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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) August 6,2020 Page 3 the Project will have any significant impacts or for the County to properly conclude that the Project will have no significant impact. The Revised IS/ND must be amended 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 a mitigation,monitoring,and reporting program(MMRP),as required by CEQA,if the Project is approved. (CEQA Guidelines,§ 1507A,subd.(d).) 11. The Revised IS/ND Does Not Clearly Demonstrate that the Project Will Not Result in Significant Impacts to Water Resources The changes and clarifications regarding manure management facilities and practices appear to have addressed most of the District's concerns 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,provided the changes are incorporated into a revised MMP. However,further corrections and clarifications are required to ensure that the changes discussed in the Revised IS/ND accomplish the stated objectives and are successfully implemented. The County,as the CEQA lead agency,has the obligation to ensure that impacts are clearly avoided and to adopt adequate enforceable mitigation measures. The Revised IS/ND should be amended to clearly describe how the County will monitor and enforce compliance with a revised MMP,and include mitigation measures to ensure compliance with applicable regulatory requirements. For example,despite the statement in the Revised IS/ND(p. 19)that chicken manure will be stored on a raised pad,the Revised Site Plan dated June 11,2020 (Revised Site Plan,attached as Exhibit B),does not indicate a raised pad in the area of the chicken barns(the westernmost area of the site detail). Instead the Revised Site Plan states "Manure stockpile to be stored under covered steel ag barns." By contrast,the easternmost portion of the site detail(where the proposed slaughterhouse is indicted)does identify a raised pad.' If the Project is approved,the conditions of approval should specify that all facilities that will generate or store manure will be constructed on an elevated pad above the flood plain. Further,the Revised IS/ND(p. 19)states that"the project has been conditioned so that all storm water is required to remain on site." However,no such mitigation measure or 'The Revised Site Plan has a notation for the southern portion of the Project site indicating"raised pad area not part of this application." It is not clear how this raised pad area relates to the raised pad area discussed in the Hydrology section of the Revised IS/ND, Planning Commission Staff Report, PA-1800316(UP) 82 Response Letters