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W move to avoid the cumulative effects. This would also adversely effect the sales efforts for the homes to be built down wind of this project on Stewart Tract. Page7. Plant/Aninial.Life Discussion of 3(a&b)'is not accurate. Apparently the Natural Diversity Database is poorly maintained and cannot be relied upon.. Both Swanson Hawk and Burrowing Owls are-found in the near vicinity of the project, this includes both nesting of the birds and foraging areas. Page 7.. Air/CWnate Discussion in 4(a) is poorly phrased and somewhat naive. A manure management plan is indeed required by the Environmental Health Department. This plan cannot guarantee that potential air,quality impacts associated with the poultry farm will be reduced to a less than significant level. I invite you to drive upwind of either Stockton's Water Treatment facility along Highway 4 or Lodi's Water Treatment facility west of Interstate 5 on a hot day for specific examples. Page 7. Utilities and Public Service The discussion of 8(a) does not recognize the difficulties of retaining all storm drainage created by the project on the site. During events like the floods that occurred in the spring of 1997 extensive pumping to Old River was required to remove standing water seeping under and through levees from the project site. Pictures of the site during the 1997 flood events are attached. Page 8. Transportation The discussion of 9(a)) does not considered the existing condition of either Undine or Roberts Roads. Additional regular traffic particularly trucks will hasten their breakdown. Also there is no discussion of the increased traffic's effect during winter periods of"Valley Fog"with impaired visibility_ Page 8. Land Use The discussion of 13(b)recognizes that property south of the proposed poultry project is located on Stewart Tract in the City of Lathrop. It does not recognize that the City of Lathrop has seriously earmarked Stewart Tract for residential housing development for almost 15 years. The Stewart Tract development now called "River Island" will undoubtedly begin during the proposed six phase (years)contemplated to build the envisioned poultry project. It is foolish to think a poultry farm adjacent to a major housing development is compatible. It would not be allowed in the planning process if they were in the same jurisdiction. We believe significant further thought and on site work needs doing to accurately and professionally update this Initial Study. The concerns are too great for a Negative Environmental Declaration to be adopted based on the errors it now contains. Thank you for this opportunity to review and continent on the Initial Study. 4