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Dr. Snow/Mr. Larrouy July 9 , 1990 Page Two For reclamation of prime agricultural lands, topsoil should be stockpiled by layers, and kept separate from subsoils. The replaced subsoil should be underlain by a layer of gravel to facilitate drainage. The depth of removal, stockpile management, and method of replacement are crucial for agricultural development of reclaimed lands. This information should be detailed in the reclamation plan prior to approval. 3 . CCR Section 3503 (8) addresses revegetation and states that proposed methods should be appropriate for the site. Once again, the Draft EIR states that a revegetation plan will be 4 developed at a later date; therefore, the plan cannot be evaluated at this time. The reclamation plan should detail the species to be planted, the rate of seeding or density of planting, the location of revegetated areas, the type and size of the plant materials to be used, proposed soil amendments, methods for protection from predation, etc. This is especially important for disturbed riparian and other critical habitat areas that are to be re-established. Until this information is supplied, the revegetation plan cannot be adequately evaluated. The following advisory comments are offered to the County of San Joaquin in its role as lead agency under SMARA for this project. 1. In Section 3 . 3 . 3 of the Draft EIR, mitigation measure 1 proposes that twenty-four inch to sixty inch box trees be planted for replacement of "certain trees. " The species of the "certain trees" is not specified. It should be clarified whether this replacement standard will be applied only to valley oaks, or if it also will apply to 5 cottonwoods, live oaks, alders, etc. Also, installation of such large trees will require irrigation for at least two growing seasons, yet irrigation was not proposed in the Draft EIR. The operator should consider using a drip irrigation system for the trees, or installing smaller plant materials on the site. 2 . Elderberries which are to be retained on the site should be fenced to ensure avoidance, as is proposed for valley oak 6 trees under Section 3 . 3 . 3 , mitigation measure 4 . 3 . The monitoring program for the resoiling and revegetation plans is also based on future studies, surveys, and submittals and, therefore, cannot be evaluated at this time. Any monitoring program for these disciplines should be 7 executed for five years following implementation. The -results of the -yearly- monitoring should be compared to performance standards developed by qualified individuals in disturbed-site rehabilitation.