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Tina Wehrmiester December 11, 2000 Page 3 Resoiling and Revegetation (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),Q),(k),(I),(m), 3707(b),(d), 3711(a),(b),(c),(d),(e)) 8. CCR 3711(b) requires that the location of the topsoil stockpiles be depicted on a map. In addition, CCR 3711(d) requires that the topsoil stockpiles be clearly identified in the field and protected from wind and water erosion. The topsoil stockpiles could be planted with vegetation such as a non-invasive sterile cereal or legumes that would fix nitrogen. Alternatively, a gravei mulch placed over the stockpile could be used as erosion control. The reclamation plan must contain information regarding these mandatory sections of the CCR. 9. The reclamation plan states that excavation will be limited to 5' outside the dripline of any existing trees and in the notes on the site plan, it is stated that the excavation setback will be 25' from the dripline of the trees. The setback length should be clearly stated in the reclamation plan and depicted on the site map. It is well documented that the roots of many trees, particularity oak trees, extend well beyond the dripline of the tree. The roots of oak trees extend three time the length of the drip line (Doug McCreary, Oak Conservation Resource Specialist, University of California, personal communication). Depending on the type of grading, Mr. McCreary stated that where a gentle grade exists, a buffer of the "dripline and one half' would serve to fully protect the trees. 10.The reclamation plan notes state that the final slopes will be seeded with native grasses. The species that comprise the mix and the seeding rate must be stated in the reclamation plan. 11.The reclamation plan states that the site will be reclaimed to a walnut orchard. CCR Sections 3707 and 3708 address reclamation of agricultural lands. CCR Section 3707(c) requires productivity rates equal to pre-project, or a similar site, for two consecutive years and the rates set forth in the reclamation plan. CCR Section 3708 requires that non-prime agricultural lands be reclaimed so as to be capable of sustaining economically viable production of crops commonly grown in the surrounding areas. Since walnut trees take years to reach maturity and peak productivity, establishing productivity rates may not be a feasible method to assess reclamation success. The reclamation plan must provide a method to assess revegetation success and the release of the financial assurance. We recommend that the survival rate of the walnut trees be used as performance criteria and stipulated in the reclamation plan. Monitoring should continue for at least 5 years or until the trees are established.