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Giuseppe Sanfilippo San Joaquin County Community Development Department Re: PA-2100238 (UP): Comments on Draft Initial Study/Mitigated Negative Declaration May 2, 2023 Page 6 • Crop production, grazing, and livestock raising facilities • Agricultural processing facilities (e.g., canning operations, stockyards, feedlots) • Agricultural support and sales (e.g., feed/grain storage, crop spraying, sale yards) • Single-family detached dwellings • Farm-employee housing and farm labor camps • Accessory second units and ancillary residential structures • Compatible public, quasi-public, and special uses • Natural open space areas (Ibid.) The Project would place a large high-intensity public use in the middle of highly productive farmland. Based on the District's long experience, such a use is not compatible with farming. The District is concerned about the potential effects the Project may have on District operations and facilities, due to the location within the District's boundaries and near its existing facilities. Conflicts and complaints from new urban uses about existing farming operations can involve everything from complaints about odors or pesticide use, to trash on farmland and conflicts between passenger vehicles and agricultural vehicles on narrow rural roadways. In the District's experience, the farming community bears the brunt of such urban/agricultural use conflicts, which are not mitigated by the Right to Farm ordinance. The ordinance does not eliminate the potential for limitations on the use of certain pesticides necessary for crop production, contamination of the District's irrigation supplies (through contaminated storm water runoff or trash), seepage of sewer water, and traffic and parking hazards, as explained more fully in these comments. The size and scale of the proposed facility amplify these concerns. And the "right to farm"will, as a practical matter,be meaningless if productive farmland is allowed to be converted to urban uses through leapfrog development, as with the proposed Project. Such development will increase the pressure to convert additional farmland, contrary to the General Plan goals and policies. The Project should be appropriately located within an established urban area, not in the middle of active, economically valuable farmland, consistent with the General Plan. III. The Draft IS/MND Does Not Satisfy CEQA's Informational Requirements The Draft IS/MND does not provide any evidence or analysis to support its determinations regarding the significance of project impacts for numerous issues. Despite being titled a Mitigated Negative Declaration, no specific mitigation measures are identified