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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 4 condition of approval is included in the Revised IS/ND. Additionally,in its January 17,2019 comment letter on the IS/MND,the Regional Water Quality Control Board(RWQCB) identified a number of applicable regulatory requirements,including waste discharge requirements and compliance with the Irrigated Lands Regulatory Program;a mitigation measure should be included to require compliance with this program and all permits identified by the RWQCB. A mitigation measure also should be included requiring documentation of how the revised MMP complies with the San Joaquin County Environmental Health Department Confined Animal Facility Manure/Solid Waste Management Plan Guidance Document. Finally,the Revised IS/ND should be amended to include a mitigation measure requiring that the owner consult with the State Water Resources Control Board and,if necessary,obtain an Industrial Storm Water Permit,and comply with all conditions of any such permit. IV. The Revised IS/ND Does Not Adequately Resolve Questions About Potentially Significant Impacts to Public Health and Safety and District Facilities from Vectors There is insufficient information in the Revised IS/ND to demonstrate that the Project will not result in potentially significant impacts from vectors,including 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 Revised IS/ND must be amended to identify specific requirements of the County Mosquito and Vector Control District(Vector Control District)and the California Health and Safety Code that apply to the Project and explain how those requirements will avoid significant impacts. To ensure that impacts from vectors will not be significant,at a minimum,the Revised IS/ND must be amended to include a mitigation measure requiring the applicant to consult with the Vector Control District,provide documentation of applicable requirements,and comply with all applicable requirements. The MMRP should require that the applicant provide proof of such consultation and ongoing proof of compliance with applicable requirements. V. The Revised IS/ND Does Not Address Potential Impacts to the District's Water Conveyance Facilities As indicated in Revised Site Plan(Exhibit B),a District-owned,operated,and maintained irrigation pipeline rims along the south side of the Project boundary,and a District drainage canal runs along the north side of the Project boundary. It does not appear that the Project proposes to locate buildings or other facilities in proximity to the District facilities. However,to ensure that District facilities are not damaged,and that the District retains access to this critical public infrastructure,a condition of approval should be included requiring the applicant dedicate a 30-foot easement for the District pipeline and a 60-foot easement for the District drainage canal,measured from the center of the pipeline and canal. The conditions of Planning Commission Staff Report, PA-1800316(UP) 83 Response Letters