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SAN JOAQUIN FARM BUREAU FEDERATION <br />MEETING TODAY'S CHALLENGES /PLANNING FOR TOMORROW <br />29,4-,404 <br />January 13, 2012 <br />Ms. Carroll Mortensen, Director <br />C/O Kevin Taylor <br />California Department of Resources Recycling & Recovery <br />P.O. Box 4025 <br />Sacramento, CA 95812-4025 <br />Sent Via Email: Kevin. Taylor@Ca/Recvcle.ca. aov <br />Re: Solid Waste Facility Permit No. 39 -AA -0015 <br />Dear Ms. Mortensen: <br />The San Joaquin Farm Bureau (Farm Bureau) represents over 4,100 farming and ranching <br />families, and members throughout San Joaquin County. We are the leading voice of agriculture <br />and remain committed to improving the ability of farms and ranches to thrive, as well as <br />provide for a healthy, rural community. We have been deeply involved over the years with the <br />Solid Waste Facility permit holder No. 39 -AA -0015 (Forward Landfill), and have been actively <br />commenting on the changes to this facility over time. We remain concerned and would like to <br />offer our comments as you evaluate Forward Landfill's request for a revised permit to include <br />operations on all 20 Sundays per year, as well as the approval of a boundary revision. <br />In the previous permit granted by the former California Integrated Waste Management Board <br />(CIWMB) there were conditions put in place on the permit that limited the facility to 10 <br />Sundays of operation per year. We would ask that the permit remain at the threshold of 10 <br />Sundays per year as it currently is allowed. We ask this because Forward Landfill is currently <br />engaging in a new notice of preparation (NOP) for a draft environmental impact review (DEIR) <br />for a project change to their facility. We believe with impending changes that will be coming in <br />the very near term, it would be disingenuous to approve the increase of operations days on <br />Sunday without considering the most recent environmental review and public process that will <br />be available in 2012. <br />In regards to the boundary revision, we see this parcel as an area that already has put into use <br />key monitoring wells that have yet to be formally approved in a boundary revision. We <br />question whether CalRecycle would consider the use of these wells as a landfill activity? And if <br />so, we would also question whether or not the originally EIR, and the Negative Declaration truly <br />provide for sufficient analysis of the impacts to the surrounding environment. <br />3290 NORTH AD ART ROAD . STOCKTON, CA • 95215 • (209) 9314931 - (209) 931-1433 Fax <br />WWW.SJFB.ORG <br />