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r-)7- William H. Reynolds 4444 W. Undine206 MARY, P2007 StocktonCA 9 SAN JOAQUIN COUNTY March 27, 2007 ENVIRONMENTAL HEALTH DEPT. Donna Heran REHS, Director San Joaquin County Environmental Health Department 304 E. Weber Ave. Third Floor Stockton, CA 95202 RE: San Joaquin County Community Development Department Application Number: PA-0500729 for Applicant: Olivera Family Limited Partnership Dear Ms Heran, The above referenced Applicant has a pending Site Approval application to build a 900,000 chicken poultry/egg farm on Undine Road on Roberts Island. The Community Development Department is proposing a Negative Environmental Declaration be adopted for this Large Confined Animal Facility(CAFO). I believe this is a mistake and a full Environmental Impact Report should be required for what would be San Joaquin County's largest egg farm for the following primary reasons: 1. The project is located in the Primary Zone of the San Joaquin Delta, which is a designated Flood Zone. The project site was under water in the winter of 1997. In high water years there is no way to contain runoff water on the property site. 2. The Site Plan indicates the at supply for this large CAFO is to come from a well on the property. I am not aware of any well on the south end of Roberts Island that produces over 200,000 gallons daily. At least this amount of water will be needed daily to cool, feed and clean up after 900,000 chickens. The Applicant has stated that much of the water used will need to be treated by Reverse Osmosis to remove iron and other water elements that will clog chicken watering emitters. Even the most efficient reverse osmosis systems produce at least two gallons of brine for each gallon of purified water,this finther adds to the water needed to sustain the poultry/egg farm. Is this amount of water pumped from a well on Roberts Island sustainable? Will a new well pumping at this high capacity affect the shallow wells of surrounding property owners? 3. The water table on the project site is only 6-8 feet to ground level depending on the tide levels. The Site Plan does not address how or where over 200,000 gallons of water per day needed to cool, feed and clean up after 900,000 chickens will be handled. It certainly cannot be allowed to percolate into the water table, nor allowed to drain on to neighboring property. her,runoff water from the approximately 10-acre facility will also need to be handled on site.