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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 7 in the IS, and where mitigation is suggested, there is no discussion of the effectiveness of such measures. Repeatedly the checklist answers are inconsistent with the narrative discussion. The IS/MND does not meet CEQA's most basic requirements, leaving the District and County decisionmakers without adequate information to understand the Project's impacts. A. Agricultural Lands Contrary to the IS's unsupported conclusion, the Project will permanently convert agricultural land to non-agricultural use, in conflict with General Plan goals and policies. Moreover, given the fundamental incompatibility of the proposed use with surrounding agricultural use, it is reasonably foreseeable the Project will result in the further conversion of adjacent agricultural lands. These clearly significant impacts must be adequately evaluated, disclosed, and mitigated, consistent with CEQA and the County's General Plan policies for mitigation of conversion of agricultural lands. Due to the significant impact, a mitigated negative declaration is not appropriate, and an environmental impact report (EIR) is required pursuant to CEQA. In preparing the EIR, the County must consider alternatives that would avoid this significant impact, including an alternative location within an urban area, consistent with General Plan policies. B. Air Quality The IS identifies that the Project's impacts on air quality are less than significant, and that no mitigation is required. However, mitigation measures from the San Joaquin Valley Air Pollution Control District are listed. There is no information comparing Project emissions to applicable thresholds of significance, or how identified mitigation measures would be feasible for the Project. For example, there is no analysis of how the mitigation measure requiring "improve walkability" could be achieved for the Project, given its rural car-dependent location. The mitigation measures contain no performance standards, nor is there any discussion of how, or to what degree, they will reduce the Project's air quality impacts. C. Cultural Resources The checklist identifies that impacts to cultural resources will be less than significant, with no mitigation required. But the narrative identifies mitigation measures that could be imposed. The impact appears to be at least potentially significant, with mitigation required. D. Hydrology & Water Quality The IS checklist identifies seven impacts that are less than significant with mitigation incorporated,but the IS does not discuss the nature or potential extent of these potentially significant impacts, or identify any mitigation measures. Thus there is no way for the District or public to understand the nature or magnitude of potential impacts, or to evaluate the effectiveness of any required mitigation measures.