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~ 5 ~ Staff Recommendations <br />i~i <br />S[-IB AGRA Project E92-7075 <br />Page 5 <br />Southdown will create 20 acres of wetlands in the prairie reclamation plan, and the current <br />reclamation plan includes 37 acres of wetlands. All of these wetlands are to be banked for <br />mitigation, if necessary. Southdown does not desire for the Canal to be lined east of County <br />Road 47 and Northern has complete jurisdiction on any lining in this segment. <br />Southdown's wetlands policies are as follows: <br />• wetland mapping will be updated every three years, and the mapping will be <br />reviewed and approved by the US Army Corps of Engineers (to include aerial <br />photo documentation), <br />• wetland mapping, current to each three year period, will be used to determine if <br />wetlands will be impacted, <br />• if it is determined that wetlands will be impacted, Southdown will apply for the <br />necessary permits, <br />• wetlands adjacent to project operations will be field staked by a wetland specialist <br />and fenced to insure that wetlands will not be inadvertently impacted, <br />• Southdown retains the ability to implement its property rights in regard to wetland <br />impacts, subject to wetland regulations, including requests to ditch companies to <br />fine and properly maintain their ditches that impact Southdown's property. <br />STAFF COM]~~IENT 6. The western limit of the mine area shall correspond to the <br />vegetation boundary between the Limestone Ridge grassland and the irrigated pasture <br />irrunediately to its east. No mine operations or roads shall be permitted on the Ridge. <br />Limestone ridge is the critical mineral resource that Southdown is seeking approval to mine. <br />Comments from David Buckner, PhD., regarding this issue are attached. 1n summary, <br />Southdown believes that no irreplaceable resources are lost by mining this ridge. A reasonable <br />plan of reclamation and mitigation would include use of live topsoil from the ridge in the <br />reclamation plan, including limestone derived soils. Live topsoil will retain the viable seed base <br />contained in the existing plant community. Southdown also reaffirms that not all of the ridge <br />will be mined (refer to Exhibit C-2 in the CMLRB 112 permit application). <br />No reclamation piles will be placed on the west flank of limestone ridge (such piles were <br />planned on the west flank of the ridge to visually screen the mine from the relocated County <br />Road 47) if the County selects the prairie reclamation plan. <br />AGRA <br />Earth & EnviionmentalGmup <br />