Andrada Quarry Expansion Environmental Assessment (TPD1912054)

1   

INTRODUCTION

1.1             Background

Mining Background

The Andrada Quarry is located approximately 25 miles southeast of Tucson, Arizona, at the north end of the Santa Rita Mountains, one mile south of the intersection of Sahuarita and Wentworth Roads (Figure 1).

The existing quarry is located on privately owned land. Andrada Holdings, LLC proposes to expand the quarry onto adjacent split-estate land where the Arizona State Trust holds the surface estate and the United States Bureau of Land Management (BLM) holds the mineral estate. The surface estate and mineral estate were severed in 1941, the result of a state exchange patent being granted by the United States to the State of Arizona for ownership of the surface estate.

The quarry is in a rural area with low density residential neighborhoods 0.5 miles to the east and 1.5 miles to the north. The area is undergoing rapid development with high density housing subdivisions two miles to the west.

The quarry has been in operation for more than 45 years and has produced a variety of high grade calcium carbonate products that have been utilized in the construction, paint, paper, and landscaping industries. The area is underlain by the Escabrosa Limestone which has been mined and exposed by numerous pits, drill holes, and exploration trenches including a pit mined by former owner Georgia Marble Company. This mine pit intersects the water table.

While the complete operational history of the privately owned Andrada Quarry is uncertain, key dates are as follows:

• The Andrada Marble Company initially began quarrying for marble at the site in 1959.
  • Georgia Marble purchased the operation from the Andrada Marble Company in 1991 and operated the quarry until 1997.
  • Imerys Marble purchased the Georgia Marble Company in 1997.
  • Imerys ceased quarrying marble, but continued material processing and bagging operations through 2003 using material from existing stockpiles and material produced from their mine near Sahuarita, Arizona.
  • W.R. Henderson acquired the site from Imerys Marble in August 2003.
    • Andrada Holdings LLC acquired the site in September 2011 and currently holds title to private lands and mining claims on state lands associated with the quarry.
    • Lamb Rock and Southern Arizona Rock operated the site for aggregate production from late 2003 through March 2014.
    • The site has been inactive since March 2014 while Andrada Holdings is in negotiations with a new operator.

Process Background

A mine plan of operations (MPO) for the proposed operation at the Andrada Marble Quarry was submitted by Andrada in 2004. In accordance with provisions of the National Environmental Policy Act (NEPA), the impacts of the proposed operation were analyzed through an environmental assessment (EA). The Tucson Field Office issued a Finding of No Significant Impact (FONSI) and Decision Record approving the EA and MPO in July 2005. In August 2005, a request for a State Director review of the decision was received.  A remand of the decision and subsequent stay was issued by the BLM Arizona State Director in November 2005. The BLM revised the MPO and the environmental analysis to better address the issues brought forth by the petitioners.

The revised MPO and EA were approved March 12, 2007. This decision was then appealed to the Interior Board of Land Appeals (IBLA). Pursuant to the IBLA order (IBLA 2007-164) of July 31, 2007, the decision to approve the MPO was set aside and remanded.

A new EA and unsigned FONSI were prepared and made available for public comment from April through June 2013. Nearly three hundred separate comments were received including one hundred seventy two substantive comments. Refer to Section 1.6.3 below for more information on how comments were addressed.

This EA addresses the substantive comments received in 2013 and new information provided by Andrada Holdings.

1.2             Purpose and Need for Action

The purpose of this action is to respond to the submission of a proposed MPO from Andrada Holdings to expand their existing quarry site. Pursuant to the U.S. mining laws, Andrada is entitled to conduct operations that are reasonably incident to exploration and development of mineral deposits on its unpatented mining claims. The need for the action is established by BLM’s responsibility under the Federal Land Policy Management Act (FLPMA) and the Mining and Minerals Policy Act of 1970, and as described in regulations at 43 CFR 3809.

1.3             Decision to be Made

The BLM must determine if the proposed MPO meets the requirements of 43 CFR 3809.401. Based on an evaluation of alternatives and potential impacts, the BLM will make a decision determining whether or not to approve the proposed MPO. The BLM may add additional mitigation measures to reduce resource impacts, if warranted.

Although a portion of the proposed project would occur on Arizona State Trust lands, the BLM is the approving surface management agency with regard to approval of the MPO. At a minimum, this includes BLM’s authority to require the following:

• Avoidance of sensitive resources and relocation of a surface disturbance activity in order to protect a sensitive resource.
  • Submittal and implementation of an adequate reclamation plan and achievement of reclamation goals.
  • Conduct operations in a manner that avoids unnecessary or undue impacts to other resources.

1.4             Conformance with Applicable Land Use Plan(s)

The Proposed Action is subject to the Phoenix Resource Management Plan (RMP), approved September 1989. Page 14 of the RMP under the Minerals Management section states that mineral development is generally encouraged on public lands that are open to entry and location under the U.S. mining laws in adherence to BLM’s multiple-use mission. The Proposed Action has been determined to conform to the land use plan terms and conditions as required by 43 CFR 1610.5.

1.5             Relationship to Statutes, Regulations or Other Plans

Per 30 USC Sec. 1602 it is the continuing policy of the United States to promote an adequate and stable supply of materials necessary to maintain national security, economic well-being, and industrial production with appropriate attention to a long-term balance between resource production, energy use, a healthy environment, natural resources conservation, and social needs. Further, the Mining and Minerals Policy Act of 1970 declares that the policy of the Federal Government is “to foster and encourage private enterprise in the development of a stable domestic minerals industry and the orderly and economic development of domestic mineral resources”.

Exploration and development of locatable mineral resources are provided for under the regulations found at 43 CFR 3809 and 3715. Mining activity is administered on a case-by-case basis. The BLM decision would authorize the use of mineral estate held in reserve by the federal government and managed under the authority of the BLM. Use of non-BLM land (State Trust land and private land) is subject to the agency or private landowners’ permission.

Pursuant to A.R.S. 27-254, Andrada has acquired a land use permit from the Arizona State Land Department. Special Land Use Permit 23-114960-11 encompasses 100 acres within the State of Arizona Lease located in the Northwest Quarter of the Northwest Quarter of Section 21, Township 17 South, Range 16 East, G&SR Meridian.

Quarry access is located on Arizona State Trust land. Andrada has access via a right-of-way from the Arizona State Land Department. Haul Road Right of Way, Lease No 18-116832, is located by metes and bounds through the West Half of Section 16, Township 17 South, Range 16 East, and by metes and bounds through the Northeast Quarter of the Northwest Quarter of the Northwest Quarter of Section 21, Township 17 South, Range 16 East, Gila & Salt River Meridian as identified on the Mount Fagan, Arizona, 7.5 Minute USGS Quadrangle Map (1996).

In 2006, Pima County prepared the Pima County Comprehensive Land Use Plan (PCCLUP) – Planned Land Use – Eastern Pima County, to regulate future development of undeveloped areas of Pima County (Pima County 2006). According to the PCCLUP, the proposed project area occurs within an area designated as a Biological Core within Pima County’s Conservation Land System. Pima County designated land use of the area where Andrada is proposing operations as low-to-medium urban development. The Pima County plan calls for protection of Biological Core lands within the Conservation Land System through low-intensity uses and acquisition by the County. Although provisions for mining are not addressed in the PCCLUP, jurisdiction over the mineral estate of the subject lands remains with the federal government.

Pima County Outdoor Lighting Code, Ordinance 2012-14, provides rules and guidelines for lighting with the purposes described in Section 101 of the code:

The purpose of this code is to preserve the relationship of the residents of the City of Tucson, Arizona and Pima County, Arizona to their unique desert environment through protection of access to the dark night sky. Intended outcomes include continuing support of astronomical activity and minimizing wasted energy, while not compromising the safety, security, and wellbeing of persons engaged in outdoor night time activities. It is the intent of this code to control the obtrusive aspects of excessive and careless outdoor lighting usage while preserving, protecting, and enhancing the lawful nighttime use and enjoyment of any and all property. It is recognized that developed portions of properties may be required to be unlit, covered, or have reduced lighting levels in order to allow enough lumens in the lighted areas to achieve light levels in accordance with nationally recognized recommended practices.

Mine Safety and Health Administration regulations require adequate lighting at surface mines.

30 CFR§56.17001 Illumination of surface working areas.

Illumination sufficient to provide safe working conditions shall be provided in and on all surface structures, paths, walkways, stairways, switch panels, loading and dumping sites, and work areas.

Mining operations located on federal mineral estate are not subject to local planning or zoning decisions. Although regulations found at 43 CFR 3809 do not specifically address applicability of local zoning to mining operations on federal mineral estate, in California Coastal Commission v. Granite Rock Company, 480 U.S. 572 (1987), the court ruled that “zoning of Federal land by a State is not permissible, as Congress, by passage of both FLPMA and National Forest Management Act, placed Federal land use planning and zoning with the Federal Government, not the States”. In addition, according to Arizona law,

A.R.S. 11-830 (2), a county cannot prevent, restrict or otherwise regulate the use or occupation of land or improvements for railroad, mining, metallurgical, grazing, or general agricultural purposes if the tract concerned is five or more contiguous commercial acres.

In accordance with applicable state statutes and applicable case law, operations such as the Andrada Quarry cannot be denied on the basis of county planning and zoning requirements.

1.6             Scoping and Public Involvement

1.6.1     Internal Scoping

Internal scoping for this EA included site visits by BLM Tucson Field Office (TFO) resource specialists, a review of available resource information, and an assessment of the types of impacts typically associated with mineral development.

1.6.2     External Scoping

Two public scoping meetings were held. The first was held February 14, 2005 at the Corona de Tucson Fire Station and hosted by the Santa Rita Homeowners Association. Approximately 20 people attended this meeting. The second scoping meeting was held February 26, 2005 at the Corona de Tucson American Legion Hall and hosted by the Empire Fagan Coalition. Approximately 35 people attended this meeting.

BLM sought public involvement from the community surrounding the Andrada Quarry. Approximately 1,800 post cards were mailed in April, 2005, to the zip-code area in which the Andrada Quarry resides to inform the public that the EA and unsigned FONSI were available for a 30 day review. In response, BLM received 25 letters and e-mails from the public, all of which generally did not support mine expansion.

The Tucson Field Office accepted public comments on the April 22, 2013 version of the EA during a 60 day comment period (April 30 through July 01, 2013) and conducted a public meeting in Corona de Tucson on May 21, 2013 during which the public was invited to make comments and ask questions concerning the project and BLM’s environmental analysis. Two hundred ninety two separate comments were received including one hundred seventy two substantive comments.

1.6.3   Response to Comments Received

In response to the release of the April 2013 EA, two hundred ninety two separate comments were received including one hundred seventy two substantive comments. Substantive comments focused on water use, dust, noise, traffic, and blasting, Please refer to Appendix A to see a list of the substantive comments and how the comments were addressed in this document.

1.7             Issues

1.7.1     Issues Considered, but eliminated from Detailed Analysis

• ·         Issue: Would the Proposed Action have disproportionate adverse impacts on minority or low income communities?

Executive Order 12898, Federal Actions to Address Environmental Justice in Minority Populations and Low-Income Populations, 1994, requires federal agencies to disclose disproportionate impacts of federal actions on minority and low-income populations. The Environmental Protection Agency defines Environmental Justice as the fair treatment and meaningful involvement of all people regardless of race, color, national origin, or income with respect to the development, implementation, and enforcement of environmental laws, regulations, and policies. Fair treatment means that no group of people, including a racial, ethnic, or a socioeconomic group, should bear a disproportionate share of the negative environmental consequences resulting from industrial, municipal, and commercial operations or the execution of federal, state, local, and tribal programs and policies.

Environmental Justice, Guidance under the National Environmental Policy Act, Council on Environmental Quality, 1997, specifically identifies low-income populations in addressing environmental justice issues under NEPA. Commenters on the April 2013 EA suggested that housing values be used in place of income as an indicator of poverty. Housing values reflect not only income availability but also lifestyle choices and personal values and are therefore not a suitable proxy for income in meeting the requirements of Executive Order 12898.

Households residing in zip code 85641 compared to criteria defining “low-income population”

Low-income populations are defined in different ways for different purposes. For this analysis a low-income population is one in which the incomes of 30% or more of families fall below 200% of the federal poverty threshold. This criterion has been adopted by the U.S. Department of Health and Human Services in determining eligibility for many community-based assistance programs and is useful for looking at community-scale poverty. According to U.S. Census Bureau data for 2010, the average family size for families residing within zip code 85641 was 3.15 persons. For 2010, the federal poverty threshold for a family of three was an annual household income of $17,374. Therefore the definition of low-income for 2010 for the average family residing within zip code 85641 was $34,748. In 2010, 8.7% of families living within the 85641 zip code met the definition of low-income (annual household income below $35,000). Therefore, the community residing within zip code 85641 does not meet the definition of low-income population.

A similar analysis for Vail, AZ and Corona de Tucson, AZ showed that for 2010, 9.8% of families in Vail met the definition for low-income while in Corona de Tucson 6.1% of families met the definition for low-income. Therefore neither Vail nor Corona de Tucson meets the definition of low-income population. Data are not available to evaluate the Copper Cut area separately from the rest of zip code 85641.

By comparison, 26.6% of Arizona families meet the definition of low-income.

According to the U.S. Census Bureau’s American Community Survey 2012-2016, the average household size in the 85641 zip code area had dropped to 2.76 persons/household. No economic data are available to update the 2010 census data and therefore it is not possible to update the determination of whether or not the population residing in zip code area meets the definition of a “low income population”.

According to 2010 U.S. Census Bureau data concerning the racial makeup of the community in zip code 85641, racial minorities made up 12% of the community population. According to the U.S. Census Bureau’s American Community Survey 2012-2016, racial minorities were estimated to make up 12% of the population residing in zip code 85641 in 2016. This is the latest available data.

Based on the above statistics, minority and low-income populations do not comprise more than 30% of the population in the project area and therefore the project would not have a disproportionate impact on minority or low-income populations.

• ·         Issue: How would the Proposed Action impact caves or paleontological resources?

While solution features exist within the proposed project area, no caves have been identified. Therefore this issue has not been carried forward for detailed analysis.

The marble in the project area has been metamorphosed and re-crystalized. The potential for fossils occurring in the project area is low as re-crystallization of the marble likely destroyed any fossils that might have existed in the precursor limestone. Therefore this issue has not been carried forward for detailed analysis.

• ·         Issue: How would the Proposed Action impact cultural resources?

A cultural resources inventory consisting of a Class I survey (records search and literature review) and a Class III survey (100% coverage, pedestrian, non-collection) were completed in May 2004 (Cultural and Environmental Systems 2004). No cultural resources were identified in the proposed project area.

According to the Pima County, Office of Sustainability and Conservation, Cultural Resources and Historic Preservation Division, a Class III cultural survey was completed by Professional Archaeological Services of Tucson, Inc. (PAST) of the haul road and an area slightly overlapping and to the west of the quarry area with findings of no significant archaeological or historic sites (Pima County, via email June 28, 2013).

Historic mine workings existed one half mile to the south of the project area. The Arizona State Mine Inspector completed the remediation of these historic abandoned mine workings in 2013. Work included the backfilling of the mine workings.

Based on the results of the two cultural resources surveys and the remediation work conducted by the Arizona State Mine Inspector, cultural resource impacts of the Proposed Action are not carried through for detailed analysis.

1.7.2     Issues Identified

• Issue 1: Would water use at the quarry affect water quantity and quality?
• Issue 2:How would the Proposed Action contribute to particulate emissions and greenhouse gases?
  • Issue 3: What are the visual impacts, including impacts to night skies, of the Proposed Action during operation and what would be the residual visual impact of the reclaimed mine?
  • Issue 4: How would the Proposed Action impact traffic on Sahuarita and Wentworth Roads?
  • Issue 5:How would the Proposed Action affect the generation of hazardous or solid wastes?
    • Issue 6: How would the Proposed Action affect the spread of noxious weeds and other invasive plant species and/or bullfrogs?
    • Issue 7: How would the Proposed Action affect neighboring residential property values?
    • Issue 8:How would the Proposed Action affect blasting related effects including noise and potential damage to neighboring structures?
      • Issue 9: How would the Proposed Action impact wildlife and threatened, endangered and sensitive species?
      • Issue 10: How would the Proposed Action affect livestock grazing?

2   

PROPOSED ACTION AND ALTERNATIVE(S)

2.1                      No Action

Under the No Action alternative the Andrada Quarry would not be expanded onto lands underlain by federal mineral estate. Mining would continue on the private lands held by Andrada Holdings. Under the No Action alternative, federal surface management regulations would not apply and the quarry would be operated under applicable state law.

2.2                      Proposed Action

The Andrada Quarry is located in Section 21, T. 17 S., R. 16 E., Gila and Salt River Base Line and Meridian, Pima County, Arizona. The Proposed Action consists of mining and processing high-purity calcium carbonate (marble) from the Escabrosa Formation. The existing quarry covers approximately 22 acres, of which 11 acres is the mine itself and 11 acres host support facilities. The proposed expansion would increase the quarry size by 14.2 acres, for a total project area/disturbance area of 37 acres.

Under the proposed MPO, a new quarry pit of 10 acres and support areas of 4.2 acres would be developed partially on private land and partially on adjacent State Trust lands west of the existing Andrada Quarry (Figure 3). Specifics of pit development would be a function of the distribution of the high grade marble, but in general, a series of highwalls and benches trending west-northwesterly would be constructed in accordance with applicable state and federal regulations to maintain pit wall safety and slope stability.

Mining Operations – Excavation would be accomplished via ripping with tracked equipment, as well as drilling and blasting, utilizing best practices to limit noise and vibration. Blasting would be conducted by licensed blasting contractors. No explosives would be stored on site. Gates and berms would be established to limit access to the project area, with no public access to the operational areas.

Broken rock would be transported by excavators, front end loaders, or dump trucks to one or more primary crushers and then to a loading facility located near the Old Quarry site (Figure 3). Crushing operations would be operated intermittently at the site, dependent on market demand. Crushing facilities would include a crushing and screening plant with attendant ancillary equipment, such as conveyors.

Crushing equipment would be powered with electricity supplied by the local power utility. Stockpiles would be established to store run-of-mine and crushed material for market sales. Crushing and loading facilities would be located on previously disturbed areas on private lands, but a portion may extend onto the adjacent State Trust land. Only one crushing phase (primary) would be conducted on site. Mine run material would be crushed to 3 inches minus and then trucked to a processing plant in Casa Grande for additional processing. No chemicals would be used in the crushing operations.

Water Usage – Total water use for all mining operations including dust suppression is estimated to be 10 acre feet (3.3 million gallons) per year. Water would be purchased from a local water utility and hauled to the site as needed. The closest hydrant that is not in a residential area is located on Davidson Road at Sahuarita Road, two miles east of the quarry entrance drive and three miles from the quarry.

Quarry Access – Access to the quarry facility would be via two routes. The main access is from Wentworth Road at the north end of the property, with a second access from private lands to the east by a county easement on East Copper Chief Trail to South Copper Cut Trail Road. The main access is gated. The second access has been blocked to prevent access to the site and is expected to remain closed during quarry operations.

Production – Past operations at the project site have produced cement-grade limestone/marble (greater than 90% CaCO3). Drill data has indicated some higher grade limestone (greater than 95% CaCO3), which would be suitable for higher use applications such as animal feed, joint compounds, cultured marble, paper filler and high brightness paper filler.

Yearly production from the federal mineral estate is estimated at 300,000 tons, or approximately 1,250 tons/day for a 240-day work-year. Estimated mine life on the federal mining claims is 6 to 8 years.

Operating Hours – Typical operating hours would be 7:00 a.m. through 6:00 p.m., Monday through Friday.

Traffic – The number of daily truck trips carrying products from the quarry to Casa Grande would be dependent upon market demand, but may range between 32 and 64 round trips per day. The quarry may be inactive during periods of low demand. It is anticipated that truck traffic would use the Wentworth Road access. In addition, water trucks would make 3-4 round trips per day from the quarry to the supply hydrant at Davidson and Sahuarita Roads.

Desert Tortoise Protection – Measures designed to mitigate impacts to the Desert Tortoise are included in the Proposed Action (JPC Consulting, 2016). These measures would be in place prior to quarry expansion onto the federal mineral estate. Measures would include the following:

• Operator would educate employees on tortoise status, tortoise ecology, avoidance and handling methods.

• A speed limit of not more than 25 miles per hour would be established and enforced by the operator on all quarry roads, including the entrance road. Operator would post signs alerting drivers to the possible presence of tortoise on roadways.

• Appropriately designed perimeter fencing would be installed to exclude the desert tortoise from active operations areas.

• Unleashed dogs would be prohibited on site.

Reclamation Plan

At end of mine life, final pit configuration is estimated to be approximately 800 ft. in length by 700 ft. in width. Total depth at the deepest portion of the final pit is estimated at approximately 110 ft. Terracing of final pit walls would be developed with 20-ft wide benches in order to mitigate rock fall potential. In order to achieve slope stability, pit walls would be graded back to obtain a final overall slope of no greater than 2:1, with a bench height no higher than 30 ft. Grading of the pit walls would be achieved by ripping the top of the highwall, then grading loosened material to the toe. Drilling and blasting may be necessary in areas that are too hard to rip with equipment.

Overburden and waste material from crushing operations would be used to backfill the Old Quarry located on Andrada’s private holdings. Erosion control of the overall site would be provided through re-grading to blend in with natural topography, re-vegetation of re-graded areas, and storm water controls. Structural controls in the form of detention/retention basins would be constructed as necessary. All reclamation efforts would be performed in accordance with BLM’s H-3041-1, Solid Mineral Reclamation Handbook (BLM 1992), and as defined in Andrada’s Mining and Reclamation Plan, as approved.

If this expansion is approved, mining operations are anticipated to continue through at least 2040. Removal of all equipment would occur within 90 days of completion of mining operations. Erosion control measures are anticipated to be completed concurrent with equipment removal. Re-vegetation activities would be scheduled during the months of October and November following final grading and completion of erosion control measures.

Concurrent reclamation would occur as areas of the active mining operations become complete and no additional activity is anticipated. Post-mining land use of the State Trust lands is anticipated to be open space returned to as close to natural conditions as possible. The private lands would be re-graded for mixed-use development.

2.3                      Alternatives Analyzed in Detail

No other alternatives have been developed or submitted.

2.4                      Alternatives Considered but Eliminated from Detailed Study

An alternative was proposed by a commenter that encouraged additional residential and park development in the project vicinity. The alternative does not meet the purpose and need for this project and will not be carried forward for detailed analysis.

3      AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES

3.1             Issue 1: Would water use at the quarry affect water quantity and quality?

3.1.1     Affected Environment

Surface Water

As a result of Arizona’s semi-arid desert climate, very little rain reaches the ground. High intensity storms have the potential to cause storm water pooling and discharge off the property. Annual rainfall within the project area is 12 inches, with 60% to 70% of the annual total occurring in the months of July, August, and September. Summer monsoonal moisture typically causes short-duration high-intensity storms that, by their nature, produce considerable runoff because the ground cannot absorb the water as fast as it falls.

Under section 402(p) of the Clean Water Act (CWA) and regulations found in 40 CFR 122, storm water discharges associated with industrial activity are prohibited to waters of the United States unless they are covered under an authorizing permit. The U.S. Army Corps of Engineers (COE) administer Section 404 permitting of the Clean Water Act regulating discharge of dredged or fill material into “waters” of the United States, which includes lakes, reservoirs, wetlands, and perennial and ephemeral streams and washes. Under the current Plan of Operations for the site, a determination from the COE in a letter dated October 18, 2004, indicated there were no jurisdictional waters of the U.S. present within the project area, and therefore was not subject to jurisdiction under Section 404 of the Clean Water Act.

In Arizona, storm water discharges are covered by Arizona Pollutant Discharge Elimination System (AZPDES) permits. Andrada has submitted a Storm Water Pollution Prevention Plan (SWPPP) to comply with the requirements of the AZPDES General Permit for Storm Water Discharges Associated with Industrial Activity – Mineral Industry, also known as the Mining Multi-Sector General Permit (MSGP). This plan identifies possible characteristics of the facility that may have an impact from a storm water discharge event, as well as the associated controls that would be used to manage an event from the site, as required by the Arizona Department of Environmental Quality (ADEQ). The MSGP establishes effluent limits and identifies control measures in accordance with applicable state and federal requirements.

ADEQ regulates facilities that discharge pollutants [(A.R.S. 49-201(49)] either directly to an aquifer, the land surface, or the vadose zone (zone between the land surface and the water table) through use of an Aquifer Protection Permit (APP). As defined in A.R.S. 49-241, ADEQ defines certain facilities as “discharging” that are required to operate under an APP. ADEQ has also identified facilities that are exempt from acquiring an APP (A.R.S. 49-250). Included in the list of exempt facilities are those where “mining overburden returned to the excavation site including any common material which has been excavated and removed from the excavation site and has not been subjected to any chemical or leaching agent or process of any kind”. After submitting an application “checklist”, ADEQ determined the Andrada Quarry site meets the criteria for exempt status.

Groundwater Use

The Andrada Quarry would purchase water from a municipal source which utilizes a mixture of groundwater from multiple wells and Colorado River water from the Central Arizona Project. Analyzing impacts of Andrada’s water use on the municipal system is neither feasible nor warranted. The scope of this analysis ends at the hook up to the municipal system.

3.1.2     Impacts from the No Action Alternative

Direct and Indirect Impacts

Surface Water

Storm water runoff is detained behind a berm constructed across a drainage at the north end of the existing quarry area.

Groundwater

Local water utilities provide a combination of groundwater and Colorado River water from the Central Arizona Project to meet customer demand. Andrada would rely on this source for all water used at the quarry under the No Action Alternative. The service area for the local water utility is north of Sahuarita Road so Andrada will truck water to the quarry from an off-site hydrant. Residences near the quarry and south of Sahuarita Road use a combination of well water and water hauling as water sources.

Cumulative Impacts

The expected impacts of the proposed Rosemont Copper Mine, located eight miles south of the Andrada Quarry, were analyzed in the Final Environmental Impact Statement for the Rosemont Copper Project (Rosemont EIS), (USFS 2013). The Rosemont EIS predicts that groundwater drawdowns at the Rosemont Mine would impact the Andrada Quarry area with drawdowns on the order of zero to five feet within 150 years of the cessation of mining at the Rosemont pit and drawdowns of zero to fifteen feet within 1000 years of the cessation of mining at the Rosemont pit. Note that the groundwater water model used in preparing the Rosemont EIS was intended to estimate regional impacts to the groundwater system from the proposed Rosemont Copper Mine and is not suited for making precise predictions at locations far from the proposed Rosemont pit. The Andrada Quarry area was modeled as an equivalent porous media using a course model grid (200 meter cell width and length), therefore the model results should not be applied to any specific well location but used as a general prediction of the impacts of the Rosemont Mine on the Andrada Quarry area.

3.1.3     Impacts from the Proposed Action

Direct and Indirect Impacts

Surface Water

Storm water impacts would be minimal and would be controlled. Controls and best management practices are outlined in the Storm Water Pollution Prevention Plan. A twelve inch or greater berm surrounding the site in the shape of a shallow dish would be constructed; sufficient to control a 500 year storm event.

Groundwater

No system that discharges to groundwater would be used on site. To ensure the existing Marble Quarry on Andrada’s private land does not expose intercepted groundwater to potential contaminants, the pit would be reclaimed as required by state law and regulation. Overburden and rejected process material may be used to partially backfill the pit on Andrada’s private land. Reclamation of the pit would occur concurrently with proposed new mining operations, with final reclamation completed at the end of quarry life. No off-site materials would be used for the reclamation of the pit on State Trust/federal mineral lands.

The rock that is removed from the site does not require washing or leaching and therefore the processing does not require water other than dust control. The only other water that would be used on site is for dust control on roads and exposed surfaces and domestic uses in the on-site building.

Local water utilities provide a combination of groundwater and Colorado River water from the Central Arizona Project to meet customer demand. Andrada would rely on this source for all water used at the quarry under the Proposed Action. The service area for the local water utility is north of Sahuarita Road so Andrada will truck water to the quarry from an off-site hydrant. Residences near the quarry and south of Sahuarita Road use a combination of well water and water hauling as water sources.

Cumulative Impacts

Construction activities subject to the Clean Water Act and pumping of groundwater in support of residential development and residential water uses are expected to continue in the vicinity of the Andrada Quarry.

The expected impacts of the proposed Rosemont Copper Mine, located eight miles south of the Andrada Quarry, were analyzed in the Final Environmental Impact Statement for the Rosemont Copper Project (Rosemont EIS), (USFS 2013). The Rosemont EIS predicts that groundwater drawdowns at the Rosemont Mine would impact the Andrada Quarry area with drawdowns on the order of zero to five feet within 150 years of the cessation of mining at the Rosemont pit and drawdowns of zero to fifteen feet within 1000 years of the cessation of mining at the Rosemont pit. Note that the groundwater water model used in preparing the Rosemont EIS was intended to estimate regional impacts to the groundwater system from the proposed Rosemont Copper Mine and is not suited for making precise predictions at locations far from the proposed Rosemont pit. The Andrada Quarry area was modeled as an equivalent porous media using a course model grid (200 meter cell width and length), therefore the model results should not be applied to any specific well location but used as a general prediction of the impacts of the Rosemont Mine on the Andrada Quarry area.

3.2                      Issue 2: How would the Proposed Action contribute to particulate emissions and greenhouse gases?

3.2.1                 Affected Environment

The Environmental Protection Agency (EPA) has the primary responsibility for regulating air quality, which includes seven nationally regulated ambient air pollutants. EPA has delegated enforcement of air quality standards to some states. In Arizona, federal air quality regulations are enforced by the Arizona Department of Environmental Quality (ADEQ) through its delegated authority from the EPA. As defined in accordance with Arizona Revised Statues (A.R.S.) §49-107, the ADEQ has delegated to Pima County Department of Environmental Quality the responsibility for determining potential impacts subject to air quality laws, regulations, standards, control measures, and management practices within the project area. ADEQ has the ultimate responsibility for reviewing and permitting any project’s air quality impacts.

National Ambient Air Quality Standards (NAAQS) are health based criteria for the maximum acceptable concentrations of air pollutants in an area of public use. Air quality standards are defined in accordance with Arizona Revised Statues (A.R.S.) 49-480 and Title 17, Article 1, Pima County Code 17.08.030.

Currently, health consequences of dust are addressed through ADEQs evaluation of pollution sources and their impacts on public health and welfare. Short and long term exposure to both coarse (PM 10) and fine (PM 2.5) particulate matter can cause harmful respiratory effects, which may include development of chronic respiratory diseases, such as asthma. In December, 2012, the EPA strengthened the nation’s air quality standards for fine particle pollution, by revising the primary annual standard to 12 micrograms per cubic meter (µg/m3), and retaining the 24-hour final particle standard of 35µg/m3.

The portion of Pima County where the project occurs is in area designated as “attainment” for ambient air quality standards equal to or less than national primary or secondary air quality standards for regulated air pollutants. Although specific performance standards regarding air quality standards for mine sites are not specified in 43 CFR §3800 regulations, performance standards, in accordance with 43 CFR §3809.420 state that “All operators shall comply with applicable Federal and state air quality standards, including the Clean Air Act (42 U.S.C. 1857 et seq.). All applicable Federal, State, and County pollution standards and permits must be in place prior to production activities, and remain in good standing through the course of active operations.

In accordance with A.R.S. 49-426, Andrada has acquired an Air Quality Control General Permit from the Arizona Department of Environmental Quality (ADEQ) for crushing and screening plants. ADEQ General Permit #102 was issued February 26, 2014 for a period of 5 years. This permit sets forth general fugitive emission and opacity standards for operating crushing and screening facilities within the state of Arizona, as well as general emission limitations and standards for operating within Pima County. Crushing and screening operations within Pima County are also subject to regulations of the Pima County Department of Environmental Quality, which requires a stationary source permit for the onsite crusher.

Soils in Arizona host a fungus, Coccidioides, which can cause Valley Fever, an illness affecting humans and domestic dogs. Humans and dogs are exposed to the fungus through the inhalation of dust particles to which fungal spores are attached. Exposure to blowing dust can increase the risk of exposure to the fungus (Arizona Department of Health Services, 2016).

Greenhouse gases are generated by the burning of fossil fuels for transportation, heating, electrical power generation, and other power needs. Agricultural burning and livestock production also produce greenhouse gases in Pima County. Mining produces greenhouse gases through the use of fossil fuels and temporarily decreases carbon sequestration in through the removal of vegetation at the mine site and along access roads.

3.2.2                 Impacts from the No Action

Direct and Indirect Impacts

Quarrying operations would continue on Andrada Holding’s private lands and would continue to be subject to Pima County Air Quality standards. Greenhouse gases would be generated through the burning of fossil fuels during mine operations. The proposed 14 acre pit expansion area would not be stripped of vegetation under this alternative.

Water is the dust control agent used to control vehicle dust and to minimize dust produced during crushing operations. Dust from areas where tracked equipment is operating and from exposed stockpile areas is controlled with regular application of water. In addition, appropriate speed limits are enforced in the existing mine area. Visible Emission Test results, as required, are reported to Pima County to demonstrate that air quality standards are being met.

Measures taken to reduce dust emissions would also reduce the dust-borne transport of fungal spores that can cause Valley Fever.

Cumulative Impacts

Other sources of dust in the vicinity of the Andrada Quarry include livestock grazing, residential construction, and motor vehicle operation on and maintenance of unpaved roads.  Sources of greenhouse gases include livestock grazing and the burning of fossil fuels for heat and motor vehicle operation. Residential development is expected to increase in the area, temporarily increasing dust emissions during construction and permanently increasing greenhouse gas emissions as more fossil fuels are burned to support residential heating and increased vehicle use. The production of dust and greenhouse gases due to livestock grazing is expected to decline as residential development occurs on former grazing lands.

3.2.3                 Impacts from the Proposed Action

Direct and Indirect Impacts

Andrada proposes to modify the current practice of using water alone to control dust. Andrada proposes to use a vinyl copolymer tackifier (Gorilla Snot or the functional equivalent) on all areas of the quarry and access road which would be used by rubber-tired vehicles only, and other areas where fugitive dust sources are likely to develop. Dust from areas where tracked equipment would be operating and exposed stockpile areas would be controlled with regular application of water. In addition, appropriate speed limits would be enforced in the mine area and spray bars would be installed at several points on crushing equipment to limit dust generation. Visible Emission Test results, as required, would continue to be reported to Pima County to demonstrate that air quality standards are being met.

Impacts of the proposed action on air quality would be from fugitive dust or equipment (rolling stock) emissions. Particulate matter emission limitations are set forth in the Pima County air quality control permit with compliance demonstration monitoring standards. Emission control techniques described in the plan would ensure that dust would not migrate in excess of standards to the nearest properties which are 0.5 miles away. The dust control measures would be based on Pima County standards and particulates in air would not exceed the 20% opacity standard at the source.

Measures taken to reduce dust emissions would also reduce the dust-borne transport of fungal spores that can cause Valley Fever.

Cumulative Impacts

Other sources of dust in the vicinity of the Andrada Quarry include livestock grazing, residential construction, and motor vehicle operation on and maintenance of unpaved roads.  Sources of greenhouse gases include livestock grazing and the burning of fossil fuels for heat and motor vehicle operation. Residential development is expected to increase in the area, temporarily increasing dust emissions during construction and permanently increasing greenhouse gas emissions as more fossil fuels are burned to support residential heating and increased vehicle use. The production of dust and greenhouse gases due to livestock grazing is expected to decline as residential development occurs on former grazing lands.

3.3           Issue 3: What are the visual impacts, including impacts to night skies, of the Proposed Action during operation and what would be the residual visual impact of the reclaimed mine?

3.3.1                 Affected Environment

The Andrada quarry is on the edge of the Tucson Basin in the bajada slopes below the north end of the Santa Rita Mountains. The quarry site is in a small drainage valley surrounded by rolling low hills and ridges covered by Sonoran desert scrub vegetation dotted by trees. The landscape in the vicinity of the quarry includes noticeable modifications from the Andrada quarry, the nearby Imerys quarry to the south, rural residential developments in the surrounding area, and roads and utilities. The existing surface disturbance caused by the Andrada quarry is noticeable and attracts attention due to the very light to white color of the exposed rock and subsoil material. The hill underlain by federal minerals provides visual screening of the existing quarry from views to the west.

According to the BLM Tucson Field Office visual resource inventory, the scenic quality on the bajada slopes is Class C, with few outstanding features, on the mountainous area it is Class B, with some outstanding features. The landscape around the quarry is viewed in the foreground-middle ground (within five miles) from rural residential areas and public roads including sections of State Highway 83, Sahuarita Road, and Wentworth Road. The quarry site is partly visible along the Arizona National Scenic trail from elevated locations three to five miles away in the vicinity of State Highway 83 and Davidson Canyon.

Because of the open character of the Tucson Basin and somewhat elevated location of the quarry, it is noticeable from background distances to the west and northwest, including parts of the City of Tucson and elevated viewing points on the west side of the basin over ten miles away and farther. Viewing volume is high, but visual sensitivity for the relatively flat rolling landscape on bajada slopes is considered relatively low. Because of the character of the landscape, relatively low scenic quality, viewing distance and relatively low visual sensitivity, the inventory visual resource values in the project area are Class IV for the bajada slopes and Class III for the mountainous area. Class IV inventory areas have relatively low visual resource value and can absorb landscape modifications without affecting visual resources. Class III inventory areas also have relatively low visual resource value, but landscape modifications could affect visual resources depending on the visual contrast of the modifications. There are no BLM visual resource management objectives established for the project area because BLM does not administer the surface.

Daytime Visibility

The Andrada Quarry contains many features from past mining activity including a pit, waste piles, and structures. Topography screens some of the past disturbances from offsite view points but much of it is visible from stretches of Sahuarita Road, Wentworth Road, and State Highway 83. The Andrada Quarry is visible from the Arizona National Scenic Trail, specifically in portions of the trail between Davidson Canyon and State Highway 83, in the “Las Cienegas Passage” of the trail.

3.3.2                 Impacts from the No Action

Direct and Indirect Impacts

Visual impacts from quarry operations would continue on Andrada’s private lands. Impacts from excavation and waste rock dumps would continue to be noticeable in the landscape, with strong visual contrast primarily caused by the very light to white disturbed surfaces. Night lights and illuminated surfaces would continue to be visible from the surrounding area. The hill underlain by federal minerals would continue to provide partial screening of the visual impacts from westerly views.

Cumulative Impacts

Continued Andrada Quarry operations on private land would contribute to growing visual impacts from landscape modifications caused by a foreseeable increase in residential and other development in the vicinity. Growing visual impacts would continue to affect existing viewing areas, including views from rural residences, public roads, and the Arizona National Scenic Trail. The hill underlain by federal minerals would continue to provide partial screening of visual impacts from landscape modifications on the private land.

Continuing mining activities at the Imerys Marble Quarry are visible from much of the same viewshed as the Andrada Quarry. For the duration of mining at the Andrada Quarry, an additive impact to visual contrasts visible from sections of the Arizona Trail and other locations is expected.

3.3.3                 Impacts from the Proposed Action

Direct and Indirect Impacts

The proposed quarry expansion would increase the size of the existing disturbed area, and result in excavation and eventual removal and leveling of the hill underlain by federal minerals. Visual impact of excavation of the hill would be most noticeable from foreground-middle ground views in the immediate vicinity. The visual impact of the existing disturbed area and proposed expansion would be primarily noticeable because of the strong visual contrast of the very light to white color of the exposed rock and subsoil on the excavated slopes, roads, flat working areas and waste rock dumps with the medium dark grays and greens of the adjacent undisturbed landscape. Visual impacts from potential glare of night lights and illuminated areas would also be noticeable. Removal of the hill would also remove a landform which provides partial screening of the quarry activity area on private land. During the hilltop removal of quarry operations, visual impacts on views from the Arizona national Scenic Trail would increase, but would remain relatively small in scale because of the viewing distance. As quarrying progresses and the hill is reduced in elevation, visual impacts on the Arizona National Scenic Trail would be reduced, with the rest of the quarry disturbance and night lights screened by intervening topography. Visibility of the disturbed areas and night lights would continue to be partly screened by local topography, and would be most exposed to views from the west northwest because of the relatively open character of the landscape and relatively elevated location of the quarry. Visual impacts on views from the south would be increased by removal of the hill, but would continue to be partly screened by intervening topography between the existing residential area and the quarry. Visual impacts of the quarry and expansion would be most noticeable and attract attention from the vicinity of the site.

Regrading and re-contouring for quarry reclamation at the end of quarry life would reduce the visual contrast with the character of the landform, but the strong visual contrast from the light to white color of regraded surfaces would remain. Revegetation for reclamation would partly screen the light to white ground surface, but the reclaimed area would continue to be noticeable for decades after reclamation due to the lighter color visible through the space between plants from revegetation.

No impacts to dark skies are expected from the quarry expansion as no expansion or relocation of the existing physical plant are proposed.

Mitigation:

Visual impacts of the quarry expansion during quarry operations could be reduced by continuing extraction operations on the hill from the east. This would orient the visual impact away from the off-site views. Visual impacts from the overall quarry could be reduced by darkening the color of the disturbed areas to reduce the strong visual contrast of the very light to white excavated surfaces. The color could be darkened using chemical treatment of the rock, or by covering the surface with darker soil, and to some extent by revegetation. The visual impact of night lighting could be reduced by implementing guidelines to comply with the Outdoor Lighting Code for The City of Tucson, Arizona and Pima County Arizona.

Residual Impacts

Strong visual contrast from the light to white color of regraded surfaces would remain. Revegetation for reclamation would partly screen the light to white ground surface, but the reclaimed area would continue to be noticeable for decades after reclamation due to the lighter color visible through the space between plants from revegetation.

Cumulative Impacts

Expanded Andrada quarry operations would contribute to growing visual impacts from landscape modifications caused by a foreseeable increase in residential and other development in the vicinity. Growing visual impacts would continue to affect existing viewing areas, including views from rural residences, public roads, and the Arizona National Scenic Trail. The hill underlain by federal minerals would continue to provide partial screening of visual impacts from landscape modifications on the private land.

Continuing mining activities at the Imerys Marble Quarry are visible from much of the same viewshed as the Andrada Quarry. For the duration of mining at the Andrada Quarry, an additive impact to visual contrasts visible from sections of the Arizona Trail and other locations is expected.

3.4           Issue 4: How would the Proposed Action impact traffic on Sahuarita and Wentworth Roads?

3.4.1                 Affected Environment

Current quarry traffic uses Wentworth Road to reach I-10 and Sahuarita Road to reach I-19. Quarry traffic varies based upon material sales from the quarry. Since 2014, the quarry has generated very little traffic as there have been no regular quarry operations. Prior to the cessation of regular quarry operations in 2014, truck traffic was in the range of 16 to 32 round trips per day.

3.4.2                 Impacts from the No Action

Direct and Indirect Impacts

Quarry traffic would continue to use Wentworth Road to I-10 and Sahuarita Road to I-19. The volume of traffic would vary based on material sales from the quarry. If regular quarry operations were to resume, truck traffic would be expected to rebound to 16-32 roundtrips per day.

Cumulative Impacts

Traffic along Wentworth Road is predominantly residential/commuter consisting of cars and light trucks. Additional large trucks carrying crushed stone would be a noticeable addition to this traffic. During the life of the quarry, increased urbanization is expected to result in more traffic on Wentworth Road which would be cumulative with the mine traffic.

Haul traffic from the Andrada Quarry and the proposed Rosemont Mine and proposed Davison Canyon Quarry would not commingle until the traffic reaches I-10. Although any commingling would represent a cumulative impact, as a percentage of overall traffic on I-10, the percentage of additional traffic would be low.

3.4.3                 Impacts from the Proposed Action

Direct and Indirect Impacts

Under the Proposed Action, truck traffic would increase by approximately 16 to 32 trucks per day totaling 32 to 64 round trips for trucks carrying mined products. A water truck would make 1-2 round trips per day. This increase in traffic would be in addition to traffic generated by any other source in the immediate vicinity. According to statistics reported in the Pima Association of Governments (PAG) Roadway Segment Traffic Counts, August 2, 2006, the average number of vehicles on Wentworth Road between I- 10 and Sahuarita Roads on May 2, 2006 was 1742. Under the Proposed Action, the Andrada Quarry traffic would represent an increase of 1.8 to 3.6% over the 2006 levels.

The increase in traffic would be greatest along Wentworth Road as haul trucks from the mine would use this road to access I-10. Along the stretch of road between the mine and the first intersection (E. Sahuarita Road), traffic would increase from 32 truck trips per day to 64 truck trips per day. Individuals who frequent Wentworth Road at the Sahuarita Road intersection would experience the greatest impacts due to quarry traffic. As overall traffic increases due to the influx of traffic from additional intersections, the impacts of quarry traffic would decrease as a percentage of overall traffic.

The water truck would use Sahuarita Road between Wentworth Road and Davidson Road, a distance of two miles, filling up at a hydrant located on Davidson Road just north of Sahuarita Road.

All loads entering public roadways would be covered in compliance with state law [A.R.S. 28-1098.A].

Cumulative Impacts

Traffic along Wentworth Road is predominantly residential/commuter consisting of cars and light trucks. Additional large trucks carrying crushed stone would be a noticeable addition to this traffic. During the life of the quarry, increased urbanization is expected to result in more traffic on Wentworth Road which would be cumulative with the mine traffic.

Proposed mining activities at the Davidson Canyon Quarry and at the proposed Rosemont mine are expected to add additional traffic to Highway 83 and also to Sahuarita Road. Haul traffic from the Andrada Quarry and the proposed Rosemont Mine and proposed Davison Canyon Quarry would not commingle until the traffic reaches I-10. Although any commingling would represent a cumulative impact, as a percentage of overall traffic on I-10, the percentage of additional traffic would be low.

3.5           Issue 5: How would the Proposed Action affect the generation of hazardous or solid wastes?

3.5.1                 Affected Environment

Diesel fuel and lubricants are the major hazardous materials found at the quarry. Fuel is stored within appropriate Occupational Safety and Health Administration (OSHA) approved storage tanks. Lubricants and oils are contained in similar tanks appropriately labeled for safety. Waste oil and other related fluids, oil rags, and used oil filters are collected and disposed of off-site. Minor servicing of equipment is done on-site in designated areas only; major repairs occur off-site as deemed appropriate. Controls are in place to prevent release of lubricant, fuels, and oils to the ground surface.

Only the materials identified above are onsite during normal operational and processing activities through use of the equipment and vehicles. None of these materials used in quarry operations meet the criteria for an acutely hazardous material/substance, as defined in 40 CFR §355, in amounts above threshold quantities. Waste rock products would consist chiefly of calcite, CaCO3.

Solid wastes are collected and disposed in accordance with applicable laws.

3.5.2                 Impacts from the No Action

Direct and Indirect Impacts

Solid and hazardous waste generation would remain unchanged from the current condition.

Business administrative functions would generate approximately one cubic yard of municipal waste per week; consisting of office and lunchroom waste. This waste would be removed by an approved waste hauling company and transferred to an approved municipal landfill. Portable restrooms would be provided and properly serviced.

Quarry material is processed by simple crushing. No chemical processes would be used in the mining or processing of the material, and no by-product would be formed or accumulated. Off-specification material would be returned to the quarry as reclamation fill.

Small quantities of hazardous waste would be held on-site until such time as they may be disposed in compliance with the Resource Conservation and Recovery Act. Hazardous waste that is expected to be generated would be limited to approximately twenty pounds per year of cleaning and maintenance chemicals. Waste tires and waste oil would be taken off site by a vehicle/equipment service company and disposed of through approved methods.

Cumulative Impacts

Waste production from the Andrada Quarry would be additive to waste streams generated by other activities in the area including construction and residential waste streams.

3.5.3                 Impacts from the Proposed Action

Direct and Indirect Impacts

Solid and hazardous waste generation would remain unchanged from the current condition and would be similar to the impacts of the No Action alternative.

Business administrative functions would generate approximately one cubic yard of municipal waste per week; consisting of office and lunchroom waste. This waste would be removed by an approved waste hauling company and transferred to an approved municipal landfill. Portable restrooms would be provided and properly serviced.

Quarry material is processed by simple crushing. No chemical processes would be used in the mining or processing of the material, and no by-product would be formed or accumulated. Off-specification material would be returned to the quarry as reclamation fill.

Small quantities of hazardous waste would be held on-site until such time as they may be disposed in compliance with the Resource Conservation and Recovery Act. Hazardous waste that is expected to be generated would be limited to approximately twenty pounds per year of cleaning and maintenance chemicals. Waste tires and waste oil would be taken off site by a vehicle/equipment service company and disposed of through approved methods.

Blasting would be conducted by a licensed contractor. No explosives material would be stored on site.

Cumulative Impacts

Waste production from the Andrada Quarry would be additive to waste streams generated by other activities in the area including construction and residential waste streams.

3.6           Issue 6: How would the Proposed Action affect the spread of noxious weeds and other invasive plant species and/or bullfrogs?

3.6.1                 Affected Environment

Executive Order 13112, requires Federal agencies whose actions may affect the status of invasive species to use relevant programs and authorities to: (i) prevent the introduction of invasive species; (ii) detect and respond rapidly to and control populations of such species in a cost-effective and environmentally sound manner; (iii) monitor invasive species populations accurately and reliably; (iv) provide for restoration of native species and habitat conditions in ecosystems that have been invaded; (v) conduct research on invasive species and develop technologies to prevent introduction and provide for environmentally sound control of invasive species; and (vi) promote public education on invasive species and the means to address them; and not authorize, fund, or carry out actions that it believes are likely to cause or promote the introduction or spread of invasive species.

Invasive and non-native weeds found regionally in the vicinity of the Andrada Quarry include Lehman’s Love Grass and Buffelgrass.

3.6.2                 Impacts from the No Action

Direct and Indirect Impacts

Ongoing quarry operations have the potential of infestation by noxious and invasive species through transport of plant material by humans and equipment and due to the prolonged exposure of disturbed soil.

Cumulative Impacts

Noxious and invasive weeds are spread through ground disturbing activities such as construction as well as livestock grazing and equestrian use. Quarrying activities would be additive disturbances potentially advancing the spread of noxious and invasive weeds.

3.6.3                 Impacts from the Proposed Action

Direct and Indirect Impacts

The project has the potential of infestation by noxious and invasive species through transport of plant material by humans and equipment and due to the prolonged exposure of disturbed soil. The proposed action would disturb previously undisturbed areas as well as disturb previously disturbed areas where natural reclamation has taken place.

The spread of weeds is a difficult process to control in any ground disturbing activity, particularly when the offsite equipment is frequently brought onsite such is the case of over-the-road haul trucks. Some establishment of weeds is expected despite the use of best management practices.

The segregation of onsite equipment (loaders/crushers) from offsite equipment (over-the-road haul trucks) can serve to minimize the spread of weed seed via mining operations. Concurrent reclamation of mined areas can aid the re-establishment of desirable native species. The reclamation plan calls for reseeding reclaimed areas using a BLM-approved seed mix. The re-establishment of native species would greatly reduce the ability of weed species to thrive in the reclaimed area.

Cumulative Impacts

Noxious and invasive weeds are spread through ground disturbing activities such as construction as well as livestock grazing and equestrian use. Quarrying activities would be additive disturbances potentially advancing the spread of noxious and invasive weeds.

3.7      Issue 7: How would the Proposed Action affect neighboring residential property values?

3.7.1     Affected Environment

The vicinity of the quarry is host to rural and suburban communities. The nearest commercial development is approximately three miles from the quarry in Corona de Tucson. The nearest industrial operation to the quarry is the Union Pacific railroad located 4.5 miles to the northeast. From year 2000 through 2010 the population of the 85641 zip code increased from 6,743 to 21,753 persons. The number of households over this period increased from 2,644 to 8,308 households (U.S. Bureau of the Census, Gazetteer Files for 2000 and 2010). According to the U.S. Census Bureau’s American Community Survey 2012-2016, the population residing in zip code area 85641 is estimated as 25,716 persons and the number of households is estimated at 9312 in 2016. This is the latest available data on population and number of households in the 85641 zip code area.

A literature review was conducted, researching how quarries affect adjacent residential property values. The following summarizes the literature:

“A properly developed and operated rock quarry operation should not have a significant effect, either positively or negatively, on the value of housing units adjacent to the quarry property” (Rabianski & Carn, 1987).

”Further, this effect can vary based on visibility of mining operations from the private residences, and presence of other mining-related “nuisance” activities, such as air pollution/dust; traffic and hazards related to the mining operations; and noise pollution and vibrations from blasting” (Rabianski & Carn, 1987).

“Based on . . . analysis of relevant data, proximity to aggregate mines is not a deterrent to development, does not cause diminution in value, and does not result in neighborhood characteristics that are incompatible with residential or other uses” (Willingham Associates, Inc. Valuation Experts, 2002).

Several studies also concluded that having open space or wooded lots between housing developments and a quarry have a positive impact on home values and mitigate any potential negative impacts of the quarry operations.

“Using a hedonic pricing model [a multi-variant model that accounts for amenities and detractions] one researcher found that a new gravel mine can affect nearby residential home values as much as 30 percent” (Erickcek, 2006).

Based on the literature review, the following analytical assumptions were made in order to assess the potential impacts of the Proposed Action and No Action Alternative on adjacent residential property values.

• The effect on home values is a function of distance from the mine and operations.
  • Since the mine and its operations have been in place before the residential development began, any effect on the value is embedded into the current home / property values. The renewal of the mining permit under the same terms and conditions would have no net effect on the property values.
  • Expansion of the mine and its operations could negatively affect property values, as it would effectively bring the mine and its operations closer to the residential properties.

Generally, any discounts attributable to such factors as mining or industrial development are factored into the original selling price of the property, especially when such factors are clearly evident. However, a change from no mining or industrial activity to a state of active operations may increase any original discount. The factors most likely to have a negative impact on property values are visibility, air quality, safety, noise and traffic.

The intermittent effects of blasting such as noise and shock vibration could affect potential home buyers. The effect on home values is a function of distance from the mine and operations. Expansion of the mine and its operations could negatively affect property values, as it would effectively bring the mine and its operations closer to the residential properties. Since the mine and its operations have been in place before residential development around the site began, any effect on the value is embedded into the current home / property values.

BLM compared the Fair Market Value (FMV) of homes near the Red Mountain Mine, an active quarry in Maricopa County, Arizona to those in the vicinity not located near an active mine. All of the homes in the comparison were built when the mine was in production and engaged in activities such as blasting and crushing. The homes range in price (or FMV) from $400K to $650K. Homes adjacent to the mine average $219.52 per square foot. Three other groups of homes, each one located adjacent to a golf course, were found to have an FMV at an average of $231.88, $177.16, and $183.61 per square foot (source www.zillow.com). These statistics show that the FMV of homes are dependent on many factors and the impact of a mine on home prices cannot be isolated from these other factors.

In the neighborhood directly adjacent to the Red Mountain property, the FMV of homes nearest the golf course were the highest at $231.88 per square foot. Those nearest the mine sold for $219.52 per square foot indicating that there may be a discount for homes nearest the mine. However, homes in the center of the subdivision (neither bordering the mine or the golf course) indicated they have an FMV of $183.25 per square foot. If there was a discount associated with proximity to the mine, homes near the center of the subdivision should not sell for less than those near the mine. On this basis we can conclude that the difference in the FMV of homes near the mine is less than the FMV of homes near the golf course because of the increase in value associated with proximity to a golf course and not a decrease caused by proximity to a mine.

3.7.2                 Impacts from the No Action

Direct and Indirect Impacts

Residential property values in the vicinity of the Andrada Quarry should already account for the existence and continued operation of the quarry. The intermittent nature of operations at the quarry would have negligible effects on local employment opportunities.

Cumulative Impacts

Residential property values are a function of many factors beyond the scope of this analysis including changing employment opportunities, interest rates, and availability of amenities. As discussed above, the operation of a quarry may impact local property values, however BLM was not able to quantify any effect in its analysis of a similar quarry in Maricopa County, AZ.

3.7.3                 Impacts from the Proposed Action

Direct and Indirect Impacts

Under the Proposed Action, active mining operations would be no closer to the nearest residential parcels than under the No Action Alternative.

The Proposed Action would result in a slight increase in local employment opportunities Five to six individuals would be employed at the mine and earn between $10.00 to $25.00 per hour. During operations, visual contrasts would increase temporarily as the quarry expansion area is developed, possibly temporarily suppressing home prices. Under the Proposed Action, Andrada would reclaim past mining disturbances such as scars and dumps of bright white rock that creates a visual contrast to the surrounding lands and possibly increase the value of the private property (and adjacent properties) over the long term. Reclamation would occur both concurrently with mining where feasible and at the end of mine life. BLM’s analysis of the Red Mountain Quarry discussed above did not find an effect of mining activities on adjacent residential prices.

Traffic in the area would increase due to the mine and the number of large trucks in the area would rise. Increased traffic, especially industrial type traffic is often seen as undesirable by potential home buyers.

Cumulative Impacts

Residential property values are a function of many factors beyond the scope of this analysis including changing employment opportunities, interest rates, and availability of amenities. As discussed above, the operation of a quarry may impact local property values, however BLM was not able to quantify any effect in its analysis of a similar quarry in Maricopa County, AZ

3.8      Issue 8: How would the Proposed Action affect blasting related effects including noise and potential damage to neighboring structures?

3.8.1     Affected Environment

Noise

Noise is generated during the course of normal operations from the crushing and screening plant, as well as from operation of the heavy equipment, predominately from back up alarms.

When explosives are used to break rock in a mine or construction project, the blast produces a change in air pressure, or overpressure, which is referred to as an airblast (noise). Air overpressure produced by blasting is expressed in pressure units called decibels (dB).

The following table gives the decibel levels produced by some typical situations:

Table 1: Produced Noise levels in dB from Selected activities

In order to protect nearby structures from blast-induced damage, a “safe” level of 134 dB is not exceeded. Seismic monitoring can be performed during a blast event to record air blast and vibration, to ensure the blasts are within accepted thresholds.

Vibration Effects of Blasting

The largest factor controlling structural damage is peak particle velocity. By containing the peak particle velocity to values below the safe blasting criterion, blasting should not place any further stresses on nearby structures than nominal cultural and natural stresses.

U.S. Bureau of Mines (USBM) has studied the effects of blast vibrations on structures extensively since the 1930s. According to these studies, safe levels of ground vibration from blasting range from 0.5 to 2.0 in/sec peak particle velocity for residential-type structures. Damage threshold values are a function of the frequency of the vibration transmitted into the residence and the type of construction. The USBM determined that for low frequency vibrations, limits of 0.50 inch per second and 0.75 inch per second apply with respect to plaster and modern drywall, respectively. These limits provide for a probability of better than 95 percent that the most superficial cosmetic cracking would not occur. The limits increase gradually to 2.00 inches per second as frequencies approach 40 hertz. Concrete block, masonry and concrete are much less susceptible to damage by short-term vibration effects. In general, an applicable limit for concrete block and masonry is in excess of 3.00 inches per second. Solid concrete can withstand vibration levels in excess of 10.00 inches per second (Siskind, et al., 1980).

3.8.2                 Impacts from the No Action

Direct and Indirect Impacts

Noise would be generated by quarry operations for the life of the quarry under the No Action Alternative.

Quarry operations would continue on Andrada Holdings’ private lands with accompanying noise associated with mining activities such as blasting, crushing, loading, and hauling of materials.

Cumulative Impacts

The cumulative effects analysis area for blasting is defined by an eight mile radius from the Andrada Quarry. This radius was selected to include the Imerys Santa Rita Quarry and the proposed Rosemont Copper Mine. On days with high humidity and low cloud cover, blasting noise from the Imerys Quarry may be heard in the vicinity of the Andrada Quarry cumulatively adding to mining noise in the area. The northern portion of the Imerys Santa Rita Quarry is located on a ridge top, allowing blast noise to carry toward the Andrada Quarry area. The proposed Rosemont Copper Mine would be located with topographic highs between the proposed mine and the Andrada Quarry area. It is not known if blasting noise from the proposed Rosemont Mine would reach receptors in the Andrada Quarry area.

3.8.3                 Impacts from the Proposed Action

Direct and Indirect Impacts

Noise would be generated by quarry operations for the life of the quarry under the Proposed Action. No more noise is expected to occur under the Proposed Action than would occur under the No Action alternative as operations which generate noise would be of the same type.

Crushing operations would produce noise during daylight hours. The noise would be dissipated by topography and the distance to the nearest homes.

Blasting would be conducted within legal limits of particle velocity and sound (decibel) levels for the protection of nearby structures and workers.

A blasting schedule would be developed with willing neighbors living within ½ mile of the quarry and pre- blast surveys would be conducted to mitigate the impacts of blasting. According to the Arizona State Mine Inspector, the customary practice is to conduct pre-blast inspections ¼ mile from the blasting site.

Although the Andrada Quarry plan of operations does not provide for a frequency of blasting, the purpose of developing a blasting schedule with the neighbors would be to establish a preferred time of day to lessen residential impacts. Blasting would occur as needed to loosen a sufficient volume of bedrock to provide feed for the crusher and the plant in Casa Grande. The feed produced by a single blast may last a week or several weeks. Blasting would therefore be intermittent and infrequent.

Cumulative Impacts

The cumulative effects analysis area for blasting is defined by an eight mile radius from the Andrada Quarry. This radius was selected to include the Imerys Santa Rita Quarry and the proposed Rosemont Copper Mine. On days with high humidity and low cloud cover, blasting noise from the Imerys Quarry may be heard in the vicinity of the Andrada Quarry cumulatively adding to mining noise in the area. The northern portion of the Imerys Santa Rita Quarry is located on a ridge top, allowing blast noise to carry toward the Andrada Quarry area. The proposed Rosemont Copper Mine would be located with topographic highs between the proposed mine and the Andrada Quarry area. It is not known if blasting noise from the proposed Rosemont Mine would reach receptors in the Andrada Quarry area.

3.9      Issue 9: How would the Proposed Action impact wildlife and threatened, endangered and sensitive species?

3.9.1     Affected Environment

Wildlife and threatened and endangered species occurrences in the vicinity of the Andrada Quarry are addressed in Biological Review, Andrada Quarry Expansion Project, (BLM 2015).

Threatened, Endangered and Sensitive Species: A search of the Arizona Game and Fish Department On- line Environmental Review Tool was conducted on March 23, 2015 (Project ID: HGIS-00883), Project Name: Expansion of Andrada Quarry, Review Date: 3/23/2015 02:49:33 PM). The search identified 12 species (Table 1) as having been documented within 5 miles of the project vicinity. No other threatened, endangered, and sensitive species occurrences were identified through this search, though Jaguar Critical Habitat, 10J area Zone 2 for Mexican gray wolf, Wildlife corridor and an Important Bird Area were identified.

Additionally, a U.S. Fish and Wildlife Service Information, Planning and Conservation System (IPaC) database report was generated on March 23, 2015. The report identifies 13 threatened, endangered or candidate species (Table 2) that could occur in or near the project area, along with a list of 36 migratory birds that could occupy the project vicinity.

3.9.2     Impacts from the No Action

Direct and Indirect Impacts

Impacts to wildlife, threatened, endangered and sensitive species from quarry operations on 22 acres of private lands would continue including truck and equipment traffic, dust generation, and noise. Existing quarry operations contribute to habitat fragmentation as quarry areas are mostly stripped of vegetation suitable for forage and cover and as wildlife avoids quarry activities and quarry noise

Cumulative Impacts

A five-mile radius area surrounding the proposed quarry expansion was selected as the cumulative effects analysis area for wildlife and threatened and endangered species. This area includes approximately 51,630 acres of State, Federal and private land (Figure 4). Within that 51,630 acres there are the following existing activities that may impact wildlife, threatened and endangered, and sensitive species:

• 6 medium to large scale rural/suburban residential developments;
• The I-10 corridor;
• State Route 83;
• Livestock grazing on State and Federal grazing allotments;
• Numerous dirt and gravel roads and trails.

Relative to wildlife and wildlife habitat, the analysis area currently represents a fragmented landscape with associated habitat connectivity and continuity problems. The relatively high level of human development within the project area results in direct habitat loss, functional loss of connectivity corridors, habitat fragmentation, noise, and dust, as well as ancillary impacts such as stray pets, off highway vehicle use, and increased vehicular ingress and egress to residential developments.

Given the land ownership pattern (private, Forest Service and Arizona State Lands Department), and the pattern of impacts across the landscape (Figure 4), it is reasonable to conclude that as urban Tucson expands, the private lands in the project vicinity would continue to be used and further developed for residential dwellings and associated infrastructure (roads, trails, power lines, etc.). Currently, approximately 12% of the surface in the 5-mile radius analysis area is developed (i.e. residential developments, roads, trails, quarry, etc.). Habitat for wildlife is essentially lost relative to these land uses. Existing quarry operations contribute to habitat fragmentation as quarry areas are mostly stripped of vegetation suitable for forage and cover and as wildlife avoids quarry activities and quarry noise.

3.9.3     Impacts from the Proposed Action

Direct and Indirect Impacts

Impacts to wildlife, threatened, endangered and sensitive species resources as a result of this quarry expansion include:

• Removal of vegetative production potential on 14 acres;
• During operating hours of 7:00 a.m. through 6:00 p.m., Monday through Friday, the following impacts can be expected:
  • Heavy truck and equipment traffic on quarry access roads
  • Dust generation as a result of road use, quarrying and crushing operations
  • Noise associated with quarry operations

Removal of vegetative production potential would reduce forage available to wildlife including mule deer, javelina, and gamble’s quail.

Increased traffic could have direct and indirect impacts on wildlife. Direct impacts include traffic caused mortality. Traffic caused mortality is expected to be higher for less mobile species such as Sonoran Desert Tortoise, Gila monsters and other reptiles. Traffic related mortality would be expected to a lesser

extent for species with greater mobility such as mule deer and javelina. Indirect impacts include a change in wildlife movements, activity patterns and site level wildlife diversity as a result of traffic noise and presence.

Proposed quarry operational hours are 7:00 am to 6:00 pm. This temporal limit would eliminate noise impacts to nocturnal wildlife species, and limit noise impacts to diurnal species. Species active during operational hours would be subject to noise impacts. Noise could influence wildlife movement patterns (both temporal and spatial), wildlife abundance and species diversity.

Lesser long-nosed bats, a BLM sensitive species, utilize agave and columnar cacti nectar as a food resource. Agaves occur in limited numbers on the proposed expansion area. No columnar cacti occur on the proposed quarry expansion area. Any agave that occurs within the proposed quarry expansion area would be destroyed, and the potential for agave production on the site would be eliminated until such time as the quarry is reclaimed (6-8 years from start of production). Because lesser long-nosed bats are a far ranging, mobile species, known to forage up to 30 miles from their roost sites, it is unlikely that the removal of a relatively small number of agave and the removal of the potential for agave production on a relatively small area (14 acres) would have impacts to lesser long nosed bats. The nearest known lesser long-nosed bats roost site is 5 miles or more from the project site. Impacts to foraging opportunities for this lesser long-nosed bats colony are not anticipated due to the distance of the colony from the project site and lesser long-nosed bats’ long range foraging capability.

Desert Tortoise habitat and foraging resources for lesser long-nosed bats would be disturbed under the Proposed Action. Twenty two acres of habitat have been disturbed by the existing quarry. Under the Proposed Action, fourteen more acres of habitat disturbance would occur than under the No Action Alternative.  The Proposed Action includes tortoise protection measures which would reduce the likelihood of tortoise encounters on roadways or within the operations areas and likely reduce harassment, injury, or mortality of tortoise encountered relative to the No Action Alternative where tortoise protection measures are not specified. Under the Proposed Action, tortoise protection measures would be apply to all operations on both private land and State Trust surface/federal minerals.

Cumulative Impacts

A five-mile radius area surrounding the proposed quarry expansion was selected as the cumulative effects analysis area for wildlife and threatened and endangered species. Cumulative impacts of the proposed action are similar to those discussed for the No Action Alternative in Section 3.9.2. The proposed expansion of the Andrada quarry represents an increase (12.04% to 12.07%) in developed acreage in the analysis area. The proposed quarry expansion adds to some of the existing impacts (particularly traffic, noise, dust), albeit for a relatively short duration (6-8 years), as compared to some of the residential impacts that would exist for decades and likely increase as urban Tucson expands. If reclamation is completed as planned, the proposed project would not add to long term impacts such as habitat loss and habitat fragmentation.

3.10 Issue 10: How would the Proposed Action affect livestock grazing?

3.10.1   Affected Environment

The project area encompasses two ecologic sites: Limestone Hills 12-16”p.z. and Volcanic Hills 12-16”

p.z. Loamy (NRCS 2015, available at the following URL:https://esis.sc.egov.usda.gov/ ). Common plant species in the project area include ocotillo, mesquite, mariola, catclaw, graythorn, desert broom, palo verde, and creosote bush (Jenkins 2004). A list of plants recorded during a biological reconnaissance of the proposed quarry expansion area on April 1, 2015 is included in Table 1. Climax plant communities on these sites are dominated by warm season grasses, as reflected by the vegetative production figures listed in Figures 1 and 2. Total annual biomass production on these sites can range from 430 lbs/acre to

1,360 lbs/acre. Lacking fire, and given potential influences of climate change, shrubs and invasive grasses can increase, and likely have increased on these sites.

The project area is currently grazed under a lease issued by the Arizona State Land Department.

3.10.2   Impacts from the No Action

Direct and Indirect Impacts

Under the No Action alternative, the area subject to the existing Arizona State Land Department grazing lease would not be altered by mining and grazing would be expected to continue subject to Arizona State Land Department policies.

Cumulative Impacts

A five-mile radius area surrounding the proposed quarry expansion was selected as the cumulative effects analysis area for livestock grazing. This area includes approximately 51,630 acres of State, Federal and private land (Figure 4). Within that 51,630 acres there are six medium to large scale rural/suburban residential developments.

Urbanization within the cumulative effects area results in permanent loss of lands available for grazing. Currently, approximately 12% of the surface in the 5-mile radius analysis area is developed (i.e. residential developments, roads, trails, quarry, etc).

3.10.3   Impacts from the Proposed Action

Direct and Indirect Impacts

Under the Proposed Action, 14.2 acres that are currently grazed would be unavailable for grazing for the duration of the mining operation. Post-mining reclamation is expected to return forage production to its pre-mining condition through contouring and re-seeding of mined areas.

Cumulative Impacts

A five-mile radius area surrounding the proposed quarry expansion was selected as the cumulative effects analysis area for livestock grazing. Cumulative impacts of the proposed action are similar to those discussed for the No Action Alternative in Section 3.10.2. The proposed expansion of the Andrada quarry represents an increase (12.04% to 12.07%) in developed acreage in the analysis area. The proposed quarry expansion temporarily removes acreage from grazing, as compared to some of the residential impacts that would exist for decades and likely increase as urbanization continues. If reclamation is completed as planned, the proposed project would not add to long term impacts such as forage loss.

4   

SUPPORTING INFORMATION

4.1                      Tribes, Individuals, Organizations, or Agencies Consulted

In May 2013, The Tohono O’Odham Nation and Gila River Indian Community were contacted concerning the proposed quarry expansion. The Gila River Indian Community response indicated a general opposition to mining and noted that the proposed quarry expansion project is within the ancestral homeland of the Four Southern Tribes (Gila River Indian Community; Salt River Pima-Maricopa Indian Community; Ak-Chin Indian Community and the Tohono O’Odham Nation). The Gila River Indian Community’s response also stated that they would defer to the Tohono O’Odham Nation as lead in the tribal consultation. The Tohono O’odham Nation elected not to provide comments on the project.

4.2                      List of Preparers

• William Auby, BLM New Mexico State Office, Geologist (formerly Tucson Field Office, Geologist )
• Daniel Moore, BLM Tucson Field Office, Geologist
• Keith Hughes, BLM Tucson Field Office, Natural Resources Specialist
• Karen Simms, BLM Tucson Field Office, Asst. Field Manager (retired)
• Amy Markstein, BLM Tucson Field Office, Planning and Environmental Coordinator
• Leslie Uhr, BLM Tucson Field Office, GIS Specialist
• Darrell Tersey, BLM Tucson Field Office, Natural Resources Specialist
• Ben Lomeli, BLM Tucson Field Office, Hydrologist (retired)
• Francisco Mendoza, BLM Tucson Field Office, Outdoor Recreation Planner
• Karen Conrath, BLM Arizona State Office, Geologist
• Nancy Favour, BLM Arizona State Office, Planning and Environmental Coordinator

4.3                      References

Arizona Department of Health Services, 2016, Office of Infectious Disease Services, Valley Fever 2016 Annual Report

GWP Consultants, 2008. Quarry Design Handbook, Principles of design for hard rock quarries. Accessed at http://www.gwp.uk.com/pdfs/Appendix%204-3%20Principles%20of%20design- hard%20rock%20quarries.pdf.

Heck, Jay Howard Sr., 2011. Effect of Blasting Air Overpressure on Residential Structures. Accessed 05/18/2015 at http://ezinearticles.com/?Effect-of-Blasting-Air-Overpressure-on-Residential- Strudtures&id=5754405.

Jenkins, P. 2004, Botanic survey of 25 acres west of Gamaco mines in the North ½ of Section 21, T17S, R16E. GSM. 2pp.

Siskind, D.E., Stagg, M.S., Kopp, J.W., and Dowding, C.H., 1980 in U.S. Bureau of Mines Report of Investigations 8507, Structure Response and Damage Produced by Ground Vibration From Surface Mine Blasting.

Pima County Comprehensive Land Use Plan (PCCLUP), Pima County, 2006

USDI BLM, 2015, Biological Review Andrada Quarry Expansion Project (DOI-BLM-AZ-G020-2013-0019- EA). 34pp.

USDI BlM, 1988, Phoenix Resource Management Plan and Environmental Impact Statement, December, 1988, Minerals Management, pg. 14.

USFS, 2013, Final Environmental Impact Statement for the Rosemont Copper Project A Proposed Mining Operation Coronado National Forest Pima County, Arizona

Van Devender, T. R., R. C. Averill-Murray, T. C. Esque, P. A. Holm, V. M. Dickinson, C. R. Schwalbe, E.

B. Wirt, and S. L .Barrett. 2002. Grasses, mallows, desert vine, and more. pp. 160-193 in Van Devender,

T. R (ed.). 2002. The Sonoran Desert Tortoise: Natural History, Biology, and Conservation. The University of Arizona Press and the Arizona-Sonora Desert Museum. Tucson, Arizona.

4.4             Figures

Figure 1. Project location, twenty five miles southeast of Tucson, AZ

Figure 2. Federal minerals included in Mine Plan of Operation

Figure 3. Andrada Quarry Operations Map