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City w4k4�� Community Development Department 390 Towne Centre Drive—Lathrop,CA 95330 Planning Division Phone(209)941-7290—Fax(209)941-7268 www.ci.lathrop.ca.us October 28,2020 San Joaquin County Community Development Department Attn:Mr.Giuseppe Sanfilippo 1810 East Hazelton Avenue Stockton,CA 95205 Re: Project 2"d Re-Referral for PA-1800316(UP)(7300 West Delta Avenue,Tracy,CA 95304,APNs:213-020-38 and-41) Mr.Sanfilippo: The City of Lathrop is in receipt of the 2"d Re-Referral for the above referenced project and would like to submit the comments below for the record and your consideration: - As stated in the City's July 23, 2020 and August 20, 2420 letters (enclosed),the City continues to express concerns related to Air Quality impacts as a result of the proposed project. The Project Description and Section III:Air Quality state that"the facility will process on average one (1) animal per day." The Initial Study does not include a description of odor control measures nor provide a floor plan of the agricukural building that illustrates the layout of the animal processing portion of the building. Additionally, the Initial Study does not describe the type of animal being processed or limit the number of animals being processed per day,only stating that on average one(1)animal will be processed per day. As stated in previous correspondence,the Project Description needs to be revised to be more specific and provide additional detail on the proposed use. As stated in the City's previous correspondence, the Initial Study fails to adequately analyze potential significant impacts related to "substantial emissions (such as those leading to odors) adversely affecting a substantial number of people" as required by CEQA Guidelines Appendix G,Section III:Air Quality. As stated in the City's August 20, 2020 letter, the City understands that all properties within any zone in San Joaquin County are subject to the San Joaquin County Right-to- Farm Ordinance. However, the Right-to-Farm Ordinance does not absolve the responsibility to adequately analyze and disclose potentially significant environment impacts related to odor. The response that "the Right-to-Farm Ordinance states, "Residents of property on nor near agricultural land should be prepared to accept the inconveniences or discomforts associated with agricultural operations or activities. Such inconveniences shall not be considered to be a nuisance [and]therefore,any incidental odors related to any agricultural farming activity are not to be considered a nuisance"is inadequate. Planning Commission Staff Report, PA-1800316(UP) 116 Response Letters