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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 4 <br /> Stormwater and irrigation runoff from the Project site has the potential to degrade <br /> surface water in Tom Paine Slough, which is the source of the District'water supply. <br /> Application of manure that exceeds agronomic rates also has the potential to substantially <br /> degrade surface an gro a istrict's questions and concerns stem from <br /> conflicting statements in the various manure management plan documents,the lack of <br /> information and analysis in the IS/MND about the range of potential water quality impacts <br /> beyond potential nitrogen effects, and the lack of mitigation measures to ensure that actions <br /> identified by the applicant's engineer as essential to avoid nitrogen-related water quality <br /> impacts are implemented. <br /> Mr. Chesney states, "Crops planted will consist of grain-type plants such as rye, oats, <br /> wheat and orchard grass." (Staff Report, Attachment C,p. 36.) He then presents the <br /> esTi'mated nitrogen racoons from the manure to be generated by the Project(up to 244 tons <br /> per year), as well as nitrogen uptake estimates based on crop types and acreage. (Id.,p. 37.) <br /> Mr. Chesney concludes that the calculations demonstrate that"barley,oats and wheat crops <br /> will assimilate nitrogen produced from manure land applications provided these crops are <br /> double cropped meaning that two crops are grown per year on the subject acreage." (Id.,p. <br /> 38.) The analysis of nitrogen uptake, and Mr. Cheney's conclusion about the assimilative <br /> capacity of on-site crops, is based on nitrogen uptake values of barley, oats,wheat, and <br /> orchard grass; no information is provided about uptake values for rye, and the analysis and <br /> conclusion does not include rye. Thus, there is no evidence to demonstrate that nitrogen <br /> uptake will be sufficient if rye is planted on site, as is indicated on page 1 of the Manure <br /> Management Plan. (Staff Report,Attachment C, p. 36.) And Mr. Chesney's nitrogen <br /> assimilation conclusion indicates that double cropping is necessary to ensure sufficient <br /> nitrogen assimilation(Id.,p. 38), but there are no commitments or mitigation measures to <br /> ensure that double cropping will occur. <br /> Mr. Chesney also states that no synthetic nitrogen fertilizers should be applied to the <br /> cropland. (Id.) However, no mitigation measures are included that prohibit the use of <br /> synthetic nitrogen fertilizers. <br /> Mr. Chesney further states that sufficient nitrogen uptake will occur only if the organic <br /> fraction of the manure mineralizes to plant available nitrogen(PAN), which depends on <br /> "certain environmental conditions." (Id.) These specific conditions are not identified in the <br /> Manure Management Plan nor in the IS/MND, thus,there is no information to demonstrate <br /> that the appropriate environmental conditions necessary to ensure mineralization to PAN of <br /> the organic fraction of the manure will be present on site. Mr. Chesney also states that <br /> mineralization will occur in the spring and summer months of the year. (Id.) This indicates <br /> the need for a mitigation measure limiting manure spreading to the spring and summer <br /> months. The lack of mitigation measures, and lack of any information about manure handling <br />