2014-10-23_INSPECTION - M1985029

• Permit No: M1985029
• IBM Index Class Name: Inspection
• Doc Date: 10/23/2014
• Doc Name: Recommendations to MLRB
• From: Eddie Kochman
• To: DRMS
• Email Name: MAC
• Media Type: D
• Archive: No

10/23/2014 State.co.us Executive Branch Mail-Alma Placer Mine
STATE QF Cunningham - DNR, Michael <[e-mail]>
COLO RADO
Alma Placer Mine
[e-mail] <[e-mail]> Thu, Oct 23, 2014 at 3:00 PM
To: [e-mail], [e-mail], [e-mail], [e-mail]
Cc: [e-mail], [e-mail], [e-mail], [e-mail],
mark.lam [e-mail], [e-mail]
Discussion with Michael Cunningham, Division of Reclamation Mining and Safety, October 16, 2014
Mr. Cunningham, thank you for the opportunity for further discussion regarding the October 2/3, 2014 sediment
discharge into the Middle Fork of the South Platte River from the High Mountain Mining Company (HMMC) near
Alma. It is my opinion that the discharge did negatively impact brown trout eggs that are currently incubating in
the gravel, as well as aquatic invertebrates in the reach from Alma down river to Fairplay,
including Fairplay Beach. Your comments helped clarify future actions of the Mined Land Reclamation Board.
This opinion is based on my observations of a portion of the Middle Fork that flows through land I own
approximately three miles downstream from the discharge point. While no dead fish were observed it is clear that
an increased level of fine silt was deposited. The present low flow of the Middle Fork increased the silt
deposition. If any chemicals, heavy metals (zinc,cadmium), or other toxic material were present in the
discharge, the level of impact will be more significant and long lasting.
It is my understanding that the Mined Land Reclamation Board will hold a hearing on aspects of the discharge in
Denver on November 19. Comment and evidence will only be provided by staff of the MLRB, HMMC and those
with party status. No public comment will be allowed, but written input will be part of the record. Mr. Cunningham
has included my previous correspondence and I ask that this correspondence be also included.
RECOMMENDATIONS TO MLRB FOR CONSIDERATION AT NOVEMBER 19 HEARING
A monetary fine levied by the MLRB is one possible outcome regarding the discharge. In my opinion a one
time fine will do nothing to mitigate impacts to the Middle Fork brown trout fishery, aquatic invertebrates and to
the future quality of the river fishery flowing through private and public lands. I ask that consideration be given to
requiring the following mitigation actions. (All associated costs would be the responsibility of HMMC)
Stock a number of fingerling (3-5 inch) brown trout in the Middle Fork from Alma downstream to Fairplay
Beach. These trout could either be purchased from commercial sources, or reared in hatcheries operated by
Colorado Parks and Wildlife. HMMC would be responsible for all associated costs. I estimate that 5,000
fingerling brown trout is reasonable. Colorado Parks and Wildlife staff would supervise the actual stocking.
Funding be made available to Colorado Parks and Wildlife for the protection and enhancement of aquatic habitat
at locations within the Alma State Wildlife Area (upstream of discharge site). This area is open to the public and
has a significant reach of the Middle Fork that is available for public fishing. Even though the area is above the
discharge point such, action will mitigate public values.
Funding be made available to the town of Fairplay for enhancement of the fishery in Fairplay Beach. Fairplay did
recently spend funding to dredge silt from Fairplay Beach and the discharge did have a negative impact.
Note: At this point I have seen no official report of impact from Colorado Parks and Wildlife staff, but have
received correspondence that indicates there was impact to incubating brown trout eggs and invertebrates.
recommend to the Park County Board of County Commissioners, town of Fairplay and to Colorado Parks and
Wildlife that they each provide written support for these mitigation recommendations at the November 19
hearing.
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