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C-1981-008 July 23, 2010 <br />PR-06 Page 14 of 31 <br />iv. Note 1) refers to Subsection 11.2.1 for topsoil balance calculations. This subsection <br />was not included in the text for 2.05.4(2)(d). Please revise the text accordingly, or <br />eliminate this note. <br />Note 2) states that February 2008 is the date from which all Bench 1 material will be <br />retained on the Morgan property. Please correct the date referenced to be May 2010. <br />Please add a new note at the bottom of the map which states, in effect, that following <br />the redistribution of topsoil which has been stockpiled, the surface of the stockpile <br />footprint will be ripped, scarified, etc. in accordance with the Section 2.05.4(2)(d) <br />Subsection 13.1 prior to topsoil being replaced over the area. <br />b. New Map 2.05.4-7 has been provided to illustrate current and proposed topsoil replacement <br />thicknesses by "Zone" on the WFC, Lloyd and Benson parcels located west of 2700 Road <br />and north of BB Road. As of June 2010, topsoil has already been placed on the entirety of <br />the Benson parcel and the eastern two-thirds of the Lloyd property. These areas comprise <br />"Zone 6". "Zone 7" currently incorporates the remainder of the area, with the exception of <br />the WFC prime farmland, which is identified as "Zone 8". The thickness of mixed topsoil <br />already placed across Zone 6 is given as an average of 21 ", while the average thickness <br />projected for Zone 7 is only 13". Given this disparity, the Division requests that a new <br />"Zone 9" be proposed by subdividing the area currently comprising Zone 7. Zone 9 would <br />incorporate those areas that are not likely to be irrigable, due either to slope steepness, or to <br />lack of water availability (please refer to Item 45.c. in this letter). Reducing the topsoil <br />thickness to 6 inches across Zone 9 would result in greater topsoil availability for the Zone 7 <br />areas with the potential to be irrigated at some future date. No rock fragment restriction <br />would apply to spoil or topsoil placed in the proposed Zone 9. <br />With respect to New Map 2.05.4-7, the Division notes the following: Ponds 009, 012 and <br />013 are riot included within the boundaries of any reclamation Zone, and no topsoil <br />stockpiles are identified for use in reclaiming Pond 009 (on the NE corner of the Benson <br />property) and Pond 013 (NW corner of WFC property). The information regarding <br />Stockpile #22 appears twice in the lower half of the map sheet. <br />The small (2.83 acre) area of long term disturbance where Pond 13 is currently located, and <br />which will not be reclaimed as prime farmland irrigated cropland under the amended plan, <br />will be reclaimed as dryland pasture. Logically, the pond disturbance area would be <br />included in topsoil replacement Zone 7, but in fact the long term pond disturbance area is <br />not included within any specified replacement zone on Maps 2.05.4-4 or 2.05.4-7. Please <br />address this apparent discrepancy, and amend the two maps and relevant text as warranted. <br />d. The Division requested that a new Section 2.05.3(5) be developed for the permit to address <br />the requirements of Rule 2.05.3(5). Rather than create an entirely new section, WFC has <br />inserted a new paragraph at the beginning of Section 2.05.4(2)(d), stating that, "topsoil <br />handling and stockpiling requirements of Rule 2.05.3(5) are addressed in this Section". Not <br />all of the :requirements of Rule 2.05.3(5) are addressed in the section modified. Stripping of <br />topsoil is described in Section 2.04.9 - Subsection 16. Please add a new sentence to the