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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 4 Stormwater and irrigation runoff from the Project site has the potential to degrade surface water in Tom Paine Slough,which is the source of the District's water supply. Application of manure that exceeds agronomic rates also has the potential to substantially degrade surface and groundwater quality. The District's questions and concerns stem from conflicting statements in the various manure management plan documents,the lack of information and analysis in the TS/MND about the range of potential water quality impacts beyond potential nitrogen effects,and the lack of mitigation treasures to ensure that actions identified by the applicant's engineer as essential to avoid nitrogen-related water quality impacts are implemented. Mr.Chesney states,"Crops planted will consist of grain-type plants such as rye,oats, wheat and orchard grass." (Staff Report,Attachment C,p.36.) He then presents the estimated nitrogen fractions from the manure to be generated by the Project(up to 244 tons per year),as well as nitrogen uptake estimates based on crop types and acreage. (Id.,p.37.) Mr.Chesney concludes that the calculations demonstrate that"barley,oats and wheat crops will assimilate nitrogen produced from manure land applications provided these crops are double cropped meaning that two crops are grown per year on the subject acreage." (Id.,p. 38.) The analysis of nitrogen uptake,and Mr.Cheney's conclusion about the assimilative capacity of on-site crops,is based on nitrogen uptake values of barley,oats,wheat,and orchard grass;no information is provided about uptake values for rye,and the analysis and conclusion does not include rye. Thus,there is no evidence to demonstrate that nitrogen uptake will be sufficient if rye is planted on site,as is indicated on page I of the Manure Management Plan. (Staff Report,Attachment C,p.36.) And Mr.Chesney's nitrogen assimilation conclusion indicates that double cropping is necessary to ensure sufficient nitrogen assimilation(Id.,p.38),but there are no commitments or mitigation measures to ensure that double cropping will occur. Mr.Chesney also states that no synthetic nitrogen fertilizers should be applied to the cropland. (Id.) However,no mitigation measures are included that prohibit the use of synthetic nitrogen fertilizers. Mr.Chesney further states that sufficient nitrogen uptake will occur only if the organic fraction of the manure mineralizes to plant available nitrogen(PAN),which depends on "certain environmental Conditions." (Id.) These specific conditions are not identified in the Manure Management Plan nor in the 1S/MND,thus,there is no information to demonstrate that the appropriate environmental conditions necessary to ensure mineralization to PAN of the organic fraction of the manure will be present on site. Mr.Chesney also states that mineralization will occur in the spring and summer months of the year. (Id.) This indicates the need for a mitigation measure limiting manure spreading to the spring and summer months. The lack of mitigation measures,and lack of any information about manure handling Planning Commission Staff Report, PA-1800316(UP) 88 Response Letters