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Comment Letter St Jorge Winery "Site Approval Application"PA-1200063 b) "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." The wholly conclusory statement that the project will have"less than significant impact to surrounding agricultural operations and will not create a premature development pressure" could be made of any proposed project in which"Zoning and the General Plan for the project site will continue to remain the same if the project is approved." This conclusion has no facts to support it;it is a bald leap of logic. 3. "5. Noise" The Initial Study reads as follows: "These mitigation measures[to wit, `l. Periodic noise measurements,2. Sound level meter staff training,calibration and use,3. Terminate events prior to 10:00 p.ro.'] will be incorporated into the Conditions of Approval. Additionally,marketing events must comply with[pertinent,enumerated County Code requirements]. Each of the noise level standards shall be reduced by 5 dB for noise primarily consisting of speech or music. Marketing events must end by 10:00 p.m. Therefore,any impacts from this project will be less than significant." (Initial Study,"5. Noise."pg. 8;emphasis added.) Response: As noted above,there were no objective controls of any type employed in the noise study, rendering it useless for purposes of environmental assessment. As to reasoning,there is no basis upon which to conclude that(a)assuming staff are trained to properly(b)calibrate and(c)use a sound meter that it will actually be done. Even were it so,there is no objective or reliable basis upon which to conclude that(d)sounds created within the County Code's numbers will(e)in fact be"less than significant"in their impacts. The Initial Study's logic relies on nothing but assuming that the winery staff training and behavior will occur and actually result in business operations meeting the County Code's presumptive parameters. 4. "9. Transportation/Circulation" The Initial Study reads as follows: "The wine tasting room will be open seven days a week. The wine tasting room will employ five employees and is open from 7:00 a.m.to 5:00 p.m. The wine tasting room expects a maximum of 100 customers per shift. If the project is approved,there will be twenty-four marketing events per year and four special events per year. The marketing and special events each expect a maximum attendance of 150 people and will operate from 6:00 p.m.to 10:00 p.m. The Department of Public works has determined that traffic impacts are expected to be less than significant because the development project is not expected to exceed fifty vehicles during any hour." (Initial Study, Transportation/Circulation."pg. 9;emphasis added.) 19