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Giuseppe Sanfilippo <br /> San Joaquin County Planning Commission <br /> Re. Proposed Mitigated Negative Declaration for Use Permit No. PA-1800316 of Ahmed <br /> Hussein (c/o Shack& Company) <br /> February 21, 2020 <br /> Page 3 <br /> and makes the finding that"San Joaquin County has determined that through the Initial Study <br /> that contains proposed mitigation measures all potentially significant effects on the <br /> environment can be reduced to a less than significant level." (Staff Report,Attachment C, <br /> p. 3.) However, the IS/MND does not identify any mitigation measures. It is not clear which <br /> actions that have been incorporated by the applicant into the Project are considered mitigation <br /> measures and which of the proposed conditions of approval are actually mitigation measures <br /> necessary to avoid significant impacts. <br /> The lack of clarity is compounded by the failure to include a mitigation monitoring <br /> and reporting program (MMRP) with the Staff Report, as required by CEQA. (CEQA <br /> Guidelines, § 15074, subd. (d).) Without an MNUZP,there will be no mechanism for the <br /> County or public to track and ensure compliance with Project mitigation measures. The <br /> IS/MND must be revised to clearly identify the mitigation measures incorporated into the <br /> Project to avoid or substantially lessen Project impacts, including any additional measures <br /> necessary to address impacts identified in these comments and by other members of the <br /> public, and those measures must be included in an MMRP adopted by the Planning <br /> Commission if it approves the Project. <br /> III. The IS/MND Does Not Clearly Demonstrate that the Project Will Not Result in <br /> Significant Impacts to Water Quality <br /> The District is particularly concerned about the Project's potential to result in <br /> significant impacts to surface and groundwater quality, due to the volume and treatment of <br /> Project-generated manure 1 The September 6, 2019 Manure Management Plan states that <br /> manure wi a spread onto the Project site and disced into the soil. (Staff Report, <br /> Attachment C,p. 36.) This treatment presents the potential for groundwater and surface water <br /> contamination from nitrogen, phosphorus, and pathogens. However, only nitrogen is <br /> discussed in the manure management pan ocumentation and IS/MND, and what analysis is <br /> provided is inadequate, as discussed below. A September 20, 2019 letter from Mr. Chesney <br /> (Staff Report,Attachment C, p. 54) clarifies that manure will be stored with a top to keep <br /> rainwater out, but this does not address the potential for stormwater runoff across the Project <br /> site to come into contact with stored manure and carry contaminants into surface waters. No <br /> information is provided in the IS/MND regarding the site hydrology, including the expected <br /> direction of any surface water runoff relative to the planned manure storage facilities. <br /> Other potential impacts to groundwater are not resolved through the IS/MND. The District notes that the <br /> Project will rely on well water,but the IS/MND contains no information about the estimated water use or <br /> availability and contains only a bare conclusion that impacts to groundwater supplies will not be significant. <br /> (Staff Report Attachment C,p.20.) <br />