HomeMy WebLinkAboutBOCC Staff Report 06.20.2005Exhibits for Encana, High Mesa Facility SUP Public Hearing held on June 20, 2005.
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Mail Return - Receipts
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Proof of Publication
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Garfield County Zoning Regulations of 1978, as amended.
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Garfield County Comprehensive Plan of 2000
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Project Information and Staff Comments
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Encana High Mesa Facility SUP Application
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PROJECT INFORMATION AND STAFF COMMENTS
TYPE OF REVIEW
APPLICANT
LOCATION
SITE INFORMATION
EXISTING ZONING
BOCC 06/20/05
MLB
Special Use Permit for "Processing, Storage
and Material Handling of Natural Resources"
Encana Oil & Gas USA, Inc
The subject property is located in N1 /2,
Section 36, T.7S., R96W of the 6th P.M.,
generally located approximately 4 miles south
of Parachute off of CR 304.
30.45 acres
Agricultural/Residential /Rural Density
(A/R/RD)
ADJACENT ZONING AIR/RD
I. DESCRIPTION OF THE PROPOSAL
The application is for "Storage, Processing, and Material Handling of Natural Resource" in order to
construct a series of three (3) lined water storage ponds on a 30.45 acre property owned by Encana
Oil & Gas USA, Inc located approximately 4 miles south of Parachute in the High Mesa area, along
County Road 304.
The proposed storage ponds will serve as a holding pond where produced water generated from
natural gas drilling operations in the area can be stored and evaporated. The proposal includes
pipelines and tanker trucks to haul or transport produced water from drilling sites to the subject site
where the water is skimmed to remove petroleum constituents at a portion of the site with storage
tanks and a separator. In the initial period of project, water will be hauled to the site by truck.
Eventually, fresh water will be piped to the site from the Colorado River. These treatment tanks
will serve as the primary separation point for lighter than water hydrocarbons and heavier than water
solids/ paraffin/ wastes /oils ( "petroleum constituents "). These tanks are also called separators where
natural separation process allows the solids to be skimmed off the produced water then be hauled
away for disposal while the produced water is pumped (from a pump located in an enclosed pump
house) directly into the storage pond for reuse in drilling operations. The proposed ponds will be able
to contain approximately 302,000 barrels of produced water at capacity. The Applicant asserts that
this facility will reduce the need for water hauling trucks to travel around the High Mesa area. The
facility will operate 24 hours a day, year- round, although most of the hauling will occur during the
daylight hours. Access to the site is proposed to be via CR 304.
An evaporation pit that contains, treats, and evaporates this water is dealt with in Section 908
Centralized E &P Waste Management Facilities of the COGCC rules. The applicant has included
their application to the COGCC for a Centralized E &P Waste Management Facility. These rules
also require that operators may be subject to local requirements for zoning which meant a Special
Use Permit was required for the facility.
II. SITE DESCRIPTION
The proposed site for the facility is to be located on a mesa sitting above the south side of the
Colorado River. The site slopes gently at about a 4% grade, from the east to the west. The site is
underlain by Potts loam , an alluvial soil derive from sandstone, shale and basalt. Pete and Bull
Creek runs to the northwest, about a' /z mile southwest of the site. Some other unnamed intermittent
drainages lie to the north and south, but will have no effect on the site.
III. ZONING & ADJACENT USES
The subject property is zoned Agricultural/Residential /Rural Density. The type of use requested falls
under the definition of "Process, Storage and Material Handling of Natural Resources" which are
identified as special uses in the A/R/RD zone district.
The proposed pond is located on approximately 2 acres of 30.45 acre property. The neighboring
uses on those lands appear to be rangeland grazing, farming, and resource extraction (natural gas
drilling).
IV. AUTHORITY & APPLICABILITY
Pursuant to Section 9.03.04 of the Zoning Resolution, an application for a Special Use Permit shall
be approved or denied by the Board of County Commissioners after holding a public hearing thereon
in conformance with all provisions of the Zoning Resolution.
V. REVIEW CRITERIA FOR SPECIAL USE PERMITS (SECTION 5:03)
Pursuant to Section 5.03, as listed under the Zone District Regulations, special uses shall conform to
all requirements listed thereunder and elsewhere in the Zoning Resolution, as well as the following
standards:
1. Utilities adequate to provide water and sanitation service based on accepted engineering
standards and approved by the Board of County Commissioners shall either be in place or shall be
constructed in conjunction with the proposed use.
Response
The proposed use does not appear to need or require potable water or wastewater services.
2. Street improvements adequate to accommodate traffic volume generated by the proposed
use and to provide safe, convenient access to the use shall either be in place or shall be
constructed in conjunction with the proposed use.
Response
The proposed facility is expected to generate an average of 6 water tanker trips per day into and out
of the facility, during peak usage times. Most of this truck travel will be corning from and going
back to drilling sites on existing and future on -lease roads in the area. The Applicant states that
County Road 304 is the primary access to the area, but is currently a non - maintained road by the
County. Encana has stated that they will assume the responsibility of maintenance of the road.
County Road 304 has been the subject of potential litigation from one of the adjoining property
owners. They claim that the road is not a County road and that they should be able to gate the
access to the area. The applicant' s attorney' s have had conversations with the County Attorney' s
office about this issue, but they have not provided any documentation to the County Attorney to
assist in determining whether or not this is a County road. It is staff's understanding that the road
access is controlled by Encana per an agreement Tom Brown Oil made with the land owners, to
make sure that the vehicles using the road are only oil company vehicles.
3. Design of the proposed use is organized to minimize impact on and from adjacent uses of
land through installation of screen fences or landscape materials on the periphery of the lot and
by location of intensively utilized areas, access points, lighting and signs in such a manner as to
protect established neighborhood character.
Response
The property is located in a fairly remote private location on a mesa that is visible from the west to
people traveling along I -70.. Further, the site itself is situated in an area already characterized by
intense industrial activity from the natural gas exploration. No screening is necessary. While no
lighting is proposed, any future lighting shall be directed inward and downward towards.
Section 5.03.07 [Industrial Operations]
Pursuant to Section 5.03.07 of the Zoning Resolution, a permit for Industrial Operations requires the
submittal of an impact statement on the proposed use describing its location, scope, design and
construction schedule, including an explanation of its operational characteristics. The impact
statement is required to address the following:
(A) Existing lawful use of water through depletion or pollution of surface run -off, streamflow
or ground water.
Response
The application states that the pond is to be lined with a 60 millimeter, impermeable high - density
polyethylene liner placed on top felt skid free pad to prevent the poly liner form moving. The liner
and pad will be placed on a prepared dirt pad surface, that is tilled and raked to at least an 18 inch
rock free surface. The pond berms will be compacted to meet or exceed 95% Proctor Density.
(B) Impacts on adjacent land from the generation of vapor, dust, smoke, noise, glare or
vibration, or other emanations.
Response
The pumps that will be used to move the water between the ponds will be electric and will produce a
low -level noise and minimal amounts of vibration. The applicant has stated that any sound
emanating from will comply with CRS 25 -12 -103, industrial standards. The nearest residential
use is approximately 3/4 mile to the northwest and at a lower elevation than the proposed facility.
(C) Impacts on wildlife and domestic animals through the creation of hazardous attractions,
alteration of existing native vegetation, blockade of migration routes, use patterns or other
disruptions.
Response
The facility sits in an area identified as by the Colorado Division of Wildlife as winter range for mule
deer and elk. The applicant acknowledges that that facility is incompatible with continued wildlife
access, but the entire facility will only occupy two (2) acres. The entire facility will be fenced to
prevent access from deer and elk, and a deterrence system will be installed, if water fowl end up
trying to land on the ponds.
(D) Affirmatively show the impacts of truck and automobile traffic to and from such uses and
their impacts to areas in the County.
Response
The proposed pond is expected to generate an average of 6 water tanker trips per day into and out of
the facility. This truck travel will be corning from and going back to drilling sites on the High Mesa
area. The Applicant states that the pond will reduce the need for more truck hauling water on CR
304 since the pond will be at the property where the drilling activity occurs rather than hauling the
water to other disposal sites in the County. The applicant has stated that they will be responsible for
maintenance of the road in the area.
(E) That sufficient distances shall separate such use from abutting property which might
otherwise be damaged by operations of the proposed use(s).
Response
The operations at the facility will not involve any abutting property with residential structures. The
nearest residence is located approximately 3/4 of a mile to the northwest. The house is located at a
lower elevation and not visible from the facility.
(F) Mitigation measures proposed for all of the foregoing impacts identified and, for the
standards identified in Section 5.03.08 of this Resolution
Special Use Permits may be granted for those uses with provisions that provide adequate
mitigation for the following:
(A) A plan for site rehabilitation must be approved by the County Commissioners before a
permit for conditional or special use will be issued;
Response
The application includes a reclamation plan that would govern treatment of the site once the useful
life of the facility (20 years) has expired which includes:
1) Removal of all surface equipment and liner material;
2) Restoration and re- contouring of grade to approximate original conditions;
3) Replacement of stockpiled topsoil; and
4) Compliance with all prevailing Colorado Oil and Gas Conservation Commission and
Garfield County regulations governing final reclamation.
(B) The County Commissioners may require security before a permit for special or conditional
use is issued, if required. The applicant shall furnish evidence of a bank commitment of credit,
bond, certified check or other security deemed acceptable by the County Commissioners in the
amount calculated by the County Commissioners to secure the execution of the site rehabilitation
plan in workmanlike manner and in accordance with the specifications and construction schedule
established or approved by the County Commissioners. Such commitments, bonds or check shall
be payable to and held by the County Commissioners;
Response
In the past, the Board has required, as a condition of approval that "A sufficient monetary security,
determined by the Board of County Commissioners, to ensure rehabilitation of the site once
operation has ceased shall be provided by the Applicant." In addition, the Board should be aware
that Section 704 of the OGCC rules and regulations regarding proper reclamation of Centralized
E &P Waste Management Facilities requires the following:
704. CENTRALIZED E &P WASTE MANAGEMENT FACILITIES An operator which makes
application for an off -site, centralized E&P waste management facility shall, upon approval and
prior to commencing construction, provide to the Commission financial assurance in the amount of
fifty thousand dollars ($50,000) to ensure the proper reclamation, closure and abandonment of such
facility.
The Application contains such a Performance Bond for $50,000 filed with the COGCC for an E &P
Waste Facility.
Section 5.03.08 %Industrial Performance Standards]
Pursuant to section 5.03.08 of the Zoning Resolution, all Industrial Operations in the County shall
comply with applicable County, State, and Federal regulations regulating water, air and noise
pollution and shall not be conducted in a manner constituting a public nuisance or hazard.
Operations shall be conducted in such a manner as to minimize heat, dust, smoke, vibration, glare
and odor and all other undesirable environmental effects beyond the boundaries of the property in
which such uses are located, in accord with the following standards:
(1) Volume of sound generated shall comply with the standards set forth in the Colorado
Revised Statutes at the time any new application is made.
(2) Vibration generated: every use shall be so operated that the ground vibration inherently
and recurrently generated is not perceptible, without instruments, at any point of any boundary
line of the property on which the use is located.
(3) Emissions of smoke and particulate matter: every use shall be operated so as to comply
with all Federal, State and County air quality laws, regulations and standards.
(4) Emission of heat, glare, radiation and fumes: every use shall be so operated that it does
not emit heat, glare, radiation or fumes which substantially interfere with the existing use of
adjoining property or which constitutes a public nuisance or hazard. Flaring of gases, aircraft
warning signals, reflective painting of storage tanks, or other such operations which may be
required by law as safety or air pollution control measures shall be exempted from this provision.
The only permanent noise generated from the facility will emanate from the electric pumping
equipment which will be housed in a building intended to protect the equipment and dampen the
noise generated. EnCana has committed to adhere to the noise standards specified by the Colorado
Revised Statutes and the Colorado Oil and Gas Conservation Commission rules. More specifically,
the Applicant has committed that the noise will not exceed 75 decibel maximum set out in the
statutes. The application did not provide any analysis of noise generated from the facility as it relates
to the statutes; however, Staff agrees that the pump building facility will dampen the noise generated
so that it will not be detected outside of the property.
The proposed equipment buildings will aid in mitigating any minimal vibration, and the vibration, if
any, should be localized to a small area immediately surrounding the pumping equipment. If, in the
unlikely event, nuisance vibration is detected at any point along the property boundary, additional
measures shall be taken to control the vibration. Staff agrees that there will be limited vibration that
will most likely not be detected at the boundaries of the property.
The equipment associated with the pond will add no emissions of smoke and particulate matter. The
facility shall be required to comply with Federal, State, and County air quality regulations and
standards. There will be some glare by the nature of the water surface; however, it will not be able to
impact adjacent properties due to the secluded location of the pond being surrounded by canyon -like
steep topography.
(5)
Storage area, salvage yard, sanitary landfill and mineral waste disposal areas:
(A) Storage of flammable or explosive solids or gases shall be in accordance with
accepted standards and laws and shall comply with the national, state and local f `ire codes
and written recommendations / comments from the appropriate local protection district
regarding compliance with the appropriate codes;
(B) At the discretion of the County Commissioners, all outdoor storage facilities may
be required to be enclosed by fence, landscaping or wall adequate to conceal such facilities
from adjacent property;
(C) No materials or wastes shall be deposited upon a property in such form or manner
that they may be transferred off the property by any reasonably foreseeable natural causes
or forces;
(D) Storage of Heavy Equipment will only be allowed subject to (A) and (C) above and
the following standards:
1. The minimum lot size is five (5) acres and is not a platted subdivision.
2. The equipment storage area is not placed any closer than 300 ft. from any
existing residential dwelling.
3. All equipment storage will be enclosed in an area with screening at least
eight (8) feet in height and obscured from view at the same elevation or
lower. Screening may include berming, landscaping, sight obscuring
fencing or a combination of any of these methods.
4. Any repair and maintenance activity requiring the use of equipment that
will generate noise, odors or glare beyond the property boundaries will be
conducted within a building or outdoors during the hours of 8 a.m. to 6
p.m., Mon. -Fri.
5. Loading and unloading of vehicles shall be conducted on private property
and may not be conducted on any public right -of -way.
(E) Any storage area for uses not associated with natural resources, shall not exceed
ten (10) acres in size.
(F) Any lighting of storage area shall be pointed downward and inward to the property
center and shaded to prevent direct reflection on adjacent property.
Response
The size of the entire facility is approximately 2 acres. The Applicant states that there will be no
storage of flammable or explosive solids or gases on the property. No increase in the size of the
property is associated with the proposed changes. No heavy equipment will be stored on site. Any
additional lighting installed at the facility will be installed so that it is pointed downward and inward
to the property center and shaded to prevent direct reflection on adjacent property.
(6) Water pollution: in a case in which potential hazards exist, it shall be necessary to install
safeguards designed to comply with the Regulations of the Environmental Protection Agency
before operation of the facilities may begin. All percolation tests or ground water resource tests as
may be required by local or State Health Officers must be met before operation of the facilities
may begin.
Response
The Applicant states that the facility is designed to protect groundwater and surface water resources
and will not generate any adverse impact on water through depletion, pollution of surface runoff,
stream flow or surface water. No sewage will be generated, no water supplies will be used and there
will be no disposal of water. All water brought to the facility will be contained in above ground
storage tanks which shall be contained within adequate secondary containment structures constructed
from impermeable materials.
Oil and Gas Conservation Commission (OGCC) Rules
For background, the following provisions are rules and regulations required by the COGCC which
basically point out that 1) produced water is defined as exploration and production waste, and 2)
whose disposal is governed by the OGCC and not the Colorado Department of Public Health and
Environment (CDPHE).
EXPLORATION AND PRODUCTION WASTE (E &P WASTE) shall mean those wastes
associated with operations to locate or remove oil or gas from the ground or to remove impurities
from such substances, and which are uniquely associated with and intrinsic to oil and gas
exploration, development or production operations of which are exempt from regulation under
Subtitle C of the Resource Conservation and Recovery Act (RCRA), 42 USC Sections 6921, et. seq.
For a waste to be considered an E &P waste, it shall be associated with operations to locate or
remove oil or gas from the ground or to remove impurities from such substances and it shall be
intrinsic to and uniquely associated with oil and gas exploration, development or production. For
natural gas, primary field operations include those production - related activities at or near the
wellhead and at the gas plant (regardless of whether or not the gas plant is at or near the wellhead),
but prior to transport of the natural gas from the gas plant to market. In addition, uniquely
associated wastes derived from the production stream along the gas plant feeder pipelines are
considered E&P wastes, even if a change of custody in the natural gas has occurred between the
wellhead and the gas plant. In addition, wastes uniquely associated with the operations to recover
natural gas from underground storage fields are considered to be E&P waste.
SENSITIVE AREA is an area vulnerable to potential significant adverse ground water impacts,
due to factors such as the presence of shallow economically usable ground water or pathways for
communication with deeper economically usable ground water; proximity to surface water,
including lakes, rivers, perennial or intermittent streams, creeks, irrigation canals, and wetlands.
The procedure for identifying Sensitive Areas is set forth in the Sensitive Area Identification
Decision Tree and Guidance Document.
704. CENTRALIZED E &P WASTE MANAGEMENT FACILITIES An operator which makes
application for an off -site, centralized E &P waste management facility shall, upon approval and
prior to commencing construction, provide to the Commission financial assurance in the amount of
fifty thousand dollars ($50, 000) to ensure the proper reclamation, closure and abandonment of such
facility. This section does not apply to underground injection wells and multi -well pits covered under
Rules 706 and 707.
901. INTRODUCTION a. General. The rules and regulations of this series establish the permitting,
construction, operating and closure requirements for pits, methods of E &P waste management,
procedures for spill /release response and reporting, and sampling and analysis for remediation
activities. The 900 Series rules are applicable only to E&P waste, as defined in ¢34 -60- 103(4.5),
C.R.S., or other solid waste where the Colorado Department of Public Health And Environment
( "CDPHE ") has allowed remediation and oversight by the Commission.
CRS §34 -60- 103(4.5) "Exploration and production waste" means those wastes that are generated
during the drilling of and production from oil and gas wells or during primary field operations and
that are exempt from regulation as hazardous wastes under subtitle c of the federal "Resource
Conservation and Recovery Act of 1976", 42 U.S.C. sec. 6901 to 6934, as amended.
907(c) Produced Water
(1) Treatment of produced water. Produced water shall be treated prior to placement in a
production pit to prevent crude oil and condensate from entering the pit.
(2) Produced water disposal. Produced water may be disposed as follows:
A. Injection into a Class II well, permitted in accordance with Rule 325.;
B. Evaporation/percolation in a properly permitted lined or unlined pit;
C. Disposal at permitted commercial facilities; or
D. Disposal by roadspreading on lease roads outside sensitive areas for produced waters with
less than 5,000 mg/1 TDS when authorized by the surface owner. Roadspreading shall not
result in pooling or runoff of produced waters and the adjacent soils shall meet the allowable
concentrations in Table 910 -1.
Water Quality Monitoring for the Proposal
As noted previously, the Applicant states that the liner is designed with a high density polyethylene
liner on a skid free liner. In previous water storage applications, the Board has required the
Applicant to conduct an annual review of the water chemistry contained in the evaporation pit at
such time when free standing water is within the pit. This analysis would be submitted to the
Building and Planning Department once a year every year the pit is in operation. The cost of this
analysis shall be born entirely by the Applicant. If this water is determined, through this analysis, to
be hazardous or toxic based on applicable standards, the Applicant or owner / operator of the facility
shall be required to submit an additional SUP to specifically address / mitigate any detected potential
hazards.
Lastly, it is clear that the COGCC 900 Series Rules are applicable only to E &P waste, as defined in
§34 -60- 103(4.5), C.R.S., or other solid waste where the Colorado Department of Public Health and
Environment ( "CDPHE ") has allowed remediation and oversight by the Commission. As a result, the
CDPHE does not regulate water in these ponds.
Section 9.03.05 [Periodic Review of SUP]
Pursuant to section 9.03.05 of the Zoning Resolution:
Any Special Use Permits may be made subject to a periodic review not less than every six (6)
months if required by the County Commissioners. The purpose of such review shall be to
determine compliance or noncompliance with any performance requirements associated with the
granting of the Special Use Permit. The County Commissioners shall indicate that such a review
is required and shall establish the time periods at the time of issuance of a Special Use Permit.
Such review shall be conducted in such manner and by such persons as the County
Commissioners deem appropriate to make the review effective and meaningful. Upon the
completion of each review, the Commissioners may determine that the permit operations are in
compliance and continue the permit, or determine the operations are not in compliance and either
suspend the permit or require the permittee to bring the operation into compliance by a certain
specified date. Such periodic review shall be limited to those performance requirements and
conditions imposed at the time of the original issuance of the Special Use Permit.
IV. RECOMMENDED FINDINGS
1. Proper posting and public notice was provided as required for the meeting before the Board of
County Commissioners.
2. The meeting before the Board of County Commissioners was extensive and complete, that all
pertinent facts, matters and issues were submitted and that all interested parties were heard at that
meeting.
3. The above stated and other reasons, the proposed special use permit has been determined to be in
the best interest of the health, safety, morals, convenience, order, prosperity and welfare of the
citizens of Garfield County.
4. The application has met the requirements of Special Use (Sections 5:03, 5:03:07, 5:03.08 and
9:03) the Garfield County Zoning Resolution of 1978, as amended.
V. STAFF RECOMMENDATION
Staff recommends that the Board approve the Special Use Permit for "Processing, Storage and
Material Handling of Natural Resources" on High Mesa for Encana Oil & Gas, USA with the
following conditions:
I. That all representations of the Applicant, either within the application or stated at the
hearing before the Board of County Commissioners, shall be considered conditions of
approval unless explicitly altered by the Board.
2. That the operation of the facility be done in accordance with all applicable federal, state, and
local regulations governing the operation of this type of facility.
3. That the Applicant shall comply with the fire protection provisions included in the rules and
regulations of the Colorado Oil and Gas Conservation Commission (COGCC) and the
National Fire Code as the Code pertains to the operation of this facility.
4. The issuance of the SUP shall be subject to an annual review of the water chemistry
contained in the evaporation pit at such time when free standing water is within the pit and
water samples collected from the ground water monitoring well. These analyses shall be
submitted to the Building and Planning Department on the first day of July for every year
the pit is in operation. The cost of this analysis shall be born entirely by the Applicant. If
this water is determined, through these analyses, to be hazardous or toxic based on
applicable standards, the Applicant or owner / operator of the facility shall be required to
submit an additional SUP to specifically address / mitigate any detected potential hazards.
5. The County reserves the right to retain outside expertise, at the expense of the Applicant /
operator of the facility, in order to conduct tests or analyses of the physical nature, water
chemistry or groundwater properties on or away from the site.
6. That this facility is for the sole use of the Applicant. If any other entities are to be added as
users, then they would be subject to an additional SUP as well as rules and regulations as
administered by the COGCC.
7. That all out -of -state vehicles and equipment assn iated with � eJ peration of the facility be
properly licensed within ty /A7'G
8. All produced water brought to the facility that is contained in any above ground storage /
treatment / separator tanks shall be contained within an adequate secondary containment
structures constructed from impermeable materials to prevent any spill from impacting
groundwater.
9. The Applicant shall comply with the following requirements in order to mitigate adverse
affects of this operation on wildlife:
a. The Applicant shall monitor the pond for the presence of oil as a matter of typical
operation and maintenance duties and to prevent wildlife from being harmed. If, in
the unlikely event, oil reaches the pond water, the Applicant shall take measures to
immediately remove it.
b. The Applicant shall install a waterfowl deterrence system that consists of the
placement of high - tensile wire at regular intervals across the pond. These wires act as
a visual deterrent to birds attempting to land on the water, and as a noise deterrent, as
the stretched wire creates an ultrasonic (inaudible to humans) sound.
c. The Applicant shall immediately report the death of any migratory bird caused by
activities or structures at the facility to the Colorado Division of Wildlife and the
United States Fish and Wildlife Service in accordance with state and federal
regulations.
10. Prior to the issuance of a Special Use Permit, the Applicant shall submit the following items
to the Count Vegetation Manager for approval:
a. The Applicant shall map and inventory the property for the County Listed Noxious
Weeds.
b. The Applicant shall provide a Weed Management Plan for the inventoried noxious
weeds.
c. The Applicant shall augment the site reclamation plan by providing a plant material
list and planting schedule for the reclamation.
d. The Applicant shall provide a Mosquito Management Plan that will address how the
Applicant intends to monitor and manage this site for mosquitoes.
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