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r t • San Joaquin County Board of Supervisors April 10,2017 Page 5 'meetings and passings are infrequent'makes the 20 foot width of Frewart inadequate for this usage. Mr. Smith opined that the Project may have a potentially significant impact to traffic safety. Mr. Smith also pointed out that the IS/MND appears to not address or disclose the truck traffic for removal of the product. Thus,the Initial Study failed to disclose or discuss how many trucks would travel on the road removing the composted material. As Mr. Smith's expert opinion supports a fair argument that the Project may have a significant impact,CEQA mandates the preparation of an EIR. Failure to prepare an EIR violates CEQA and constitutes a prejudicial abuse of discretion. C. THE IS/MND FAILS TO MITIGATE THE RISK OF FIRE Testimony from the public identifies the potentially significant impacts resulting from fire at the expanded facility. The testimony discusses the number of fires that have resulted form the operation of the current facility. Expanding the size and scope of the operation may lead to additional fires putting nearby residents and their livestock at risk. The comments constitute substantial evidence supporting a fair argument requiring the preparation of an EIR. D. THE PROJECT WILL RESULT IN ODOR IMPACTING NEARBY RESIDENTS Testimony from nearby residents regarding odors from the existing operation and the potential for increased odors from the expanded facility constitutes substantial evidence to support a fair argument that the Project may have significant impacts regarding air quality and odors. Although the Initial Study provides for completion of a revised GIMP,the previous plan does not sufficiently mitigate odor impacts as indicated by the testimony and comments of the nearby residents. Moreover,nothing in the Initial Study indicates that a revised OIMP would reduce the impact to less than significant. In fact,as discussed below,the Initial Study contains no performance standard for the revised GIMP. Additionally,it is uncertain whether the revised OIMP would address the significant odors from the existing facility or the expanded facility. E. THE INITIAL STUDY FAILS TO DISCUSS AND MITIGATE IMPACTS FROM DUST Testimony from the public identifies the potentially significant impacts resulting from dust at the expanded facility. The testimony discusses the dust impacts from the existing operations. Expanding the size and scope of the operation may lead to additional dust putting nearby residents and their livestock at risk. The Initial Study does not address and disclose the dust impacts. Moreover,the Initial Study does not provide adequate mitigation measures to reduce the impacts from dust to less than significant. ,� J