Jesse Morrow Mountain Mine and Reclamation Project

PLANNING COMMISSION HEARING May 30, 2012

PRESENTATION OVERVIEW

• Biology Surveys and California Mountain Lion • Hydrology:

– Loss of Groundwater Recharge and Impact on Groundwater Levels – Groundwater Use During Dry Years and Impact on Groundwater Levels – Blasting Impacts on Wells and Canals – Central Valley Flood Protection Board Comment Letter

• Air Quality:

– NOx Emission Sources and Impact Comparison Between Project and Reduced Alternative 4 – PM Emissions Threshold

PRESENTATION OVERVIEW

(cont.)

• Geology & Soils:

– Core Samples – Reduced Alternative 4 Slope Stability

• Questions

Biological Surveys and California Mountain Lion

• Biologists conducted five sets of biological surveys between May 2005 and May 2010.

• Literature reviews, state records searches, and map overlay analyses • As required by CEQA, the EIR focused on federally or state listed endangered or threatened species.

‒ Mountain lions are not designated as threatened nor endangered in California – “One old dropping, noted on the ridge.

”

potentially

that of a mountain lion was - FEIR, Appendix D-1, p. 2 – “No deer feces were noted on any of the Project area, indicating deer use is transitory and sporadic.

” - FEIR Appendix D-1, p. 2 • Impacts to mountain lions were not required to be analyzed, unlikely to occur, and therefore were not evaluated.

Hydrology Loss of Groundwater Recharge and Impact on Groundwater Levels:

• Under normal conditions, approximately 118 acre-feet of runoff retained from the Project areas and used for the Project.

• Captured runoff for the Project represents less than 20 percent of the total runoff from the western side of Jesse Morrow Mountain.

• Amount of runoff from the Project area that percolates into the alluvial basin is only a small fraction of the total runoff.

• Alluvial basin area to the west and southwest of Jesse Morrow Mountain encompasses at least 5,000 acres.

Hydrology (cont.) Loss of Groundwater Recharge and Impact on Groundwater Levels (cont.):

• Groundwater recharge occurs through percolation of rainfall, seepage from canals and the various sloughs and channels of the Kings River system to the west, and seepage of excess irrigation water.

• Average annual rainfall in this area totals over 4,500 acre-feet, which is substantially greater than the 118 acre-feet of runoff that would be retained for the Project (less than 1/3 of 1%).

• Only a small fraction of the runoff from the Project area reaches the alluvial basin. Therefore, retaining runoff from the Project would have a miniscule effect on the amount of groundwater recharge and no measurable effect on groundwater levels.

Hydrology (cont.) Groundwater Use Groundwater Levels: During Dry Years and Impact on

• Typically, approximately 85-90%, of water used for processing operations is conserved and recycled through a series of retention systems and/or flocculation tanks.

• During dry years, under worst-case conditions, groundwater may be needed to supply up to the 165 acre-feet of water needed for the Project.

• This volume of water is equivalent to the annual quantity needed to irrigate approximately 40 acres.

• As analyzed in the SB 610 Water Supply Assessment and EIR, groundwater levels in wells located in the area of the Project are not significantly affected during drought conditions.

• Additional pumping of groundwater during dry periods will not have any measurable effect on groundwater levels in the area.

Hydrology (cont.) Blasting Impacts on Wells and Canals:

• A threshold range of .5 in/sec (wells) and 5.0 in/sec to 20 in/sec (canals) of peak particle velocity is used for the protection of structures.

• EIR concluded the maximum particle velocity that would occur at the nearest groundwater well due to blasting would be approximately 0.15 inches per second (in/sec).

• This particle velocity is comparable to that caused by a person walking across the ground or the floor of a building.

• This maximum particle velocity is more than three times less than that which could potentially affect a well.

• Maximum particle velocity at the closest point along the Friant Kern Canal to the mining area is approximately 1.07 in/sec.

Almost 5 times less than could potentially affect a canal.

• Ground vibrations due to blasting will not be sufficient to damage the Friant-Kern Canal, or any other more-distant canals.

Hydrology (cont.) Central Valley Flood Protection Board:

• The Project Description does not include any disturbance within 300 feet of the Alta Main Canal. • County has included a Condition of Approval for the Project specifying that if any disturbance or activities occur in either of these parcels, the Applicant must first contact the Central Valley Flood Protection Board to determine if an application for an encroachment permit should be filed.

Air Quality NOx Emission Sources and Impact Comparison:

• Project NOx emissions sources include diesel generators, on-site mobile equipment with diesel/gasoline engines, asphalt plant’s burner, and off-site mobile sources (i.e., diesel haul trucks).

• Final EIR determined under both a 1 million tons per year (“TPY”) and a 2 million TPY production scenario the Project’s NOx emissions would be significant.

• Reduced Alternative 4 will lead to fewer NOx impacts. Reducing annual production by 25 percent and the Project’s lifespan by 50 percent necessarily results in fewer on-site NOx emissions.

• Reduced Alternative 4 requires the use of electric conveyors rather than diesel haul trucks for removal of aggregate from the active mining area to the processing plant.

• To mitigate NOx the Final EIR requires the Applicant use state-of the-art NOx reduction technology (e.g., engines meeting strict Tier 4 NOx emissions standards and an asphalt plant with a low NOx natural gas/propane burner).

Air Quality (cont.) PM Emissions Threshold:

• Current SJVAPCD standard requires compliance Regulation VIII.

• GAMAQI holds that compliance with Regulation VIII will render a project’s PM10 emissions less than significant. Therefore, the Final EIR uses the proper threshold and concludes PM10 emissions will be less than significant.

• SJVAPCD submitted a comment letter stating the Final EIR should use the agency’s informal 15 TPY PM standard.

• SJVAPCD has not formally adopted the 15 TPY standard therefore that threshold cannot be used as a generally applicable CEQA threshold.

(See 14 Cal. Code Regs., § 15064.7(b), (c)) • If the 15 TPY informal standard were applicable, the Project’s PM10 and PM2.5 emissions would slightly exceed that threshold • PM10 emissions would be minimized under Reduced Alternative 4.

Air quality analysis submitted by te Applicant shows that Project PM10 emissions at the maximum proposed production of 1.5

million TPY would amount to about 11.3 tons.

Geology and Soils Core Samples:

• Core samples were recovered by the Applicant when they conducted a drilling program on the Project site.

• Portions of those core samples were analyzed for rock quality and chemistry.

• Data derived from these tests, where relevant, were provided as part of the Applicant’s CUP Application.

• In preparation of the EIR, the County peer reviewed those documents as it related to potential environmental impacts.

• The County determined, using their independent judgment, the data provided was sufficient to prepare a legally defensible EIR impact analysis.

• The County did not require, nor determine necessary, review of physical core samples.

Geology and Soils (cont.) Reduced Alternative 4 Slope Stability:

• Slopes designed at an overall slope of 1:1 (h:v) with interim slopes of 0.5:1 (h:v) incorporating: – Minimum bench width of 25 feet; – Maximum bench height of 50 feet; and – 60 foot wide access road to quarry floor • Proposed slope angle will be globally stable and suitable for the currently proposed post mining use of the Site (Slope Stability Report (Sept. 2011) p. 8) • Post-mining land use, cattle grazing, is a feasible and allowed use – Cattle can, and do graze on steep slopes (See D.G. Ditsch, et al., Managing Steep Terrain for Livestock Forage Production, Univ. of Kentucky College of Agriculture (2006) p. 7) • County has coordinated with Department of Conservation, Office of Mine Reclamation, in review of Applicant’s Reclamation Plan – As a result, three new Conditions of Approval requiring monitoring of active mine slopes have been required

QUESTIONS