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SHUTE�M <br />Via Via Email <br />396 HAYES STREET, SAN FRANCISCO, CA 94102 <br />T: 415 552-7272 F: 415 552-5816 <br />www.smwiaw.com <br />asame =3KIIE, <br />Robert McClellon <br />San Joaquin County Environmental Health <br />Department <br />1868 East Hazelton Avenue <br />Stockton, CA 95205 <br />rmcclellongsi cehd. com <br />Re: Solid Waste Facility Permit No. 39 -AA -0020 <br />Dear Mr. McClellon: <br />LAUREL L. IMPETT, AICP <br />Urban Planner <br />impett@smwlaw.com <br />We appreciate your September 24, 2014 letter in response to this firm's September <br />18, 2014 letter regarding Forward's application for a Solid Waste Facility Permit <br />("SWFP")/Waste Discharge Requirements ("Application"). We have reviewed the <br />Environmental Health Department's ("EHD") letter to Kevin Basso dated June 18, 2014, <br />the July 2014 draft Transfer Processing Report ("TPR"), and the July 2014 draft Report <br />of Composting Site Information ("RCSI"). There appear to be issues identified in your <br />June 18, 2014 letter that remain unresolved in the July TPR and the July RCSI. These <br />issues, which are discussed below, relate to the facility's potential to result in odors, litter, <br />vectors and noise impacts and to adversely affect aircraft safety. We request that EHD <br />resolve these issues prior to taking action on Application. <br />I. Operation of Forward's Facility Has the Potential to Result in Odors. <br />Without proper management, the disposal and decomposition of solid and liquid <br />wastes has the potential to result in fetid odors. See e.g., Draft Environmental Impact <br />Report ("DEIR") for the Forward Landfill Expansion at IV.D-22 stating that <br />""Noticeable (moderate) odor detected from composting facility" during the odor and <br />dust survey observations and "moderate to strong odors detected on all three days" at the <br />entrance to the Forward Recovery Center. In the June 18, 2014 letter, EHD specifically <br />asked Forward how it would monitor loads for odors and questioned the action that <br />