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Gregoria Garcia <br /> Jennifer Jolley <br /> November 18, 2002 <br /> Page 2 <br /> Mining Operation and Closure <br /> (Refer to SMARA R Section 502(b)(2), (b)(5),3709(a). (b). 371(3(a),()b))) (c)(8), (c)(9), <br /> 1. SMARA Section 2772(c)(9) requires a discussion of the impact of reclamation on <br /> mining in the surroundinq area_ The reclamation plan should include this <br /> discussion. <br /> End Land Use <br /> (Refer to SMARA Section 27c)(7), (c)(8),CCR Section 3707 (a), (c), 3708) <br /> 72( <br /> 2. Productivity rates for the agricultural end use are not stated. CCR Section 3708 <br /> requires that performance standards for non-prime agricultural lands shall be <br /> reclaimed so as to be capable of sustaining economically viable production of <br /> _ crops commonly grown in the surrounding areas. For an end use of grazing,we <br /> recommend performance standards include an animal unit month (AUM). An AUM <br /> is the amount of forage needed to sustain one cow and her calf, one horse, or five <br /> sheep or goats for a month. The County Agricultural Commissioner can be <br /> contacted for the AUM. <br /> Geotechnical Requirements Hydrot� and Water Quay <br /> (Refer to sMARA Sections 2772(c)(8),2773(a). and 370 Se @(s) (b)(3)(9),37), (b(a)(b),(c)(3712)(a)(3) <br /> (b)(t).(b)(2), (d).(a),3704(a), (b),(d). (e),(fl <br /> 3. The hydrology study indicates that two hydrologic sub-basins drain to the site <br /> that total 447.3 acres, yet no discussion of how that drainage will be collected <br /> and conveyed to the pit floor is included in the mining and reclamation plan, nor <br /> does the plan reflect how the drainage will be handled. This appears to be a <br /> major omission both in the reclamation plan and Negative Declaration. <br /> 4. Performance criteria should be included in order to identify how much erosion <br /> can be tolerated in reclaimed areas before implementing erosion control <br /> treatments. Such criteria may state, for example: "erosion of rills greater in <br /> cross section than 5 square inches exceeding 5 feet in length will be arrested by <br /> placement of graded rock interceptors or straw bales to slow concentrated runoff <br /> within 1 week following any rainfall event' <br /> 5. The plan proposes to mine the slopes at 1.5h:1v, with <br /> one f of ter From <br /> at <br /> elevation 215 (msl). The overall slope would be ptel ed a variety of slope <br /> observation of mining projects that have incorporated <br />