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is downwind of the project site and is approved at this time to include 11,000 dwelling units at with over 30,000 residents. These residents,existing and future,are sensitive receptors of the odors that will emanate from the proposed slaughterhouse. As noted in the City of Lathrop's response to your referral,dated July 23,2020 and provided to you,the initial study fails to adequately analyze potentially significant impacts related to"substantial emissions(such as those leading to odors)adversely affecting a substantial number of people)."hz addition to the comment above,the project description does not include information related to odor control measures for the 1,600 square foot.animal processing portion of the agricultural building to reduce odor impacts to a less than significant level.Additionally,the storage of manure may produce objectionable odors that may be considered a significant impact. As a result,we also request that an Air Quality Analysis be prepared by a qualified professional to analyze potentially significant impacts related to odor.This would be in addition to the detailed information and data necessary to describe the whole of the action described above. 3. Manure Management Plan:The Manure Management Pian(MMP),dated September 6, 2019 is not consistent with the project description.The project description states that "manure will be hauled off site to an approved facility a minimum of once per month, and not utilized for crop production on the property.°However,the Manure Management Plan describes how manure will be spread on the cropland(Page I of MMP)and that manure deposited from pastured animals will not be raked up.According to the project description and MMP,the project will also include pastured animals(cows,goats,and sheep/lamb)but the MMP is not consistent with the project description in how manure will be managed,Additionally,the MMP states that approximately 3,000 chickens will be present on the site and housed in environmental houses.However,the project description states that approximately 1,500 chickens will be kept in a fenced enclosure with an area of approximately 6,000 square feet.The MMP has not been updated to the revised project description. We urge the County Planning Commission delay action on the application and negative declaration Laid a more thorough environmental analysis can be performed and be recirculated for public review.A more robust document(e.g,FIR)may be required. Should you have any questions about this letter,you may contact me(209)879-7900 or sdellosso(ibriverislands.com. We also request that we continue to be notified of any proposed action regarding this application. CALIFIA,LLC 1676 N.CALIFORNIA$Lvt).,SUI7E 420,WALNUT CREEK,CA 94596 (925)933-1405 I FAX(925)933-1404 Planning Commission Staff Report, PA-1800316(UP) 142 Response Letters