Introduction
This Initial Study evaluates the environmental consequences of the project as proposed and the reasonably foreseeable related scenarios identified in Section 3.0 (Approach to Defining the Scope of Analysis). While SCE has specifically proposed to sell its 56% share of the MGS, to be conservative in terms of potential for environmental change, this Initial Study assumes that 100% of the MGS will be sold. The Initial Study also evaluates impacts associated with construction of the 500 feet of fence that may be constructed as part of the sale to separate the switching yard from the rest of the plant.

In terms of reasonable foreseeable operations after sale of the plant, this Initial Study examines two scenarios: (1) continued existing level of operations and (2) up to a 10% increase in the level of operations. Actual operation may fall between these two scenarios, but an examination of both scenarios will capture the projected range of operations expected upon sale. For ease of review, each topical section considers separately the impacts associated with the sale of the plant; the construction of the fence; continued existing levels of operations; and up to a 10% increase in levels of operations. However, the document evaluates and considers the totality of impacts that would result from either (a) sale of the plant and fence construction, plus continued existing operations or (b) sale of the plant and fence construction, plus up to a 10% increase in the level of operations. The boxes checked at the beginning of each section indicate the maximum level of impact that would be reached by either of these two scenarios.

AESTHETICS

Would the Proposal have:	Potentially Significant Impact	Less-Than-Significant With Mitigation Incorporated	Less-Than-Significant Impact	No Impact
a) Have a substantial adverse effect on a scenic vista?	.	.	.	X
b) Substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway?	.	.	.	X
c) Substantially degrade the existing visual character or quality of the site and its surroundings?	.	.	.	X
d) Create a new source of substantial light or glare, which would adversely affect day or nighttime views in the area?	.	.	X	.

ENVIRONMENTAL SETTING
The visual character for the region is dominated by desert terrain, with the Newberry Mountains in the background to the west and north and the Colorado River and the town of Laughlin to the east, west, and south. The overall visual character to the north of the site reflects undeveloped desert landscape. Development characterizes the landscape to the west, east, and south. The area immediately to the west is developed residential areas. Casino Drive parallels the southern portion of the site, with views of a golf course, open space, and Colorado River to the south. Directly adjacent to the eastern border of the site is Casino Drive and the downtown portion of Laughlin, with the Colorado River in the background.

The Bureau of Land Management (BLM) manages visual resources on BLM lands through the Visual Resources Management (VRM) Program. The VRM program sets objectives for retaining the quality of the visual environment and reducing the visual impact of development activities. Scenic areas that warrant protection through special management attention are also identified. There are five possible VRM classes—I through V (Table 4.1-1)—where Class I represents the most highly valued, pristine landscape, and Classes II through V represent, in descending order, natural landscapes that have either been modified or lack distinguishable features to the extent of needing rehabilitation. The VRM classes are used as a guide by the BLM in deter-mining the degree of compatibility between the landscape and the proposed develop-ment. BLM lands surrounding the facility have a VRM class rating of III (BLM 1998).

Certain landscapes are considered more sensitive to visual change than others due to their visibility from sensitive receptors. Typically, receptors considered most sensitive to visual change include scenic roadways and view corridors, local residents, and recreation areas. The landscape of the MGS is dominated by the industrial area and the evaporation ponds. The tallest features are the smokestack and boilers. Scenic corridors are considered sensitive because large numbers of individuals use these routes, which have been identified, as areas of outstanding scenic quality. Local residents are considered sensitive due to the duration of their exposure to change, their familiarity with the existing landscape, and their ability to detect change. The viewing corridors around the facility are not of outstanding quality, because of the plant itself and the lack of other unique features. Recreation areas are considered sensitive because scenic quality generally carries importance for recreational users enjoying activities such as bicycling, boating, and picnicking. There are recreational facilities around the plant, but activities are not centered around scenic views or vistas. Recreation is focused on sports, such as softball, or indoors, such as the community center. Landscapes classified as VRM I or II by the BLM are considered sensitive to visual change due to their unique or outstanding scenic quality.

Table 4.1-1: BLM VRM Classes

Class I: This class provides primarily for natural ecological changes; however, it does not preclude very limited management activity. Any contrast created within the characteristic environment must not attract attention. It is applied to wilderness areas, some natural areas, wild portions of the Wild and Scenic Rivers, and other similar situations where management activities are to be restricted.
Class II: Changes in any of the basic elements (form, line, color, texture) caused by a management activity should not be evident in the characteristic landscape. A contrast may be seen but should not attract attention.
Class III: Contrasts to the basic elements (form, line, color, texture) caused by a management activity may be evident and begin to attract attention in the characteristic landscape. However, the changes should remain subordinate to the existing characteristic landscape.
Class IV: Contrasts may attract attention and be a dominant feature of the landscape in terms of scale; however, the change should repeat the basic elements (form, line, color, texture) inherent in the characteristic landscape.
Class V: Change is needed or change may add acceptable visual variety to an area. This class applies to areas where the naturalistic character has been disturbed to a point where rehabilitation is needed to bring it back into character with the surrounding landscape. This class would apply to areas identified in the scenic evaluation where the quality class has been reduced because of unacceptable cultural modification. The contrast is inharmonious with the characteristic landscape. It should be considered an interim or short-term classification until one of the other VRM class objectives can be reached through rehabilitation or enhancement.

ENVIRONMENTAL IMPACTS
Sale of the MGS
a), b), c), d) The sale of the facility itself would result in a change of ownership and would not result in any physical changes except as discussed below. The sale of the MGS would not result in physical changes and would therefore not result in visual impacts.

Construction of 500 feet of Fence
a), b), c), d) The fence would connect two portions of an existing fence within an industrial facility and would be located between the existing switchyard and the plant facilities. The construction of 500 feet of fence to divide the switching yard from the generating facility would not affect the aesthetics of the area because of the existing industrial nature of the MGS, the facility’s remoteness, and the fact that the fence would not be visible outside of the plant area. No scenic vistas would be affected, and the fence would not be visible from any highway. The facility is an industrial complex, and the addition of internal structures, such as fences, would not fundamentally alter the facility’s visual character. The fence would not introduce any light or glare into the area.

Continued Existing Operations
a), b), c), d) Continuation of existing operations would not result in new impacts to the visual resources of the area because there would be no physical or other visible operational changes to the facility.

Increase Plant Output by Approximately 10%
a) Increased plant output would not be expected to result in significant physical changes that would affect surrounding scenic vistas.

b) Increased plant output would not be expected to result in significant physical changes that would be noticeable from area highways. No scenic resources would be affected.

c) The visual character of the facility is industrial, and up to 10% increased output emissions would not cause substantial impacts to the visual character or quality of the site.

d) Increasing plant output may require the installation of new equipment and associated lighting, within the industrial complex of the MGS. The facility currently has night lighting; additional lights would not substantially increase the facility’s visibility at night.

MITIGATION MEASURES
None required.

AGRICULTURAL RESOURCES

In determining whether impacts to agricultural resources are significant environmental effects, lead agencies may refer to the California Agricultural Land Evaluation and Site Assessment Model (1997) prepared by the California Dept. of Conservation as an optional model to use in assessing impacts on agriculture and farmland.

Would the project have:	Potentially Significant Impact	Less-Than-Significant With Mitigation Incorporated	Less-Than-Significant Impact	No Impact
a) Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use?	.	.	.	X
b) Conflict with existing zoning for agricultural use, or a Williamson Act contract?	.	.	.	X
c) Involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland, to non-agricultural use?	.	.	.	X

ENVIRONMENTAL SETTING
Agricultural Use
There is no agricultural use on the site or surrounding lands. The land is not considered to be prime or unique farmland. The Laughlin Land Use and Development Plan has no agricultural zoning districts or designated agricultural use areas within the Laughlin area (Clark County Department of Comprehensive Planning 1993).

Grazing
The BLM manages grazing activities on BLM public lands. The grazing range in the area surrounding the facility is designated as ephemeral (annual). Ephemeral ranges lie within the general southwest desert region extending primarily into southern Arizona, southern California, and southern Nevada, an area that includes portions of the Mojave, Sonoran, and Chihuahuan deserts. The region is characterized by desert-type vegetation, some of which may be classed as ephemeral only. Ephemeral range does not consistently produce forage, but periodically provides annual vegetation suitable for livestock grazing. In years of abundant moisture and other favorable climatic conditions, a large amount of forage may be produced. Favorable years are unpredictable and the season is usually short-lived. Ephemeral areas fall generally below the 3,200-foot contour and below the 8-inch precipitation isoline. A minor percentage of the total plant composition is made up of desirable perennial forage plants, and potential to improve range condition and produce a dependable supply of forage by applying intensive management practices is lacking. On ephemeral range, the season of use depends on the production of ephemeral forage, which can change from year to year. For the ephemeral range in southern Clark County, the range has been used for grazing only once since 1976 (BLM 1998).

ENVIRONMENTAL IMPACTS
Sale of the MGS
a), b), c) The sale of the MGS would not, in and of itself, result in physical changes and would therefore not result in impacts to agricultural resources.

Construction of 500 feet of Fence
a), b), c) Currently, there is no agricultural use on the site and no plans to change the existing land use. Structural additions to the site would not affect agricultural resources because improvements would not affect off-site land use, including grazing, on adjacent BLM land.

Continued Existing Operations
a), b), c) Continuation of existing operations would not result in any physical changes and would therefore not result in impacts to agricultural resources.

Increased Plant Output by Approximately 10%
a), b), c) There are no agricultural resources within the site boundary or in the project vicinity. No change in land use would be associated with increased plant output. Consequently, no impacts to agricultural resources would occur.

MITIGATION MEASURES
None required.