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JUL-08-1998 11: 18 209 858 5259 H.02IU2 Mr. Kai Luoma Re: SA-98-40 and SA-9841 July 8, 1998 Page 2 4. The information provided (both in writing and in conversation with you) does not adequately address the issue of septic tanks and wells. Continued expansion of septic tanks can lead to ground water problems. This area is also at the edge of an overdrafted groundwater basin and will increase that problem incrementally. In addition, the site is near Sharpe Defense Depot that has contaminated groundwater. Those properties near the Depot and within the City are prevented from using on-site wells because of this contamination and the possibility of spreading the contaminated plumes. How can this project be exempt? 5. The initial studies provided with the applications are inadequate. There is not an adequate project description. A checklist format is not adequate unless there is a source rioted for each answer and an explanation of why there is or is not a significant impact. For example, the initial study for both applications says that the project will not generate significant traffic volumes or make a significant contribution to an existing circulation problem but there is nothing to substantiate such a statement. None of the sources listed in the beginning of the initial study addresses traffic for this project and no additional sources are noted. In actual fact, there is a problem at Roth Road because of the traffic from the intermodal facility that the County also permitted without mitigation. Similarly, the initial study says that the project will not have impacts that are individually limited but cumulatively considerable. Once again, there is no discussion as to how this conclusion was arrived at and we seriously question its validity. In summary, this project has been segmented from the beginning and the County is thus far ignoring the traffic impacts of this project along with the many other projects approved by the County in the past without traffic mitigation measures being imposed. The City of Lathrop is recommending that this project either be denied or that adequate environmental review be conducted to mitigate the cumulative impacts of this project. Since this application is approved or denied at the staff level, and since information from other County departments is not due until July 14 (the same day our comments are due), we do not automatically have the ability to review the possible conditions you might place on this application. If you would like further input from the City,we would be glad to discuss our concerns with you. Sincerely, � •. at� Pamela R. Carder Community Development Director TOTAL P.02