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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 9 result, the proposed project is not anticipated to have an impact on aesthetics." The IS fails to explain how flood-compliant structures would comply with Development Title requirements regarding building heights. F. Traffic and Parking Impacts The Project will generate a significant number of vehicle trips and is not accessible by walking or transit. The project description indicates this is a proposed regional use that will redirect vehicle trips currently being made to the Bay Area into the middle of County agricultural land. The Project thus conflicts with General Plan policy LU-1.8 Support for Alternative Transportation Modes, which provides, "The County shall encourage land use patterns that promote walking and bicycling and the use of public transit as alternatives to the personal automobile." (P. 3.1-6.) Further, while onsite parking is provided, the District anticipates that during large events attendees will park on the side of the road, where there is no shoulder, creating a safety hazard for pedestrians and the potential for conflicts with agricultural vehicles. Moreover, there is a narrow bridge over the District's main canal at the intersection of Bethany Road and Naglee Road that may require widening in order to safely accommodate two-way and increased traffic. Finally, the trip analysis does not appear to consider construction trips, including trips associated with importing soils to elevate structures 13 feet, consistent with the flood control requirements discussed above. G. Tribal Cultural Resources The checklist is marked"no impact" for each question in this section, but mitigation measures are identified in the narrative discussion. While the measures are called"conditions of approval,"they clearly function as, and are intended as, mitigation measures and should be identified as such. Also, the IS does not contain any information on the response to the AB 52 consultation. H. Utilities "Less than significant with mitigation measures" is checked for a number of questions in this section, but no mitigation measures are identified. The IS contains no information about the Project's projected water demand or analysis of the adequacy of its proposed water supply. This not only violates CEQA but is inconsistent with County General Plan goals and policies designed to ensure reliable water supplies, including: GOAL IS-4 To ensure reliable supplies of water for unincorporated areas to meet the needs of existing and future residents and businesses, while promoting water conservation and the use of sustainable water supply sources. (P. 3.2-34.)