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Doug and Erika Robinson P.O. Box 771 21624 Johnson Road Clements, C 5227 RE May 21,2003 NAY 2 7 2003 ENVIRO pER � rNJiff �I San Joaquin ERVCES Community Development Department Development Services Division 1810 East Hazelton Avenue Stockton, CA 95205 RE: Application no PA-0300014 (SA) Dear Mr. Griffen, Last March,we sent a letter voicing our opposition to the composting application referenced above. The applicant, Good Earth Farms LLC, is seeking a permit to operate an on-site composting facility.After doing more research on composting permitting and operations,we are still not convinced this project is safe, as we will explain. The Leachate Control Plan that accompanies the revised permit application states that during rainstorms all "runoff will be infiltrated and retained within the vineyard."The proposed site drains directly into the floodplain and into Bear Creek. Bear Creek bisects the vineyard and almost every year most of the vineyard floods during the heaviest rainstorms. All the runoff water eventually ends up in Bear Creek. It would be difficult to retain the leachate to the vineyard as proposed. Since most of the vineyard is located in the floodplain, it's not clear whether composting is a safe alternative at all (more on that below). Another concern is from pesticides in the compost feed material. Enclosed is an article, "Clopyralid and Composting",which is just one example why soil testing should be done. Measuring nutrients and heavy metals (as shown in the applicant's proposal)is not enough—it's the chemical toxins and pesticide residues in the yard waste that will leach into the groundwater supply. Chlopyralid is only an example— there are many other toxins present in yard waste recycle material that will be part of the leachate from the piles. As a further sanity check on this, we are including a compost site analysis checklist prepared in a report funded by the State of Washington and the US Department of Commerce's National Institute of Standards and Technology'. The purpose of this study was to establish standards for site selection and safe operation of composting operations. The site evaluation form is pertinent relative to Good Earth Farm's compost application. Site selection categories are listed in the left column, each of which is assigned a score, then weighted relative to that category's potential environmental impact. Two categories, "Environmental" and "Groundwater", indicate that a low score indicate that the site should not be considered for a composting operation. It's worth mentioning that prior to planting vines, the bedrock was located 1-3'below the surface. Although the ground was ripped, the calcites and silicates in the bedrock are still intact, giving the"Groundwater" category a failing rating (see scoring key for further explanation). The"Environmental"category also receives a failing mark. This site is well within the 100-year flood plain (see photos supplied to the County in March of this year), and is still within 200' of vernal pools located on the adjacent property. 'The entire report can be viewed on the WEB at http://www.mc.org/organics/organic_htnns/cnn976rpt.htm