SU0013675_STAFF REPORT - Laserfiche WebLink

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As stated in the Staff Report,the proposed project would not exceed the San Joaquin Valley Air Pollution Control District's(SJVAPCD)thresholds of significance as it relates to Air Quality. The Initial Study fails to adequately analyze potentially sigriftcant 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, The City understands that all properties within any zone in San Joaquin County are subject to the San Joaquin County Right-to-Farm Ordinance and that the County "recognizes and supports the right to farm agricultural lands in a manner consistent with accepted custorns, practices and standards" (Page 7 of Staff Report). However, the Right-to-Farm Ordinance does not absolve responsibility to adequately analyze and disclose potentially significant environmental impacts related to odor. The Planning Commission will be faced with many questions regarding odor for which the response is going should not be limited to "the County has a Right-to-Farm Ordinance." The Planning Commission should be provided with information on odors before supporting Staff's recommendation that the IS l MND is adequate. Furthermore,the proposed project includes a requirement for approval of a Use Permit which implies that there are inherent issues with this use that need special consideration (i.e. operation of the business, required findings for approval, and in this case, the potential for odor). Finding Number Four(4)from the"Findings for Use Permit"states that"issuance of the permit will not be significantly detrimental to the public health, safety,or welfare or be injurious to the property or improvements to adjacent properties" The supporting statement is that the Initial Study/Mitigated Negative Declaration covers all of the potential environmental impacts. However,there is no analysis for potential environmental impacts related to odor. The City of Lathrop requests the Planning Commission continue the item to a date uncertain so that an Aar Quality Analysis can be prepared by a qualified professional to analyze and properly disclose the potentially significant impact related to odor, Once completed, the Initial Study should be re-circulated for public review consistent with CEQA Guidelines Section 15073.5. The City of Lathrop appreciates the opportunity to comment on the Planning Cotmnission Staff Report for Item#2 and looks forward to San Joaquin County working cooperatively with the City of Lathrop on this project. if you have any questions please can me at(2D9)941-7296 or email me at mmeissner@ci.lathron.ca.us. SincerelMssn —�Mark M Community Development Department Cc: Stephen Sal Mote.City Manager Salvador Nawarrete,City Attorney Glenn Gebharck,City Engineer Brad Taylor,Associare Engineer Michael Ring,Public Works Dircuor Susan De11'Gsso,River Islands Development Rick Cap iat,Principal Planner Ramon Batista,River]glands Development Jennifer Jolley,San Joaquin County Planning Commission Staff Report, PA-1800316(UP) 119 Response Letters