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Martorella, Domenique [CDD] <br /> From: Scott Ivy<Scott.lvy@mccormickbarstow.com> <br /> Sent: Thursday,November 19,2020 11:51 AM <br /> To: perecords[CDD] <br /> Cc: Scott Ivy;Dawn M.Houston <br /> Subject: PUBLIC COMMENTS PA-1800316(11-19-20 6:00 p.m.) <br /> Attachments: PUBLIC COMMENTS.DOCX <br /> CAUTION:This email is originated from outside of the organization.Do not click links or open attachments unless you recognize the <br /> sender and know the content is safe. <br /> San Joaquin County Community Development Dept.—PUBLIC COMMENTS PA-1800316 <br /> perecordsA_sj yov.org <br /> I am co-counsel,along with Steve G.Rau,for the Costamagna family and their affiliates,including Ernie <br /> Costamagna,owner of APN 213-020-470,EGC Investments,LLC,owner of APN 213-020-440,and Gloria <br /> Costamagna,Trustee,owner of APNs 213-100-250,310,and 340. These parcels are just East of the proposed <br /> project site. <br /> The purpose of this email is to provide public comments on Use Permit PA-1800316 on behalf of the above <br /> parties to supplement those previously provided and any that may be provided at the hearing. <br /> The comments are attached,and are a further effort to try and avoid the necessity of legal action to enforce the <br /> provisions of CEQA should the proposal be adopted. The standards for a challenge of an approval by way of a <br /> negative declaration are extremely low,requiring only that we show there is"substantial evidence"(which <br /> includes facts,reasonable assumptions predicated on facts)that there is simply a"fair argument"that the project <br /> may have a significant environmental impact. <br /> We believe substantial evidence of a"fair argument"that the project may have significant environmental <br /> impacts has clearly been established by the materials submitted to date,including the attached. We would urge <br /> you to reconsider the proposal and instead proceed with a full EIR,which will likely be the end result if we are <br /> ultimately required to challenge this in court. <br /> Please confirm receipt of this email and that the comments will be included in the administrative record for this <br /> matter. If you have any questions,please do not hesitate to contact me. <br /> Scott Ivy <br /> (559)433-2255 <br /> Scott Ivy <br /> Partner <br /> i <br /> Planning Commission Staff Report, PA-1800316(UP) 153 <br /> Response Letters <br />