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San Joaquin County July 7, 2003 PA-0300273 Page 2 Department of Agriculture and the University of California, Davis have done extensive research into confined animal waste emissions and control techniques. The District recommends the County review all available options and include all measures deemed feasible by the County to reduce this potential impact. In addition to odors, the storage of manure can emit reactive organic gases (ROG) and ammonia (NH3). These pollutants contribute to our ozone problem in the case of ROG and to our PM 2.5 problem in the case of ammonia. The District's recent experience is mostly with dairy projects. Dairies of about 1 ,300 head of cows and larger were found to produce emissions in excess of the District's threshold of significance for ROG of 10 tons/year. Additionally, this project contain operations which are subject to the permitting requirement of the District. Any equipment subject to the District's Permit to Operate requirements must obtain an Authority to Construct (ATC) from the District. Construction of equipment that requires an ATC or construction of any intimately related appurtenance, such as foundations and utility hookups for equipment, cannot begin until an ATC is obtained. This process can take up to 180 days. Construction of equipment not requiring a District permit is not subject to this ATC requirement. To determine specific permit requirements, the applicant should contact the District's Small Business Assistance Office at (209) 557-6446, or our Permit Services Section at (209) 557-6400. To avoid unnecessary delays in the project, this should be done as soon as the applicant has determined the scope of the project. Thank you for the opportunity to comment. If you have any questions, please feel free to contact me at (209) 557-6400. Sincerely( /John Cadrett Environmental Planner APCD REF#20030317 Northern Region