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Z 1981-038 TR-48 <br />2"d Adequacy Review <br />09-Jun-2008 <br />SMCRA or associated state reclamation laws and regulations. The area is a "grand-fathered <br />" <br />alluvial valley floor, and topsoil was not salvaged prior to disturbance. The AVF was flood <br />irrigated cropland (apparently fruit orchard) prior to disturbance and the predominant soil type <br />was Aqua Fria stony loam, 3-12% slopes, which NRCS has identified as a soil type that supports <br />"Farmland of Statewide Importance ". <br />There are apparently two contradictory plans in the application regarding revegetation of the <br />approximately 40 acres ofdisturbed land within designated Cropland land use area associated <br />with the loadout facility. One plan is for orchard reestablishment, and a second plan is for <br />establishment of irrigated grass hay cropland. <br />Orchard Reestablishment <br />On page 71 i of the Reclamation Plan (Section 2.05.4(2) (e) (ii)), narrative indicates that selected <br />species offruit trees will be planted "at the standard orchard density ". Notation indicates that <br />the page was amended "02104 ". The brief statement is followed by a reference to "Vegetation <br />Report, page 30... in the Vegetation Appendix, Volume 9A ". In the Volume 9A Vegetation <br />Appendix report, there is generalized discussion ofplanting various species offruit trees, at <br />specified densities and "whip sizes ", along with measures to be used to control ground cover <br />between planting rows. The appendix report also includes Westmoreland Orchards fruit crop <br />production data for 1977 through 1980, and reference to possible establishment of success <br />standards based on theoretical fruit crop yields as a function of time. <br />Planting offruit trees in orchard cropland areas is also referenced in the second paragraph of <br />page 82 of the Reclamation Plan. <br />Irrigated Grass Hav Cropland <br />Permit Volume 7 is a comprehensive operation and reclamation plan for the loadout, which was <br />apparently submitted as a technical revision in 2001. The revegetation plan presented in Section <br />2.05.4(2) (e) (ii) entails planting of a "premium irrigated pasture mix " of brome, orchardgrass, <br />and perennial ryegrass. The plan includes a generalized irrigation plan involving sprinkler <br />irrigation initially and flood irrigation following grass establishment. The plan mentions fertilizer <br />application prior to seeding, and states that amount and type of topsoil is unknown. The <br />narrative also indicates that success would be based on production measured in an adjacent <br />hayfield reference area, but it is not evident that such reference area has been secured, approved, <br />and incorporated into the permit. <br />Confusingly, there is an Exhibit 5 included in Volume 7, which refers to plans for orchard <br />reestablishment and the potential time/yield approach for establishment of a success standard. <br />In summary, the revegetation plan for the loadout cropland postming land use area is confusing, <br />contradictory, and poorly defined. Submittal of a technical revision application to clarify the <br />proposed loadout revegetation plan and eliminate outdated information is warranted. The <br />application will need to provide additional detail regarding topsoil acquisition and replacement, <br />or alternatively, a plan for amendment (e.g. fertilizer and organic matter incorporation) of on-site <br />materials to provide a productive agricultural growth medium. In addition, the plan will need to <br />address management details with respect to annual irrigation and fertilization rates, irrigation <br />layout, harvest methods, tillage operations, weed and pest control, fencing, and other practices <br />4