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May 04 06 09:49a Community Development 2099417270 p.24 r City of Planning Division __... _ 390 Towne Centre Drive Lathrop, CA 95330 Phone(209).941-7290—fax(209) 941-7219 -: w�vur.ci;Iatfirop.ca.us April 27, 2006 Y . Kathy Allen Sari Joaquin County E{.' E 11l E D Community Development Department 1810 East Hazelton Avenue MY Stockton,CA 95205 Ci7YATTORNEYt3 Subject: PA 050079-Olivera Family Partnership OFFICE Dear hos.Allen: The City of Lathrop has reviewed the proposed Negative Declaration for the Site Approval Application for a discretionary project consisting of (1) a poultry farm to be constructed in six phases over a period of six years;(2)a 5,200 square foot packing roorn and a 25,800 square foot Iaving house;and(3) subsequent phases encompassing four additional laying houses; totaling an additional 103,200 square feet resulting in a total of one million birds. Opposition to Negative Declaration and Objection to Project Based on this review, the City opposes the approval of the Negative Declaration and objects.to this poultry farm project on the ground that the California Environmental Quality Act ("CEQA") will be violated if the Negative Declaration and project are approved by the San Joaquin County Planning Commission. Specifically, the proposed project will cause direct and cumulatively significant environmental impacts affecting water quality, drainage, water disposal, waste disposal, odors, and air quality. Factually,:the proposed poultry farm project is located adjacent to the San Joaquin River and across the river from the 4,900 acre River Islands project within the City. The River Islands project is an approved ►easter planned community projecting approximately 11,400 residences, schools, community parks, inland tivaterways and parks, and employment center. A poultry operation of this magnitude is no longer an agricultural use, but, as a confined animal feeding operation, is."an industrial operation" that would have a direct impact to City of Lathrop in general' and to the River Islands project in particular. Accordingly, the City of Lathrop strongly disputes the analysis and Conclusions of the Initial Study and Negative Declaration for the following reasons. First, reliance on the imposition of government regulations to mitigate potentially significant environmental impacts is no substitute for thorough analysis of the nature, scope and severity of environmental impacts, particularly with respect to air and water 'quality in this case. There is no quantitative comparison of the "before" and "after" environmental effects of a one million bird poultry farm, particularly with respect to air and water quality. Stated differently, there is no objective determination of the nature, scope and severity of environmental impacts potentially generating from this enormous project. I