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Bird Control Program Forward Landfill—Manteca, California bird control program, observations are made by an independent observer as an added oversight. The independent observer noted two cases on Thursday, February 7, 2013 where gulls began feeding at the active face. In both cases, the gulls were able to begin feeding but were deterred by the control program prior to reaching the site-specific failure criteria'. Forward staff was notified regarding the gull incidents. Based on discussions with landfill staff, it appears that the position of the active face may have prevented the controllers from observing the gull landings. The controller was notified of this incident. Measures taken to deter future gull landing and _ feeding included requiring the controller to monitor areas that may be screened with the support of landfill staff in constructing additional access roads. Therefore, given the limited number of incidents and the responses to the observations noted above, the control program continues to be _ successful. Gulls Approaching the Landfill and Flying Past the Landfill _ The falconer conducting the gull control documented the numbers of gulls that approached and flew past the landfill. These observations are presented in Appendix 1 and summarized in Table 1. It is important to correctly interpret the data in Table 1 and Appendix 1. The numerical estimates of daily numbers of gulls are not estimates of the numbers at the landfill or even the numbers approaching the landfill. Many of the gulls in the totals were birds that flew past the landfill without visiting it. The numbers of such gulls were usually higher during the influxes of migrants and during periods of stormy weather that drove the gulls inland from the coast. Over the three years of the study, the number of flocks of gulls that approached or flew past the landfill ranged from 6.3 to 11.8 per day during the November-March period in each year, or a little over one flock per hour. The average flock size ranged from 7 to 21 birds during each of the _- three years. These are very small numbers when compared to the large numbers that used to feed at the landfill before the control program began. The results indicate that the gull flight lines from gull night roosts in the delta or on San Francisco Bay no longer passed over the airport on route to — Forward Landfill but rather had moved further north en route to Foothill and North County landfills. Observations by LGL Personnel V LGL personnel conducted spot checks at the Forward Landfill. There were 9-11 visits per month and each visit was about 3 to 3.5 hours long. During the periods 1-10 October 2012 and 15 April-15 May 2013, the LGL biologist was present on the site for 6-6.5 hours on 8 and 21 days, respectively during which he performed gull control using a model airplane glider. The results of all of these visits are presented in Appendix 2 and summarized in Table 2. — The data gathered by the LGL personnel were consistent with the observations by the falconers on the same days (Table 1). In fact, the falconers generally recorded more birds because they were always searching for distant gulls approaching the landfill and they were on site earlier in the morning when more gulls approached the landfill. Therefore, it is again concluded that the data collected by the falconer/controllers are reliable and unbiased. — Letter from LGL Limited to Lewis Engineering dated June 21,2012. Min 5 30 December 2013