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-3- Air Pollution The Air Pollution Control District in their letter dated October 17, 2001, indicated in part"confined animal facilities are serious potential odors sources due to the production and handling of animal wastes. The District's Guide for Assessing and Mitigating Air Quality Imports(GAMAQI) recommends that projects of this type conduct additional review of sensitive receptors which are located within one mile, to determine if the impact is significant." The letter further states that the "District recommends that the County review all available options and include all measures deemed feasible by the County to reduce this potential impact." It is the City's position that these impacts have not been adequately addressed in the Negative Declaration. Traffic The studies do not adequately address how the animals will arrive and leave the site. Therefore, it is unclear how a determination could be made regarding the traffic impacts or the impacts on two-lane country roads such as Frewert, Manthey, Lathrop, and Roth Roads. Response to Appeal Statement No. 2 Noise Impacts The Initial Study prepared for this project indicated that noise impacts would be less than significant. According to Development Title Section 9-1025.9(c[5]) noise sources emanating from any agricultural operation, including activities associated with the processing or transportation of crops, when such activities are conducted on agriculturally zoned lands shall be exempt from the provisions of the chapter(Performance Standards, Chapter 1025). This project is an agricultural operation on agriculturally zoned land and is exempt from the provisions of the chapter. Waste Disposal The Environmental Health Department required as a condition of approval that the applicant supply a manure management plan and conduct a soil suitability/nitrate loading study for hogstanimal waste indicating that the area is suitable for the usage number of animals proposed. Development Title Section 9-1105.2(d)states, "The suitability of an area proposed for septic tank usage shall be determined prior to submission of a General Plan Amendment or Zone Reclassification application, the approval of a parcel map or final map, or the issuance of a building permit for other development project applications." The Department's requirement of a manure management plan and a suitability/nitrate loading study as conditions of approval is appropriate because these are commonly encountered reasonable mitigation measures reasonably justifying an expectation of compliance. Air Pollution A representative from the Air Pollution Control District has stated (in a phone conversation on November 8, 2001)that, because of the District's lack of experience with "pig farms," it will defer to the expertise of the Environmental Health Department. The Environmental Health Department determined that the conditions of approval would mitigate any potential air quality impacts to less than significant.