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t CALIFIA, LLC. November 19,2020 Mr.Giuseppe Sanfilippo San Joaquin County Community Development Department 1810 East Hazelton Avenue Stockton,CA 95205 Subject: County Planning Commission Review of PA-1800316(Proposed Slaughterhouse at 7300 Delta Avenue,Tracy,CA)- Second Referral of Application and Negative Declaration Dear Mr.Sanfilippo: We first provided comments on this application on February 6,2020 and then again on July 28, 2020 regarding this proposal. In review of the re-referral by County staff of the site plan and Negative Declaration,we continue to have significant concerns regarding the proposal and the appropriateness of a mitigated negative declaration with the information that has been provided. We note the following issues: L Lack of Detail in the Initial Study and Odor Impact Analysis:The project description in the Initial Study continues to be lacking. Specifically,there is an inadequate description of the environmental setting,the thresholds of significance,and the quantitative and/or qualitative impacts of the proposed project as it relates to Air Quality,especially for odors.While the revised project description describes modifications to the proposed project that may reduce odors such as the storage of manure in an enclosed building, increase in frequency of being hauled off-site,and animal renderings being placed in a sealed container,these measures indicate that there are in fact odor impacts but with no quantification of what these impacts are,nor is there a description of the threshold of significance in which odor impacts can be analyzed against. The Initial Study fails to disclose this impact or analyze how the impact is considered"less than significant".The Initial Study should include the following to be considered adequate: a. Description of the environmental setting and the purpose of the modifications to the proposed project; b. Thresholds of Significance in which odor impacts are analyzed against;and C. A quantitative and/or qualitative analysis of the proposed project and if necessary, Mitigation Measures to reduce potentially significant impacts to a less than significant level. Further,the Initial Study fails to adequately analyze potential significant impacts related to"substantial emissions(such as those leading to odors)adversely affecting a substantial number of people"as required by CEQA Guidelines Appendix G,Section III:Air Quality. Planning Commission Staff Report, PA-1800316(UP) 151 Response Letters