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Some values, statements, and assumptions were selected from different maps, some references <br />were made to the Bond Permit documentation, some from Phase 1 findings, some from none or <br />incomplete references (i.e. Renard et al.), and from Bond Release approval documentation. <br />Others items like the location of slope lengths and gradient are only referenced from an entire <br />map without specific location presented or why this specific length or slope was selected. The <br />Southfield Sediment Demonstration spreadsheet (in-depth review) adds further confusion with <br />references of values of "book, tall weeds/brush, mwh test, phase 1 findings", which are lacking <br />adequate explanations for those of us who lack training in the technical aspects of sediment <br />modeling. <br />As landowners or agents for the landowner, our primary concern is that the amount of sediment <br />being eroded from the watershed within the permit boundary may exceed the acceptable soil loss <br />standards or Non -Point Source (NPS) pollutants for water quality in Colorado. If this the case, <br />then the landowner could be responsible to resolve these problems in the near future. The stated <br />second objective (2) of the sediment report is to demonstrate that the reclaimed area does not <br />contribute excess suspended solids to streamflow as compared to a similar non -mined area. <br />There is no information within the January 13, 2016 sediment report to prove this has been <br />satisfied or that actual quantities were ever measured or modeled. I believe the sediment reports <br />provided for Bond Release Application resolves nothing and provides little or no data, <br />documentation, or information as to sediment generated within and transported from the permit <br />boundary, nor does it provide any data or information about suspended solids to streamflow <br />between reclaimed and non -mined land areas. Therefore, the conclusions in the sediment reports <br />are not supported. <br />I believe it is in our interest that I express my concerns about the erosion and sediment <br />deposition that I have observed within and outside the permit boundary and the methods and <br />conclusions of the sediment reports. The sediment reports provide no evidence that existing <br />reclaimed condition is equal or better than non -mined condition on the basis of the annual <br />sediment loss or suspended solids to streamflow. Our concern is the sediment dislodged, <br />transported, and deposited within and adjacent to the permit boundary may be exceeding some <br />water quality standard or soil loss tolerance level. The most recent copy of the sediment report <br />(January 13, 2016) has again failed to demonstrate nor has it provide any supporting evidence <br />that the conclusion was based on results of the model demonstration. Further iterations of the <br />same or similar methods and results will unlikely convince me of the predictable conclusion and <br />increase my skepticism of this process. This methodology may be all that has been required for <br />Bond Release approval in the past or for approval or removal of the loadout pond, but I believe <br />the current methods and demonstrations are inadequate and outdated, and that the demonstrations <br />presented in the sediment report have failed to satisfy EFCI's own stated objectives. <br />Thank you for your time. <br />Sincerely, <br />Daryl E. Mergen <br />