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SHUTE M I HALY <br />&�WEINBERGERLLP <br />396 HAYES STREET, SAN FRANCISCO, CA 94102 <br />T: 415 552-7272 F: 415 552-5816 <br />www.smwlaw.com <br />June 15, 2012 <br />2 <br />Mr. Robert McClellon, Program Coordinator <br />San Joaquin County Environmental <br />Health Department <br />1868 East Hazelton Ave. <br />Stockton, CA 95205 <br />E -Mail: rmcclellon@sjcehd.com <br />PETER R. MILJANICH <br />Attorney <br />miljanich@smwlaw.com <br />Re: Illegal Landfill Activity on Proposed Forward Landfill Expansion <br />Site; Related Public Records Act Request <br />Dear Mr. McClellon: <br />This firm represents Clean San Joaquin, a group of citizens, farmers, <br />aviators, business leaders, and conservationists concerned with the adverse <br />environmental consequences associated with the operation of the Forward Landfill. <br />Members of Clean San Joaquin have recently observed, verified, and thoroughly <br />documented significant landfill activities on the proposed Forward Landfill expansion <br />site, outside of the existing landfill area. These activities include the land discharge of <br />cannery waste and the construction of an access road leading into the current landfill. <br />Jeannie La Forge of Clean San Joaquin informed County staff of these activities in mid- <br />May, yet it is our understanding that the County thus far has taken no enforcement action. <br />Forward Landfill's activities on the proposed expansion site are illegal. <br />They constitute clear violations of the landfill's Solid Waste Facilities Permit and Land <br />Use Permit, as well as the Land Conservation Act (Williamson Act, Government Code § <br />51200 et seq.) contract for the proposed expansion site. To the extent that these landfill <br />activities are the first step towards implementing the proposed landfill expansion project, <br />they also violate the California Environmental Quality Act (CEQA), (Public Resources <br />Code § 21000 et seq.) and CEQA Guidelines (California Code of Regulations, title 14 § <br />15000 et seq.) <br />