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5.0 FINDINGS REGARDING CONSIDERATIONS THAT MAKE ALTERNATIVES ANALYZED IN EIR INFEASIBLE Based on the entire record, the County finds that the EIR identified and considered a reasonable range of feasible alternatives to the proposed project which are capable, to varying degrees, of reducing identified impacts.The EIR evaluated three alternatives in accordance with the CEQA Guidelines,including: Alternative 1: No Project Alternative Alternative 2: Reduced Development Alternative 3: Modernization Only 5.1 NO PROJECT Under this alternative, no expansion or modernization of the existing UP Intermodal Facility would occur.No changes to the site would take place and no adjacent acreage would be used for cargo lift operations or container storage. 5.1.1 Environmental Effects Under the No Project alternative, no additional farmland would be converted, existing aesthetic conditions would remain unchanged,no potential impacts to sensitive species or wetlands would occur,there would be no potential for the discovery of unknown archaeological or paleontological resources as no new site areas would be disturbed during construction, no changes to the ground surface would occur,there would be no increased risk of potential releases of hazardous materials,or the potential to disturb areas containing such materials, no changes in surface water runoff would occur, no changes in public service demands (fire, police, medical) would result and demands for water and wastewater services would not change. Similarly, no increase traffic trips would occur as a result of project expansion. At the same time,without an increased loading ramp constructed by the project,most incoming and outgoing intermodal trains could not be handled in one section. Most trains would have to be broken down and handled in two to three sections to fit on the existing working tracks, requiring multiple switching moves across Roth Road. In addition, one intermodal train can transport the same amount of cargo as 280 trucks. If the cargo containers originally assumed for the proposed project were instead shipped by truck (vs.rail),truck traffic within the region could significantly increase with the No Project Alternative as compared to the proposed project. Construction-related and operations-related air emissions would not increase with the No Project alternative. At the same time,without an increased loading ramp constructed by the project,most incoming and outgoing intermodal trains could not be handled in one section.Most trains would have to be broken down and handled in two to three sections to fit on the existing working tracks,requiring multiple movements of yard equipment and switchers within the yard and across Roth Road, generating continued, increased emissions of VOC and NOx and GHG per intermodal train as compared to such emissions per train with the project Also, the current facility would continue operating without being required to implement, or implement as quickly Mitigation Measures AIR 2a (switch locomotives to Tier Zero Plus emissions levels by 2021), 2b (anti-idling), 2c (AGS), 2d (CARB diesel) and 2e (electrification of TRUs) to reduce operational VOC and NOx at the facility. It should also be noted that with the No Project Alternative, overall regional emissions with truck traffic may be increased because if the cargo containers originally assumed for the project were shipped by truck (vs. rail), the diesel emissions, including VOC and NOx, and GHG associated with trucks within the region would significantly increase. Findings of Fact/ 30 November 2012 Statement of Overriding Considerations