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<br />e <br /> <br />e <br /> <br />e <br /> <br />Stephen Rohlf <br />April 4, 1994 <br />Page 2 <br /> <br />Reclamation <br /> <br />The document generally construes reclamation to mean the stabilizing of slopes and the re- <br />establishment of vegetation. As indicated in several places, various permits will require the <br />mining companies to take these actions to prevent erosion. Reclamation, however, is a <br />much broader concept than the re-establishment of vegetation. Reclamation in this sense, <br />especially in the case of a gravel mining district covering such an extensive acreage, should <br />be a planning exercise that is aimed at directing mining activities toward a well detailed <br />and coordinated end use. <br /> <br />The DEIS indicates that substantial acreage has already been reclaimed by a number of <br />companies. The current reclamation status of these areas should be fully detailed. This <br />analysis should be coupled with an assessment of how the existing reclamation conditions <br />fit with an overall reclamation plan. The DEIS provides a projected schedule for <br />progressive reclamation throughout the life of the mining activity, with some reclamation <br />expected to occur as early as 1994 or 1995. A generalized reclamation plan should be in <br />place to guide all progressive reclamation efforts. <br /> <br />We recognize that it is not possible to predict the future in great detail, thus annual <br />planning for reclamation as minin~ advances by means of a city permit is a practical way to <br />deal with it. However, the diSCUSSIon throughout the DEIS suggests alack of a ''big picture" <br />view of final reclamation and end use, and the document could be viewed to present an <br />impression that reclamation will be handled piecemeal on an annual basis.with each <br />individual company. We strongly recommend that long-term planning should.begin now so . <br />that reclamation is a coordinated process among all the mining companies throughout the <br />life of the mining district. A timetable for reclamation planning should parallel the <br />time frame presented for the transportation plan. <br /> <br />Tables 2.1-1,2.2-1,2.3-1 and 3.1-2, 3.1-3, 3.1-4 <br /> <br />The tables depicting the changes in land use under each alternative are confusing as <br />presented. Do the numbers in the "Trees Within CBS Site" column refer to County <br />Biological Survey site-acres expected to be impacted by mining activities? It is also unclear <br />whether or not the numbers in the tables are cumulative. For example, will 60 total units <br />(acres?) in a CBS site be impacted under Alternative B or will 90 units be impacted, (which <br />is the number reached by adding the Stage 0, Stage 1, and Stage 4 values provided?) <br /> <br />Section 3.1 Land Use <br /> <br />,. <br /> <br />The document indicates that there are 20 residences, 12 of which are occupied, located <br />within the proposed gravel mining district. Those 12 residences may be the ones most <br />affected by the mining operations. It is appropriate to address in limited fashion the <br />special concerns these people may have and what the final disJ?osition of these properties <br />will be (Le., is there interest on the part of the mining compames to purchase?). <br /> <br />There is essentially no discussion in the document regarding mine waste. Is mine waste <br />going to be produced, most likely in the form of overburden, undersize and oversize <br />materials? If so, the EIS should indicate what volumes will be produced and how it will be <br />used or disposed. For example, will mine waste be used in the creation of final landforms <br />