HomeMy WebLinkAboutBUTTE COUNTY ADMINISTRATIVE OFFICE (2)BOARD OF SUPERVISORS
March 1, 2007 MAR 0 2 2007
OROVILLE, CALIFORNIA
Butte County Administrative Office,
We appeal the Planning Commission's decision of February 22, 2007 regarding the M&T
Chico Ranch Mine. We respectfully request that the Board of Supervisars deny the mining
permit and reclamation plan approved by the Commission as well as the certification of the
Environmental Impact Report on the grounds that the project is unnecessary and
incompatible with current land use of the area. The location of this mine is completely
inappropriate, and if the project is permitted it would adversely impact the health, safety,
and well-being of the community.
Baldwin Contracting claims that there is a great need for gravel in Butte County, suggesting
an urgency to permit mines as quickly as possible in order to keep up w-th projected
demands in the future. On the contrary, not only is there an overabundance of gravel
available in the county, but there is more than enough gravel already permitted in the county
to last for the next 60 years (Please see attached independent gravel availability study).
The urgency to mine is Baldwin's, not Butte County's.
Our concerns include, but are not limited to, the following:
A. General Plan Noncompliance
We believe that this project is not in compliance with the Genera Plan; but it will be
up to you to decide whether or not it is and if having prime farmland -uined forever is
what the original writers of the General Plan would have envisioned as an appropriate
end use.
1) According to the Agricultural Element of the Butte County General Plan, the only
acceptable alternate uses for agricultural land are those that preserve, promote, and
support agriculture, which this project does not accomplish (AE — 14).
2) The writers of the General Plan were obviously interested in preserving farmland.
Approving this project would set a precedent which could make any prime farmland
fair game for other companies who might want to put a gravel pit anywhere they
wanted in the county whether the land was prime or not.
3) The Butte County Code says, "...mined lands are reclaimed to useable
condition..'; and '...provide for the protection and subsequent beneficial use of
mined and reclaimed land" Once mining is done in this area it VAII no longer
be useable or have a beneficial use.
4) Butte County has a seriously deficient General Plan that is internally inconsistent and
out of compliance with state law. Projects like this should not be approved until a
new General Plan is implemented.
(Page 1 of 4)
B. Problems for Area Farmers
1) This project will cause increased flooding and flood water damage on neighboring
properties.
2) Having a bypass channel 15 feet away from the property lines of the three ranches
which are located to the west of the mine site would legally forbid dormant spraying in
the first 85 feet of these orchards, impairing normal farming practices on these three
ranches.
3) Mining in the aquifer and leaving it exposed to sprays and floodwater -borne
contaminants will pollute community drinking water.
4) Allowing such a heavy industrial operation in the middle of intensely farmed land
would be an incompatible use for this area.
C. Destruction of Prime Farmland
1) There is no gravel shortage in Butte County and, therefore, no pressing public
need to approve this project. At the January 25, 2007 Planning Commission
meeting Rene J. Vercruyssen made the following statement: "You have heard
over the years that Baldwin can get their rocks somewhere else. This statement
is more than100%true. This statement is fact.... We currently import the
overwhelming majority of our construction grade aggregates from Glenn County;
and we have the reserves and planned reserves in Glenn County that will make
this option a viable one for decades."
2) Both the Assessor and the NRCS have determined that this is prime soil. The
real pressing public need is to save as much prime farmland as possible for future
generations (Please see attached document — Prime or Non -Prime).
3) Approving any project that destroys farmland, while at the same time giving the
owners of that property a tax break which was designed to insure the protection of
that land, is diametrically opposed to the intent of the Williamson Act.
4) Baldwin claims that their site contains the only proximate available concrete grade
aggregate available in the county; however, no aggregate survey has been. done
to confirm this claim. In fact, according to the Butte County Assessor there are
several proximate sites available.
D. Inadequacies of the EIR and Reclamation Plan
1) The Department of Conservation has made it very clear that the EIR and
reclamation plan for this project are not in compliance with either SMARA or
CEQA (Please see attached DOC letters).
(Page 2 of 4)
2) The DOC said the reclamation plan is incomplete and does nct meet minimum `
K • requirements of SMARA and that there needs to be a detailed engineered design -
'done for the bypass channel before the project is approved.
3) The flooding section of the DEIR is inaccurate. It stated that no floodwaters from
- the Sacramento Riverenter the project site. This is not true; actually, raging
w waters enter the site. Because of this discrepancy all future studies about any
+� potential. flood -related problems were completely invalid. `.
4) The Gravel Availability Study in the FEIR was not done in accordance with DOC
guidelines_ .: This led to the incorrect conclusion that Butte County has a shortage
_ of gravel.
5) The Batch Plant is not in compliance with the Williamson Act, snd all references
• `, to,the Batch Plant should be removed from the Environmental Impact Report.
6) It is impossible to adequately determine'the potential environmental impacts of
f this'project because the EIR and reclamation plan were so poorly done.
E. Traffic'
A
"1)' At the present time most of the gravel trucks in the county use. designated truck
routes. -However, if this project is approved these gravel trucks would be traveling ;
on substandard, undersized rural roads. This situation would pose a serious
threat to the health and safety of others who use those same roads — especially to
the large number of bicyclists and operators of slow-moving farm equipment on'
River Road and Chico River Road. Having the majority of these trucks come into
Chico on a very narrow West 5th Street would create an unacceptable risk for
- elementary and college students trying to cross West 5th as well as 8th and 9th
Streets. Also, a large number of the trucks would take Durhan Dayton Hwy right
" through the middle of Durham, which would create a dangerous situation for all
students going to and,from school. (Please see attached Highway Patrol letter). "
2)_Projects like this need to be located where they have easy access to freeways,.
not where they will need to go down narrow residential streets that were never
designed for this kind of truck traffic. This has to be the worst;possible area Jn all
of Butte County for a gravel pit. If you were trying to find a location that would
create the most serious traffic problems, this would be it. Ninety-five percent of all-, ,
the trucks leaving this plant will have to go right through the middle of either Chico
or Durham, using highly residential streets, in order to get to almost all of their job '
sites. The routes that these trucks intend to use would seriously degrade the : -
environments of two very special communities. -
3) Road repair'costs to the county would greatly exceed Baldwin's "fair share"
contributions. River Road and.Chico River Road were not built to handle this. kind,
of truck traffic and will soon deteriorate and West 5th Street is -oo narrow. Many
projects are turned down because the infrastructure is not adequate to handle the R
• - project, and that is'exactly what we have here. It would seem appropriate to have
Y
a fiscal 1 analysis. done to assess just how costly this project might be to the county ,
if it is approved.
L .(Page 3 of 4)
If this project really was as beneficial and benign as the applicant claims. then wouldn't the
record irrefutably support those claims? Yet, it doesn't. We have participated in the civil
process of opposing this project for the past 10 years. Not only has'the Planning Commission
waived aside our concerns, but it voted to approve an unnecessary project that will benefit a
large conglomerate at the expense of the residents and taxpayers of Butte County. On these
grounds; we the undersigned do hereby ask that you deny the approval of this project.
Please contact Ron Jones at 345-4286 if you have any questions. Thank you.
(Page 4 of 4)
Business, Transportation and Housing Agency
State of California Flex
Mem0"and urn Puf R:
9 PE'C II ENT
Dater December 3. 2002
S®AF:® OF SUPERVISORS
To: State Clearing House ��R 2 %Q�
1400 Tenth Street, Room 121
Sacramento, California 95814
From: )i?)l1EAIATMIEI°lT O.F CALIFORNIA IDGHWAY PATROL
Chico Area .
File No:; . 241.10360
Subject: M & T CMCO RANCH SCH # 97022080
Thank you for the' opportunity to review the Draft Environmental Ianpact Report (EIA) for the M
& T Cllico Ranch Mine, State Clearing House 9 97022080. The California Hi sway Patrol
(CHP) Chico Area, is the primary agency that provides traffic taw enforcement, safety, and
management within the unincorporated portions of Butte county. Chico Aree is responsible for
;fiver Roac1, Chico River Road, Ord Ferry. Road, Hegan Road, Da}ton Road. Durham Dayton'
Highway and the Skyway. We offer the following comments:
.The'proposed project will have a significant adverse impacts on the roadway: the project
mentions that are under our command. These roads mentioned are also prinluy routes of travel
for local commuters. The additional truck traffic would create an unacceptaHe safety hazard for
the motorilg public. In addition to commuters these roads are used to transport slow moving.
agricultural equipment and bicyclists.
a- ---- .d-KiVer (v 42 to -Chico River Road): This roadway is narrow in wi•ith, separated by., _
double yellow lines- and has numerous curves. The design of this roadway makes it difficult
for corrunercial vehicles to safely and legally negotiate. The increased commercial traffic will
create a potential safety hazard for the motoring public.
® River Road (Chico River Road to Ord Ferry Road): Truck traffic will be entering and exiting
the project site slowly as well as crossing into the opposing lanes of traff_c as they enter and
exit the project site. This additional truck traffic will create a safety hazard for the, motoring
public.
s Ord Ferry Road: The Little Chico Creek Bridge is substandard and not. -,Vide enough to
accommodate opposing large commercial vehicles. Large commercial vehicles. attempting to,
simultaneously traverse the bridge would create a safety hazard for the motoring public.
State Cleaning House
Page 2
December 3, 2002 ,
Skyway/Baldwin Plant Driveway: The additional truck traffic at this location would create an
unacceptable safety hazard for the motoring public. Because this intersection is uncontrolled;
trucks who would be slowing to enter, or accelerating to leave the driveway would have to
cross eastbound Sky-way to go westbound This maneuver is inherently untFafe due to the
Slow speeds large commercial vehicles travel. These above factors increase the probability for
a high speed collision to occur.
The traffic an for the Final E1R should consider these concerns and identiy appropriate and
adequate mitigation measures to alleviate these conditions.
A. T. SM111L Captain
Commander
Chico Area
F30ARD OF SUPERVISORS
Prime or Non Prime? MAR 0 2 2007
CROVILLE, CALIFORNIA
There has been a lot of controversy as to whether the soils at the M & T. -nine site are prime
or not. The Butte County Assessor, the NRCS and the opponents of this project say.they
are prime, but Baldwin and the Planning Division insist that they aren't. Here are the facts.
In 2004 1 went to the Natural Resources Conservation Service (NRCS) regional office and
talked to Dean Burkett, the person in charge of the soil mapping project currently being
done in Butte County. He told me that the NRCS had gone to the mine site itself, not the
M&T Ranch as a whole as you might have been told, but to the actual mine site, and
determined that the soils at this particular site were deemed to be prime =soils.
Mr. Burkett said that whoever had done the soil survey for the DEIR had ,made several
mistakes in the study. He explained that the NRCS uses five areas to classify soils in order
to determine if they are prime or not (these are listed in the DEIR on page 4.3-21). The
DEIR states that the soils at the site did not meet the criteria for being prime in three of the
five areas. However, Mr. Burkett told me that this was not correct; the soils at the mine site
actually met the criteria for being prime in all five areas of soil classification. He went on to
explain each soil classification area to me and why the DEIR was incorrect in concluding
that the soils were non -prime.
One area which Mr. Burkett said the DEIR was mistaken about was irrigation. The soil
study in the DEIR states that, "The project site does not have a developed or reliable
irrigation system" and therefore he concluded that it did not meet the criterion for
classification as prime farmland. Mr. Burkett told me that the question the NRCS asks is
not if it is irrigated but can it be irrigated. He said that all the farmlands around the pit site
are irrigated and the water table is only 11 feet down in this area, so obviously it could be
irrigated and that is the question being asked here. He said whoever did the report should
have said that this area did meet the criterion for irrigation.
Another area which wasn't done right deals with the flooding frequency. IMr. Burkett said a
location has to flood a certain number of times over a period of years in order for flooding to
be considered a problem. He told me that the area of the mine site did rot flood often
enough for it to fail, and he showed me the data supporting his position. He said the
flooding frequency report in the DEIR incorrectly assessed the information and that the
amount of flooding which occurs at the site should not have resulted in the DEIR's
conclusion about flooding frequency resulting in it not meeting this criterion.
The last area which Mr. Burkett said had been done incorrectly was regarding the water
table. He said there was no way that this area, even though it floods, should have been
classified as having a problem with the water table. So Mr. Burkett said the mine site
should be considered prime regarding the water table and that the site did, in fact, meet the
criteria for being prime in all five areas used by the NRCS to classify soil.
He went on to say that a large portion of the mine site consisted of a soil type that they are
now calling Parrott Silt Loam. He said this is a Class One soil and that rreans that this
area is considered to be prime soil.
Another way of assessing if soils in a given area are prime or not is to give that site.a Storie
Index rating. At the April 18, 2006 LCAC meeting Blake Bailey from the Assessor's office
said that Dean Burkett of the NRCS office had told him that they try to give each area a
Storie Index rating for its highest and best use. Blake said Mr. Burkett told him that if the
gravel pit site were to be irrigated that it would have a Storie Index rating of 85. Anytime.
you have a Storie Index rating over 80 that ground is considered prime.
I understand-thatthe Planning Division called the NRCS and talked to Dean Burkett back
in, I think, 2004, and I suspect that he told them exactly what he had told me. However, in i
spite of the fact that Mr. Burkett probably explained what had been done incorrectly in the
soil analysis for the DEIR, the Planning Division persists in saying that the soils are not
prime simply because the person who did the soil study said they aren't. It seem like the
.Planning Division is determined to ignore the independent evaluations of two unbiased
experts, the NRCS and the Butte County Assessor, who have both told them that the soils'
are prime, and they have decided instead to listen to the person who made repeated
mistakes in the process of determining if these soil were prime or not.
You could easily verify this information for yourself by either calling Mr. Dean Burkett at the
NRCS office at 343-2731, or making an appointment to see him at their regional office at.
717 Wall. Street in Chico. He is very approachable, and I'm sure that he'd be more than
willing to answer any questions that you have.
Thank you,
Ron Jones
J -_4
TABLE 4.3-2
Dmiur: PAPTI/11 AKJn rRITFRIA EVALUATION
Meets
Criteria/Considerations Criteria Prime Explanation
IFIR
�01_$.,
Land Use: Prime farmland designation is independent of Yes The project site is not water or urban built-up
current land uses, but cannot be water or urban built-up lands, as defined by National Resource Inventories.
land as defined for National Resource Inventories. Map
units which are complexes or associations containing
components of urban land or miscellaneous land types as
part of the map unit name cannot be designated as prime
farmland. The soil survey memorandum of understanding
determines as the scale of the mapping and should reflect
local land use interests in the design of map units.
include both No Soils on the project site are characterized as
Flooding Frequency: Some map units may
and non -prime farmland because of variation in frequently' Flo . oded.
prime
Floodifig and related access problems prohibit
flooding frequency.
farming about five out of ten- years under
normal Ebfididons.�:_-�
Irrigation: Some map units, include both areas that have a
No
The project site does not have a developed or
Jr-,ngati" ";
developed irrigation water supply that is dependable and of
rdi a .ionsystem.(
reliable ,L.
adequate quality and areas without such a supply. In this
case, only the irrigated areas meet the prime farmland criteria.
Water Table: Some map units include both drained and
No
Drainage problems associated with several soils
undrained areas. Only the drained areas meet prime
on site are recognized within the series
descriptions in the preliminary soil survey data
farmland criteria.
for the project area.
Wind Erodibility- Product of I (Soil Erodibility) X C Yes According to the preliminary soil survey for
(climate factor) cannot exceed 60 for prime farmland. A Butte County, the soils mapped on the project
map unit may be prime farmland soil in one survey area but site are not subject to excessive wind erosion.
not in another.
v
Land Capability Classification: All land which qualifies No Based `preliminary on soH . survey for Butte
, e. s6ii'm"lapping units on project
for rating. as Class I or Class 11 in the Sod Conservation 'the.
site: are re considered Class III 'soils due t� a lack
Service land use capability classifications.
of a developed and reliable irrigaeon 'systein.
Storie Index Rating: Land which qualifies for rating So
No
The Storie Index Rating for this site is estimated,
through 100 in the Storie Index Rating.
to be approximately 46.5% which is
considered non rime.
Livestock Production Value: Land which supports
No
This site does not support livestock.
livestock used for the production of food and fiber and
which has an annual carrying capacity equivalent to at least
one animal unit per acre as defined by the United States
Department of Agriculture.
Crop Production Value: Land planted with fruit or nut-
No
This site does not currently support any fruit or
bearing trees, vines, bushes or crops that have a non-
nut -bearing trees, vines, bushes, or crops.
Crops on portions of the site over the
bearing period of less than five years and which will
planted
last several years have not returned the $200
normally return during the commercial bearing period on an
annual basis from the production of unprocessed
minimum threshold. The average annual return
agricultural plant production not less than two hundred
per acre for safflower and wheat planted
dollars ($200) per acre.
between 1993 to 1995 was less than $115.
Crop Production Value: Land which has returned from
No
i
Agricultural crops planted on portions of the
the production of unprocessed agricultural plant products
project site over the last several years have not�
an annual gross value of not less than two hundred dollars
returned the minimum $200 minimum
($200) for three of the previous five years.
threshold. The average annual return per acre
for safflower and wheat planted between 1993
to 1995 was less than $115.
M&T Chico Ranch Mine Project Draft EIR
4.3-21
Gravel Availability for Butte County BOARD OFSUPERVISORS
An Independent Study.
Rv Ron Jones MAR 0 Z 2001
OROVILLE, CALIFORNIA
Aggregate production figures for Butte County are given in the M & T Chico Ranch
Mine DEIR dated October 2003 (page 4.0-20). According to this study, there are 54 million
tons of permitted aggregate available in Butte County and in the next 50 years we will need
127 million tons of aggregate. If we looked only at these figures it would -certainly seem
that we have a 73 million ton shortage of gravel in Butte County. A lot o1 the information
that was used to determine future aggregate needs for Butte County came from the.
Department of Conservation's Aggregate Availability in Califomia Study by Susan Kohler.
This document was included in the agenda materials that the Land Conservation Act
Committee (LCAC) received before their February 21St meeting. According to Ms. Kohler's
report, the statewide average of aggregate used in California was seven tons per person,
and this is the figure that was used to determine the yearly and the 50 -year aggregate
needs for Butte County. It was obvious that person doing the gravel availability study for
the DEIR had used Ms. Kohler's report because they quoted from her report several times.
The person who did the gravel availability study for the DEIR accurately determined. that
Butte County will need 127 million tons of gravel in the next 50 years and that the total
permitted reserves for the County is 54 million. However, it was at this point that they
made one huge mistake in determining whether or not Butte County actually has a gravel
shortage
The Department of. Conservation's Aggregate Availability in California Study says,
"The per capita consumption model has proven to be effective for prediction of aggregate
demands in the major metropolitan areas.......". "However, the model may not work well in
County aggregate studies where the boundaries have little correlation to the aggregate
market area and in P -C (Production -Consumption) regions that import or export a large
percentage of aggregate. In such cases, projections were based on a modified per capita
consumption model. For example, if a P -C region imports 30% of its aggregate, the total
50 -year projected aggregate demand for the P -C region may be decreased by 30%.° (pg. .
5) (This page of her report is at the end of the study.)
This is the situation we have in Butte County. Much of the gravel used in Butte
,County comes from outside the County so in order to do an aggregate availability study you
have to take into consideration all the gravel we get from other counties. One word from
the quote in the previous paragraph bothered me. It says the demand "may". be decreased. v
wondered what Ms. Kohler meant by this. Should a person doing an aggregate
availability report lower the 50 -year demand by the percentage of gravel being imported or
.did the word "may" mean that this was optional, so I decided. to call Ms. Kohler and ask her.
She said when she originally wrote that statement she used the word "should", but she said
that for legal reasons when someone else from the State edited her study they decided to
change the word "should" to "may". She said in all of the 32 areas they studied in this
report if gravel was imported or exported, then the 50 -year demand figures were either
raised or lowered accordingly. The purpose of doing an aggregate availability stud is s not
to find out how much gravel is available in the County but to find out how much .gravel is.
available to the County. The writer of the Environmental Impact Report did not take into
consideration any gravel being imported into Butte County, and this oversight led to his
incorrect conclusion that we have a gravel shortage in' Butte County. According to Ms.
Kohler, if gravel is being imported then the 50 -year demand figures should be lowered,
which the person doing the gravel availability report in the EIR did not do.
So just how much gravel is imported into Butte County? In the Glenn County
Resource Report (1997) the State Division of Mines and Geology states that 55% of the
aggregate mined in Glenn County is exported to Butte County. Now the problem was
figuring out how much gravel is -produced in Glenn County in a year. Each year in Glenn
County the gravel companies are charged a per ton fee by the County based on how many
tons of gravel they produce each year. I called the Glenn County Assessor's Office.an.d
talked to Mardy Thomas, and he told me he didn't have the figures for 2005 but in 2004 the
gravel companies produced 1,252,000 tons. If the 55% figure quoted above is about right
that would mean that about 688,600 tons of gravel would be coming from Glenn County
into Butte County each year.
Next I tried to figure out how much gravel was coming from Tehama County. Just
about 10 miles north of Chico right next to Highway 99 there are two gravel pits within a few
miles of each other. Both are just over the Butte -Tehama County line. I asked the owner
of the 7-11 Pine Creek Gravel Pit how much gravel he thought came from, his gravel pit into
-Butte County last year and he,said about 250,000.tons. Next I called the Deer Creek
Gravel Pit and.they told me they ship about 40,000 tons a year into Butte County. Then I
called several gravel operations in Yuba County but they. didn't think that.4ery much of their.
gravel went to Butte. County. - This seemed to concur with the Aggregate Availability Study
done for Yuba City-MarysVille area in which they said that only 1.8% of the gravel mined'
there ends up in Butte County.
So it appears that about 978,600 tons of gravel are being imported each year into
Butte County from Tehama and Glenn Counties (688,600 from Glenn County and 290,000
from Tehama County). According to the M & T Ranch FEIR (October 2003 - pg. 4.0 -18) -
the estimated use for Butte County for 2005 should have been about 1, 560, 000 tons. We
know that this figure' is arrived at by multiplying the number of people in Butte County by.7
tons, the average amount of aggregate used by everyone in California each year. As I read
the aggregate availability studies for surrounding counties, I noticed that the amount of
aggregate used in. a County can vary dramatically from one year to another since housing
booms or major road projects can cause the actual yearly amounts to fluctuate wildly.
However, this figure of 1,560,000 tons should fairly well approximate the average usage in
Butte County over a period of several years.
By subtracting the total amount of gravel that's imported from the average amount of
gravel that's used in the County (1,560,000 — 978,600) we find that in an average year
Butte County. probably produced about 581,400 tons, which means that vve actually
imported more gravel than we produced in Butte County. If we divide that figure. (581,400
tons) by 1,560,000 tons we get a figure of 37%. This means that in an average year about
37% of the gravel used in Butte County is produced within the County. We can then
multiply the 50 -year aggregate need for the County (127 million tons as fcund in the FEIR
on pg.4.0-2) by 37% and'we will come up with the actual 50 -year aggregate needs of the
County, which would.be 47 million tons. If youcompare this to the 73 million tons,presently
permitted in Butte County (54 million permitted when report was done plus the amount just
permitted at the Table Mountain Mine), we already have more tons of aggiregate permitted
than we will need for the next 50 years.
i
Another thing Susan Kohler said in her gravel availability study is that the supply of
gravel in your area can be depleted very quickly if the gravel in surrounding counties were
to run out. So is this something Butte County should be concerned about? According to
Ms. Kohler's study, the Yuba City -Marysville area has permitted aggregate reserves of
2,000 million tons (pg. 8). This is 34 times as much as we would need in Butte County.for
the next 50 years and 66 times as much as Yuba County will need in the next 50 years. ,In
the Department_ of Conservation's Report on concrete -grade Aggregate in Glenn County it
was established that a large portion of the land area in Glenn. County contains aggregate
resources of regional significance with a potential supply of 1,031 million tons of aggregate
which is about 17 times the total we will need in Butte County for the next 50 years. The
Department of Conservation's Aggregate Availability Study for Tehama County indicated
aggregate reserves. of over 1,100 million tons. Clearly there is no chance that any of the ,
counties around us are going to be running out of gravel anytime soon, and they should be
able to keep supplying us with a continuous stream of gravel well into the foreseeable
future.
Do we have a shortage of gravel in Butte County? When the gravel availability study
is done according to the DOC's guidelines, it's clear that we already have more gravel
permitted than we will need for the next 60 or 70 years.
D d C is 14 g 1 rC� a.1e H vac / e b s 1 t f y r est
.ey
The steps used for forecasting Califdrnia's 50 -year aggregate needs entail: 1) collet ng yearly
historical production and population data for a period of years ranging from the 1950s through.
2000; 2) dividing yearly aggregate production by the population for that same year to determine'
annual historical per capita consumption; 3} determining an average historical per'.mapita
consumption; 4) projecting yearly population for a 50 year period; and 5) multiplying each year of
projected population by the average historical per capita consumption rate to get a -total 50 -year
aggregate demand. It should be noted that the years chosen to determine an average historical per
capita consumption differ depending upon historical aggregate use for that region. For example, in
Shasta County, major construction projects from the 1940s through the 1970s cans �d historical per
capita consumption rates to be extremely high -and unrepresentative of future aggregate demand
(Dupras,1997). Consequently, an average historical per capita consumption rate fcr Shasta County
was based on the years 1980-1995.
Effectiveness of the Per Capita Consumption Model
: The assumption that each person will use a certain amount ofconstruction aggregate every year is
a gross simplification of actual usage patterns, but it is intuitively correct to assume that an -
increase in the number of people will lead to the use of more aggregate. Over along enough
period, perhaps 20 years or longer, the random impacts of major public construction projects and
economic recessions teed to be smoothed out and consumption trends become similar to historic
per capita consumption rates: Per capita aggregate consumption has, therefore, become a
commonly used national, state, and regional measure for purposes of forecasting.
The Per capita consumption model has proven to be effective -for predictionof aggregate demand
in the major metropolitan areas. The Western San Diego P -C Region and the San Gabriel Valley
P -C Region are examples of how well the model works having only a 2°j° and a 5°/a difference
respectively, in actual versus predicted aggregate demand Wet; 1994, 199 o�veyvi:.the :
�•H.o :
model may not Mork well in coon •ate studies where boundaries have little correlation to . .
the. a e market area and in P -C re V ons that int ort or export a ge percentaae of a-ap7repate.
T t
region imports 30% of its W-gregrafe, the total 50 year projecte
P -C region may be decreased by 30%.
Where no correlation could be made between population and historical use, 50 -year aggregate
demand was based on projections of historical production. This lack of correlation can exist when
a study area has a large percentage of aggregate imported into the region such as in Orange County
(Miler, 1995) or_when a large percentage of aggregate is exported from a region such as in the .
Monterey Bay P -C Region (Kohler-Antablin, 1999).
Permitted Aggregate Resources .
Permitted aggregate resources (also called reserves) are aggregate deposits that have been
determined to be acceptable for commercial use, exist within Properties owned or leased by
aggregate producing companies, and have permits allowing mining and processing of aggregate
material. A "permit" means any authorization from or approval by'a lead agency, the absence of
which would preclude mining operations. In. California, mining permits are issued by local lead
agencies (county .or city governments) not by the state. Map Sheet 52 shows permitted aggregate
resources as a percentage of the 50 -year demand on each pie diagram (see Fif YeaQ►Aggregute
5
OFFICE OF MINE
RECLAMATION
Be
B0 K STREET
MS 09-06
SACRAMENTO
CALIFORNIA
95814
PHONE
916/323-9198
FAX
916/322-4862
DEPARTMEN T OF CONSERVATION
S T A T .E O F C A L I F O R N I A
June 10, 2004
BOARD OF SUPERVISORS
`/I.A► FAXED- (fi3 ) 538-7785
c:DI�IFIRMATIQN MAILED MAR 0 2 2002
OROVI _L E, cauFct NIA
Mr. Dan Breedon
Butte County Planning Division
=
'7. County Center Drive
Oroville, CA 95965-3397
Dear Mr. Breedon:
Transmittal of a Reclamation Plan for the M&T hi o Ra ch Mine
dated Dece h r 9 in 11d1- ex rptc from the Draft EIR for
Ck�ico Ranch Mining Qperatimn and R _clarnatinn Plan
TDD S C H# 199702
916/324-2555
The Department of Conservation's Office of Mine Reclamation (OMR) has
INTERNET
consrvxa.gov reviewed the documents included for a reclamation plan fo the M&T Chico'
Ranch Mine in conjunction with the relevant sections of the Draft EIR as
referenced in the submittal. We also reviewed the reclamation plan map
:RNOLD and operations map, date stamped November 2003 by butte County. We
S C H W A R Z E N E 6 6 E R previously commented on this project in letters dated November 18, 2002
GOVERNOR P y
and October 22, 2003.
.The project will entail the establishment of a 70 -toot deep excavation and
an aggregate processing site in a flood prone area along Little Chico
Creek in Butte County on 235 -acres. The site will be reclaimed as open
ground water pond and wetland wildlife habitat and is also intended to be
used to recharge the groundwater aquifer.
The Reclamation Plan uses the "Small Mine Prototype" t5rmat from the
State Mining and Geology Board's website. The Small bine Prototype is
useful for very small operations (5 acres or less) in areas with negligible
environmental issues. This format is not appropriate for a site of this size
and complexity.
The.reclam2tion Ian is innmmplete and_does not meet the minimum
requirements of the Surface Mininn anrt RP iamation Act of 1975
(SMARA)(Public Resources Code Section 2710 et seq.l and the State
Mining and Geology Board regulations for surface mining and reclamation practice
(California Code of Regulations (CCR) Title 14, Chapter 8, Article 1, Section 3500 et
seq.; Article 9, Section 3700 et seq.). The following items should be included in the
reclamation plan.
iningQperation and ClasUre
(Refer to SMARA Sections 2770.5, 2772(c)(1), (c)(2), (c)(3), (c)(4), (c)(5), (c)(6). (c)(9),
CCR Section 3502(b)(2), (b)(5), 3709(a), (b), 3713(a), (b))
1. There should be a termination date for the operation, and the tirre frame in
which reclamation will be completed should be discussed (SMARA Section
2772(c)(3)).
End Land 1 ose
(Refer to SMARA Section 2772(c)(7), (c)(8), CCR Section 3707 (a), (c), 3708)
2. The effects of siltation and the reduction in substrate transmissivity values by
deposition of suspended sediment carried in Little Chico Creek during periods of
flooding has not be evaluated in terms of the proposed end use Df the site as a
ground water recharge lake". The effectiveness of groundwater recharge would
be expected to diminish. as the ponds silts in. The effect of evaporation of the
pond surface would also tend to negate the benefit of any enhanced recharge to
the aquifer. We recommend that recharge not be listed as a beneficial end use
for this project (CCR:Section 503(0)(2).and 3706(b)) unless it is designed and
maintained to be functional.
(Refer to SMARA Sections 2772(e)(8;
(b)(1), (b)(2), (d), (e), 3704 (a);
(b)(4)i-(b)(M, 3503(a)(2), (a)(3),
(g), 3716 (a) Jb),(c), 3712)
a 3. There is no detailed erigin.edred:dasidh. for_the bypass channel or weir structure
proposed to mitigate.m_O'a o* 'thy :'. ldodpl�in impacts that would re-sult.from the
placement of a deep`. r fining: pit wi flin:100 feet of Little Chico Creek and in
proximity of the Sacramento River: `This aspect of the reclamation plan is totally
lacking and must be addresses.pror to approving the reclamation plan (SMARA
Section2772(c)(8)(B);. CCf; Section V0.6(e)).
4. There is no design .basis .given for.thb proposed increase from a 50 -foot to a
100 -foot buffer to be.left'adjacentto L;i#tle: Chico Creek. In any case, this buffer
has not been incorporated ih-1he cross.sections or diagrams supplied for the
reclamation plan --The. buffer width shou Id be arialyzed and inCDrporated when
err.,
Dan Breedon
June 10, 2004
Page 2
Mining and Geology Board regulations for surface mining and reclamation practice
(California Code of Regulations (CCR) Title 14, Chapter 8, Article 1, Section 3500 et
seq.; Article 9, Section 3700 et seq.). The following items should be included in the
reclamation plan.
iningQperation and ClasUre
(Refer to SMARA Sections 2770.5, 2772(c)(1), (c)(2), (c)(3), (c)(4), (c)(5), (c)(6). (c)(9),
CCR Section 3502(b)(2), (b)(5), 3709(a), (b), 3713(a), (b))
1. There should be a termination date for the operation, and the tirre frame in
which reclamation will be completed should be discussed (SMARA Section
2772(c)(3)).
End Land 1 ose
(Refer to SMARA Section 2772(c)(7), (c)(8), CCR Section 3707 (a), (c), 3708)
2. The effects of siltation and the reduction in substrate transmissivity values by
deposition of suspended sediment carried in Little Chico Creek during periods of
flooding has not be evaluated in terms of the proposed end use Df the site as a
ground water recharge lake". The effectiveness of groundwater recharge would
be expected to diminish. as the ponds silts in. The effect of evaporation of the
pond surface would also tend to negate the benefit of any enhanced recharge to
the aquifer. We recommend that recharge not be listed as a beneficial end use
for this project (CCR:Section 503(0)(2).and 3706(b)) unless it is designed and
maintained to be functional.
(Refer to SMARA Sections 2772(e)(8;
(b)(1), (b)(2), (d), (e), 3704 (a);
(b)(4)i-(b)(M, 3503(a)(2), (a)(3),
(g), 3716 (a) Jb),(c), 3712)
a 3. There is no detailed erigin.edred:dasidh. for_the bypass channel or weir structure
proposed to mitigate.m_O'a o* 'thy :'. ldodpl�in impacts that would re-sult.from the
placement of a deep`. r fining: pit wi flin:100 feet of Little Chico Creek and in
proximity of the Sacramento River: `This aspect of the reclamation plan is totally
lacking and must be addresses.pror to approving the reclamation plan (SMARA
Section2772(c)(8)(B);. CCf; Section V0.6(e)).
4. There is no design .basis .given for.thb proposed increase from a 50 -foot to a
100 -foot buffer to be.left'adjacentto L;i#tle: Chico Creek. In any case, this buffer
has not been incorporated ih-1he cross.sections or diagrams supplied for the
reclamation plan --The. buffer width shou Id be arialyzed and inCDrporated when
err.,
Dan Breedon
June 10, 2004
Page 3
adequate. The design parameters should be discussed and verified and
included in the site design (SMARA Section2772(c)(8)(B), CCR3706(g)).
5.- The mitigation for erosion of the proposed bypass channel is, in part, repair by
onsite heavy equipment. The mitigation would not be effective when the site is
reclaimed and heavy equipment removed from the project site. The bypass must
be designed as a long term solution and have a maintenance agreement in place
to perform_re airs 'after_site closure (SMARA Section2772(c)(8)(B),
CCR3706(g)). �� ��
(Refer to CCR Sections 3502(b)(1), 3503(c), 3703 (a), (b), (c), 3704(g), 3705(a), 3710(d), 3713(b))
6. Separation of Little Chico Creek and the lake formed following mining only limits
commingling of the two water bodies to 10 -year flood events. Therefore, it would
be expected that commingling of the waters of Little Chico Creek and the lake
will occur in the future. The potential for movement of warm water prey species
out of the lake and down the creek to the Sacramento River with possible
impacts to anadromous fisheries seems possible. We recommend that the plan
describe how commingling of waters can be prevented.
Elesoilina and fr vegetation
(Refer to SMARA Section 2773(a), CCR Sections 3503(a)(1), (f), (g), 3704(c),
3705(a), (b), (c), (d), (e). (f, (g), (h), (i), (1). (k), (1), (m), 3707(b), (d), 3711(a), (b), (c), (d), (e))
7. The reclamation plan indicates that revegetation will be attained by natural
revegetation except those areas where revegetation is "insufficient." Page 7 of
the reclamation plan specifies "augmented seedings and plantings will be
implemented on a case by case basis." Reliance on natural revegetation is not .
an option..under the statewide reclamation standards regulations. Proactive
measures ta,achieve the stated end use must be described in the plan, including
a complete description of the number of plants, cuttings and or seed of each
specie h will -be used'in the rave: etation plan. ^--
A description of the quantities of each species to be planted (seed or plants) is
esseritial artd-vatidates that the revegetation procedures will achieve the
performance:atandards established f6f each habitat within the specified
monitarfng. period. Seed and .plaht quantities are also required for formulation of
the f'rriancial. assurance cost est[f at6b .: a pan mus a augmented with a
-t- —__ .
descriptari oflproactive revegetation: including quantification of species per unit
area for each of the habitats that are 'to be created.
Dan Breedon
June 10, 2004
Page 4
8. Although the plan.describes three plant communities, maps presented with the
submittal do not reflect where each:planting will occur within the project. The
maps presented were prepared on August 15, 1996 and July 3, 1997
respectively and both are stamped received by the Butte County planning
Division on November 26, 2003. tt is not clear if these maps represent the most
current design for the project. Identification of the specific areas where- each
habitat community will be established with a descriptor of the tots# acre_a_ gg for
each habitat needs to be included in the plan.'.�-
The reclamation text indicates the formation of a nesting island in the deepest
portion of the lake. However:, exhibit 2 shows the nesting island adjacent to the
east shoreline. The presumption of a "nesting island" is to provida a safe
breeding area separated from the shoreline by deep water that restricts access
to the nesting island by predators. As depicted, the island location does not
appear to meet these criteria and appears to be at odds with the :ext. Location
of the island needs to be clarified.
9. Construction of shoreline habitat is an appropriate approach for reclamation of
the project but the plan needs to contain more detailed informaticn concerning
the water fluctuation levels and how this would imps t the 0 foot wide bench
create for the "margin habitat." The plan does not describe any irregular
features to the s ore ine such as peninsulas or bays. The revegetation plan
reports that 2.5 million yards '_of overburden and -500,000 yards of fines will be
available for reclamation. We recommend that overburden and fines be used to
construct irregularities to the shpreline to further enhance habitat quality of the
reclamation. A final reclamati.d :map illustrating the modified shoreline needs to
be included in theplan_and. a...visuai presentation of the 50 -foot w de margin
habitat illustrated.
10. Construction of wildlife habitat: i6
standards CCR 3705 m fo[:`ea
reclamation plan fails to describe
following standards; specie;
standards must be based s,
and density most be preser
Species richness is the -nun
number of live, perennial sti
res specific revegetation performance
of the three habitats proposed. The
rformance standards and must be
.:.tach or the three t1abstats mush_ contain the
hness, density and percent cover. All three of the
y: p.h.native perennial species. Species richness
`asww.hole numbers per unit area (e.g. 100m2).
r`.of native species per unit area and density is the
,:pe unit area.
Dan Breedon
June 10, 2004 .
Page 5
11. Revegetation monitoring must also be described. The plan does mention that
revegetation will be monitored for five years but the plan fails to link monitoring to
performance standards. Approval of the release of the financial assurance
cannot be granted until the revegetation performance standards have been
achieved. The plan must state that revegetation will be monitored annually in the
spring by a qualified botanist or restoration ecologist for a minimum of five years
following planting. A description of the monitoring plan must inclide a discussion
of the statistical sampling method for determining revegetation success. The
sampling method must provide at a minimum an 80% confidence level that the
portion of the revegetation sampled represents the revegetation of the .site as a
whole. Failure to achieve the standards within in this time perioc will require
remedial measures and continued monitoring until the performance standards
have been achieved.
Administrative Requiram .nth
(Refer to SMARA Sections 2772 (c)(10), 2773.1, 2774(b), 2776, 2777, PRC Section 21151.7)
12. The reclamation plan must be supplemented with the applicant's signed
statement of responsibility for reclaiming the site in accordance with the plan
(SMARA Section 2772(c)(10)).
If you have any questions on these comments, please contact me at (916) 323-8565.
Reclamation Unit
Nov -IS -MV Qi:V3 x
Fra, -DIVISION: OF LAD RESOURCE PROTECT104 iRIB3273430 T-3qo v nnanln c-939
�n
1
I Of C 9 M 5 E R V A TI 0 14
11 lg
tJ t3.
T X T Ll a- F C' A L F 0 R N r A-
November 18, 2002
i -z ar
130ARD OF SUPERVISORS
e c
VIA FAXED: (530) 538-778.5
��fE>rr MAR 0 2.2007
g
,:Mr r�1on R.noiJ..n
.." . L.Y,Cl�L1Jlf11
OROVILLE' CALIFORNIA
@QI K sTaGGT
surrE Z�00
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4/Cy vI IIY I�lot /I 111 lIgVIV]Jltl11
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,
S nG k N n E h TO
.7 C'0Un Y C'2r iter ur:vte
9 So 14
PMO1/•E•
Dear -Mr. Bm.edor -
916/322.1000
-
FRk
�_..
FtE--: Ssatemhe. 13rgft- ,ISVIrlfIT�1'Trs7RrtATrv9 C7��nr�'tTTCr1 ��
916/445.0712'
M & T Chico Ranch Mining Operation and oedamatior, Ply„
rn-o
Sew-'E"IS70212ru>-?,
1 R r c e K.z -
Th�Depar��Tar�t: H€'C�tSei�ofii'S iQeDarlmett4? t�1f1i5tr3rT 1af• I-�TT� FggQl rrra
consrv.r_n.gov
Protection (Division) and Office of Mine Reclamation 110MR1 havA-Pviawctd
. �. a
tfiTef3Effff�t�ref�rN�tt-araisct. Tfts�3iuis►c�marTitor� f�tarrt
conversion on a statewide basis and administers theCalif rnia i_arei
&ien� o�vtS
_,. T� Q� Q
_
CfiriSEft+uil9fT` W4fiarrtS� g1 -Act td ottteranrrca -fit fazxt rrrTgarv� vsrr
programs. OMR oversees issues relative to the Su4are Mininn anrN
t E Ql7' ' .FEt fvffoaufrtg corrrr*, nts arts cr1#seepittgri in arrnr,ivw,
WRh-pagectatac-11 .. prnyinw C^mmonlMrin not
rerW n,-•aprrtscTrsttrn;: mw cornmen4c ief'Mtr �.rlhmi:t•��. �.n,.`'- ti iCv .
re6?o taWLi T--jiset-Dmft, -E 1R '
Tha pie} i�p€opos bV-Paeiffz Reatty Assmiate!-,w tkA rias- contracted-.
with KRC Holdings, Inc., a subsidiary of Baldwin Contracting Company. The
si#e is -1 rr tf3 Sasr� Ri�rsr ii-vtf�FfWherrr portion of fia
Sacramento River Vallev, five mites southwest of the city of Chico, n western
•
f3cat�Ccrarti}c (�sFTt}r};. �i,+r �wiff^r3�9t ttigEa'>�raiit of a- .
processing area and mining a 70 -toot deep ground water"pond or prime
fafFtrtrferrrl�Fit{iar�tsoEr�kefe+�r�traet aFra �3aere Tri-,
site wilt be reclaimed as "high aualb open water and wetland wildife habitat
within4h>r 1�aeres-rained.areaasdawiculture-4ofthe-40-acremocessing--
vea:" Twa-acres'wift be7.useettgr,stockpiling topsoil.
The DER- is- inadequate W thfee reasons that- are- summarized below ;and -
each is turther disc ssed-under separate tmadinus-irrthe remainder of this
corresnondence.
Nnu-t 8-2001 D3:1ds� FFWG40S1 4 OF UND 0-50D EE PRQF@Cfi1o# rgTSr�rtgrt T_38E
-03i
Mr. Dan Breedon
November 1R, 21)02
Page 2
The.DEIR fails lo'-point-outthat ihepropmed reelarmatortwoLld be i--
withstatutory requirements of the Williamson Act, The prn?por y is designated
as'Ptirne,farrnFand and is- t cWiffigrnrson A.crCont,-4t ffecausaof the
restrictions of the contract, the mined land must he reclaimed'to Pri-e fa,,;,la„d.
e• Tile SCQI7-C3f LtIsC��SI�rT.=Trtr^-ort rnncci Ic'rnr�e...Mwir:oi wie(r,�CiS frvrri
the protect is too narrowly limited. The ;;iSCL'SSions regarding tt`,a 6iiiiro,m,�Ci'ital
wildlife and riparian habitat are Inco-plets.
.on D.Wo, cmatafroad'in tl~iCs 4LrEfe& ii we•isi; .,e,trLafid drjC& �IVt'FIYCCF
!rte ^:t^►^^• r� S!rr�te ns +r.,. �...r. ,,' AA:= .� -_Rg{;if3iTidtlO►l Act of 1975
-r-='—=- — --"c---�--
(SPJMARA) ,(Fbb.'R,- 6,6soi.ices Code ion 2710 et seG.) and the State fvIning
and Cialcgy , r egu,a tons -fbfsir <aeo -iniiing zFjd i rnation practice
(Cak:Fr 'G or Re rkai ,s �CC�TW& t4, Chr�r 6, R�rieit'r, sectio
35M at sem; esFi ��ss s6c.fiv'%i eit''seu'�:
OMR publishes -a'gaarterty revised-•lisro€-mines -regufated-under-SMARA that meet the
provisions set forth- under- P.GG.seetkx!v-1}285:5r: This'listisgenerally refe,md-tor as
•tne'AB 3098-fist. in-reference-to the enabling,legistation This-section of Public Contract
Codwplaees restriofimssem'State-agemies-regardim-frorrravhom they rftv-obtaiin sand,
graver, aggregates or ather-ntrterals.'. The project., asprnpesed;.ukes the Wiliamson
Ad; CEQA, and SMARA_ . Deficxer►eies aFe-diseased: in•detag-baton - lAle FeeoFFMeAd- t'
that-Ahe protect ria -be ammved as-€resented_-. The Williamson Ast-clearty requires that
w en Prime iarrMar i'imined, if be--reelaO,*&to-- P6rnwfarrritst d-OUrsuar*tC'-ft
minimum •state=de recfarrratimctstandard tar Prune nwicultura Umd. The reclamation
Phan w0poses-to- reclaim mem ol-the-sit-to a- lake; which- is- a-violation ot: the
tAtiltiam on Act-anct•inconsistent.with. the SMARA standand'far. reclamation of Prime'
agficultufal- land: Untit these-detleiencles-arezeffected,- the- mine eanr+at-be placed or►-
the AB 3048 list,
Wi'c.fcPeco r'
i`he' land is effbmaa* restficted' b `NIkk`rfftsm Act cort'rract, and tI•re Butte C &I
Assessor consiaers,the site'Prime agricuiturW:'lafjaO -sue ' to Me act- Histo-icai and
current use. has been agftuiturat The site Is surrounded by agrieuitwar use Proposed
reclamation is 40'acres of :agr cuuuic j land'anti'.i wildlife habits, the
central feature ar wftii is an open-waier pond(take-creat*d fronr t#te-excavated p &). Page
t-* a Ahet DE R A cl c.-:)ntracted
lands were considered; the project is not considered in conflict, and no additional
mitt rriaFpr�os k" Tlrks ig rpt s crfted
by fach* informatkxv.n the
current DEIR. and is incorrect. Both proposed project scenarios.(with and without a batch
1ty-ta_tnn> nz•!e� e.��nluicl�u �c t un nc:�L�ce n ,��cr`-.�u loto31N—. U T-ry lo: jib
Mr_ Da-
P]nP Q'
plant.? a inve�:r_nt b!e with the Willi rn cn ACt TF. nt� .�.....\• !.� . a.-.' r -
) r i it h Ila s/J ar raya_ a t12 LcYCir arlrGlll !!Q5 lwifi7 t !e�lr>�51j
ren[ncnen�nct . r� n tt.3 suniaa�' Q ' ...:as►.a ... caa u:.;� __- w �- _ --te�a,r_ t�
vtijv.n ✓n.dvrrr aavrtrc^�Cr7 if79 rlr!1!f?!rr2crlr wrrt rlrr G[K+!:.Ir��'.I lG�;.Q
rnmmanfS(n: r�fnrnnreo.1/1,+r'1'7 1pu✓7.`! 1..1.. 4nne` .1.._
v1 v\ rvv tr-.vl i1 .a, r ante uv1Y �, 1 .779, ,
Butte Count— has continuously clalrn.ed ih'o oito �p:... 1 t,._. 1 ur•u•.
A {. ,� ty v1u olio V11 as upr*
!CC/!Ca ldi lNaCl lllC F�tl!1�1"!}b C!t
Act,-- ¢Hf{CCT, +-'ra1l PK ;_% �.thCL' os ifa=n.�r..�.f......�..i�.1-".,.•t.
a r-�'^••• r•vwry n vv /.Y•a.u.,\u.r vast v rt Io aJ.a,r. /Y4614rIH1
Resource Conservation Cnnrine (nlorCl tehi�t, l5tc ih •! •1,,. site I:l. .:-
u�• ��•+� vs, .• � J a•.2 $vir$ vi1 uac Ziac as uiigl!1vplu
i o
f: 1 iM..b.... T�rk4• � �a ii�sr�.�awr" sre>-.iw-w. �,� !� �i...
Ctt6 yd ILA
y�'vl�t:v�� •Iv a� ara ra+alauo arG as+�+�Gµ'S�� Icgel —Ii
1907 Keft & As_c i$tec 1_narirnramra—I C.: ra..r..e.. u11 .t' ,r...... ♦ r___.-:
(� arJ I•envrtnlwn 1 vyieuuea rrroirrvigriCal/td/ {jr ifie; r wit!rt_rrr1
••• a/, .,VV • . • yr J'/Iva 11/VI 4tU IV/ IG VIQVV trl ll lte%:
d'r eument. The nFlo did n_^t cite antsy.in/fcr/;rall n from .the Suff? vn,}�I_. As-_.-,--
liirt''�rrvFa�iii�n�i •.-rrrl�a.tur!r V� t! 4J 46111 l C'd� 7Y l! lQ.![�t�et t.~SSaL �[!!{163, ailfl
/:a.e+a. .044 V—* 4. Sqv CC.e 16 .., t Id A. -s a t_- a.. • I rr.••e n u ra a.
urvvruoas M. reyiZvr w as rc- r. -i a r1Gu� Lst Yld3t/>!G!!C? iittaJ! iyiniitn-��r� laa rt�.�• �y7rr tf ii lS
i°I tiS aaa u r aal tl llCll IQCI !, !! IC ilQl' ! cFee t't jt ~�GCrii 'i t� Coiu ttq oI Tw%y
4�rr.161ia!fl�Ci lrlC i C66 t4{IJ �.i iT 1[Y: a3 TflSt14 -Au jiA-i son dict laTi -
Da`l�aidivv}.�r+,,how vrvi, ::/hether tf:3 v:ia^, is ii/iiiiu("i\i$vi aCi Piiiiic or Nici 4iiiilo iniSfi, 1111.2
�F•^TtTP3f-�-��'i.•Ps'��/�FiifwF'Iit_ /```—isas►-�r4L. ninrinn--
!,,�• VIVVV Vt•I tali `
lg a rr\rnna3Ne Mtge 1Mhi1e the DEJR states I iat ,.he cri"giiiui iiiilliar aa*J1vi, Act cviitraccl ivi
tht3�f1 �f!°llft3rQ-$@ffl?!+F4y1M-►.co�Yasra,� rvortlaoa�l#"�►`'.ro<..�:o'a.Q -
the Williamson Act itself. and meet current compatibility standards. Victual contract
L-F,�rr
•waw" • 1 Ir ✓L -t/ l4VVYa\aLV a VTV�i VVVV 111 Ia.11\
r
Uodeserctivm -.and 512.38.7; hitt fails tp dicMlgS�W t#►ar�r`:ert will meet the
/�r�/�a�a�tita' a rrntli n1�-i�\j�.�j��/��� C1. rr..:a»�i.4 w.+•.:�..r-�r�r4
VV)t1V YVVtt1 yV,IV„IV V,a�Vvv ,Ii �IjjiJ�i 3v La1V7iV• Ya�� IVrIV �• VI at1 VI V�V VI YIIV
fhasa roctir!.�c rrnrt„+lr!rFac ttsat.Ma t"vrtlr„z tiksiliht finr3i�:S cannot be met
r :r he ..ctuv:�rir^o t VnLv Serticl �12vva.9.\2/c�i - h:$ $wtl�n renuircycV 1��t t:fno'
St.m., .,ft. =&fi 1 ... ,s���ci+�er!"•" r r`►�tW"1"wa 4�a�e�'1e C t r ih� .
. it he t,aiYtCPi f.^.! Un t0 'l/l years, a^'� ttlB rocL'Itln(s' tr3:tS wllc�:led to fill ::'itr! :a;Mfar, fli:S
r.. e mined V VV rye/
test- h_6- -
' vrna:rnmc . ode se.d.cr51 9.0. 1131( ) - T,kIis soction states that 'he use
Cannot
r� •. , -i" �a.�• �./, 1 .. aroma ars�`vs�hk�-�oV�Y.. .::3'v: G! :..�i�:-
Agaln lnnn_torrn Mlnlnn and flcCr�oN nits .I;r;ll incfeorJ r�tienlar as aniirllttl lral tlSec S0
thns,4est"eataftoi•b�al�sr • .
• .
Government Code
overnmn•CcdeS,*.rr51238,2 - This SG4tti!A .LvrVavV. afinding of �ecru u�4tiuKriyty
1 CACwc-ft=tq i•1 Ii VnIVV- vV ate.—if\ 4nurr
nnnlrnitnnonf tri nroccinim Crime lands or r:enrnprim5 landss is n^t significantly impaired.
S"�� Jr�f`. d'!".'!!if'yfr'f*^mL� .wriil•s--�vr inriv�r�><�wn�',r �-�►�p{iai ac!!-.
ya' h1 and with an eventual- return to flooded n/.lty. Si.n. .if.i.ra..n. .t.lL im..ai.rs the
a.aatraloua a�ri •I a.rlr ltylr.0 u. it'.\tr.'l�Irl ia7il,ezvriT�v:
Nov-1fl-20x1 Q3:Idolo- Fanm-A+WCIM}�F-IdllA tFCen4+F(•Lt+enKr�lru- io-rrrm..�,,. _ _ _
Mr_ n;an Rrawinn
Rano d
In a rl------nnp C0.. cation with tho 00"r,.r tt.; .LG-: .
1 net41 for %111 piv�oi.F, et :":CLA:L
S SCLEE a
RnarGi'nfCttr�ntvi�rsrlfTss�t'•n�.oS�r:•ro.r�"r"��,�:..,_•�•._..,•--s.i`_I__. L•••,
. �—..•.-..-• ••u611eieeielsf.nst:lt.F•-e:•••.}{� =;E%LF lG.ttJ"1E'•[s
cnar,� nr ueJril�fn h�h:fat L-,�S ��mn�►ii.l.. .t, tAe:Fl:. _
r t+e..l4ry vriml vvulial-lGoil edit Cor[t:C;a�CJ] !�,^,[,;. o
Flcnattmont' reZrn�-en�tnt{ a t-mr }. ...G
�annnt vvMM�n{ vnvvi�i!•fltl•• 't •e• j jQjr1 J___ ; J_
vi! iw i"tice Ito. 111c L.l['[ {iGC:,vlu any unlounaum,
. vwlsr•Ivr, yr SIO iat¢e�C•:..r•e ... our
nip\Iin. 1f• nAlY.1!Y\AAS !i. - _ 1 r vr/r..
C•v144.244/1l111 •-�
Y t.71 vle �lte1lge:� i1�t�Ft:� L•.t:1Gi Y9:1{IC1:Sciii N.Cl?..iiv-iiS C�eili(cICI .
wRrO hT s►� •H66rbSFt•! F Cbl• .. ` -' 'ts� r'�.•rr. � _ • '
jf• � Fet C�"CF.tbGEF:)LJ L'[ [ ^u ...i �ey/wu�i�r"�r�',^7^p, i j}6 FY'1rH.i�,IlOS.
v! a.vlTtyl¢axstiFii;: etvEe� at_•IJdC,.LYtFeGtl tilllSl Le.1OHowed in
. . .x. 'provl:^-CCiN3ibiE LSES•
areSJv1lSfCiy
app�t�;
F,t-211 Its IV 6)IJt'ibG..vFty LF•FS�:•L.: -n •R:e., Vt�ii-r/•ji1 ���.. - �+ .y
?e7' iicl 101-skiandards for pfime
.. •.- .__ " rt''t'.L�.�«`t:S_vSIS."••C=..�!._..•:F1!�! `_ --r.^'' �• pti�t•'•ry-Itty'lC'Ftt-EtJ��..
w :•.. •.. . Kli1bF' NfIT.VtoL-i::E�
•.�tivFt"viGv'wtj.. Ydv^utdappear. ihat the
$Gafv °re"tiorF;ascfas•�rib@d
eE ai cec:h, [it»et Ems ir..c n: u War -Mr, ILU=mcr r-:
8-'�>-!'a ice.-rM4�� war.y,•^:::k...."o�� �W
iianarimeni hae rin}ort>?inan f}�w* swan �.ia^.i1;t...�,fe�c r..t_t�r.ot:t rr.•..,,.. .....t.......•G
••• IY1 YS!!1.21ls t1YtFt MG MSEXCL
It�BFik1F R n1F4 mow.jlinyt fe r }xvi is dmft_�,rn_an
- ��;r'
tinriear'utliiiiarncnn Tari rnniraM i�Initi�nr ;n �menrimont t_ ef,o (`-,ut•�
rter=arimetes_s��e+rYie�r�-e�lti�iewi,;r�-� ..t.:.�.......,... ...���E.,D-�o�.r�-er,•t-,�o ,�:
oLeen!Uai 41nrmuai tnr•iko hfnh niarO '-5n O.m.kryA
the .•..v�:[J.'�`::u vi-th.a.lA/'ll'�......... A.a
Kiti'7f�r_II 7itTC'.1'SE>ZECSfT IS/TC�.t'3ttF.lTa^�_�Fin �Ytl1�_tacic 2ryr:lt�nnnnti�ilil.e �sn�er tF.o
•uatrsbrF_-nihvec••3tc_-
• v.l v., •vvv.•..•.vr.v'•••. 4 . �•.��u vY�.,s�.�r�.�..../wit:YY_IM"pI••i+tt^-:1'19._.1•.. .
Af'fiii?=ham b=j F3ioap-Ad,'2i4or: P?31? G]PnipY`P_eC:Rrsi?iPftYEsr linrfGr.i7ra.'mtsintr!azitio roctnniinnc ni the
i..0c!
r�attwtm�i_ry.+Y,tariti.i7�ii_r�_r F�ta.tA�i..i:SenTta •�aiiarrraiitnaiv ifip'�rx�iirani r_nF�fri Iiia inr
nrantes+r�r+�i.auin+rrl�4its-nfc►ioPi-re+alaieif�-P •• .. .
fYnventrrront tM.rscie anertinn 4i13A'J _ Nntiti�ainMn p4-a-rae4aiarn 6rrn re�_nrn_iia}inn m�lc} �n
nree�irFid} t�,r6a E_larortrvTn�ti r } .{'lana nrn
V--4- F 4 f�� f
Uveiinfl..nn tho ru4tiiinn
r.
Arnwih-indiarinn anri i.umuiative rrffPris
. • ..... �•�-.t:-: mss: iit�.� rt:;e::_� •-�
ei��.- i-i�n�aes�cf,. ie`r3 eppii%artt ft8s incsrr ztra:eayc �.aC.v=tt nir ee`te; pivjo�t =ir. e.ar-r
$•tu y� % `�u - '- �- a '- -' .J_..._-'�_' '�--ea�rf.: -tic_. - - '_ •. r_y..
.-F...r�--- - r- �---i..:,=..•t. i�.�`:.•Lt�it __.. ut2 ': ACL[ � •t �CGLt:.�E=ttt Et:; •Gri�t'1.-;1 t`._�..
^e r6.'r :c::.1[rcit:;i[es� i:i rrtfiZ iit3 ad �FER) in'da d �[aii;Ity a4dfaas utaprr ie i-.-
it�� sig^.i•i . �._ _� �...__�—_ � - - _ ,.:.. _.__—
[ adr~ a[ i::t[i:; ��rct•� EE:� :xs c::M c:=r'- --_ ��:�t U, qui • u:.
H�! .Pizim-NVIS103 r LAND RGSOUXE PROTECT!'.19.3127.34330^5u5
i
Mr' Dan Breedon .
.'oveF-lr ber 18, 2'002 `
rage � ti
agricultural land, in terms of the project encouraging alining activities or removirg
i>arriers to.miniftct thAt-woWd result ih the conversi6n of forma or removal of Fond
-irom Wiiiiamson Act contracts.
iyjjti�tlOr) iui!'3SSur�,
As the pf-ajeet:d&oesnotw&xvtno"cu"atibiii€v,f6cwtAgs.'of:ih&-.WMamsorrAet. it would.
as currenily configured; require iermination of a Williamson Act coritract, The CEQA
citideffnes 5gi}tiu� t®Ffrt!EEicsrt°af a#i }ion rseitrtsni over 5O0 acres is ,
treated as a significant environmental impact oT staiewide significance. Thus, the FER
far, a�-ar-'signihcafit-enviFonmt3aiia
impact, and must provide mitigation for this iriMpact. The adoption of a $Qateineen= of
Teasibie mitiaaton that lessens a project's impacts.
PtassElant` trs— cEaa"" nwre;6d 05 m easo Mat ta'"-.
minimize, rectify, reduce or eliminate, or compensate° Tor the impact. Forexample,
crttiiriativrt=ineirteieg-" ;irr�-irt,�a�"r'�' _ ��sttF�s: ,
resources or environments. (o 15370(e))- ° Ail measures ostensibly feasible should be
kicluded.ift the-F-Ej measure shout tied € : Urso: ra-r@asoa'ii ioX `
selection or rejection_ A measure brought to the aliention of the, Lead Agency -sliould
nobe`ie out unless iii irtfesteie ori its face fp �•G t seu�t:nitT
y-
Qkg 11.
t r --- An - g1as til g3 t) 58 Gal: -App:Ar 1019); - liilitigatic&� should be specific,
• rnea$uraizl�.actiQtts.thai allow-rrtohi��tr�errsurs t � tia�-ae�luaiion-
of succ gs.., A mitigation consisting only oi*a staterffe-M of inten-fi n or an unspecified
hapadociau iuttxe-aetfoft-mav-f�ot be-aoeauate��rrsta�i�i�=€��v: ►�sx-;- .
(1998Y., 209 Cal. App. 3d 296).
t tje t�eoaEeet revers i+�tsaltMFF f F aa:=
conservation- easement ,aa otherlranO Gt-aW6a3t egUcl Sim aril quality as the larid A
remove rd from co-ntrect_ lrr-thea..tarrratttve w(vrecmnrimrid,ft:contrtt}tnieefFE3f•ee-akstef*:
mittaaban tees to an orumzati3on, such as--a land lrust::for--the Pu"se of a pofmanon,
aarievfivas-corat; %
Information about-agricullmxa{:conservation ea5�fients;:ttmWiliiamson Act and
provisiofls- noted arF trt� E}ep�ie, o icy coFa.
Division at the address.-and phone numtoerfisted b7elovv:- The=:15,qpartment's websile
address-is.
hft:tlwww.1dIro/indAx_.hln
P • t;
''--
h„+-io-iuliZ.bM-01VI:ION ONF lsl:i• ;Str,.,,pcC ccrzEC:!`�;
iu?oiliiesu r -3B6 PPr�/i)TT F -03e
Mr. Gann STeadon
November:! 89_c*2
Pace E
U"Af ; t�-� r Fr `t
s.rr rr-rs,•t ��_,-
CtUJIVII &1'lld 3EidlRi6r?EaTrQ�?Rtpa(`,ts
tt?at:tiiayrasuftfr~ :las :ri:.yt,6
excavatlOn have not been addressed. The tbllowir? issues should
g discusse ; in
'the
�t=f i arTd'rTP15t'i]B COTiSiGlenp..d tp:d�tRcrF!it@` Ran.�t�r^atm ret 't1341�.�s3r�E
Themr...w.. .,.t n a . I`. -tL .
a L ►,v 1—Pri0ovu SG-,10ufiar'.tbetwgen Llftde-LOhico creek (Creek).and the
proposed excavaaions ShOuld be examined in the El in -terms of future channel
,Inylalit3rl. T IIu-hislyry:of:•channeiiitfianges in �tfe-t:hpO creek should - he.
studied in order to doieemine changes in planform of the creek over time in order
ICT pro—pow all adequate
s7eaCl(.'6r:UUTIST : fC[I'aasasi%TellL of the. pnssibl-a
capture arid diversion of Litile Chico creek and the deposition of bedload
606tMerd..carried-byr tibia Chico Greek. in thepiand Shm9a be_ inckidee& T",e,
iriipaci of ahungry water° on Little Chico Greek downstream of the pit sh=ld be
addressed ifcagture otbeftad matei:{al is likely to occur.
A geotechnical discussion assessing the adequacy of the proposed buffers
should.-baLpmvidad.�TttapmposecsetbackbiAffe ictf v t�r:ns
of their ability to withstand seepage failures. The possible flooding of the batch
PtzM'and ;
chn„Iri enannnn air en 'ono Fhmdj a4 Orr# r,
- - -r-aa
: The'+r3n^�at1.._' cat 4 .1 hr.Lf�e+r++v�°teF+vit ..►. re.. �..
aaerery- tU
:,;§6C,I=nd .^.ve tonni-n 1a,:1.. ns dur:n if....A•.... ,♦ a ba' iate I .......
t't' y � "� r� ��+ •� rC� ..wvlr ,a�. r L ,T,ajr vv apj'ii vjri rate tv ,v-av>r-
Mh_ �r ►1}L� t'�1V\. ./�11't�9I.A �.'\ Lt('/rA 1l YIJYPi.. ►i�A .�. rOwVh�'fA.� C •.w Liwww it.� I
crw•.VVH?M-N•YN�M-e.-.Q..�•LG�[br@e.er+rr+rre-�� r�i+rerrt �irCCR
wd tha, www 10. .nl:nw ath • • de •he •='k-
1*
L fi.._
t3,ry •..e rvr,CS eCjiJaercc, iouli3r than to ei0uv ulv Svet3a n titinolS.
K.w..L• Mw www. - i •w +•r•ww 61..w •...�..� �w,1 .i�...w�L��+�
T r" roc a nc�prtcste t�icerttcc It= �r�rirsw,trattvartrstvr�6 �raEa`6ttta ii1
order to lumil I leadward erosion and dawnsirearn scour processes should ale pit
b6 �zzvttrrere�i-Etetty�7rrite:-atnBlF .
s i- rtl6thOds.iG b@ US@Ct i0 Confirm pit depih.and.siope Gradients should be-
8' -
should rof rni in.� nvnNc._r=Finn
s an^.� .::� r�Baa^:�s nncn
Water lake to Liiti4 ir` O Cfeiek. Lliile�! in`roFinatEt7�i Es yive3n Irr cite %rein.
cone:efoing aquaiie: species icfu 8 irk Liiti� GiirC 4.iee6i.: ii saitiloriids ether he
stream, fish passage and entiaprnen, rnusi be considered. ^Shit es t he lake wiii 'we
awarm wafBt itam,-nQn-"att+e iaiDfv-sgeeie$*f ffmt likeiy become.
established and present a potential threat to saimonias that may enter the creek.
I i �t tjr'vjazmfr atBr-f stt S ffOilf tie WIM- i�it (IAg the- Crsak and
Nrvying on young sair-nonidS Siiwvuld be investigate -U.
4
h i wat���LiF`t1�4`tt�Y "etw It lake- RW-Dw-'540arn-C.*L"cause
deleterious effects on riparian species along and in the stream channel.
Biological effects -to,- rivarian species affected -by - Channel reioeation
must. . 2 Lcm be c-nrc„gideL:red: -
nt.rc- t,M-DWSION OF raun ri•c YRT Dg Crtrw rarF:Imerr T_gnz o nnc/nin' t_,zu
-
iYii . L'di i Ol dwUUj i -
Noveflibef-4 67 20D2
i✓ace i
The ir�itrnuiftrv:watar n17a'itv and prEtrtnri water iccunc ha avNYiMtoY in tF o'R`IA
Recharge basins should pie luny (e-.g, no inkrceplion Cf,gro+,rtd water) toba most
aftectma.- Tt"Eg@Xcalf��rL���'�`-�tFt¢watart�kticrsuitttirra'tawfaatr�{fha'
nracgnf (;rnitnri ctirfara, RgCa:iga !he uratn'r t2hio is roia7iynhr high, httla rcrs=se
in the r�icn_F rsralr� trsC tr n tF.umri�ah nrr. .tion CI(l6"Clt1C56¢ r-fin hM wr:trir_insfaii
Gurthor tido roto r f law nnratinn frnrn aha nnn� c�rrf4r CoQGi� r2inf�lr �r-nnrdinn
. "Y .,. Y� a urao ---
P�t��MrT{t9tir'nntr ren.`7!*-l"f�'�rv�rror' ��Qf•.4'rFu��n�l enr.� nrnr n��:rn�r. n n _ - .
ba anticipated.
fiS:iv� L'il�ne•r-.�w ll"'` .IF' �o iiwa�e�w..Yn�i"x�i-r���c 'vw'�"`ir��i w-str .. L
eiroees�ee•revv�erny--v�.r-i�rnr� �e�o.o`r �txwoy
rc�Caiu%c VIII$ tabor 'tit ilio �ivii7�iuiirvcat s nifuitci.
rP rrri& -9-- --....�wf ff`r ltt�-rO-~ ....1' w.....7.. .1....._. J:r.♦
vv! vtro- vto I v I �ray.rcrrc.. rrtrtrr n rc i
a... e. atlr...�...lan't,`v iriE rivii'i yr t tr c Sr c•Srivuld uc auur.a$Svu. This may `b e--
walpriiwQli1'1Ct11 FI
c-rriicat-irt lar' tvparatirraue7it�frFvyiiiFC3-t�raty+fim-i i ssri rifirirnivvlairi iii .
trot restlr f aceb jj :S- o1 nG rliitTi r� f rt2 �idi� '�S :s{+is` �r G.
REGLAM i i ii. N -PLA6d
The surface iviating and Reclamation Act of 1975 (SW1ARA) (Public tRvSfSurGa�s Gode
seii�[tc71r`sseartE'rEst�r�Failtiiffmin_ _ ia�iorr5riorsuFiac®..
mining ani rectarnAtian-practice (ialitornia-Code'of -Feguh*ons (CC—M) Title 14,
. ChaQt�-t3; -4e-�: se�i��SBB-e4--Seq:; se�r-09=e�s�-�-req�il�=that-a.;
reclamation pian be prepared for the mining operation th* Meets the minimum
DEI? Is: whotiu inadeomte and- Loes trot p_ontain the specific itemsrRquired by-SMARF►
- The' Rediarnafiort; ?tan" das mibad in the DEIN does not desur be how the site will
atw , a1& 2� c+the-ope-ft Wates ,,
and'wetland, habitat that .wilt'be established to benefit w{dlife. Erosion and
t>r2%s rt. The,mciaiviAftn o4'prirrm farmland` ,
to open water is not consisteint`with Williams flet Contract-requirements, as stated in
Departrrter* dei m. date&:,#ffTy-2�,- 1a E
9 Rt'dAmatierc is preseMed itt the DEIR only conceptUatiy; and-tie document sales
- that: F _ -raet a Ica wattand habit
will clopend on many tactors ... ".` The habitat to actually be crawled is no
4r0taDredana1&andicrr144iarr-, [tte remota tativr>F firs�enssiem
includes many non-crommictal statements such as, "Reclamation design includes the .
Wabmifiaf diavviamn f tel
_i-:.."` tttpirfirtai dt'sig wi{lzieae on in a`raitai�iii
of," 3r1A possible. Shoreline edges will be ...'. these `excerpts relate to the
Feov-iii-ZdU[ U3:F6nnr From-DiyfF roi 0IANU RtS-OU E- MTECT [DR. IBtB32 Un r-;trF P.QealRrfr F --q3;
93r [
-...
Nv'vciiiLitf i6, �iiJG
c.,ctors a atki ti
v'irJi racSiyi� �a►.w�a uxsu iii Cio''� v at"i-iiai_ lti6iNli6re,iS-tile SllOreiln@ So be
�raa, kde lir ; at,y •�:, „�" , 'oF' baeldlll-avaiiabie�(Or use ,n creauncr
. a :
,IverSc'S,-Glcline i5 un'S,cted a to unplanned; and Stope profiles-wovided. are oenienF
at i non -co al:" `irk O mmga tm. Cif
guru a5 IhO-Constrimiium of a"'b passe
i.iaTiritsf f6r exatiruty jiviifiGa.�on IMeasury 4.4=7Ei,. is not fii.Cor 0ratRd lrt the .
P�=�:vtatt:
rFiCI Fea' i�iu'aPtd s -i ► div�n��.i,�!nCivae:iha•ievoi of daiaii-required of ? rec-isma�?
ii.. F"i" }c�,�u�+s1 6•.v..,:e 1. i "p— ..'�i•acjj.,4
�1�f! rp }"L. �.`af'i tJt7• cif`ICCaftVCJ �Jp��Cp{�i f%�;5 ritCrt4Liiaiis ba
C-Offsis�w6Ilat7howt-} onthe
-.•
plan:: The smut— of :the €apagrapbic cu-niours p;e,sentlad !Ypouii3 be stated and
ri►kiss''v�erlfj/-crkszt'�,ed-ptote'ssior� f}E�OfR�ed-�srcirve�t aflcri#1a� gam-
DoncitrtFt Can be reproduced.
r! !t ic`w"ir iK',io„ vSiE is ;irii� be�iftsitet� iFr iFie ree4a{FOFr p1aFT f St1t.:
secilor, 27.116) f -ir - Tile staMm- ii•tthat:ft sits•..wit- ba mfiapd "over a 20 l( 30
v+eaf Fifth.& is-- i isui�teier,1i:
�/vf' S7Ci:5 •TIfa p�a gt1 faifs-tG 6.eF.�. y`,G
p7vii•iCic a'S dviii ��<it ►Cil tr to ++�cL�'tti'vc w'ver .^-"liable
16-4.6 eAd ute--otR4EV'theFais--itOS deacfip6ofi•"6 �iasei+Fly sftlivta^st vBtifliei?2iit� '
cover, ddnsity an,,.d� suecies richness.'..' -
dr WE4 LQ
dei' , „;� a tt;e %AaGNlthu cr ted'-wiidiife habitat-
�F'r:tt Togseir fewtftt av-Fret-meed-m�. r afe4han or,c_veal.
frThe r6ctarrtatm'p;an does ►Mtdescritma ;mer ft ;urp,�.ee�i,;,.w,iiii be rem ved.
�d�-
•' �4rGi.Yr-ti3(�).'6 '�'f5c�iS"idPi��raii C.�itiraGii:io`j/. '
The resclafriatiE?�plan-Siat6S-thaF; °
sWara10 UrWr and aui piaced on Firms surra ce fir-reda#aed�land ... Bili? alS6
' e... a fes. y,
steams:Wttat ... a iHe :v�en,�r,►o�c eFTt Eat sFin''tr, the PIC tl" Fl*Grm will be.
e�r • 'tI CW hTs" arrrd V-16 s r " is r twt�i i bv-Fr€ac;ea:.Crci${ie Suilace." Prime
a ieteater salts'rtt b®-segregated-irtto-Arand t 0`to4zons.
•• tMEf ifiiJ(t�)'F li@iE "i5 fit; riTEPrfi�rl cifi'ttsYPiSto assess ling is,ethods and
rte» ati=i. prncedures-
CCR 37sS(g) I cr PEci"tt i o r, pIaiYfiaiIs 10 pri v dp- a aiiv`a pr8SciipI n
describing-Spft-ies-ioF eaeh Fe�c a#i6n-a€ea '
�'37o54rr1).NG perform. ance standards are presentee in the rectanation
Man; Performance staAdaf&c ,-are-FeouiM4 for agricultural lands and for �%iidlife
habitat.
Erie r»la mafiert plarr -te-he- lliamson AEt"and.
SMARA. Please forward a Copy of the revised mart to ONIR for review pursuant lc
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