SU0005751 - Laserfiche WebLink

Home Browse Search

Mpy 04 06 09:39a Community Development 2099417270 p.2 .t v City of Planning Department 390 Tnwnc Centre Drive-1.ath:rop, CA 93330 Phone(209) 941-7320—Fax (209) 941-7339 wwxv,ci.lathro p.c a.a s May 3,2006 San Joaquin County Planning Commission. '. 1810 E. Hazelton Ave. Stockton,CA 95205 °` t Re: PA 050079�Olivera Family.Partnership ' Dear Commissioners: 'The City of Lathrop has reviewed the Staff Report for the proposed Concentrated Animal Feeding Operation(CAFO) that will result in the operation of a 1,000,000 bird poultry farm. In its broadest sense, the proposed Negative Declaration is inadequate and incomplete as an enviromnental review and public disclosure document for this proposed project. Thus, the proposed project cannot be approved because it will violate the California Environmental Quality Act(CEQA). More specifically, the City of Lathrop emphatically disagrees with the analysis presented in the Staff Report as follows: • Flooding/Drainage: The Staff Report relies on the preparation in the future of a drainage plan. There is no evidence'to show that a satisfactory drainage pian can be devised to eliminate any possibility of contamination of surface or ground waters from the proposed . operatiotl• • Odors: The Staff Report claims that measures will be taken to "reduce" odors and to "discourage" the proliferation of flies and other disease vectors, and makes note of the location of the manure pad in relation to the city limits of Lathrop. However, given that the urban population is located downwind from the site based on local prevailing winds, there is no analysis provided as to the expected odor impact. + Air Quality: The Negative Declaration and the Staff Report rely on-an offset rationale for determining that the impact of the project will -be below the Air Pollution Control District's threshold for significance. By scaling from the statements in the Staff Report, an operation of the magnitude proposed will produce about 24 tons per year of reactive s organic-gases (ROGs) and will exceed the Air District's 10-ton threshold of significance. The analysis relies on the applicant's statement that the other facilities will be closed as this facility comes into production. However, -no enforcement of such closure is proposed, and, thus, this project could result in a contribution to the Valley's smog of 2 and 112 times the District's threshold of significance. Nonetheless, this project will cause a significant unmitigated cumulative impact contributing to human health issues in this part of the Valley. Further, the Staff-Report offers no analysis of the effect of concentrating this emission source adjacent to an urban area as opposed to the current