SECTION 4.0 ALTERNATIVES

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1 SECTION 4.0 ALTERNATIVES 4.1 CEQA REQUIREMENTS The key requirements under the California Environmental Quality Act (CEQA) to identify and evaluate alternatives in an Environmental Impact Report (EIR) are listed below: (a) states that An EIR shall describe a range of reasonable alternatives to the project, or to the location of the project, which would feasibly attain most of the basic objectives of the project but would avoid or substantially lessen any of the significant effects of the project, and evaluate the comparative merits of the alternatives (b) states that the discussion of alternatives shall focus on alternatives to the project or its location which are capable of avoiding or substantially lessening any significant effects of the project, even if these alternatives would impede to some degree the attainment of the project objectives, or would be more costly (c) states that The range of potential alternatives to the proposed project shall include those that could feasibly accomplish most of the basic objectives of the project and could avoid or substantially lessen one or more of the significant effects. Under CEQA, the County must identify feasible alternatives that will avoid, or at least lessen, any significant impacts associated with the project. The County must determine what represents a feasible alternative, taking into account costs and engineering feasibility, and how the alternative may affect meeting the project objectives. An alternative cannot be dismissed simply because it prevents the project objectives from being fully realized. Any new environmental impacts of an alternative must also be considered. In addition, the No Project Alternative must be evaluated in an EIR. 4.2 NO PROJECT ALTERNATIVE Under the No Project Alternative, the existing mining and processing operations would stop and the site reclaimed per the conditions in the 1997 and 2003 reclamation plans. On-site emissions of NO X from operating excavation and transport equipment, which may be considered a significant and not mitigable impact (Class I), would be avoided under this alternative. Under this No Project Alternative the following significant, but mitigable (Class II) impacts would be avoided at this location: Possible upstream headcutting due to excavations within the river channel and downstream scouring during flood events as bed load refills pit areas. S:\07 PROJ\Ventucopa GPS Mine\2009 Final EIR\4.0 Alternatives.doc 4-1

2 The removal of about 10 acres of alluvial scrub habitat from the Cuyama River channel during the 4- to 5-year mining period, and for several years afterwards as channel terraces and vegetation become reestablished. This effect would displace wildlife and reduce the amount of scrub habitat for wildlife use along this portion of the river for this time period. Potential direct effects and mortality to small mammals and reptiles from vehicle operations between the mine pit and processing area. Creation of potential impediments to wildlife movement by the mining operation in the river channel, forcing wildlife to find new travel corridors. Possible disturbance or displacement to the endangered blunt-nosed leopard lizard from adjacent mining activities. The upland processing plant would be restored to its former scrub and grassland habitat and active river channel allowed to restore itself naturally. PCC-grade aggregate would continue to be supplied to the region from various other existing and possibly newly permitted sources in Santa Barbara, San Luis Obispo, Ventura, and Kern counties. Assuming production at a similar rate, other similar projects are likely to also have the same Class I impact related to NO X emissions from mobile equipment. Some of these aggregate sources will establish haul truck routes that utilize segments of State Routes 33 and 166 used by traffic generated by the proposed project. Hence, the No Project Alternative may not entirely avoid the traffic, air quality, and highway noise impacts. 4.3 PROJECT AS PROPOSED: WESTERN PIT REPLACEMENT WITH MITIGATION The proposed 20-acre western pit replacement and 8-acre re-excavation of the Phase II/III mining area represents a reduced size and duration (4 to 5 years) alternative, when compared to the original application for a 30-acre expansion and continued mining of the 15-acre Phase II/III mining area over a 10 year period (RAM 2003). The dry season stage that previously was proposed across the width of the active river channel to the south has been eliminated. The proposed project reduces the potential for upstream headcutting and downstream channel degradation, although these effects would have been less than significant. The proposed project also utilizes the existing Processing Area. Except for the disturbance to about 9 acres of moderately low density alluvial scrub terrace habitat, the proposed project would have the same effects as existing mining conditions. It represents the most viable alternative for GPS to continue to produce Portland Cement Concrete- (PCC) grade aggregate and other marketable material in the shortest timeframe. This alternative is the least environmentally damaging practicable alternative that meets the objectives of continuing the life of an economically viable and competitive source of highquality sand and gravel products, including construction-grade aggregate located near an S:\07 PROJ\Ventucopa GPS Mine\2009 Final EIR\4.0 Alternatives.doc 4-2

3 existing major roadway, and operating in a manner that will maximize compatibility with surrounding land uses and minimize adverse environmental effects. 4.4 REDUCED MINING DEPTH (AND REDUCED ANNUAL PRODUCTION) Under this alternative, the proposed maximum allowable mining depth would be reduced in the replacement mine area to 40 or 50 feet. The objective of this alternative is two fold: 1) avoid encountering groundwater and potentially unstable slopes during mining; and 2) reducing the volume of the maximum excavated mine pit to increase the probability that it will fill with sediments during moderate sized runoff events. The latter objective would reduce the potential for adverse hydraulic effects from a deep pit being present in the river channel (i.e., headcutting, downstream channel bed erosion, bank erosion) and the interference with overall sediment transport in this segment of the river which would affect the mine pit size, and material quality. Annual production would be decreased under this alternative due to the reduction in the available material to be mined. The maximum daily production may or may not be reduced, but the frequency of days with maximum daily production would be less. The air quality impact related to NO X production from operations equipment may still be significant on high-production days. A shallower mine pit coupled with limitations on work hours, days, and production may decrease the magnitude of the impacts that were identified as significant but mitigable (Class II) for the proposed project, as follows: Possible downstream channel degradation and upstream headcutting due to sediment deficit in the river as mining rates exceed natural sediment replenishment rates. The potential for this effect may be reduced with a shallower pit, but the project as proposed can also mitigate this impact. The removal of 10 acres of alluvial scrub habitat from the Cuyama River channel during the 4-5 year mining period, and for several years afterwards as channel terraces and vegetation become reestablished. This effect would displace wildlife and reduce the amount of scrub habitat for wildlife use along this portion of the river. A shallower pit may have a slightly smaller boundary than the pit area as proposed, but the difference is not likely to be substantial. The nighttime lighting at the Processing Area would adversely affect nocturnal wildlife in the habitat area located to the south. To the extent that a shallower pit and reduced annual production may involve fewer peak production days, this effect may be reduced somewhat under this alternative. Haul trucks traveling from the mine pit to the Processing Area may inadvertently strike reptiles and small mammals. To the extent that there would be less annual production under this alternative, this impact would also be reduced. Appropriate worker training, S:\07 PROJ\Ventucopa GPS Mine\2009 Final EIR\4.0 Alternatives.doc 4-3

4 use of speed limits, and other methods, can also minimize this effect, so the difference would not be substantial. The mining operation in the river channel could create potential impediments to wildlife movement in the river channel and force wildlife to find new travel corridors. This effect would be the same under this reduced depth alternative as for the proposed project, and in either case will be mitigated through specifications for buffers adjacent to the pit area and for the haul route design and operation. Possible disturbance or displacement to the endangered blunt-nosed leopard lizard from adjacent mining activities. This effect would be the same under this reduced depth alternative as with the proposed project. Preconstruction surveys and appropriate management would avoid significant impacts to this species. Stockpiles and mining equipment at the Processing Area affect the aesthetic views of the valley for travelers along State Route 33, but this effect is less than significant. Changing the depth of the excavation would not alter this effect. The nighttime visual setting may be affected due to lighting at the Processing Area during night operations. To the extent that this reduced depth and production alternative lessens the frequency of peak production days, there may be some reduction of this effect. Other project conditions, however, will require lighting controls to minimize this effect, so the difference would not be substantial. 4.5 UPLAND MINE SITE Although no specific locations have been suggested with this project, there are scattered aggregate mines along the eastern flank of the coast ranges. Based upon the assumption that suitable subsurface conditions exist, an upland mine site located in the hills south or east of Taft could potentially provide material for PCC aggregate. Development of an entirely new site would require access, a 20- to 30-acre processing area and at least an 80-acre mine site to make this alternative economically viable. Such an alternative would avoid the hydraulic and biological impacts of mining in the Cuyama River. However it would likely displace over 100 acres of denser habitat with a higher potential for special-status plant and animal species such as kit fox, antelope ground squirrel, and blunt nosed leopard lizard. In addition, it would be difficult to reclaim the mine pit in an upland area because it would require the hauling and dumping of fill from another location to return the mine pit to pre-mining grade. The extraction of material from another location for mine reclamation purposes could adversely affect land use, biological habitat, cultural resource, aesthetic conditions and water quality at the source site. These reclamation impacts would likely be significant given the large volume and area required to supply the fill. Depending on location, it may not be visible from public roads. Assuming the same daily S:\07 PROJ\Ventucopa GPS Mine\2009 Final EIR\4.0 Alternatives.doc 4-4

5 production rates, air quality emissions would be similar to the proposed project, but of longer duration. Exploration, testing, leasing, permitting and approvals for an upland site would take approximately 4 to 5 years to plan and permit. 4.6 ALTERNATIVES CONSIDERED BUT ELIMINATED To be economical, new mining sites would be larger in acreage and affect new areas that are not already disturbed. They would take 3 to 5 years to acquire or lease and go through the necessary planning, CEQA review, permitting, and approvals BLM Land Immediately Downstream in Cuyama River Under this alternative, GPS would lease 40 to 80 acres in the active channel of the Cuyama River immediately downstream (north) of the existing mining site from the Bureau of Land Management (BLM). This alternative would require review under CEQA and under the National Environmental Policy Act (NEPA) because of the federal land ownership. This alternative has the advantage of using the existing Processing Area. However, this alternative would impact more alluvial scrub habitat that could support special-status species. It would also have greater hydraulic impacts in terms of potential headcutting and downstream degradation due to the cumulative impact of another new mine site within a channel. A larger mine pit would take a longer time to fill to the original grade of the riverbed. This alternative has the potential to confine flows around berms and wash out Big Pine Road. Air quality impacts would be the same but of longer duration. Mining operations in the channel may be visible to southbound travelers on Highway New Mining Site Upstream or Downstream in the Cuyama River This alternative would involve mining about 80 acres of currently natural riverbed in phases at various locations upstream and downstream. It would require a new processing area on the eastern terrace which would have the significant impact to approximately 20 to 25 acres of agriculture for the duration of the project (about 20 years). If located to the north (downstream) the processing area is likely to be more visible from Highway 33, and thus impact aesthetic conditions in the area. More alluvial scrub habitat and potential specialstatus species would be impacted for a greater duration. This operation would result in temporary (about 20 years), but probably significant, air quality impacts due to daily NO X emissions. All impacts of this alternative would be similar to alternative and of longer duration than the proposed project. S:\07 PROJ\Ventucopa GPS Mine\2009 Final EIR\4.0 Alternatives.doc 4-5

6 4.6.3 Floodplain Terrace Adjacent the Cuyama River DRAFT ENVIRONMENTAL IMPACT REPORT Under this alternative, a new processing area and mine pit would be located on the floodplain terrace adjacent to the Cuyama River in order to avoid the river channel and associated hydraulic and biological impacts. This alternative would result in a new significant impact: displacement of existing agriculture such that the agriculture viability of the affected parcels would be removed. In addition, it would be difficult to reclaim the mine pit in an upland area because it would require the hauling and dumping of fill from another location to return the upland mine pit to the pre-mining grade and reestablish agriculture. This operation would result in temporary, but probably significant, air quality impacts due to daily NO X emissions. Filling the mine pit at the end of the 30-year permit period would require finding a source of fill and soil that would be suitable to reclaim the area for agriculture uses. Extraction of this material from another location could adversely affect land use, biological habitat, cultural resources, aesthetic conditions, and water quality at the source site. These impacts would likely be significant, given the large volume and area required to supply the fill for reclamation. The depth of fines over marketable gravel and sand and cost of reclaiming the pit to agriculture may affect the economic viability of this alternative. 4.7 COMPARISON OF ALTERNATIVES Other than emissions of NO X from on-site mobile equipment, which are part of the current operation, the project as proposed would not have any Class I, significant and not mitigable impacts. Any of the alternatives involving production levels similar to the current GPS operation would have a similar air quality impact, and generally similar impacts with respect to other topics. The No Project Alternative would cease the current NO X emissions, and would avoid the other significant, but mitigable impacts (Class II) of the proposed project. PCC-grade aggregate would continue to be supplied to the region from various other existing and possibly newly permitted sources in Santa Barbara, San Luis Obispo, Ventura, and Kern counties. The Reduced Mining Depth Alternative would also not avoid the Class I impact related to NO X emissions from on-site operations. With some issues, however, the effects of this alternative on the Class II impacts may be reduced when compared to the project as proposed. The primary issue of this type is the potential hydrologic effects on the Cuyama River, which would be further reduced with a shallower pit. Impacts such as noise, traffic, and lighting, which are related to the intensity of processing and material production, would be similar to those from the project, but less frequent as the number of peak production days would be smaller. S:\07 PROJ\Ventucopa GPS Mine\2009 Final EIR\4.0 Alternatives.doc 4-6

7 The use of the adjacent agricultural lands for the mine pit (Upland Mine Site Alternative) would avoid some habitat related impacts, but would also create a new significant impact by displacing a viable agricultural operation and intensifying visual impacts. Under the CEQA Guidelines, the EIR must identify the environmentally superior alternative, if it is other than the No Project Alternative. Except for the disturbance to about 9 acres of alluvial scrub terrace habitat, the proposed western expansion of the existing mining site would have the same effects as existing mining conditions. It represents the most viable alternative for GPS to continue to produce PCC-grade aggregate and other marketable material at the same rate in the shortest timeframe. This alternative is the least environmentally damaging practicable alternative that meets the objectives of expanding the life of an economically viable and competitive source of high-quality sand and gravel products, including construction grade aggregate, located near an existing major roadway and operating in a manner that will maximize compatibility with surrounding land uses and minimize adverse environmental effects. S:\07 PROJ\Ventucopa GPS Mine\2009 Final EIR\4.0 Alternatives.doc 4-7

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