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Comment Letter St.Jorge Winery "Site Approval Application"PA-1200063 they felt was typical of the music which currently plays in the courtyard area" (Initial Study,"5. Noise."pg.8.) The"owners of the winery,"who are the project applicants as well, are anything but objective or neutral. The use of what"they felt was typical of the music which currently plays in the[currently illegal]courtyard area"provides neither objective nor reliable basis upon which to make any conclusion. 2. The Absence of Controls Renders the Noise Study Useless The absence of any controls to ensure that the"amplitude"used in the noise study even approximates that actually used in the applicants'business operations renders the study useless. It cannot support a finding of fact that"the wine garden can comply with the county noise level standards provided the following recommendations ["mitigation measures"which"will be incorporated into the Conditions of Approval"] are implemented." (Initial Study,"5. Noise." pg- 8.) C. Conclusions of"Less Than Significant"Impacts Are Flawed 1. Introduction The project's Initial Study is actually a San Joaquin County Community Development Department form which is filled out by checking boxes"Yes"or"No"in 17 different categories of analysis. By its terms,the Initial Study must include an attachment which discusses each category marked with an asterisk. For the St.Jorge"small winery"expansion application,the Initial Study required answers in categories 1,2,3,5, 8,9,and 13. In these seven categories' answers,the Initial Study for this project makes conclusions of"less than significant"impact to the environment in categories 2, 5, 9 and 13. The facts and argument used in the Study are inadequate to support these conclusions of less than significant impact,and therefore the Initial Study is flawed and does not support project application approval. The following sub-sections(2-5)show the facts,and in italics the logic, the Initial Study employs,with a"Response"to each: 2. "2. Earth" The Initial Study reads as follows: "The surrounding land uses are primarily agricultural with scattered residences. The Zoning and the General Plan for the project site will continue to remain the same if the project is approved. Therefore,the proposed project will have a less than significant impact to surrounding agricultural operations and will not create a premature development pressure on surrounding agricultural lands to convert land from agricultural uses to non-agricultural uses." (Initial Study,"2. Earth"pg. 7; emphasis added.) Response: It does not follow that simply because a) "The Zoning and the General Plan for the project site will continue to remain the same if the project is approved"that 18