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i o l Ms. Kerry Sullivan ' December 23, 1996 Page 2 End_Land Use (Refer to SMARA Section 2772(g),(h), CCR Sections 3704(e),3706(a), 3707(a),(c), 3708) 2. The project is located on prime agricultural land. Apricots were once grown on the site, but have since been removed. The reclamation plan proposes to reclaim the pit floor to ' 1 agricultural uses. CCR section 3707 provides performance standards for prime agricultural land. The standards require that prime agricultural land be reclaimed to a M productivity level equal to or:greater than pre-mining levels or to levels based upon productivity levels for simila j`crops in the area. To demonstrate successful reclamation, the productivity levels should be maintained over two consecutive growing seasons. N The Department recommends that the reclamation pian address this requirement of the iCCR and propose specific agricultural performance standards for the project site. € n 3. The Department recommends that the reclamation plan describe what plants will be I used as cover craps for the pit floor prior to establishment of the final agricultural crop. I Geote hnic ll Requirements a (Refer to CCR Sections 3502(b)(3), (b)(4),3704(a),(b),(d),(f)) 4. In order to adequately evaluate the stability analysis, additional documentation is . ' needed. Using PCSTABLE6 computer program,.OMR examined the stability analysis provided in the reclamation plan. PCSTABLE6 calculated a static factor or safety of 1.1 and a pseudo-factor if safety if 0.8 for an overall final slope of 2:1 (horizontal to vertical) that is 125 feet high. Therefore, the proposed interim and final slope may not have the required minimum factor of safety. Additional documentation is needed to clarify these discrepancies in factor of safety. It is not clear if water was considered in the stability analysis. The stability analysis should be supplemented to consider the affects of seepage form the near-by canal. � !I The stability analysis should'clarify if fill or cut slopes were analyzed. The reclamation plan states that the inter-bench slopes will be mined a 314:1 and final inter-bench slopes will be 1.5:1. It appears that the final slopes will be fill slopes. A cohesion of 500 psf may not accurately reflect compacted fill material. Therefore, the stability analysis should provide compaction and shear test data for any fill material used to construct the fill slopes. In addition, the reclamation plan could be augmented to discuss fill slope constructionmethods. Environmental Setting and Protection of Fish and Wildlife Habitat (Refer to CCR Sections 3503(c),3703(a),(b),(c)) 5. The project is within the range of the San Joaquin kit fox and on the border of the San f Joaquin kit fox Habitat Conservation Plan (HCP). The California Department of Fish y and Game (DFG) and/or U.S. Fish and Wildlife Service (USFWS) can assist you in determining if kit fox mitigation is applicable to this project. k 1 ° 6. The reclamation plan proposes to control rodents "using methods common to the i agricultural practice of thea`ea." Rodent control measures using poisons can result in direct poisoning of the kit fo I as well as kit fox mortality through ingestion of poisoned ground squirrels. DFG and USFWS can assist by reviewing this proposal to ensure that inadvertent take of listed species is prevented. ,.