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City of Lathrop _ �' °r "'"" Community Development . Planning Division p13 (209) 858-2860, Extension 327 \ h ' (209) 858-5259 Facsimile " October 16, 2001 oar Jennifer Jolley, Associate Planner C0n)mo" Z00J San Joaquin County Community Development Department 1810 East Hazelton Avenue Stockton, CA 95205 Subject: Site Approval-01-75 Richard Stagno This letter is in response to the subject application referral, initial study, and Draft Negative Declaration for a feedlot for 500 pigs, consisting of 24,725 square feet of animal pens and an existing 2,400 square foot commercial coach for office use, located on the south side of Frewert Road 4,600 feet west of Intersate-5. The City of Lathrop has filed an application with LAFCO to include the area between Interstate 5 and the San Joaquin River north to Roth Road within the City's Sphere of Influence. The proposed project site is included in this area. The development of the specific plan for the area will likely include residential, recreational, open space, and commercial areas but it will not include pig feedlots. The Riverwalk Specific Plan, a planned residential development that is within the City of Lathrop's Sphere of Influence and our General Plan, is located approximately 1800 feet south of the proposed pig feedlot site. The proposed use of the subject property will create objectionable odors to those existing residences in the area, to the proposed residences of the Riverwalk development and in addition the prevailing winds will care the objectionable odors over to existing residential areas currently in the City of Lathrop. The Initial Study is inadequate and the issuance of a Negative Declaration on this project is not appropriate. There are potentially significant impacts on the environment, specifically traffic, odors, flies and other pests and potentially inadequate sanitation facilities. There is no appropriate documentation in the Initial Study to support the conclusions that are made. It includes no discussion as to what thresholds are needed to consider any impact significant. There is no explanation of why odors are not a significant impact. Odors coming from an agricultural land use are not exempt from CEQA. This site may not be suitable for the type of development and for the intensity of development and may not be compatible with surrounding and proposed development. Issuance of the permit may be significantly detrimental to the public health, safety or welfare or be injurious to the property or improvements of adjacent properties. The site is very close to an existing urbanized area (Lathrop) and is in an area that has many smaller parcels even though they are zoned agricultural. In addition, with the larger number of smaller parcels surrounding the subject site and the location of the existing and planned residential development in the City of Lathrop, the County must find that the issuance of the permit will be significantly detrimental to the public health, safety and welfare because of the odors and flies from such an operation. 16775 Howland Road, Suite One, Lathrop, California 95330