October 19, 1999

Traci Tesconi, Planner III                                                                                               .
Permit and Resource Management
2550 Ventura Avenue
Santa Rosa, California 95403

Re: Petaluma Mushroom Farm Negative Declaration

Dear Ms. Tesconi,

Thank you for this opportunity to comment on the proposed negative declaration prepared by your office for a proposed expansion of the Petaluma Mushroom Farm facility on Thompson Lane in Petaluma.

San Francisco BayKeeper's Petaluma  RiverKeeper project has been involved in documenting illegal discharges of animal waste and pesticides from PMF over the last year. Our investigation included direct observations of Marin Creek clotted with animal waste, a sampling effort that confirmed the nature of the waste as well as the presence of significant concentration of the pesticide diazinon, and an unauthorized pipe discharging waste from the site. In addition to our observations, the Regional Water Quality Control Board confirmed that the facility was illegally discharging pollutants from its site. Those efforts led directly to the investigation by the District Attorney's office that resulted in a judgment entered against PMF on September 21, 1999. A pattern of disregard for the both Californiars water quality laws as well as a chronic disregard of the requirements set forth in the facility's existing use permit suggests that the County take a very close look at the expansion proposed by PMF..

The judgment stipulated to by PMF requires the company, "within a period of one (1) year from the date of entry of judgment, to relocate its composting operations from its existing location at 782 Thompson Lane, Petaluma, to a facility located in the Two Rock area." Stipulation for Entry of Judgment, paragraph 6(c)(ii) (attached). The proposed negative declaration fails to mention the specific terms of the Judgment. The court-ordered relocation also is not included in the negative declaration's mitigation requirements. The prudence of relocating the composting operations is underscored by the location of the facility in the 100 year flood hazard area.

In order to assure compliance with all applicable water quality laws and the order of the Superior Court for the County of Sonoma, the proposed negative declaration must incorporate the relocation requirement set forth in the judgment. To omit that requirement will not assure that the long-term protections for Marin Creek ordered by the court will be realized. Without that mitigation, the negative declaration also cannot support a finding of "less than significant impact."

Thank you again for this opportunity to comment on the negative declaration. If you have any questions, please give me a call at (415) 561-2299 x. 15.


Michael Lozeau
San Francisco BayKeeper
Cc:      David Yearsley, Petaluma RiverKeeper

475567 2299
Presidio Building 1004 , ' , fax 415 561 2290
PO Box 29921 1-800-KEEP-BAY
San Francisco, CA 94129-0921 Printed on recycled paper  www.sfbaykeeper.org

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