20080868 Ver 2_Major Variance_20080825

o8-D8to 8 U a
1. Request for a Major Variance from the Tar-Pamlico Riparian
Protection Rules (15A NCAC 2B.0259 and .0260) for Buffer
Mitigation for the PCS Phosphate Company, Inc.
The Division of Water Quality (DWQ) will discuss a proposed major variance to the Tar-
Pamlico Riparian Protection Rules. The PCS Phosphate Company, Inc. (PCS) is
proposing a mine continuation in Beaufort County near Aurora, North Carolina along the
lower Pamlico River. In October 2000, PCS submitted an application to the Department
of the Army, Corps of Engineers (Corps) for authorization to continue mining operations
at their Aurora North Carolina (Beaufort County) facility. In October 2006, the Corps
filed a Draft Environmental Impact Statement (DEIS) that evaluated ten (10) alternative
boundaries. In November 2007, the Corps filed a Supplement to the DEIS (SDEIS) that
evaluated two (2) additional alternatives. In May 2008, the Corps filed the Final
Environmental Impact Statement (FEIS). In Section 2.7.6 of the FEIS, the Corps
determined that six (6) of the twelve (12) alternatives are practicable. "Of these
alternatives, L is the most restrictive and therefore avoids the most aquatic resources."
Although the Least Environmentally Damaging Practicable Alternative (LEDPA)
determination has yet to be documented by the Corps, the Alt L boundary parameters
have been used in this request.
On March 8, 2006, the Water Quality Committee (WQC) of the EMC discussed a similar
variance request from PCS. A May 10, 2006 letter from WQC Chair Dr. Peterson to PCS
states, "After considerable discussion, the Committee decided not to approve a Major
Variance at this time until the extent of unavoidable impact to the protected stream
buffers as well as the proposed mitigation is clearer." The extent of environmental
impacts and the proposed mitigation plan (Appendix I) presented in the FEIS provide the
information as requested by the WQC. In their 2006 deliberations and letter, the WQC
did conclude, "In principle, the Water Quality Committee considers flexible buffer
mitigation to be an appropriate tool for buffer mitigation for the PCS Phosphate
Company mine continuation." The first priority of this variance request is to request
EMC delegation of authority for DWQ to issue stream buffer credit of riparian headwater
system stream restoration in the Tar-Pamlico River Basin for the PCS mine continuation
project. The second priority of this variance request is to request EMC authorization for
DWQ to issue buffer credit for DWQ-approved flexible buffer mitigation projects
associated with the PCS mine continuation. DWQ staff recommends that the WQC
approve this major variance request.
plftgoygy
AUC 9 5 2008
WETLANDSAND STORMWATER p MKN
Environmental Management Commission - Water Quality Committee
PCS Phosphate Company, Inc. request for Major Variance
from the Tar-Pam Buffer rules (15A NCAC 2 B .0259)
September 10, 2008
Summary
PCS Phosphate Company, Inc. (PCS) requests that the North Carolina Environmental
Management Commission (EMC):
? delegate authority to DWQ to issue stream buffer credit of riparian headwater
system stream restoration in the Tar-Pamlico River Basin for the PCS mine
continuation project, and
? delegate authority to DWQ to issue buffer credit for DWQ-approved flexible
buffer mitigation projects for the PCS mine continuation project as described in
this document.
This variance request is in harmony with the general purpose and intent of the State's
riparian buffer protection requirements and preserves its spirit. There are practical
difficulties and hardships associated with this project. Public safety and welfare will be
assured, water quality will be protected, and substantial justice will be provided with this
variance.
Introduction
In October 2000, PCS submitted an application to the Department of the Army, Corps of
Engineers (Corps) for authorization to continue mining operations at their Aurora North
Carolina (Beaufort County) facility. In October 2006, the Corps filed a Draft
Environmental Impact Statement (DEIS) that evaluated ten (10) alternative boundaries.
In November 2007, the Corps filed a Supplement to the DEIS (SDEIS) that evaluated two
(2) additional alternatives. In May 2008, the Corps filed the Final Environmental Impact
Statement (FEIS). In Section 2.7.6 of the FEIS, the Corps determined that six (6) of the
twelve (12) alternatives are practicable. "Of these alternatives, L is the most restrictive
and therefore avoids the most aquatic resources." Although the Least Environmentally
Damaging Practicable Alternative (LEDPA) determination has yet to be documented by
the Corps, the Alt L boundary parameters have been used in this request. Graphical
depictions of the Alt L boundary are provided as attachments. The mine plan for Alt L is
shown as Attachment I (FEIS Volume II Appendix D). The biotic communities impacts
graphics for Alt L are shown as Attachments 2, 3 and 4 (FEIS Figures 4-7a, b, and c).
On March 8, 2006, the Water Quality Committee (WQC) of the EMC discussed a similar
variance request from PCS. A May 10, 2006 letter from WQC Chair Dr. Peterson to PCS
states, "After considerable discussion, the Committee decided not to approve a Major
Variance at this time until the extent of unavoidable impact to the protected stream
buffers as well as the proposed mitigation is clearer." The extent of environmental
impacts and the proposed mitigation plan (Appendix I) presented in the FEIS provide the
information as requested by the WQC. In their 2006 deliberations and letter, the WQC
did conclude, "In principle, the Water Quality Committee considers flexible buffer
mitigation to be an appropriate tool for buffer mitigation for the PCS Phosphate
Company mine continuation." The first priority of this variance request is to request the
EMC delegation of authority for DWQ to issue stream buffer credit of riparian headwater
system stream restoration in the Tar-Pamlico River Basin for the PCS mine continuation
project. The second priority of this variance request is to request EMC authorization for
DWQ to issue buffer credit for DWQ-approved flexible buffer mitigation projects
associated with the PCS mine continuation.
Discussion
The FEIS provides a detailed evaluation of the affected environment and environmental
consequences of Alt L. The FEIS (Tables 4-10 and 4-28) indicates that, within Alt L, a
total (Zone 1 and Zone 2) of 55 riparian buffer acres would be impacted. Table 3 from
the FEIS Volume III Appendix I mitigation plan is included as Attachment 5. Alt L
avoids impacts to 215 riparian buffer acres within the project area (FEIS Table 4-27).
Much of the stream mitigation proposed by PCS involves restoring "riparian headwater
systems" and is based on the "Information Regarding Stream Restoration with Emphasis
on the Coastal Plain" (April 4, 2007) publication from DWQ and the Corps. Many of
these headwater systems do not appear on NRCS county soil surveys or USGS
topographic maps. These systems typically have small watersheds draining into defined
valleys with little longitudinal slope. Relatively unaltered riparian headwater systems will
usually possess a braided, diffuse surface water flow pattern across a narrow floodplain
of riparian, wooded wetlands. However, many lower Coastal Plain examples have been
converted to agricultural or silvicultural use. According to the DWQ/Corps publication,
restoration of these riparian headwater systems can provide both stream and wetland
mitigation credit without physically constructing a distinctive stream channel. This type
of mitigation would typically be appropriate for offsetting impacts to those systems that
either do not appear or appear as first order streams on county soil surveys or USGS
topographic maps. The publication does not discuss Tar-Pamlico buffer mitigation credit
for restoring wooded buffers around these restored riparian headwater systems.
The FEIS contains a detailed compensatory mitigation plan (FEIS Volume III -
Appendix I) including a report describing each mitigation project proposed to be used by
PCS to mitigate for the first 15 years of impacts with Alt L. Within the first 15 years, 32
riparian buffer acres would be impacted resulting in a mitigation requirement of 77 buffer
acres based on documented mitigation ratios by zone (Zone 1 @ 3:1 and Zone 2 @
1.5:1). With EMC delegation of authority for DWQ to issue stream buffer credit of
riparian headwater system stream restoration in the Tar-Pamlico River Basin for the PCS
mine continuation project, successful implementation of the FEIS mitigation plan would
yield 85 acres of riparian buffer mitigation credit, thus exceeding the riparian stream
buffer mitigation requirement for the first 15 years of Alt L. Table 4 from the FEIS
Volume III Appendix I mitigation plan is included as Attachment 6. Buffer mitigation
credit for the remainder of Alt L impacts will be satisfied through the flexible buffer
mitigation projects approved by DWQ, and payment into the in-lieu fee program for any
remaining mitigation credit requirements, as allowed by state statutes.
With approval of this variance request and implementation of the proposed FEIS
mitigation plans, water quality will be protected and, as a result, the public will have
water available for domestic and recreation use, and wildlife and aquatic species will
benefit.
Hardship
Section 15A NCAC 2B .0260 "Tar-Pamlico Basin - Nutrient Sensitive Waters
Management Strategy: Mitigation Program for Protection and Maintenance of Riparian
Buffers" specifies three options for providing compensatory buffer mitigation. These are:
1) payment of a compensatory mitigation fee to the Riparian Buffer Restoration Fund, 2)
donation of real property or of an interest in real property, or 3) restoration or
enhancement of non-forested riparian buffer by the applicant.
PCS has performed an exhaustive search for available tracts of land that have the
potential for restoration or enhancement of non-forested buffer, including reviews of all
available mapping (USGS and county soil surveys), LIDAR data, and field
reconnaissance. Through this process PCS has identified a number of sites that should
yield sufficient stream and wetland restoration credit to satisfy the stream and wetland
compensatory mitigation needs for Alt L. However, based upon the proposed buffer
impacts and the ratio applied to such impacts under the Tar-Pam buffer rules, a deficit of
appropriate buffer restoration sites to compensate for these impacts may occur.
During the search for buffer mitigation sites, several un-buffered channelized drainage
features (ditches), and Waters of the State (streams), located in agricultural tracts were
identified for potential buffer restoration. The concept of buffer development (with
permanent conservation easements) while providing continued agricultural use of the
remaining property was presented to the landowners. During discussions and
negotiations, landowners consistently expressed concerns about limited access and
limited ability to periodically clean out these drainage features, and therefore were
unwilling to sell a 100-foot wide strip of their property. Many potential sites were
comprised of a mosaic of several landowners, and obtaining agreements from the
necessary parties to create a satisfactory length of stream buffer has not been possible.
Based on the above discussion, an adequate amount of riparian buffer restoration sites is
not available. The lack of available riparian buffer restoration sites has created a hardship
for PCS.
A summary of the stream buffer impacts associated with Alt L, the buffer mitigation
requirements, the buffer mitigation available, and the buffer mitigation deficit (without
EMC approval of this variance request) is shown in the following table.
years
Alt L stream buffer impacts 31.9 ac
Buffer mitigation required (FEIS) 76.7 ac
Buffer mitigation available (*) 26.6 ac.
Buffer mitigation deficit 50.1 ac
(*) without EMC approval of this variance request
Fulfillment of buffer rules intent
Entire Alt L
55.1 ac.
132.1 ac.
26.6 ac.
105.5 ac.
EMC delegation of authority for DWQ to grant stream buffer credit for riparian
headwater system stream restoration in the Tar-Pamlico River Basin for the PCS mine
continuation project is consistent with the current mitigation rules and with the intent of
the Tar-Pamlico buffer rules. Current DWQ practice grants credit for riparian headwater
system stream restoration. The riparian headwater system stream buffers provide similar
functions as compared to other stream buffers, and therefore the requested DWQ
authorization would be consistent with fulfillment of the intent of the buffer rules.
15 A NCAC 2B .0259(l) states in part, "The purpose of this Rule shall be to protect and
preserve existing riparian buffers, to maintain their nutrient removal functions, in the
entire Tar-Pamlico Basin." In addition to the above requested clarification of authority,
PCS is requesting a variance from 15A NCAC 2B.0260(6) and 15 A NCAC 2B.0259(10)
in order to be allowed to provide flexible forms of mitigation that replace the nutrient
removal functions of the impacted buffers. By providing alternative means of nutrient
removal as compensatory mitigation for riparian buffer impacts, PCS proposes methods
with a goal to improve the total nitrogen (TN) and total phosphorus (TP) removal
functions of the buffers, which is consistent with the general purpose and spirit of 15A
NCAC 2B .0259 and .0260. DWQ recommends, and PCS concurs, that a broad based
stakeholder advisory group be established to help guide the selection of alternative BMP
mitigation sites (urban and rural). This group would have broad membership in the local
community and regulatory agencies, and would be established to provide advice to DWQ
with respect to the identification of possible mitigation sites and their selection. This
group would also review and comment on the proposed method to calculate offset credits.
DWQ would consider all comments from the stakeholder advisory group, but DWQ
would retain the decision-making authority for these projects. In July 2008, PCS
submitted a report entitled, "Draft Flexible Buffer Mitigation Strategy Report". This
report provides a basic methodology that will be reviewed by the stakeholder advisory
group.
Riparian headwater system stream buffers
At most of the mitigation sites identified in the FEIS mitigation plan (FEIS Volume III
Appendix I), there will be an opportunity to use the "Information Regarding Stream
Restoration with Emphasis on the Coastal Plain" (April 4, 2007) publication from DWQ
and the Corps. In the case of riparian headwater system stream restoration, credit can be
provided for the length of the riparian headwater system regardless of whether a defined
channel with a wetland or wetland only forms, as long as there is surface water now.
With EMC-WQC approval of this clarification request, when surface water flow is
documented and the riparian headwater system is used for linear stream restoration credit,
DWQ would be authorized to approve riparian stream buffer credit for the 50-foot
forested zone around the riparian headwater system. This is reasonable since the forested
zone around these swampy headwater systems that flow slowly in the eastern North
Carolina coastal plain will provide the same nutrient removal functions as a riparian
buffer around blue line streams.
Flexible buffer mitigation
With EMC-WQC approval of this variance request, DWQ would be authorized to issue
buffer credit for non-stream buffer restoration activities that fulfill the intent of the Tar-
Pamlico River buffer rules. The following methods could be approved to replace the
nutrient removal functions of the riparian buffers that may be impacted within Alt L:
• Conversion of existing untreated cropland into forest and riparian
headwater system mitigation as described in the recent DWQ and
Corps publication, "Information Regarding Stream Restoration with
Emphasis on the Coastal Plain" (April 4, 2007).
• Stormwater best management practices (BMPs) that remove nutrients
from currently untreated urban (developed areas) and agricultural
runoff.
• Other similar quantifiable means of nutrient reduction.
Credits would not be granted for agricultural or silvicultural BMPs if required by other
rules administered by DWQ. As such, none of mitigation activities provided by PCS
could be applied towards any required county nutrient management or reduction
requirements. PCS also agrees that riparian buffer preservation and wastewater (as
opposed to stormwater) treatment would not be acceptable as riparian buffer mitigation in
the context of the variance as proposed. PCS will provide at least one urban BMP
project subsequent to review by the stakeholders advisory group and approval by DWQ.
If completion of at least one urban BMP project is not possible, then with DWQ
consultation, a report describing the situation will be submitted to the EMC as an
information item for review and comment.
Note: DWQ issued a memorandum, "Buffer mitigation and the mining industry"
(09/22/06), which allows mining activities that result in a permanent waterbody within
the footprint of the mine to receive buffer credits for creation of a 50 foot wide wooded
buffer with diffuse surface water flow around the edge of the permanent waterbody. This
provision has not been included in PCS Phosphate's mitigation plan at this time. No
permanent waterbodies are projected in the reclamation plan associated with the Alt L
boundary. Drainage from all reclamation areas will be reconnected to the natural
drainage features outside the mine permit boundary.
/y
G5
S I\\ ? G-3/4
nth ?/ ? R-1
c 1.5011 5 000 7 500 10,000 ???\ ?J I\/'Lp\ \ G 6
Feet ? ? - W
L YEAR 10
AR 1o YEAR9 - / R2
t. F YEARS f/
!? ! Recycle Lake
(YEAR 11i
BONNERTON AREA R4
YEAR 12 /? - -
1 R-5W
YEAR 13+y!
R-5
YEAR 3
Yj
~? r
"IR
i? R-6 ,
YEAR 15
I _
R-8 II
tiA
:III 11'y,-I, R-7 • • -
i \ 11
\ Dredge 6?y
Lak T
•1I ?., `, uaoaa
r?
1
YEAR 31 IYE R23,
I( E I
YEAR `YE R 6 1 YEAR 3U 1
I7I YEAR IB. I
? ? ? I 1 Brourall
Y ? I -1 ,LF r -
I 1 _YEAR?2 1 - ? ?`?
YEAR 27
YEAR 33 YEAR p YEAR 25 YEAR 35
YEAR
YEAR 11
1 ?
I. JO ?LAF YEAR 29 ??
EPR:i2 YEAR" YEAR
All,
I._. EAR32
5.: i! Ru?l
- YEAR 33 YEARS YEAR
-YEAR 3 A l ! CtAd1'
YEAR J7 rOAa S1 /! oP
YEAR 3[
1
1
SOUTH 33 AREA
Pq/R(/CG
fi/l Fk
NCPC AREA
? Y£AR<1
i
,o `,• ? CCC YEAR d i
YEAR)
BAR a, YEAR 2
YEAR YEAR 1
\ IF+
S

1 47-74C9A4rAiT
Legend
a'

.
..--11-111"L. ,
rEAF .x

-
- vrAR I
-? YEAR e DRAGLINE MINING SEQUENCE

-
?1 YEAR 15 YEAR 21
tT F ,a
vrna 35
_
YEAF as
rr
PI.
Ir!x ciwiuxw.u' ®VEAR-5 uYEAR2 YEARS YEARIL YEAR 13 YEAR 3(1 YEAR 17 YEAR- Phospha
ate

YEARI
VEAR3
TRIM ;,II YEAR 10
YEAR 11
VEAR24
YEAR 11
YEAR 90
VEAR1s PCS PHOSPHATE CONTINUATION OF MINING
NEAR AURORA. N. C.
YEAR-3 YEA. YEAR11 YEAR IA YEAR25 YEAR 32 YEAR 3R YEAR a,. ALTERNATIVEL
'
"
r L YOII
I AV SLQJEN::E
U? <. LINF
AN LA
-l
IC. NBITOIN111-a
cou
R
-YEAR 2 YEAR 5 YEAR 12 YEAR 19 YEAR 25 YEAR 33 YEAR 00 YEAR ?i] ATE JULY 11
Y--[er ®YFAR-1 ®VEAR6 rl, YEAR 13 YEAR 20 YEAR 27 ?YEAR 34 ®YFAR 41 ? YEARJft 9CA E.W3b.
VEAF /i vEAF ] YEAR 1,1 YEAR YEAR e vCAR S` r
I Marston
?? ? ?- - I DWG: E610-5107-07

NC 306'
RELOCATION
PAMLICO RIVER
h^ 3L15
PRL-OSED EH:'!::__ tiVUO:rs cur
{ F
s. ? oe
tIF 1 .?k5 '! J i f. ,5 a

f SANDY LANDING ROAD
NORTHERN ROUTE
V C L
!'\ t ? 9 2?urs
F A '
if 1, ?x U?'
Y. `C
T LTX
L F I
1 .. ! 4 ? nF .dl
T6pLY CFu
(n
A ?

2 N T?,
6 ..
'
LEGEND
ACRES
' , 11
I NCPC BASE PROJECT AREA 3,608
• a _..-_,...,_.. NCPC Extension-ALT L 2,185
NCPC Extension-Excavation Lirnds 1,354
° Recovered Concentrate = 37,697,000 7on9*
CREEKS/OPEN WATER
s 1:. PUULD TRUST AREAS D LF 0
S PERENNIAL STREAM 0 HE 0
'.INTERMITTENT STREAM &,427 LF <1
b
s ,o 2 WETTAND BRACKISH MARSH COMPLEX 0
i F4
_ MAI 3 WETLAND BOTTOMLA.ND HARDWOOD FOREST i8
'Ere WETLAND HERBACEOUS ASSEMBLAGE 2$7
+ i %
' 5
WETLAND SHRUB - SCRUB ASSEMBLAGE 138
6 WE LANO PINE PLANTATION 324
- T 7 WETLAND HARDWOOD FOREST 422
B WETLAND MIXED PIKE - HARDWOOD FOREST 356
9 WETLAND PINE FOREST 95
10 WETLAND POCOSIN - BAY FOREST 0
11 WETLAND SAND RIDGE FOREST 0
12 POND 11
13 WFRAND MAINTAINED AREA 0
14 UPLAND HERBACEOUS ASSEMBLAGE 160
A -L .1 15 UPLAND SHRUB - SCRUB ASSEMBLAGE 143
' 18 UPLAND PINE PLANTATION 27
' 17 UPLAND HAROWOOC FOREST 17
,T 18 UPLAND MIXED PINE - HARDWOOD FOREST 77
19 UPLAND PINE FOREST 15
20 UPLAND SAND RIDGE FOREST 0
21 UPLAND AGRICULTURAL LAND 94
_
! 22 UPLAND NON - VEGETATED/MAINTAINEO AREA 67

^ WETLAND AREAS 1,584
'
?saa cucx UPLAND AREAS 601
f .r. e 47% WETLAND AREAS 59
(UPLAND/WETLAND ACREAGES WITHIN THIS
-A AREA HAVE BEEN ACCOUNTED FOR WITHIN
COMMUNITIES ACREAGES LISTED) ABOVE )
ROAD RELOCATION IMPACTS AREAS
PROPOSED BRI
E * PROVIDED 8Y PCS PHOSPHATE 9-2-05 (CZR Rev. 9/20/05)
DG
NCPC ALIERN4TA/[ L - N. C. M'GHWAV 3pS aRIOGE
SHMING AND PILES * NOTE BOUNDARf AS SHOWN INCLUDES DCM/CAMA AVOIDANCE
PUBL TROST AREAS 0,02
2 WIJAND BRACKISH MANSH CCMPLEX
6 Wi:T A PINE PLA
N 0,17
0.0t
H
9 WERAN0 MUM PI
E PINE - HPFDWOOD FOREST 0.01
0.21 ACRES
MCP[ AITERNATiVE L - N.C. H]GNJYAY ]05 1,900 D 1,BOD EDDI
WETLAND HERBACEOUS ASSEMBLAGE D.a3
6 WELAND P'NE PuWATON 1.47
A WETUWD MIxED PINE - HARDW000 FOREST
15 UPLAND SHRUB - SHRVB ISSEMBLACE 2aO
001 500 0 500 Meters
11 UPLAND MIXED PINE - HARDWOOD FOREST D.04
21 UPLAND AGRICULTURAL LAND ].]t
22 UPLAND NON - VEGEATED/MwMANE@ AREA 0.13
779 ACRES L Alternative Boundary NCPL
Biotin Comm nlties tmpacts and
r PG NNAT ?NDr .NOIN NDnD Sand Land tn Re.d NC 306 Relocation Impacts
N
S WILAND PINE PCS PHOSPHATE MINE CONTINUATION
E

a W
HANOWODO FOREST
MIXES PINE TI FI
D
0 002
.
03
16 UPLAND PINE PLANTATION 1.04 -
22 UPLAND NON _ VEGETATED/MAINTNNEU A LA 004 Scole: As shown Drawn b : 9FG TW
1.50 ACRES Date: 3/1 9/08 File:17156224/rEIS 4609/-UAES/1-7a/
1I1 NCPC DID- -2001-
Approved by: Psa9?--?2-DS Figure 4-7.
TO
IXRX CROCK
BONNERTON BASE PRCJECT AREA
BONNERTON L ALTERNATIVE
BONNERTON L. ALTERNATIVE - EXCAVATION LIMITS
RECOVERABLE CONCENTRATE a 36,940,000 TONS-
CREEKS/OPEN WATER
-+. PUBLIC TRUST AREAS C LF
e PERENNIAL STREAM 3,050 LF
INTERMITTENT STREAM 5,449 LF
WETLAND BRACKISH MARSH COMPLEX
WETLAND BOTTOMLAND HARDWOOD FOREST
WETLAND HERBACEOUS ASSEMBLAGE
WFTLANO SHRUB - SCRUB ASSEMBLAGE
WETLAND PINE PLANTATION
WETLAND HARDWOOD FOREST
WETLAND MIXED PINE - HARDWOOD FOREST
WETLAND PINE FOREST
WETLAND POCOSIN - BAY FOREST
WETLAND SAND RIDGE FOREST
POND
WETLAND MAINTAINED AREA
UPLAND HERBACEOUS ASSEMBLAGE
UPLAND SHRUB - SCRUB ASSEMBLAGE
UPLAND PINE PLANTATION
UPLAND HARDWOOD FOREST
UPLAND MIXED PINE - HARDWOOD FOREST
UPLAND PINE FOREST
UPLAND SAND RIDGE FOREST
UPLAND AGRICULTURAL LAND
UPLAND NON - VEGETATED/MAINTAINED AREA
= WETLAND AREAS
= UPLAND AREAS
'PROVIDED BY PCS PHOSPHATE 8/20/07
NOTET BOUNDARY AS SHOWN INCLUDES DCM/CAMA AVOIDANCE
ACRES
2,806
2,685
0
0
4
0
54
45
276
206
472
488
211
264
22
0
0
5
74
61
40
118
14
42
245
45
2041
644
1,500 0 1,500 F..I
500 0 500 M.I.-
LREEM
ut
U,
Ol

v
29-

r j1 r
}r

1V CYPRESS RUN
UU

° ,11'4. •,
• ° .
r
"
r
SOUTH RT 33 RASE PROJECT AREA g
SOUTH RT 33 L ALTERNATVE 7.039
v SOUTH RT 33 L ALTERNATIVE - EXCAVATION UMITS
t R€OOVERA5,E CONCENTRATE = 710.576.000 70NS-
„
e '

n
11
r f
8 I LREEKSfOPEN WATER
PLAB,.,.. ,.^ TRU5- AREAS LF 0
x
„ w
.
SDlf1H CREEK GAUAJ.
PERENNIAL ST SIRE iD, IF 2
INTERT STREAM 4.02 A27 LF 0
A
2 WETLAND BRACKISH
D
EOM
MARSH
D
-
D F
O
3 WETLAND BOM
GREST
1
HERfl
A CEO ASS EMBLA
71
4 WERANG S
R
SSEMBLAGE
, , H
5 WETLAND SHRUB B - - S
SCRUB ASSEMBLAGE 31
6 WETLAND PINE PU OId I.11
7 WE NO HARDWOOD FOREST 161
B WEr LAND MIXED PINE -HARDWOOD FOREST 66
9 WETLAND PINE FOREST 46
10 WCEIANO POOO5I4 -BAY FOREST 0
T1 WETLAND SAND RIDGE FOREST 0
12 POND 0
13 WETLAND MAINTAINED AREA 0
' 19 UPLAND HERBACEOUS ASSEMBLAGE 226

4 t5 UPLAND SKRUR - SCRUB ASSEMBLAGE 67
16 UPLAND PINE PLANTA71ON. 609
17 UPLAND HARDWOOD FOREST 277
18 UPLAND MIXfO PINT - HARDWOOD FOREST 414
19 UPLA740 PINE FOREST 167
20 UPLAND SAND RIDGE FOREST 4
21 UPLAND AGRICULTURAL LAND 4578
22 UPLAND NON - VEGETATED/MAINTAINED AREA 194
WETLAND AREAS
510

UPLAND AREAS 6,529
„PRGV1pE0 RY PCS PHOSPHATE 8/20/07
NOTE' BOUNDARY AS S!4OWN INCLUDES DCM/CAW AVOIDANCE
2,200 0 2,200 Feel
500 0 500 Melers

V o
o =
V) ?' r r r r T r r r r r T Q Q Q
N N CD (D CO OO CO 00 00 00 00 CO V Z Z Z
C
C m a
O
?-0
C
Cn
- (0
E
0 4)
c
U 0 0 ro N
O Z " T r r r r Q r r r T F c[ r T
L _C C ro
C T M M (*] Z M M M M Z c`)

ro
m T
E ` •
X
_
- W
oN
O U

C ?

? ?
v? = N C
Q} ro N
-
( p N E T Q T T Q
r T
(4
? row a ro
C 0
T
Y
T
T
T
Z
T
T
T 7:
T W
Z
M tfi
O
T T
L O
?
O O N
?X3
? Q
o
m r)
w m
o
C =
0
N
0
Q) 0 , O M
•w
ro
ro M m Qa:
>
CL
_j r.. N. ro N r Y T Y Q Y Y T F r Q F F
. L L
0 Y r N N N Z N N N N Z M Y

N C a 0 L

L 0
a) = V
O
:3
9
C ?3
(? C _
N 0
t
CO 0
c (gyp C co Q) co co CO co co CO 0'>
U')
0)
co
LO
cn
- O
? T -
C
E ..
..
•
O 0)
CIA N
(0 d' M
M M
4
c? (n
CD M
CD

. R U LO N co co M N N (- ? r r r r M
E o= a
ti ? ~ U
cc o
Q
a
L
(n 0,

N
Q (D U N
co
N
to
N
V
0)
OD
O
LO M
N to
('7
V)
M
M
V'
cn
(p F t (s? 0
p LO 0) (D N (C) -,t h 65 T O

M O p C
~ ti
N ro

o
U)
a)
.p C(9 N O X w o%.

?

Q p}
(0 p]
C
C4

o
B

ro

ro

c q .
E
E
o
o
o
r --
m
L d
t

M E r.
ro N
m a)
(n ?,
m
o U N
w
n ns
i y N 3
sx
a) =
s a v
o m
? L
2 °
a M
? ro
m ro
3 _
ro
?_ ? ? 7 ? Q} E C6 Qa ? y
i ti G ? •L
O L
C6 ,
'CS C
cu N `U 0 N 9i
c '0 [C6 h R = r N g.
m (=c (moo o CL 0 ° Q - o ro o L o o _
v) ?, :. m L X m n 0
c a) 0 a) c ° ns N N +a,
M C LO
., r N
d N
T s
cn co
_
00
a- O
0- a)
(n O
In o H
(A o
a_ 0
H
d' O
H
PCS Phosphate Mine Continu ation 3 FEIS Appendix 1
Compensatory Mitigation Plan
Id) ti r U N
z r- c) co LO
J
F
a
z
w
a
H
U
a
b
+?r

a?
m
3
m
0) m f r
- Y (fl M
M N
w
N
C.1
E
E
M
4)
N
v v °?
cn
0
a
V w
?p 2
N J
U ?
R O
LO r r_ U)
E c,',j Lc.3 LU
N M N L U
a
M
7
m ^
Z c:
jp OdZ ?
` o? U O
m ?Zm---
Q 0. J J J

O
a) YC OO V OO
p 0000 r c O
r M
LO
c7
U
d1 ?
:= a a
M
W N
O
O Sp O p p O CD 0 O
ti
UD LO N
C
O

m U7

ooo? (O
©C
o M
N
m

UI ?
D
M
N? o

d r co
4
CD
a
U
?
O
0.
C
w
- N
E
o
O U p p p 0 0 0 0 0 0 0 p O
C
m L h

*'

r =
w
E=
d

Va O

O 0 0 0 o Y
O QOO p 00 G)'T z p
N M < L6 CD

O
m ? Ycc,O O)mO???NO
.--.
L V! Y N
U
IL
'G
O
a.
d C
L ?
Y

C

M
m
C
N
f0 O CD 0 0 0 f? 10 O O
L
N '0
O

? ?
t
2M
C
w

C
O
d
C
a
t-

N

o U-) Y li 7 W r N r
CO co N
NV N O cp V) Y Y O

r-'MY
U7 00 04 (0 r
N
a)
N a aT
7 O C L
C ? m a)
?ECraa?? ? a)

a)
U: a
1
L ?

cL
F va
? .
C ?+ ? y C Y U
m o y U
? J
a
o ?_
m o y
U to ? ? ?'
D m @
Q
(
.
co ?UU) °
o O
M
?= y L L O_ C M
m F
7 O_ 0 ?

w
J
IO
Q
J
a
Fm-
w
U
? m
l0
? O a
C 7 ? L
N ? 'a
? ? 19
Ua2
z N ._ N
O ?
N C U ?
? C C
U U ?
t
C1 OL v
3 0) U)
C m ?
? a) CO
-?Eo-
Q) N a7 Q
U 4 C
R -
? N
E 4 ?
RS N N 2
S U
c6
a o N
C •p C,
C N
7 ? U E
C R$ 2
m
ca.
??m¢
Q
PCS Phosphate Mine Continuation 4 FEIS Appendix I
Compensatory Mitigation Plan