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11 <br />Caroll Mortensen <br />January 13, 2012 <br />Page 6 <br />The 184 acres that would become part of the landfill facility, as <br />contemplated by the SWFP Revision, is agricultural land and is currently under <br />Williamson Act Contract. See 2010 DEIR at IV.A-2,4. The SWFP ND suggests that <br />impacts to agricultural lands would not be significant because, "expansion into the <br />undeveloped southwest area of the current permitted landfill site is not permitted at this <br />time and no increase in waste placement will occur under this proposed application..." <br />ND at 7. <br />As we explained above, this boundary relocation is the first step toward the <br />expansion of the Class II refuse footprint. Consequently, the SWFP Revision will result <br />in the conversion of these 184 acres of agricultural lands to industrial uses. The 2010 <br />DEIR confirms that the conversion of this agricultural land is a significant impact <br />requiring the identification of feasible mitigation measures. 2010 DEIR at IV.A-16. <br />Inasmuch as the 2010 DEIR has not been certified, the Project's clearly significant <br />impact on agricultural lands remains unmitigated. <br />In addition, the significant loss of farmland that would result from the <br />SWFP Revision would contribute to the cumulative loss of agricultural land in San <br />Joaquin County and the Central Valley and would conflict with the San Joaquin County <br />General Plan's goals and policies calling for the preservation of agricultural land. See <br />2010 DEIR at IV.A-16. Neither of these impacts is addressed in the SWFP ND, nor have <br />mitigation measures been identified. <br />Again, we urge Calrecycle to deny the SWFP Revision until such time as <br />an EIR is prepared that adequately analyzes and mitigates the Project's impact on <br />agricultural resources. <br />B. THE SWFP Revision Would Allow the Facility to Operate Ten <br />Additional Sundays Per Year and the Environmental Impacts <br />Resulting From These Operations Have Not Been Adequately <br />Analyzed. <br />The SWFP Revision calls for Forward to increase the number of Sundays <br />that the landfill would operate from 10 to 20 Sundays per year. The SWFP ND does not <br />even acknowledge this proposed change in operations. Because the SWFP Revision <br />would allow the landfill to operate on additional Sundays, the environmental impacts <br />associated with these increased operational levels must be thoroughly examined. <br />SHUTE I MIHALY <br />--P <br />