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News Home pageDraft comments Hearing has been postponed to 9-21-99
Regional Planning Commission
Concerning: Transit Mix Surface Mining Permit
Gentlemen,
Since we have not been able to get an electronic searchable copy of the DEIR, these comments are made from what we have learned about the project and are incomplete due to the limited time to study the Hard copy the county provided on April 12 . The proof that the file exists in electronic form is the file names are printed on the inside corner of each page. (8200A(EIR) 2/11/99).
1. There is no need for more sand, gravel and concrete sources .
2. A healthy supply of material available from their competitors. CalMat shut down their mine and removed their batch plant in the same area, for lack of need, in 1996. And to this day they have not reopened it even though it is fully permitted. Further, Calmat in its 10K report claims that it has a 100 year supply in the Los Angeles area.
3. The project mitigation is inadequate and will destroy the endanger habitat, scenic Highway and a rural community .
In fact the real need for this project is exposed on page S-6 "If approved, the Project will allow TMC to continue manufacturing sand and gravel products within the County after TMC's existing sand and gravel reserves in the City of Azusa are depleted within the next few years.".
This project is not needed. There are adequate existing commercial sources of sand and gravel in both Los Angeles County and specifically in the Santa Clara Valley and Antelope Valley. Proof of this is period of time because again there is no significant need for sand and gravel.
CalMat closed its surface mining operation, which is located about one mile south of the project, because of lack of use. Closing a working project for lack of use is absolute proof that this new project is unnecessary.
Calmat claims in their 10-K stockholder's report filled with the SEC that they have a 100 year supply of sand and gravel (1.8 billion tons) in LA County. This statement was contained in the 10K report Provided to the Agua Dulce Town Council and published to the community on 4-24-96
There are several sand and gravel mining operations using renewable sources which are
1. the new sand and gravel washed down the stream by natural actions during floods in the Santa Clara river.
2. Recycling of construction debris
The rocks and the mountains which Transit Mix intends to surface mine, contain a high level of nitrates. (see S-4 "The principal material to be mined will be the Vasquez Conglomerate,"
Those who know Spanish realize that Agua Dulce means "sweet water". Nitrates dissolved in water tastes sweet,
See report by Howard Carlip "An element occurring in volcanic rock. Soda Niter or Sodium Nitrate (NaO3) N 16.5%, Na 27%. It is described as deliquescent powder or granules, which means it undergoes gradual dissolution and liquefaction by the attraction and absorption of moisture from the air (Merck Index). It too is very soluble in water. "
See comments on the UCR report showing huge quantities of nitrates in the rocks."Also pointed out is the one Riverside rock and soil test on the "Vasquez Volcanics", showing 797 ppm nitrates buried in the appendix (B3-5),"
See comment about the Adjacent CalMat project published in 1996
Agua Dulce has one of the highest concentrations of natural nitrates occurring in the soil and rocks. This has been confirmed by a USGS study in the 1880’s when Chili cut off sources of Salt Petre for production of munitions. In a study of the entire United States they determined that the Agua Dulce area had the highest occurring natural amount of nitrates in the U.S. When sand and gravel is crushed and washed, the nitrates are dissolved and placed in the water table. Since the runoff of this project would be directly into the Santa Clara river, which supplies a substantial portion of the drinking water for 100,000 -plus individuals, this additional source of nitrate pollution is critical and is sufficient to stop the project.
A study of the commercial wells in the area shows that the Pine Tree well, located just south of the existing sand and gravel areas, has a high concentration of nitrate in the water. This nitrate approaches the maximum safe level of 40 mg/l. To allow this project which is unneeded, to pollute this drinking water, would be unconscionable. There is no possible mitigation except to do the project in another area that does not pollute drinking water.
Agua Dulce has already been designated as a health hazard area by Los Angeles County because of high nitrates in the ground water.
Page S-3 "Existing aggregate reserves for the Los Angeles County P-C Region, which includes the Saugus-Newhall, Palmdale, San Gabriel Valley, and San Fernando Valley P-C Regions, will be depleted over the next several years." This unsupported self serving statement is not true. The Antelope Valley has sand and gravel mines approved by LA County, with supplies for current needs to exceed 100 years. All other areas have sufficient supplies based on current needs for at least 30 years.
Page S-3 "Because public agencies are the primary purchasers of aggregate products, increased costs associated with bringing materials from distant production locations will be passed on to the taxpayers." This is just not true as very limited public agency projects are planned or budgeted at the present time. An informal survey of several suppliers indicated that private uses are 10 time agency uses.
Page S-3 "The CDMG monitors consumption of aggregate reserves in six separate aggregate P-C regions within the County. Among the conclusions presented by the CDMG in its 1994 update report are the following: The CDMG estimates that the current sand and gravel reserves in the County will run out by the year 2016 unless new reserves are permitted. Actual County consumption for the period from 1982 to 1992 exceeded estimates for the period by 24 percent."
The CDMG report in 1994 is obsolete and used data on the unlimited growth era of 1982 to 1992. This growth rate will never be seen again. If you look at projects filed with the RPC from 1994 to today they supports the sharp downturn in growth showing a lack of need for more aggregate sources.
The area is a non-attainment area for particulates. Obviously surface mining and rock crushing will produce significant dust added to the community. Therefore, these effects cannot be mitigated adequately.
The only access are two narrow mountain roads, Agua Dulce Canyon and Soledad Canyon, both with high traffic levels and high accident rates. This would be unacceptable.
See page S-5 The Project would operate 7 days per week with aggregate processing occurring up to 16 hours per day and product shipping occurring 24 hours a day, depending on demand. and goes on to claim on S-9 However, because of distance and intervening topography, no significant noise impact on the town of Agua Dulce is predicted
Agua Dulce is a quiet, rural community which prizes it’s dark nights and no street lights or other urban lighting. This project would produce night lights and many of them would probably be left on all night long. The noise would be heard and would disturb the people living in the community.
See page S-7 The Project is located in the Acton Valley Subunit near the boundary of the Eastern Subunit of the Santa Clara River Valley hydrologic unit. Precipitation is the primary source of water in the Acton Valley Subunit, and although the annual and seasonal precipitation varies, the aquifer recharges quickly regardless of the annual precipitation amount.
What an outrageous statement. We have plenty of water regardless of the annual precipitation. What can we believe in the entire report if this is an example of their "engineering".
See Page S-8 "The Eastern Subunit comprises a larger area than the Acton Valley Subunit. Water resources in the Eastern Subunit include development of alluvial sediments of the Santa Clara River and development of the Saugus Formation. Neither the Acton Valley Subunit nor the Eastern Subunit is projected to be in danger of overdrafting the respective water resources".
The so-called eastern Subunit is the water supply for Santa Clarita and points down stream all the way to Ventura. Acton according to LA County is so short of water the county and the developers spent 12 million dollars to connect the Acton Water System to AVECK.
The Newhall ranch project has to identify new sources of water supply for each of their developments as You as the RPC agreed that the ground water was already overdrafted from this exact source in your approval of that project.
See Page S-8 Both surface and subsurface water quality in the immediate area of the site is considered to be good by the CRWQCB
Wrong the CRWQCB has issued a report showing hazardious nitrate pollution in Agua Dulce and a public report of the commercial wells in the area shows that the Pine Tree well, located just south of the existing sand and gravel areas, has a high concentration of nitrate in the water, making it unfit for direct use.
See Page S-10 Approximately 23 acres of riparian habitat occur adjacent to and downstream of the site in the Santa Clara River channel. This reach of the river is part of the essential habitat of the endangered unarmored threespine stickleback (stickleback) fis
The Santa Clara river is the last wild running river in Los Angeles County. To Extract all of this water and then pollute it with nitrates and return it to the river will destroy its natural state and cause severe damage to sensitive environmental areas. The exiting surface mining operations in the area are an eyesore and particularly bothersome is the pool of greenish colored water which slowly seeps into the river.
There are many other areas in Southern California where sand and gravel can be mined and particularly in this case there are areas which are operating mines that are closed for lack of use. This project therefore, is environmentally unsound and economically unsound and is simply a mechanism for one company to attempt to obtain supplies to enhance its competitive position relative to another company who has existing mines and mining rights. I therefore request that you deny this request and consider the environmental impact study improper and the use as unneeded.
On page S-9 "Fire protection services are provided by the Los Angeles County Fire Department and include three engines, a patrol, and a paramedic squad within 30 minutes of the Project site".
Mining and blasting has one of the highest injury rates for industrial occupations. How would you like to wait 30 minutes for a paramedic after a major injury. The effect on the our community while our only paramedic unit, in 15 miles, spends its time serving the mining site is a reduction of service to our community.