if OWTS should continue to be utilized or if a package treatment plant should be incorporated (Section 8:Areas of Concern, Variances, Prohibitions, Areas with High OWTS Density, Mobile Home and Recreational Vehicle Parks, Page 40, LAMP). 6. Martinez further pointed out that the Shady Rest is in negotiation to sell the subject project site (real property). EHD Comments: None. 7. The Shady Rest agreed to excavate to the 25' level and retest a percolation rate. EHD Comments: You stated a belief that the Percolation test would fail even if performed an additional time due to the clay soils. The contractor at the meeting and Michael Kith, REHS, Program Coordinator for EHD, recommended performing a deeper Percolation test because the contractor stated the soils around 20-25 feet would be more favorable for a Percolation test. When asked why you didn't perform the Percolation test at 20-25 feet when clay soils were discovered, you stated you thought the Percolation test would pass. The contractor stated he recommended performing the test deeper originally. 8. The Shady Rest also pointed out that the leach field has not failed. The Shady Rest seeks to prevent failure and had thus requested that a repair permit be issued in 2018. EHD Comments: The Onsite Wastewater Treatment System (OWTS) is not functioning properly at this site resulting in surfacing sewage complaints and permits to repair every 3-4 years. Existing permits for this site indicate there are more than 60 pits already on site, many of which appear to be beneath the mobile homes. Note: A new complaint of surfacing sewage at this site was received by the EHD on the day of this meeting. The complaint inspection verified surfacing sewage and found an air compressor hose running automatically connected to the septic tank. 9. The County did not issue a permit for repairs when requested in 2018 but rather transferred that matter to the Water Quality Control Board (WQCB). 3