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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 4 There is no indication the County has considered the required soils information during its review of the Project. By converting farmland to urban use in a leapfrog pattern, the Project directly violates General Plan policies designed to prevent this outcome. Contemplating growth, the General Plan Land Use Element emphasizes that protecting agriculture from impacts will necessitate "shifting away from historically inefficient development patterns" and"require development to take on new forms that make more efficient use of existing infrastructure, reduce pollution, support public transit and other modes of active transportation, and preserve agricultural and open space lands." (P. 3.1-3, emphasis added.) Relevant policies with which the Project conflicts include (but are not necessarily limited to): LU-1.5 Clear Boundaries. The County shall strive to preserve agricultural and open space areas that contribute to maintaining clear boundaries among cities and unincorporated communities. (P. 3.1-5.) The Project will further blur the distinction and boundary between agricultural areas and the City of Tracy. LU-1.7 Farmland Preservation. The County shall consider information from the State Farmland Mapping and Monitoring Program when designating future growth areas in order to preserve prime farmland and limit the premature conversion of agricultural lands. (P. 3.1-7 emphasis added.) The Project is not within a designated future growth area, and there is no evidence the County has considered information in the State Farmland Mapping and Monitoring Program in its environmental review of the Project. LU-1.4 Encourage Infill Development. The County shall encourage infill development to occur in Urban and Rural Communities and City Fringe Areas within or adjacent to existing development in order to maximize the efficient use of land and use existing infrastructure with the capacity to serve new development. The County shall balance infill development within outward expansion of communities and new development in other unincorporated areas. (P. 3.1-5.) The Project is not within or adjacent to existing development. The General Plan further specifically directs consideration of the ripple effects of agricultural land conversion: LU-2.15 Agricultural Conversions. When reviewing proposed General Plan amendments to change a land use diagram or zoning