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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 2 <br /> I. The IS/MND Fails to Accurately,Consistently,and Adequately Describe the Project. <br /> The IS/MND and Staff Report present inconsistent and conflicting information about <br /> important aspects of the Project,including manure generation and handling,vector control, <br /> and permitting requirements. These inconsistencies raise questions about the scope of <br /> potential Project impacts and appear to undercut the IS/MND's determination that the Project <br /> does not have the potential to result in significant impacts. <br /> For example,on page 2,the IS/MND states that no permits are required other than <br /> from San Joaquin County(County). This appears to be incorrect,as the Initial Study and <br /> correspondence from the County Department of Public Works and other agencies such as the <br /> Regional Water Quality Control Board(RWQCB)indicate that permits from other agencies <br /> are required. (See,e.g., Staff Report,Attachment B,p.4[July 15,2019 letter from County <br /> Public Works referencing State Water Resources Control Board(SWRCB)and RWQCB <br /> permit requirements];id.,pp.25-29[January 17,2019 letter from RWQCB referencing <br /> multiple permit requirements,including Waste Discharge Requirements];Staff Report, <br /> Attachment C,p. 11 [IS/MND discussion of air quality stating Project will need to meet <br /> requirements of San Joaquin County Air Pollution Control District(APCD)];id., p.20 <br /> [discussion of hydrology—reference to meeting requirements of RWQCB].) There is no <br /> analysis of how the various applicable permits wil I ensure that significant impacts do not <br /> occur,and there are no mitigation measures requiring the applicant to obtain the full range of <br /> permits and comply with any conditions to those permits. <br /> The Manure Management Plan documentation included in the Staff Report contains a <br /> number of inconsistent descriptions of the Project that raise questions about Project impacts. <br /> For example,the August 8,2019 Manure Management Plan(provided as a response to <br /> Michael Keith from Dylan Wooten)states,"The total manure from the animals will be one <br /> wheelbarrow to a maximum of a half a cubic yard." (Staff Report,Attachment C,p.41.) <br /> This does not square with the estimated annual manure production identified in the <br /> subsequent Manure Management Plan by Don Chesney of Chesney Consulting,dated <br /> September 6,2019,which identifies a total of 244 tons per year of manure production.The <br /> August 8,2019 response further states that"There is no anticipation of any manure storage <br /> areas,"(Id.)whereas the September 6,2019 plan states,"Manure from all animal types will be <br /> raked up from the pens and stored in holding bins." (Staff Report,Attachment C,p.36.) <br /> II. The IS/MND Fails to Identify or Incorporate any Mitigation Measures <br /> CEQA requires that a proposed mitigated negative declaration must include"any <br /> mitigation measures included in the project to avoid potentially significant effects." (CEQA <br /> Guidelines,§ 15071.) The IS/MND is clearly identified as a"mitigated negative declaration" <br /> Planning Commission Staff Report, PA-1800316(UP) 86 <br /> Response Letters <br />