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Mr. Sullivan Page 5 operations. - The cumulative and growth-inducing impacts of the project on farmland in the surrounding area. - A listing of other proposed or approved projects in the County which are contributing to the cumulative loss of agricultural lands. • Mitigation measures and alternatives that would lessen farmland conversion impacts. Some of the possibilities are: Establishing buffers such as setbacks, berms, greenbelts and open space areas to separate farmland from urban uses. Many communities have considered 300 feet as a sufficient buffer for impacts such as pesticide spraying, noise and dust. Increasing densities or clustering residential units to allow a greater portion of proposed development sites to remain in agricultural production. The NOP notes that amount of prime soil on the project site is "small. " The loss of prime agricultural land should be quantified, and possibly treated as a significant environmental impact. The California Administrative Code (Section 15000 et seq. , Appendix G (y) states that a project will normally have a significant effect on the environment if it will convert prime agricultural land to non-agricultural use or impair the agricultural productivity of prime agricultural land. Particularly in light of the large amount of prime agricultural lands being converted to urban uses due to other projects in the County, the loss of prime lands due to this project must be viewed as a significant increase to a cumulative impact. The Department appreciates the opportunity to comment on the NOP. We hope that the farmland conversion impacts and Williamson Act issues are given adequate consideration in the DEIR. If I can be of further assistance, please feel free to call me at (916) 322- 5873 . Sincerely, �-S d od Dennis J. O'Bryant Environmental Program Coordinator cc: Kenneth E. Trott Office of Land Conservation Dale Will, Legal Office Department of Conservation San Joaquin County Resource Conservation District