PLANNING AND HOUSING COMMISSION
STAFF REPORT
DATE: 10/8/2018
TO: Honorable Chair and Commissioners
FROM: Community Development Department
APPLICATION REQUEST:
Title
SMP2017-0101: Application made by All American Asphalt to amend an existing surface mine permit (SMP95-01) to: 1) extend the permit for a period of 100 years; 2) excavate to a depth of 400 feet above mean sea level (amsl) from 500 feet above mean sea level under the existing permit; 3) reconfigure the mining phases of the operation from three to five phases within the current footprint allowed by the existing surface mine permit; and 4) increase total reserves to 177 million tons from 112 million tons. The quarry is located at 1776 All American Way, generally south of Magnolia Avenue and east of Interstate 15 in the M-3/MR (Heavy Manufacturing/Mineral Resources Overlay) zone. (Applicant: All American Asphalt, 400 East Sixth Street, Corona, CA).
End
RECOMMENDED ACTION:
Recommended action
That the Planning and Housing Commission adopt the Subsequent Mitigated Negative Declaration and Mitigation Monitoring Plan and adopt Resolution No. 2518 GRANTING SMP2017-0101, based on the findings contained in the staff report and conditions of approval.
Body
PROJECT SITE SUMMARY
Area of Property: 263.2 acres within SMP boundary
Existing Zoning: M-3/MR overlay (Heavy Manufacturing with Mineral Resources overlay)
Existing General Plan: GI (General Industrial)
Existing Land Use: Quarry and Asphalt Batch Plant
Proposed Land Use: Same as existing land use
Surrounding Land Use:
N: M-3 zone (existing knoll as a natural buffer) with residential beyond in Home Gardens (unincorporated county area)
E: M-3/MR zone (undeveloped)
S: M-3/MR zone (existing Vulcan Quarry)
W: M-3 zone (Temescal Wash)
BACKGROUND
Mining on the property originated sometime in the 1930s; however, the permit history on the property started in 1979. The property and mining operation originated in the unincorporated area of Riverside County and in 1991 the property was annexed to the City of Corona. The city inherited the mining operation upon annexation and issued a city mining permit to replace the mining permit that was previously issued by Riverside County. Site topography ranges from an elevation of 1150 feet above mean sea level (amsl) along the eastern most area of the site down to an elevation of 665 feet amsl along the western portion of the site near the quarry’s entrance. Over the past several decades historical mining operations have altered the natural topography of the site. The table below summarized the permit history for All American Asphalt.
All American’s permit, SMP95-1, allows an inert debris engineered landfill in conjunction with the existing mining operation. The modification to the permit in 2002 allowed AAA to excavate to a depth of 500 feet above mean sea level (amsl). The current operation extracts mineral resources from the hillside mine using conventional surface mining methods (Exhibit A). After topsoil stripping, material is loosened within active mining areas using heavy equipment, and/or by drilling or blasting as needed to fracture rock. Material is then loaded and transported to the processing area by large capacity, off-road haul vehicles or by conveyor for crushing. Material is crushed, screened and conveyed to stockpiles based on material size. These materials may be further segregated into stockpiles for outside sales that facilitate loading into on-highway trucks for transport to customers.
On-site mining and processing operations, including equipment maintenance, drilling and processing, are permitted 24 hours a day if those operations are located more than 300 feet inside the outer boundary of the property. Otherwise, operations are confined to the hours between sunrise and sunset of any day. Transportation of materials via on-highway trucks to off-site locations occur 24 hours.
A negative declaration was adopted by Riverside County for the initial surface mine permit in 1979, and subsequent negative declarations were adopted by the County when the surface mine permit was amended. A mitigated negative declaration was approved by the Corona City Council in March 1991 when SMP90-1 was approved. The annexation of the existing surface mine and the operation of the facility was determined not to have significant impacts on the environment because the mitigation measures reduced potential environmental impacts to less than significant. A subsequent mitigated negative declaration was approved by the City Council in 1995 for a modification to the existing surface mining permit (SMP95-01) allowing an inert debris engineered landfill in conjunction with the mining operation and mining to a depth of 614 feet amsl. The permit was modified later in 2002 allowing mining to a depth of 500 feet amsl. The 2002 modification was exempt from CEQA review because the modification did not result in additional environmental impacts from the evaluation in the subsequent mitigated negative declaration that was approved in 1995.
The permit amendment also includes the review of Surface Mine Reclamation Plan (SMRP) 2018-0001 which covers the reclamation plan for the quarry and Development Agreement (DA) 2018-002 which establishes an extraction royalty that All American Asphalt would pay to the city for the mineral resources extracted from the site.
PROJECT DESCRIPTION
SMP2017-0101 is an amendment to existing surface mine permit SMP95-01 for All American Asphalt. The quarry operation is located at 1776 All American Way generally located south of Magnolia Avenue and east of Interstate 15. The quarry site was zoned M-3/MR, which means heavy manufacturing with mineral resources overlay. The MR overlay zone in combination with the M-3 zone permits certain uses not otherwise permitted in the underlying zone and restricts certain uses otherwise permitted in the underlying zone. The MR overlay zone provides supplemental development standards for surface mining and related activities. Additionally, the California Geological Survey published by the Department of Conservation shows the quarry located in the Temescal Valley Production Area for Portland Cement Concrete-Grade Aggregate region. The State Geologist has classified the site MRZ-2, which means significant mineral deposits are present or there is a high likelihood for their presence exists.
The permit amendment would extend the term of the permit for 100 years to allow All American Asphalt (hereafter referred to AAA) the ability to exhaust the mineral resources available within the project boundary, revise their operational phasing plan and excavate an additional 100 feet from 500 feet above mean sea level. The permit amendment will not expand beyond the existing footprint of the surface mine permit. Table 2 summarizes the existing surface mine permit and proposed amendment.
The gross acreage of the property is 321 acres, but only 263.2 acres is within the boundary of the existing surface mine permit. Approximately 190 acres of the 263.2 acres has been disturbed by quarry operations. AAA produces construction aggregate material for the Southern California region. Materials range from aggregate base to rip-rap. These products are used as the basic ingredient in concrete for the construction of highways, bridges, buildings, roof tiles, large diameter pipes, parking lots and other structures. AAA also has an on-site hot mix asphalt batch plant (HMA) that utilizes materials produced on the property, as well as recycled products. Because AAA uses recycled products as part of their production, the need to excavate organic aggregate from the site has slowed. This is the reason AAA is requesting to extend their surface mine permit 100 years. It is also worth mentioning the adjacent quarry operated by Vulcan Materials was granted an extension of time for 100 years in 2014. Vulcan’s surface mine permit will expire on June 4, 2114, or until the exhaustion of permitted reserves, whichever one occurs first.
Table 2
Existing SMP and SMP Amendment Comparison
|
Item |
Existing SMP |
SMP Amendment |
Change |
|
Term |
May 15, 2021 |
December 31, 2118 |
Additional 100 years |
|
SMP Boundary |
298 acres |
263 acres |
Corrected parcel boundaries to be more precise (less 35 acres) |
|
Total Resources Mined |
112 million tons |
177 million tons |
Reserves increased by 65 million tons |
|
Excavation Depth |
500’ above mean sea level |
400’ amsl |
Increase depth 100 feet |
|
Final Cut Slopes |
60-degree bench face with 10’ wide bench every 50 vertical feet |
80-degree bench face with 25’ wide bench every 50 vertical feet |
Steeper bench faces and wide, safer benches |
|
Operational Phases |
3 |
5 |
Revised phasing to include two additional phases for better operation and reclamation |
|
Operating Hours |
24 hours |
24 hours |
No change |
The annual rate of production allowed under the existing permit is up to 4 million tons per year. This annual production rate will continue to be carried forward with the permit amendment.
Mining and Operation
The permit amendment will not change the current operation or hours of operation at the quarry. Quarry operations include drilling, basting, processing of materials, and general maintenance. The quarry is allowed to operate 24 hours of day, but the existing permit limits drilling and processing to the hours between sunrise and sunset if quarry operations are located within 300 feet of the site’s outer perimeter. Quarry operations beyond that 300 feet inside the outer perimeter of the site are allowed outside the restricted hours of operation. However, quarry blasting is only allowed to occur between the hours of 12:00 p.m. to 5:00 p.m. and limited to the days Monday through Friday, except on holidays. The permit amendment will continue to carry forward the hours of operation stipulated for the quarry under the existing permit.
Mineral resources are extracted by using conventional surface mining methods. After the stripping of topsoil the material is loosened with heavy equipment, and/or by drilling and blasting as needed to fracture rock. The material is loaded and transported to the on-site processing plant by off-road haul vehicles or by conveyor for crushing. Material is crushed, screened and conveyed to stockpiles based on material size. From here, the material may be further segregated into stockpiles for outside sales that require loading into on-road trucks for transport to customers. In some cases, the aggregates are washed to meet specific product specifications. The transportation of materials via highway trucks to off-site locations are allowed 24 hours a day.
Mining Phases
The permit amendment will change the current phasing plan from three to five phases to better accommodate mining and reclamation activities. The following information describes the revised phasing plan and Exhibits F1 - F7 show the site plan for each phase.
Phase 1.
Complete mining within the existing mine footprint in a single phase. Mining would be
followed closely by reclamation of all final slope areas.
Phase 2.
Backfill mining pit with inert fill to an elevation of 580 amsl to accommodate the relocation
of the processing plant to this area. The backfilling of the pit will occur simultaneously
with mining operations in Phase 1.
Phase 3.
Relocate processing plant currently located in Phase 1 to the backfilled pad in Phase 2.
Mine mineral resources in the processing plant’s former location.
Phase 4.
Mine mineral resources in areas that once contained the quarry’s equipment storage and
administrative offices and backfill Phase 3 area.
Phase 5.
Complete backfill of all mined areas to an average elevation of 680 feet amsl and complete reclamation of all mined areas.
The existing phasing plan shows mining activity moving in a west to east direction (Exhibit E). The revised phasing plan will now show mining activity along the outer perimeters of the boundary to be all included in Phase One with the pit area expanding east. The revised phasing resembles a top-to-bottom sequence creating a bowl like appearance on the property. The quarry is currently allowed to mine to a depth of 500 feet amsl; however, the permit amendment is requesting to go down an additional 100 feet to a depth of 400 feet. The final cut benches along the perimeters would be established at 25-foot wide benches with 50-foot high walls. Phase 2 will begin to backfill the pit area with inert fill to an elevation of 580 feet amsl. This phase will run concurrently with Phase 1. The backfilled pit area is being prepared to accommodate the relocation of the processing plant currently located at the west end of the quarry. Phase 3 involves relocating the processing plant to the backfilled pit area created in Phase 2 to allow mining in the processing plant’s current location, which is part of Phase 4. Phase 5 is the final reclamation phase and involves the backfilling of the pit area to an average elevation of 680 feet amsl across the site.
ACCESS & CIRCULATION
Access to the AAA quarry is from All American Way via Magnolia Avenue. This intersection is controlled by a traffic signal that was paid by All American Asphalt as part of their traffic mitigation associated with their previous surface mine permit. A focused traffic study was prepared by LL&G Engineers (January 2018) for the permit amendment and took into consideration the extension of the permit for 100 years without any increase in the mining area acreage or operational intensity. The traffic report analyzed daily AM peak hour and PM peak hour conditions for existing 2017 and future Year 2040 buildout traffic conditions with the project. Peak hour and daily forecasts for the Year 2040 traffic conditions were projected by increasing existing traffic volumes by an annual growth rate based on the city’s General Plan Traffic Analysis. The focused traffic analysis showed the peak hour intersection capacity at Magnolia Avenue and All American Way currently operating at LOS A and will continue to operate at LOS A in Year 2040.
SPECIAL CODE REQUIREMENTS
Title 19 of the Corona Municipal Code (CMC) governs Surface Mines in the City and their reclamation for the protection of public health, safety and welfare in accordance with the State Surface Mining and Reclamation Act (SMARA) of 1975. SMARA is enforced by the State of California, Natural Resources Agency, Department of Conservation, Office of Mining and Reclamation. SMARA was passed by the California State Legislature in response to the loss of significant mineral resources due to urban expansion, the need for current information concerning the location and quantity of essential mineral deposits and to ensure adequate reclamation of mined lands.
Title 19 of the CMC establishes the purpose and general provisions for surface mining, permit processing and reclamation plan procedures, minimum site performance standards, annual inspections and financial security to be borne by the operator, and findings for permit approval. The quarry is inspected annually by staff in addition to AAA preparing an annual inspection report for the quarry. The annual inspection report and financial assurance is submitted annually to the Department of Conservation. AAA complies with both state regulations and local ordinances concerning the operation of the quarry.
ENVIRONMENTAL ANALYSIS
A mitigated negative declaration was approved by the Corona City Council in March 1991 when SMP90-1 was approved. A subsequent mitigated negative declaration was approved by the City Council in 1995 for a modification to the existing surface mining permit (SMP95-01) allowing an inert debris engineered landfill in conjunction with the mining operation and mining to a depth of 614 feet amsl. The permit was modified later in 2002 allowing mining to a depth of 500 feet amsl. The 2002 modification was exempt from CEQA review because the modification did not result in additional environmental impacts from the evaluation in the subsequent mitigated negative declaration that was approved
Once the environmental review process is complete for a project, the California Environmental Quality Act (CEQA) does not require further environmental review of a project unless changes that require additional discretionary approval are proposed for the project. If a proposed project change triggers further CEQA review, the lead agency must determine whether those changes necessitate a subsequent, supplemental or addendum to the previously approved EIR or negative declaration. A subsequent or supplemental EIR or negative declaration is required only where it is necessary to explore the environmental ramifications of a substantial change not considered in the original environmental document (CEQA § 21166; CEQA Guidelines §§15162 and 15163).
The City of Corona has determined that a subsequent Mitigated Negative Declaration should be prepared for the proposed project (Exhibit H). CEQA Guidelines § 15162 (a)(2) states that when a negative declaration has been adopted for a project, no subsequent negative declaration shall be prepared for that project unless the lead agency determined, on the basis of substantial evidence in the light of the whole record, substantial changes occur with respect to the circumstances under which the project is undertaken which will require major revisions of the previous negative declaration due to involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects. The project proponent proposes some variations to the previously approved project that involves mining to a depth of 400 feet amsl from 500 feet amsl. This change in itself required additional mitigation measures to protect groundwater resources. The City of Corona has determined that this subsequent mitigated negative declaration is appropriate and in compliance with CEQA.
The subsequent MND (SCH# 2018081065) was submitted to the State Clearinghouse on August 23, 2018. The 30-day review and comment period for state and regional agencies closed on September 25, 2018. Since the close of the public comment period and as of the preparation of this staff report, the city received one comment letter from South Coast AQMD. The comment had to do with the future relocation of the processing plant and analysis according to Rule 1401. The subsequent mitigated negative declaration was revised to include discussion on the application of Rule 1401 in the final document.
FISCAL IMPACT
The associated Development Agreement 2018-002 will establish an annual extraction royalty that will be paid by All American Asphalt to the city. The extraction royalty will remain in effect for as long as active surface mining is being done on the property. The city will be paid a royalty of $0.05 per ton of Portland cement concrete - grade aggregate material (PCC Material) extracted from the site, and a royalty of $0.03 per ton of material not suitable for Portland cement concrete use (Non-PCC Material), including without limitation overburden, other waste rock, or topsoil, extracted from the site. The extraction royalty would provide a positive revenue source to the General Fund.
The permit extension also benefits the existing Operating Covenant Agreement (last amended December 2015) between AAA and the City of Corona. The Operating Covenant Agreement allows California sales tax to be shared between AAA and the city as a means of providing an incentive to ensure that AAA maintains and expands its existing asphalt and concrete sales facilities in the City of Corona. The operating covenant agreement requires the city to make covenant payments equal to the sum of 25% of sales tax revenue attributable to AAA’s taxable sales that exceed $500,000 and covenant payments equal to 50% of AAA’s taxable sales if sales tax revenue exceeds $1,000,000. If AAA’s taxable sales are less than $500,000 in a year, the city is not obligated to make covenant payments and the city is not obligated to make covenant payments on the first $250,000 of taxable sales each year. Although the sales tax revenue is essentially shared between the city and AAA after a certain threshold, the city does benefit from the sales revenue from material sold outside Corona.
PUBLIC NOTICE AND COMMENTS
The notice of public hearing was published on September 19, 2018, in the Sentinel Weekly News newspaper, posted on the city’s website, and mailers were distributed to properties within a 500-foot radius of the project site. As of the preparation of this staff report, one resident in the nearby neighborhood of Home Gardens inquired about the scope of work and if the boundary of the mining operation was going to be closer to the houses. Staff explained there are no changes to the mining boundary and as the mining operation moves east the buffer expands and moves farther away from the residents.
STAFF ANALYSIS
Existing Condition
The All American Asphalt quarry is an existing surface mine operation and inert debris landfill. The permit amendment is not establishing a new use on the property nor is the amendment expanding the operation beyond the boundaries of the current surface mine permit. AAA operates within the scope of all approved permits, including regulatory permits issued by state and regional agencies.
All American Asphalt is adjacent to the Corona Quarry operated by Vulcan Materials and beyond is the 3M quarry. The mines in this area are closely located because of the mineral resources that exist in the area and the land classification of MRZ-2 issued by the State Geologist at the State Department of Conservation. The quarry operation is not uncommon in this area as the property has been used as such for several decades. The permit amendment will allow AAA to continue their mining operation until available mineral resources are exhausted from the area, which has slowed down due AAA accepting and using recycled building materials from construction sites. The aggregates extracted from the site are used to build highways, bridges, concrete pipelines for necessary infrastructure, buildings, and roads in the Southern California region.
The site is properly zoned for mining by the M-3/MR zone and underlying General Plan designation of General Industrial. The General Industrial designation defined by the General Plan is to accommodate a wide range of manufacturing, construction, transportation, wholesale trade, and related service activities. Mineral resource mining activities are also included in this category. The permit amendment also continues to be consistent with several of the city’s General Plan’s goals and policies specifically intended for surface mines described in the below findings for SMP2017-0101.
Economic Benefit
AAA is a privately-owned family operated business. The below tables are from the City’s adopted budget for Fiscal Year 2018-19, which shows AAA as one of the top 10 employers in the city by providing 842 jobs and one of the top 25 sales tax producers. The source of the information was provided by Hinderliter, deLlamas & Associates, commonly known as HDL.
|
TOP 10 LARGEST EMPLOYERS, 2017 |
|
Employer |
Sector |
# Jobs |
|
Corona Norco Unified School District |
Education |
5,098 |
|
Corona Regional Medical Center |
Health Services |
1,113 |
|
Kaiser Permanente |
Health Services |
995 |
|
All American Asphalt |
Construction |
842 |
|
City of Corona |
Government |
749 |
|
Fender USA |
Manufacturing |
600 |
|
TWR Framing Enterprises |
Construction |
600 |
|
Monster Energy |
Distribution |
544 |
|
CoreMark International |
Manufacturing |
421 |
|
Dart Container |
Manufacturing |
420 |
Source: City of Corona Adopted Budget FY2018-19 & HDL Associates
|
TOP 25 SALES TAX PRODUCERS, 2017 |
|
Alphabetical Order, FY2016-17 |
|
Agile Sourcing Partners |
Home Depot |
|
All American Asphalt |
Honda Cars of Corona |
|
American Electric Supply |
Kohl’s |
|
Anixter |
Larry H. Miller Toyota |
|
Best Buy |
Pro Parts |
|
Cardinale Way Volkswagon, Hyundai and Mazda |
Robertsons Ready Mix |
|
Chevron |
Ross |
|
Costco |
Sam’s Club |
|
Culver Newlin |
Stater Brothers |
|
Downs Commercial Fueling |
Target |
|
Ganahl Lumber |
Vulcan Materials |
|
Guest Supply |
Walmart |
|
Hansen Beverage |
|
Source: City of Corona Adopted Budget FY2018-19 & HDL Associates
FINDINGS OF APPROVAL FOR SMP2017-0101
1. Pursuant to CEQA Guidelines § 15162 (a)(2), the City prepared a subsequent Mitigated Negative Declaration from the 1991 and 1995 Mitigated Negative Declarations approved for All American Asphalt’s surface mine permit and permit amendment. SMP2017-0101 proposed variations to the previously approved project that required additional mitigation measures not originally discussed in the previous environmental analysis. The City has determined the subsequent mitigated negative declaration is appropriate for the permit amendment and in compliance with CEQA.
2. The proposed surface mining operations will not be detrimental to the public health, safety or general welfare and will be in harmony with various elements and objects in the city’s General Plan for the following reasons:
a. The proposal promotes General Plan Goal 10.13 to ensure that the process and manner of locating and extracting mineral resources in the City and Planning Area occurs in a non-impactive manner as the revised plan implements a superior mining and phasing plan that facilitates sequential reclamation.
b. The proposal implements General Plan Policy 10.13.2, as the project is required to maintain compliance with SMARA (Surface Mining and Reclamation Act).
c. The proposal implements General Plan Goal 10.15 as it honors surface mining permits and reclamation plans that were issued by the Riverside County for sites that are annexed into the City of Corona.
d. The proposal promotes General Plan Goal 10.16 to recognize and protect valuable mineral resources in a manner that does not create land use conflicts.
e. The General Industrial designation accommodates a wide range of manufacturing, construction, transportation, wholesale trade, and related service activities. Mineral resource mining activities are also included in this category.
3. The surface mining operations will be located in a zone in which such operations are a permitted use.
a. The subject site is zoned M-3/MR (Heavy Manufacturing w/Mineral Resources overlay). The MR overlay designates properties in the city that contain mineral resources suitable for extraction based on the California Geological Survey published by the Department of Conservation. The AAA quarry is located in the Temescal Valley Production Area for Portland Cement Concrete-Grade Aggregate region and is classified MRZ-2 by the State Geologist, which means significant mineral deposits are present or there is a high likelihood for their presence exists.
4. The site for the surface mining operations is adequate in size and shape to accommodate those operations and the intended reclamation of the mined lands.
a. The subject site is an existing quarry situated in a mountainous area and consists of 321 acres of which 229 acres are proposed to be mined with all quarry operations being maintained on-site.
5. The site for the surface mining operations relates properly to streets and highways that are designed to carry the type and quality of traffic that will be generated by those operations.
a. The project site is accessible from a local/private street (All American Way) that has direct access from Magnolia Avenue and will continue to be the quarry’s primary distribution road. Additionally, the quarry is in close vicinity to the State Route 91/ Interstate 15 interchange thereby facilitating distribution to the surrounding regions and minimizing impacts to the City’s surface streets.
6. The surface mining operations will not pose a threat to the city’s groundwater resources or have any adverse impact upon the city’s ability to utilize those resources.
a. SMP2017-0101 will allow mining down to an elevation of 400 feet above mean sea level, and the conditions of approval for the permit amendment require the operator of the quarry to implement the mitigation measures in the subsequent mitigated negative declaration for groundwater monitoring and sampling in accordance with requirements imposed by the Corona Department of Water Power General Manager. The mitigation measures for groundwater resources in the subsequent MND indicate the mining operation will not be detrimental to the quality or quantity of the City’s groundwater.
7. The reclamation plan submitted by the applicant is sufficient in all respects to prevent or mitigate any adverse effects on the environment caused by the mining operations and gives adequate consideration to values relating to groundwater supply, recreation, watershed, wildlife, range and forage and aesthetic enjoyment.
a. The reclamation plan discussed in SMRP2018-001 is done in accordance with the Surface Mining and Reclamation Act and provides for the re-vegetation of the benched slopes with plant species which are native to the region and will thereby mitigate long term impacts of the mining operation. Furthermore, the operator has paid and will be paying the balance of all mitigation fees for the mitigation of the Stephen’s Kangaroo Rat Habitat Management and Monitoring Plan for Riverside County Habitat Conservation Agency Lands in the Lake Mathews and Steel Peak Reserves.
8. The reclamation plan will adequately provide for the protection and subsequent beneficial use of the mined lands because:
a. The project site will be reclaimed and restored to a condition that is compatible with, and blends with, the surrounding natural environment, topography and other resources as the plan provides for the re-vegetation of the benched slopes with plant species which are native to the region.
9. The reclamation plan complies with Surface Mining and Reclamation Act and the state regulations because:
a. The reclamation plan for the site has been prepared in accordance with the guidelines of the Department of Mining and Reclamation. Annual inspections of the mining operation will continue to be held in accordance with SMARA to ensure that the reclamation plan is being adhered to and reclamation is occurring sequential with the completion of the respective mine phases.
PREPARED AND SUBMITTED BY: JOANNE COLETTA, COMMUNITY DEVELOPMENT DIRECTOR
EXHIBITS
1. Resolution No. 2518.
2. Locational.
3. Exhibit A - Site Plan
4. Exhibits B1-B3 - Conditions of Approval SMP2017-0101, Conditions of Approval for SMP90-01 and Conditions of Approval for SMP95-01.
5. Exhibit C - Property Zoning.
6. Exhibit D - Property General Plan.
7. Exhibit E - Existing Mining Phases.
8. Exhibit F1-F7 - Proposed Mining Phases.
9. Exhibit G1-G4- Revised Phasing Cross Sections.
10. Exhibit H - Environmental Documentation.