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May 04 06 09:40a Community Development 2099417270 p.4 Letter re;PA-050079-Olivera Fan-dly Partnership x/3/2006 Page 3' ".finding The massive concentration of p6ultry adjacent to an urban population raises coincerr for diseases known to lse.transmissible bet�3een''`avian aind human populations such-as:the "bird 'flu." The proposed operation has the potential for "significant 'odor impacts to the adjacent population as well as disease impacts from flies'and other vermin. It:has.the.potential for significant air quality and water quality, impacts, including.the potential for both surface and groundwater contamination. While the`raising ofpoultry is a traditional agricultural use, the scale and magnitude of the operation are key factors in determining compatibility. This is retI66ted in the County's regulations, which provide for review of larger operations, and in state and federal regulations, such as the rational Pollution Discharge Elimination System (N-PDES) noted above. It is indisputable that Large CAFOs present serious environmental issues. See, e.g., enclosed EPA, Poultry Production and Environmental St",ardship (April 2003) stating that "Management of manure, litter, and poultry by-products is a complex environmental issue." Notably, Best Klanagemeni Practices have not been proposed nor discussed in the Negative Declaration, nor have they been required for this project. Additionally, as stated by Schwab (1998) in the American Plaruling Association's Planning {APA} Advisory Service Report Number 482enti#led Planning and Zoning fur Concentrated Animal Feeding Operations: "Manure floating downstream from a lagoon spill is graphic. Fish kills are dramatic. Odors provide a daily, aggravating reminder of an undesirable neighbor. Gioundwater contamination may take longer to materialize, but once it does, it leaves neighbors with a sense that all is lost. They cannot even drink the water from their wells." See also the enclosed copy of EPA's CAFO Fact Sheet W3A: CAFO Requirements for the Poultry Production Area (October 2003) and Concentrated Animal Feeding Operations Clean Water flet Requirements(December 2002). Based on a review of these referenced documents from EPA and APA, it is clear that the proposed project has not made full public disclosure regarding whether and how this project will deal with the serious CAFO issues raised by this project. Hence, it is strongly recommended that the County address the information in these.EPA submittals in terms of how this project will deal with the serious environmental issues raised by this project. As an urban planner with over 30 years of experience (including a decade as head of planning for the City of Modesto), coupled with professional experience in the preparation of scores of Environmental Impact Reports (ETRs) and other environmental documents (including negative declarations and notices of exemption), and based on the analysis provided herein, it is concluded that the Negative Declaration of this project is inadequate and incomplete; that there is a "fair argument" that the proposed poultry farm project may cause significant effects on the environment as discussed above; and as such, an EIR must be prepared for this project.