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<br />occur as excavation taking place below existing ground surfaces. Within that mining <br />methodology overburden will be removed and stockpiled in areas higher in elevation than base <br />flood elevations and/or stockpiled at locations on company property that are below existing <br />ground elevations. EGR concludes that the proposed mining methodology on the proposed <br />expansion area will not impede flood flow, reduce flood storage volume within the flood plain or <br />increase the velocity of water flowing across the proposed expansion area. EGR further <br />concludes that the proposed mining methodology completely avoids all potential flood impacts. <br /> <br />Opponents of the application argue that the existence and operation of the aquaclude (see <br />subsequent discussion and findings regarding the aquaclude) will cause flooding on adjacent <br />residential lands because groundwater will be prevented by the aquaclude from migrating from <br />those lands to the mining site during heavy rain events. EGR has addressed that argument and <br />has demonstrated, in its rebuttal materials provided during the planning commission joint public <br />hearing and deliberation, that the movement of groundwater is not connected to surface water <br />that constitutes flooding during such events. Nonetheless, in response to the opponents' <br />argument, the applicant and EGR have provided a modified aquaclude construction that leaves <br />the top elevation of the clay-filled aquaclude one foot below the measured elevation of the <br />wetland that exists on the meandering scar, approximately six to eight feet below ground surface. <br />While continuing to impede the rate of flow of groundwater from the adjacent property to the <br />expansion area (and mining pit), the aquaclude would allow the passage of a limited amount of <br />groundwater from the adjacent property, over the clay material and into the mining area during <br />heavy rain events. That elevation will also ensure that the aquaclude has no negative impact on <br />the water level of the wetland at different times during the year. We find that EGR has provided <br />significant evidence to support it conclusion that the aquaclude will minimize potential conflicts <br />resulting from the movement of groundwater from adjacent lands to the mining area and that its <br />existence and operation will not produce flooding on adjacent lands. <br /> <br />The Eugene Planning Commission voted 3-2 that there was not a conflict due to flooding. <br /> <br />We find that approval of the application will not result in flooding conflicts with adjacent land <br />uses. <br /> <br />Groundwater <br /> <br />EGR recommends that a low permeability barrier, groundwater dam or other flow restriction of <br />the upper aquifer should be constructed, at the applicant's expense, as the excavation proceeds to <br />the west. EGR concludes that the construction of a low permeability barrier could actually result <br />in lower pumping of water, with significant benefit to the aquifer and area groundwater users. <br />That low permeability barrier has been termed the "aquaclude" by EGR and the applicant. <br /> <br />EGR recommends that excavation should begin on the east side of the expansion area and that <br />the aquaclude should proceed ahead of the excavation to the west. Construction of the aquaclude <br />should occur before excavation comes within 400 feet of its location. The aquaclude should be <br />at least 12 feet wide at the bottom and slope upward through the upper aquifer from 1:5 to 2: 1 to <br />the original ground surface. The aquaclude should be placed within the setback area to insure its <br />separation from the excavation proper and to place its outer edge as close as possible to the <br />surrounding off-site shallow aquifer. EGR also recommends that a buttress of native material be <br />left between the aquaclude and the excavation area proper. <br /> <br />EGR's ultimate conclusion is that placement of a low permeability barrier around most of the <br />excavation should result in restoring groundwater levels around the excavation pit to near pre- <br />development levels. DOGAMI has provided the applicant with its preliminary concurrence with <br />EGR's ultimate conclusion. A copy of correspondence from the agency to the applicant is <br />included with EGR's evaluation attached to the application. The correspondence states that <br />"there may actually be a slight mounding of the ground water in the shallow aquifer within close <br />proximity to the barrier thus eliminating the possibilities of drawdowns which could impact <br />supply wells within the area." <br /> <br />Exhibit A to Ordinance 20413 - 22 <br />