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storing dead birds and the construction of manure drying tunnels will reduce the potential for odors emanating from the project site. A referral was also sent to San Joaquin Valley Air Pollution Control District (APCD) for review. APCD submitted a letter dated November 12, 2015 that concludes that the construction and/or operation of the project may exceed the thresholds of significance for oxides of nitrogen (NOx), reactive organic gases (ROx), or particulate matter of 10 microns or less-in size (PM10). APCD recommended that project emissions be identified and quantified, pre-and post-project emissions should be identified, nuisance odors affecting a substantial number of people should be reviewed, and a Health Risk Assessment (HRA) be performed to determine the health impact of Toxic Air Contaminants (TACs). APCD also stated that the project is not subject to District Rule 9510 (Indirect Source). However, an Authority to Construct (ATC) may be required prior to the start of construction and the project may be subject-to other APCD rules and regulations. On July 22, 2016, the applicant submitted an HRA to APCD. APCD submitted an email dated November 4, 2016, concluding that based on the information provided, the project would not result in a significant impact and no further modeling is required. With the rules and-regulations of the APCD and the Environmental Health Department, the odors, air quality, and pest impacts are expected to be less than significant. Traffic: The neighborhood opposition raised concerns about traffic. Eighty-six (86) trucks will access the site per week and there will be no increase in the number of employees. The Department of Public Works reviewed the project and states that the proposed project would have a less than significant impact on traffic on the local streets because the expansion of the existing development project is not expected to increase- traffic ncreasetraffic in excess of fifty (50) vehicles during art hour. In addition, as a recommended Condition of Approval, the owner shall improve driveway approaches in accordance with the requirements of San Joaquin County Improvement Standards Drawing No. R-17 to improve access to and from the site prior to release of the Improvement Plan. Wastewater Management: The neighborhood opposition raised concerns related to groundwater. No new waste ponds are proposed with this project. A referral was sent to the Central Valley Regional Water Quality Control Board (CVRWQCB). On January 19, 2016, CVRVAIQCB submitted a letter stating that a Poultry General Order was being developed, and that the project would be required to file a Notice of Intent and receive coverage under the General Order. The-letter also indicated that the design and construction of any new ponds would require Executive Officer approval prior to construction and use, and that water flowing through the fan emissions area should be managed through the wastewater management system. This project shall be required to comply with CVRWQCB regulations regarding groundwater and surface water. Therefore, groundwater impacts are expected to be less than significant. Property Values and Enjoyment of Property: The neighborhood opposition also raised concerns about the expansion affecting property values and the rights of neighbors to enjoy their own properties. Analysis of property values and the enjoyment of property, is not necessary to recommend approval of the project, as these impacts are not considered in the required Development Title findings for a land use application and are not directly related to land use. However, in regards to the enjoyment of property, the poultry ranch has existed on the site most recently since 1993, and with-the exception of a three (3) year vacancy, for more than twenty-nine (29) years prior to that. Additionally, the San Joaquin County Right- To-Farm Ordinance (Section 6-9004[3]) recognizes and supports the right to farm agricultural lands in a manner consistent with accepted customs, practices, and standards. Residents of property on or near agricultural land should accept the inconveniences or discomforts associated with agricultural operations or activities, including but not limited to noise, odors, insects, fumes, dust or the operation of machinery during any 24-hour period. San Joaquin County has determined that inconveniences or discomforts associated with such agricultural operations or activities shall not be considered a nuisance. San Joaquin County PA-1500200/Jenkins Community Development Page 7