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P.O.Box 37 NOV 0 4 2003 Clements,CA 95227 26 October 2003 ENVIRONMENT HEALTH PERMIT/SERVICES Mr. Robert McClellon San Joaquin County Environmental Health Department 304 E.Weber Avenue,Third Floor Stockton,California 95202 Subject: Good Earth Farms LLC Proposed Composting Facility PA-03000014(SA) Dear Mr.McClellon: I have become aware of a proposal by Good Earth Farms LLC to construct a composting facility at 23000 N. Johnson Road in Clements. To date,the information provided by the San Joaquin County Community Development Department has been sketchy at best and I have many concerns that must be answered before such a proposal should receive the approval of your department. I am sure you are aware that groundwater quality and quantity in San Joaquin are increasingly threatened. If permitted,this project poses a significant threat to our already severely taxed groundwater supplies and will likely impact surface water of Bear Creek. Without the use of engineered liners,stormwater diversion structures and sedimentation basins and strict controls on the management of operations and monitoring of leachate and surface water discharges the proposed project poses an unacceptable threat to water quality. Green waste,while it sounds benign,has been documented over and over again to contain other debris that can add metals,pesticides,petroleum products and possibly other chemicals to the composting material. How is the Clements community going to be safeguarded from these chemicals of concern if this project is allowed to proceed? Does your department,or some other county agency,have the resources to provide such protection? Composting operations can pose a significant fire hazard. The Clements community relies on our mostly volunteer fire department for our protection. This project will strain our already thin resources to protect ourselves from fires This project is proposed in an AG-40 zone under the guise of composting being an agricultural endeavor. Large scale composting such as this proposal is actually an industrial operation and is inappropriate for the area. The heavy diesel fueled equipment needed to manage and maintain a composting operation is not in keeping with the agricultural operations of the area. It is proposed to deliver the green waste to the Johnson Road site by truck. The increased truck traffic will exacerbate the already overused area roadways and will increase diesel emissions further decreasing air quality. The San Joaquin Valley Unified Air Pollution Control District has failed to meet federally mandated air quality standards and this proposal will only make it harder to do so unless strict emission controls are placed on the industrial equipment and trucks. Thank you for your consideration. Please contact me at(209)759-3056 to discuss my opposition to this project. Xery truly yours, n' n ^ �c �-" Tom Sicklei cc: Supervisor Sieglock Rick Griffen,San Joaquin County Community Development Department c.'doc t aM aeaingaVaiekWa laellii Vampoiaiyk Met MWON33Nbmen19 Pel em(Nhl.tl