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SHUTE, MIHALY <br /> C4 EIN ER E LLP <br /> 396 HAYES STREET, SAN FRANCISCO, CA 94102 PETER R. MILJANICH <br /> T: (415) 552-7272 F: (415) 552-5816 'Attorney <br /> www.smwlaw.com miljanich@smwlaw.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 /> 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 />