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Richard Prima 6613 E.Sargent Rd. Lodi,CA 95240 December 7, 2022 Giuseppe Sanfilippo San Joaquin County Community Development Department 1810 E. Hazelton Ave. Stockton, CA 95205 Subject: River Maid Land Company Applications PA-2100295 and PA-2200090 Thank you for taking the time to discuss the subject application with me when I called last week. You clarified several questions I had about the project and I am providing written comments for consideration by the Community Development Department and the Planning Commission. As I mentioned, I am generally supportive of the project as it supports a vital part of our local economy- agriculture. However, the project needs to be well designed and operated to avoid placing an undue burden on the environment and nearby residents. While the project is an expansion of the existing River Maid operation, it is being done on a separate parcel and I am concerned that the project is not being evaluated in it's entirety, rather the expansion is being looked at as a stand alone project. I think this in inappropriate for at least three reasons: 1) The expansion area includes a process wastewater disposal area that serves both the existing operation on APN 049-120-65 and the proposed expansion project. 2) River Maid's Waste Discharge Order R5-2021-0063 includes both parcels and the information clearly describes shared wastewater facilities between the two parcels. 3) River Maid has already provided an employee parking lot for the existing operation on APN 049-120-04, thus they are relying on that parcel for their existing seasonal employees. With these thoughts in mind, I offer the comments below: A) Traffic & Parking 1. The proposed site plan shows the sole access to the expansion area consisting of a new driveway that creates a 4-way intersection at Pine Street and Curry Avenue. Given that Pine Street to the east is a dead-end, one-lane road with only a half-dozen or so homes and the visibility eastward from Curry Avenue is poor, this new intersection should be evaluated for a multi-way stop control and the intersection fully improved by the applicant. This is preferable to offsetting the new driveway which would be a safety hazard. 2. Given that the expansion fronts Victor Road (Hwy 12), consideration should be given to provide access from the highway. -At a minimum emergency vehicle access since fire vehicles would come from the East on Victor Road and alternate routes are circuitous. 3. The site plan does not show enough of the existing project to evaluate on-site circulation, but there would likely be internal traffic between the existing facility and the expansion. Thus, should be a requirement that internal circulation be provided on-site - Pine Street should not be used for that internal traffic. 4. The initial study indicates the the expansion will generate less than 110 trips per day. This seems unreasonably low given that the study mentions a total of 81 employees during the season. No other data is provided to support this result.