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May 04 06 09:39a Community Development 209941/2/U p;3 U t Letter re PA 050079-Olivera Family Partnership 5/312006 .Page 2 'dispersed operation. The otentia1 for dust and articulate matter from . the air handling system is not analyzed, nor is the potential for significant wind-borne manure dtisl from the apparently open air manure piles proposed.. • NVater Quality: The proposed project is of a scale twelve to thirty times the threshold set for a Large Concentrated Animal Feeding Operation by the USEPA for purposes of the National Pollutant Discharge Eliminatio-ra System (NPD.ES). This threshold is set at 30,000 laying hens if a liquid manure handling system is used, or 82,000 if other than a liquid manure handling system is used. The manure handling system to be used in this proposal is not specified. The ultimate system for disposal of manure is not specified. The lack of a plan for this critical element of this massive operation makes the analysis. and disclosure incomplete. Both mineral and microbial contamination from runoff and leaching are a concern. The proposed project is an egg facility. Substantial amounts of water are required in the processing of eggs. No plan is proposed for the treatment and disposal of this stream. • Right to Farm: The County relies on its Right to Farm Ordinance as an excuse to avoid discussing the adverse public health effects that will occur as a result of approving the proposed project. The :,Right to Far►n Ordinance does not justify allowance as an agricultural land use that constitutes a "public nuisance" in operation, and particularly a nuisance that rises to the alarming level that can kill people. See, e.g., NPR, Health Oflicials Keep Close Watch on Bird Flu (May 3, 2006). Stated more poignantly, approving a one million bird fann that can potentially kill people as a result of the spread of Avian Flu cannot be justified on the untenable ground of the Right to Farm. This project,. as characterized in the Staff Report, will not cause mere annoyance and discomfort. Instead, it can cause serious public health effects if not controlled properly. Despite the regulatory and scientific literature on the subject, the Negative Declaration did not discuss the adverse public health effects that potentially could occur to the adjacent subdivisions proposed in the City. The findings set forth for approval of the project are inadequate for the following reasons: 1. Consistency with the General Plan and related plans is not established. The reasons given are conclusory and do not establish factual consistency with the General Plan. 2. Adequate sanitation, drainage and other facilities are not established. .A manure management plan has not been prepared and exposed to public review, nor has a drainage plan. It is not established that adequate drainage and manure handling will be provided. 3. While it appears that the site is physically large enough to accommodate the proposed use, factors other than size must be considered in making this finding. The location within a flood plain calls into question the appropriateness of locating a use with massive manure production. 4. The finding that the project "will not be significantly detrimental to public health, safety or welfare, or be injurious to the property or improvements of adjacent properties" is unsupported. As noted above, the environmental analysis is not adequate to support this I I