CHAPTER 4 ALTERNATIVES COMPARISON

CHAPTER 4 ALTERNATIVES COMPARISON 4.1 INTRODUCTION This chapter provides a comparison of the and its alternatives as described in EIS/EIR Section 1.8.3 (s Evaluated in this EIS/EIR) and analyzed in Sections 3.1 through 3.10. This chapter is intended to provide decision-makers with information about the merits and disadvantages of the alternatives to assist them in their consideration of approval or denial of the, as well as to assist the public in understanding the differences between the alternatives. The four alternatives evaluated in detail in this EIS/EIR include: The ( 1) The ( 2) The ( 3) The ( 4) Four additional alternatives were considered, but ultimately eliminated from detailed analysis. These alternatives include the following: A Non-Phased Construction An Upland Disposal A Full Enclosure An Use Please refer to EIS/EIR Section 1.8.2 (s Considered But Not Carried Forward For Analysis) for a description of these alternatives and the reasons why they were not carried forward for detailed analysis. 4.2 NEPA REQUIREMENTS TO EVALUATE ALTERNATIVES According to CEQ NEPA regulations (40 CFR 1502.14), an EIS must rigorously explore and evaluate a reasonable range of alternatives to a proposed project, or action, that can be feasibly carried out based on technical, economic, environmental and other factors. NEPA also requires that an EIS analyze a No Action alternative, and that each of the alternatives identified for analysis be evaluated at an equal level of detail (40 CFR 14[b]). The intent of the alternatives analysis is to identify the environmentally preferable alternative. Ordinarily, this means the alternative that causes the least damage to the biological and physical environment; typically it also means the alternative that best protects, preserves, and enhances historic, cultural and natural resources. 4.2.1 NEPA s Comparison Table 4.2-1 summarizes the results of the NEPA impact analysis under each alternative for each resource area and impact criterion, as described in EIS/EIR Sections 3.1 through 3.10. Table 4.2-2 compares the environmental impacts of the four analyzed alternatives by impact significance, and Table 4.2-3 compares the four analyzed alternatives to the NEPA Baseline. These tables are located at the end this chapter s text. 4.2.2 NEPA Environmentally Preferable The Corps Agency preferred alternative is a preliminary indication of the federal lead agency s preference of action, which is chosen from among the and its alternatives. The agency preferred alternative may be selected for a variety of reasons (such as the priorities of the particular lead agency), in addition to the environmental considerations discussed in the project s environmental review document. The federal lead agency must identify both the agency preferred alternative and the environmentally preferred alternative(s) in its Record of Decision (ROD) for an EIS (40 CFR 1505.2[(b)]). The Corps will prepare the ROD following completion of the Final EIS/EIR and after consideration of EAGLE ROCK AGGREGATE TERMINAL PROJECT 4-1 APRIL 2013

comments received during the Draft EIS/EIR s comment period. However, consistent with Question 6a of the Forty Most Asked Questions Concerning CEQ s NEPA Regulations (46 Federal Regulation 18026, as amended by 51 Federal Regulation 15618), the Corps has determined that consideration of the comments received from the public and reviewing agencies on the s Final EIS/EIR is warranted prior to making a final decision as to which alternative or alternatives is/are considered the environmentally preferable alternative(s). A final decision regarding the environmentally preferable alternative(s), and agency preferred alternative(s) will be made and expressly explained by the Corps in its ROD. As shown in Table 4.2-1, under the NEPA Baseline, the would not result in any impacts. Table 4.2-2 summarizes the impacts of each alternative by impact significance. As shown in the table, under the NEPA Baseline, the would result in one beneficial impact, four significant and unavoidable impacts, one adverse impact that can be mitigated to a level of less than significant, and 24 less than significant impacts. The remaining impact criteria were determined to have no impact (five). The ( 2) would result in one beneficial impact, two significant and unavoidable impacts, two adverse impacts that can be mitigated to less than significant and 21 less than significant impacts. The remaining nine impact criteria were found to have no impact. The ( 3) would result in one beneficial impact, one significant and unavoidable impact, 21 less than significant impacts, seven no impact determinations, and five criteria that had no determination. No construction activities would occur in, above, or below waters and no federal action or permit would be required for either 2 (the ) or 3 (the ). Accordingly, either alternative may be considered the "Environmentally Preferable " under NEPA, as there would be no impacts related to a federal action or permit. Under the CEQA Baseline, in comparison with 3 (the ), 2 would result in similar construction emissions, a moderate increase in operational emissions, and substantially lower impacts upon sensitive receptors, as measured by residential cancer risk, off-site worker cancer risk, and cancer burden. Both alternatives would achieve the overall purpose of establishing "a coastal aggregate receiving, storage and distribution facility that would optimize throughput capacity by providing up to 2.75 million tons of aggregate material per year to the greater Long Beach and Los Angeles areas." In comparison with 2, 1 (the ) would result in additional work within waters of the U.S. and would result in substantially higher construction emissions of certain criteria pollutants (VOCs, NOx) during a one-day dredging episode. The use of an electric dredge has been evaluated as a potential means of pollutant reductions. Due largely to the use of tugboats for electric cabling and cable retrieval, in comparison with 1 ( ), the use of an electric dredge would lead to relatively small reductions in maximum NOx and CO emissions (approximately 18 percent and 12 percent, respectively) that would still remain well above the SCAQMD CEQA threshold for NOx, and a substantial increase in total emissions of NOx, CO, PM10 and PM2.5 (approximately 300 percent, 215 percent, 269 percent, and 269 percent, respectively). Please refer to Final EIS/EIR Chapter 10 (Comments Received and Responses to Comments), Response to Comment SCAQMD-2, for additional information regarding the evaluation of electric dredge emissions. However, the small extent of work within waters (0.66 acre) and the highly temporal nature of associated environmental impacts (e.g., air quality, biota and habitats) during the one day of dredging are considered relatively minor distinctions in light of the high degree of similarity between these two alternatives EAGLE ROCK AGGREGATE TERMINAL PROJECT 4-2 APRIL 2013

(including mitigation measures) with respect to other construction and operational impacts as well as peak throughput. Both alternatives would achieve the overall purpose." 4.3 CEQA REQUIREMENTS TO EVALUATE ALTERNATIVES State CEQA Guidelines Section 15126.6 requires that an EIR present and consider a range of reasonable alternatives to a project, or to the location of a project, which would feasibly attain most of the basic objectives of the project but would avoid or substantially lessen one or more of its significant effects. Unlike NEPA, CEQA does not require that the alternatives to a proposed project be evaluated at an equal level of detail; however, the intent of CEQA s alternatives analysis is to foster informed decision making and public understanding and participation. An EIR is not required to consider alternatives that are considered infeasible or too speculative, such as those described in Section 1.8.2 (s Considered but Not Carried Forward for Analysis). 4.3.1 CEQA s Comparison Table 4.3-1 summarizes the results of the CEQA significance analysis under all alternatives for each resource area and impact criterion, as detailed in Sections 3.1 through 3.10. Table 4.3-2 compares the environmental impacts of the four analyzed alternatives by impact significance, and Table 4.3-3 compares the four analyzed alternatives to the CEQA Baseline. These tables are located at the end of this chapter s text. 4.3.2 CEQA Environmentally Superior State CEQA Guidelines Section 15126.6(e)(2) requires that an EIR identify an environmentally superior alternative and, if the no project alternative is determined to be the environmentally superior alternative, then the EIR must also identify an environmentally superior alternative from among the other project alternatives. As shown in Table 4.3-1, under the CEQA Baseline, the would not result in any impacts, including the beneficial impact associated with socioeconomics (Impact SE-1). Due to its lack of any adverse impacts, the is the environmentally superior alternative; however, as indicated in the paragraph above, CEQA requires that in this case, another alternative from the other project alternatives must be identified as the environmentally superior alternative. Table 4.3-2 summarizes the impacts of each alternative by impact significance. As shown in that table, under the CEQA Baseline, the would result in one beneficial impact, five significant and unavoidable impacts, one adverse impact that can be mitigated to a level of less than significant, and 23 less than significant impacts. The remaining impact criteria were determined to have no impact (five). The ( 2) would result in one beneficial impact, three significant and unavoidable impacts, two adverse impacts that can be mitigated to less than significant and 20 less than significant impacts. The remaining nine impact criteria were found to have no impact. The ( 3) would result in one beneficial impact, five significant and unavoidable impacts and 20 less than significant impacts. The remaining nine impact criteria were determined to have no impact. The would result in two significant and unavoidable air quality impacts: Impact AQ-1 (exceed SCAQMD daily thresholds of significance for NOx) and Impact AQ-2 (exceed SCAQMD thresholds for off-site ambient air concentrations for NOx). These impacts would only occur during the one day of dredging activity. Two additional significant and unavoidable air quality impacts would occur through the life of the project. These impacts, identified as AQ-3 (exceed SCAQMD daily thresholds of significance for NOx and VOCs {only under the CEQA Baseline}) and AQ-4 (exceed SCAQMD thresholds for off-site ambient air concentrations for NO 2 ]) would also occur for s 2 and 3. Under EAGLE ROCK AGGREGATE TERMINAL PROJECT 4-3 APRIL 2013

2, for the CEQA Baseline, operation would additionally exceed off-site ambient air concentrations for PM10. Additionally, under the, there would be a significant and unavoidable impact due to GHG emissions that exceed the SCAQMD s interim threshold value (Impact GCC-1). This same impact would also occur under s 2 and 3, with respect to the CEQA Baseline. Under the CEQA Baseline, the would result in three significant and unavoidable impacts during operation: AQ-3, AQ-4 and AQ-5 (expose the public to significant levels of TACs). The difference in operational emissions for VOCs and NOx for s 1 and 2 is essentially negligible (see Tables 3.1-8 and 3.1-16). However, for 3, the estimated emissions for these pollutants are approximately 20 percent less for VOCs and 27 percent less for NOx. As mentioned previously, uunder the CEQA Baseline, s 1, 2, and 3 would result in significant and unavoidable impacts related to GCC. This would not occur with respect to the NEPA Baseline. 2, the, would require mitigation for the protection of bat and bird species during the nesting and maternity season due to vegetation clearing, if applicable. 1, the, would require dredging; however, all impacts to marine water quality and marine biota and habitat would be less than significant with implementation of Mitigation Measure BIO-1 and BMPs. All three action alternatives would incrementally contribute to cumulatively significant and unavoidable impacts related to potential whale strikes outside of the Port, and the introduction of invasive species due to accidental ballast water discharges. All three action alternatives would result in less than significant impacts related to environmental justice. However, under the CEQA Baseline, 3, the, is the only alternative that would create potential excess cancer risks and burden that exceed established significance criteria. Based upon the above, the ( 1) is considered to be the environmentally superior alternative because it both reduces impacts to the maximum extent feasible and additionally meets all objectives. EAGLE ROCK AGGREGATE TERMINAL PROJECT 4-4 APRIL 2013

TABLE 4.2-1 COMPARISON OF NEPA IMPACT ANALYSIS BY ALTERNATIVE Air Quality and Health Risk Exceed SCAQMD daily thresholds of significance Exceed SCAQMD thresholds for off-site ambient air concentrations Exceed SCAQMD daily thresholds of significance Exceed SCAQMD thresholds for off-site ambient air concentrations Expose the public to significant levels of TACs Conflict or obstruct implementation of an applicable AQMP or exceed applicable General Conformity Rule thresholds Global Climate Change GHG emissions exceed SCAQMD interim threshold Expose people and structures to a significant risk as a result of SLR Marine Water and Sediment Quality Violate applicable regulatory standards or guidelines Substantially alter water circulation or currents or cause long-term detrimental alteration of circulation causing reduced water quality Cause harmful flooding to people, property or biological resources Result in wind or water erosion causing substantial soil runoff or deposition ( 1) ( 2) ( 3) ( 4) I III III IV I III III IV I I III IV I I I IV III III (AQMP) N/A (General Conformity Rule) III (AQMP) N/A (General Conformity Rule) III IV IV IV IV EAGLE ROCK AGGREGATE TERMINAL PROJECT 4-5 APRIL 2013

TABLE 4.2-1 COMPARISON OF NEPA IMPACT ANALYSIS BY ALTERNATIVE Biota and Habitats Have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special-status species in local or regional plans, policies, or regulations, or by the CDFG or USFWS Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites Have a substantial adverse effect on any riparian habitat or other sensitive natural community, including marine habitat, identified in local or regional plans, policies, or regulations, or by the CDFG or USFWS Result in the loss, or a substantial adverse effect on a natural habitat or plant community, including wetlands, as defined by the CDFG or USFWS Substantially disrupt or conflict with any local policies or ordinances protecting local biological resources and communities Ground Transportation Increase an intersection s V/C ratio or LOS in a manner that exceeds applicable performance standards Increase the V/C ratio or LOS at any CMP monitoring station in a manner that exceeds applicable performance standards Vessel Transportation Result in a change in vessel patterns, increase vessel traffic volumes, or cause a substantial change in vessel safety Result in a change in vessel patterns, increase vessel traffic volumes, or cause a substantial change in vessel safety ( 1) ( 2) ( 3) ( 4) III II ND IV III III ND IV III IV ND IV III IV ND IV II II ND IV III IV IV IV EAGLE ROCK AGGREGATE TERMINAL PROJECT 4-6 APRIL 2013

TABLE 4.2-1 COMPARISON OF NEPA IMPACT ANALYSIS BY ALTERNATIVE Noise Increase ambient noise levels by 3 dba at any sensitive noise receptor location Exceed noise level limits established by the LBMC at any sensitive noise receptor location Permanently increase ambient noise levels by 3 dba at any sensitive noise receptor location Exceed the maximum noise levels allowed by the LBMC Hazards and Hazardous Materials ( 1) ( 2) ( 3) ( 4) Accidently release hazardous materials in a manner that would adversely affect human health and safety Result in noncompliance with State guidelines associated with abandoned wells Substantially increase the probable frequency or severity of consequences to people or property due to the accidental release of a hazardous or petroleum substance Conflict with the POLB RMP Result in the presence of soil or groundwater contamination that causes a significant hazard to the public or environment Socioeconomics Directly or indirectly induce a substantial decrease in area employment Directly or indirectly induce substantial population growth Directly or indirectly induce a substantial increase in area housing B B B IV EAGLE ROCK AGGREGATE TERMINAL PROJECT 4-7 APRIL 2013

TABLE 4.2-1 COMPARISON OF NEPA IMPACT ANALYSIS BY ALTERNATIVE Environmental Justice Result in a disproportionate human health or significant environmental impact on minority and/or low income populations Result in a disproportionate decrease in the employment or economic base of minority and/or low income populations ( 1) Notes: I = Unavoidable Significant Impact II = Significant Impact but Mitigable to Less Than Significant III = Less Than Significant Impact (Not Significant) IV = No Impact B = Beneficial Impact N/A = Not Applicable ND = No Determination ( 2) ( 3) ( 4) TABLE 4.2-2 COMPARISON OF THE NEPA IMPACT ANALYSIS BY ALTERNATIVE AND IMPACT SIGNIFICANCE IMPACT SIGNFICANCE ( 1) ( 2) ( 3) Unavoidable Significant Impact 4 2 1 0 1 2 0 0 Significant Impact but Mitigable to Less Than Significant ( 4) Less Than Significant Impact 24 21 21 0 No Impact 5 9 7 35 Beneficial Impact 1 1 1 0 No Determination 0 0 5 0 TABLE 4.2-3 COMPARISON OF THE ALTERNATIVES TO THE NEPA BASELINE. Environmental Resources Area ( 1) ( 2) ( 3) ( 4) Air Quality and Health Risk + = = - Global Climate Change + + = - Marine Water and Sediment Quality + + = - EAGLE ROCK AGGREGATE TERMINAL PROJECT 4-8 APRIL 2013

TABLE 4.2-3 COMPARISON OF THE ALTERNATIVES TO THE NEPA BASELINE. Environmental Resources Area ( 1) ( 2) ( 3) ( 4) Biota and Habitats + + = - Ground Transportation + + = - Vessel Transportation + + = - Noise + + = - Hazards and Hazardous Materials + + = - Socioeconomics + + = - Environmental Justice + + = - Notes: (-) = Impact considered to be less when compared with the NEPA Baseline (=) = Impact considered to be equal to the NEPA Baseline (+) = Impact considered to be greater when compared to the NEPA Baseline TABLE 4.3-1 COMPARISON OF CEQA IMPACT ANALYSIS BY ALTERNATIVE Air Quality and Health Risk Exceed SCAQMD daily thresholds of significance Exceed SCAQMD thresholds for off-site ambient air concentrations Exceed SCAQMD daily thresholds of significance Exceed SCAQMD thresholds for off-site ambient air concentrations Expose the public to significant levels of TACs Conflict or obstruct implementation of an applicable AQMP or exceed applicable General Conformity Rule thresholds Global Climate Change GHG emissions exceed SCAQMD interim threshold Expose people and structures to a significant risk as a result of SLR ( 1) ( 2) ( 3) ( 4) I III III IV I III III IV I I I IV I I I IV III III I IV III III (AQMD N/A (General Conformity Rule) III (AQMD) N/A (General Conformity Rule) I I I IV IV EAGLE ROCK AGGREGATE TERMINAL PROJECT 4-9 APRIL 2013

TABLE 4.3-1 COMPARISON OF CEQA IMPACT ANALYSIS BY ALTERNATIVE Marine Water and Sediment Quality Violate applicable regulatory standards or guidelines Substantially alter water circulation or currents or cause long-term detrimental alteration of circulation causing reduced water quality Cause harmful flooding to people, property or biological resources Result in wind or water erosion causing substantial soil runoff or deposition Biota and Habitats Have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special-status species in local or regional plans, policies, or regulations, or by the CDFG or USFWS Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites Have a substantial adverse effect on any riparian habitat or other sensitive natural community, including marine habitat, identified in local or regional plans, policies, or regulations, or by the CDFG or USFWS Result in the loss, or a substantial adverse effect on a natural habitat or plant community, including wetlands, as defined by the CDFG or USFWS Substantially disrupt or conflict with any local policies or ordinances protecting local biological resources and communities Ground Transportation Increase an intersection s V/C ratio or LOS in a manner that exceeds applicable performance standards ( 1) ( 2) ( 3) ( 4) III IV IV IV III II III IV III IV IV IV III IV IV IV II II III IV EAGLE ROCK AGGREGATE TERMINAL PROJECT 4-10 APRIL 2013

TABLE 4.3-1 COMPARISON OF CEQA IMPACT ANALYSIS BY ALTERNATIVE ( 1) ( 2) ( 3) Increase the V/C ratio or LOS at any CMP monitoring station in a manner that exceeds applicable performance standards Vessel Transportation Result in a change in vessel patterns, III IV IV IV increase vessel traffic volumes, or cause a substantial change in vessel safety Result in a change in vessel patterns, increase vessel traffic volumes, or cause a substantial change in vessel safety Noise Increase ambient noise levels by 3 dba at any sensitive noise receptor location Exceed noise level limits established by the LBMC at any sensitive noise receptor location Permanently increase ambient noise levels by 3 dba at any sensitive noise receptor location Exceed the maximum noise levels allowed by the LBMC Hazards and Hazardous Materials Accidently release hazardous materials in a manner that would adversely affect human health and safety Result in noncompliance with State guidelines associated with abandoned wells Substantially increase the probable frequency or severity of consequences to people or property due to the accidental release of a hazardous or petroleum substance Conflict with the POLB RMP Result in the presence of soil or groundwater contamination that causes a significant hazard to the public or environment ( 4) EAGLE ROCK AGGREGATE TERMINAL PROJECT 4-11 APRIL 2013

TABLE 4.3-1 COMPARISON OF CEQA IMPACT ANALYSIS BY ALTERNATIVE Socioeconomics Directly or indirectly induce a substantial decrease in area employment Directly or indirectly induce substantial population growth Directly or indirectly induce a substantial increase in area housing Environmental Justice Result in a disproportionate human health or significant environmental impact on minority and/or low income populations Result in a disproportionate decrease in the employment or economic base of minority and/or low income populations ( 1) Notes: I = Unavoidable Significant Impact II = Significant Impact but Mitigable to Less Than Significant III = Less Than Significant Impact (Not Significant) IV = No Impact B = Beneficial Impact N/A = Not Applicable ( 2) ( 3) ( 4) B B B IV III III I IV TABLE 4.3-2 COMPARISON OF THE CEQA IMPACT ANALYSIS BY ALTERNATIVE AND IMPACT SIGNIFICANCE IMPACT SIGNFICANCE ( 1) ( 2) ( 3) Unavoidable Significant Impact 5 3 5 0 1 2 0 0 Significant Impact but Mitigable to Less Than Significant ( 4) Less Than Significant Impact 23 20 20 0 No Impact 5 9 9 35 Beneficial Impact 1 1 1 0 EAGLE ROCK AGGREGATE TERMINAL PROJECT 4-12 APRIL 2013

TABLE 4.3-3 COMPARISON OF THE ALTERNATIVES TO THE CEQA BASELINE. Environmental Resources Area ( 1) ( 2) ( 3) ( 4) Air Quality and Health Risk + + + = Global Climate Change + + + = Marine Water and Sediment Quality + + + = Biota and Habitats + + + = Ground Transportation + + + = Vessel Transportation + + + = Noise + + + = Hazards and Hazardous Materials + + + = Socioeconomics + + + = Environmental Justice + + + = Notes: (-) = Impact considered to be less when compared with the CEQA Baseline (=) = Impact considered to be equal to the CEQA Baseline (+) = Impact considered to be greater when compared to the CEQA Baseline EAGLE ROCK AGGREGATE TERMINAL PROJECT 4-13 APRIL 2013