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5. The recently created gravel parking lot for seasonal employees was a great help in reducing the frequent congestion on Pine Street due to employees parking on-street, along with the lack of improved shoulders which led to dirt and debris tracking onto the street. However, the proposed site plan substantially reduces the available parking in this lot. Again, no data is provided to evaluate this impact. The Regional Board Order mentioned above notes 800 seasonal employees and 40 off-season employees (pre- expansion). Sufficient employee parking should be provided such that Pine Street does not again become part of their parking lot. 6. There is no mention of truck traffic which is understandably considerable. (And this presumably includes STAA trucks and the turn-around already provided should be retained since the only STAA access is via Pine Street from the West. B) Wastewater 1. There are several inconsistencies between the current Regional Board Order and the proposed project that need to be resolved. And, it appears to me that a revised order should be obtained by the Applicant. For example,the current Order shows an 11 acre wastewater disposal area and the proposed project reduces it to 8 acres. Obviously this along with the expansion (which is not covered in the Order), increases the loading rates and needs to be evaluated. 2. Wastewater service (for domestic and/or process water) could be provided by the City of Lodi as facilities are available in Guild Avenue at Pine Street. While there would be additional fees,they would be offset by reduced need for land devoted to wastewater needs on-site. This should be evaluated as part of the project review as an alternative as it would reduce potential impacts to groundwater. 3. The process water includes a variety of chemicals as noted in the Regional Board Order, but there is no groundwater monitoring that confirms for potential impacts from these chemicals. This should be required and could be accomplished by use of downgrading shallow wells. C)Water 1. The existing site receives water from the City of Lodi. An alternative extending the on-site system and eliminating the need for wells should be evaluated as the City's supply includes a significant portion of surface water from the Mokelumne River and the groundwater basin is in overdraft. 2. Again, the initial study contains little information about water demands for the project from which to make an informed decision on the project. Given the above information, I believe the initial study is inadequate and request that more analysis be done in support of appropriate project requirements. Sincerely yours, S/ Richard Prima Via email