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If the analysis determines a shadow or mounding effect will occur off site impacting a groundwater <br /> user,the Applicant must explain all mitigation measures to be implemented and trigger points which <br /> would put mitigation measures into effect. Typically, a trigger point of a 2 feet change from historic <br /> ground water levels is acceptable. The mitigation measures must include a scenario for the installation <br /> of a French drain to direct groundwater around the clay liner and restore groundwater levels to the <br /> historic elevation in area of groundwater mounding. <br /> The AWES evaluation and report of 16 March 2016 states that impacts from the proposed lined <br /> ponds to the on-site and surrounding hydrology are de minimus. <br /> 10. A copy of the Water Impoundment Hydrology dated July 1, 2010 by CGRS was included in the <br /> amendment application. The report does not appear to be related to the Western Sugar amendment. <br /> Please explain why the report was included with the amendment application. <br /> Reservoir water elevations at the completed Western Sugar basins will approximate the upper <br /> elevation of the known groundwater table. Reservoir water elevations at this level will not create the <br /> hydrologic head necessary for shadowing and mounding to occur. The 1 July 2010 report affirms this <br /> empirical relationship built upon the experience of past analysis of similarly sited locations. Further, <br /> even if reservoir elevations were elevated above this level,if temporary, the time necessary for the <br /> head difference to affect the surrounding hydrology would not be manifest. <br /> 11. Please state if all the registered alluvial wells within 600 feet were identified based on SEO records and <br /> if field inspections were conducted to identify all wells within 600 feet. <br /> Refer to approved Well Permit (# 75865f),included with this submittal. A copy of the notification <br /> sent by the Office of the State Engineer as part of the well permit application is also included with <br /> this submittal. <br /> 12. Please state if the Applicant is pursuing agreements with the existing well owners within 600 feet of <br /> the site. Please provide signed copies of the agreements,if available, or provide evidence the <br /> appropriate notice was provided to the well owners. <br /> Refer to approved Well Permit(# 75865f),included with this submittal. A copy of the notification <br /> sent by the Office of the State Engineer as part of the well permit application is also included with <br /> this submittal. <br /> 4 <br /> Varra Companies, Inc. Western Sugar Project OMLR M-2010-049 <br /> Correspondence to Peter Hays 9 May 2016 <br />