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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 6 IV. The IS/MND Fails to Demonstrate that Air Quality pacts Will Not Be Significant The Project has the potential to result in significant localized impacts from dust and odors that are not analyzed or mitigated,as noted by Califia,L.L.C.in its February 6,2020 letter regarding the Project. In addition to the Califia comments,the District notes that the IS/MND indicates that the Project will be required to meet the requirements for emissions and dust control as established by the APCD,and on that basis,concludes"that impacts to air quality will be reduced to less than significant." (Staff Report,Attachment C,p. 11.) The IS/MND contains no evidence or analysis regarding the level of potential emissions,nor does it discuss what APCD emissions and dust control requirements will be required. Thus,there is no way for the District to know the scope of potential Project emissions and dust impacts. At a minimum,the IS/MND must be revised to include a mitigation measure requiring the applicant to consult with the APCD,apply for any required permits,and comply with APCD pen-nit requirements. IV. The Project May Result in Potentially Significant Impacts to Public Health and Safety and District Facilities from Vectors There is insufficient information in the IS/MND to demonstrate that the Project will not result in potentially significant impacts from vectors,including rodents. The Manure Management Plan is merely an"outline"that states that a local pest control company will be hired and pesticides and traps will be used. (Staff Report,Attachment C,p.43.) The proposed conditions of approval contain an"informational note"that the Project is subject to the requirements of the San Joaquin County Mosquito and Vector Control District and the CA Health and Safety Code." (Staff Report,Attachment F,p.6,note 2.) The note to the conditions of approval further states that`Best Management Practices(BMPs)guidelines for stormwater devices,ponds and wetlands are available." (Id.) It is unclear whether this "informational note"states a condition of approval. Condition 6a requires the applicant to incorporate mosquito best prevention BMPs for the design,construction,operations,and maintenance of the proposed stormwater infrastructure. (Staff Report,Attachment F,p.4.) However,this condition is limited to potential impacts of the stormwater infrastructure and does not address other vectors that may be attracted to the Project site,such as rodents,which may pose a risk to public health and safety from disease,as well as potential degradation of District levees from burrowing rodents. The IS/MND does not explain what requirements of the San Joaquin County Mosquito and Vector Control District apply to the Project or how they will avoid significant impacts from vectors and mosquitos. To ensure that impacts from vectors will not be significant,at a minimum,the IS/MND must be revised to include a mitigation measure requiring the applicant to consult with the Mosquito and Vector Control District,provide documentation of Planning Commission Staff Report, PA-1800316(UP) 90 Response Letters