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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 3 and makes the finding that"San Joaquin County has determined that through the Initial Study that contains proposed mitigation measures all potentially significant effects on the environment can be reduced to a less than significant level." (Staff Report,Attachment C, p.3.) However,the IS/MND does not identify any mitigation measures. It is not clear which actions that have been incorporated by the applicant into the Project are considered mitigation measures and which of the proposed conditions of approval are actually mitigation measures necessary to avoid significant impacts. The lack of clarity is compounded by the failure to include a mitigation monitoring and reporting program(MMRP)with the Staff Report,as required by CEQA. (CEQA Guidelines,§ 15074,subd.(d).) Without an MMRP,there will be no mechanism for the County or public to track and ensure compliance with Project mitigation measures. The ISIN4ND must be revised to clearly identify the mitigation measures incorporated into the Project to avoid or substantially lessen Project impacts,including any additional measures necessary to address impacts identified in these comments and by other members of the public,and those measures must be included in an MMRP adopted by the Planning Commission if it approves the Project. Ili. The 1S/MND Does Not Clearly Demonstrate that the Project Will Not Result in Significant Impacts to Water Quality The District is particularly concerned about the Project's potential to result in significant impacts to surface and groundwater quality,due to the volume and treatment of Project-generated manure.' The September 6,2019 Manure Management Plan states that manure will be spread onto the Project site and disced into the soil. (Staff Report, Attachment C,p.36.) This treatment presents the potential for groundwater and surface water contamination from nitrogen,phosphorus,and pathogens. However,only nitrogen is discussed in the manure management plan documentation and IS/MND,and what analysis is provided is inadequate,as discussed below. A September 20,2019 letter from Mr.Chesney (Staff Report,Attachment C,p.54)clarifies that manure will be stored with a top to keep rainwater out,but this does not address the potential for stormwater runoff across the Project site to come into contact with stored manure and carry contaminants into surface waters. No information is provided in the IS/MND regarding the site hydrology,including the expected direction of any surface water runoff relative to the planned manure storage facilities. I Other potential impacts to groundwater are not resolved through the ISlMND. The District notes that the Project will rely on well water,but the IS/MND contains no information about the estimated water use or availability and contains only a bare conclusion that impacts to groundwater supplies will not be significant. (Staff Report Attachment C,p.20.) Planning Commission Staff Report, PA-1800316(UP) 87 Response Letters