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i <br />Mike Boulay -37- April 11, 2011 <br />81. Please refer to Item 3 of this letter, under "Site Description and Land Use <br />Information" regarding requested map and narrative clarifications pertinent to both <br />premining and postmining land uses. Provision of separate premining and <br />postmining maps may be warranted for clarification, as noted in Item 3. <br />CAM: Comment noted, and addressed in Site Description and Land Use section. <br />82. In section 2.04.3(2)(b), narrative states that "the barren lands east of Reed Wash <br />are limited to some future industrial use", and narrative in Section 2.05.5(2)(a)(iii) <br />states that industrial use is considered to be the highest and best use of the lands <br />to be reclaimed to the east of Reed Wash. Please include further discussion <br />pursuant to 2.05.5(2)(a), addressing the utility and capacity of the lands east <br />of Reed Wash within the permit area, and why a future industrial use is the <br />highest and best use of the lands. Consider revision of the "Industrial" land use <br />boundary to coincide with the Previously Disturbed Lands perimeter, or provide <br />justification for designation of Reed Wash as the boundary between "Industrial" <br />and "Fish and Wildlife Habitat" land use areas. <br />CAM: The "Industrial" land use boundary has been changed on Map-07 to <br />coincide with the Previously Disturbed lands perimeter. The highest and best use <br />of the land is Industrial because that is what currently exists, and how the land is <br />zoned with the County. As discussed in section 2.04.3, the site adjoins the former <br />Fruita Refinery to the east. To the south there are former evaporation ponds and <br />undeveloped areas and in the future south of the permit boundary a gravel pit is <br />planned. The land east of Reed Wash is currently unused and is a remnant of the <br />former petroleum refinery operations to the east. There is a 39-acre landfarm <br />area consisting of former evaporation ponds. There are odor issues associated <br />with this area and the surface soils appear to be sterile since they are completely <br />devoid of vegetation. It would not be practical to have a future land use of fish and <br />wildlife, or rangeland for that matter as the area clearly has an industrial past and <br />clearly will have an industrial future. Therefore, based on the past use of the site, <br />the industrial pre-mining and post-mining land use zoning from the County, and the <br />odor issues associated with the site, Industrial is the highest and best use of the <br />lands. Please see revised pages 2.05-40 and 41. <br />83. The type of support activities that would be needed to achieve the industrial land <br />use are not addressed, beyond the statement that the use would be achieved by <br />reclaiming the disturbed area in accordance with Section 2.05.4. The fact is that <br />unless/until a specific postmine industrial use for the site is determined, details <br />regarding necessary support measures cannot be known. However, at present, <br />reclamation of the site to support a future industrial use would entail facilities <br />removal, site grading, burial or coverage of exposed industrial wastes, and <br />establishment of a stabilizing vegetation cover. Please include explanation <br />using language similar to the above, within the narrative of Section 2.05.5.