SR0081147_MANURE MANAGMENET PLAN

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i Giuseppe Sanfilippo San Joaquin County Planning Commission Re. Proposed Mitigated Negative Declaration for Use Permit No. PA-1800316 of Ahmed Hussein (c/o Shack& Company) February 21, 2020 Page 2 I. The IS/MND Fails to Accurately, Consistently, and Adequately Describe the Project. The IS/MND and Staff Report present inconsistent and conflicting information about important aspects of the Project, including manure generation and handling,vector control, and permitting requirements. These inconsistencies raise questions about the scope of potential Project impacts and appear to undercut the IS/MND's determination that the Project does not have the potential to result in significant impacts. For example, on page 2,the IS/MND states that no permits are required other than from San Joaquin County (County). This appears to be incorrect, as the Initial Study and correspondence from the County Department of Public Works and other agencies such as the Regional Water Quality Control Board(RWQCB) indicate that permits from other agencies are required. (See, e.g., Staff Report, Attachment B,p. 4 [July 15, 2019 letter from County Public Works referencing State Water Resources Control Board (SWRCB) and RWQCB permit requirements]; id.,pp. 25-29 [January 17, 2019 letter from RWQCB referencing multiple permit requirements, including Waste Discharge Requirements]; Staff Report, Attachment C,p. 11 [IS/MND discussion of air quality stating Project will need to meet requirements of San Joaquin County Air Pollution Control District(APCD)]; id., p. 20 [discussion of hydrology—reference to meeting requirements of RWQCB].) There is no analysis of how the various applicable permits will ensure that significant impacts do not occur, and there are no mitigation measures requiring the applicant to obtain the full range of permits and comply with any conditions to those permits. ,-p:�>The Manure Management Plan documentation included in the Staff Report contains a number of inconsistent descriptions of the Project that raise questions about Project impacts. For example,the August 8, 2019 Manure Management Plan (provided as a response to Michael Keith from Dylan Wooten) states, "The total manure from the animals will be one wheelbarrow to a maximum of a half a cubic yard." (Staff Report, Attachment C,p. 41.) This does not square with the estimated annual manure production identified in the subsequent Manure Management Plan by Don Chesney of Chesney Consulting, dated September 6, 2019,which identifies a total of 244 tons per year of manure production. The August 8, 2019 response further states that"There is no anticipation of any manure storage areas," (Id.)whereas the September 6, 2019 plan states, "Manure from all animal types will be raked up from the pens and stored in holding bins." (Staff Report,Attachment C,p. 36.) 11. The IS/MND Fails to Identify or Incorporate any Mitigation Measures CEQA requires that a proposed mitigated negative declaration must include "any mitigation measures included in the project to avoid potentially significant effects." (CEQA Guidelines, § 15071.) The IS/MND is clearly identified as a"mitigated negative declaration"