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Cosumnes power plant (01-afc-19) data response, set 1A


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1.0 DESCRIPTION OF “NO PROJECT” ALTERNATIVE


If the “No Project” alternative is selected, the District would not receive authorization to construct and operate a new power generation facility. As a result, the proposed facility would not be developed at this time and would remain at least temporarily as annual grassland pasture. Subsequently, energy that would have been produced by the proposed facility would need to be generated by another available source; common available sources include older power generation facilities that consume more natural gas and release greater quantities of air pollutants. In addition, under this alternative, the District’s customers and the people of California would have less total generating capacity and, therefore, a less reliable and less competitive electric system.

The purpose of this generating facility is to provide a source of clean, reliable energy for the Sacramento area and the District’s customers. It also intends to put to use that land and infrastructure that was originally developed by the District for the purpose of generating most of the region’s energy needs. With CPP, the District is responsible to the ratepayers to avoid financial risks of project failure.

The “No Project” alternative is not considered feasible because it neither meets the objectives of providing power nor does it meet the District’s business plans to rely less upon the purchase of power from outside the District.

2.0 Environmental Analysis of No Project Alternative


This section provides a brief environmental analysis of the No Project Alternative.

2.1 Air Quality


With the No Project Alternative, air quality in the Sacramento Metropolitan Air Quality Management District (SMAQMD) would be slightly worse that with the project since their would be no permanent reduction in air pollutants resulting from the purchase of emission reduction credits. Electricity required to support growth within the District’s boundaries would be provided under contracts from other power generating sources outside the District. Therefore, it is likely that older plants that create more air pollution than the proposed CPP would remain online. Thus, overall the air quality would be slightly worse than if the CPP plant is not built.

2.2 Biological Resources


Habitat types potentially affected in the project area comprise agricultural, annual grassland, vernal pools, ephemeral streams and irrigation ditches, riparian shrub, and landscape and urban communities. See AFC Figure 8.2-1 for location of biologically sensitive resources in the project area. A description of these resources is found in AFC Section 8.2.3.2.

With the No Project Alternative, the project site would remain as cattle pasture and no additional biological impacts would occur.


2.3 Cultural Resources


With the No Project Alternative, there would be no impact to archeological or historic resources along the gas line or at the project site since the project construction would not occur and the potential to disturb cultural resources would not exist.

2.4 Land Use


The proposed project is part of 2,480 acres purchased by the District in the 1960s to establish Rancho Seco Plant (RSP). The area affected by the proposed CPP project is leased by the District for cattle grazing for weed control. No crops, irrigation, or special cultivation are conducted on the project site. Within the vicinity of the project site, row crops and vineyards are cultivated. The land use designation for the site is Public/Quasi-Public with a Resource Conservation overlay. The Resource Conservation overlay pertains to potential, but uninvestigated natural resources based on information available to the Sacramento County Planning Department. The designation does not necessarily restrict the land use for the area included in the overlay. The site is zoned as AG-80, which is compatible with the land use designation. Also included on the property are areas set aside for a wildlife refuge and a permanent conservation easement area used for mitigating sensitive habitat.

Over the years, other power generating sources have been established on the property. Approximately 40 acres is currently used for four photovoltaic farms, which produce about 5.5 MW of energy. Long-term management of RSP is planned to occur in the next several years and includes off-site disposal of the spent fuels in accordance with NRC requirements.

SMUD intends to further develop the approximately 2,000-acre property consistent with its Public/Quasi-Public status. A recreational area surrounds the man-made Rancho Seco Reservoir, which was established for Rancho Seco Plant’s emergency water supply. Periodically, the District reviews proposals for commercial uses for the remainder of the property compatible with existing and planned land uses. The only current development of the area is for the expansion of the District’s photovoltaic farm. No other future plans have been identified. Since any proposals for future development would be consistent with existing and planned uses, the no project alternative would have no adverse Land Use impacts.

2.5 Noise


The proposed project is part of 2,480 acres purchased by the District in the 1960s to establish Rancho Seco Plant. Over the years, other power generating sources have been established on the property. Noise-sensitive land uses closest to the site are primarily isolated residential buildings located in farmlands surrounding the site. The property line of the closest sensitive receptor is located approximately 200 feet southwest of the site. The nearest residence on this property is approximately 800 feet from the site.

Sources of environmental noise in the vicinity of the site primarily include vehicular traffic and noise associated with the Rancho Seco Plant. Ambient noise surveys of the area indicated an average nighttime ambient noise level of 39 dBA (see AFC Section 8.5.3.2). With the No Project Alternative, further development of the photovoltaic farm would only produce slight construction noise during daytime hours and due to its distance to the residential receptors, would have no impact on ambient noise levels. Noise impacts to the closest resident would be avoided with the No Project Alternative.


2.6 Public Health


No existing recreational, scenic, natural resource protection, natural resource extraction, educational, or religious land uses exist within one mile of the project site. The project site is approximately 1.2 miles west of Rancho Seco Park, which is owned and operated by the District. Rancho Seco’s Park’s recreational facilities include fishing, boating, swimming, and camping. No other recreational facilities exist in the vicinity of the project site. According to the Sacramento County General Plan (1993), no additional recreational or park facilities are planned for the area. There are no sensitive receptor facilities (such as schools, daycare facilities, convalescent centers, or hospitals) in the vicinity of the project site. A few residences (primarily farmers) are located in the vicinity of the site, and a sparsely populated residential area begins approximately 0.75 mile to the west. There are no sensitive receptors within a 3-mile radius of the project site. Consequently, there would be no Public Health impacts from the No Project Alternative.

2.7 Worker Health and Safety


Under the No Project Alternative, there would be no construction and no impacts to workers. The only planned construction is the existing expansion of the photovoltaic farm. The workers on that project are required to follow the District’s safety procedures.

2.8 Socioeconomics


With the No Project Alternative, no economic development benefits would be realized within the Region of Influence (i.e., Sacramento and San Joaquin counties). During construction, the region would not receive the benefits of a $60 million construction payroll or the $16 to $20 million in local purchases for materials and supplies. It would also forgo the creation of 38 direct jobs and 555 induced jobs, which would have a direct and induced impact of more that $1 million (direct) and $14.8 million (induced). In addition, the state and region would forgo between $1.2 to $1.5 million in sales tax revenue. Since workers are expected to come from the local workforce, there would be no impacts to schools, housing, public services or utilities with or without the project.

During operations, the region would not receive the benefit of an annual operations and maintenance budget estimated to range from $8 million to $10 million. Of that amount, approximately $5 million is anticipated to be spent locally. The operations payroll is projected to be approximately $1.25 million. Estimated indirect and induced employment within the two-county region would be 25 and 18 permanent jobs, respectively. Indirect and induced income impacts are estimated at $1,026,893 and $488,055, respectively. Based on the annual operations and maintenance budgets, the state and local governments would not receive an estimated annual sales taxes of approximately $375,000. Since the District is a municipal entity, it does not pay property taxes, so Sacramento County would not derive any additional funds from property taxes, with our without the project. Since the workforce is small, there would be no impacts to schools, housing, public services or utilities with or without the project.


2.9 Agriculture and Soils


The types of land use surrounding the project site are described and mapped in AFC Section 8.4, Land Use. Currently, the project site and surrounding area are used for agricultural purposes, primarily grazing, which is consistent with the farmland classification. No prime farmland on the project site or adjacent areas would be lost due to construction and operation of CPP. Under the No Project Alternative, approximately 30 acres of grazing land would be retained for grazing.

Typical agricultural uses along the pipeline corridor include vineyards, pasture (grazing land) and row crops. Construction, consisting of trenching or horizontal directional drilling would be followed by restoration of the natural contours, soil replacement, and revegetation where appropriate. In areas where agricultural land is crossed, the land would be restored to agricultural production after pipeline installation. Therefore, under the No Project Alternative, only short-term impacts to agricultural land along the gasline would be avoided.


2.10 Traffic and Transportation


Clay East Road borders the project site to the south. Twin Cities Road (SR 104) is the closest road to the north and west of the project site. Two state highways serve the project area, SR 104 and Highway 99. The No Project Alternative would avoid an estimated 590 peak vehicle trips per day along these affected roadways during the construction period. The No Project Alternative would avoid the reduction in level-of-service from A to B along SR 104 and would avoid potential traffic impacts to the residential area west of the project along Clay East Road.

2.11 Visual Resources


The project site is located within a regional landscape characterized by a nuclear power plant, rolling hills, vineyards, cattle grazing land, open space, and rural residences. Portions of the site is developed for RSP, a photovoltaic facility, and Rancho Seco Park. Facilities at the RSP, just north of the project site, include: two 426-foot-high parabolic cooling towers, a 160-foot-high reactor building, a 60-foot-high auxiliary building, a 40-foot-high turbine building, and a 70 foot tall training and records building. Although RSP is being decommissioned, it is still lit at night, at approximately 75 percent of its operational lighting. The existing Rancho Seco buildings and structures will not be removed as part of decommissioning activities, but will remain a part of the landscape.

The No Project Alternative would avoid visual impacts from the development of the CPP project on a 30-acre site. Since the number of near-field receptors is small, and the existing RSP and facilities already dominate the landscape, the visual impacts from the plant are not expected to be significant. Other current activities on the District property would continue such as the further enhancement of the photovoltaic farm, which replaces the grassland with photovoltaic cells.


2.12 Hazardous Materials Handling


The No Project Alternative would avoid the transportation, use and storage of hazardous materials on the CPP site during construction and operations, as the site would remain as grazing land.

2.13 Waste Management


Since construction of RSP, and the subsequent decommissioning of the facility, the site has been fenced and protected as a buffer area to the facility, with no public uses. The District has leased the property for cattle grazing to control vegetation growth. Sometime prior to the 1960s, there was an old mining operation approximately 0.25 mile east of the project site. Mine tailings, consisting of evident low mounds of gravel, have become heavily overgrown with vegetation. Neither the project or the No Project Alternative would affect the mine tailings.

The No Project Alternative would eliminate the need to dispose of liquid and solid waste from the construction and operation of CPP. It is estimated that the CPP project would generate about 335 tons of solid waste during construction and 85 tons per year during operation, including up to 5 tons of hazardous waste. The loss of this waste stream would have an insignificant impact on the County’s landfills.


2.14 Water Resources


The Folsom-South Canal and Rancho Seco Reservoir are the major surface water features in the vicinity. Water from the canal is used to maintain water levels in the Reservoir as well as for cooling RSP before discharge to Clay Creek. The District has a contract to purchase water from the US Bureau of Reclamation (Bureau), to provide a maximum entitlement of 60,000 acre-feet per year (AFY) of CVP water and 15,000 acre-feet of non-CVP water assigned to the District by the City of Sacramento. Because the Rancho Seco Plant has been decommissioned, the District has never used the maximum entitlement under this contract.

The No Project Alternative would avoid the use of approximately 8,000 AFY of non-treated surface water from the Folsom-South Canal. The failure of the District to use its water rights for a beneficial use may result in the loss of those rights. A reduction in the use of 8,000 AFY to the Central Valley Project would represents less than 0.0009 (0.09 percent) of the 9 million acre feet allocated by the CVP, and about 0.013 (1.3 percent) of the water used for municipal and industrial purposes. The availability of additional water under the No Project Alternative would have a slight, but insignificant, benefit to the CVP.


2. 15 Geologic Hazards and Resources


The No Project Alternative would not affect geological hazards or resources. Under the No Project Alternative, the only construction would be planned expansion of the photovoltaic farm, which is being constructed to meet Seismic Zone 3 requirements of the Building Code.

2.16 Paleontological Resources


Although no fossils are known to directly underlie the proposed project site, the presence of fossil sites in alluvial deposits of the Laguna, Riverbank, and Modesto formation elsewhere suggests that there is a high potential for additional similar fossil remains to be uncovered by excavations in these formations during project construction. The No Project Alternative would avoid any disturbance to these formations as a result of plant or pipeline construction since the only construction would be the planned expansion of the photovoltaic farm.

Attachment Alt-2

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