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alluvium”) and a lower layer (“older alluvium”). The EGR report also acknowledges that layers of mudflow/clay from 4 to 12 fee thick have been experienced on the existing excavation site and are encountered along the pit wall (see also in Exhibit 1, EGR’s Exhibit A (e.g. p. 5- 8 and 11- 13, Figures 7, 8, and 9, and Boring Log of pit wall) and Exhibit 216). Based on that information, we also find that neither of these individual layers of aggregate is 60 feet thick. Therefore, OAR 660-023-180(3)(d)(B) applies. In summary, even if the proposed expansion site satisfied the significance criteria of OAR 660- 023-180(3)(a), because section (3)(d)(B) applies to the site, the site would not be significant. Step 3 Determine if conflicts from mining can be minimized OAR 660-023-180(5) -- For significant mineral and aggregate sites, local governments shall decide whether mining is permitted. For a PAPA application involving an aggregate site determined to be significant under section (3) of this rule, the process for this decision is set out in subsections (a) through (g) of this section. Because the City Council has found that the proposed expansion site is not a significant aggregate site under OAR 660-023-180(3), findings under -180(5) are superfluous. Nonetheless, the City provides the following findings to provide a complete evaluation of the application. (a) The local government shall determine an impact area for the purpose of identifying conflicts with proposed mining and processing activities. The impact area shall be large enough to include uses listed in subsection (b) of this section and shall be limited to 1,500 feet from the boundaries of the mining area, except where factual information indicates significant potential conflicts beyond this distance. For a proposed expansion of an existing aggregate site, the impact area shall be measured from the perimeter of the proposed expansion area rather than the boundaries of the existing aggregate site and shall not include the existing aggregate site. The definition of “mining area” restricts the review of impacts to 1,500 feet from the boundary of the area where mining is proposed to occur, unless factual information indicates that a significant potential conflict from mining could occur with existing and approved uses beyond that distance. We find that no credible factual information existing in the record to indicate or demonstrate that analysis of a larger impact area is required for the proposed mining activity. The applicant has analyzed all potential conflicts with mining of aggregate material on the expansion area within an impact area extending 1,500 feet from the perimeter of the proposed expansion area. The land uses of that impact area and the potential conflicts, with identified mitigation measures, are discussed in the following sections. The applicant has analyzed the potential conflicts with in an impact area extending 1500 feet from the perimeter of the proposed expansion area. The City and County Planning Commissions deliberated and considered whether or not the impact area extended beyond the 1500’ minimum as they considered each conflict ‘type’. Both Planning Commissions found that none of the conflicts extend beyond the 1500 ft. minimum impact area as measured from the perimeter of the proposed expansion site. The City Council agrees that the 1500 foot distance is sufficient to include the uses listed in - 180(5)(b). Ordinance - 14