2018-12-26_REVISION - M2008078 ‎(29)‎

• Permit No: M2008078
• IBM Index Class Name: Revision
• Doc Date: 12/26/2018
• Doc Name Note: Preliminary - Part 1 of 4
• Doc Name: Adequacy Review Response
• From: J&T Consulting
• To: DRMS
• Type & Sequence: AM1
• Email Name: AME
• Media Type: D
• Archive: No

RE. Prowers Aggregate Operators, LLC. - West Farm Pit-Permit No. M-2008-078
112c Permit Amendment Application (Revision No. AM-01)
Preliminary Adequacy Review Response 12121118
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3) The Exhibit C - Pre-Mining/Mining Plan Map shows a large sediment pond located north of
the wash plant, the northern and western edges of which appear to be very close to the
proposed permit boundary. Please clarify how the operation will maintain and eventually
reclaim this pond without disturbing land outside of the permit boundary. Will the operation
maintain a buffer between the pond and the permit boundary? If so, please include this
buffer on the map.
Response: This sediment pond has been fully reclaimed, including being
backfilled, topsoiled, and seeded. The approved seed mix/rates and seeding
procedures in Exhibit E were used to reclaim the pond. It has been removed from
the map. See the attached revised Exhibit C-1 Pre-Mining/Mining Plan Map and
photos of the reseeded sediment pond area.
4) The Exhibit C - Pre-Mining/Mining Plan Map shows the proposed western permit boundary
to be very close to the western edge of the wash plant/stockpiling area. The current
approved permit boundary includes more space in this area. Will the revised western permit
boundary allow enough room for mining and reclamation activities to occur in the wash
plant/stockpiling area without creating off-site disturbance?
Response: Yes, the revised western permit boundary allows sufficient room for
mining and reclamation activities to occur in the wash plant/stockpiling area
without creating offsite disturbance.
5) The Exhibit C - Pre-Mining/Mining Plan Map shows a series of sediment ponds in Phase
13 which overlap the proposed mining limit for the South Mining Area. Please explain
and/or correct the location of these ponds on the map.
Response: The sediment ponds have been constructed to assist in treating the
water discharged from the wash plant. A portion of the ponds is outside the south
mining area limit. The portion of the ponds outside the south mining area limit will
be backfilled prior to the extraction of the sand and gravel within the south mining
area limit in that area. Costs for backfilling the ponds has been included in the
reclamation bond estimate calculations. The portion of the ponds within the south
mining area limit will be mined through during the extraction of the sand and
gravel in that area.
6) The Exhibit C - Pre-Mining/Mining Plan Map includes the feature "Phase 1A Stockpiling
Area" with an arrow pointing to the northern edge of the South Mining Area. This appears to
be an error. Please explain and/or correct the location of this feature on the map.
Response: The label has been removed from the map as the amended phasing of
the mine has changed and the label no longer relevant.
7) The Exhibit C - Pre-Mining/Mining Plan Map shows portions of the proposed permit area to
include land identified as "Conservation Easement". Please provide more details on this
easement. Has the easement owner been notified of the proposed expansion of the permit
area?
Response: The properties on which the conservation easements (two) are
recorded are owned by GP Irrigated Farms, LLC, which purchased the properties
on April 25, 2013. See the attached Special Warranty Deed. The conservation
easements prohibit the gravel reserves in the easement area from being extracted.
Both GP Irrigated Farms and the easement holder(Greenlands Reserve) are aware
of the proposed expansion of the permit area. See the attached conservation
easements deeds.
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