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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 6 <br /> IV. The IS/MND Fails to Demonstrate that Air Quality Impacts Will Not Be Si nificant <br /> The Project has the potential to result in significant localized impacts from dust and <br /> odors that are not analyzed or mitigated, as noted by Califia, L.L.C. in its February 6, 2020 <br /> letter regarding the Project. In addition to the Califia comments,the District notes that the <br /> IS/MND indicates that the Project will be required to meet the requirements for emissions and <br /> dust control as established by the APCD, and on that basis, concludes"that impacts to air <br /> quality will be reduced to less than significant." (Staff Report,Attachment C,p. 11.) The <br /> IS/MND contains no evidence or analysis regarding the level of potential emissions, nor does <br /> it discuss what APCD emissions and dust control requirements will be required. Thus,there <br /> is no way for the District to know the scope of potential Project emissions and dust impacts. <br /> At a minimum,the IS/MND must be revised to include a mitigation measure requiring the <br /> applicant to consult with the APCD, apply for any required permits, and comply with APCD <br /> permit requirements. <br /> IV. The Project May Result in Potentially Significant Impacts to Public Health and <br /> Safety and District Facilities from Vectors <br /> There is insufficient information in the IS/MND to demonstrate that the Project will <br /> not result in potentially significant impacts from vectors, including rodents. The Manure <br /> Management Plan is merely an"outline"that states that a local pest control company will be <br /> hired and pesticides and traps will be used. (Staff Report,Attachment C,p. 43.) The <br /> proposed conditions of approval contain an"informational note"that the Project is subject to <br /> the requirements of the San Joaquin County Mosquito and Vector Control District and the CA <br /> Health and Safety Code." (Staff Report, Attachment F,p. 6, note 2.) The note to the <br /> conditions of approval further states that"Best Management Practices (BMPs) guidelines for <br /> stormwater devices,ponds and wetlands are available." (Id.) It is unclear whether this <br /> "informational note" states a condition of approval. Condition 6a requires the applicant to <br /> incorporate mosquito best prevention BMPs for the design, construction, operations, and <br /> maintenance of the proposed stormwater infrastructure. (Staff Report, Attachment F, p. 9.) <br /> However,this condition is limited to potential impacts of the stormwater infrastructure and <br /> does not address other vectors that may be attracted to the Project site, such as rodents,which <br /> may pose a risk to public health and safety from disease, as well as potential degradation of <br /> District levees from burrowing rodents. <br /> The IS/MND does not explain what requirements of the San Joaquin County Mosquito <br /> and Vector Control District apply to the Project or how they will avoid significant impacts <br /> from vectors and mosquitos. To ensure that impacts from vectors will not be significant, at a <br /> minimum,the IS/MND must be revised to include a mitigation measure requiring the <br /> applicant to consult with the Mosquito and Vector Control District,provide documentation of <br />