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t" > CALIFIA, LLC. July 28,2020 Mr,Giuseppe Sanfilippo San Joaquin County Community Development Department 1810 Gast Hazelton Avenue Stockton,CA 95205 Subject: County Planning Commission Review of PA-1800316(Proposed Slaughterhouse at 7300 Delta Avenue,Tracy,CA)- Revised Application and Negative Declaration Dear Mr.Sanfilippo: We first provided comments on this application on February 6,2020;a copy of that letter is attached. We are in receipt of the notice for the resubmitted application,site plan and initial study,as well as County staff's recommendation for the adoption of a mitigated negative declaration for the revised proposal We continue to have concerns regarding the proposal and the appropriateness of a negative declaration with the information that has been provided, We note the following issues: 1. Lack of Detail in Protect Description and Deferral of lmbact Analyses;The project description states that"the facility will process on average of one(1)animal per day." The referral and initial study do not include specifics as to the types of animal Slaughtered,where the carcasses will be stored before final disposal,where they are to be disposed of,what odor and water quality controls will be in place for the remains and other appropriate mitigations for such a facility.We are also concerned that the site plan ROWS a"future slaughterhouse,office and general purpose ag barn,"which indicates an inerementalization of the use into a larger facility that the CEQA review being offered does not analyze.Under Sundstrom v.County of Mendocino,202 Cal,App.3d 296 (1988),and Gentry v.City of Murrieta,36 Cal.App.4th 1359(1995),the determination of whether a project will have significant environmental impacts,and the formulation of measures to mitigate those impacts,must occur before the project is approved;they cannot be segmented.We do not believe the whole of the action is being considered and that additional impacts are either not being fully described or are being deferred. 2. Air Quality Impacts:As stated in Section III of the initial Study,"the facility will process on average one(1)animal per day"and that"the second use is a chicken farm for a maximum of 1,500 chickens within a 6,000 sq.ft.enclosure with two(2)800 square foot metal agricultural barns for the storage of manure."As you were notified in our February 6,2020 letter,we are the property owners and developer of the River Islands Master Planned Community within the City of Lathrop,only one(l)mile from the project site. River islands is an approved urban development that already has constructed 2,000 residences,two schools,parks,and other nob-residential uses.The River Islands project Planning Commission Staff Report, PA-1800316(UP) 141 Response Letters