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Analysis Background This project consists of twenty-four (24) lots that were created as part of two antiquated subdivisions, Bret Harte Gardens and Melton Tract. The original parcels range in size from ten (10) to forty(40)acres. Density Development Title Section 9-905.9 (a) states that the area and width of lots or parcels in a subdivision map shall conform to the particular zoning district in which the property is located. However, Section 9- 905.9(e)(2) states that any subdivision map that redesigns an existing subdivision in which the density of lots is not increased is not subject to the minimum lot size requirement. There are twenty-four(24) legal lots within the five parcel numbers submitted with this application. These parcels are part of two antiquated subdivisions, Bret Harte Gardens and Melton Tract. The tentative map dated June 15, 2006 indicates the redesign of the twenty-four (24) lots into twenty-one (21) lots. Fewer lots means the density has decreased and therefore the subdivision is not required to conform to the forty acre"minimum lot size requirement of the AG-40 zone. Farm Bureau The San Joaquin Farm Bureau Federation was sent a referral on June 23, 2006. The Farm Bureau responded with a letter dated July 19, 2006 in opposition to the project stating that"the re-subdivision of lots in the AG-40 zone to include 17 lots of 2.16 acres will be detrimental to the agricultural viability of the neighboring farms, ranches, and dairies. This is leapfrog development." The Farm Bureau recommends a full Environmental Impact Report (EIR). There are currently 24 existing lots. If the project is approved, there will be twenty-one lots. Parcels in the AG-40 zone are permitted one primary residence per parcel. Therefore, the potential number of primary dwellings would decrease with approval of this project. If the project area were developed as it currently exists, new roads that meet rural residential standards would need to be constructed. Moving sixteen lots so that they have direct access onto a County-maintained road would decrease the number of roads required for development. The Initial Study for the project found no significant adverse environmental impacts associated with this prcject and therefore an EIR is not required. The conditions of approval will ensure that the impacts from development will be less than significant. Opposition Two letters were received in opposition to this project One letter addresses concerns regarding the increased number of potential wells and the impact of the surrounding dairies on the project. The other letter stated that other neighbors may want to subdivide their property in the same way, thereby creating a residential community. The letter stated that"we could end up with an unincorporated area of houses in a farming community that could adversely affect the farming in our whole community. Neither letter specifically opposes the project. Each lot could have one residential well. The approved project will have fewer parcels than what currently exists. Therefore, the potential number of wells has not increased. This project meets Development Title criteria for subdivisions in the AG-40 zone. The project does not increase the density of existing parcels. It relocates sixteen parcels that do not have direct access to a county maintained road and locates them along Manteca Road and Melton Road. The purchasers of the parcels will be notified of the County Right- to-Farm ordinance. The right-to-'arm ordinance requires that the following note be placed on the Final Map: San Joaquin County PA-0600346\Circle JM Dairy Community Development Page 3