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Letter to Kathy Allen November 16,2005 Page 2 2. Environmental Review:; We have only had a•cursory review of the initial study since we`ju5t received the;document-and comments are due today. Our review of the initial study in this:short time,period reveals a series of conclusory statements that.appear to be unsupported-by evidence on the record. As an example,there is-no analysis of how potential impacts E ,associated with odors will be dealt with. Even a properly run poultry operation.of this size mill create odors that will be difficult, if not impossible to mitigate and that will certainly affect downwind receptors. Without sufficient details on the proposed use,we can only conclude that there is not sufficient analysis regarding potential impacts to air quality (odors specifically) and there is no way of knowing if any mitigation measures that could be employed would be part of the project's approvals. As noted above, River Islands is directly downwind of this use and future residents of the project(as well as other areas of the City.of Lathrop downwind of.the project) will be adversely affected,the extent to which is unknown, due to the lack of information provided. Other issue areas, such as public utilities and services, groundwater and surface water resources and land use have a similar lack of details and backup information to support the conclusions of the initial study that the identified impacts are less than significant. In particular,we are concerned about impacts to Old River,due to the close proximity of this watercourse to the project siterpermittedsor-nonTernr tted-discharges-to-Old*Ri erco l'ccw and,there,c©ir1a'-b- i7pa-cts-fo� groim�water-resourcessas wel°l�-Delny-g t!p araalys3s ofsnchiotential' rnpa�t�`to`thegional Nater Quality Control board±and-to the=C-c7unty.t-nvironm-ental-Health-Division*direct cozifli`ct,with jeuirent;L EQA'case law;-(S6hdstrom v-Countyof Mendocino (198$) 202' iCj4 Opp-3��296):-Such potential-impacts shouldbe rev evF7d aid a a_lyzedyTI County-staff'and-relevant7respons-i•1•e,agepci-es"befbr,approval of,the-perrnit) giMMOMMMM is�ancl�pnt�rsti�i r�"F't� gation�measuresrevrev�`ed�are=approveda�`d'i�plerneri�"ed a more rigoroushich�is likely m this case), an EIR should be drafted and circulated for review. 3. Level of Project Review: Due to the dearth of information provided and in light of potential environmental impacts associated with this type of use, the project should be reviewed by the Planning Commission at a public hearing, with appropriate project information and a detailed site plan as required by the County Development Title, along with a proper environmental analysis. We suggest that the staff make this recommendation at its November 23rd Development Committee meeting. THE CAMBAY GROUP,INC. 73 W. Stewart Road, Lathrop CA 95330 209.879.7900 Fax 209.879.7928 www.riverislands.com