ARCHIVED REPORTS_DRAFT ENVIRONMENTAL IMPACT REPORT

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location could avoid the significant effect. Therefore, it is valid to determine if feasible alternative locations may exist in the area. The State CEQA Guidelines Section 15126.6(f) (2)(B) indicates that"if the lead agency concludes that no feasible alternative locations exist,it must disclose the reasons for this conclusion."If feasible alternative locations do not exist,the EIR analysis need not continue to consider the issue of an off-site alternative. As discussed in Section 7.1,"Alternatives Approach"above,the existing WQCF and wastewater collection system constitute a large-scale wastewater collection,treatment, and disposal system,representing a substantial public investment. The WQCF is located on 210 acres of land surrounded by rapid urbanization, and is located at the terminus of several trunk sewers that convey sewage from all areas of the city. This substantial public investment (represented by existing facilities),the urbanizing nature of the area, and the location of wastewater conveyance and effluent outfall pipelines all serve to limit feasible alternatives. In addition,the construction of off-site wastewater collection and treatment pipelines and facilities, in addition to being impractical, could result in significant environmental impacts to biological, cultural and other resources. Therefore, an off-site location for the plant is not feasible. Given the impracticality,high costs, and likely additional environmental impacts,this alternative was rejected from further consideration. 7.4.2 SITE REORIENTATION ALTERNATIVE Implementation of the proposed project would result in the construction of a secondary effluent equalization pond,tertiary disinfection facilities, anaerobic digesters, secondary clarifiers, and aeration basins at the WQCF site(Figure 3-6). These new facilities would expand the footprint of the existing WQCF site and result in the conversion of approximately 14 acres of Important Farmland to nonagricultural use. This impact would be significant and unavoidable. To avoid this significant and unavoidable impact,the Site Reorientation Alternative would alter the design of the proposed project such that new construction would not require the conversion of Important Farmland to a nonagricultural use. However,the WQCF site is completely surrounded by Important Farmland(Exhibit 4.1-1), and it would not be practical to locate these facilities elsewhere. The WQCF and wastewater collection system constitute a large-scale wastewater collection,treatment,and disposal system, representing a substantial public investment. The WQCF is surrounded by rapid urbanization, and is located at the terminus of several trunk sewers that convey sewage from all areas of the city. This substantial public investment (represented by existing facilities),the urbanizing nature of the area, and the location of wastewater conveyance and effluent outfall pipelines all serve to limit feasible design alternatives at the WQCF site. Therefore, an alternative WQCF site design alternative is not feasible, and this alternative was rejected from further consideration. 7.4.3 OFFSETS ALTERNATIVE The Offsets Alternative is the same as the proposed project except that it also involves the use of offsets to reduce the amount of mercury that enters the San Joaquin River. The use of offsets involves reducing another mercury source in the San Joaquin watershed, along with earning of credits for pollutant reductions. This alternative was considered because the San Joaquin River is Section 303(d)listed for mercury.Waterways that are Section 303(d) listed are not expected to meet the water quality standards for particular constituents using technology-based controls alone. The City is studying the feasibility of using offsets,but there is substantial uncertainty in the regulatory environment, a number of liability issues, lack of an institutional framework, and uncertainty about the sources of mercury and the effectiveness of this approach. Importantly,the project would not result in any significant mercury impacts. For the reasons stated above,this alternative is neither necessary nor feasible, and has been eliminated from detailed consideration. Manteca WQCF and Collection System Master Plans EIR EDAW City of Manteca 7-13 Alternatives to the Proposed Project