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In the September 23, 2003 Conditions of Approval Document from EHD, Item "I" states that"The EHD is recommending the installation of monitoring wells for ongoing monitoring of nitrates, Total Dissolved Solids, etc. The final determination of the installation of these wells and the monitoring required is subject to Central Valley Regional Water Quality Control Board approval." It is our opinion the sampling, analysis and ongoing monitoring of the cropland soils is the beginning of groundwater and surface water protection. The very nature of soil and irrigation _ water testing makes these analyses imperative for the prevention or mitigation of groundwater and surface water contamination. Monitoring wells monitor"after-the-fact,"or in other words' ; impact may have occurred and/or continues o occur, wi or without land surface nutritional . adjustments being made immediately, or in"real time." Finances that may be spent on groundwater monitoring may be better used for analyzing all the applicable media to prevent groundwater and potential surface water contamination. Therefore, we are recommending a surface monitoring program, that includes the following: Before the planting of a crop, the soil of a representative field area should be individually analyzed. This field size is typically taken to be 40 acres. The field numbers that may be used to denote a sampling area are designated in the top right-hand corner of the Site Plan for the Home Ranch and the Site Schematic for the Acampo Ranch. Individual media to be analyzed during each growing season include: Beaver Slough irrigation water Nutrient water from holding pond Blended irrigation water immediately before land distribution Cropland soil Manure solids before export IUbtoaddition to the above analyses, the wells that were tested for this Technical Report can continue e monitored on a periodic basis. The procedures for determining crop nutritional needs, particularly nitrogen, without overloading the cropland can be a complex process. In an effort to simplify the information required to make best management decisions for optimum crop growth and nutrient utilization, we are recommending the Manure Analysis Reference Guide from U.C. Davis to be used in conjunction with the analyses obtained on the tested media. The suitable rate of solid and liquid applications is determined by the ability of the soil and crop combination to immobilize and utilize the nutrients in the applied manure nutrients. In addition, direct visual observation and monitoring will continue to be done during irrigations so that proper water volumes are applied with minimal runoff. Results of the domestic well testing reveal that the North domestic well at the Home Ranch and the domestic well at the Acampo Ranch contain nitrate concentrations over the Maximum Contaminant Level (MCL). Bottled water for drinking and cooking purposes is being provided for the de Snayer Dairy employees who rely on these two wells. It must be recognized by the general public that the dairy operates in a predominately agricultural region where related agricultural operations such as odors, dust, flies, pesticide/nutrient water applications and truck traffic are going to occur. The results of these studies are founded on current scientific knowledge to assess factors that are extremely variable and complex, and can change at any point in time. -23 _J// - Chesney Consu(ting