2008-03-14_REVISION - C1981038 (2)

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There are apparently two contradictory plans in the application regarding revegetation of the approximately 40 acres of disturbed land within designated Cropland land use area associated with the loadout facility. One plan is for orchard reestablishment, and a second plan is for establishment of irrigated grass hay cropland. Orchard Reestablishment On page 71i of the Reclamation Plan (Section 2.05.4(2)(e)(ii)), narrative indicates that selected species of fruit trees will be planted "at the standard orchard density". Notation indicates that the page was amended "02/04". The brief statement is followed by a reference to "Vegetation Report, page 30...in the Vegetation Appendix, Volume 9A". In the Volume 9A Vegetation Appendix report, there is generalized discussion of planting various species of fruit trees, at specified densities and "whip sizes", along with measures to be used to control ground cover between planting rows. The appendix report also includes Westmoreland Orchards fruit crop production data for 1977 through 1980, and reference to possible establishment of success standards based on theoretical fruit crop yields as a function of time. Planting of fruit trees in orchard cropland areas is also referenced in the second paragraph of page 82 of the Reclamation Plan. Irrigated Grass Hay Cropland Permit Volume 7 is a comprehensive operation and reclamation plan for the loadout, which was apparently submitted as a technical revision in 2001. The revegetation plan presented in Section 2.05.4(2)(e)(ii) entails planting of a "premium irrigated pasture mix" of brome, orchardgrass, and perennial ryegrass. The plan includes a generalized irrigation plan involving sprinkler irrigation initially and flood irrigation following grass establishment. The plan mentions fertilizer application prior to seeding, and states that amount and type of topsoil is unknown. The narrative also indicates that success would be based on production measured in an adjacent hayfield reference area, but it is not evident that such reference area has been secured, approved, and incorporated into the permit. Confusingly, there is an Exhibit 5 included in Volume 7, which refers to plans for orchard reestablishment and the potential time/yield approach for establishment of a success standard. In summary, the revegetation plan for the loadout cropland postming land use area is confusing, contradictory, and poorly defined. Submittal of a technical revision application to clarify the proposed loadout revegetation plan and eliminate outdated information is warranted. The application will need to provide additional detail regarding topsoil acquisition and replacement, or alternatively, a plan for amendment (e.g. fertilizer and organic matter incorporation) of on-site 5