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Comment Letter <br /> St. Jorge 97nery"Site Approval Application"PA-1200063 <br /> 2. Noise Study is Flawed <br /> As a part of the Initial Study required for this project,a"noise study"was also required. <br /> The Initial Study shows that there were no controls of any type on the sound levels employed in <br /> making the noise study. The absence of any controls to ensure that the"amplitude"used in the <br /> noise study was based on objective,reliable data renders the study useless. The noise study has <br /> no reliable facts upon which to make any conclusions. <br /> The Initial Study cannot support a finding of fact that the St.Jorge wine garden can <br /> comply with the County Code's presumptive noise level standards,provided the mitigation <br /> measures recommended for the Conditions of Approval are implemented. <br /> 3. Conclusions of"Less than Significant"Impacts Are Flawed <br /> The project application's Initial Study provides textual answers in seven of its 17 <br /> categories,making conclusions of"less than significant"impact to the environment in four of <br /> those categories. <br /> As seen below,the facts and argument used in the Initial Study are inadequate to support <br /> these conclusions of"less than significant'.'impact,and therefore the Initial Study is flawed and <br /> does not support project application approval. <br /> II. THE VIERRA'S 2005 ST.JORGE WINERY PERMPT <br /> A. The Vierra's 2005 St.Jorge Winery Application <br /> 1. 2005"Application-Site Approval" <br /> In May,2005,Vernon and Denise Vierra submitted an"Application- Site Approval"form <br /> to the San Joaquin County Community Development Department, file number PA-0500306. The <br /> application was for a"small winery,"consisting of two buildings at 22775 No.Bender Rd.in <br /> Acampo,on property zoned AG-40(General Agriculture,40-acre minimum),with a General <br /> Plan designation of A/G(General Agriculture). <br /> The Vierras proposed that the winery business have four"marketing events"a year which <br /> would be restricted in terms of season,weekday,hours and number of attendees, and occurring <br /> without onsite food preparation or amplified music. <br /> 2. 2005 Building Proposal <br /> The 2005 application proposed construction of two buildings,and limits on hours and <br /> content of the"St.Jorge Winery"business. The building specifics were: <br /> • Building"A,"proposing a lobby,office,restrooms, lab and barrel storage at 3,000 <br /> sq.ft.; and <br /> • Building"B,"proposing a serving and wine tasting room and barrel storage on the <br /> first floor, with a caretaker space and empty case storage on the second, at 3,836 <br /> sq.ft.; and <br /> • Parking,proposed at 29 total spaces. <br /> 3 <br />