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applicant will also be required to file a Waste Management Report to*be <br /> approved by the Central Valley Water Quality Control Board (CVRWQCB)." Our <br /> understanding is that the CVRWQCB is not a county agency. We therefore <br /> request that your staff explain this apparent discrepancy. <br /> : .. :. -, <br /> We understand the statement under Environmental Impact which defines -0 <br /> the requirements for"Yes" answers to the questions contained in these sections�,., <br /> as based on California Environmental Quality Act (CEQA) guidelines. However,L.- <br /> we're not convinced your staff understands that CEQA was intended to'be. - <br /> interpreted in such a manner so as to afford the fullest possible protection to the <br /> environment within the reasonable scope of the statutory language.,(Please <br /> refer to Friends of Mammoth v. Board of Supervisors, S Cal. 3d 247.). <br /> As such, the language contained in this section following "substantial <br /> evidence" is generally interpreted and reported by other public agencies'to ready <br /> "substantial evidence that the project may have a significant.effect on the <br /> environment." Under CEQA, a significant effect on the environment is'defined <br /> as-a substantial adverse change in the physical conditions which exist in the .. .t. <br /> area affected by the proposed,project. (Please see Section-15382)s If your- <br /> agency approves this project, there will be a substantial a6e"rse change in:the+ : <br /> physical conditions which currently exist.in our neighborhood in the form of.a_,w <br /> deterioration of existing air quality;.the creation of objectionable odors,'and an,::. <br /> increased risk of groundwater impairments. <br /> Each egg-laying hen can excrete up to 18 pounds of manure per year.- <br /> This <br /> ear:This manure contains high,levels of bacteria and.pathogens, including E. Coli <br /> and Salmonella, as well as metals like arsenic, copper and zinc.' These'metals <br /> can cause groundwater impairments over time if left to accumulate in settlement`. <br /> ponds. The solid waste also contains approximately 3.50W nitrogen and.1.8% d..} <br /> phosphorus. An excess of nitrates.in groundwater can lead to health problems,, :*l <br /> particularly in small children: The over-application of manure,`or a leaking; i <br /> sediment pond can lead to excess nitrates'in our groundwater. This concerns us, ; <br /> since we all share a common aquifer. Additionally, we fail to understand how <br /> any,solid waste management plan that processes the waste material on-site can <br /> be successful as there are only ten acres upon which to draw from.--Any soli&r-,J <br /> waste management plan of this type should incl ut de requirements fora, <br /> groundwater monitoring, recordkeeping of monitoring results and regulars - <br /> inspections of any settlement ponds to locate possible leakage: <br /> Chicken manure is also very high in urea.'During'decomposition of theme;, <br /> solid waste, large amounts of ammonia are,produced. Atmospheric emissions of <br /> ammonia (NH3), nitrous oxide,(N20) and methane (CH4)"associated.with animal <br /> waste are a significant problem and contribute to a detrimental impact on the <br /> environment: Additionally, these agricultural gaseous emissions have the <br /> potential for long distance transport in our ambient air. Agricultural pollution <br /> caused by animal waste can have a serious impact ori'our air.quality:,,Historical <br /> meteorological datarshould be reviewed to verify the average wind speed:and i <br />