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9786 , Daily Appellt project Die (rather than as a permanent structure, as under the proposed Project)," and eliminated the need for ongoingmarntenance of the weir and fusephig. The Draftdetermined that "stranding or entrapment of special- status salmonids" would be a potentially significant impact if the Project were constructed with theweir and fuse pin g, However, mitigation measures that included salmonid rosette and relocation programs Implemented In consultadon with NMFS and the Deparbr ent of Fish. and Game (Fish & Game), would make this would "reduce[] the potential significance of pit capture and salmonid entrapment" and "eliminate the need for the rescue plan:" In November 4, 2009, comments on the Draft, NM[S expressed concern that when pit veining operations resulted in ponds of standing .groundwater more than 35feet deep, anaerobic conditions would threaten the vitality of any salmonids trapped in the ponds, and the depths of the reciaimed ponds would need to be regulated to achieve suitable habitat. The County detenrimed in the EIR that Alternative 3 was "envlroureentally'supeeloel to the weir mud fuse plug, and the -NMFS supported Alternative 3 in comments 'submitted prior to Planning Commission approval of the EIR As approved, the Project included the pond - rveer connection hi lieu of the weir and fuse plug. reflected in the revised reclamadoaplan appended to the Ell Although die Draft stated that the pond- river connection would eliminate the need for a salmonid rescue program, the EIR retained a rescue program during the mining phase of the Project, The Draft set forda two options for the reclamation phase, Option A provided for construction of the pond -fiver connection unless NMFS mud Fish & Game staff determined that the "Potendal adverse - water quality within ale pit' would outweigh the connection's expected 'benefits to salmonid habitat. Option B requited Granite to continue the salmorld rescue program until NMBS and Fish &'Game said it was no longer needed." In the EIR Option B was unchanged, and Option A was amended to provide simply for construction of the pond -river connection, The deference to NMFS and risli & Game concerns over water quality In the pit was replaced in the EIR by more detailed mitigation requirements, set forth in new mitigation measure 3.4.4 -ALT 3, to address . concerns raised In NMF&s November 2009letter. SpeciftcallytbeEIRstatedthatGrmu to would limit the depth in the reclaimed ponds to 35 feet as NMFS stated would be'acceptable; or deeper if acceptable pursuant to a fiiture• water quality assessments - (b) Floodplabi Benching The term "floodplam benching" refers to a proposal by Granite in the Project application, to widen the Ackerman Creek' apt] 'Russian River channels to hnprave channel hydraulic capacity and winter rearing habitat for salmonids above what is cu red�lyavailable which, It ivrn, t to Report Monday,luly2' will increase annual winter juvonile; °orddr - survivability In the project yidittiry'. "• " ". s' "floodpiain benching" was hutorpo['Atpd :ftiO fie Daft, along with mitigation • measures' for its Impact on salmonids and riparian habitat. In its comments on the Draift; SCS Engineers for Masonite criticized the floodplain benching. i SCS wrote; "Artificial and ' unwarranted 'improvements' such as those prilptised %by` Granite serve to upset thej:eiil1iIAffi`tb ff@` fluvial system for the financial begefit'•of•bffe' r landowner, This proposed 'channel NWidenhtg' la not only unneeded under" irren0c6ridifiodst, such channel manipulations have't ,pctehflai to destabilize downstream banits and to'ah ft the position of the channel thalweg with tendalty'. negadvehnpactstodownstreamland4wners Such negative impacts may include ifidreased'pote bat t for flooding or other unanticipated; "lion- linlan! , responses that may occur : . asi a rresult'of''fhe', proposed unwarranted mechanical manlp ulation of the channel..., (1) ... [79here is little 'or no geomorpldc or other scientific justification- for such a proposal and many potential,' Itfalls," The Mendocino County Water Agency also• expressed concerns that erosion would dccur'id diefloodplam bench area. In response to these, , comments, Alternative 3 was revised lu'theiTIR' to eliminate floodplain benching from the 'Prfijeck • The EIR also observed that removal'offloe'dplab; benching "would not create any flooding Impacts relative to the baseline condition. ' .:' After close of the period for public continent' on the Draft, the California Department' of - Conservation Office of Mine Reclamaflon wrote - a lettcr' to - the County noting that floodit a rl' - was X„ and mvir rsta tie fot Aso the & Game It would adv, habitat of I discussing 75B -2 to ar - �aunea no nerenvrronmenrat was being removed "'to "avoid nrnnntnl imnactu. "" - the to'