RE: SGI Quarry Expansion Draft EIR Comments
Dear Mr. Beatty,
Attached are Foothill Conservancy’s comments on the currently circulating draft
Environmental Impact Report for the proposed expansion of the SGI Mine Quarry
located outside the City of Ione.
Project Timeline
We wish to renew our objection to the length of the project timeline. Given the
ever-changing nature of technology and the environment, to grant this mining permit out
to the year 2175 is untenable. Even the fifty-year timeline in the original project strains
our ability to reasonably analyze the environmental impacts of this project. If this permit,
with this timeline, was issued in 1875 it would have analyzed the impacts from pick and
shovel mining and still have been good until the present day. Think of the technological
and social changes over that time. The nearby city of Ione grew from 600 to 6,000
residents in that time. Also given the nature of our changing climate, analysis with
regard to water, air quality, and biology have the potential to change massively over a
150 year time period. The length of the permit also undermines the purpose of the
reclamation plan, as it puts its implantation at the end of mining operations into the
distant future. We recommend that the project be given a 25 year timeline before
requiring a review of the project by the County, so that the permit conditions can be
updated to keep pace with any changes in technology or conditions near the site.
Air Quality
The analysis for the Air Quality section relies on questionable assumptions. First, the
baseline air quality levels are based on data from monitoring stations in Jackson and
San Andreas, located ten and twenty miles from the project site, respectively, while the
City of Ione and its residents are just two miles away. The project’s impact to air quality
in Ione is not captured by a baseline set from a location five times the distance as the
real area of concern. The private crowd-sourced website Purple Air shows that air
quality readings can be quite different for sensors in Jackson compared to those in Ione.
The analysis also assumes that the quarry operation will use more fuel- and
emission-efficient vehicles and equipment in the future as the fleet is replaced and that
the project will conform with a host of established federal, state and local air quality
regulations. These assumptions are in fact mitigation measures that should be
incorporated into the EIR as such to ensure that they are identified and enforced.
To ensure effectiveness of the measures described in the EIR, air quality monitoring
should be installed by the applicant at the quarry site and in the City of Ione to ensure
that air quality is not being compromised.
Water
As was expressed by nearby residents, concerns persist that the mining operation at
the quarry could fracture the rock basin and drain groundwater supplies in the area. The
EIR should include analysis of the water table and possible impacts therein by the
quarry.
Noise
We object to the characterization of 80 blasting events per year as “infrequent” as it
represents an event over 20% of all days of the year, or a blast every 4 and a half days.
If measures are taken to minimize the impacts from blasting and other mining activities,
they should be included in the EIR as mitigation measures.
Aesthetics
The DEIR analysis fails to engage with the largest visual impact of the project,
specifically the expanded stockpile area, which will increase to an elevation of 560 feet
(200 feet higher than existing conditions) and cover 86 acres. This huge pile of rock and
soil is not included in the photo simulations and not sufficiently addressed in the written
analysis. Mitigation measures should be introduced to address the appearance of the
stockpile, specifically the grading of slopes, placement of topsoil, and the planting of
vegetation so the stockpile has the appearance of a natural hillside, rather than a
scarred industrial landscape. This restoration work should commence before the 150
years pass before the end of the mining permit.
Please feel free to contact us to discuss any of the comments submitted. We are
pleased to work with your staff and the community to work toward a better future for
Amador County.
Sincerely,
Craig Baracco, Executive Director