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6 <br /> Finding 2 is highly suspect given the applicants' proven record of not complying <br /> with the terms of their 2005 permit, and the absence of staff inspections and any record or <br /> documentation of compliance. Compliance is baldly assumed in its findings, and is not <br /> supported by even one affirmative fact being set forth. The state of the applicants' <br /> compliance is simply asserted as being true. <br /> B. Finding 1 is Wrong <br /> B. 1. Finding 1 Reads: <br /> 11 <br /> 1. The proposed use is consistent with the goals, policies, standards, and maps <br /> of the General Plan, any applicable Master Plan, Specific Plan, and Special Purpose <br /> Plan, and any other applicable plan adopted by the County. <br /> • This finding can be made because the proposed expansion of the small <br /> winery may be conditionally permitted in the AG-40 (General <br /> Agriculture-40 acre minimum) zone with an approved Site Approval <br /> application. The proposed expansion is consistent with the goals, <br /> policies, standards, and maps of the General Plan. There are no <br /> Master Plans, Specific Plans, or Special Purpose Plans in the project <br /> vicinity." <br /> B. 2. Reason # 1 Why Finding 1 is Wrong: A Tautology is Inadequate for a <br /> Finding of Fact <br /> The finding's logic: <br /> 1) Because "the proposed expansion of the small winery may be conditionally <br /> permitted in the AG-40 (General Agriculture-40 acre minimum) zone with <br /> an approved Site Approval application,"therefore <br /> 2) "This finding can be made" <br /> B.3. Reason#2 Why Finding 1 is Wrong: The Proposed Marketing Events <br /> Are Neither"Accessory"Nor"Subordinate to the Primary Agricultural <br /> Use" <br /> A "major purpose" of the San Joaquin County Code's explicitly stated "Intent" as <br /> to "Wineries and related facilities" "is to guarantee that ... winery ... marketing events are <br /> accessory and are subordinate to the primary agricultural use." The size, scope, <br /> numbers of people and sheer magnitude of the activities proposed--and already allowed to <br /> happen--make these so-called "marketing events" neither accessory nor subordinate to the <br /> growing of grapes or the production of wine. Instead, the reverse is occurring: The <br />