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Channel Monitoring Plan <br />This plan was submitted during 7anuary of 1997, as requested in the permit. <br />The plan said that Sandco had established eight sections where it expected to mine during <br />the next season, and that Sandco would establish other sections as the mined area grew. <br />USACE formally accepted the plan, ensuring that baseline surveys would not be <br />conducted throughout the pit in late 1996 or early 1997. <br />Plan was silent on all other points in permit, which were not modified by plan <br />acceptance. <br />4.3 Compliance with Documentation Requirements and Recent Requests <br />• Baseline thalweg elevations were established during December, 1996 in upper part of pit <br />and December, 1997 in lower part (Table 3). <br />• In its yeazly "Channel Monitoring Reports," Sandco generally provided plots of cross <br />sections only if that section had been mined during the year (contrary to permit <br />requirements and the Lidstone & Anderson report). <br />• The plots generally showed full pre-mining and partial post-mining surveys (slight <br />misregistration suggests these were often along slightly different alignments). <br />• On 10/21/03, Sandco provided tabulaz numeric data for these plots and for 24 more pre- <br />mining surveys not provided previously for mining seasons as early as 1997-1998. <br />• Permit and Channel Monitoring Plan require 104 late summer orpre-mining surveys <br />(through spring 2003), but 84 were done (Table 3). <br />~ Permit and Channel Monitoring Plan require 104 spring orpost-mining surveys (through <br />spring 2003), but 56 were done. <br />• Permit and Channel Monitoring Plan require 7 late summer or pre-mining lohgitudinal <br />profiles (through spring 2003), but two were done in1996 (upper part of pit only) and <br />2002. <br />• Permit and Channel Monitoring Plan require 7 spring orpost-mining longitudinal profiles <br />(through spring 2003), but none were done. <br />• Sandco never provided inter-annual comparisons or analyses of its survey data until this <br />fall. <br />• Sandco never provided other monitoring information or the comprehensive 5-yeaz report <br />as proposed by Lidstone & Anderson (1996). <br />4.4 Compliance with Mining Requirements <br />• In a majority of mined cross sections for each yeaz, the base of excavation was apparently <br />below the 1996-1997 baseline (or thalweg) elevation. My analysis indicates some <br />excavation below that level roughly 70% of the time, at least one foot below roughly 57% <br />of the time, and at least 10 ft below roughly 2% of the time (Table 4). <br />Gillam to Hellige, Nov. 28, 2003 <br />page 9 <br />