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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 8 The District is concerned about the potential for the Project to contaminate surface water and District water supplies. In particular, the Project's proposed reliance on a septic system in an area with high ground water levels creates the potential for significant water quality impacts. The Project site has a tile drain system that drains to the San Joaquin River. Thus, it is reasonable to assume Project wastewater will seep into the drain and then into the river. Similarly, the Project has the potential to significantly impact water quality from the discharge of contaminated stormwater runoff into District ditches. The IS states that stormwater will be detained on site,but there is no information about how runoff into the District's irrigation canal will be prevented. Because the water table under the Project site is very high, it is reasonably foreseeable that rising groundwater levels during wet periods could cause the water level in the Project stormwater detention basin to be released from the basin and reach the District's canal. Thus it is not clear to the District that the County has adequately considered the site-specific conditions in its impact analysis. There is a fair argument that the Project likely will create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff, and without substantial additional information and clearly effective mitigation measures, an EIR will be required to address these potentially significant water quality issues. If approved, the Project should be conditioned to demonstrate that it will not discharge any additional waters, greater than predevelopment flows, or create the potential for such discharge from the septic system, into the District's ditches or canals, unless such runoff is first treated to State standards. E. Flood Control RD 1007 is located along the southerly edge of the secondary zone of the Legal Delta, north of Interstate 205 and the City of Tracy. RD 1007 comprises nearly 6,100 acres of land and about 9.07 miles of non-project levee along the south bank of Old River, Tom Paine Slough and Sugar Cut. RD 1007 is a critical infrastructure tract that protects major roads/freeways, the City of Tracy's main sewage treatment ponds, storm drain facility, and is in close proximity to the pumping plants for the Central Valley Project and State Water Project. RD 1007 is also responsible for flood protection and maintenance of the levees in the Project area. The Project is located within a special flood hazard area. The IS does not evaluate the Project-specific flood risks, but merely states, "At the time of future development, all new construction and the substantial improvement of any structure in the area of special flood hazard shall be elevated a minimum of 13-feet or flood-proofed in accordance to San Joaquin County Development Title Section 9-1605.12(a), (b), and(c)." There is no information about how the Project will be flood proofed, or how, in the alternative, it will be feasible for it to be elevated a minimum of 13 feet above grade. There also is no indication that the related impacts associated with flood proofing or elevating the structures 13 feet above grade were considered. Where will the soils required to elevate the structures be obtained? What will the aesthetic impacts be of 27,000 square feet of structures constructed 13 feet above grade? The IS states, "The proposed building will be subject to all applicable Development Title requirements regarding setbacks and building heights. As a