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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 5 reclassification to change from an agricultural use to non-agricultural use, the County shall consider the following: • potential for the project to create development pressure on surrounding agricultural lands; • potential for the premature conversion of prime farmland, farmland of statewide importance,unique farmland, farmland of local importance, and confined animal agriculture; • potential for impacts on surrounding farming operations and practices; • provision of infrastructure and services to the new use and the potential impact of service demands or on the surrounding area; and • protecting habitat restoration opportunities. (P. 3.1-69.) The Project does not involve a change to the General Plan land use diagram or zoning reclassification, but approval of the proposed use permit would have the same effect,by changing an agricultural use to a non-agricultural use and prematurely and permanently converting important farmland, while creating the potential for impacts on surrounding farming operations and practices. If approved, the Project should be conditioned to require it to fully mitigate for its conversion of agricultural land, consistent with the General Plan's Agricultural Preservation Mechanisms, Policy LU-7.10. Agricultural Mitigation Program, which requires that "The County shall continue to require agricultural mitigation for projects that convert agricultural lands to urban uses." (P. 3.1-61.) II. The Proposed Use is Incompatible with Surrounding Agricultural Uses Although the County Development Title allows religious assemblies on lands designated General Agriculture (A/G), the proposed use is unlike any of the uses contemplated in the General Plan for this category of lands: This designation provides for large-scale agricultural production and associated processing, sales, and support uses. The General Agriculture Designation generally applies to areas outside areas planned for urban development where soils are capable of producing a wide variety of crops and/or support grazing. Typical building types include low-intensity structures associated with farming and agricultural processing and sales. (P. 3.1-57.) "Allowed Uses"within the A/G land use are limited to commercial agricultural operations and associated support uses: