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Comment Letter <br /> St. Jorge Winery "Site Approval Application"PA-1200063 <br /> In fact,the applicants' data are that the project's build-out will allow up to approximately <br /> 40,000 people a year to use the St.Jorge Winery,seven days a week. No study was conducted, <br /> nor was any information at all presented,to show that this projected impact is"not a growth- <br /> inducing action." <br /> VIL CONCLUSION <br /> A. The Expansion Project Application's Environmental Review Is Inadequate and <br /> Does Not Support Approval <br /> As shown above, the environmental review conducted for this expansion application is <br /> inadequate and cannot support the project's approval. <br /> By its own terms,the 2012 St.Jorge Winery Expansion Application seeks to: <br /> a) More than double the square footage under the current,2005 permit; <br /> b) Increase by seven-fold the number of"events"from four to twenty-eight; <br /> c) Increase by six-fold the number of attendees at these"events"from 25 to 150;and <br /> thereby <br /> d) Raise the annual traffic to the business to up to 40,000 people,all of whom arrive <br /> in private vehicles or hired coaches. <br /> The Initial Study neither presents nor discusses these facts,nor the environmental impact <br /> issues they raise. Further,it reaches numerous conclusions of"less than significant"impact <br /> without providing supporting facts or analysis for those conclusions. <br /> The necessary findings of fact to support the 2012 Expansion Application cannot legally <br /> be made. <br /> B. The County Must Both Deny This Application and Enforce Its Own Laws <br /> The St.Jorge Winery business has been operating illegally well beyond the terms of its <br /> permit and the San Joaquin County Code for years. The business owners and operators have <br /> been: <br /> • Advertising their"small winery," <br /> • Which is permitted for four"marketing events"a year, <br /> At 25 people per event, <br /> • As a"full service event destination"that <br /> • "Can accommodate up to 200 guests"for <br /> • "Weddings,banquets, or small gatherings,"or <br /> • "Your personal gatherings,birthdays,anniversary and meetings,"featuring <br /> • A"summer concert"series in the winery's"amphitheater,"with <br /> • A chef"from Italy,"and <br /> • "An exquisite [caretaker dwelling unit] suite for rent,before or after events." <br /> In conducting these so-called"marketing events"the Vierras have violated all of the St. <br /> Jorge Winery 2005 permit's pertinent terms,as well as the San Joaquin County Code, as outlined <br /> above. <br /> 21 <br />