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SA - 010075 b. WASTE DISPOSAL Condition of Approval No. #3A requires that a Soil Suitability/Nitrate Loading Study be prepared to determine that the area is suitable for handling the amount of animal waste to be generated by the number of swine proposed. This represents delayed information which is needed before a determination can be made on the level of CEQA analysis required for this project and before the project can be acted upon. This manure generated by 500 pigs is significant but there is no indication on how the manure disposal will be handled. C. AIR POLLUTION The Air Pollution Control District in their letter dated October 17, 2001, indicated in part "confined animal facilities are serious potential odor 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. d. 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. 3. There has been an improper delay of numerous studies related to sensitive receptors, discharge requirements, noise, waste disposal and traffic impacts. It is inappropriate to approve of a project based on studies yet to be preformed. 4. The project has been designated as a "Feed Lot", but it is the City's position that the project is more appropriately defined as "animal raising" and that a Conditional Use Permit is the appropriate level of entitlement due to the large number of animals involved In summary, a Negative Declaration is not suitable for this project because of the potentially significant adverse impact of traffic, noise, air quality and odor associated with 500 swine so close to an urban area.